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Home My WebLink About00-06307 (, i" ',C. . . . . . .. '" "':f.i1i"'''' m '" ;Ii"'''' '" .. . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY . . . . . PENNA. STATE OF . J Ub/M If. J"'/lJ E--S Y/.-!tr NItti . NO. OfJ- h:3tJ? Ut/;'L M; ; . . . . . . . . VERSUS lYw J/J ~. JoNLg \)~ C>/1Ja n f: . . . . . . . . DECREE IN DIVORCE . . . . . o=t 10: ~r'~' ,~ , IT IS ORDERED AND . . . . . AND NOW, ~dl JUD/ih I), OMlb {!. , DEFENDANT, . . JlJlltg JON8? DECREED THAT PLAINTIFF, 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; . . IJJ I/-RI btL S~JI-h me/} ~ 11Mk'~ fJ)F A/I /JoJJL- . . . . . . J. ~ UaEL . . . . ATTEST: . . . ROTHONOTARY . . . . . . ;E '" '" '" "':f. . . . . . . :f.:f. :f.:f.:f. Of. 'f.:f. :Ii , '......~ .'W,;,;; .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . '- ~ Ii I Ii I ~~ ~ ," , ~,^^, ' 9./t/ 'Od-. tJ-/~ .Cl:,) . .' d ","~~' "",'%' C'. '~. , ~. , <,' M~~#4~ 7f~ ~ -6, ~- , 1 '"1'!'-~~'~'~ '" ,~ ,,","" "~ ~" ~ """"~--,---" _ ~ ;' -"', ,':,,,,,,~,,"<. ,"" ~ . ,V~,_ - lljiJ'~", f "'" , JUDITH A. JONES, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW DAVID CHARLES JONES, D.efendant NO. 00-6307 IN DIVORCE MARITAL SETTLEMENT AGREEMENT AGREEMENT, made this J3:th day of ll~~, 2002, between Judith A. Jones, (hereinafter called "Wife") and David Charles Jones (hereinafter called "Husband"). WITNESSETH: Diverse unhappy differences, disputes and difficulties have arisen between the parties and it is the intention of Wife and Husband to live separate and apart for the rest of their natural lives, and the parties hereto desire to settle fully and finally their respective financial and property rights and obligations as between each other, including without limitation: (1) the settling of all matters between them relating to the ownership of real and personal property; in general, the settling of any and all claims and possible claims by one against the other or against their respective estates. NOW THEREFORE, in consideration of the premises and of the mutual promises, covenants and undertakings hereinafter set forth and for other good and valuable consideration, receipt of which is hereby acknowledged by each of the parties hereto, Wife and Husband, each intending to be legally bound hereby, covenant and agree as follows: _~_~tM" . ~ ~. - -,~ ~,-,"- ( ,. . . ft\ " . I. AGREEMENT NOT PREDICATED UPON DIVORCE It is specifically understood and agreed by and between the parties hereto and each of the said parties does hereby warrant and represent to the other that the execution and delivery of this Agreement is not predicated upon nor made subject to any agreement for the institution, prosecution, defense or for the non-prosecution or non-defense of any action for divorce; provided, however, that nothing contained in this Agreement shall prevent or preclude either of the parties hereto from commencing,. instituting or prosecuting any action or actions for divorce, either absolute or otherwise, upon just, legal and proper grounds, nor to prevent either party from defending any such action which may, has been, or shall be instituted by the other party, or from making any just or proper defense thereto. The parties further agree that they will each sign the Affidavit of Consent and Waiver of Notice after the required ninety (90) day time period has elapsed when such a divorce procedure is instituted. 2. ADVICE OF COUNSEL Wife and Husband declare that each has had a full and fair opportunity to obtain independent legal advice of counsel of her and his selection; that Wife has been independently represented by Karl E. Rominger, Esquire and that Husband, aware of his right to legal representation, declares that it is his express, voluntary and knowing intention not to obtain counsel and he chooses instead to represent himself with respect to the preparation and execution of this Agreement or has consulted with an Attorney of his choosing. 2 --~' ~=. '.. .~ -- "'- ~ :' ""'.10>"'~"' . ..' 3. PERSONAL RIGHTS Wife and Husband may and shall, at all times hereafter, live separate and apart. Each shall be free from all control, restraint, interference or authority, direct or indirect, by the other in all respects as fully as if she or he were unmarried. Each may reside at such place or places as she or he may select Each may, for her or his separate use or benefit, conduct, carry on and engage in any business, occupation, profession or employment which to her or him may seem advisable. This provision shall not be taken, however, to be an admission on the part of either Wife or Husband of the lawfulness of the causes which led to, or resulted in, the continuation of their living apart. Wife and Husband shall not molest, harass, disturb or malign each other or the respective families of each other, nor compel or attempt to compel the other to cohabit or dwell by any means or in any manner whatsoever with her or him. 4. PERSONAL PROPERTY Except as otherwise provided herein, the parties acknowledge that they have heretofore divided between them, at the time of their separation, all their personal property to their mutual satisfaction, except as otherwise stated. Henceforth, each of them shall own, have and enjoy independently of any claim or right of the other all items of personal property of every kind, now and hereafter owned, or held by him or her, with full power to dispose of same as fully and effectively in all respects and for all purposes as ifhe or she were unmarried. The property to be transferred is as follows: 3 ,-- ,~'" "- _'_" r-I. _",jC "';" ,q 0' 0); I. Members First Account is to be given to Wife. 2. Langley Account is to be given to Husband in its entirety. 3. Tyndall Account is to be applied to the mortgage on the house. 4. Husband's military retirement is to be divided and split equally between the parties. Husband is to provide a one-half allotment of the current value to wife, and Husband agrees to adjust that allotment to one-half of whatever his retirement is as the government makes adjustments for cost of living and other matters. This allotment will be permanent and may not be removed, and shall at all times be one-half of Husband's retirement. Husband shall also make an additional $150.00 monthly allotment to Wife from his government retirement. Said allotment to terminate at the expiration, cancellation or cashing the life insurance policy referenced in paragraph 9. 5. Each party will keep any IRA or 40 I (k) now in their own name. 6. Husband agrees to keep Wife on Champus Insurance. 7. Certain monies are to be paid to Husband and Wife if the right-of-way to the marital home is obstructed by construction on the Home Depot project across the street, and Husband agrees to have that entire amount provided to Wife, recognjzing that it will devalue the marital residence, which Wife is to receive. 5. VEHICLES Wife shall receive the Dodge Intrepid and Husband shall receive the Jeep. Both parties agree to execute all necessary documents to transfer the title into the other party's name. The truck now in possession of the parties is to be used for a mutual benefit during the moving phase 4 h .'" 8. TAXRETURNS Husband and Wife agree to sign joint returns for the calendar year 200 I and 2002; and if the parties are entitled to any refund hereunder; Wife and Husband shall be entitled to the proceeds thereof. Should there be a tax liability, it shall further be Wife's and Husband's obligation to pay for any tax liability for 200 I and 2002. Husband further agrees that he will be responsible and hold Wife harmless for any contingent liabilities on joint income tax returns previously filed by the parties and will agree to pay any claim or expenses arising out of such returns or liabilities, unless additional liabilities are found to be attributable to misrepresentations or failures to disclose the nature and extent of Wife's income as it may appear on said previous tax returns. 9. LIFE INSURANCE Husband warrants and represents to Wife that he will transfer ownership of the life insurance policy to her and in the meantime keep her as beneficiary. Upon Wife's request, Husband will execute any document necessary to effectuate a conversion of or surrender such policies. Wife will make the payments on the life insurance policy and keep it current until the transfer of ownership can be obtained, 10. LIABILITIES Wife and Husband each covenant, warrant and represent and agree that each will now and at all times hereafter save harmless and keep the other indemnified from all debts, charges and liabilities incurred by the other prior to or after the effective date of this Agreement, except as may be otherwise provided by the terms of this Agreement. 6 ~ , ,,","" " - ~ -~ ~ . .~ "'-.",''''' II'~. - '"" li;jti'<iliIii.,...~,~,"~,~ , ,. , , fir' COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ) : SS. ) On this, the /3 d.day of 12a~ P' , 2002, before me, the subscriber, a Notary Public for the Commonwealth of Pennsylvania, residing in the County of Cumberland, personally appeared Judith Jones and in due form of law acknowledged the above Agreement to be her act and deed and desired the same to be recorded as such. ~p.~ Linda 1. Jumper, Notary Public Notarial3e:al U~a J. Jumper, Notary PlitJ!ic Carlisle 80'0. Cumberland County My CommiSSIon Expires Jt.'y 23. 2006 Member. Pennsylvania AsSOCiation Of Notaries 12 ~~ ~ - --"-"0 ~. , .. ~~JH!.,"",,,m",i;,,"-1>;--." t ,. 11 ,lit' . COMMONWEALTH OF PENNSYLVANIA ) : SS. COUNTY OF CUMBERLAND ) On this, the 13 a day of ~ subscriber, a Notary Public for the Commonwealth of Pennsylvania, residing in the County of , 2002, before me, the Cumberland, personally appeared David Jones and in due form oflaw acknowledged the above Agreement to be his act and deed and desired the same to be recorded as such. ~J~,~ Linda J JNotanaJ Seal --, Carlisle B~~~r':;"otary Pu","c I My Commissro;, E ~ rlane! County Meniiie< Pe "Pires July 23. 2000 . I1I1sYMmia AsSOciation Of No . fanes 13 , I I 'c, ~_ , .. . .L j~l U.ll!ll'~~~~m''-.,.',~~!~"~..,,,, ~~: ~ .,;, Z -< ~:(': c::: :)."0' ,., (") C c- ':'", ....) C,) 0; C) (.: ;) -~~~J -< "11 ,....:: !Ifl!1Jm~I!I~~" .",~ '9'". ~~ ,__""."' :~ r ;;~ ,-~. . _.~ ~ ~ ~'~1'~ " c ~ .4,11&1101 O_"'~"""~~~!" ""","""jw.1);Ji;q'''''''''I.', JUDITH A. JONES, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLV ANlA v. CIVIL ACTION - LAW DAVID CHARLES JONES, Defendant NO. 00-6307 IN DIVORCE 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. Grounds for divorce: irretrievable breakdown under ~ 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Affidavit of Service, September 15, 2000. 3. Date of execution of the affidavit of consent required by ~ 3301(c) or The Divorce Code: by the Plaintiff, August 13,2002; by the Defendant, August 13,2002. 4. Related claims pending: None. 5. Date Plaintiff's Waiver of Notice in ~3301(c) Divorce was filed with the Prothonotary: August 14,2002. Date Defendant's Waiver of Notice in ~3301(c) Divorce was filed with the Prothonotary: August 14, 2002. Date: August 14,2002 ~ Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, P A 17013 (717) 241-6070 Supreme Court ill No. 81924 ,~ co" '-:, '~.i, ~, - -" - 1l>"~'~"'~'1!l!~~";l\'~~~ ~~ -'''~'~''--'- . o c s: "'"0(:0 f11 fT~ Z::J::,1 ~~:" J.?,-' ~(...:"1 'M .." ~'C: ~ -<. o N "'" .- G3 o '-n :::,! i~ "'r- I' ,.::.:~ :JJ '~-:;::~) ;:;.:.:;-~ \ Ii ;:\ :6 -< .~.~ - .J,!:> r.:? \-,.0 "' ~ ' . '''' C'" ",."'" _" "'.~'1."" --,- ,,"", ._"'.'; '" ,I JUDITH A. JONES, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : NOlX> ~Y'ck TERM : IN DIVORCE DAVID CHARLES JONES, Defendant NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following Complaint, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Coutt your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. 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 BELO'i -TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA '17013 Phone: (717) 249-3166 H"~ , -,,", ,.. '- __ -->>, ", ""_"'.1'_ ,'<;-" ,_, '~~" -'"'"",,,,'. = JUDITH A. JONES, Plaintiff v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW MJ. (.. 3,:>"1 : NO. CIVIL TERM : IN DIVORCE DAVID CHARLES JONES, Defendant COMPLAINT IN DIVORCE Plaintiff, by per attorney Karl E. Rominger respectfully represents: 1. Plaintiff is Judith A. Jones, who currently resides at 1004 Holly Pike, Carlisle, P A 17013. 2. Defendant is David Charles Jones, who currently resides at 1004 Holly Pike, Carlisle, PA 17013. 3. Plaintiff and Defendant are sui juris, and both have been bona fide residents of the Commonwealth of Pennsylvania for a peri9d of more than six (6) months immediately preceding the filing of this Complaint. 4. The parties were married on the third day ofJune, 1967. 5. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. 6. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request the parties to participate in counseling. COUNT I: DIVORCE 7. The causes of action and sections of the Domestic Relations Code under which ~ -' ""' -- , " .J;..,,;,,,'"_'H_~"'_ '~--"~'o,-,_]""C" .',0. _ ^-"__,;,"__,,, ~',,,. "~' ;-_"' " ,,;,,~ Plaintiff is proceeding are: Section 3301 (a)(6). Defendant has offered such indignities to Plaintiff, the . innocent and injured spouse, as to render her condition intolerable and life burdensome. Section 3301 (a)(2). Defendant committed adultery continuously from approximately Memorial Day of 2000 to the present. . WHEREFORE, Plaintiff respectfully requests the Court to enter a Decree in Divorce, divorcing Plaintiff and Defendant. COUNT IT: REOUEST FOR EOUITABLE DISTRIBUTION OF MARITAL PROPERTY UNDER SECTION 3502 (d) OF THE DOMESTIC RELATIONS CODE 8. The prior paragraphs of this Complaint are incorporated by reference. 9. Plaintiff and Defendant have acquired property, both real and personal, during their marriage. 10. Plaintiff and Defendant have been unable to agree to an equitable distribution of said property. WHEREFORE, Plaintiff respectfully requests the Court to enter an Order equitably distributing the parties marital property pursuant to Section 3502 (d) of the Divorce Code. COUNT m: REOUEST FOR APPROVAL OF ANY SETTLEMENT AGREEMENT AND INCORPORATION THEREOF IN DIVORCE DECREE UNDER SECTIONS 3104 fa) AND 3323 (b) OF THE DOMESTIC RELATIONS CODE 11. The prior paragraphs of this Complaint are incorporated by reference. 12. The public policy of the Commonwealth of Pennsylvania encourages parties to a 'J',,'~" .~,.- . ,', ,_'''. ~_" ,,~,,"'_~"'^ _,.","C ;;,,,,/.,,,,~', , ,. ,_~~ ~- no. ':1'" marital dispute to negotiate a fair and reasonable settlement of all matters with Defendant. 13. The parties may enter into a written agreement with regard to support, alimony and property division. In the event that such an agreement is executed by the parties, Plaintiff desires that such written agreement be approved by the Court and incorporated, but not merged, in any divorce decree dissolving the marriage between the parties. WHEREFORE, if a written statement is reached between the parties prior to the time of the hearing on this Complaint, Plaintiff respectfully requ~sts that, pursuant to Section 3104 (a)(1) and (3) and 3323 (b) of the Divorce Code, the Court approve and incorporate, but not merge, such agreement in the final divorce decree. COUNT IV: NO FAULT DIVORCE 14. The prior paragraphs of this Complaint are incorporated by reference. 15. The cause of action and section of the Domestic Relations Code under which Plaintiff is proceeding are: Section 3301 (c). The marriage of the parties is irretrievably broken. After ninety (90) days have elapsed from the date ofthe filing of this Complaint, Plaintiff intends to file an Affidavit conseliting to a divorce. Plaintiff believes that Defendant may also file such and Affidavit. WHEREFORE, Plaintiff respectfully reque.sts this Court to enter a Decree in Divorce, divorcing the Plaintiff and Defendant. "~'" ' Dated:5y f / 3~? u 00 ,,--'';'- i.:...., ,;;~:, ,,-,,,. - "-." ~'i"", ~'oM',.,,'.' .",,;>;!C' ""', I""'-'-~ ~,&;:, Respectfully submitted, ~ ---- --Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ill # 81924 Attorney for William N. Treichler, Sr. , ~ """,' "-'" -,"', ,-',~ ',. " ~ . ," . JUDITH A. JONES, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLV ANlA v. : CIVIL ACTION - LAW DAVID CHARLES JONES, Defendant : NO. CIVIL TERM : IN DIVORCE I veritY that I am the petitioner and that the statements made in the foregoing Petition, Complaint in Divorce, 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:... 4111 If/; ;2oou CZIldd /j~ ~dith A. Jones "0 ,-', L;;;" ,~ O~', ',~""" "'" '~. ~" " ~" tJiOJl-I~i JUDITH A. JONES, Plaintiff v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA : CIVIL ACTION -LAW DAVID CHARLES JONES, Defendant : NO. 00 - 6307 ,CIVIL TERM Affidavit of Service COMMONWEALTH OF PENNSYLV ANlA ) : 2g ~ CO~:::::::_fua[~~-""", oopyofili, ~ .~~ Divorce, executed by the Plaintiff in the above-captioned matter, upon the Defend:!t~.' '.p~nal~Pn ~, c..> 1'i service September 15, 2000, at approximately 1:00 P.M. by handing it to the Defend t tJte 0< Defendant's residence at 1004 Holly Pike, Carlisle, Cumberland County, Pennsylvania 17013. 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: September 15, 2000 ~b.~ By: Aaron D. Rossiter doC' 'k.~I~.kk.'", ~ '~""'II;l~~"'''' ,W"'""',W"'k'''', ." '",c' .".-'" ~, ..,,, u "~ i g 0 "n \Cw.-, (f) ....j ~ :~ ,.1 - ._" M tf\ b "'" ..,"4- K ::r:::t\ ~, :;; ~5 ti! i:{" ~ ~ (.ii) ?P. .- ;;<;; - ", _"''',-",,,,,''''''Mtdb JUDITH A. JONES, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW DAVID CHARLES JONES, Defendant NO. 00-6307 IN DIVORCE AFFIDA VlT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 15, 2000. 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. Date: ~"IJ,. J.ff)~Z- ~~,t!:~ ""'mlr' 'lL !ll~lir~"~>~ "1~mq!im'l!!M~ilm"ij""1g!ili:";!'ID'W,,-,,"~!"",""""M~~1 IIiIiIi ,. '''''''''~~' -~ "~.~ - ~~, -~ ~iiiII!] 0 0 0 C f"-.) TI ~,.. "'" .---{ :--~, V t).",'! 0::; ;C': rn L;.'~ Z h,- Z t ".., C} uJ. .,. --'~ I ~'" (J ~: c, _.,-, ,,: , ~ ( :7.. .:~;~, ~,',:. " ./ C) :.,.] \''1 ).:> C :::-\ Z -p- =<' CO ~ .,~~- D I~ -- ,. ~ ,~ ;..4"",,",,,,,"~,,..,(<,"F JUDITH A. JONES, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW DAVID CHARLES JONES, Defendant NO. 00-6307 IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 3301(c) OF THE DIVORCE CODE I. I consent to the entry of a final decree of divorce without notice. 2. 1 understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if 1 do not claim them before a divorce is granted. 3. 1 understand that 1 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. 1 verifY that the statements made in this Affidavit are true and correct. 1 understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~4904, relating to unsworn falsification to authorities. Dateh/4 t1 J-- ',4 ~~ ,';':.L:',,~ J!l,~,iIittllill!l~1l00iW~___~o':;,*1;iI-_~,j'M&i~~[j"a>f"'*,,0il.l~~,,;l!iW~.J~)j-j' ~...:... .dIl-,H'li"~ . "~~~lllliilliliil () c -o~: nlr+~ 77~ 7f-' en> --/' -- ,- ~:f.' ~~ 4C -, -< ~ ~ ~". ~" '[ I I I , C) j""0 o "1"1 :r::r-. C;S ""1"; f';;; ",;T1 :,','0 , , '-"::C) .::i~~ ~J,' , "";:';' s'S -< .).:'" ~?: , , .v r);) .. '.~,- ~~ ,...... ~" ~",*~",-'O:-"": JUDITH A. JONES, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW DAVID CHARLES JONES, Defendant NO. 00-6307 IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 15,2000. 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. Date: Ill~ /)1 ~tM ~ j2uJJc~ David Jon ,Defendant b~ I i;.', ~W>Jitb..lj~-,gmj;,-m::-~1i'~~l~:"I");"~"~,,~,,",,,.i<\(l<;H!g-'--',,i\"'<ii~~iw&00.,111' ~ ie- ,,;;~t" 'I ' f;4.l ^ '1I<E~ :Iii " , ","' () C) C f"'..:;. ;s:: :n- Un] r:: ITlnl Z'Ti '::'J 2f}: 0), .;;::.' -< ",,' ~c, -0 Pc; -V' .- 20 -' :l>c c....:) c.=:) 2 .-j =< );.. CO ::xJ -< . ~ - ~-- ._,~" - i'"".o;;~\lli""",_"" JUDITH A. JONES, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW DA VlD CHARLES JONES, Defendant NO. 00-6307 IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 3301(c) OF THE DIVORCE CODE I. I consent to the entry of a final decree of divorce without notice. 2. 1 understand that 1 may lose rights concerning alimony, division of property, lawyer's fees or expenses ifl do not claim them before a divorce is granted. 3. 1 understand that I will not be divorced until a divorce decree is entered by the Court and that a copy ofthe decree will be sent to me immediately after it is filed with the Prothonotary. 1 verify that the statements made in this Affidavit are true and correct. 1 understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 94904, relating to unsworn falsification to authorities. Date: 4"t- /~ J.tl&) . j)~ ~2 ~p/ David Jones, Defe ant '_L.~ '~I~#j"~m~~;"b'h;(,P.:<~;o;.,-,,;.,J,~~"",,";'i'>iiL" < ",,~i'- ,"i~:,~~~~~ '"~'W" 1tI~~1llW'.Jm'~~" ~_._" ,~,. ,~.,~, r ,',"M ~,_ ~.~ _, _.< ~. -~ - " ~llfl (") c: s:: -o-l:O rllfTl 2":: ::;~: Z[~. (f),c- ~(~ ~E'; Pc z --{ ~ o r-v ~ 73 n -'n ;;:;:J t~: :,~] (':; ,::1 " -'q ;(~f-~ u ..-.-' -.; :lJ -< ~-,. ...1," ~ (n r -. ,-,'j',. ., ..', " "",' , :_C'",'",'.~ ",- ,----"" '" ," " , ' "" 'I I ! i , , , I I I I , JUDITH A. JONES, Petitioner : IN THE COURT OF COMM:ON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : CIVIL ACTION - LAW DAVID CHARLES JONES, Respondent : NO. 00 - 6307 CIVIL TERM Affidavit of Service COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND ) I, Aaron D. Rossiter, hereby swear that I have served a true copy of the Pennon for Exclusive Occupation of Marital Residence, with Court Order granting temporary exclusive occupancy in the Petitioner, executed by the Petitioner in the above-captioned matter, upon the Defendant by personal service September 15, 2000, at approximately 1:00 P.M. by handing it to the Respondent at the Respondent's residence at 1004 Holly Pike, Carlisle, Cumberland County, Pennsylvania 17013. 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: September 15, 2000 By: Aaron D. Rossiter ~~ ~ x-- ",,"-,,, ,,'I' _ .',,'T 'd_'~~~''''''' HI. "'",. aii "" .~" TX ",,"~o" ",_ "" ~,"~"."..", ....~ (') ~: ~ ,4C.. ~o ~(') ~'~~' , Q Q Q) m -0 Q '-I :o-~':.;3! \"'r ~Q18 ?L,t', 'c-tc) ';?~ Sl~ ~Q ~ '< (Jl -0 ;:::It., reo (.i) t;O' .~ J . -" ~--",,,,,,,' Nav 22 00 11:33a p _ 1 giol)l//~7('1' ,':;L((({! (Ji/,"" ,~", rt t f;;;)... 155 South Hanover Street Carlisi", Pennsylvania 17013 1 North Main Street Chambersburg, Pennsylvania 1 7201 717,241.6070 . 888.241,9679 . Fox: 717.241.6878 law@romingerlaw.com . www.romingerlow.com please n:ply to Carlisle office. November 22, 2000 The Honorable Edward Guido One Courthouse Square Carlisle, PA l7013 Via Fax Only: 240-6462 RE: JONES v. JONES /.-000 -1v307 Dear Judge Guido: This letter will simply t:Onfinn that the hearing scheduled for the above captioned case for November 22, 2000 at I :00 p.m. has been canceled. Thank you for your assistance in this matter. Sincerely, . / l/, , /5, ^- t(/U/ " ",/) ( A.,?' /Ii . ,....rr----L-- Karl E. Rominger, Esquire KER:ljj cc. Ms_ Judy Jones Advocacy Advice Answers -'1t. ". ",,,.,,.,.","~,OI" '.', '.,,'^ ., -- "",;",';;_--~",c'- '~" .~""\"-,<"",_,,,-. "'"~- 'i,",l'-,"~""""'""'__i.'"'' ,",' "'?-'~'''';,,~;'' --"" JUDITH A. JONES, Petitioner v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : tJ()..'(i;3() 7 : NO. - civIL TERM DAVID CHARLES JONES, Respondent Order AND NOW, this ~()~ day of s;.?f~K up~ ~gration of the Petition '1 for Exclusive Occupancy of Marital Residence, a hearing is fixed on the ~ J..IJ I day of /i)y~, at/:t.I1o'clock, L.M., at Courtroom ..5"' ,Courthouse, Oitd:Jt. Pa. Respondent is ordered to vacate the Marital Residence pending the hearing.. Karl E. Rominger, Esquire Attorney for Peititioner Bytlw~ 1::..-;; IA//vl.d E. Cu..,' J () 1. Y . ~-aD l? a;~~ David Charles Jones Respondent y I "0 ,~ .~. ..~ ........u...., , "~~, ~=~ , ~~1QlI! ~ , ~"~ , C' ,'"^~ '-,.'~ "-'~,~'" -, '.'~ ,~-'~ F1LED-OfF1CE O~ -, W '''''(l7l "'~'~-ARY \ Co' . ~",. F'''' I ,',I ~ ui '\ ' r ,'" ,,: ", -"_' ~J. 00 SEP 21 AM 8: 57 CUMBERUW COUNTY PENNSYLVANIA , ~~~~" ~, >'&,~ -::~r~"- ,',n-, c . , ", ~ '" ~. d'" '-" "<-"""' . '"" ",,~j .~ ;""1. -'0' . " , ~"., ~ :'. " >lIl!lIlIillitcw,"", JUDITH A. JONES, Petitioner v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW t>v-(.307 : NO. CIVIL TERM : IN DIVORCE DAVID CHARLES JONES, Respondent PETITION FOR EXCLUSIVE OCCUPANCY OF THE MARITAL RESIDENCE The Petition ofJudith A. Jones respectfu11y requests that: 1. The Petitioner is Judith A. Jones and Respondent is David Charles Jones who both reside at 1004 Holly Pike, Carlisle, P A 17013. 2. On or about September 14, 2000, Petitioner instituted the above captioned divorce action. 3. The parties share the marital premises at 1004 Holly Pike, Carlisle, P A 17013. 4. Since approximately March of this year, the Respondent has subjected the Petitioner to numerous acts of mental cruelty and one act of physical cruelty. The Petitioner must live in the marital residence without the Respondent because the Respondent has repeatedly and continues to communicate with his mistress through instant messages on the Internet while Petitioner is present. He has called his mistress on the telephone at least three or four times, and continues to call her to the best of Petitioner' s knowledge. He attempts to hide the calls although several have shown up on the phone bill. Further, he has full knowledge that the Petitioner is aware of his communication with her over the Internet and telephone. While flaunting the illicit relationship within the home, he expects his wife to allow ~ '-f ,i':,',~:,,=,'.,,~ "-~ ""'"""_'__"f;"""''.''._ ,;::: 0" >'''''',_~ ;~'" ""'.,,, " ""'"j,jf.\'ii,C;' him to communicate with his mistress without protest. He has repeatedly asked her to leave the computer room when he communicates with his mistress. The living room, their bedroom, and the kitchen, however, are all adjacent to the computer room. The Petitioner should not be expected to leave the room to allow the Respondent to communicate with his mistress. The Respondent not only expects her to leave when he communicates with her, but also wants Petitioner to allow him to spend one weekend a month with his mistress. He has made this specific request on at least two separate occasions. Additionally, Respondent has told Petitioner to stay off of the computer for no apparent reason. When Petitioner reminded the Respondent that the computer is her property as well as his, he threatened her with bodily harm. He raised his arms and fists at her barely restraining himself from attacking his wife in her own home over a dispute about use of the computer. The Petitioner believes that Respondent fears she may find evidence of the relationship. A poisonous atmosphere exists within the Jones home as a direct result of the Respondent's outrageous demand that the Petitioner accept his illicit relationship by allowing him to communicate with her in their home and his physical threat. He has threatened her physically in an attempt to force her to accept his shameless flaunting of an adulterous relationship. 5. Petitioner is without financial resources to move comfortably to another location. Moving would represertt an unfair burden on Petitioner. Petitioner's income is approximately $350.00 in salary plus $50.00 to $75.00 in . . '~- . '~ Ie;", ~, , L '. h' "'" 'c'"',,,-. ,.'-', '0 V",",,, , '~'Y tips a week. She could certainly not afford to live in a dwelling similar in size and quality as she is now. 6. Despite numerous requests by Petitioner to Respondent that he cease engaging in the above mentioned conduct and implicit requests that he withdraw from the marital residence, Respondent has refused to do so. WHEREFORE, Petitioner respectfu11y requests this Honorable Court to enter an Order awarding exclusive occupancy of the marital residence to Petitioner and denying Respondent access to the home. Date: 5'Y { } r L 70 tJ / By~2~ -' Attorney for Petitioner Rominger Law Offices 155 South Hanover Street Carlisle, PA 17013 J.D. No. 81924 (717) 241-6070 " , . , ",-"" . . ,,' " . ,', ~' ruDlrn A. JONES, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL V ANlA v. : CIVIL ACTION - LAW DAVID CHARLES JONES, Defendant : NO. CIVIL TERM I verifY that I am the petitioner and that the statements made in the foregoing Petition, Petition for Exclusive Occupancy of the Marital Residence, 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: /.i.,yd /Lfr 2-tJc{} ~4-~~/ J th A. Jones ""~ V'...J~-~ -L-'-. ,tl!;iI..'~"}'}J' ,. JUDITH A. JONES, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW NO. 00-6307 DAVID C. JONES Defendant IN DIVORCE ORDER OF COURT AND NOW, this 2litL~ of /YJA 'I , 2002, a hearing will be held the JJ!!...4ay of U uJ V , 2002 in Courtroom #~, at the Cumberland County Courthouse atl.E1J'clock A-m. in Carlisle, Pennsylvania, in consideration of the within II : ..J() Plaintiff's Petition for Emergency Special Relief. Distribution: EdWAted.E. C,l4d 1. / Karl E. Rominger, Esquire David C. Jones P.O. Box 60863 Harrisburg, P A 17106-0863 ~~ S/30j6:J., ...&.?r. . , . ""'"~~ ." ~.. ":',1 ....IT.0.py .,)11")' 02 i.~rY 30 tdl U: D3 ""I 'f ,":,; ,l:';' ..' ','.: [~1TV ',\)11"" '''I""",! ",Io..\,! V ..___, ,.~, ,_~ -,-,,--I I PEN;\SYLVAr,,ii,(i. ",,"I"~ _,........,~""""'~h~I!l!III"...,,"""'~,j7'il#r;:'~J%I\~ti'R',-,f.~"';pf~~.~..~ ,,1 "' - "L '-., , JUDITH A. JONES, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW NO. 00-6307 DAVID C. JONES Defendant IN DIVORCE PLAINTIFF'S PETITION FOR EMERGENCY SPECIAL RELIEF AND NOW, comes Judith A. Jones, by and through her privately retained counsel, Karl E. Rominger, Esquire and in support of her Petition for Emergency Relief avers as follows: 1. Your Petitioner filed a Divorce Complaint on September 15,2000. 2. The parties have not reached an agreement on the marital property. 3. During the pendency of the divorce Defendant has paid the first and second mortgage on the marital residence. 4. Defendant has stopped paying the mortgage on the martial residence and is using the mortgage payment as a negotiating tool in the marital property settlement. 5. Your Petitioner is not in a position to take over the payments and is in jeopardy of losing the marital property if the payments are not made by the Defendant. ~ -" ilf&d'~~:ih ,rir ~~. ' , , '-1 " . '"4\",;;.,'" , WHEREFORE, Petitioner respectfully requests that this Honorable order the Defendant to pay the first and second mortgage payments and continue paying the mortgages until the divorce is finalized. Date: May 24, 2002 Respectfully submitted, ROMINGER & BAYLEY 'l~ .." ------ Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, P A 17013 (717) 241-6070 Supreme Court ID # 81924 Attorney for Plaintiff VERIFICATION I verifY that I am the petitioner and that the statements made in the foregoing Petition 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: May 24, 2002 ~~~ / Judith A. Jone y ~~"~ -"~ , JUDITH A. JONES, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW NO. 00-6307 DAVID C. JONES Defendant IN DIVORCE CERTIFICATE OF SERVICE I, Karl E. Rominger, Esquire, attorney for Plaintiff, do hereby certify that I this day served a copy of the Plaintiffs Petition for Emergency Special Reliefupon the following by depositing same in the United States Mail, first class postage prepaid, at Carlisle, Pennsylvania, addressed as follows: David C. Jones P.O. Box 60863 Harrisburg, P A 17106-0863 .' /'/ ---- // ~-----., Karl E. Rominger, Esquire Attorney for Plaintiff Dated: May 24, 2002 , ,- "tiil;::;- ~Bi~~I\W~tlj~M~U~.'~ -''''~<'~~'';U~.>'!l1P.cl!i;"",,~f<!!;~'ill~~~~; "' ~,' ~o"~ "..~ ,~ " '.In I . ,.' " , 0 0 ,- e J'''-.) '~ <:;-, ~ -VCIl !TtfT1 J~'t --;>"--,., ,.-<: -L-.-C ' Z ,f"'- f'.) i',:j (J) ~c;: . ." ~, f~c__,: , , ".~ c:,~ ;E; (-) .-, -'1--i L'"-c-;, ,~ )>(= ~~ :~ fn!",! ?j :D --<. .(:"'" -< ~ l"f~".dI'" ~.~ ~~""""'h"1 ~,a W-"'~I1;fiJ__ Jul 22 02 10:25a p.l ~&~ LAW OFFICES lariromingerlaw.com www.romingerlaw.com 155 SOUTH HANOVER STREET CARLISLE, PENNSYLVANIA 17013 TEL: 717.241.6070 FAX: 717.241.6878 KARL E. ROMINGER, Esq. MARK F. BAYLEY, EsQ, July 22, 2002 The Honorable Edward Guido One Courthouse Square Carlisle, P Via F nly: 240-6462 JONES v. JONES NO. 00-6307 Dear . .~.. --~ .,- This letter is to request that the hearing scheduled in the above captioned ca~e for July 22, 2002 at 11 :30 a.m. be canceled and continued to the call of the parties. Counsel bas conferred with the Defendant and the parties have reached an agreement and therefore the hearing is unnecessary at this time. Thank you for your assistance in this matter. Sincerely, /? . --- Karl E. Rominger, Esquire KER:ljj cc. Judy Jones ADVOCACY - ADVICE - ANSWERS