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HomeMy WebLinkAbout00-06771 , s ~ ~ i ~.~ '-0'" ~ ~.'! ~ ~ ~ i ~.~ "".,., ~ ~.~ ~.~ ~. ! ;~ ts ~ ~~ ~ ~.~ . to,. a ~~ k~ ~ >~,; ~ ~ t~ ~ ~ ~.~ ",; .,-" .'l, _" cd ,'" ,. F, '-.l_"'~~'''~'''___d'___;'''''_''''''_C>~ "~'''; !ii;i" '. ' OF CUMBERLAND COUNTY - ~::i::.::!~~':::~>>)(:::!::.::~~-:;:!.{:[~!>>~{>::';~~:;!:+::<:::!::C~:::!:CO:1.J!::CK:1~>>;:::(:!>>::~~;::::~::C~~;::~:!::C~;;:~!:+::~;::::::':+::~;;:::,!::c~;::xc.{::::!~~;::::!>>::!;;;r*,z,!:Ci€~!::.:::4}~t,-g!::.~;;Y"e{:)~:::::~~~m::C(?'1 ~ -, ~ ~ -. . ~ w ~ ~ ~.~ .~:::~ : IN THE COURT OF COMMON PLEAS ~ ~.~ I ~~~ ~ ~.~ ~ ~) ~ ~ ~ ~.'" ;..; ~ t~ ~ ~ ~.~ ~.~ ~ t"; ~.~ ~ ~', ~l' ~ ~ i I 1":';::'>>:-'>~:';':'aJ'" STATE OF PENNA. ....);!~Y;J;P..G.,__ JONES No. ..00-.6-171... .................. Versus CHRIl>.'l':r__J:,Y:l'l~.. .r9tml>. DECREE IN D I V 0 R C E _'/~ ,,u - LI .::r '::" ~J> '''''. J hJ.' ,~ ). 7 -""O/'t' d d d AND NOW, ........... q.........,..... ,f/I'U ......, I IS or ere an decreed that ... Oay.lD. G... .JONES . . . . . . . . , . . . . . . . . . . . . . . . . . . . " plaintiff, and............ CHRIS!!!:I .L~NN ..JONES.....,................., defendant, 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; . .TH& .MARJ/l'AL. &ETTL&MEN<[,. 'SIGNED '0N' ''PHE' 'c6TH' DAY' OF . SEPTEMBER . :2000 . . SlIALL. BE. .INCORPORATED. INTO. :r.HE. DIVORCE .DECREli:.. . . . . . . . . . . . . . . . . . By Attest: u.uma Prothonotary ~.~ , ~'S , ~.~ ~ ~ ;"s ~ . ~.~ s ~ ~~~ ~ ~ ~';i ~ t,J a ~.~ ~ I ~';i ~ ~-:~ ~ i:l ~ a ~.~ ~~~ ~.~ ~ ~~:~, ~ i ~.I! ~.~ . ;:~ ~ ~ ~ ~.~ .,.' ~ ~.,~ ~ ... ~ ~.~ ~ ~.~ _n.. J. ~ '.~ ~ ;0, ~ ~ '.' ~ ~.~ ~ ~... ~ ~----- ~ ::.::+}:::x:+::< ::.::.::.-_ :::.:;:",;.{ :::~::.::'-::>'>>::':. )::.:::< -:-':::"::<::":.::< )::+;.:: - '" ; i~,,,.,......~_" " .". .~ "-1 - ~ "." ''>~ ~ , J~'" '" 0/-;;;';;01 &/ (~/,,~,..w'~ ail ~~# CJ I -;25' d ~~ ,?~; ~. '"P - , , - ~_""_.Jif~!l'~~~~,,","'''.l'''\'!'''''''?~ "J',:~,_~ _, ,,"." '"'~:>",J ". i_I -i:<. ",~ --~, '. SEPARATION AND PROPERTY SETTLEMRNT AGRRRMRNT OF DAVID G. JONE..l;l AND CHRISTI LYNN JONES TIllS AGREEMENT, made this U ~ ,day of ~-k-.bt..,... , 2000, by and between David G. Jones, hereinafter referred to as "Husband", and Christi Lynn Jones, hereinafter referred to as "Wife". WITNESSETH: WHEREAS, Husband and Wife were lawfully married on 22nd day of May 1986; and WHEREAS, certain differences have arisen between the parties as a result of which they have separated and now live separate and apart from one another, and are desirous, therefore, of entering into an agreement which will provide for support, distribute their marital property, and will provide for their mutual responsibilities and rights growing out of the marriage relationship; and WHEREAS, the parties hereto, after being properly advised, have come to the following agreement. NOW, THEREFORE, in consideration of the above recitals. and the following covenants and promises mutually made and mutually to be kept, the parties heretofore, intending to be legally bound and . to legally bind their heirs successors and assigns thereby, covenant, promise and agree as follows: 1. SEPARATION: It shall be lawful for each party at all times hereafter to live separate and apart from the other at such place or places as he or she may from time to time choose or deem fit. 2. INTERFERENCE: Each party shal1 be free from interference, authority and contact by the other as fully as if he or she 1 ~.. ,'f~ "-"<,.', :"l .1 ~ I, ,--I ~~ i:i>'_ ~~<ru~~ti '. was single and unmarried, except as may be necessary to carry out the provisions of this Agreement. Neither party shall molest the other nor attempt to endeavor to molest the other, nor compet the other to cohabit with the other, nor in any way harass or malign the other, nor in any way interfere with the peaceful existence, separate and apart from the other in all respects as if he or she were single and unmarried 3. WIFE'S DEBTS: Wife represents and warrants to Husband that since their 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 and demands made against him by reasons of debts or obligations incurred by her. 4. HUSBAND'S DEBTS: Husband represents and warrants to Wife that since their 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 and demands made against her by reasons of debts or obligations incurred by him. 5. OUTSTANDING JOINT DEBTS: Husband and Wife agree that they have no outstanding debts and obligations of the Husband and Wife incurred prior to the signing of this Agreement that are not otherwise specifically addressed by provision of this Agreement. In the event that either party contracted or incurred any debts since the date of separation, any party who incurred said debt shall be responsible for the payment thereof regardless of the name in which the account may have been charged. 6. MUTUAL RELEASE: Subject to the provisions of this Agreement, each party waives his or her right to alimony and any further distribution of property inasmuch as the parties hereto agree that this Agreement provides for an 2 1f ~WXk - ill' ~~ ~, . -I ,,~ - . ~ . -Wi:, equitable distribution of their marital property in accordance with the Divorce Code of 1980, as amended. Subject to the provisions of this Agreement, each party has released and discharged, and by this Agreement does for himself or herself, and his or her heirs, legal representatives, executors, administrators and assigns, release and discharge the other of and from all causes of action, claims, rights or demands whatsoever in law or equity, which either of the parties ever had or now has against the other, except any or all cause or causes of action for divorce and except in any or all causes of action for breach of any provisions of this Agreement. Each party also waives his or her right to request marital counseling pursuant to Section 202 of the Divorce Code. 7. EOUITABLE DISTRIBUTION OF MARITAL PROPERTY: The parties have attempted to distribute their marital property in a manner which conforms to the criteria set forth in Section 401 of the Pennsylvania Divorce Code, and taking into account the following considerations: the length of the marriage; the age, health, station, amount and sources of income, vocational skills, employability, estate, liabilities and needs of each of the parties; the contribution of each party to the education, training or increased earning power of the other party; the opportunity of each party for future acquisitions of capital assets and income; the sources of income of both parties' including but not limited to medical, retirement, insurance or other benefits; the contribution or dissipation of each party in the acquisition, preservation, depreciation or appreciation of the marital property, including the contribution of each spouse as a homemaker; the value of the property set apart to each party; the standard of living of the parties established during the marriage; and the economic circumstances of each party at the time the division of property is to become effective. The division of existing marital property is not intended by the parties to constitute in any way a sale or exchange of assets, funds or other property not constituting marital property. The division of property under this Agreement shall be in full satisfaction of all marital rights of the parties. 3 ~ (iY4f he I, ~. -Ck~, _ . ~_"';'~;;;l " A. DISTRIBUTION OF PERSONAL PROPERTY The parties hereto mutually agree that they have effected a satisfactory division of the furniture, household furnishings, appliances, and other household personal property between them, and they mutually agree that each party shall from and after the date hereof be the sole and separate owner of all such tangible personal property presently in his or her possession. Except as otherwise provided by the terms of this Agreement, the parties hereto have divided between themselves, to their mutual satisfaction, all items of tangible and intangible marital property. Neither party shall make any claim to any such items of marital property of either party, which are now in the possession and/or under the control of the other. Should it become necessary, the parties each agree to sign, upon request, any titles or documents necessary to give effect to this paragraph. Property shall be deemed to be in the possession or under the control of either party if, in the case of tangible personal property, the item is physically in the possession or control of the party at the time of the signing of this Agreement and, in the case of intangible personal property, if any physical or written evidence of joint ownership, such as passbook, checkbook, policy or certificate of insurance or other similar writing is in the possession or control of the party. Husband and Wife shall each be deemed to be in the possession and control of his or her own individual pension or other employee benefit plans or retirement benefits of any nature with the exception of Social Security benefits to which either party may have vested or contingent right or interest at the time of the signing of this Agreement, and neither will make any claim against the other for any interest is such benefits. From and after the date of the signing of this Agreement, both parties shall have complete freedom of disposition as to hislher separate property and any property which is in their possession or control pursuant to this Agreement and may mortgage, sell, grant, convey, or otherwise encumber or dispose of such property, whether real of personal, whether such property was acquired before, during or after the marriage, and neither Husband nor Wife need join in, consent to, or acknowledge any deed, mortgage, or other instrument of the other pertaining to such disposition of property. 4 ~g ~Qg "' ,I - J 1_. ,;;;;0_ ~M!'>r" '. -" ". 8. REAL PROPERTY Husband and Wife are the legal and equitable owners of a three bedroom Cape Cod home located at 2503 Mallard Way, Mechanicsburg, PA. 17055. Husband hereby agrees to allow Wife and Children to occupy the Marital Residence exclusively. Wife covenants that she shall place the home for sale on the open market within a one (1) year period and no later than the expiration of a one (1) year period and shall make every reasonable effort to sell the home and during which period, Husband also agrees to pay one- half 112 of the monthly mortgage payment as well as one-half 1/2 of all of the utilities, until the home is sold on the open market. In addition Husband agrees to pay one-half V2 of the cost necessary to sell the home. Upon the sale of the home Husband and Wife shall divide the profits, after all outstanding mortgages and applicable expenses related to the home have been paid with 50 % percent of the profit to be received by Husband and 50% percent of profit to be received by Wife. 9.. MOTOR VEffiCLES: The parties hereby agree that the party in whose possession there remains a Motor Vehicle shall continue to own this motor vehicle free and clear from any claims legal or equitable that the other party may assert. To the extent the vehicle in possession of either or both parties in is both parties names then the party relinquishing ownership shall sign title of said vehicle over into the other spouses name. Husband shall receive the 1999 Ford F-150, truck and shall assume sole responsibility for the payments related thereto and shall hold harmless and indemnify Wife in the event payments are not being made. Wife sha11 retain sole tegal and equitable ownership of the 1993 Toyota Previa Van. All existing automobile insurance policies that are jointly held sha11 be transferred to the respective party's individual names and each will assume sole fmancial responsibility for payment to the same. 5 ~ <mv -' .1 .1.-, -~ .-. .",-, - :ll1lll11lht<,l\!:~' " . '. 10. SUPPORT: Both parties waive, relinquish, and forever release any claims to, or the right to collect spousal support, alimony, alimony pendente lite, costs and expenses and attorney's fees or any other form of support except as specifically provided for within this agreement. 11. ClllLD SUPPORT Husband hereby covenants that he will pay to Wife to be used for the support of their children the sum of $1,253.00 (dollars) per month and in addition thereto Husband shall pay one half '/2 of child care costs, as well as one-half '12 of all unreimbursed medicat and dental expenses, to commence upon the execution of this agreement and to end on September of 2001. Thereafter, and commencing on October of 200 1 Husband agrees to pay to Wife to be used as Child Support, the sum of $1,347.00 (dollars) per month for a period of two years and in addition thereto Husband shall pay one half 'h of child care costs, as well as one-half '/2 of all unreimbursed medical and dental expenses with this level of support to continue for a period of no less than two years. Thereafter, the amount of support that Husband shall pay shall be governed by the Pennsylvania Support Guidelines, and either party may modify the level of support upward or downward, to the extent allowable pursuant to the Pennsylvania Guidelines but no modification shall be allowed more frequently then every two year period. Wife shall be entitled to claim the children on her income taxes as dependents until the parties mutually agree to do otherwise. 12. PENSION PLANS: The parties release any interest in the opposite spouse's Pensions, bank accounts, stocks, bonds, or any other tangible or intangible assets wheresoever located and accumulated during the marriage and/or subsequent to the dissolution of their marriage. Wife shall maintain her inves1ment in her name and shall hold such inves1ment for the benefit of the children. 6 ~ -"'0/ iiJ ' ::ll ,,' L , ^ -~;;; -1IiIiIiIIlilsI L.,~". . .. 13. COUNSEL FEES AND EXPENSES: Husband and Wife Acknowledge and agree that the provisions of this Agreement providing for the equitable distribution of maritat property of the parties are fair, adequate and satisfactory to them. Both parties agree to accept the provisions set forth in this Agreement in lieu of and in full and fmal settlement and satisfaction of all claims and demands that either may now or hereafter have against the other for alimony pendente lite, counsel fees or expenses or any other provisions for their support and maintenance before, during and after the connnencement of any proceedings for divorce or annulment between the parties. 14. 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 estate of the other as a result of the marital relationship, including without limitation, dower, curtesy, statutory allowance, widow's allowance, intestate share, right to take against the will of the other, and right to act as administrator or executor of the others estate. Each will, at the request of the other, execute, acknowledge and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interests, rights and claims. 15. SUBSEOUENT DIVORCE: Husband intends to file a no-fault complaint in divorce against Wife. Husband and Wife each agree to jurisdiction of the Court of Connnon Pleas of Cameron County and further agree to sign an affidavit of consent to be filed in said divorce action. In the event such divorce action is concluded, the parties shall be bound by all the terms of this Agreement which may be incorporated by reference into the Divorce 7 Qf P'ik v ,~. - ,I L J . I .f< '~u-~".;~, Decree, shall not be merged into the Divorce Decree, and shall not be modified, but shall in all respects survive the same and be further binding and conclusive upon the parties. It is the intention of the parties that the Agreement shall survive any action for divorce which may be instituted and prosecuted by either party and no order, judgment or decree of divorce, temporary, finat or permanent shall affect or modify the financial terms of this Agreement. This Agreement may be incorporated in but shall not merge into any such judgment or decree of final divorce, but shall be incorporated for the purposes of enforcement only. 16. BREACH AND ENFORCEMENT: If either party breaches any provision of this Agreement, the other party shall have the right, at his or her election, to' sue for damages for such breach, or seek other such remedies or relief as may be available to him or her, and the party breaching this Agreement should be responsible for payment of legal fees and costs incurred by the other in enforcing his or her rights under this Agreement. A. It is expressly understood and agreed by and between the parties hereto that this Agreement may be specifically enforced by either Husband or Wife in Equity, and the parties hereto agree that if an action to enforce this Agreement is brought in Equity by either party, the other party will make no objection on the alleged ground of lack of jurisdiction of said Court on the ground that there is an adequate remedy at law. the parties to not intend or purport hereby to improperly confer jurisdiction on a Court in Equity by this Agreement, but they agree as provided herein for the forum of Equity in mutual recognition of the present state of the law, and in recognition of the general jurisdiction of Courts in Equity over agreements such as this one. B. Notwithstanding anything to the contrary herein, Husband and Wife may also proceed with an action at law for redress of his or her rights under the terms of this Agreement, and in such event it is specifically understood and agreed that for and in specific consideration of the other provisions and covenants of this Agreement, each shall waive any right to a jury trial so as to expedite the hearing and disposition of such case and so as to avoid delay. C. Each party further hereby agrees to pay and to save and hold harmless the other party from any ~ 8 rrtJv.4....... U I. ~_L u__ -,j", j,;-,~: '. . . and all attorney's fees and costs of litigation that either may sustain, or incur or become liable for, in any way whatsoever, or shall pay upon, or in consequence of any default or breach by the other of any of the terms or provisions of this agreement by reason of which either party shall be obliged to retain or engage counsel to initiate or maintain or defend proceedings against the other at law or equity or both in any way whatsoever; provided that the party seeks to recover such attorney's fees, and costs of litigation must first be successful in whole or in part, before there would be any liability for attorney's fees and costs of litigation. It is the specific agreement and intent of the parties that a breaching or wrongdoing party shall bear the burden and obligation of any and all costs and expenses and counsel fees incurred by himself or herself as well as the other party in endeavoring to protect or enforce his or her rights under this Agreement. 17. ADDmONAL INSTRUMENTS: Each of the parties shall from time to time, at the request of the other, execute, acknowledge and deliver to the other party any and all further instruments that may be reasonably required to give full force and effect to the provisions of this Agreement. 18. VOLUNTARY EXECUTION: The provisions of this Agreement and their legal effect have been completely reviewed by the parties, and each party acknowledges that the Agreement is fair and equitable, that it is being entered into voluntarily, with full knowledge of the assets of both parties, and that it is not the result of any duress or undue influence. The parties acknowtedge that they have been furnished with all information relating to the [mandai affairs of the other which has been requested by each of them. 19. ENTIRE AGREEMENT: 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. Husband and Wife acknowledge and agree that the provisions of this Agreement with respect to the division and distribution cf 9 ",,\ '~";/ \~ j~ -~ ~ "' J .", ,"""J--. '. , . of marital and separate property are fair, equitable and satisfactory to them based on the length of their marriage and other relevant factors which have been taken into consideration by the parties. Both parties hereby accept the provisions of this Agreement with respect to the division of property in tieu of and in full and fmal settlement and satisfaction of all claims and demands that they may now have or hereafter have against the other for equitable distribution of their property by any court of competent jurisdiction pursuant to Section 401(d) of the Divorce Code or any other laws. Husband and Wife voluntarily and intelligently waive and relinquish any right to seek a court ordered determination and distribution of marital property, but nothing herein contained shall constitute a waiver by either party of any rights to seek the relief of any court for the pmpose of enforcing any provision of this Agreement. 20. 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 party of all assets of any nature whatsoever in which such party has an interest, the sources and amount of the income of such party or every type whatsoever and of all other facts relating to the subject matter of this Agreement. 21. MODIFICATION AND WAIVER: A modification and waiver of any of the provisions of this Agreement shall be effective only if made in writing and 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 shat! not be construed as a waiver of any subsequent default of the same or similar nature. 22. PRIOR AGREEMENT: 1t 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 nut! and void and of no effect. 10 9? ':j~> =-- '." -. ' ' - -.: "'-- -~ ~ - ~ ~----" '. . . 23. DESCRIPTIVE HEADINGS: The descriptive headings used herein are for convenience only. They shall have no effect whatsoever in determining the rights or obligations of the parties. 24. INDEPENDENT SEPARATE COVENANTS: It is specifically understood and agreed by and between the parties hereto that each paragraph hereof shall be deemed to be a separate and independent covenant and agreement. 25. APPLICABLE LAW: This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania. 26. VOID CLAUSES: If any terms, conditions, clause or provision of this Agreement shall be determined or declared to be void or invalid in law or otherwise, then only that term, condition, clause or provision shall be stricken from this Agreement and in all other respects this Agreement shall be valid and continue in full force, effect and operation. 27. AGREEMENT BINDING ON HEIRS: This Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective heirs, executors, administrators, successors and assigns. II ~ 1)~ -' ,;; 'I """I ~ ;,;.;- - "-".",- _1"-;,016 :. IN WITNESS WHEREOF, the parties hereto have set their hand and seals the day and year first above written. ~ DAVID . JONES CommonwewfuofPennsywama County of Cumberland On this, the d 6 j(... ,day ot ~r A.D. 2000, before me a Notary Public appeared David G. Jones, known to me (or satis actorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEKEOF, I hereun seal. Seal lllarial I<enn!llh I,. Sdilg&l.NoIary PlIiD Hampden 1Wp" Cilnbeiland CCXIlIy Com~ ExpirOs Man:h 15, 2001 Member, Pennsylvan~ AssoCIation at Notarles ~() t/f/?';' /t//?L/ C Title of Officer IN WITNESS WHEREOF, the parties hereto have set their hand and seals the day and year first above -~Q Commonwewfu of Pennsylvania County of Cumberland On this, the cPt!5 ,day of. A.D. 2000. before me a Notary Public appeared Christi Lynn Jones, known to me or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEKEOF, I hereunt al. Seal Notlil'ial Seal Kenneth L SohIegel, Notary Public Hampden Twp., Cumberland County My Commission Expil8s Maroh 15, 2001 Member, Pennsylven~ _lion at Notaries ;1/om..er j/wlfL./c Title of Officer 12 ,ti1 11m ~" ~_I- , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, COMMONWEALTH OF PENNSYLVANIA DAVID G. JONES, No. 00-6111 PLAINTIFF, Civil Action---- Divorce V. CHRISTI LYNN JONES, DEFENDANT PRAECIPE TO TRANSMIT THE RECORD To the Prothonotary: Please Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown lUlder Section 3301(c) of the Divorce Code. 2. The complaint in Divorce was filed on the 3RD, day of October 2000 and received by the defendant by way of Acceptance of Service on the 5th day of October 2000 (attached hereto) 3. The plaintiff, signed his Mfidavit of Consent on the 8th January 2001. (which is attached hereto.) 4. The defendant signed her affidavit of consent, on 8th day of January 2001. (copy attached hereto). 5. There are no related claims pending as between the parties hereto and listed herein. The parties have executed a Marital Settlement Agreement on the 26th day of September 2000 which settles all issues relative to distribution of marital property and claims regarding support. 6. The defendant signed a Waiver of Notice ofIntention to Request Entry of a Divorce Decree on the 8th day of January 2001 as required by Rule 1920.72. Date: I /It>-;~ I ~ ~~ -. . =~_'!!lIBlII!IlIlr.-I'li"ifJ~~~Q~~~M;~i>t1i~riI<OO::t0~",,'; +~",,',,~,!!,;:~:t_!Pt._ .' Jf!,J~~.u_'_"':"':1,"''1-'" _,' - ii:.:.l6'~'I!.~-~__~'- "_,,s,"_"^_~. - '''-_'',~.' .,,~ '_, '-"_ 0" " '. "__,^" _,__." I_t"-", . ,,_, ."", .. .~ .....; ... , " (",) <::) ~ ~ i; --{ i! -.,- % ~:~ u:> :J:i, ~(, ~ " ~=B ::z '~'-0 W Zorn 0 " ~ ,::> -' -< ~,~L I ..1.::. " I " .f~xi;g;~ . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, COMMONWEALTH OF PENNSYLVANIA DAVID G. JONES, No. aJ- &7'71 ~A/ PLAINTIFF, Civil Action---Divorce V. CHRISTI LYNN JONES, DEFENDANT, NOTICE TO DEFEND AND CLAIM OF 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. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LffiERTY AVENUE Carlisle, Pennsylvania 17101 (717) 249-3166 - ~I~I -~ - ~~,; ~iI ' m' 'L!;~~' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, COMMONWEALTH OF PENNSYLVANIA DAVID G. JONES, No. PLAINTIFF, Civil Action----Divorce V. CHRISTI LYNN JONES, DEFENDANT A VISO PARA DEFENDER Y RECLAMAR DERECHOS USTED HA SIDO DEMANDADO EN LA CORTE. Si desea defenderse de las quejas expuestas en las paginas siguientes, debe tomare accion con prontitud. Se Ie avisa que si no se defiende, el caso puede proceder sin usted y decreto de divorcio 0 anulaminento puede ser emitido en su contra por la Corte. Una decision puede tambien ser emitida en su contra por cualquier otra queja 0 compensacion rec1amados por el demandante. Usted puede perder dinero, 0 propiedades u otros derechos importantes para usted. Cuando la base para el divorcio es indignidades 0 rompimiento irreparable del matrimonio, usted puede solicitar consejo matrimonial. Una lista de consejeros matrimoniales esta disponible en la officina del Prothonotary, en la Cwnberland County Court of Common Pleas, I Courthouse Square, Carlisle, Pennsylvania. SI USTED NO RECLAMA PENSION ALIMENTICIA. PROPIEDAD MARITAL. HONORARlOS DEABOGADO U OTROS GASTOS ANTES DE QUE EL DECRETO FINAL DE DIVORCIO 0 ANULIAMIENTO SEA EMITIDO. USTED PUEDE PERDER EL DERECHO A RECLAMAR CUALQUlERA DE ELLOS. USTED DEBELLEV AR ESTE P APELA UN ABOGADO DE INMEDIATO SI NO TIENE 0 NO PUEDEPAGAR UN ABOGADO. V AYA 0 LLAME A LA OFFICINA INDICADA ABAJO PARA A VERIGUAR DONDE PUEDE OBTENER ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE Carlisle, Pennsylvania 17101 (717) 249-3166 - ~; L .,. I,,,,~~ ;,;.;, "'~~-'] 11-" J~ift: AVAILABILITY OF COUNSELING THE DIVORCE CODE OF PENNSYLVANIA REQUIRES THAT YOU BE NOTIFIED OF THE AVAILABILITY OF COUNSELING WHERE A DIVORCE IS SOUGHT UNDER ANY OF THE FOLLOWING GROUNDS: 23 Pa.C.S. & 3301(a)(6)-------Indignities 23 Pa.C.S. & 3301 (c)----------Irretrievable Breakdown; Mutual Consent 23 Pa.C.S. & 3301(d)----------Irretrievable Breakdown; Two year separation where the court determines that there is a reasonable prospect of reconciliation. A list of marriage counselors is available in the Office ofthe Prothonotary Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013. HAZLETT & OESTERLING o aintiff 20 South Market Street Mechanicsburg, P A. 17055 (711) 790-0490 [, -,- r. -I.. "-'-'~ "" - ~ .i--Ll "~,-'" IN THE COURT OF COMMON PLEAS COUNTY OF CUMBERLAND COMMONWEALTH OF PENNSYLVANIA DAVID G. JONES, No. Q-tJ - ~ 1'7( (l;..,..J ~ PLAINTIFF, Civil Action----Divorce VS. CHRISTI LYNN JONES, DEFENDANT, COMPLAINT UNDER SECTION 3301(C) OR 3301 (D) OF THE DIVORCE CODE PARTIES 1. Plaintiff is David G. Jones, an adult individual, sui juris and who currently resides at 1516 Timber Chase Drive, Mechanicsburg, 17055 County of Cumberland, Commonwealth of Pennsylvania 2. Defendant, is Christi Lynn Jones, an adult individual, sui juris, who currently resides at 2503 Mallard Way, Mechanicsburg, 17055 County of Cumberland, Commonwealth of Pennsylvania. JURISDICTION & VENUE 3. Both the Plaintiff and the Defendant has been a resident of the Commonwealth of Pennsylvania for a period of more than 6 months. 4. The parties were married on the 22nd day of May 1986, in the city of Annapolis, State of Maryland. II -I L- " ~" lul!.i!illllt)iililiit;" , 5. Both the Plaintiff and the Defendant are in the military service and occupy the positions of Lieutenant Commanders with the United States Navy. 6. There have been no prior actions for divorce or annulment instituted by either party against the other in this or any other jurisdiction. GROUNDS FOR DIVORCE COUNT I REQUEST FOR A NO-FAULT DIVORCE UNDER SECTION 3301 (Cl OF THE DIVORCE CODE. 7. The prior paragraphs are incorporated herein by reference. 8. The marriage between the Plaintiff and Defendant is irretrievably broken. After (90) days have elapsed from the date of the filing of this Complaint, plaintiff intends to file an affidavit consenting to a divorce. WHEREFORE, if the parties file affidavits consenting to a divorce after ninety (90)days have elapsed from the date of the filing and the serving of this Complaint, plaintiff respectfully requests the Court to enter a decree of divorce pursuant to section 3301(c) of the Divorce Code. COUNT II 3301 (J)) REQUEST FOR A NO-FAULT DIVORCE UNDER SECTION 3301 (J)) OF THE DIVORCE CODE. 9. The prior paragraphs shall be incorporated herein as if fully set forth. 10. For the purposes of section 3301 (d) of the Divorce Code, the parties have been separated since July of2000. 11. The marriage is irretrievably broken. - ~ , I ;L d 1_ ~ . .< 12. Plaintiff has been advised that counseling is available and that the plaintiff may have the right to request that the court require the parties to participate in counseling. 13. In the event that consent from the defendant is forthcoming Plaintiff shall seek a unilateral divorce pursuant to and in conformity with section 3301 (d) of the Divorce Code subsequent to the filing of this Complaint upon the expiration of 2 years from the aforementioned date of separation if consent is not forthcoming pursuant to 3301 (C). WHEREFORE, if plaintiff request the Honorable Court to enter a Divorce Decree under section 3301 (d) upon the expiration of two (2) years from the aforementioned date of separation. 14. The parties have three biological children born of the marriage and of the names of Jake Tyler Jones, Cacey Lee Jones, and Chad David Jones. 15. The parties have not heretofore entered into any written agreement as to support, alimony, or property division. COUNT n CUSTODY 16. The prior paragraphs are incorporated herein by reference. 17. The parties have three biological children born of the marriage and of the names of Jake Tyler Jones, Cacey Lee Jones, and Chad David Jones. 18. The parties intend to enter into a Custody Stipulation Agreement relative to the custody of the children, which shall allocate their respective rights and responsibilities regarding Legal and Physical Custody of the children. WHERFORE, the parties respectfully request that the Honorable Court, enter an Order pursuant to the Custody Stipulation Agreement, as entered into between the parties ~-~ ~~.~,' , ,~~'". .I - -- '~ HAZLETT & OESTERLING ATTORNEYS AT LAW Gre Attorn for n 20 South Market Street Mechanicsburg, Pennsylvania 17055 (717) 790-0490 ,:; - -~,~~ ..~j.~~ l'Wil~~M , -- I" - ,~ ~ , ..--- ----: r,~!l:"c '. AMERICAN WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available 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. BY THE COURT: Date: J. ......' ~. _,];l, -~~~t,", . VERIFICATION I verifY that the statements made in the foregoing document 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 '2 ~eo " l~I-' ,"'I L __: I ~,~ >i ......-~"~rr;~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, COMMONWEALTH OF PENNSYLVANIA DAVID G. JONES, Plaintiff Civil Action--- DIVORCE Vs. Docket # 00-6711 CHRISTI LYNN JONES, Defendant CERTIFICATE OF SERVICE I, Gregory S. Hazlett, Esquire, hereby certify that on the 4th day of October 2000 I made service of the foregoing Divorce Complaint and accompanying documents, upon the defendant Christi Lynn Jones by way of first class mail postage prepaid and the same was received by defendant by Acceptance of Service on the 5th day of October 2000 (Attached hereto.)to the following address listed hereunder.. Christi Lynn Jones 2503 Mallard Way Mechanicsburg, P A. 17055 DATE: HAZLETT & OESTERLING / ~Bwl~l,jV;ji;:~~ljilf_i(~:ieJ~~.]-''''_';;''M';''_""'.,'!',b'(c;t1ti_",,,;J,M>ii'''-*-<dwm~J -~ r.~ l[mli/l&l~il/i.ll1!w.__llit.E!;~~...-.-'Iol- CJ ~ uie, ~~~,; ~~t~: ~e -;-L p -.. o 1d'~ -I II II II I I -' , ~~? ::::> f.0 ;;! " '-, -"'..,...,. ~ r;~!Uc'--;:. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, COMMONWEALTH OF PENNSYLVANIA DAVID G. JONES, Civil Action---Divorce PLAINTIFF Docket No. 00-6771 VS. CHRISTI LYNN JONES, DEFENDANT AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 330l(c) of the Divorce Code was filed on October 3n1 2000 , and served upon defendant on 10/5/2000, by way of Acceptance of Service on (Attached hereto). 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have Elapsed from the date of service of the divorce Complaint. 3. I consent to the entry of a final decree of divorce. 4. I understand that I may lose rights concerning alimony, division of property, lawyers Fees or expenses ifI do not claim them before a divorce is granted. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made snbject to the penalties of 18 Pa. Cons. Stat. S 4904 relating to unsworn falsification to authorities. I Date: <? 0krJ 0 I -,~ ~fiailh.~t:;o);!j~,~~_m~b"-_'it~.~"'" r4"','.fl:;;'i._~_"":i,H;!;,(; ,,11?-,,*o!~1J-},~~_lilri r .._.......>o\idl,.&~:!i!)iJ~dIlltit1~Oit "'a&:il 'iiiWi~' ~ " -'f""=~' ~~O lllil.K~+ C) C', C::. " " v fj\ rn z ~~ e "-: r::: : " " " , " , .' :r '-_..' ~ , I , , C.::: =< ,- Lc..:~ ^"c ,.-~ ,",C,"., ~ ..l " Cv __c ""~l..i;L\ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, COMMONWEALTH OF PENNSYLVANIA DAVID G. JONES, Plaintiff, No. 00-6771 v. Civil Action - Divorce CHRISTI LYNN JONES, Defendant WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DVORCE DECREE IJNDER ~ 330HCl OF THE DIVORCE CODE 1. I consent to the entry of a finaI 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.. I verify that the statements made in this affidavit are true and correct. I understand that fatse statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: <:6 0hJ 0 I <1J')~~ David G. Jones:! laintiff - f"";"'~-.~~lfr:!im4lM8::1i"7<Mii'&f'''*''~'Il~'''-,i", :IMi>e.....,,-,,,,_:l.$, ."i_,y;".,""";_"i",,,-''JtJ<<fJ~;O"*l.~iir-'-'=~'- .= --1" -'~'w"ri.lt"-p'~~""" o ~; Q~l~: ~::c [~:>~. r:: -'*il$Im1idllS ~ "~- C') "........ '-.":~ ~ C..;) , - -~ ". , - , ...iI, ... ............ - .~ IT !')Ie '~'"'lIUk"' . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, COMMONWEALTH OF PENNSYLVANIA DAVID G. JONES, Civil Action--- Divorce PLAINTIFF Docket No. 00-6771 VS. CHRISTI LYNN JONES, DEFENDANT AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 330l(c) of the Divorce Code was filed on October 3'" 2000 , and served upon defendant on 10/5/2000, by way of Acceptance of Service on (Attached hereto). 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have Elapsed from the date of service of the divorce Complaint. 3. I consent to the entry of a final decree of divorce. 4. I understand that I may lose rights concerning alimony, division of property, lawyers Fees or expenses if! do not claim them before a divorce is granted. 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. Cons. Stat. S 4904 relating to unsworn falsification to authorities. ) 10<61 0) , Defendant Date: ~_~ft"'''J1IlE'';----'''',;ii!~'';i'}i~!Mj,,,.;,.~i,"llii,,il><'J'i!t->ii;,m-l,~~t''''':~~''i"","~_"lIth ',"!?4',*~_~1i/;l'"''''' ,~~ - ..> ,,"llIm.~~'i",,^ ~- ~~~!lrMc;;~1!jiIiI ,~.J., ,---~ iitiIlIIMIi!lil_lU!.l!liM~1&WM ( "~~ ~Ii~, -,." 92 -?: ::::: r~ -,-, ;~E.; ..>"c -~ C..:J '-...., i"".,) :::> L0 "', ~:::-:; ~. ::rj --. -" ..., ~I" " ~~ '" ~ ,. 'lIlirii?'J;Enm. . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, COMMONWEALTH OF PENNSYLVANIA DAVID G. JONES, Plaintiff, No. 00-6771 v. Civil Action - Divorce CHRISTI LYNN JONES, Defendant WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DVORCE DECREE UNDER ~ 330UCl 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. Section 4904 relating to unsworn falsification to authorities. Date: ,MOl I ~/ '"" 'C_,,, Alliii!jjlli~i!jd'!]''''l*,k*~*~6''J!lili&~~M~.~~i!,-~G,:~i,;''$l;f[j;,k,jn-d""t,~~~~liW,j~OilfY~~llil@.i'il"ti!iii!t~IIli~lin ,~,' !!!i~1' - !sHt,,:ii::-!il3.~ l!~lb.HJi:" C) .~ ~. rR~f :~. ;,;':~- 0~'" ~- ~ ..7- ",,~ ,~ ~~ -, '......' ~.~~': . r:--~l :::> l".) " ~,"'-~ .JJ....,.,; . , ' >~- '"Iv" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, COMMONWEALTH OF PENNSYLVANIA DAVID G. JONES, Plaintiff, v. CHRISTI LYNN JONES, Defendant No. 00-6771 Civil Action - Divorce ACCEPTANCEOFSER~CE I Christi Lynn Jones, accept service of the Complaint in Divorce, Notice to Defend and Notice of Availability of Counseling in the above-captioned matter. I acknowledge that I am the Defendant in said matter or that I am authorized to accept on behalf of the Defendant. ~ Date 1'3J3 ~CA.lw~ LJIM.t ~€ck.N.c;buf3) 0\- (IOs.i Mailing Address II >-~"._, ~'.1~~l.n - -- ~ _ L . . "'", ..'w >''illlt' ~ ~ I~~i~" " . UL:T' 4 20~ ,- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, COMMONWEALTH OF PENNSYLVANIA DAVID G. JONES, Plaintiff, No. m- h)71 ~ v. Civil Action - Custody CHRISTI LYNN JONES, Defendant ORDER AND NOW, this ~, day of 0 L-t:~C'r , 2000, upon presentation of the foregoing Stipulation For Entry of an Agreed Order of Custody, it is hereby Ordered that , Christi Lynn Jones, hereinafter referred to as ("mother") shall have PRIMARY PHYSICAL CUSTODY of the children Jake Tyler Jones, Cacey Lee Jones and Chad David Jones. (Hereinafer "Children") subject to David G. Jones, ("father") rights of PARTIAL PHYSICAL CUSTODY: IT IS FURTHER ORDERED THAT: 1. This agreement shall replace all any and all other previous Orders issued by this or any other Court relating to the Custody of the aforementioned child. 2. The parties shall have shared Legal Custody of the children. 3. The mother shall have Primary Physical Custody of the children subject to the father's right of Partial Physical Custody. 4. The father shall have Partial Physical Custody of the children pursuant to the terms, conditions, and restrictions herein contained and recited. 5. Mother shall be entitled to custody of the children during those times the children are not within the father's custodial care and control pursuant to the terms, conditions, and . ! ' \~ "e,_, .,.,.. ~,-~_"",,JJ'I!1~~ .-~ "' Cif:" "I}. )~/",S:'f 00 (JCT , i J;. '-"',n t,. .JC CUI11"<"'L ,\.....i...'") /:..;, i-',i' """'1\' - \..\'L.,!'., ii ,!I'I"!")' I" 'II.... '..~,~', ,,\. ' C '\,.\'J.."""J""" "'" ~I"'.t' !l\ . rr'l!ll;f'H!.. 7 ,'.~<,~ ,p,~!lh~1'if4WJ~~lj:ii~~jlIilf!!,lWr,~_~'r""~'~""_ -.-1 J, l'l. ,.,.."'fi1f' [jJ~' ~l...L . ' ,.1. ,c- - 1-- "'"' .... ~ , 11~0(,; " ". restrictions of this agreement. 6. Father shall have physical custody of the children for four (4) days every fourteen (14) day period to be exercised either consecutively or non-consecutively and shall choose the dates and times that he is to exercise custody with the children during these periods giving as much advance notice as his schedule allows, to the mother. 7. Both Mother and Father shall be entitled to two (2) consecutive weeks of custody with the children during 'their summer vacation. If either the mother or father intend to remove the child from the Commonwealth of Pennsylvania, they agree to provide the other parent with the name, address, and telephone number of their place of de~tination prior to their departure. 8. Father shall be allowed to attend all sporting events, or any and'; all other extra-circular activities that the children participate in, and shall be given proper notice of the dates, times, and locations of these events from the mother. 9. The parties shall have custody of the children during holidays on an alternating basis within each succeeding year as follows: (d) Christmas, Easter, and Thanksgiving shall alternate within the year except that neither party shall receive the same holiday two consecutive years in a row. Mother shall be entitled to Christmas in the year 2000. (e) The parents shall share the day for the children's birthdays with each parent receiving one-half V2 of the day, the times to be decided by the parties as they may agree. If one of the parties is unable or unwilling to accept or receive one-half of the day for the children's birthdays that party shall be entitled to exercise his or her time with the child at any day or time during a one week period of the children's birthdays. (1) All other holidays not specifically described shall be shared as between the parties on an alternating basis within the year except to the extent that one parent will - . "lJ I: ~~~iI;,i, \ . receive two consecutive years in a row with the same holiday. 10. Each party shall have reasonable telephone contact with the children during their periods of custody with the custodial parent during appropriate times of the day or evening. 11. The party receiving custody of the children shall provide transportation with regard to commencing his or her periods of custody with the children. BY THE COURT, J C~1'\c0J 10-/1-00 _""'~~ t L " __l ........1 J ~'iI ~fIIIIi!lf&1~!ii~,' , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, COMMONWEALTH OF PENNSYLVANIA DAVID G. JONES, Plaintiff, No. ~- 1,77/ ~ kr>"- v. Civil Action - Custody CHRISTI LYNN JONES, Defendant STIPULATION FOR ENTRY OF A CUSTODY ORDER THIS STIPULATION AND AGREEMENT entered into this.J.2~ day of SPjJ-hv1rr 2000, by and between CHRISTI LYNN JONES, (hereinafter referred to as "Mother") and DAVID G. JONES, (hereinafter refereed to as "Father"). NOW TillS AGREEMENT WITNESSETH THAT: WHEREAS, the Mother and Father are the natural parents of children, by the names of Jake Tyler Jones, Cacey Lee Jones and Chad David Jones (hereinafter "Children"), and WHEREAS, the parties wish to enter into a Stipulation Agreement, relative to the custody of the aforementioned children and have the same entered and enforced as an Order of Court. NOW, THEREFORE, in consideration of the mutual promises, covenants and agreements as hereinafter set forth and intending to be legally bound, the parties hereto stipulate as to the custody of their children, as follows: 1. The parties shall have shared Legal Custody of the children. !"~"=~~ ~I..-I-- .L ~~ ... ~~-~. 1 -~ !Oi.Etl'j;:>h" 1. The parties shall have shared Legal Cnstody of the children. 2. The mother shall have Primary Physical Custody of the children subject to the father's right of Partial Physical Custody. 3. The father shall have Partial Physical Custody of the children pursuant to the terms, conditions, and restrictions herein contained and recited. 4. Mother shall be entitled to custody of the children during those times the children are not within the father's custodial care and control pursuant to the terms, conditions, and restrictions of this agreement. 5. Father shall have physical custody of the children for four (4) days every fourteen (14 ) day period to be exercised either consecutively or non-consecutively and shall choose the dates and times that he is to exercise custody with the. children during these periods giving as much advance notice as his schedule allows, to the mother. 6. Both Mother and Father shall be entitled to two (2) consecutive weeks of custody with the children during their summer vacation. If either the mother or father intend to remove the child from the Commonwealth of Pennsylvania, they agree to provide the other parent with the name, address, and telephone number of their place of destination prior to their departure. 7. Father shall be allowed to attend all sporting events, or any and all other extra-circular activities that the children participate in, and shall be given proper notice of the dates, times, and locations of these events from the mother. ~~~,_... t. ;:, ~-~ ~:!I.~<itaf,> < IN WITNESS WHEREOF, the parties hereto, intending to be legally bound by the terms hereof, set forth their hands and seals the day and year herein set forth. ~~ David G. on , Plaintiff COMMONWEALTH OF PENNSYLV ANlA COUNTY OF CUMBERLAND : s.s BE IT REMEMBERED, that on thiff. r day o~ IuL ,2000 personally appeared before me the Subscriber, a Notary Public for the State and County aforesaid, David G. Jones party to this Agreement, known to me personally to be such, and she acknowledged the act of signing this Agreement. Sworn to and subscribed before me the day, month and y~e~ ""... '" \()[JA/;y) p NOTA.R:AL SEAL BAR34RI\ STUMP, Notary Public otary Public harr;Sburg, Dauphin County My Commission Expires Nov. 12,2002 -' ..","- =__J~,I~~ -"~" "k. p 1"- I" 'I , ~.~~"'" " ~ --'''''"'''''~''''''",~~1 . , . ~ IN WITNESS WHEREOF, the parties hereto, intending to be legally bound by the terms hereof, set forth their hands and seals the day and year herein set forth. COMMONWEALTH OF PENNSYLV ANlA : s.s. COUNTY OF CUMBERLAND BE IT REMEMBERED, that on this-..(1 ,day o~~ ~OOO, personally appeared before me the Subscriber, a Notary Public for the State and County aforesaid, Christi Lynn Jones party to this Agreement, known to me personally to be such, and he acknowledged the act of signing this Agreement Sworn to and subscribed before me the day, month and year aforesaid CJ~I NOTARiA~ SE"L BARBARA STUMP, Noiar; Public Harrisburg, Dauphin County ~ Commission Expires Nov. 12, 2002