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HomeMy WebLinkAbout02-5209 MICHAEL L. JONES, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 0,;;. -,5'.l. () 9 COMPLAINT IN DIVORCE BOBBI JO JONES, Defendant NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the following 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, 1 Courthouse Square, Carlisle, PA. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS ENTERED, 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 Respectfully: FRIEDMAN & / submitted, NG, P.C. / By: Rich. d S. Friedman, Esquire 600 N. Second St., 5th FIr. P. .0. Box 984 Hatrisburg, PA 17108 (717) 236-8000 v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. P;( - 5~ ocr MICHAEL L. JONES, plaintiff BOBBI JO JONES, Defendant COMPLAINT IN DIVORCE COMPLAINT UNDER SECTION 3301(0) AND SECTION 3301(d) OF THE DIVORCE CODE 1. plaintiff is Michael L. Jones, who currently resides at 550 Salmon Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Defendant is Bobbi Jo Jones, who currently resides at 428 Herman Avenue, Lemoyne, Cumberland County, Pennsylvania 17043. 3. The parties have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on May 21, 1986, in Camp Hill, Pennsylvania. 5. Plaintiff avers that there are children of the parties under the age of eighteen (18), namely: Jessie Jones (date of birth 2/1/88) and Jenna Jones (date of birth 6/19/90) . 6. There have been no prior actions of divorce or for annulment between the parties. 7. Plaintiff has been advised that counseling is available and the plaintiff may have the right to request that the Court require the parties to participate in counseling. 8. The marriage is irretrievably broken. 9. Neither Plaintiff nor Defendant is in the military service of the United States. 10. The parties separated on March 27, 2001. WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. COUNT I - CUSTODY 11. Paragraphs 1 through 10 are incorporated herein by reference as if more fully set forth at length. 12. The Plaintiff and Defendant are the parents of two minor children, Jessie Jones and Jenna Jones. 13. Plaintiff seeks partial custody of the following children: NAME PRESENT RESIDENCE AGE 14 Jessie Jones 428 Herman Ave. Lemoyne, PA 17043 Jenna Jones 428 Herman Ave. Lemoyne, PA 17043 12 The children were not born out of wedlock. The children are presently in the custody of Defendant, who resides at 428 Herman Ave., Lemoyne, Pennsylvania 17043. During the past five (5) years, the children have resided with the following persons and at the following addresses: NAME RESIDENCE DATE Michael L. Jones and Bobbi Jo Jones 428 Herman Ave. Lemoyne, PA 17043 2/88 to 3/27/01 Bobbi Jo Jones 428 Herman Ave. Lemoyne, PA 17043 3/27/01 to present The mother of the children is Bobbi Jo Jones, currently residing at 428 Herman Ave., Lemoyne, Pennsylvania 17043. She is married. The father of the children is Michael L. Jones, currently residing at 550 Salmon Road, Mechanicsburg, Pennsylvania 17055. He is married. 14. The relationship of the Plaintiff to the children is that of Father. The Plaintiff currently resides with the following persons: NAME RELATIONSHIP Danielle Jones Friend 15. The relationship of the Defendant to the children is that of Mother. The Defendant currently resides with the following persons: NAME RELATIONSHIP Jessie Jones Daughter Jenna Jones Daughter 16. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth or any other state. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the child. 17. The best interest and permanent welfare of the children will be served by granting the relief requested because the Defendant refuses Plaintiff, the natural father, access to the children for purposes of visitation, and it is necessary to establish a scheduled court order. 18. Each parent whose parental rights to the children have not been terminated, and the person who has physical custody of the child, have been named a party to this action. There are no other parties who are known to have or claim a right to custody or visitation of the child. WHEREFORE, Plaintiff requests the Court to grant partial custody of the minor children, Jessie Jones and Jenna Jones. Respectfully submitted, Date:(JLMK-,---,;2').J ~,)- / / / ,/ FRIEDMAN & KING, Richard 600 N. econd Street pentho'se Suite P.O. Box 984 Harrisburg PA 17108 (717) 236-8000 Attorney for Plaintiff fjp:divorce\mjones.div VERIFICATION Plaintiff in the foregoing action; that I have read the foregoing I, Michael L. Jones, hereby acknowledge that I am the Complaint in Divorce; and the facts stated therein are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Dated:~d'5j~ Mi~/~" G~ - 0-' v ~ --I - ~ ~ ~ ~ ~ r """- <::-. ~ ~\ tn ~ Cr. t: c o c: :;''': ~(; (j-) -_/ . r:~i__) ~\i -'~ ...( C:..l 1'<''' \~ ,') " ;' ~ o '-~') -I ", ,::0 ., -i:1. \'i,:n co ,.:) ~-:? "J"I 0.' ','~21 t~, '..;'() '::',rn (,-::{ " '<:0 :<: MICHAEL L. JONES PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. 02-5209 CIVIL ACTION LAW BOBBI JO JONES DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Friday, November 01, 2002 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator. at 301 Market Street, Lemoyne, PA 17043 on Monday, December 09, 2002 at 8:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: Isl Melissa P. Greev.y, Esq. }V Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All 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. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ~ fpp~~ .~ Z ~7>??b>k, ~~~~~.I'W \/1!\\I~/\1.ASt\lN3d f III r(~. ""..' ,.... r'"1.', 1, ,r"11 ".""-"/Jr'lr') I\.U\~,' (,':..: - """-;""'~r IV 0<; :[ LId . '''J "0 1)_ /tUi'l C },o",i !. ! J ("~./1./1 (" C?- 7'? _// C"C7/r -II ,IAN 2 1 2003 ~. MICHAEL L. JONES, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 02-5209 CIVIL TERM v. CIVIL ACTION - LAW BOBBI JO JONES, IN CUSTODY Defendant ORDER TO RELINQUISH JURISDICTION AND NOW, this 9th day of January, 2003, the counsel for parties having requested a thirty (30) day continuance granted on November 27,2002, and the Conciliator having received no further request for the Custody Conciliation Conference to reconvene, hereby relinquishes jurisdiction of the above captioned matter. :200106 0 0 roo, ~__1 C <....:> ., S- (- :! ""Do: J;:J't cpr,., --.OJ" o<t-::'C. ,""- Le.' N (f)L,: ..' -<",::,. C) r- ,". ""r ,,-..' -0 ~t~ >-;-; C; 1"3 ~~ n~ 5~c:: ....--' -~( Z ':.0 ~;:." =< ~XJ (,,::) -< MICHAEL L. JONES, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-5209 Civil Term v. BOBBI JO JONES. COMPLAINT IN DIVORCE Defendant NOTICE TO DEFENDANT If you wish to deny any of the statements set forth in this Affidavit, you must file a counter-affidavit within twenty (20) days after this affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on or before March 27. 200 I. and have continued to live separate and apart for a period of at least two (2) years. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony. division of property. lawyer's fees or expenses if I do not claim them before a divorce is granted. I verify that the statements made on this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.P. Section 4904 relating to unsworn falsification to authorities. M~iff DATED: 10- 12.-os Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-5209 Civil Term MICHAEL L. JONES. v. BOBBI JO JONES. COMPLAINT IN DIVORCE Defendant DEFENDANT'S COUNTER-AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): (a) J do not oppose the entry of a divorce decree. (b) I oppose the entry of a divorce decree because: Check (i) (ii) or both: (i) The parties to this action have not lived separate and apart for a period of at least two years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): (a) I do not wish to make any claims for economic relief. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. (b) I wish to claim economic relief which may include alimony. division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree. the divorce decree may be entered without further notice to me. and I shall be unable thereafter to file any economic claims. I verify that the statements made in this Counter-Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATE: , Defendant NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF. YOU NEED NOT FILE THIS COUNTER-AFFIDAVIT. (..... ., C'" - "", c::;;> <'~ ~~.q . ) -=:-] o (~] -.J !'-) ~J1 -~..: ;- , MICHAEL L. JONES. Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-5209 Civil Term v. BOBBI JO JONES. COMPLAINT IN DIVORCE Defendant DEFENDANT'S COUNTER-AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): \/(a) I do not oppose the entry of a divorce decree. (b) I oppose the entry of a divorce decree because: Check (i) (ii) or both: (i) The parties to this action have not lived separate and apart for a period of at least two years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): (a) I do not wish to make any claims for economic relief. I understand that I may lose rights concerning alimony, division of property. lawyer's fees or expenses if I do not claim them before a divorce is granted. ~ (b) I wish to claim economic relief which may include alimony. division of property. lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file ail of my economic claims with the prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree. the divorce decree may be entered without further notice to me, and I shall be unable thereafter to file any economic claims. I verify that the statements made in this Counter-Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATE: /()iz, /1)) I I ~.!)L~ /" . Defendant NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF. YOU NEED NOT FILE THIS COUNTER-AFFIDAVIT. " ( , MICHAEL 1. JONES, Plaintiff /Respondent THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA v. : No: 02-5209 CIVIL TERM BOBBI JO JONES. DefendantlPetitioner CNIL ACTION - LAW IN DIVORCE PFTTTTON FOR RFT,ATFn cr,ATMS PTlRSTlANT TO PA R CPo 1920 15(h) AND NOW. comes the Defendant, Bobbi Jo Jones, pro se, and respectfully represents as follows in support of this Petition: I. The Petitioner is the Defendant above-named. 2. The Respondent is the Plaintiff above-named. 3. The Petitioner and Respondent were married on May 21, 1986. 4. Respondent had filed a Complaint for Divorce to the above caption and number in 2002. COT TNT T RRQIfRST FOR AUMONV. AT.TMONY PENDF.NTF. UTE, ANn/OR COlTNSJU. FF.RS PTJRSIJANT TO SRrTJON J702 OF THR nrvoRCF. conF 5. Paragraphs one (I) through eight (4) are incorporated herein by reference as though fully set forth. 6. The Petitioner is the dependent spouse and lacks sufficient property to provide for her reasonable means and is unable to support herself completely through appropriate employment. 7. Petitionerrequires reasonable support to adequately maintain herself in accordance with the standard ofliving established during the marriage. 8. Petitioner has hired an attorney and may need to hire an accountant. appraiser. or other expert during the pending divorce litigation and does not have the funds necessary to pay said fees. WHEREFORE. Petitioner requests this Honorable Court to enter and award counsel fees, costs. and expenses as are deemed necessary and appropriate. to enter an award of alimony pendente lite, and to enter an award of reasonable alimony upon final hearing and permanently thereafter. RESPECTFULLY SUBMITTED: ~i~ntiff 428 Herman Avenue Lemoyne. P A I 7043 Phone: (717) 761-2289 Dated: /012.1;//)) / MICHAEL L. JONES. Plaintiff /Respondent : THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : No: 02-5209 CIVIL TERM BOBBl JO JONES. DefendantJPetitioner : CIVIL ACTION - LAW : IN DIVORCE VF.RTFTC: A nON I. Bobbi Jo Jones. verify that the statements made in the foregoing Petition for Related Claims are true and correct to the best of my knowledge. information. and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: (-1<'0)" MQ~ Bobbi Jo Jouts / MICHAEL L. JONES, Plaintiff/Respondent v. BOBBI JO JONES, Defendant/Petitioner THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA : No: 02-5209 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE CRRTTFTCATR OF SFRVTCF, I, Bobbi Jo Jones, hereby certify that I am this day serving a copy of the foregoing document upon the person, and in the manner, indicated below, which service satisfies the requirements of the P A Rules of Civil Procedure by depositing a copy of the same with the United States Post Office at Lemoyne, Pennsylvania, through first class mail, prepaid, and addressed as follows: Richard S. Friedman, Esquire 600 N. Second Street, Fifth Floor P.O. Box 984 Harrisburg, PA 17108 BY: Dated: / D/~~:) Bobbi Jo Jo es, se Plaintiff 428 Herman Avenue Lemoyne, P A 17043 Phone: (717)761-2289 ~ ~ ~ \) ()I ~ -0 w P- ~~ .-\ t. ,-: ;-;-, r_j MICHAEL L. JONES, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 02-5209 Civil Term BOBBI JO JONES, COMPLAINT IN DIVORCE Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 330 1 (c) of the Divorce Code was filed on October 28, 2002. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce after service of Notice of Intention to Request Entry of the Decree. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~ 4904 relating to unsworn falsification to authorities. DATED: { { ((,4 ~- ....--1/'. ":'''T'' --() tj.) c ,-n\;. '-." ~~,~~ . ~L . -p"r ':;~, (~' 'Pc..... ";~ :~ ~ ~ ~ ~ ~ ~ ~~ :9)C{ bQ ~~;) ';} -"-) ..-0 '~;'7 ~ "'$ ~ - J.?;: ~ -..!l .-1 Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA MICHAEL L. JONES, v. NO. 02-5209 Civil Term BOBBI JO JONES, COMPLAINT IN DIVORCE Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 330HC) AND 330HD) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree of Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a Divorce is granted. 3. I understand that I will not be divorced until a Divorce Decree is entered by the Court, and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary. 4. I verify that the statements made in this Affidavit are true and correct. 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: tl/{g(Cit, , .:.... (") c:. ~:. "'0(; f11P' : ~t:." (./~~:~ ~ ~~. z. ':2 r--:l g c:T' 6 .;.c. c...> c:> -0 :% q. ~:n ~tn ") t;J 60 ~..., ~ .....rt ;>5--' '...".Q ";"-,\ 1" ~ S\ ?i5 ;;.<::, - ., t.f\ -! Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA MICHAEL L. JONES, v. NO. 02-5209 Civil Term BOBBI JO JONES, COMPLAINT IN DIVORCE Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on October 28, 2002. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce after service of Notice of Intention to Request Entry of the Decree. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~ 4904 relating to unsworn falsification to authorities. DATED: t/ I efL /O&. B (') c -, -of;~i ~.,\,~ U).~I; ..<: " ,.-.3 ~ Ie":."" ~\~;, ~ 'g c:T' t5 ....c ~ ~~ -otD '00 bO ::? -r, ,- -1\ \:)0 -;Z.'" g ~ c.n ::< (TI "" o -0 ::J.' - MICHAEL L. JONES, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY , PENNSYLVANIA v. NO. 02-5209 Civil Term BOBBI JO JONES, COMPLAINT IN DIVORCE Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 330HC) AND 3301(D) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree of Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! do not claim them before a Divorce is granted. 3. I understand that I will not be divorced until a Divorce Decree is entered by the Court, and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary. 4. I verify that the statements made in this Affidavit are true and correct. 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: / t)~ /O~ (") c ~ '"\J (\ rnr: ~:'f~ 0:'~':,:" r;...t. ~- i~ 2:' :2 ~ c;;:.> cr ':<& ~ "" o -0 ::t:. ~ ~"'11 ~~ ~.1Jd 06 ::-J -r. " _...~ t}i') ;,;- fl' (') .-\ ~ .-<. - (J"\ c:;)> """""'.'~""'"- PROPERTY SETTLEMENT AGREEMENT WHEREAS Michael Lee Jones, hereinafter referred to as "HUSBAND", and Bobbi Jo Jones, hereinafter referred to as "WIFE", arc contemplating a divorce and are living separate and apart and to furthermore arrange their obligations in anticipation of their imminent divorce. HUSBAND and WIFE have agreed as follow: The parties acknowledge that they were lawfully married on May 21, 1986, in Pennsylvania, and are currently HUSBAND and WIFE. The parties warrant to one another that they have made complete disclosure of financial matters and each has a basic understanding of the nature and extent of the community properties and community debts and their respective relative incomes. 'The parties acknowledge that they have had the opportunity to consult with attorneys or other advisors of their choice regarding their rights and duties in the event of a divorce, The HUSBAND shall assume the any debts from henceforth on in his own name or in his wife's name and hold WIFE harmless from the same, and HUSBAND further warrants there are no current outstanding debts. Neither party shall incur any further debts which may result injoimliability, In the event that either party does incur such a debt on joint credit of the parties after this agreement, they shall be solely responsible for the same and hold the other party harmless thereon. The real estate and personal property will be divided as follows: The HUSBAND shall receive the following property: Jones Maintenance Business, Trucks and equipment. Husband has already received his personal property. The WIFE shall receive the following property: The House and aU property located in at 428 Herman Avenue, Lemoyne, P A 17043 All personal property for herself and the two daughters, The 200 I Ford Mustang GT If any debts are associated with the items of property divided herein including, but not limited to, lease terms, taxes, insurance, etc" the party receiving the same shall assume the debt and hold the other party harmless thereon and will furthermore indemnify the other in the event of a collection ~ lI':';t,i1~U~ r ............._~~' . ~'......""""~"~r.,."".~:J'1",i:'i'"=~,~.'irlJ~,I'1"'''''.,,-!<,.<'!i....,=.,.~.."~"",~~.,,.",~,,;...., """,,'..~~'_._--'~'._---_._--_. -----'.. '--- attempt. Unknown tax obligations [or any past year, which may become known in the future shall be paid by the party whose incomes, credits or deductions caused the tax liability. If either party has hidden property which is community and has not been specifically divided by this agreement then said property shall be subject to distribution at a later time. The parties agree that this agreement is intended to be a final disposition of marital matters agreed upon herein. This agreement may be introduced into evidence as an exhihit and incorporated into any final Decree of Divorce. In the event of a breach of this agreement the prevailing party is entitled to attorney's fees. This agreement shall be interpreted by Pennsylvania law, Both parties will execute any and all documents necessary to carry out the purpose of this Agreement HUSBAND and WIFE acknowledge that they have two daughters together, Jessi Lee Jones and lena Jo Jones. HUSBAND and WIFE agree that the WIFE has custody of the two daughters, Jessi and Jena, HUSBAND and WIFE agree that the two daughters visit with their father. HUSBAND and WIFE agree that the child support will continue until both daughters are out of school, HUSBAN D and WIFE agree to share the college expenses for both daughters. 11lJSBAND and WIFE agree that the llUSBAND is responsible for Y:z oLdl m(~dici1!, dcnlal, or eye expenses for both daughters if \V1FE'S insurance arrangements do not cover it in fulL HUSBAND and WIFE agree that they are responsible for their own legal fees and eosts associated with an lillcontested divorce. HUSBAND agrees to pay WIFE spousal support as follows: Husband is to continue to pay the Wife support of $250 a month until Husband or Wife make changes at Domestic Relations, (tHusband agreed to pay a separate check monthly of $250 outside of Domestic Relations. ,....JHE:A,jfJGY~Z2-c. /.?1Yy . THIS AGREEMENT IS LEGALLY ENFORCEABLE SO READ IT CAREFULLY BEFORE YOU SIGN IT AND OBTAIN ANY ADVICE YOU DEEM NECESSARY -f[fl, 2(')(1 1. Dated this ACKNOWLEDGMENT STATE OF .~~;>ON>.L" COUNTY OF Gw.~~ ) )S5: ) 2 .. On the _~~~____ day of _'+ E~~._____, there aJlPeared before me, a Notary Public, a man who identified himself to me in proper form as /Y(:rC:J.JJ1EL-. ~;..E$nd who acknowledged to me th~t he signed ~regOing I' IWPERTY Sr;T!!!!ftlli~i!T_~(LR};~A1~~T t -) - ~ Not.uria! Seal --~ - _ Harold E, Robin,o", NOlary Public ~~h~ _ _ ~ (MeChal;icsnurg, Boro, Cumberland countyl _ 1 ARY PUBLIC My ComrnlsSlon l:xplres July 19, 2005 / C) ,/'.:' a ' M,;;j~bGf, h'I1J1;;';;;;;;J 112 t.;;';;:;;;'"", rXi~~':)l::;;;;;:: Dated this_L~__ day of _t-e/3 ' 2o()'i sSg"~9~.~ WIFE, --}7-'-- ~ ACKNOWLEDGMENT STATE OF tk:t~~ COUNTY OF .(., ) )ss: ) On the / I day of fi:.1$. Z c)Ot/-, there appeared before me, a Notary Public, a woman who identified herself to me in proper fonn as ~~,lb-('ymd who acknowledged to me that she signed the foregoing PROPERTY SETTLEMENTAGREEMt,NT ~c.~ Nh, TJtltY'-~LIC - 1 OIanal Seal Harold E, Robinson, Notary Public M, eCha[~IC'hUrg,. ."00. C,m"",,,d Cmoo" I My c.()mml~slOn [:xplres July 19, :wo~ Member, PemlsJ'lv8nr8 AssocEltlcn of NO\i:lnes -' n F ......, C:;t (~:',;:J C'", n il ~ :1: -r. rn.',1 f"' .. ~~I:J CJ j-;-; CJ :.~ (::) r .- '" MICHAEL L. JONES, Plaintiff v. BOBBI JO JONES, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-5209 Civil Term COMPLAINT IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN : SS: Personally appeared before me, a Notary Public, in and for said Commonwealth and County, Richard S. Friedman, Esquire, Attorney for the Plaintiff, who, being duly sworn according to law, deposes and says that a Certified copy of the Complaint in Divorce in the above-captioned matter was served upon Defendant, Bobbi Jo Jones, by a process server on November 6, 2002, as evidenced by the attached Proof of Service from the process server. /7 '/ Sworn and subscribed to before me this ~ day of ~~"" , 2006. -f)O/1~.p~ Notary Public " ,. " Richard/~< Fri~q~ire I .... _PROOF OF SERVICE e (Requesting Agent) FRIEDMAN & KI8NG, P.C. ATTORNEYS AT LAW 600 N. SECOND STREET HARRISBURG, PA 17108 (Plaintiff) MICHAEL L. JONES (Defendant) BOBBl JO JONES (Type of Document) DIVORCE COMPLAINT WITH AN ORDER OF COURT OF CUSTODY CONFERENCEE (Witness Fee) (Case No. & Jurisdiction) COURT COM PLEAS OF CUMBERLAND CTY, PA CASE 02-5209 (To Be Served On) BOl3BI JO JONES 428 HERMAN AVE LEMOYNE, PA (Accepted By) 13 c)h hi' ~-o Jo he, .5--. L( ;J:? 'f-l-p ( ryL C-t n A u'-f . l,e VV'-l":-'-{/ rLX, 10 ~ (Date Served) /lfp'6;;;< (Process Server's Report) (Time) ro .- Od flh Description: [ ]Male ~hite Skin [ ]Black Hair cf;>}fema/e [ ]Black Skin -;:HBrown Hair [ ]Brown Skin .' []Blonde Hair [ ]YeHow Skin [ ]Gray Hair . , /i [ Wed S~d [ ]Red Hair Afo.-1AfMl J' f) ;: ~'f.A;.{lmg duly sworn according to law, deposes and.t~s that he/she is process server herein named; and that the fact herein set fonh above are true and correct to the b t of t eir kno edg$ "ation and belief. <" /, ' / , r:: [ ]White Hair [ ]Balding [ ]Moustache [ ]Beard [ ]Glasses (Process Servers Name) rJ~~la'J,J jJ r<"-tkr;['j [ ] 14-20yrs [ ]21-35yrs c;MJ6-50yrs [ ]51-65yrs [ lOver 65yrs []Under 5' [ ]5'0"-5'3" ~"-5'8" [ ]5 '9"-6 '0" []Over 6' [ ]Under 100lbs [ ] 100-130lbs [ ] 131-160lbs Cfi'L61-200lbs [ lOver 200lbs / (2 LtMj , ! ',:: ';l ----'--1 ";;!~tctry !J'm:,c .,..':In County jl , :li.S'~:e~~~ 2006 ..------. . -~----- o ~ ~-(. ~-' ~ = 0-' Cl f'i'l o -0 __t.J'>> .:;:- - .' .. MICHAEL L. JONES, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. NO. 02-5209 Civil Term BOBBI JO JONES, COMPLAINT IN DIVORCE Defendant 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 3301(d)(I) of the Divorce Code. 2. Date and manner of service of the complaint: Served on November 6, 2002 by Sheriff. 3. Date of execution of the Affidavit required by Section 3301(d) of the Divorce Code: October 12, 2005. Date of filing and service of the Plaintiff's affidavit upon the Respondent: Filed on October 17, 2005 and served Defendant by Certified and regular mail. The certified mailing came back marked "unclaimed" (copy attached). However the regular mailing was not returned and deemed to have been received. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff, November 6, 2006; by Defendant, November 2, 2006 (copies attached). 4. Related claims pending: There are no related claims pending. 5. Date Plaintiff's Waiver of Notice was filed with the Prothonotary: November 30, 2006 (copy attached). Date Defendant's Waiver of Notice was filed with the Prothonotary: N~Qyember 30, 2006 (copy attached).1 ",/,,/ i / ,,/ I Richard S. Friedman, Esquire Att9rney for Plaintiff (") ~ 0 ~;:, ~? -n t:.;r" 0 f';".". C) - - --C - :;; - ~ Y>~ ~~~ ~ <;\t l' - \'=\ ~ '0 ~ '" ii' .. ". " .. ,fl ~\ ~ d t H", ,-t?' - N ...... ~ ~:~ ~~';;': j ~~' (\ t _ r>.:.(:, f - -, -t1 ~ "-/. ;;',. .,,! .-.~" ""'l!'t::!<, .. - ~ "',' ;"- ,~,tJ, ",-'Ii. r ::,~i % "'~. ~. ~ ?H \'~~\'~\' :; to.'.~ (1) ;:; r i I Cl:':"--~" ~ C.. ~ ,r I j '1~..,..:: -= (Y.. \ ~'Ji)1i I 1 I' '. ~ ,. , , ~, C\ ;;- "~ :-/' U, , ~ ~ n,~. "" 'Ei ~/~ ~ 0:::= ~ ~ g :;"--=:'''''' ~~ ;~, ~ - 'g ~ W ~ \i\ 0 \l ~ 'J> .~ ''''''' ------- -' t: -- - - -. -- - == - -. - :.- .. ;:::: ~ ~, - ':- - :.- =- r~~ ~ ~'td ~tr1~ 'Z ~ oJ tr1 ..... '-' ~ 'Z 0 >oQ '-' ';P'-~O ~tn'Z "8. ~ t; ::.- o~ Cf)O 000':, .%%~~ cOO-lc:: %-ICI>'i'" ~~g~~ rn~%o';. -Irnc%-I 0:0::0 "'~""'-I~ 0'-';;0:.0 ~rn_%:o ~?P~~~ c;J~~% c;J~ :0 rn ~~ -I ~ rn ::D - - - - - ~ :::- ::;:. ~ - ", ~ '~:O~~ ~9~~ ~ td 'N ~ ~~~~ C...o>-1ljt:? ~~~,~ ~ tr!~ >oQ >-1Q ';P'- ~~ ':J ~:d ~ '() O ...-1 C'P ;:e. . '-rI S o ~ , '-N ~",,,, h L\ ~.\.:; I ~ C) I \--} -".... ~"..." ... II MICHAEL L. JONES, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 02-5209 Civil Term BOBBI JO JONES, COMPLAINT IN DIVORCE Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on October 28, 2002. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce after service of Notice of Intention to Request Entry of the Decree. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~ 4904 relating to unsworn falsification to authorities. DATED: Ii (iRf4., !Z21//z- Michael L. Jop.es, Plaintiff o f; :g?f; :...~: ~~_._' :;.-:;:: '" = = 0... ~ a o "T1 :J!." rnp elm ?~O ''''-r) I~r, ;~~ ;.=; ,~> :XJ -< ~ Ii. ,~' c':: ?; -< w a -n -.", --~ - .. <.n -.} MICHAEL L. JONES, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 02-5209 Civil Term BOBBI JO JONES, COMPLAINT IN DIVORCE Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on October 28, 2002. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce after service of Notice of Intention to Request Entry of the Decree. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~ 4904 relating to unsworn falsification to authorities. DATED: Ii /oG/O~ n "'---' = 0 c = -n Z c.... 1:") \~r Z ::;j i!~ f 0 _f_ 11 ~, -< nl r= ,- -(1 lT1 '. (".) '..,J -r<! y -. 0 r'o--:-, r ~.:::j() .<..... I .....,~; '-, -0 i"! .Z -2J~ -(;? c=:; ~-..., " :~~ rn ~ ~;;;;. - .. :3 CJ1 ~ . , --.l -< . Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA MICHAEL L. JONES, v. NO. 02-5209 Civil Term BOBBI JO JONES, COMPLAINT IN DIVORCE Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 330HC) AND 3301(D) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree of Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! do not claim them before a Divorce is granted. 3 . I understand that I will not be divorced until a Divorce Decree is entered by the Court, and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary. 4.' I verify that the statements made in this Affidavit are true and correct. 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: t ( I Co((k , , o c Jji~; ~"'--- ~'- ~ c--~. ;'7) '. -,...." ?(~, I'--:l = = c-, ~ C3 <:: t:.., o o 11 -I :c rn:IJ r- -0 iT! :,)0 ,-') I =1 C~J -r-,-r ':5.:;u "c- ("l ofTi :J;! ;-:0 -< -0 -- --i!Yl;o )co~ ::-.:j --( CJ1 -..; f .. MICHAEL L. JONES, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. NO. 02-5209 Civil Term BOBBI JO JONES, COMPLAINT IN DIVORCE Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 3301(C) AND 3301(D) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree of Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a Divorce is granted. 3. I understand that I will not be divorced until a Divorce Decree is entered by the Court, and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary. 4. I verify that the statements made in this Affidavit are true and correct. 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: /),;2 /pc, I -L) (J t~ ~. ::RQ:; .....:.;>- ',!. ~-tj_: ell "" ~ {-; r":.--: :s ~< '" = .=:J c..~ ~ c..~ o 11 ::;:J m;::r2 ;S8 9cj -;---Tl '~J?5 arn -I ?6 -< ~.:;;.-;:::: (...) o -0 -,- -L. (}1 -.J fI! fI!fI! fI! fI! fI! fI! fI! fI! ~ ff. ff. '" Of. fI! fI! ff. Of.fI! "'ff."'ff. fl!ff. ff.ff. ff. ff. '" IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY ;f. ff. ff. Of. ff. ff. PENNA. STATE OF ff. ff. ;f. ff. MICHAEL L. JONES, No. 07. - r; 7. 0 q r.i vi 1 Tp.1"JIl Plaintiff VERSUS BOBBI JO JONES, llifendant DECREE IN DIVORCE o t.. t.(_W\ \ tf' \'l 't~ , IT IS ORDERED AND AND NOW, MIrnAEL L. Jams , PLAI NTI FF, DECREED THAT BOBBI JO JONES , DEFENDANT, AND 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; ;f. fI! fI! ;f. ;f. ;f. The attached Property SettleJrent AgreeIrent is incorporated into this llicree ff. ff. ff. ff. ff. ff. ff. ;f. ff. ff. ff. ff. ;f. ;f. ;f. ;f. ;f. ff. ;f. ;f. ;f. ff. ff. ff. ;f. "'ff.ff."'''' ff. ln Divorce. By THE COURT: PROTHONOTARY ff.fI!ff. ff. fI! Of. Of. '" "'ff.ff. "''''Of.ff.fI!''' ff.fI! ff."'~ ff. '" "'ff.ff. ff. "'''' ff.ff. "',+; '" '" ;+: ;+: ff. ff. ff. ff. '" ff. J. '" ff. Of. 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