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HomeMy WebLinkAbout01-05992 . . . "'-" , ~, ,>.. .'--; ,',', ""_c',_,"" <"_",,,,,->;~;.i.;,,,,(-;'" ,,-,;-':'M-_'~~ ';--~"~iIIi- --"-'-i!;ji~\;-' . . . . . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY . . . . . . STATE OF . . . . ROBERT L. MYERS, . . Plaintiff . . VERSUS . CRYSTAL A. MYERS, . . Defendant . AND NOW, . PENNA. NO. 2001-5992 CIVIL DECREE IN DIVORCE ~'JJ, DECREED THAT ROBERT L. MYERS . CRYSTAL A. MYERS AND . . ARE DIVORCED FROM THE BONDS OF MATRIMONY. . . f 'l:3r A.}t. 2004, IT IS ORDERED AND , PLAINTIFF, , DEFENDANT, 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; ~ No,.)l:: - c't!ept- ~ ~~(.~t! ~~i~l ~tt1e~..,.)i ~UtJVIt~t IS LJ~~ ......~ ~ '1A.tf)~~ to a. Of , . . . . . . . . . . . . . . . ATTEST: . . . PROTHONOTARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J. . . . . . . . ~' e_ ~'~~.&li1i~~~~~.h%;-_~~liiW'; -'~L ~ ~ ".~-r.:P- ~~.rp , " /!5 ~ ,__ =~,_ ~__~,,'~_~..~".,,"".c'A' __,~_""'r"""'_"". ~_. _. -"'~~"'t';'~rjj"- -~-i'(" /j tP. [(> j /717- ["~ - 6 ,~."" ~~=-.,,~=-,~,~-"=-~, . ....w..w_, " d "I " --- - 't ~lll ~~, Mil~"l'~-,rJi'-w",:_ ROBERT L. MYERS, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2001-5992 CIVIL TERM CRYSTAL A. MYERS, DEFENDANT IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the Court for the entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: On October 22, 2001 by Acceptance of Service. 3. Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: By Plaintiff, September 16, 2004; By Defendant, September 14, 2004. 4. Related claims pending: None 5. Date Plaintiff's Waiver of Notice in S 3301(c) divorce was filed with the Prothonotary on September 16, 2004. Date Defendant's Waiver of Notice in S 3301(c) divorce was filed with the Prothonotary on September 16, 2004. ~~.~ Thomas D. Gould, Esquire Attorney For Defendant Yclii-- "il' - , '"",",.,~_'-"~<';';'~~".h''''='":i~~w~,4fi,""~~~""."""\'lfjIl~_-,-_~r ~. I. Ij 0 ,..., C = -' C = -n 3~. :- -~ (0 t:,C rli :I:--n ,. ~:;.' fl"iF '2':' -'tJ -nrn ./-- ;JJO ~;~ CT' .:).!. ~;:'~:: ~::j:1 .- -0 ~2.t~ ~~F',~ -1''' Q1f\~ :P'C s.? ?~ ..",. CJ ~Q -< .I:'" ~, 8 R;?l ~jf~",J";_"J$11ji!l!L\,~:,,,,~: ,~'L.rJJ,-JL.~_~~:: .4l!l1" j.~;'~\;i"';<ij.;:..Jl~~~H~I}t~':)1;:,.",.l; ~":""J~.f,)~J;:,.,~~~;b,J--"lL,l",."-~;.,,~.,,.~,, _"d''''''~ ",.,,,,,,,.,~'1)I'!""-'''-f .. _" ^"'-'.,l~ill.."_"" .N~" .~,=~:, '.",oN. __.W ~ -"~",,.''''''-. >-,< ="~,,;;.,,. , " - -,..- '''';''-''~",.~~,- no. 01- 5'99.2... ~ 'I::.... . and and MARRIAGE SETTLEMENT AGREEMENT THIS AGREEMENT made this li day of ~~~ ,2004, by between ROBERT L. MYERS, (hereinafter referred to as "Husband") CRYSTAL A. MYERS, (hereinafter referred to as "Wife"). WITNESSETH: WHEREAS, the Husband and Wife were lawfully married on June 1, 1985; and WHEREAS, differences have arisen between Husband and Wife in consequence of which they have lived separate and apart since May 5, 2000; and WHEREAS, two (2) children were born of this marriage, Jessica Marie Myers, born February 24, 1986 and Ryan William Myers, born June 14, 1996; and WHEREAS, Husband and Wife desire to settle and determine their rights and obligations; and NOW, THEREFORE, the parties intending to be legally bound hereby do covenant 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 party at such place or places as he or she may from time to time choose or deem fit. The foregoing provisions shall not be taken as an admission by either party as to the lawfulness or unlawfulness of the causes leading to their living apart. 2 . INTERFERENCE Each party shall be free from interference, authority, and contact by the other as fully as if he or she were single and unmarried except as maybe necessary to carry out the provisions of the agreement. Neither party shall molest the other nor attempt to endeavor to molest the other, nor compel the other to cohabit with the other, or in any way harass or malign the other, nor in any way interfere with the peaceful existence, separate and apart from the other, and each party hereto completely understand and agree that neither shall do nor say anything to the children of the parties at any time that might in any way influence the children adversely against the other party. . ~~~71 3 . DIVISION OF PERSONAL PROPERTY The parties have equitably divided between them to their mutual satisfaction the personal affects, household furniture and furnishings and all other articles of personal property which heretofore have been used by them in common. Neither party will make any claim to any items that are now in the possession nor under the control of the other. 4. AUTOMOBILES The parties own a 1955 Chevrolet purchased during the marriage. Husband is to be the owner of the 1955 Chevrolet. Husband shall have all right and title to his vehicle. He shall maintain insurance on his vehicle and be responsible for any and all maintenance, liens and other payments related thereto. Husband shall indemnify and hold Wife harmless for all matters related to his vehicle. Wife relinquishes all right and interest in the 1955 Chevrolet and agrees to cooperate in the transfer of the vehicle ti tIe. Wife is to remain the owner of her individually titled vehicle. She shall maintain insurance on her vehicle and be responsible for any and all maintenance, liens and other payments related thereto. Wife shall indemnify and hold Husband harmless for all matters related to her vehicle. 5. DIVISION OF REAL PROPERTY The parties own no real estate. 6. FINANCIAL ACCOUNTS, STOCKS, BONDS AND INVESTMENTS The parties haveequi tably divided their respective financial accounts, stocks, bonds, joint ventures, businesses and other investments. Each party shall maintain their separate accounts and investments and hereby release any interest they may . have in the other's accounts, stocks, bonds, joint ventures, businesses, real estate or other investments. 7. PENSION/RETIREMENT Husband has applied for and been approved for disability retirement from his former employer. Upon receipt of his back benefits disability check, but not later than September 5, 2004, Husband shall pay Wife $2,000.00 as her equitable share of his disability pension. In the event Husband's disability status is 2 '-'.'" n ,""'. " ~~.. ~~'1lf",," ""!~~~;::iJ-;'-.i"",&.4,;,.(",i . . changed so that he becomes eligible to withdraw his retirement contributions, he shall pay Wife $8,000.00 from any distribution. Husband shall notify his retirement administrator, OPM, of Wife's potent~al interest in Husband's distribution. If required, Husband and W1.fe will cooperate in obtaining and filing any documents required to protect Wife's interest in Husband's retirement or pension. In all other respects Husband and Wife shall maintain their separate pension and/or retirement accounts. Husband relinquishes any and all rights he may have in Wife's pension or retirement accounts and except as provided above, Wife relinquishes any and all rights she may have in Husband's pension or retirement accounts. 8. MARITAL DEBTS There are no joint marital debts. Husband shall be responsible for all marital debts solely in his name and Wife shall be responsible for all marital debts solely in her name. 9. ALIMONY, SUPPORT AND APL up any support, Each party hereby waives, releases, discharges and gives rights either may have against the other to receive . alimony pendente lite or alimony. 10. CUSTODY The parties agree that Wife shall have Legal Custody and Primary Physical Custody of their children with Husband having significant periods of Partial Custody as mutually agreed. Each party agrees to inform the other of the major parenting decisions affecting the child's health, education and welfare. Eachparty shall have the right to access the children's medical, educational and other records. The parties agree that the above custody arrangement may be changed by the mutual agreement of the parties or, if the parties are unable to agree, through legal action. 11. CHILD SUPPORT Husband shall pay Wife $ 600.00 each month, due and payable by the 5th of each and every month, for child support. The $600.00 monthly amount shall continue until Jessica reaches age 18 or graduates from high school, whichever last occurs. Upon that occurrence, Husband's obligation will be reduced to $400.00 per. month until Ryan reaches age 18 or graduates from high school, whichever last occurs. The amount shall not be subj ect to a decrease, but may be increased if Husband's income/earning capacity substantially changes. If Husband is late in his support payment Wife shall have the right to seek enforcement through a contempt action, a Support Order and wage attacnment. 3 . w' ~<, .Jj- "c.;, ,'~, ~ , ;, ,,'.i_-'I~;;; 12. FILING OF IRS RETURN . Husband and' Wife shall continue to file separate tax return for all subsequent years. 13. DIVORCE The parties agree to cooperate with each other in obtaining a final divorce of the marriage that Husband has filed, docketed at 2001-5992 CIVIL TERM. It is agreed that the parties shall promptly execute and allow to be filed the documents necessary to obtain an uncontested no-fault divorce. 14. . ATTORNEY FEES Each party shall be responsible for their respective attorney fees and costs. 15. INCORPORATION This agreement is to be incorporated into any subsequent Decree in Divorce. 16 . . CONTINUED COOPERATION The parties agree that they will wi thin fifteen days after the execution of this agreement, or request of the other party, execute any and all written instruments assignments, releases, deeds or notes or other writings as may be necessary or desirable for the proper effectuation of this agreement. 17 . BREACH If either party breaches any provlslon of this agreement, the other party shall have the right, at his or her election, to sue for damages for such breach, and the party breaching this contract shall be responsible for the payment of legal fees and costs incurred by the other in enforcing their rights under this agreement or for seeking such other remedies or relief as may be available to him or her. 18 . VOLUNTARY AGREEMENT The provisions of this agreement are fully understood by both parties and each party acknowledges that the agreement is fair and equitable, that it is being entered into voluntarily, and that it is not the result of any duress or undue influence. 4 . "~'- . ". .c'" , 'i~;~J,~~[.r{.- . . 19. WAIVER OF CLAIMS AGAINST ESTATES Except as herein otherwise provided, each party may . dispose of his or her property in any way, and each party hereby waives and relinquishes any and all rights he or she may now have or hereafter acquire under the present or future laws of any jurisdiction to share in the property or the estate of the other as a result of the marital relationship, including without limitation, dower, curtesy, statutory allowance, widows allowance, right to take in intestacy, right to take against the will of the other and the right to act as administrator/executor of the other's estate. 20. BINDING AFFECT This agreement shall be binding upon the parties' heirs, successors and assigns. 21. MODIFICATION AND WAIVER Any modification or waiver of any of the provisions of this agreement shall be effective only if made in writing and executed with the same formalities 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. 22. PRIOR AGREEMENTS It is understood and agreed that any prior agreements which may have been made or executed or verbally discussed prior to the date and time of this agreement are null and void. 23 . 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. 24. DESCRIPTIVE HEADINGS The descriptive headings used herein are for convenience only. They shall not have any binding affect whatsoever in determining the rights or obligations of the parties. 25 . APPLICABLE LAW This agreement shall be construed under the laws of the Commonwealth of Pennsylvania. 5 . "= '_'L "'~-"-'"''V-~'A~&~i.:~,; , ' 9-/0oC; Date q -{ Lf-d-f IN WITNESS WHEREOF, the parties Commonwealth of Pennsylvania: county of l?~ Date ss PERSONALLY APPEARED BEFORE ME, this I~day of ~ ,2004, a notary public, in and for the Commonwealth of Pennsylvania, Robert L. Myers, known to me (or satisfactorily proven to be) the person whose name is subscribed to the within agreement and acknowledged that he executed the same for the purposes herein contained. COMMONWEALTH OF PENNSYLVANIA Notarial Seal Robert J. Reese, Notary public Silver Spring Twp., Cumberland County My Commission Expires Aug. 10, 2008 Member, Pennsylvania Association of Notaries ;?,LJ-1;f.e,. ~ Notary puliiic commonwealth of Pennsylvania: County of ~ PERSONALLY APPEARED BEFORE ME, this /1 day of ~ ,2004, a notary public, in and for the Commonwealth of Pennsylvania, crystal A. Myers, known to me (or satisfactorily proven to be) the person whose name is subscribed to the wi thin agreement and acknowledged that she executed the same for the purposes herein contained. ss NWBAL: OF ENNSYLVANIA Notarial Seal . Robert J. Reese, Notary Public SIlVer Spring Twp., Cumberland County My Commission Expire. Aug. 10, 2008 MeMber, pennsylvania Association of Notaries IbJfll~ Notary Publici 6 ;;I~~~""iit{.j"*""""",I!-~>wl!!i<;~"*\1;,.&"-<ri1i!i"".i,",,,i>;~4~w'iifMt,,dt+iJ';io~l j"~_'i,',;,,,"!i"'",,,,'''~.d,''~.'''__iod~~''~''''''''''''''''"~~--=~-~'_._',..~._-"--------- - UJW. lU4:.b &> ~ ~..",,; ",,,,,_,,,,,~,,,",,,,,_,, O~ _''_n. -"""-,,;;., ,,- ~ p"_,""",___,~_~-",,,,"Y_.., ~ Q ~f. ".C(;'~' l;~ _," ,/.- ~~; ~;(~ );t.~ 7, :::( ,..., C~;:l c:;':) -" (/) rn --v C1' c> -<1 .-\ -y" ~r~ rnp -Mrn :ti'=;"J St) ;?;~,~ _..~ ~ :d.:: ~ -:"... (./-.:> ,-, ~- {,J.:>' -^ ~,,~, ---^ ",~ u " ' .--.--.-. .,' . _~ d__ ',-" , __: ROBERT 1. MYERS, Plaintiff, v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01- t:ttfd-..- CUlt <--r-~ CRYSTALA. MYERS, Defendant. CIVIL ACTION- DNORCE NOTICE TO 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 imp<>rtant to you, including custody or visitation of your child. 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 at the Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DMSION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DNORCE 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 LAWYER REFERRAL SERVICES 2 Liberty Avenue Carlisle; P A 17013 Telephone Number: (717) 249-3166 ,I 1\ - . ~- -- ROBERT L. MYERS, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01 -~99~ Qo~L'-r~ Plaintiff, v. CRYSTAL A. MYERS, Defendant. CIVIL ACTION- DIVORCE COMPLAINT UNDER SECTION 3301 (C) OF THE DIVORCE CODE COUNT I I. Plaintiff is Robert L. Myers, who currently resides at 500 Mumper Lane, Dillsburg, P A, York County, Pennsylvania. 2. Defendant is Crystal A. Myers, who currently resides at 1425 Apple Drive, Apt 141, Mechanicsburg, P A, Cumberland County, Pennsylvania 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on June I, 1986 in Mechanicsburg, PA, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the Parties. 6. The marriage is irretrievably broken. I II ., ;"'L~__:""",<~ >-: ,', , . .'-- . '~~""'~.. . I'"'~"'#~;;;,",;i 7. Neither Party is a member of the Armed Forces of the United States or any of its aIlies. 8. The Plaintiff has been advised of the availability of counseling and that either Party may compel the other by Order of Court to attend counseling sessions. WHEREFORE, Plaintiff respectfully requests that your Honorable Court enter a Decree in Divorce under Section 3301 ( c) of the Divorce Code. COUNT II--CUSTODY 9. The Plaintiff incorporates by reference Paragraphs I through 8 of the Complaint for Divorce as fully set forth herein. 10. There were 2 children born during this marriage, to wit: Jessica Myers, born February 24, 1986; and Ryan Myers, born June 12, 1996. II. During the past five (5) years, the children have resided with the following persons and at the following addresses: Person( s) Address Dates Crystal A. Myers 1425 Apple Drive, Mechanicsburg P A May 2000 to Present Crystal & Robert Myers 300 Mumper Ln, Dillsburg, P A May, 1995 to May, 2000 II II <'-. -~--~ - " -~ t-~"- - "'...~- -'~.d~2' 12. The Court of Common Pleas of Cumberland County, Pennsylvania, Family Division, has the sole and exclusive jurisdiction in this matter, pursuant to the Uniform Child Custody Jurisdiction Act, and the Commonwealth Child Custody Jurisdiction Act for the following reasons: a) Cumberland County, Pennsylvania, has been the children's home within six (6) months before the commencement of the instant proceedings. b) It is in the best interest and welfare of the children that the Court of Common Pleas of Cumberland County, Pennsylvania, assume jurisdiction because the children have a significant connection with this jurisdiction, and there is available in this jurisdiction substantial evidence concerning the children's present or future care, protection, training and person care and relationships. c) No other state has jurisdiction in this matter under the requirements of the Uniform Child Custody Jurisdiction Act and the Commonwealth Child Custody Jurisdiction Act. 13. The Plaintiff has not participated in any capacity whatsoever in any other litigation concerning the custody of the two (2) minor children in this or any other state. I, II _ 'H "'M , , ~-, ,~,. ~"'~r~?1;'",i'dJ", 14. The Plaintiff does not know if any other person than the Defendant herein claims to have custody or partial custody rights with the minor children. IS. The Plaintiff submits that it is in the best interest and welfare of the children that he be granted custody of the children, and that the Plaintiff can best provide the minor children with a more stable, healthful, religious, and proper environment. WHEREFORE, Plaintiff prays that the Honorable Court grant custody of the minor children of the Parties to Plaintiff. Respectfully submitted, Date: By: Ger S. Robinson, Esquire A orney LD. #27423 4407 North Front Street P.O. Box 5320 Harrisburg, Pennsylvania 17110-5320 (717) 232-8525 Attorney for Plaintiff ,I II -~;""'_'i -""",,,,.o,J.1.di1, VERIFICATION I verif'y that the statements made in this Divorce Complaint are true and correct. I understand that false statements herein are made SUbjf~enalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to aut1{orities./ , \ " ,I ,I . '. ROBERT 1. MYERS, Plaintiff, v. CRYSTALA. MYERS, Defendant. , ,'- ,- -:~~L~j:1 "0 ~--~ .."~ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL V ANlA NO.00391-S-2000 CIVIL ACTION- DIVORCE CERTIFICATE OF SERVICE I, Gerald S. Robinson, Esquire, do hereby certify that on the /;;{ tf, day of ()d.o&r ,2001, I caused a true and correct copyofthe Divorce Complaint to be served upon the following individual by first class mail by depositing same in the United States, postage prepaid, in Harrisburg, Pennsylvania. :1 II Maryann Murphy, Esquire 8 Irvine Row Carlisle, P A 17013 ~ ~ By: Ger S. Robinson, Esquire ROBINSON & GERALDO ATTORNEY J.D. NO. 27423 4407 North Front Street P.O. Box 5320 Harrisburg, P A 17110 (717) 232-8525 ~~i1lI.~I;"W'-- . "~~~~'I~"<ilif4';;lt"",J"'iliM.<&'W;4;0;j.j,fii~Mj--'-' ~ '.H*' , '<"'""""~"''''Tl't~~Wiii-..;,:.d'~ ",-,--"',- - ,,-- - ~:'.' ~ -6q, ~ ~ ~ 'i \i- .c: 6"- ....... ........ 0 ~ ~ Q D ~ </) C " ~ .~ ~~~,- Q -rJtn ........ ~ Q1u; C) ~ .::::- 1v () ....oj ~., B () Z:.:c ~ 0 C) C/) 2~r-- (:} U~=-:'; CD .- (i'- j 0 ~ ..... I I ~C; ,"" ~ I ' - >'-, ~ ;~;~ .~r~ ~ ~ Z' :x r 0 5>C \.0 C)r-n '--(t. '<; z ~ ~ c- p (JI :0 -< .11,!..1,..1] _ "_"7'_~'''(J;;\.w~.,,~~'1f'_ ..,.,J,o' "-~l"JL.u,,, ,"",,'0,"'.""""'" ~~ - .~.=__~, ,_"o,.>,~". "'''-. ~ _~" .7'.=", ,'~_'-~~,__,."w_..~~~_,c_. - "~. c.... .,'~~ ,",-,.' >' < y_.~"~ .,,--~- 'iGi,~i'~:4:N" ROBERT L. MYERS, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2001-5992 CIVIL TERM CRYSTAL A. MYERS, DEFENDANT IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on October 18, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a Final Decree of Divorce after service of notice of intention to request entry of the decree. I acknowledge that pursuant to Rule 1920.42 (e) I have waived the requirement that I receive 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 subject to the penalties of 18 Pa. C.S. DATED: c; -/ t; - 0 C( unsworn falsification to authorities. ROBERT L. MYERS ~;;j~'i:;1~;id'l6il-W""1is.",';;""3dl;,b,iit:\'~<h""""-"''''''')'i'''ilM>;".'~:;ti~''~ll:.t_"",'1.j.'=',,",,^61-b,-" <;__,""_,"_l"-;,_,,,,,,,:_,o:,,,;,"elt~i,:.o-,~;,-tlc"Jl'iIli~~_,,~~~3Mii~~"fd ~ ~_~, ..',"....'~".<,~,'""""""b ;:(5 I!(d o~_ "'___~~"_"__ ",,~~~~. <.~ ..t.,~~_~=-. .",y _~~o~=' " .~~~ ,_".~ v, ~. ""' ~ '"'(.-'0':' ~T!j -.c' ,.-- ....~_.. .' u,_;- f ch,/ -<. ~- '--' ~f: 2: --' -< ..., = = ..,- if) rn "'u o -;, -< rfle. -nIl, :;:lY S~! ~~, :::0, ~1-:>- :0 -< 0-, -0 "';"4 w o v.l ,. ., ,lidiiim;i,'li;'b,,'f.. ROBERT L. MYERS, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2001-5992 CIVIL TERM CRYSTAL A. MYERS, DEFENDANT IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on October 18, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a Final Decree of Divorce after service of notice of intention to request entry of the decree. I acknowledge that pursuant to Rule 1920.42 (e) I have waived the requirement that I receive 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 subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: Q/16/olj ( ~~~i:a'iii!ill\is~~~~~~~W.",,",--...a.J""","'''''i."~i''''"NiWi';:'''.''''!Jt'''>liij.,'i'..Jil'>l.''= ,~,&~_~.JJ IDlillLL . .,."" o..""",,,o~,,,,,^,,,,,"'C,,,,,, .~."~., ,=~.~.., -'__~, "'-'_" "", -".'"., "'. e:5 I!!.;/t "~_ ",~>il', ,<\C. <.<, ~ '"."\ " - .< ". " --~.., ,,- .~-, ,~" "'~'-, ,. ~-" () '" C.::;J 0 C C-? ., .- .r- '-c1 tf: C/l -1 rn !>. rri ::r: .~ -'0 tnfI Z~ -fjrn (f) . ~~;iy -< cr, ~ C)c- <: ::;1..'-"'! J> " ' " / -", ~~~ ).:;. ',~" :5 nl ,~.- (,0 :Z -~ -.; <=> :P.!. .-< .'-' C,~ -< ',."""-',. "-,,,'^,- . " ~w '" -'"'-- '''" -~"'~'i~;ll<f, ROBERT. L. MYERS, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2001-5992 CIVIL TERM CRYSTAL A. MYERS, DEFENDANT IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301/c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree 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 state nts herein are subject to the penalties of 18 Pa. C.S. Section ~90 relating to unsworn falsification to authorities. DATED: r -If( ~C/( ~: ~l~"~,~'i:ill<~t'~'"J.Ml'~~~\!1/iii,j_#~~i~;;'\;cll0i:J;,""~:"~,-, :;.F,'c """"h~~g1':'!."E'<l.-JlliM~ji,'l!;r~tii.._l!IiIl ~,' ,,,- ~\>.W"J~ilil!;;;!Il;@~__ lIL!!l! -"- ~- ,".. ~ ,,~ .~~"" ?5 ea ~_ ~"_<~___~~,~~__.>~" ,,~o~ '"" ~~",_c _~,~.O ('") '"-' c; = c: = --n -.,.- .c- -t "Tl 1,'lJ t/> -r__o. n-:p f"'lj 01p.1 ;;~ e. -0 -Off: ",~~ . ,% r~ 0', "";; ~ -, C- ..~ -c '}> C'/ ::..-:: ;?-. C' >- C:f? ~ c: ::---: ~ c:> :D. - -<. - - ~ ---~ , ~ ,~ t' ~'-_~.i":. ROBERT L. MYERS, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2001-5992 CIVIL TERM CRYSTAL A. MYERS, DEFENDANT IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301/0) OF THE DIVORCE CODE 1. I consent to the entry of a final decree 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 subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: 0, IlbJO,! , "~~ ~~,,",,",,_.,.k'>"'_ ROBERT L. MYERS, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2001-5992 CIVIL TERM CRYSTAL A. MYERS, DEFENDANT IN DIVORCE ACCEPTANCE OF SERVICE I, Crystal L. Myers, accept service of the Divorce Complaint in the above captioned matter. Dated: 101 dd /.4DO I I I ~ Crystal L. e . 165 ! 5th Street New Cumberland, PA 17070 DEFENDANT . -'. ~ ~ ~,~. "",,'''';~r_.Ji.0~ii2:';:';--' , " ROBERT L. MYERS PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA V. 01-5992 CIVIL ACTION LAW CRYSTAL A. MYERS DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Thursday, November 01, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. at 39 West Main Street, Mechanicsburg, PA 17055 on Tuesday, November 27, 2001 , the conci]iator, at 1:00 PM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Fai]ure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish auy and all existing Protection from Abnse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: Isl Dawn S. Sunday. Esq. ~ Custody Conciliator The Court of Connnon Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of ]990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HA VB AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlis]e, Pennsylvania ] 70 13 Te]ephone (717) 249-3]66 '>'.""""~".."" "~,,, "-",'0..'. ~< ,_-,~ .-""_L' '~,.',"'- ,_ -~,' Jf. /-,f// /1- / -CJ/ ;' ~~'_L - '~~~, ",,' <,,,~;,, "-'" ,->.!.",,,,,,,,~,,.~,, ,'-",,""""-'"'_:".>;-c">'" ~, -~',,""",:._,"~'~",,'''' .""-""-"~,~~.,,,,,,.,">><>~.,,,,,,,~-,-.",,,,,,~,,, "ilCfiW ()~ /-7c!7 s.-;"'~ ..:7' 01 m.':!-I J:\['t il: S7 C111\"C:::,::-: ':-,,:-'- ('(')' i\ITv' Ul'ltu,__~ ;d-\i '~l.J ..J,-, lJl... I PENi\!SYLWNI/\ w~~~a!f~~ ~~ 74~ ~ l~r,__~~~~.}w~"~,:-;,,,~'''-P";~~''-'r''-'l~''''-':"-'"''f'__"f'f"~"'C<<~"':i!.t"'m:,m'''''~'''''ffI~~'f"''~:\'l:-HAAI'llfll'foj'l'''I_1''i-1!'!'!;fi'j;~,~~.ffi>'ll!~ < '.' " , " .~ - ,,~,,'-,,-"~'_ ,"'. 'f. .::" - ,;.. ;\~;' (,.. ~ OCT 2 2 20011\ 'il-" , ." \) . ROBERT L. MYERS, Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. OJ -s-q9~ e,utL ~~ v. CRYSTAL A. MYERS, Defendant. CIVIL ACTION -CUSTODY ORDER OF COURT AND NOW, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before , on the day of ,2001 at ,in the ,for the Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the Court, and to enter into a Temporary Order. Failure to appear at the conference may provide grounds for the entry of a temporary or pennanent Order. For the Court, Date: By: Custody Conciliator I II II - ,j "._-C ~ , , ROBERT L. MYERS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. ()I -~9~C;~IC-T~ Petitioner, v. CRYSTAL A. MYERS, Respondent. CIVIL ACTION- CUSTODY PETITION TO CONFIRM CUSTODY Petitioner, Robert L. Myers, by and through his attorney Gerald S. Robinson, Esquire, and the law firm of ROBINSON & GERALDO, respectfully requests the following: 1. Respondent is Crystal A. Myers, an adult individual and the natural Mother who is currently resides at 1425 Apple Drive, #141, Mechanicsburg, P A. 2. Petitioner is Robert L. Myers, an adult individual and the natural Father who currently resides at 500 Mumper Lane, Dillsburg, P A. 3. Petitioner seeks legal custody of Jessica M. Myers, born February 24, 1986, and Ryan W. Myers, born June 14, 1996, currently residing with the Respondent. The children were not born out of wedlock. 4. The children are presently in the custody of Respondent, Crystal A. Myers. II II -, ...J~'ili- '" '-'ti.,, '-I"'-<"-_~,;2 5. During the past five years, the children have resided with the following persons and at the following addresses: Person( s) Chrystal A. Myers Chrystal & Robert Myers Address Dates 1425 Apple Drive, Mechanicsburg P A May 2000 to Present 300 Mumper Ln, Dillsburg, P A May, 1995 to May, 2000 6. Petitioner has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. 7. Petitioner does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 8. The best interest and permanent welfare of the children will be served by awarding Custody to Petitioner Robert 1. Myers. 10. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as a party to this action. I .-:;~ , ~ "' WHEREFORE, the Petitioner respectfully requests this Honorable Court to grant Custody to Petitioner. Respectfully submitted, ROBrn~ By: ( Gerald S. Robinson, Esquire Attorney J.D. No. 27423 4407 North Front Street P.O. Box 5320 Harrisburg, Pennsylvania 17110 (717) 232-8525 Attorney for Petitioner II "- '-lIul;'-~"- ~~~~ -~~'.- "' ~-- "-,;-;'.;;i~J . , VERIFICATION I verify that the statements made in this Petition for Custody are true and correct. I understand that false statements herein are made subject e enalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. I / I l~~' lY'l1'IIl~'iiai .", - .''; o t?~ '-'<>""'~""""';'''~:~:W'iit''f'2,;(.h'7i",_-hil"i''!;;'.ilt.".,).;iu',oll,j-~~tj' ----Mill'ilJ$: -,. IN' ill :iUt,,U!,J}la-,,-_'!,L.,,~ ,~lm,tl .- _~_ Jjl~~J.__..,)J-;"~,;:,.:"",;,~,, -,.,,~,_~,"J 1~jJJl>>J%; ,,;,~,!(~~,',P'-~'1'-'4"'P,_MF,," :<>,~. ',,'- ,_>_ '__~"'''~<'~''~''''''''''''''"".,., .", ,_ ,'. '"~ _,r. ,; .._ ~,", ~~, ~" 0 0 CO c: "'.~, s: 0 -ODe C") t'})f.I! '-1 Tj ""-"J_' r: ~~~ " CO " :,::,~) r' U 9(~) ;E; ,. "., ~ ::K ~~.~2 --i-i z , , , .-) 5> 0 cD t~ iTI C Z r:- 52 --< -< D (J1 '< ...'O~,,~ _" ..~ ,--- ~'''''''''''''''~'''''101b1;'; ROBERT L. MYERS, Plaintiff, v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. ()I-SW~ C;(..)~l ~ CRYSTAL A. MYERS, Defendant. CIVIL ACTION- DIVORCE CERTIFICATE OF SERVICE I, Gerald S. Robinson, Esquire, do hereby certifY that on the 1:< ih day of ocloiuA. , 200 I, I caused a true and correct copy of the Petition to Confirm Custody to be served upon the following individual by first class mail by depositing same in the United States, postage prepaid, in Harrisburg, Pennsylvania. Maryann Murphy, Esquire 8 Irvine Row Carlisle, P A 17013 , By: Gerald . Robinson, Esq re ROB SON & GERALDO ATTORNEY LD. NO. 27423 4407 North Front Street P.O. Box 5320 Harrisburg, P A 171 10 (717) 232-8525 ;tJ~ -:~-:''! ;~-~.~~~.iI~1Jjj-n ~'~l!iIi~~Jig,,",,,,,,,;.,,,,,,M,,;~l!lliil_1iiil!;tilt ~"" ., ".- .,;' ~,.;, "*t:.Il..JIi'IHl <, fr""N. "'. \II () 0 0 c t: :;;: "q C) ';-J -ocr; n mrn ...... T:pD 2;:0 t;<; :!~(~ co """'-r-" -<:::::.: -. , ~C:; ~ ~~~ )0- :J1:: '~--~! E3 z''-'' $2 1..0 ;"':;rl' ~, Z c- o;ci =<! :D en -< !.. "~ .~. ~- ,_".__w_ >__'O"~'_"~_ ,~~__ ,." >C"~ ~.-, ~'~IU ~.~;. l'",~,~"""-",",,,,,d=,c NOV 3 0 2001 \,0 ROBERT L. MYERS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 01-5992 CIVIL ACTION LAW CRYSTALA. MYERS, Defendants IN CUSTODY ORDER OF COURT AND NOW, this 27TH day of November, 2001, the Conciliator, being advised by Plaintiff s counsel that all custody issues have been resolved by agreement of the parties, hereby relinquishes jurisdiction in this case. The Custody Conciliation Conference scheduled for today is canceled. FOR THE COURT, Q'A-/~ Dawn S. Sunday, Esqmre Custody Conciliator .<"W~,^' ._,-,^"..". .~ """,M~'"',..,," "',('1' ""1f"'\'"rllli1ill')ln~'''''I't]''''A''n''ill"-' '",,,', ,.,. '1 Inn~IH'T "rrTI' ljg (') ~; -D;-~- n-ll, ~~~':... .c,:::'i.. (!.: 0:: - f~(., - ~,. '::-'-"!'. ~~;~~ C) ~, '--' '-"I C) ~~-.~ -< \LJ __~_.~.~_P-""""..,o_~_~.,=!A\Ill!l!I _' ^" ,~l!tlrf_. _ 1!f~r;';"<'1>""''-~'':~'''J:''''''''FA:i''W''1~''"'''''~''f''~~~$O',filf~~MI~~~:m:!\1!i!I~~ ~~ , . , . . , , , , , , , . , . , , . , , . , , , , , , . , , . , . . , , , . , , , . , , .' , , , , , . , , . , , , , . . , , . . , , , , , , , , , , . ~ . , , , , , , , , , , , , , , , . , , , , . , , , , , '+':+.:+::+: , " " , " , :+:::+:: :Ii;!;'" :+:;F. Of.;t; :+::;I\;I;:+: , . fIi:+::+: :+:::f.:+:: :+: :+::+::+:::+::+::+:", , , , , , , , , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. ROBERT L. MYERS Plaintiff No. 2001-5992 VERSUS CRYSTAL A. MYERS Defendant DECREE IN DIVORCE 09:35 AM AND NOW September23 , 2004 , IT IS ORDERED AND DECREED THAT ROBERT L. MYERS , PLAINTIFF, AND CRYSTAL A. MYERS , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. , , ~ . , . , , , , . , , , , , , . , , , , , , , , , , , , , , , , , . ~ , , . , :+:: :+::+::+::+::+::+::+::+::+:::+:::+::+:: "':of. ~ 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; NONE - Except that attached Marital Settlement Aareement is Incorporated herein pursuant to its terms (No. 15) By THE COURT: Edward E. Guido ATTEST: Certified Copy Issued: PROTHONOTARY September 23. 2004 :+::+: :+: :f.:+::f. :+::+: :+:: :+:::+:::+::of. :+:::+: :+::+:::+::+::+:::+::+: :+::+::+::of. Of. :!':;Ii:+: , , , , , ~"I , , . , , , , , , . , . , , , , , , , , , , . , , , . , , , , , , ~ . , , , , , , , , , , , , J. ~,.;;