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Home My WebLink About95-01381 (.. Q) 3 o E -7 (.. tJ :3 o E ~ ~ J - " i I i I j , I " ~~'~~~~~~~~~--*~~~-~~)'~-;;_._..~--~~'~ ~ - 8 None . . . . . . . . . . . . . . . . . . . . . . . . . , . , . . . . . . . . . . . . . . . . . . . . . . . . . . . ./. ..............., . / .........................,....,...................../.."................. n y T.h ~_ C tli .' : M ~~~ * AII~~.w~X6' E' ~I,.~~#~/. ill; ?-~m r ~, (/JL- .. .. .. ~ / 77 Prothonotnry 11 ~ ~ ~ d Y ~.____._.... ....."............ .................v.....'~ . /.-:. .~:. .:.:- .:.:. .:+:. .:;. .:.:- .:+:. .:+:. -:.:. .:.:. .:+:. .:+;. .:+:. .:+:. .:+:. .:+:. .:+:. .:+:. .:.:. .:+:. .:+:. .:+:. .:.:. .:+:. .:+:. .:+:. .:.:. .:+:. .:+:.' 8 ,'. ~ $ .'. ~ *- ~.' ~ " ~ ~ ~I ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY ~~. ~~ w ., ~ STATE OF PENNA. ~I ~ ~ ~ '.' RO,se..M(),\<J13.I:1 Plaintiff " . . . .' , . ' . . . . . , I N (I. ,.1361.........., ..1!l!!.5,... ~ '.' w '.' Vel'SllS ~ '.' John D. Mower ~ '.' !I ::r:. F p. 11 $: QJ bUt CuuV\-iy oefenClant w '.' .' .', ~ w '.' DECREE IN DIVORCE ANDNOW,...~.~....?l......... 1996.. it is ordered and decreed that ... ~~.~~ . ~?~~7. .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . '. plaintiff, and"""",... .~~~? ,~:. ~~.~:7".".........,.,..",."..,.. defendant, ~ ',' ,'~ ~ ~ (; ." ~ ?- ~ ,'~ ~ ,,' S ~ are divorced from the bonds of matrimony, The court retains jurisdiction of the following claims which have been raised of record in this action for which a final order has not yet been entered; .', ~ s ~ '.' ,', * ~ ., 8 8 ~ $ ~ 8 ~ ,', ~ $ ,,~ * ~ " ,.; ~ ~ 8 8 S .', ~ ~ ~ ." ~ .', ~ w ~;. $ .', * ~ ... ~ ~ ',' ?,lll~ bd I~ ;/la4/ t...4 tYn.:..j yJJt.J ),11,7'& 7l&*ta /H~Jb ~ JtIf i \ I i I ROSE MOWER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, : CIVIL ACTION - LAW : IN DIVORCE AND CUSTODY JOHN D, MOWER. Defendant : NO, 95-1381 CIVIL TERM PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section 3301(d)(l) of the Divorce Code, 2, The Divorce Complaint was served on John D, Mower on June 24, 1995 by United States mail. certified, restricted delivery, 3, Date of execution of the plaintiffs affidavit required by Section 3301(d) of the Divorce Code: March 16, 1995; Date of service of the plaintiffs affidavit upon the defendant: June 24, 1995, 4, Related claims pending: None, 5, John D, Mower was served with the Notice of Intention to file Praecipe to Transmit Record, a copy of which is attached, on June 17. 1996, Evelyn Mower, John's mother, served John by hand-delivering the Notice of Intention, ' ~\\(.L'v, 'C'L) ,) ~<49-LD SHANNON S, PIERGALL~I Certifi d Legal Intern FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/243-2968 717/243-3639 (") ill ~ C C1' :... , :;i!::rJ -of.) 2 ~~::! ,- I\a zc I -n r../"" :" o:l -::J -c .:.>6 .' c:c: ~ :~~ ~>. - ~;b ~~(.'.: - '-m ~) .. .., :~ ::- ,J:: .:;- .0 ...; no.. ~.. ROSE MOWER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : IN DIVORCE AND CUSTODY v, JOHN 0, MOWER, Defendant : NO, 95- I '3 S I CIVIL TERM NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court, If you wish to defend against the claims set forth in the foUowing pages, you must take prompt action, You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court, A judgment may also be entered against you for any other claim or relief requested in these papers by the plaintiff, You may lose money or property or other rights important to you, including custody or visitation of your children, When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling, A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, Carlisle, Pennsylvania, IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, Court Administrator Cumberland County Courthouse Carlisle, PA 17013 717/240-6200 The father of the child is John D. Mower, currently residing at 67 Prosper Road, Carlisle, Cumberland County, Pennsylvania 17013. He is married. 11. The relationship of the plaintiff to the child is that of mother. The plaintiff currently resides with the following persons: rBou: RelatlonshlD John Michael Mower Son 12. The relationship of defendant to the child is that of father. The defendant currently resides with the following persons: Name Relationship Robert Mower Brother 13. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth, Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 14. The best interest and permanent welfare of the child will be served by granting the relief requested because: a) Plaintiff has been primary caretaker of the child since birth; b) Plaintiff provides the child with a home with adequate moral, emotional and physical surroundings as required to meet the child's needs; c) Plaintiff is willing to accept custody of the child; d) Plaintiff continues to exercise parental duties and enjoys the love and affection of the child; e) Defendant has not indicated to plaintiff an interest in accepting custody of the child, 15, Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child has been named as parties to this action, WHEREFORE, plaintiff requests the court to grant her primary custody of the child, Date 03(/(, ( 95 ~ :1.'& -1.-11(/11 . "'. ,\0," ./ EN L, RiVERA Certified .Le,m -. & _ 1?J t~" . ~ - . , .." i-C-v' C:/' tlV1'0 THOMAS M, PLACE ROBERT E, RAINS LINDA E, FISHER Supervising Attorney THOMAS L, PEELER Staff Attorney FAMILY LAW CLINIC 45 N, Pitt Street Carlisle. PA 17013 (717) 243-2968 COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND: SS, I verify that the statements made in this Divorce Complaint are true and correct to the best of my personal knowledge and belief, I understand that false statements herein are made subject to the penalties of 18 Pa,C,S, ~4904. relating to unsworn falsification to authorities, Date: j 1/ G /if~ -I'~ ~ti2t- ROSE MOWER ". .I ,. r...~ . " ~ ~ 8 ~ b' ::I: e'l J; <:'l""1 t:.-. _ --:.L~~""T'I a") ""~:';I"~ ;O:-"!~.~~ N ;~_-, l~ ~~ ~ ~>::,,,, t." ~; :: i~,~ :3 =::, . '::"'-'111 =-= ,;.::~~ -1-, "<:.c - ~ , MAR201995./,., ROSE MOWER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE AND CUSTODY JOHN D, MOWER, Defendant : NO, 95- \ 38 I CIVIL TERM PRDER OF COURT "I....... AND NOW, this 21 'day of {\I\IIv' (,I.(' , 1995, on consideration of the attached petitioner's Affidavit, leave is granted to the petitioner to proceed in forma pauperis to the extent that she is relieved of all costs in this action, By the Court, L1~ f:? - r;G- J, I " 1i~':f, IASHS3d At~t~.jJ O'~~;.'H3:JrlnO A',U:;/iQW' ;; :1'1;, JO ~OH:F'I:', ! 56. UV sz 6 IZ uvw ROSB MOWER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PBNNSYLV ANIA : CIVIL AcrION - LAW : IN DIVORCB AND CUSTODY v. JOHN D. MOWER, Defendant : NO. 95- \ ~ ca I CIVIL TERM AFFIDAVIT SUPPORTING PETITION FOR LEAVE TO PROCEED IN FORMA PAUPERIS TO mE HONORABLE JUDGES OF SAID COURT: The Petitioner, Rose Mower, residing at 24 South Bast Steet, Carlisle, Cumberland County, Pennsylvania 17013, upon her oath deposes and says: I. I am the named plaintiff in the above titled civil cause of action and the defendant is John D. Mower. 2. This affidavit is made to inform the court as to my status of indigency and to induce the court to grant me leave to proceed in this cause as an indigent. 3. In making this affidavit, I am aware that perjury is a felony and that the punishment is a fine of not more than $3,000 or imprisonment for not more than seven years or both. 4. I do not have any money on my person, at home, or elsewhere which could be used for the expenses of this proceeding. 5. I do not own real estate, personal property, or any other assets, I am not owed any amounts of money by any person. 6. My husband, John D. Mower, presently resides at 67 Prosper Road, Carlisle, Cumberland County, Pennsylvania 17013. He is approximately 33 years old, (a) I last lived with my husband in December 1992. (b) I do not have infonnation or knowledge as to whether my husband is employed, has any money, owns an automobile, owns real estate, or has any other personal property or assets, (c) I have brought action for child support payments, 7, I have one child, John Michael Mower who was born on March 6, 1988 residing with me at 24 South East Steet, Carlisle, PA 17013, 8, I am presently unemployed because I have been unable to find work, I also have transportation problems, I last worked part-time at Eagles Club, Carlisle, PA 17013 as a hostess, 9, My social security number is 191-46-2466, 10, I have the following income: Public assistance: $316 Food Stamps: $206 TOTAL: $522 11, My monthly expenses are as follows: Rent: Food: Telephone: Electric: Trash: Cleaning Supplies: Toiletries: Laundry: Clothing: TOTAL: $0 $306 $30-40 $40-50 $12 $15 $10 $30-40 $50 $493-523 12, My husband and I have not maintained a checking account throughout our marriage, 13. I do not own an automobile, 14, I understand that I have a continuing obligation to infonn the court of improvement in my financial circumstances which would pennit me to pay the costs incurred herein, 15, I verify that the statements made in this affidavit are true and correct, I understand that Z 32L 765 069 ...e-. Receipt for . ~ Certified Mall _ No Insurance Coverage Provided .Itlr.U'.\=U Do not use for International Mail (See Reverie) ~ ;.:::jJn n 11 t;"1'" i I"! . ~l." .ott.lIP g- OO .., ! Cllfl,l~tt FH' .f. UJ S~..I Oo!I......"y r.... ... R.Sllltled Ot!hVPIY hIt! :.~..~~.,.;f,~.:,.,:-,~:~::;'.;:,~.t,)f.,~,'..'~.'~'."..'.".{ir'{~ ,-~ ',",'.;c" , , -.,;:. It.." "W"~' ~;'~~''';'''' ,. ' ','1 ' "" :'i:~.,;)~-Z:\,/~~f{~:=,::~~)J;,:~)~,t. \~~~(""",":""'c~~:".:~~,.",,':_ ',,' ,--ll' ... r.,?r M~ ,.\f'~"~ ?1lioComplole 'aiR' ~"; ," .. me..ttU' . . , " ' I .110 willi' to ,_I... ,th. ,.\'."'" i./tf4iComplole. ' '. ""; lollowlng ..nile.. .ra, en'llcri 'I'" >;.:::; ;;;,f::PttntYoui form eo thlt W. nn , ,..,- ,',' , _ 'e." t ~'_ q:.~l'8tUmtNIClfdto~," ", _', .'.-. .,' - '" " i'i tial'::'~:."" -gg,NERV or on lho bock If _0. 1, 0 A~~"'"A~~" ..'1',.....' '\. 0 W'""'__Roquod"onlho---IhoIllldo-' 2 h/''';'':':''ed O' n';' ". :,11 0 ""'1IoIum-......ohawlo_lho_w..dollvooodondlhod... . ...........u.ct . I V!ry", : . Ii. _. Conoult ootm.stor lot I..; LI3' Artlel. Addrellld to, 41, Article Numblr I' . Cmb.-~, !/.UJwe.,(LI 4b SIT J. ,/l~, ,~~ ' Irvca ypa ; , . ~ '1 ro5JJta.:-C.. 'Koa.d 0 Rogl.tlred I /J I r Ji!clrtlllod . I D., ,.s/~ III /7013 o Exp....M.1I I 7,0 te 0 I I I L I I I 8, Signature CAgan" !I.' .' ~. -.. . !'5 Form DOMESTIC R iOocombar 1991 . .u.LCII'Oll__'" ROSE MOWER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : IN DIVORCE and CUSTODY v. JOHN D. MOWER, Defendant : NO. 95-1381 CIVIL TERM NOTICE OF INTENTION TO REOUEST ENTRY OF DIVORCE DECREE TO: John D. Mower, You have been sued in an action for divorce. You have failed to answer the complaint or file a counter-affidavit to the plaintifrs affidavit. Therefore, on or after, July S, 1996, the plaintiff can request the court to enter a [mal decree in divorce. If you do not file with the prothonotary of the court an answer with your signature notarized or verified or a counter-affidavit by the above date, the court can enter a final decree in divorce. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you wilIlose forever the right to ask for economic relief, A COUNTER-AFFIDAVIT WHICH YOU MAY FILE WITH THE PROTHONOTARY OF THE COURT IS ATIACHED TO THIS NOTICE, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, Court Administrator Cumberland County Courthouse Carlisle, PA 17013 717/240-6200 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990, For infonnation about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office, AU arrangements must be made at least 72 hours prior to any hearing or business before the court, You must attend the scheduled conference or hearing, () .0 0 C <n "11 ~ <- .:;:l "Or,; c:: ~i rTlr' ,- Z" I z1;' cljO:': co '.:1 ec 2~ ~.:- -,.. ",) C.,. -- J" I .<. , - (5 ~;: ' ~. .. -, :.::-, c- ~ .s:- o<, ........ .,,, I i i " i , , , i ! ROSE MOWER, PLAINTIFF VI, JOHN D. MOWER, DEFENDANT IlIlhe Court or CommoD Plea or Cumberlalld CoUDty, PeDDl)'lvanla No.- 1381 Civil 1995 CIVIL ACTION - LAW IN DIVORCE & CUSTODY PRAECIPE TO REINSTATE Please reinstate the complaint in the above-captioned matter for Plaintiff, Rose Mower, on behalf of the Family Law Clinic. -...------------ Lawrence E. Welker To flUr:! 'i r. RtrId- z:., 'RahvJ Robert E. Ra'i ns SUpervisinll Ally Prothonotary 19 Y S- ~ I')' 4/J/j/1'1 ( /"(Iv-elrt\... Carmen L. Ri veritudenl Ally for Plaintiff > ( , I I , \ , r . I - -- --- . .... .....- -. ~ 'f , .--. . -.- -, --. 8 ...., 0 0' '11 <- r_ -.J ~t;:; r-:; ~i~ -,- ~!l, - -,e- N --...., ~./I.: . en " ,:$", --... ..- ..... "'0 ::!~ ;1.2r ::!; ".:.: ,c:3C :.; " W '.5' c );J ., 0 ~\.., -< Iv -< 0, ~, ~ ~ co f. .:J r N .!.~ ~. c :;: ~: u... 111 c' {:. co '" u"'~ C'4 'l:Z -t~-J -, "2 -, :hiJ 1== =:' :'10.. -, LJ, \.0 :5 0 c-. U ROSE MOWER, IN THE COURT OF COMMON PLEAS Plaintiff/Petitioner . CUMBERLAND COUNTY, PENNSYLVANIA . V. CIVIL ACTION-LAW IN DIVORCE AND CUSTODY JOHN D. MOWER, . . Defendant/Respondent . NO 95-1381 CIVIL TERM . MOTION TO WXTHDRAW CUSTODY COUNT FROM DXVORCE COMPLAXNT NOW COMES, the petitioner, Rose Mower, by and through her attorneys, the Family Law Clinic, and states the following: 1. Rose Mower filed a divorce complaint under S 3301(d) of the Divorce Code, with a count for custody, on June 22, 1995. 2. John Mower was served on June 17, 1996 with the Notice of xntention to Request Divorce Decree and Defendant's Counter- Affidavit. 3. Custody is not an issue at this time. 4. The granting of this motion will not result in prejudice to either party as they may still raise custody in a separate action if and when it becomes necessary. 5. Rose Mower would like to withdraw the custody count so that her divorce may be finalized. WHEREFORE, petitioner requests the Court to grant her motion to withdraw the custody count from t~e divorce comPlai~ . ~,^"v0 .5 ~~ SHANNON S. PIERGALL1~I - cer;f,fie~ Legal Intern l(tJ I, II'U/Vc.l.-t- G IL R, S ARER Staff Att rney FAMILY LAW CLINIC 45 N, Pitt Street Carlisle, PA 17013 (717) 243-2968 (717) 243-5204 JJ alP Iq~ Date VERIFICATION I verify that the statements made in this Motion to Withdraw Custody Count from Divorce Complaint are true and correct to the best of my personal knowledge and belief, I understand that false statements herein are subject to the penalties of 18 Pa,C,S. S4904, relating to unsworn falsification to authorities, Date: t., 1a.6 /9-6 , , ~ 1J}t~(,UA_ ROSE MOWER g ..0 0 C' -n -, c.... ""- :;:l --oC:J Co ~(!! :::: f';:r.J y~ N ~~ .._ c.. ~'t". C1' ~ .." ~o ::r. ha '- 'C- ~ ~Jr c~ .. ,.., -r r ~ =:> I~ :Q. ~ ~ ~ t,