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Home My WebLink About01-2465 FX .>ll '~." W ~.~ I ;"j ~ ~.~ I ~ ~.~ ~ f.~ ~.~ ~ ;..; I ~ ~.~ ~.~ ~ ;..; ~ ;..; ~ J ~ ~'l ",. '~" , ~~~'~.XX.~<::';:<<<X~~<~.X':K.;<X.X}~~~e<:K.;;:::.,;:.~::?:~e<x.~<::';~.~~:::';~.:;'::XC<K.X:,~::x.;;g;:+;;gi~*:t);~.~i'.;'i:+X'::;~.X:::;:<<;::::;;:+;;'Ji~C<';::l...; ~":.~ : : ~ ~ ~; ~ ~ N ;..~ ~ ~ ~.~ ~ ,", IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY ~.", W .,. PENNA. 'v' ~ ~.~ STATE OF ';,~, j ~.~ ~.~ ~ ~ ... No 2001-2465 . uUUuuuuuu.uu ,uUuuu.uu le: 8 ~.; ~ ~.~ ~ uul1t\~YBE:~.H.uI<,.J 1\CKSO~, Versus ,:.~ ~ ~.~ ~ \,4 ~ ~.~ i ~.~ ~ ~.~ ~ ,', ~ ~ uuuSU10N ul3,..JA<;;KSON,. DECREE IN DIVORCE AND NOW, . , . . ,vQv~~" ]>,. " ~~ ,ZQQ?, > it is ordered and decreed that"., ,~~~.>>:~~~~, .~:, !,~~~~?,~""",.,.,.,.,',."., plaintiff, and. .. , . );~!ll,qI). ]3,'. ,~~~~,s<?1).. . . .. , . , . . , .. . , . . , . . . . . .. .. . . ", 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; The attached Matrimonial Settlement Agreement , .~~ . ~~,~~~p.o,~~ ~~,d, .~~~,e,~~: , . , , . V~, . , . , . , . . .. , . . . , . , . , . . . , , . . . , ",...,.,",.,.,..,..~,.". ./" By J, +~.t.....uu.. ~it::t~~tary v ~ t.,; - i ~ ~ ~...."'.-...~~.,..."'. '''ZP.'''''.;:;: ',....::. .......~.-..,'.:."'.; ....3t;.. ..'...",. '.-:.::,. ..,.'.+.",.;., '_.'":.."'~':".'":.."'." "'.":""'." '.:..... ".,,:.:. "'--1."--"--"'" "_I". '__"" . '" .'".' '""". -.......,'~. ,-__"'."" .........~" - .........~, ,', '" ,. """ --'" ~" '" ',,- '" ,",.'. ,'" '"' - '" ,"" "'.., ..' '" . )~ x.:~.:: :::.:+x ::.:.:.- >::+::.-.: )::.::.....::.:.:.', ,"'::.:'" -- .::+::...:: : ':+:'. ":.:+::.: " ~. _1&' ;..; ~ ~ ~.~ ~ "'S ~ .~ ~ ~'S ~ ~ ~.; . N ~ ~ '~ ~.~ ~ ~.'; ~ ~~ 8 ~":.~ ~ ~~~ * ~ ~ ~~ i ~.~ N * ;::) W ~l ~ ~.~ ~ M ~.~ ~.; ~ j ~.~ ~ ~.~ f.; * i ~.! ~ \~ ~ '.~ ~ ,,' ~ ',' ~ v ;t: ,,' >;!i\{ ~ i" 'C~. . . ~-"'.. .. illfl~,!llI~., <6'- 9 -0 ..) 'i?-9.0.,2 ,W ~-, ~ ~, .',~ ,'_",',' .~" '"._~ ,.-~, 1'~~'~_~h"'''"'N'.'__'=^,^,,' c?&d-~ ~~J1, ~ ~~ 71~~~ -Z;'~ . ,=~& -- ~-, - <'~""''''-<~~-''''\'~UI " ~ ff'~$''ll'.I!-e'il>>H'''''_'-''ffilw,"mmll":!'!!~~~~f.~iili~'~~~ ",,.,.,.A_U_~J,,,",- ~,J, '-," - ''''''"'~" f MARYBETH K. JACKSON, Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 2001 - ;)l/l95'" CIVIL TERM SIMON B. JACKSON, Defendant CIVIL ACTION - LAW 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, 1 Courthouse Square, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, . YOU MAY LOST THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU',DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. COURT ADMINISTRATOR CUMBERLAND COUNTY COURTHOUSE ;,."4TH FLOOR ONE COURTHOUSE SQUARE CARLISLE, PA 17013-3387 (717) 240-6200 . j L;. '-, 'k'~- ~""'("~ " --~--i:'J. J MARYBETij K. JACKSON. Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 2001 CIVIL TERM SIMON B. JACKSON, Defendant : CIVIL ACTION - LAW ACTION IN DIVORCE : NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN NAMED DEFENDANT: YOU HAVE BEEN NAMED AS DEFENDANT in a divorce proceeding filed in the Court of Common Pleas of Cumberland County, Pennsylvania. This Notice is to advise you that, in accordance with Section 202 of the Divorce Code, you may request that the Court require you and your spouse to obtain marriage counseling prior to a divorce decree being handed down by the Court. A list of professional marriage counselors is available at the Office of the Prothonotary, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from the list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty (20) days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. PROTHONOTARY . '--" ""'.,. .--,.,," , ~h-' " _ "'__'.* ,. c. """t: ; MARYBETH K. JACKSON, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 2001-.;l,/("~~ CIVIL TERM SIMON B. JACKSON, Defendant CIVIL ACTION - LAW ACTION IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE AND NOW, comes the Plaintiff MARYBETH K. JACKSON, by her attorney, Herschel Lock, and seeks to obtain a Decree in Divorce from the bonds of matrimony with the above-named Defendant, and avers the following: 1. Plaintiff Marybeth K. Jackson, is an adult individual residing at 6117 Stephen's Crossing, Mechanicsburg, Cumberland County, Pennsylvania 17050. 2. Defendant Simon B. Jackson is an adult individual residing at 29 S. pitt Street, Apt. #5, Carlisle, Cumberland County, Pennsylvania 17013. 3. Both Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on November 4, 1995, in Alexandria, Virginia. 5. There have been no prior actions of divorce or annulment between the parties. 6. The marriage is irretrievably broken. 7. Defendant is not a member of the Armed Services of the United States or any of its Allies. ,~'~ ! ~,I ,- '"~ < '",~-', d. '. ',1 -<"'c> - " . ."- ti1: 8. Plaintiff has been advised of the availability of counseling, and understands that he has the right to request the Court to require the parties to participate in counseling. WHEREFORE, Plaintiff respectfully requests the Court to enter a Decree in Divorce. DATEO: 4/26/01 ~Jl~ HERSCHEL LOCK, ESQUIRE ATTORNEY FOR PLAINTIFF 3107 North Front Street Harrisburg, PA 17110 (717) 238-6661 . , " / '<'C 0 .-,.' >' . ",".< V' "'-.'., ~-~_J -,;,<"cJk VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa. C.S, Section 4904 relating to unsworn falsification to authorities. DATED: 4/26/01 ~~k+1- 1./ ~ o.-cJU-- MARY BET K. JACKSO ~.m;I~jj,>i~';'H.'!-lllii!;,1lM!>>f~iHiJ;ill.Jf4';~~fu~",""",,,,,t<~~;lW;i18G'MiIiM~1~ -~-<..:... ,<~ v . ~_~ """"..;~ (:) CJ 0 -:t> C '1 "- \ -0$,. "" ---{ r;:" ~ OJ .'0 ~ -........ DJfT; ::-v ,:'-;1 iId ~ YJ ~ ",,-:t.1 < ZC N -.-'." ~ (j)" -' ---". , d ~ ../~::'" ;\'J:" "- ~ cl ~O ",. ~~~~ -.. ~ ~ )i.. C-o, () ~ VI <::, ~O 00 '~fTl '<..I <:: ~J ~ c u ~ ..-4 ~ :::;) -p. ::t:. 0'0 (1'\ -< ->-.. r .~ '" (' r- ,:::') () VV:A MARYBETH K. JACKSON, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 2001 .;I(1)G5" CIVIL ACTION - LAW ACTION IN DIVORCE CIVIL TERM SIMON B. JACKSON, Defendant : CERTIFICATE OF SERVICE I, Herschel Lock, Esquire, do hereby certify that on thisJI~ day of ~ ' 2001, I served a copy of the Complaint in Divorce for Plaintiff by depositing same in the United States Post Office, certified mail, return receipt requested, at Harrisburg, Pennsylvania, as follows: Simon B. Jackson 29 S. pitt Street, Apt. #5 Carlisle, PA 17013 DATED: i{/n /b I BY:~ clc/( HERSCHEL LOCK, ESQUIRE AT~ORNEY FOR PLAINTIFF 3107 North Front Street Harrisburg, PA 17110 (717) 238-6661 , . , MARYBETH K. JACKSON, Plaintiff . . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : vs. NO. 2001-2465 CIVIL TERM SIMON B. JACKSON, Defendant CIVIL ACTION - LAW ACTION IN DIVORCE AFFIDAVIT OF SERVICE Herschel Lock deposes and says: 1. That he is an adult individual residing in Dauphin County, Pennsylvania. 2. That on April 27, 2001, he sent by Certified Mail, Return Receipt Requested from Harrisburg, Pennsylvania, No. Z200-145-616 the Complaint in Divorce in the above-captioned case to: Simon B. Jackson 29 S. pitt Street, Apt. #5 Carlisle, PA 17013 3. That on May 2, 2001, Simon Jackson signed the receipt No. Z200-145-616 which is attached to this Affidavit. DATED: 11/3/ /tfL-. ( BY: ~r/l HERS HEL LOCK, ESQUIRE ATTORNEY FOR PLAINTIFF 3107 North Front Street Harrisburg, PA 17110 e7l7) 238-6661 Sworn to and subscribed befo~--,~j j, this 3/~/ day of rVV-t ' ;2,00;1.. ('~~Y~JbdC Notary Public NOl'AIIAI. SEAl. ;' ;f'~'9 CONNIE I.. FAIfNm'OCl(, I<oiaIy NIle IWnlobul'fl, D:ouphL, ~ . . II., CotmnIscl"" Explres Mtty 22, 200S b~',!V__, ~ ',.-.. n- . '. '"-"- " - ,r . Oq~p(ete lt~ms 1, 2, and 3,.Also complete Item 4 if Restricted Delivery is desired. . Print your name and address on the rever~a so that we can return the card to you. . Attach this card to the back of the mailpiec:e, or on the: front if space permits. 1. Article Addressed to: . .... Simon B. Jackson 29 S. Pitt Street, Apt. *5 -.''''--c'd";:.l i-s~l e I . >"'=~.~1.7-013 .'. 3. ~Jce Type }i?JCertJfJedMail o Registered o Insured Mall o Express Mail o Return Receipt fOf Merchandise o C.O.D. 4. Restricted Delivery? (Extra Fee) DYes 2. Article Number (Copy from service label) Z200-l45-616 PS Fohn '38 j j; July 1999 -' bomestk: Return Receipt 102595.99.M.17S9 l .f Z 200 145 616 US Postal Service ~ Receipt for Certified .-rail No Insurance Coverage -P~ed. Do not use for International Mail (See reverse) Se~'imon B. Jackson Stre,2' ~ Number #5 S. Pitt St., 'Apt. Post Office, St{l.te, 1 ZIP Code 17013 Carlls e, PA Postage $ .5'5 Certified Fee i. 9 () Special Delivery Fee Restricted Delivery rOO '" '" Retum Receipt Showing to /,51) '" ~ Y-Ihorn & Date De6vered ~ Re!Jm Receipt S1iow;,g " WIl!m, .:t Date, & Addressee's Address 0 $ ':{. 9 S- O TOTAL Postage & Fees <Xl M Postmark or Date E 1; 4/27/01 lL U) f a. I.iJii;,!Jl!.ml'i:'BiiI@i1S~~","~;'j"~I"'~"~' c"'L<-"'00,:wji11~llfl1li+.;ilcq~Jli!&rA'!!:;~d"i"bfil(!;mi]!,i "!X,"-,:+-..'j,."'jii"'f.ri~!...,j'...L:"'-!1A~~~.kllltt , "",~. ~ ,.. K~ '.'- nl!'.iII1EliiII1WW'-'-""'"'''"'"-~'<"''Ii!\\wi..'&itl~M-',jjill~tJ'.."~ t. ,... , , " ~. -" :z .. - :::J:;!; :c 8z 0- ~ O:::i "" ~~::: >- ," (f) I ,::'lz (!) o::z =:J U..1LU mo.. OC( ~ N :::J 0 Q t ~ . .-", "'" ". --!l!!!.j~ -"" "' .tt''j ; ,", 1.< "~I' i'" JAN 02 1900 03:09 P,01 0' , MARYBETH K. JACKSON, Phintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA , Via. NO. 2001-2465 CIVIL TBRM : SIMON la. JACKSON, Defendant CIVIL ACTION - LAW ACTION IN DIVORCE : : AFFIDAVIT OF CClNSEJIIT P~rsonally appeared befo~e me, a Notary Public in and fo~ the afo~esaid C~onwea1th and County, MARYBETH K. JAC~SON, who, being duly sworn acco~dinq to law deposes and says that: 1. A Complaint in Divoroe under Section 3301 (c) of t.he Div~ce Code was filed on April 27, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complai~t. 3. I consent to the erltry of a f~na~ 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. Section 4904 relating to unsworn falsification to authorities. Dat.e. (/L~02- I ~E~~b;A2isoi- ~~ Sworn to and subscr~bed beHhi'PM "." of J L' I ~M ~ . J ~ '/Y~~ Me Notary public NOr..... -.. ., .' CONNIE L FAI~N.;;;' 1tcmIsbutg, Davphin C'4unI!I ., ~ 1 t ij........,..... ~j~Jful;'>;'!~t"i.;<''''~_1~~~'-'i'MTi1'''clf_$k!iL~"~.<.$-,i!ii&,fJ<H:; 'W_"H,,~,a<';iit1;-.k"<<"_"'-*',S-;j ~,~i,"@ii~Ir- .,,~ --uH_ _~LIU ~ _fI~~.",,..,.,,.,.,_~~ ~_=_~,~'" _~~""'., ,_"',0 I' '"",~, ,_. ~ " <." ,~' ~- ',~-~~~, '" (') Cl <:;;!. C N s: ~ .-l -rJCJJ ~~~~ q;H-'-; en __,lJ \ zc r'-' :'p9 <ft.dC' C}O -=<~ ":::J-;i k~" "'<:l ...0._-<1 ?fa :x ~,~O -0 - esrn J:>C ., S;! ~ t::" ~ W ';,' "J,:'.' li, " 'i' /'.' ;~ ,,', ;..-, .'., ,) <~~, ~ .1_-, '," .',In,' , . JAN-02-1900 03:10 P,02 ~J.' I MARYBETH K, JACKSON, plaintif! IN THE COURT OF COMMON PLBAS CUMBERLAND COUNTY, PENNSYLVANIA VB. NO. 2001-2465 CIVIL TERM SIMON g, JACKSON, Defendant CIVIL ACT~ON - LAW ACTION IN DIVORCE WAIVER OF NOTICE OF IliITBIilT TO REQUEST EHTRY OF DXVORCE DECREE 1J!IDER SECTIOll1 3301(c) OF Tim DIVORCE CODB 1, I consent to the entry of a final decree of d~vorce without notioe. 2. division of them before I understand that I may lose rights concerning alimony, property, lawyer'S fees or expenses if I do not claim a divorce is granted. 3. I understand that I will not be divorced until a divoroe 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 "tatements herein are made Subject to the penalties of 18 Pa. C.S. Section 4904 related to unsworn falsification to authorities. DATED: 7 /2-2./0"L . , ~kt--l_ll~<AJCA-- MARYB TH . JACKSO <~:~+:~,~~T:,-~',.,J;,;,~[.J _J[lL",,,,,,,,,-,,,,,,,,,,,,,]IJILL_~_ _. .rec'. _ r '~-I _" ..~-_ ''''''''''''''__ '.~--"-...",_",,,,,.......io'" .". :: '~.,;;.;;:;'::,;:,:;,;- ,"~' h.'" ~ ,,' ,. 'c' .'-, " ,_. _~ _, .),~~ "" , 0 Cl 0 C N -n ?:;: "'" :;:1 -eU' c:: in:;:; mfn G") 2:-;::'1 I nm zr" 09 ~3~ I" 'JQ '~Q '"'0 ~" o:D ~o ~ 2'0 -(11 >2 ~ :z ;:- ~ ::J w , , ;-, W: ---~" 1,"< ;',:1':':',:: ...." ',;.';, . JAN-02-1900 03:10 "I P,04 . . "iii..:!' . " , MARYBETH K, JACKSON, Plaintiff IN THE COURT OF COMMON PLEAS CUMBE:RLluw COUNTY, PENNSYLVANIA V$, NO. 2001-2465 CIVIL TERM SIMON E. JACKSON, Defendant CIVIL ACTION - LAW ACTION IN DIVORCE AFFIDAVIT OF CONSENT Personally appeared betore me, a Notary Public in and for the aforesaid Commonwealth and County, SIMON B. JACKSON, who, being duly sworn according to law deposes and says that: 1, A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on April 27, 2001. 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, after service decree, I consent to the entry of a final decree of divorce of notice of intention to request entry of the I verify that the statements made true and correct. I understand that fa made subject to the penalties of 18 pa C.S. to unsworn falsification to auth ie in this Affidavit are atements herein are S tion 4904 relating Date:~ Sworn to and subscribed before me this_ GilG1h. day of .r......l} 2002, :WO'-- NOTARIAL SEAL JENNlFERLMJI,LEII, NOTARYPUlLIC UPPER FlIA/IIII'IlRDTWP.CUlIBE1UIIlI COUNTY. PA MYCOM~EllPlAESAUGUST"- '~r~~'l;t;!!.1hr:;)ftl;,!,'C,;fu~'\~<'\;""~':.,"1,J\i~~:%.,1i..An''',,-:L>;&.7,WMl''i1i)'di'o.'_WJ'r,,~,:~,tA~" i-,::'td,'Oi", T')~~i:'l<olW!~ ~'-~~-" ~ "-~'-I!Ii!.~m...-~;..iiiii!il;t~l"i'''"'''~W' .. ". '",,'~ s.,.: .> . > ,~ 0 0 (~:) c i'0 ,; <' ",. -055 '.- mrT' Ci") Z::D ZS; I ;~ (j) .... ,x) -<.,2:' ,<~~ r:r-'l ~K~ ..,." ~O -,,, ,~~,~ -H - ~C) "0 ZM )>e: S1 z , ::< ~ 35 "\'1,'; (..:> -< ---", ~. \ t~,,~~ _ ,d>=H""'~'<='<~ ,"",,,-."''''',,. ,'""".,_",,~ ,.,,~ . _~, -,,"~'~'- '" - ~~ ~" J\@ ." -' ~.' " " ,..,,-. _h .- ~ \t.\i JAN-02-1900 03:11 P,05 ... ,:- " MARYBETH K, JACKSON, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VB, NO. 2001-2465 CIVIL TERM SIMON :S. JACKSON, Defendant CIVIL ACTION - LAW ACTION IN DIVORCE WAIVER OF NOTICE OF IIlI'l'_'J: TO REQUEST ENTRY OF DIVORCE DECREE mmER SECTION 3301{c) OF THE DIVORCE CODE 1. I consent to the entry of a final decre@ of divorce without notice. 2. division of them before I understand that I may lose rights concerning property, lawyer'S fees or expenses if I do not a divorce is granted, alimony, claim 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 related to unSWOrn falsification to authorities. DATED:~ " J SIMON B, JACKSON ~~~,~il>liiL~&~;cij~cillliW:J.1i&~~:,Jfilil'!'&iif.il.f.l"''''-'~';'"' "",,<'d,'.j,-}N,'d't;Wji>;~Ml' ~ib. .~- d .. At Jf,J~+";'_L."l-_"" ___-""_,~. =,. "",~" "__,~o._ -.'_""""'''~_''''~' '"",,,., '?"".,' ____,. _~ < ^_ < - ~" '. ,to, C) 0 0 C N ., <':"" :po ..~ ClUJ C ~~'~p nlri; CO') Z:rJ 2:5- I -,-m CD...::: N :5? -<~ ") !:;20 ::.-..,C) -u -T',; _1.. ." ~O 3 ~O --=0 Om )>c ~ l:"" ~ W -< 1M ['~", ""r~ ~" -~'-~",,,,o-.1..~ ~<-.'- 'f .. . , MARYBETH K. JACKSON, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. . . NO. 2001-2465 CIVIL TERM : SIMON B. JACKSON, Defendant CIVI~ ACTION - LAW ACTION IN DIVORCE PRAECIPE TO THE PROTHONOTARY: Plaintiff's Social Security No, 169-54-7489 Defendant's Social Security No, 220-58-6835 DATED: 1/'Jlltv I I aJ1JJ{ HERSCHEL LOCK, ESQUIRE Attorney for Plaintiff 3107 North Front Street Harrisburg, PA 17110 (717) 238-6661 Supreme Court No. 22691 p ,';. I"'" 'r: [',-. .' , ,':"" I'" :':." "".J~~ ","-' I : ;-, , .. 0-.'," ,~- ; ~, , -" ~ JAN-02-1900 03:10 P.03 MARYBETH K. JACKSON, Plaintiff IN THE COUll'!' OF COMMON PLEAS CUMBERLAND COUNTY, pgNNSYLVANIA vs. NO. 2001-2465 CIVIL TERM SIMON B. JACKSON, Defendant : CIVIL ACTION - LAW ACTION IN DIVORCE . . AFFIDAVIT I, MARYBETH K. JACKSON, beinq duly sworn according to law, deposes and says: 1. I have been advised of the availability 9f marriage counseling and understand that I may request that the Court require that my spouse and I partioipate in counseling. 2. I understand that the Court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me upon request. 3. Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a divoroe decree being banded down by the Court. I understand that false statements herein are made subject tc the penalties of 18 Pa. C.S. Sec. 4909 relating to unsworn falsification to authorities. ~~k-H-J/tcdu- MARY ETH. JACK~ON Sworn to and 5ubscrtbed before me this ;<;tnc1iiay of ~ ' ~~^ f"~.~~~tWL Notary Pub ic ~$IAI."'< CONNIl! L FAlMS'l'Cla._",,* IiGmobu~. .....~.....n~. . . .. ..'.W. "".....'._."'_ "'. Nty~"" E>IpIM Mftt _- ,,'.~ ~ " ~_~~i~f.~Mi!tililM',*4!fftU::C,bi\li+~2;:;liffJj~1-~-"~&~;;M;'\~J"fJ""il ';"""'5::;r;.\:-;;~i4li"W_'~;_~{~',~1<l'~Jjt_ tljl" '... ,"." " ^. ,~,.., ,.N',"'''=' ?,."' '>_~" '>'" ,. - ~,~ '" '-'~~"'~'";:'~""""'"'~:"']- -.- ~ l ..~ , " 0 0 0 C [\j ? 11 ;:B [1:; :0- : rr c:; 2:;)'1 en 'T"] Z~ I t-:"~ .'--.-.j--., C/) .' N So ::-< -;;0- r:C <~)(~ K ~ ~O ~ =[i-r- ~ B-H ;SO ~o ~ - orn 0'.. .::- ~ (..) -< ~ ~ , ;., \:" "", ,,".' ;', "",'".,.' ,,'," I'L" , JAN-02 1900 03:11 P,06 MARYBETH K. JACKSON, Flaintiff IN THE COURT OF COMMON PLEAS COJ:I1BERLAND COUNTY, PENNSYLVANIA VOl. NO_ 200l-2465 CIVIL TERM SIMON B. JACKSON, Defendant CIVIL ACTION - LAW ACTION IN DIVORCE AFFIDAVIT I, SIMON B. JACKSON, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my speuse and 1 participate in counseling_ 2, I understand that the Court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me upon request. 3_ 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, 1 understand that false statements herein are made subject to the penalties of 18 Fa. C_S, see, 4909 relating to unsworn falsification to authorities. 5<- ~ ""'SIMON B. JACKSO .- \....J - Sworn to and subscribed before me this Clam. day C:>~. , 2002. 'IlOTAAlALIIEAL JEIINIfielL,IolIWR.IioTARVPUBUC UPPER fIIA!I!!F!lRblWP. CIlIIII&IlLANDCOUHTY. PA uvl:OlilliSS1OH EXPIIIESAUGUllfe.- " ,~ TOTAL P, 06 '~~~'k"-<idOi.'tif!!;ii>li;~tm,b'i'-tfi!ift(1:W~!i!fi-liR;""<!IM<,"':;.\:\"'(''''~f',,"'~'~'''-'''h;il'fii,L'lii0$~I'h~..\;;r:!>Wk~!I!~" ~i,,", ~"'~,~'~,~I'"" .,"~, ~ ~ - ,~.,."_ .~..,~- ,7'.",;<U''1'''-, "',__'0'~"_1"'''~__''"" .' ,~ ".~ ,." ,_ fl',' ~,C,,~, ~ "..~ l~Jfl IT~f c.;,..~.~. '~"~;',"ll:"'''''''''' ''!f'''''".J.. ,..- - -'\,-I I I 0 0 0 C N .. -.>0 . "'- :D- c:;:! ""Oct c:: ~g:j ",w' f";'-i'1;;9 Z'C. I ""..om W"i: K:> C,6 -:,~ ",./.-. "(~t ~CJ -0 '''''11 >'c :x f') - La :::...C) >c ofn ~ t=" :t'! (..) :5l ,\,' 1~ l , " -""~' i ~l ,~ , "..,." I~ - ~'i!! """ IN lHE COURT OF CCMMON PLEAS OF. CUMBERLAND COUNTY, PENNSYLVANIA MARYBETH K, JACKSON, Plaintiff NO. 2001-2465 CIVIL TERM vs. CIVIL ACTION - LAW ACTION IN DIVORCE SIMON B, JACKSON, Defendant PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Grounds for divorce: irretrievable breakdown under Section 3301 (c) ~x~x* of the Divorce Code. (Strike out inapplicable section) 2. Date and manner of service of the complaint: April 27. 2001. Certified Mail. Return Receipt Requested 3. Complete either Paragraph A. or B. A. Date of execution of the affidavit of consent required by Section 3301 (c) of the Divorce Code: by the plaintiff July 22, 2002 by the defendant July 26, 2002 B. (1) Date of execution of the plaintiff's affidavit required by Section 3301 (d) of the Divorce Code: (2) Date of service of the plaintiff's affidavit upon the defendant: 4. Related claims pending: None 5. Indicate date and manner of service of the notice of intention to file praecipe to transmit record. and attach a copy of said notice under Section 3301 (d)(l)(i) of the Divorce Code 0//JJ J( Herschel Lock, Attorney for Plaintiff/~~~~x ~1;o",,,,,,<~,;~~,JtI~~@'~:ili!l\~~.~~!W",_,:,,."l'I'_<I;ilI;;?.i<i~#"~""'"""" .; , ~^' '"c~__ --'--Q---'> . '" . ~ " - ~. ~ ~ "~ ~~ g Z -niP ITlr.p Z.--..) Zt;:', C{J",,;::'. _<"r, cO -- -"'r- "", , ~O J>-c: 3 ~ C> l'v "" c: C) I I" -0 ~;: .,.. ,.,.. ~ .-1 ;~fQ -r'}fT1 :.by r.__~C) ~"_-;l ..L -n ()r"') Z r\1,- o -\ ?ii '< j <-- , ' -'~I-';~ ~-, . .i-I..."";',,i.- , '- ~, -':-i',' MATRIMONIAL SETTLEMENT AGREEMENT R THIS AGREEMENT, made this l.J - day of M~ , 2001, by and between MARYBETH K. JACKSON, hereinafter referred to as "Wife", and SIMON B. JACKSON, hereinafter referred to as "Husband." WITNESSETH: WHEREAS, Wife and Husband were lawfully married on November 4, 1995; and WHEREAS, certain differences have arisen between the parties as a result o,f 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 their mutual responsibilities and rights growing out of the marriage relationship; and WHEREAS, Wife, after being properly advised by her attorney, Herschel Lock, and Husband, after being advised to retain legal counsel but choosing not to do so, 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, - 1 - ~ 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 she or he may from time to time choose or deem fit. 2. INTERFERENCE: Each party shall be free from interference, authority and contact by the other, as fully as if she or he were 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 compel 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. 3. WIFE'S DEBTS: Wife represents and warrants to Husband that since the 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. - 2 - l__ ~ .;- '-li-''',~~:;,,,.;, ,~ -. "'., """'i:. 4. HUSBAND'S DEBTS: Husband represents and warrants to Wife that since the separation he has not, and in the future he will not, contr.act or incur any debt or liability for which Wife or her estate might be responsible and shall indemnify and save Wife from any and all claims or demands made against her by reason of debts or obligations incurred by him. 5 . MUTUAL RELEASE: Subject to the provisions of this Agreement each party waives her or his right to alimony and any further distribution of property inasmuch as the parties hereto agree that this Agreement provides for an equitable distribution of their marital property in accordance with the Divorce Code of 1980, its supplements and amendments. Subject to the provisions of this Agreement, each party has released, discharged, and by this Agreement does for herself or himself, and her or his 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 their right to request marital counseling pursuant to the Divorce Code. - 3 - ,~ ~ ~~ - ". ~,,~" " _ J' ;,_, H ~k __" ,~>; 6. DIVISION OF PERSONAL PROPERTY: Husband and Wife agree that Husband shall be the sole owner of their 1996 Ford and Wife shall remain the sole owner of her 2001 Subaru. All personal property, household furnishings, furniture and the like, as well as any bank accounts, stocks and bonds, savings, retirement accounts or pensions of any sort and any other personalty presently in the possession of each party shall remain the sole and exclusive property of that party. 7. DIVISION OF REAL PROPERTY: Wife and Husband agree that contemporaneously with the execution hereof Husband shall execute a deed transferring to Wife all of his right, title and interest in the marital home known and numbered as 6117 Stephen's Crossing, Mechanicsburg, Cumberland County, Pennsylvania 17050 who thereafter shall be solely responsible for payment of the mortgage thereon to USAA Federal Savings Bank and to indemnify him and hold him harmless for any liability therefore. 8. ALIMONY: Both parties acknowledge and agree that the provisions of this Agreement providing for equitable distribution of marital property are fair, adequate and satisfactory to them and are accepted by them in lieu of and in full and final settlement and satisfaction of any claims or demands that either may now or hereafter have against the other for support, maintenance or - 4 - - . ~ ,--". ~I- .~ alimony. wife and Husband further, voluntarily and intelligently, waive and relinquish any right to seek from the other any payment for support or alimony. 9. ALIMONY. PENDENTE LITE, COUNSEL FEES, AND EXPENSES: Wife and Husband acknowledge and agree that the provisions of this Agreement providing for the equitable distribution of marital 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 final 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 provision for their support and maintenance before, during and after the commencement of any proceedings for divorce or annulment between the parties. The provisions of this Agreement dealing with alimony, alimony pendente lite, counsel fees, spousal support and the like are intended by the parties to be in full and complete satisfaction of any statutory marital rights or obligations of the parties. 10. WAIVERS OF CLAIMS AGAINST ESTATES: Except as herein otherwise provided, each party may dispose of her or his property in any way, and each party hereby - 5 - " _J .'- _ ,. .0..0' .,- ~'" _ ,,- C' -"'-~-n-;'; waives and relinquishes any and all rights she or he may now have or hereafter acquire, under the present 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, curtsy, 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, 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. 11. SUBSEQUENT DIVORCE: A Complaint in Divorce has been or shall be filed by Wife. Wife and Husband each agree to sign an Affidavit of Consent and Waiver of Notice of Intent to File for Divorce to be filed in said divorce action. The parties further agree that each of them shall be responsible for their own attorney's fees, if any there be. In the event such divorce is concluded, Husband shall be entitled to receive a copy of the Decree In Divorce for the normal fee charged by the Prothonotary. In the event such divorce action is concluded, the parties shall be bound by all the terms of this Agreement which shall be incorporated by reference into the Divorce Decree but, notwithstanding such incorporation, this Agreement shall not be merged in such Decree, but shall in all respects survive the same and be forever binding - 6 - and conclusive upon the parties. 12. BREACH: If either party breaches any provision of this Agreement, the other party shall have the right, at her or his option, remedies or relief as may be available to her or him, and the party breaching this contract should be responsible for payment of legal fees and costs incurred by the other in enforcing their rights under this Agreement. 13. ADDITIONAL 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 required to give full force and effect to the provisions of this Agreement. 14. VOLUNTARY EXECUTION: The provisions of this Agreement and their legal effect have been fully explained to wife by her counsel, while Husband has chosen not to retain counsel but acknowledges he fully understands said provisions and their legal effect, 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 acknowledge that they - 7 - , , ~~ <- 'j" ~ have been furnished with all information relating to the financial affairs of the other which has been requested by each of them. 15. ENTIRE AGREEMENT: This Agreement contains the entire understanding of the parties and there are no representations, warranties, covenants or understandings other than those expressly set forth herein. wife and Husband acknowledge and agree that the provisions of this Agreement with respect to the distribution and division 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 lieu of and in full and final 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 or for alimony, alimony pendente lite, counsel fees or costs by any court of competent jurisdiction pursuant to the Divorce Code or any other laws. wife and Husband each 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 purpose of enforcing the provisions of this Agreement. - 8 - .- - ~.. '-"0"" - ,,_~""'__"r_' " '-'_ji'k 16. 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. 17. 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. 18. APPLICABLE LAW: This Agreement shall be construed under the law of the Commonwealth of Pennsylvania. 19. VOID CLAUSES: If any term, condition, 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 or provision shall be stricken from this Agreement and in all other respects this Agreement shall be valid and continue in full force and operation. 20. AGREEMENT BINDING ON HEIRS: This Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective heirs, - 9 - i[ .~ . ,-. ,,' . -.,~ ". b '. 1: ~-" ;.<. '- ~ .~-.. L:: executors, administrators, successors, and assigns. 21. MODIFICATION AND WAIVER: A modification or 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 shall not be construed as a waiver of any subsequent default of the same or similar nature. :') IN WITNESS WHEREOF, the parties hereto have set their hands and seals the day and year first above written. WITNESS: lfltaJurOInM. ~. !JJ1A~@ ~~(!.&~ - 10 - ^" -,-.',,-":..1, '-6"_~'>"" Y'" AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA . COUNTY OF 'fl.M::JPHIl~ (!tllYlt3e!dI/1J])) SS: Ir#-_ day of ,..../J/1!U,;f- On this, the 7 I/f' U ' 2001, before me, a Notary Public, the undersigned officer, pe~sonally appeared MARYBETH K. JACKSON, known to me (or satisfactorily proven) to be the same person whose name is subscribed to the within instrument and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and notarial seal. ~ y:J ~jf1UuJ Notary Public NOTARIAl SEAl GAIL P. STRICKlER, Notary Public SI~h:!.'_TWP., Cumberlalid County m_klO Fell, 3, 2003 ~, _. I _~ - -~ ..., . ~., -, .~ ., , " ,,--, '-'h .h"'''_~: , , . AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF DAtlh.LN (!u..1J1 !jeL!/hJ)); SS: On this, the /jtt day of '1Ilarr- 2001, before me, a Notary Public, the undersigned officer, personally appeared SIMON B. JACKSON, known to me (or satisfactorily proven) to be the same person whose name is subscribed to the within instrument and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and notarial seal. ~yJ~ Notary Public GAIL P S~TARIAL SEAL Sliver spring T~~' Nota'Y Public My CommlatJon EllPJ:~~~,~~ty j h"Ml!!~i:k~;jj,@U.ili;!ffi~J;&~"~W'~t.""~~*.<lilfu",,,",,i;I;\li;:r.4i;"w._.;ii..'~r .~. . < ". Ii! , )'(~,:i{~.,-{,;~:,:,~h~L;__,_" rnr J n.~~~HL.:.,. ,""'":0 '.'"':<<". 'r'l'\""_~_ .~. --, , , W~ ~ ---' -- ','~= o c <' "'litO n In"! Z~.rj o 5~~~ [S~t) ~tE~ ....'r-- "'" :3 , ~.~ ,"' a N "'" ,'- ?5 I 1') o 'Tl :-;:J cc?-,JJ "r- "nit'l :DQ :,::) .t. --{C) -r'-j (''l:D 2::.~C-) orn -I ~ -< ~ '.0 ~J) .Jl