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Home My WebLink About00-02488 , '"-lJ'-",-<-,, ""_ ~ ':.. t" ,-~_, _"C,_~ JO_':" h~,'l-, ,;-.- " ~ ~ k . . '" ~~a:;;;::::~8~;:,.~~!::C!;;::(:!8}',::::~8:(>::.X:::~::+:X::~::c!~::::~::C<:::_~-)::C!~:X*~}8)t:;:!::C!~:::::~>>::!~:,)8::!;;::Ke(J!"::!;;;::~!::+::!~::~!::+::!~~l}.::~~~n!::+}tr:~::+::!t:~O{*H:!::C!~fK+::!9:;~::+::*~ ~ I ~ I K ~ ~ IN THE COURT OF COMMON PLEAS ~ ~.~ . ,", ~.S . i f"j ~ ~.~ ~ N ~ ~.S ~ ~ ~.~ ~ ~ ~.~ * '",' its ~ ;..~ ~ M ;t~ ~ ~ i ~.~ i ~l . ~7~ ::~ ~ ~.~ i ~.,~ ~ t.~ i i ~., ~ No ~.~ t ,. ~~~ , ~, . ~.'< I ;,,; ~ ~ S r~'< OF CUMBERLAND COUNTY STATE OF RHONDA A. CALDERON PENNA, PLAINTIFF 00-2488 No,........................ ..................19 Versus JOSE J. CALDERON DEFENDANT DECREE IN D I V 0 R C E ~ l ~( S PM AND NOW,~.t.l> . . . . .. " JtI<. .2000, it is ordered and decreed that ... ~.~<?t:l?~. .J?:. ~!~~J?~~q~. . . . . . . . . . . . . . . . . . . . . . . " plaintiff, and. . . . . . . . . . . . .~'?~.E. .~: . .c.~~?~~<?t:l. . . . . . . . . . . . . . . . . . . . . . . . " defendant, are divorced from the bonds of matrimony. ~,' . i ~ i ~_......."" ....- ,....~..,,.,...,,,,"._i--',-' 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; THE PARTIES'S PROPERTY SETTLEMENT AGREEMENT. ~~.~~~. .N.<?':~!"I.~F!~. ~.~I. . ?OOO ................................................. , IS HEREBY INCORPORATED I BUT NOT M~~~.E;I?,. .I)',[,J;'Q. :r.lnS. P.ECREE. . . A. .COPY .................."................. . OF THE HERETO. ............wp.. J, .......-- Prothonotary i A i ~.~ ~.~ ~ ?" ~~; ~ (~ t~ ~ i ~.~ ~ ~.; . ~ ~ . ~~~ I i ~.~ ~ ~~~ ~ :"j ~ ,~r" "'~ ~ ~--~ ~ i ~.~ ,,~ ~+:~ * ~~:, ~ ~~ v:: ~ ~.; ~ i ~.~ ;.s ~ ~.s ~ ~.; ~ i ~.~ a ~.~ ~ ~.~ w ~.~ ~.; ~ ,..,; ;., ~ $ ~ ~.' ~ ~.~ ~.; ~~ ::.::.::!;:: )::.X::~::.:.-,: )::.:(:~~::.:< )::.:.:. :::-::.:.": >'::..::~,;: :;.::.:< :::.::.::~:: - "i{ ':-.::C{ -::O::C('::_( ';..X .::.::+~( :-:0::+:>:,: :".::.::( ,:..::+:~:-- '::.::+::< "'.::.::( "..::+::..,: ':'.::+::~'" , . 'd. -..._- ,. .M _ ~ fa - ~() LJo /~ - 020 . a:t " ". .. .' . t . 'i . ,;,~-, tW-~~~4~ 7l~~ ~ 1d- , > ~ ~ """"""' ~ ~!!l.. ~ '1!'" -~ ~ ""'Y"." ,_ f .,~-1,~-" -,~ ,., '_~_""c6, ;}:-; . PROPERTY SETTLEMENT AGREEMENT THIS AGREEMENT, dated the 28th day of November, 2000, by and between Jose J. Calderon, of 6754 Longparrish Court, Fayetteville, North Carolina (hereinafter, the "Husband") and Rhonda A. Calderon, 81 Appalachian Drive, Cumberland County, Pennsylvania (hereinafter, the "Wife"), who agree as follows: WITNESSETH: WHEREAS, Husband and Wife entered into a marriage on or about April 20, 1983, in Marianna, Florida; WHEREAS, the marriage between Husband and Wife has produced two (2) minor children, to wit: Javier Antonio Calderon (date of birth: 12/29/84) and Candice Calderon (date of birth: 2/20/87) (hereinafter, collectively the "minor children"); WHEREAS, differences have arisen between Husband and Wife in consequence of which they desire to live separate and apart from ea,ch other; WHEREAS, Husband filed a Complaint for Divorce on or about April 20, 2000, which is docketed in the Court of Common Pleas for Cumberland County, Pennsylvania at No. 00-2488 (Civil Term); and WHEREAS, Husband and Wife desire by means of the within Agreement to settle and determine all of their rights and obligations to one another under the Divorce Code of 1980, as amended. NOW THEREFORE, in consideration of the promises and covenants contained herein, and intending to be legally bound, it is agreed by and between the parties hereto that: 1. Separation. It shall be lawful for each party at all times hereafter to live separate and apart from each other at such place as he or she from time to time shall choose or deem fit. They shall be free from any interference, direct or indirect, by the other in all respects as fully as if they were unmarried. They shall not harass, disturb or malign each other or the respective families of each other. The foregoing provision shall not be taken as an admission on the part of either party of the lawfulness or unlawfulness of the causes leading to their living apart. ~- " 2. Entry as Part of Decree. An action seeking the dissolution of the marriage is pending in a court of competent jurisdiction. The parties hereby agree to execute the Affidavits of Consent for divorce and Waivers of Notice of Intention to Request Entry of a Divorce Decree at the earliest possible date. The parties acknowledge the availability of counseling and both parties have waived their right to counseling. It is the intention of the parties that this Agreement shall survive any action for divorce which may be instituted or prosecuted by either party and no order, judgment or decree or divorce, temporary, fmal or permanent, shall affect or modify the financial terms of this Agreement. This Agreement shall be incorporated, but not merged, in any fmal Decree in Divorce. 3. Mntual Release. Except, and only except, for all rights, agreements and obligations of whatsoever nature arising under or which may arise under this Agreement or for the breach of any part of this Agreement, Husband and Wife each do hereby mutually remise, release, quitclaim, and forever discharge the other and the estate of the other, for all time to come, and for all purposes whatsoever, of and from any and all rights, title and interest, or claim in or against the property of the other or against the estate of the other, of whatever nature and wheresoever situate, which he or she now has or at any time hereafter may have against the other, the estate of the other or any party thereof. Except, and only except, for all rights, agreements and obligations of whatsoever nature arising under or which may arise under this Agreement or for the breach of any part of this Agreement, it is the intention of Husband and Wife to give to each other by the execution of this Agreement a full, complete and general release with respect to any and all property of any kind or nature, whether real, personal or mixed, which the other now owns or may hereafter acquire. 4. Waiver of Claims under the Divorce Code of 1980, as amended, Includin2, but not limited to, Claims for Spousal Support, Alimony, A.P.L., Attorney's Fees, etc. Except as herein noted, each party absolutely and unconditionally releases the other and the estate of the other from any and all rights and obligations which either may have for past, present, and/or future obligations arising under the Divorce Code of 1980, as amended, including, but not limited to claims for support for himself or herself, spousal support, alimony pendente lite, temporary and/or permanent alimony, counsel fees or expenses from the other party. 5. Warranty of Disclosure. Husband and Wife each represent and warrant to the other ,~ that he or she has made a full and complete disclosure to the other of all assets of any nature whatsoever in which such party of every type whatsoever and all other facts relating to the subject matter of this Agreement. The parties waive their respective rights under the Divorce Code of 1980, as amended, to obtain formal valuations and appraisals and to engage in formal discovery to identify and value all property owned individually or jointly by a party. Each party has had ample opportunity to review the fmancial condition of the other and each party agrees not to challenge the instant Agreement based on an allegation of lack of sufficient disclosure of assets, debts or income. 6. Duty of Cooperation. The parties shall mutually cooperate with each other in order to carry through the terms of this Agreement. Within ten (10) days after demand therefore, the a party shall execute and deliver to the other any deeds, bills of sale, assignment, consents to change of beneficiary on insurance policies, tax returns and other documents and do or cause to be done in any other act or thing that may be necessary or desirable to the provisions and purposes of this Agreement. 7, Breach of A2reement. In the event that either party breaches any provision of this Agreement, the non-breaching party may seek to enforce this Agreement in a court oflaw or equity, and, if a breach of the Agreement is established in a court oflaw or equity, the breaching party shall pay the non-breaching party damages for said breach, if any, and all reasonable attorney's fees, court costs and expenses which are incurred by the non-breaching party in enforcing the Agreement. 8. Personal Property. Husband and Wife have previously agreed to the distribution of all items of personal property, including, but not limited to, accounts and household goods. Except as provided herein, Husband agrees that all such property in the possession of Wife shall be the sole and separate property of Wife. Except as provided herein, Wife agrees that all such property in the possession of Husband shall be the sole and separate property of Husband. Each of the parties does hereby specifically waive, release and renounce any further claims with respect to said items. However, Wife agrees to transfer any and all interest she may have in the two (2) Ford Mustang automobiles (presently stored at 1818 SeaCrest Street, Immokalee, Florida) to Husband. Husband shall be solely responsible for all costs, expenses, insurance, taxes, tags, and other responsibilities or liabilities associated with these automobiles. -'I ~ ~ ~ ""-1 9. Waiver of Right to Share in Retirement Benefits. The parties hereby waive, relinquish and release any and all claims and rights either may have or ever had, presently has, or may in the future acquire, in and to any and all retirement benefits titled in either parties' individual name, whenever acquired, including, without limitation, any and all pension and profit sharing plans, Keoughs, 401(K)'s, I.R,A.s and any and all other assets of like kind and character, and any appreciation in the value thereof, whether due to market conditions or the direct or indirect contributions or efforts of either party. 10. Marital Debts. Except as otherwise provided herein, each party agrees to assume full responsibility for any and all debts in their individual name, regardless of whether the debt(s) is/are marital or non-marital. Each party agrees to indemnify and hold the other party harmless from any liability, cost or expense, including attorneys' fees, which are incurred in connection with such debt(s). 11. Other Debts. Wife represents and warrants to Husband that since the parties' separation she has not and in the future she will not contract or incur any debt or liability for which Husband or his estate might be responsible and shall indemnifY and save Husband harmless from any and all claims or demands made against him by reason of debts or obligations incurred by her. Husband represents and warrants to Wife that since the parties' separation he has not and in the future he will not contract or incur any debt or liability for which Wife or her estate might be responsible and shall indemnify and save Wife harmless from any and all claims or demands made against her by reason of debts or obligations incurred by him. 12, Medical Insurance. Each party will be responsible for his/her own medical insurance. 13. Waivers of Claims Against Estates. Except as herein otherwise provided, each party may dispose of his or her property in any way, and each party hereby waives and relinquishes any and all rights he or she may now have or hereafter acquire, under the present or future laws of any jurisdiction, to share in the property or the estate of the other as a result of the marital relationship, including without limitation, dower, curtesy, statutory allowance, widow's allowance, right to take in intestacy, right to take against the Will of the other, and right to act as administrator - -~ or executor of the other's estate, and each will, to the request of the other, execute, acknowledge and deliver any and all instruments which may be necessary or advisable to carry into effect tlris mutual waiver and relinquishment of all such interests, rights and claims. 14. Real Property. The parties own as tenants by the entireties certain improved real property located at 6754 Longparrish Court, Fayetteville, North Carolina (hereinafter, the "real property"), which is subject to a mortgage in Husband's name. Wife agrees to relinquish, forfeit and waive any and all interest she may have in the real property, and Wife shall immediately execute a deed prepared by Husband evidencing same. If Husband decides not to sell the real property, he agrees to take all necessary steps to remove Wife's name from the deed and mortgage on the real property. From the date of the execution oftlris Agreement, Husband shall be solely responsible for all past, present and future costs, expenses or liabilities attributable andlor resulting from the real property, including but not limited to all mortgage payments, real estate taxes, water and sewer rents, gas, electric, telephone service, insUfC\llCe, repairs, and routine maintenance. Husband shall keep Wife and her successors, assigns, heirs, executors and administrators indemnified and held harmless from any liability, cost or expense which are incurred in connection with such past, present and future costs, expenses or liabilities attributable and/or resulting from the above-described real property. 15. Custody of Minor Children. The parties agree to the following with respect to the aforesaid minor children: A. Husband and Wife shall have joint legal custody of the minor children. Except in the case of an emergency, all major decisions affecting the minor childrens' growth and development, including medical treatment, education, and religion, shall be made jointly by the parties. Neither party shall, while in the presence of the minor children, make (or allow to be made) any disparaging or derogatory remarks about the other parent. It shall be the express duty of each parent to uphold the other parent as one whom the minor children should respect and love. Each parent shall be entitled to receive information concerning the minor children, including medical records, educational records and religious records. Each parent may attend medical appointments or scholastic conferences and activities. B. Wife shall have primary physical custody of the minor children. C. Husband shall have partial physical custody of the minor children at such times as the parties mutually agree. In this regard, it is expressly noted by the parties that Husband's military service requires extensive travel throughout the United States and in various foreign nations, and that an established partial custody schedule is impracticable. Should the parties not be able to agree on Husband's periods of partial custody, Husband reserves the right to seek appropriate relief in a court of competent jurisdiction. D. Husband agrees to provide or pay for all transportation necessary to exercise his periods of partial physical custody. In addition, Husband agrees to pay 50% of the transportation expenses actually incurred when the minor children visit any member of Husband's family. E. The parties shall have reasonable telephone contact with the minor children at all times. F. Husband agrees to be responsible for the full cost of medical and dental insurance for the minor children by paying for a plan(s) selected by Wife. Husband also agrees to be responsible for any medical/dental bills that are not completely paid for by insurance. G. Husband agrees to pay Wife the sum of $800.00 per month for support of the minor children until December 29,2002. After December 29,2002, Husband agrees to pay the sum of $650.00 per month for support of the minor children until February 20,2005. Child support shall be paid directly to Wife. Wife may seek an increase or decrease in child support at any time; however, Husband may not seek a decrease in child support. H. Husband agrees to pay one-half(Y2) of the cost for college tuition, room and board and related expenses for the minor childrens' college undergraduate ~. education. 16. Husband's Life Insurance. It is recognized by the parties that Husband has one or more policies of life insurance. Husband agrees to maintain these policies until his death. Husband further agrees to have the parties' minor children listed as beneficiaries on the life insurance policies so that each child, upon Husband's death, receives the sum of $75,000.00 from the life insurance policies. Husband agrees to submit a copy of the life insurance policies annually to Wife. 17. Cash Payment to Wife. In consideration for the promises contained herein, Husband agrees to pay Wife the sum of $500.00 per month for the twelve (12) month period following execution of this Agreement. The parties specifically agree that these payments do not constitute alimony, but rather, are made solely for the purpose of effectuating an equitable distribution of the marital estate. 18. Advice of Counsel. It is recognized by the parties hereto that Wife is represented by Michael A. Koranda, Esquire. It is recognized by the parties hereto that Husband is not represented by counsel, although he understands his right to be represented by an attorney of his choice. The provisions of this Agreement are fully understood by both parties and each party acknowledges that this Agreement is fair and equitable, that it is being entered into freely and voluntarily and that it is not the result of any duress or undue influence. 19. Bankruptcy. In the event that either party becomes a debtor in any bankruptcy or financial reorganization proceeding of any kind while any obligations remain to be performed by that party for the benefit of the other party pursuant to the provisions of this Agreement, the debtor- spouse hereby waives, releases and relinquishes any right to claim any exemption (whether granted under State or Federal law) to any property remaining in the debtor as a defense to any claim made pursuant hereto by the creditor-spouse, and the debtor-spouse hereby assigns, transfers, and conveys to the creditor-spouse an interest in all of the debtor's exempt property sufficient to meet all obligations to the creditor-spouse as set forth herein, including all attorney's fees and costs incurred in the enforcement of this paragraph or any other provision of this Agreement. No obligation created by this Agreement shall be discharged or dischargeable, regardless of Federal or State law to the contrary, and each party waives any and all right to assert that any obligation hereunder is .~ ~ .~ - fi discharged or dischargeable. 20. Effective A2reement. This Agreement shall bind the parties, their heirs, executors, administrators and assigns. 21. Entire A2reement. This Agreement contains the entire understanding of the parties, and there are no representations, warranties, covenants or undertakings other than those expressly set forth herein. 22. Prior A2reement. It is understood and agreed that any and all property settlement agreements which mayor have been executed prior to the date and time of this Agreement are null and void and of no effect. 23. Modification and Waiver, Any modification or waiver of any provision of this Agreement shall be effective only if made in writing executed with the same formality as this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall not be construed as a waiver of any subsequent default of the same or similar nature. 24. Governin2 Law, This Agreement shall be governed by and shall be construed in accordance with the laws of the Commonwealth of Peunsylvania. 25. Contract Interpretation. For purposes of interpretation and for the purpose of resolving any ambiguity herein, Husband and Wife agree that this Agreement was prepared jointly by the parties. < IN WITNESS WHEREOF, the parties hereto, intending to be legally bound hereby, have hereunto set their. hands and seals on the day and year first above written, WITNESS: c:1~) Cfi-h</J_ ?;;l:d./ft~ JOSE J. CALDERON RHONDA A. CALD~O~ ~ ~~J COMMONWEALTH OF PENNSYL VANIA) Notarial Seai ) ss: Mary J. Gouffer, Notary Public Silver Spring Two., Cumberland C.oun!y ) My Commission Expires Nov. 17, 2003 rV1~1t,~,,""n2}!v:""'i;:: I\s::'.o;::~allofj Of NotariSS COUNTY OF CUMBERLAND On this, the sri:.. day of -::n E L{ ffI /8 'Ee , 2000, before me, a Notary Public, personally appeared RHONDA A. CALDERON known to me to be the person whose name is subscribed to the within Property Settlement Agreement and acknowledged that he executed the same for the purposes ther,e,in contained. IN WITNESS WHEREOF, I het~unto set my hand and official seal. STATE OF ~~ ~G:"~,,, COUNTY OF ~ \.~~'\,,,,( Notary Public ) ) ss: ) On this, the ~<& <lay of ~"""~ ,2000, before me, a Notary Public, personally appeared JOSE JAVIER CALDERON, known to me to be the person whose name is subscribed to the within Property Settlement Agreement and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. Notai"y Public - --, . %, " ~? (t i;,riBERLANO COUNTY I, f\p.v-O'l \., Co.I>vb.'-' ,a Notary Public ~or $l'J.id County and, tate, do hereby certify that'" ",,\... , personally . appeared bef re me this day and acknowledged the due execution of the foregoing instrument Witness my hand and of 'cial seal, this th~~if."'" ~~ e ~:r"'O , -. "-.- Notary Pullc My commission expires: \0., ~'"'\ ~'C')4 . 1~*._WW-....,..",..IWtI~~,II!JJ:-liili!!1l~'" . , . ="'lMt<W;'1,m!L{;:l~'4.,-"~'.. -"-~ ..... ,,- ,<._? _~~ .", e, ~", '"j ',,'n,- ,.,<, ""h ,-~, - ~~ L~, .~ Q ~ -M -o,p g?P1 -n e 'Z ,.> at) :e:o kL-' YC :2.. :2 . .~h~ o o o r<~" t'''') ,- - -1C\ ~$ - ,...:> ., "T C) ~-n .--" - c:P .~ -nl,2,., ..fI\j ~~~; 9. '~il~ :o,---r\ "" 51 ~ .1.-__-'>. , '~~-----'",,--:; . . " RHONDA A. CALDERON, Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 00-2488 JOSE J. CALDERON, Defendant. Civil Action - In Divorce PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: 1. Ground for divorce: Irretrievable breakdown under ~ 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: By an Acceptance of Service dated May 8, 2000, a copy of which is attached hereby as Exhibit "A." 3. Date of execution of the affidavit of consent required by ~ 3301(c) of the Divorce Code: by Plaintiff December 5, 2000; by Defendant December 6, 2000. 4. Related claims pending: None. 5. Date Plaintiffs Waiver of Notice in ~ 3301(c) Divorce was filed with the prothonotary: December 5, 2000. Date Defendant's Waiver of Notice in ~ 3301(c) Divorce was filed with the prothono- tary: December 6, 2000. Respectfully submitted, TOMASKO & KORANDA, P,C, 219 State Street Harrisburg, P A 171 0 I Telephone No.: 717-238-1100 By;/~{!j~~ Attorney for Plaintiff LD. No. 58808 - .. . , RHONDA A. CALDERON, Plaintiff, vs. JOSE J. CALDERON, Defendant. ': '~['r , : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No. : Civil Action - In Divorc,e ACCEPTANCE OF SERVICE I, the Defendant in the above-captioned matter, accept service of the COMPLAINT UNDER SECTION 330I(c) OF THE DIVORCE CODE, and certifY that I am authorized to do so. Dated: ~'r :#1gr II ~J ~O~ J SE 1. COON EXHIBIT A '-~_ikirn. ..~.-~ """'~""'~,~ J:llifi\iillldt,il!li~" ."~ ~-~",.""'" ~_.-.c '''~>''_",~_.' _,_,,~ "~~., ", ..~. ~ -~-.~ . ~ ..........,~~.~ ~- ......60. ~~_~<""'" ,,0. ~'",,-".- ,""'- _'''~''''_~'' ~~ "" _ ~, . :.; ,. , (") = 0 ~ 0 ...,., c::I :~ -0(.0 ["'T1 ;O:-~~pl mfn " Z::!J ~~ '";'Jm :00 06 KU -0 ;;-:!-.j ..L::n ~o ::It DO 5>8 ~ Zrn 0 ~ N :;;! :0 .r;- -< ~ ~~. .~ vs. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ~;C);( ~ 00 - .;;.qpp "II I I 1 I ,I i il " il I 'I ~ I' II i! " I' II :1 II RHONDA A. CALDERON, Plaintiff, : No. JOSE 1. CALDERON, Defendant. : Civil Action - In Divorce 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, I Courthouse Square, Carlisle, Pennsylvania, 17013. 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 TillS 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 Telephone: (717) 249-3166 - , ';"" , " ,', '~ '- _.,10 .....: RHONDA A. CALDERON, Plaintiff, vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : No. ()1]. ;;L.'IPf ~ -r~ JOSE 1. CALDERON, Defendant. Civil Action - In Divorce COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE L Plaintiff is Rhonda A. Calderon, who currently resides at 106 W. First Street, Boiling Springs, Cumberland County, Pennsylvania, 17007. 2. Defendant is Jose J. Calderon, who currently resides at 6754 Longparrish Court, Fayetteville, North Carolina, 28304. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on April 20, 1983, Marianna, Florida. 5. There have been no prior actions of divorce or annulment of marriage between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the court require the parties to participate in counseling. 8. Plaintiff requests the court to enter a decree of divorce. WHEREFORE, Plaintiff prays that a Decree be entered divorcing the said Plaintiff and Defendant from the bonds of matrimony heretofore contracted between them. _...~ --, ,--' ""I I verify that the statements made in this Complaint 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 falsifications to authorities. Date: 4/.-/Y-..?CcJO ~~4f~d77 RHONDA~.CALDERON Respectfully submitted, TOMASKO & KORANDA, P.C. 219 State Street Harrisburg, PA 17101 Telephone: (717) 238-1100 By: ICHAEL A. KORANDA PA ID #58808 1_._ '"~W."'i RHONDA A. CALDERON, Plaintiff, vs. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA : No. 06 - ,;)qpp CZ u\ '( 7~ JOSE J. CALDERON, Defendant. : Civil Action - In Divorce ACCEPTANCE OF SERVICE I, the Defendant in the above-captioned matter, accept service of the COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE, and certifY that I am authorized to do so. ~~dD~e~ Dated: ~'i y#~ II 01 i i< , , I' t' """e' ',,-, ~ "' -""- , "'~-", . ." ~. '-''1,,.- -",,~ ~ 0_" ..~..---, - ~~. " ~-",-,- ~ ~ ~ !:lc\ 'J - ~ .:::, \. "'1-. ,'f- C> Q ::. "' ~.,.., ,~ J:> :r: -. (', , ~ "C " () Cl \) 0 -+-; ~ " - - ~ _ "._ _ _-.4.l",_~ ._w ~ ,..,,~ I!!':..,~~ ,-~.~" "~ ~:; . . .. RHONDA A. CALDERON, Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 00-2488 JOSE 1. CALDERON, Defendant. Civil Action - In Divorce AFFIDAVIT OF CONSENT 1. A complaint in divorce under S 3301(c) of the Divorce Code was filed on April 20,2000. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of di vorce after service of notice of intention to request entry of the decree. 4. I have been advised of the availability of marriage counseling, and understand that I may request that the Court require that my spouse and I participate in counseling. I further understand that the Court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the Court. 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. S 4904 relating to unsworn falsification to authorities. Date:/.l-..:5--0() ~ ~/ ./. ~j' ~ ~.. ~/0' RHONDA Pi.. CALDERON ,~:.&i!: " "" . lIlJ.:>""--iI1ll1l" , " .6it,bilm rlnf~"'" ~__ ,._ 0 "'" ". ,~",,-- ~~ "'." .. ~ - ,. ~- .. () 0 0 c: 0 ,1 ~ 0 ::rn::o fTl -n mrp n ,- Z__......: -nrr. Z~ ~~1 ~b CD;;> ~i"" " ~:,~:B :<: ....w. ~C :x C~C) r:: Zrn >8 0 ~ N ~ - ~ " ~ 1r '''n..~, ".' .. RHONDA A. CALDERON, Plaintiff, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 00-2488 JOSE J. CALDERON, Defendant. Civil Action - In Divorce WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 3301(c) OF THE DIVORCE CODE L 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. ,. 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. S 4904 relating to unsworn falsification to authorities. Date: //- ;5=-c;JO '~i(czM~ RHONDA . CALDERON ;",,,-,=,~ . ", >'-""=~ - ~~.~" =~ --~ "" ~"~-'IV-~g'.;illlill"" - ~""""'-i ,. "_~..L -~'""""".~ 0 c::> 0 ~ c::> -n CJ "-j ~w, rrl ,~ C"') :D ";';8 C c'JX ~z; :"'''" -........." . h20 ---"'-" -0 ~-~:B ~O :x :'7~) --0 I)? O'u >-c ~ N ');} ::0 .- -< -~, ~~ .-'.,- ., "l^_lf.~-' . ~ . - RHONDA A. CALDERON, Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs, No. 00-2488 JOSE 1. CALDERON, Defendant. Civil Action - In Divorce AFFIDAVIT OF CONSENT 1. A complaint in divorce under ~ 3301(c) of the Divorce Code was filed on April 20, 2000, 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of 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. 4. I have been advised of the availability of marriage counseling, and understand that I may request that the Court require that my spouse and I participate in counseling, I further understand that the Court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request, Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a divorce decree being handed . down '.by the Court. . . I-x~rify thllPt4e statemeIlts made,in this affidavit are true and correct, I understand ".~ ,.':, , . ." . . - ".., " ; . ."....... _. ... d.>,.. _. "" , i;~"-''''-'J'"' ' ,'-, "~'~~ ,:~' ':_, '.;':'.;;;" (-::':J6,' t/mi.fiI~:!sJllt:ertl~I)J:~he.r~in;u"e' m:adewbject to the penalties of 18 Pa. C,S, ~ 4904 relating j;." ' .. . "f, " , ~'- ,- f i ,to ,:;~<. to'Uriswomi falsificatibl1td'autlt'O'titi€s, ',' '.;r:r~~:"; , 1 ~~ \f, ' '-. <.,'-d. <'" ~GJ&.. J SE J, LDERON Date: G15~-6b" !d- ~i"_~,. 'tln;' ~'Ll!lJif~" >... j[]~"~ . - ,l",~ " h ."~ ,_~~, ~__..,~" l"e, ,- t:lJill~"" --",,,jj,,~.w.,,,.- ~ . ,. .,,,,, ,-" '-, ,....'-'-''''''''-r...'. r~~~ '"' ~ J!.. . -LI c (') 0 '7' ~ <::> 0 ..~~ -OeD M F;~ :rJ 92gg C? rc ZC "om ~r'-JO CJ:!,~ !:~~) r': -<c ~c -0 :~: ~rt )>~ :;;: ~-!(') zl.- 0 1'5 or-t'! S>c:: -.J Z; J''> ;? =< - :;J;J - -< NORTH CAROLINA CUMBERLAND COUNTY --- I, l'-f",ffJpw T. L;~Notary Public for said County and StSj,& do hereby certify that L<e.7. r &7""",.. personally appeared before me this day and acknowle~ged the due executlOll of the foregoing instrument. Witn~my hand a,(f offici~ seal, this the day ~;/#y)~, Notary Public My commission expires: ::z Hlf/I-:.l :;z.OD3 . -~ c c o~..... 1- ~.lIJ~~ ... - , " .. .. ~ RHONDA A. CALDERON, Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No, 00-2488 JOSE J, CALDERON, Defendant, Civil Action - In Divorce WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 3301(c) 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 , 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: (-, ~ 6tJ \{"" J~ GU~~ SE ALDERO ''C:IOif:>rl (;~, ,f{ ,; ;~r \!f);;. "..-",.~.p-' , ",,~ '!.; J':;i "._ ;', j;'. . ......,. > " .~..__., :.. _ -:;; .0 j. ';j i';;::>..: ~)~!.:<t , t-:L'j.::.~ '. ;?:~n ~:":V' ~>i":'i' 'I. .~nJ ~ . ,"~';1-!,; :-;.~r<? ':\"<: :""T :r'-_~(;i: '!'~'\-~ :.;rw> . . ~ ,'-;...-.' ; E i -', ,'" j-,..,,,,- ',_", ~. i':. ,; \ '" . n_... -.- ~-, , , """ -..~,.~..<--'t'i~~lI1iirIJlllJ' ~lii-l~~ ;iIi;' - .1, __ilillImlf""-~~''';,M~iII:>.- . ~ ,..... . -. .ii .. ~, = u ~_ " '<-'- ,,-,," -~~ " - 'iIffiI!~~'ri ~'~-"idJlm~""'''''''~fii- . ~ '" ,~"..... - << ., . (") 0 0 s:;; 0 -n s;: 0 --,--I -0 OJ ;r1 .;T~~ f'11rn C) Z::rJ ~~1. p:; Zr;:: ~~6 (/')"".-", ~E-5 '"'=J ',., " ~8 ::IJ: L2(!~ I'::' Srn C "'" ~ N ~~ C' ~ NORTH CAROLINA CUMBERLAND COUNTY -- I, N'l/Ift....,.J ~ /:/~5"l'a Notary Puflfie for said County and Stat.&, <10 hereby certify that J"'05A1.. :\", ~/dt'Vb,^. personally appeared before me this day and acknowledged the due execution of the foregoing instrument. Witne&: my hand BJ1 ottiC);! seal, this th, - d";;U/" Notary ubI / My commission expires: "2 Mpfclt :2a3 0,_ , - .~._~~ -- -"-- "- -