HomeMy WebLinkAbout01-06804
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IN THE COURT OF COMMON PLEAS .
.
OF CUMBERLAND COUNTY
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.
PENNA.
STATE OF
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JODIE BETH KLINE,
.
NO.
01-6804
Plaintiff,
VERSUS
PAUL JOSEPH GEFFERT,
.
Defendant
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.
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DECREE IN
DIVORCE
AND NOW,
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IT IS ORDERED AND
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DECREED THAT
JODIE BETH KLINE
, PLAINTIFF,
AND
PAUL JOSEPH GEFFERT
, DEFENDANT,
ARE DIVORCECl 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; ~
'I'HR 1I'1''I'IIf'HRn MIIRT'I'IIT. PROPRR'I'V !':R'I''I'T.RMF.N'I' II~RRRMRf'\T'I' nll'l'F.T)
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FEBRUARY 24, 2003 IS INCORPORATED, WITHOU
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BY THE .40UR .
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ATTEST:
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PROTHONOTARY
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MARITAL PROPERTY SETTLEMENT AGREEMENT
THIS AGREEMENT is entered into this twentv-fourth day of February 2003, by and
between JODIE BETH KLINE and PAUL JOSEPH GEFFERT.
RECITALS
Wife's Birthday and Social Security Number:
October 3,1964
190-54-8564
Husband's Birthday and Social Security Number:
November 28,1963
196-38-6476
Date of Marriage:
April 7, 1990
Place of Marriage:
Harrisburg, Pennsylvania
Last Marital Residence:
28 Evergreen St. Apt. C3. Thompsontown, P A 17094
Date of Separation:
December 1, 2002
Children:
Two (2):
Evan David Kline-Geffert. born on October 8,1994
Owen Paul Kline-Geffert. born on May 19. 1999
Pending Court Proceedings: Divorce
Court of Common Pleas No. 01-6804 Civil Term
of Cumberland County, Pennsylvania
WHEREAS, diverse unhappy differences, disputes and difficulties have arisen between the
parties and it is the intention of Wife and Husband to live separate and apart for the rest of their natural
lives, and the parties hereto are desirous of settling fully and finally their respective financial and
property rights and obligations as between each other including. without limitation: the ownership and
equitable distribution of marital property; the past, present and future support. and/or maintenance of
Wife by Husband; and. in general. any and all claims and possible claims by one against the other or
against their respective estates.
NOW, THEREFORE, in consideration of the premises and of the mutual promises. covenants
and undertakings hereinafter set forth and for other good and valuable consideration. receipt of which is
hereby acknowledged by each of the parties hereto, Wife and Husband. each intending to be legally
bound hereby, covenant and agree as follows:
ORIGINAL
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PERSONAL RIGHTS
Wife and Husband may and shall. at all times hereafter, live separate and apart. They shall be
free from any contact. restraint. interference or authority, direct or indirect. by the other in all respects as
fully as ifthey were unmarried. Each may. for his or her separate use or benefit. conduct, carry on and
engage in any business. occupation, profession or employment which to him or her may seem advisable.
Wife and Husband shall not molest, harass, disturb or malign each other or the respective families of
each other nor compel or attempt to compel the other to cohabit or dwell by any means whatsoever with
him or her.
WAIVER OF RIGHTS AND MUTUAL RELEASES
Except as otherwise expressly provided by this Agreement:
(a) Each party hereby absolutely and unconditionally releases and forever discharges the other
and the estate of the other for all purposes from any and all rights and obligations which either may have
or at any time hereafter have for past, present or future support or maintenance. alimony pendente lite,
alimony. equitable distribution, counsel fees, costs, expenses and any other right or obligation, economic
or otherwise, whether arising out of the marital relationship or otherwise. including all rights and
benefits under the Pennsylvania Divorce Code of 1980, its supplements and amendments, as well as
under any other law of any other jurisdiction. except and only except all rights. agreements and
obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of
any provision thereof. Neither party shall have any obligation to the other not expressly set forth herein.
(b) Each party hereby absolutely and unconditionally releases and forever discharges the other
and his or her heirs. executors. administrators, assigns, property and estate from any and all rights,
claims, demands or obligations arising out of or by virtue of the marital relationship of the parties or
otherwise, whether now existing or hereafter arising. The above release shall be effective regardless of
whether such claims arise out of any former or future acts, contracts, engagements or liabilities of the
other or by way of dower, curtesy, widow's rights, family exemption or similar allowance, or under the
intestate laws, or the right to take against the spouse's will, or the right to treat a lifetime conveyance by
the other as testamentary, or all other rights of a surviving spouse to participate in a deceased spouse's
estate, whether arising under the law of Pennsylvania, any state, co=onwealth or territory of the
United States, or any other country. It is expressly understood, however. that neither the provisions of
this release nor the subsequent entry of a divorce decree are intended to defeat the right of either party to
receive any insurance proceeds at the death of the other of which she or he is the named beneficiary
(whether the beneficiary designation was made prior or subsequent to execution hereof), nor to defeat
the right of either party to receive any legacy. bequest or residuary portion of the other's estate under his
or her will, or to act as personal representative or executor if so named by the will of the other, whether
such will was executed prior or subsequent to this Agreement.
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(c) Except for any cause of action for divorce which either party may have or claim to have or
claim to have, and except for the obligations of the parties contained in this Agreement and such rights
as are expressly reserved herein. each party gives to the other by the execution of this Agreement an
absolute and unconditional release and discharge from all causes of action, claims. rights or demands
whatsoever. in law or in equity. which either party ever had or now has against the other.
FINANCIAL DISCLOSURE
The parties have disclosed to each other and they are each aware of the extent of each other's
income, assets, liabilities, holdings and estate.
AGREEMENT TO BE INCORPORATED
BUT NOT MERGED INTO DIVORCE DECREE
In the event that either of the parties shall recover a final judgment or decree of absolute divorce
against the other in a court of competent jurisdiction. the provisions of this Agreement may be
incorporated by reference or in substance but shall not be deemed merged into such judgment or decree.
This agreement shall survive any such final judgment or decree of absolute divorce, shall be entirely
independent thereof, and the parties intend that all obligations contained herein shall retain their
contractual nature in any enforcement proceedings. whether enforcement is sought in an action on the
contract itself or in any enforcement action ftled to the divorce caption.
EFFECT OF DIVORCE DECREE ON AGREEMENT
Either party may enforce this Agreement as provided in Section 3105(a) of the Divorce Code, as
amended. As provided in Section 31 05( c), provisions of this Agreement regarding equitable
distribution, alimony, alimony pendente lite, counsel fees or expenses shall not be subject to
modification by the court.
Concurrently with the execution of this Agreement. the parties shall sign Affidavits of Consent
and Waivers of Notice of Intention to Request Entry of Final Divorce Decree. Husband shall be
responsible for ftling these documents and finalizing the divorce.
DATE OF EXECUTION
The "date of execution" or "execution date" of this Agreement shall be defined as the date upon,
which it is executed by the parties if they have each executed the Agreement on the same date.
Otherwise, the "date of execution" or "execution date" of this Agreement shall be defined as the date of
execution by the party last executing this Agreement.
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ADVICE OF COUNSEL
The provisions of this Agreement and their legal effect have been fully explained to the parties
by their respective counsel, Lester Zimmerman. Esquire, for Wife and Matthew J. Eshelman, Esquire.
for Husband. The parties acknowledge that each has received independent legal advice from counsel of
their selection and that they have been fully informed as to their legal rights and obligations, induding
all rights available to them under the Pennsylvania Divorce Code of 1980. as amended and other
applicable laws. Each party confirms that he or she fully understands the terms. conditions and
provisions of this Agreement and believes them to be fair, just, adequate and reasonable under the
existing circumstances.
VOLUNTARY EXECUTION
Each party understands the terms and conditions of this Agreement and acknowledges that the
Agreement is fair and equitable. The parties have reached this Agreement freely and voluntarily, without
any duress, undue influence, collusion or improper or illegal agreements.
WAIVER OR MODIFICATION TO BE IN WRITING
No modification or waiver of any of the terms hereof shall be valid unless in writing and signed
by both parties and no waiver or any breach hereof or default hereunder shall be deemed a waiver of any
subsequent default of the same or similar nature. Notwithstanding this provision, under applicable
Pennsylvania law, the parties understand that any provision of this Agreement relating to child support
or to custody shall be subject to modification by the Court upon a showing of changed circumstances.
LAW OF PENNSYLVANIA APPLICABLE
This Agreement shall be construed in accordance with the laws of the Commonwealth of
Pennsylvania.
AGREEMENT BINDING ON HEIRS
Except as may otherwise be provided, this Agreement shall be binding and shall inure to the
benefit of the parties hereto and their respective heirs, executors, administrators, successors and assigns.
INTEGRATION
This Agreement constitutes the entire understanding of the parties and supersedes any and all
prior agreements and negotiations between them. There are no representations or warranties other than
those expressly set forth herein.
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ADDITIONAL INSTRUMENTS
Wife and Husband covenant and agree that they will forthwith (and within at most ten (10) days
after demand therefor) execute any and all written instruments, assignments, releases. satisfactions.
deeds, notes or such other writings as may be necessary or desirable for the proper effectuation of this
Agreement.
NO WAIVER OF DEFAULT
This Agreement shall remain in full force and effect unless and until terminated under and
pursuant to the terms of this Agreement. The failure of either party to insist upon strict performance of
any of the provisions of this Agreement shall in no way affect the right of such party hereafter to enforce
the same. nor shall the waiver of any breach or any provision hereof be construed as a waiver of any
subsequent default of the same or similar nature, nor shall the waiver of any breach of any provision
hereof be construed as a waiver of strict performance of any other obligations herein.
SEVRABILITY AND INDEPENDENT AND SEPARATE COVENANTS
The parties agree that each separate obligation contained in this Agreement shall be deemed to
be a separate and independent covenant and agreement. 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. 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. Likewise. the failure of any
party to meet her or his obligations under anyone or more of the paragraphs herein, with the exception
of the satisfaction of any conditions precedent, shall in no way avoid or alter the remaining obligations
of the parties. .
MANNER OF GMNG NOTICE
Any notice required by this Agreement to be sent to Wife shall be sent by certified mail, return
receipt requested, to Lester Zi=erman, Esquire, 416 Orange Street. Mifflintown, P A 17059
or such other address as Wife from time to time may designate in writing.
Any notice required by this Agreement to be sent to Husband shall be sent by certified mail,
return receipt requested, to Matthew J. Eshelman, Esquire, Law Offices of Patrick F. Lauer. Jr., 2108
Market Street, Camp Hill, P A 17011 or such other address as Husband from time to time may designate
in writing,
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HEADINGS NOT PART OF AGREEMENT
Any headings preceding the text of the several paragraphs and subparagraphs hereof are inserted
solely for convenience of reference and shall not constitute a part of this Agreement nor shall they affect
its meaning. construction or effect.
BANKRUPTCY OR REORGANIZATION PROCEEDINGS
In the event that either party becomes a debtor in any bankruptcy or financial reorganization
proceedings of any kind while any obligations remain to be performed by that part for the benefit of the
other party pursuant to the provisions of this Agreement, the debtor spouse hereby waives. releases and
relinquishes any right to claim any exemption (whether granted under state or federal law) to any
property remaining in the debtor as a defense to any claim made pursuant hereto by the creditor-spouse,
and the debtor-spouse hereby assigns, transfers and conveys to the creditor-spouse an interest in all of
the debtor's exempt property sufficient to meet all obligations to the creditor-spouse as set forth herein,
including all attorneys' fees and costs incurred in the enforcement of this Paragraph or any other
provision of this Agreement. No obligation created by this Agreement shall be discharged or
dischargeable, regardless of federal or state law to the contrary. and each party waives any and all right
to assert that any obligation hereunder is discharged or dischargeable.
EFFECT OF RECONCILIATION OR RECONCILIATION ATTEMPT
This Agreement shall remain in full force and effect even if the parties reconcile, cohabit as
husband and wife, or attempt reconciliation. This Agreement shall continue in full force and effect and
there shall be no modification or waiver of any of the terms hereof unless the parties, in writing. signed
by both parties, execute a statement declaring this Agreement or any term of this Agreement to be null
and void.
EXISTING AND FUTURE PERSONAL OBLIGATIONS
Further, Wife and Husband each covenant, warrant, represent and agree that neither has
heretofore contracted for any debt, liability or obligation for which the other or the estate of the other
may be responsible or liable except as specifically disclosed and provided for by the terms of this
Agreement. The parties further covenant. warrant, represent and agree that each will now and at all
times hereafter save harmless and indemnify the other and the estate of the other from all debts, charges
and liabilities incurred after the execution date hereof. except as may be otherwise specifically provided
herein. as well as from all debts. liabilities or obligations of every kind which have been incurred
heretofore by either party, including those for necessities, except for obligations arising out of this
Agreement.
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ENFORCEMENT
The parties intend that this Agreement shall be subject to enforcement under the Peunsylvania
Divorce Code of 1980, as amended. and that, notwithstanding any language herein that may be
construed to the contrary, this Agreement is not subject to modification except under such terms as the
parties have specifically provided for in this Agreement.
ENFORCEMENT OF SUPPORT AND ALIMONY PROVISIONS
The parties hereby agree that all of the support and alimony provisions contained in this
Agreement (including both direct and indirect contributions to support and alimony. such as health care
payments and the maintenance of health and/or life insurance) may be enforceable by an action in
support in accordance with Peunsylvania Rules of Civil Procedure 1910.1 et seq.
REMEDIES AND SANCTIONS
In addition to such other remedies and sanctions available under applicable law, the parties may
utilize any remedy or sanction set forth in. the Pennsylvania Divorce Code. as amended, to enforce any
term of this Agreement as though it had been an order of the Court.
ATTORNEY'S FEES FOR ENFORCEMENT
In the event that either party breaches any provision of this Agreement and the other party retains
counsel to assist in enforcing the terms thereof, the parties hereby agree that the breaching party will pay
all attorney's fees incurred by the other party in enforcing the Agreement. provided that the enforcing
party is successful in establishing that a breach has occurred.
EQUITABLE DISTRIBUTION
1. PERSONAL PROPERTY
Husband and Wife do hereby acknowledge that they have previously divided their tangible
personal property including. but without limitation, jewelry. clothes, furniture, furnishings, rugs. carpets,
household equipment and appliances, pictures, books, works of art and other personal property; and
hereafter Wife agrees that all of the property in the possession of Husband shall be the sole and separate
property of Husband; and Husband agrees that all of the property in the possession of Wife shall be the
sole and separate property of Wife. Wife will receive bubble glass back from husband to determine what
she wants. The parties do hereby specifically waive, release, renounce and forever abandon any claims,
which either may have with respect to the above items, which shall hereafter be the sole and exclusive
property of the other.
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2. MOTOR VEmCLES
A. Wife shall keep her 1995 Nissan Quest. Husband and Wife agree to cooperate in having this
vehicle titled solely in Wife's name. Husband will pay off the vehicle using portion of Wife's proceeds
from the sale of the marital residence (855 Acri Road, Mechanicsburg, Pennsylvania. 17050). Wife
agrees to be solely responsible for all loans, expenses and insurance for this vehicle. This vehicle shall
hereinafter be the sole and exclusive property of Wife.
B. Husband shall keep his 2000 Toyota Corolla, titled in his name. Husband agrees to be solely
responsible for all loans, expenses and insurance for this vehicle. This vehicle shall hereafter be the sole
and exclusive property of Husband.
C. The parties agree to execute any documents necessary to effectuate the provisions of this
Paragraph on the execution date hereof. including Vehicle Sales and Use Tax Returns as necessary to
make any conveyances on a tax-free basis if possible. The said documents shall be delivered to the
party entitled to receive same pursuant hereto on execution date.
D. In the event that any documents of title to the vehicles shall be in the hands of a bank: or other
holder of a lien or encumbrance upon either of the vehicles, and it is intended that
such vehicle be conveyed subject to said lien or encumbrance, the parties agree that they will advise the
bank: and/or lien holder as to the transfer of title and they further agree to execute whatever documents
may be required to transfer title where the parties' documents of title are in the ands of such bank: and/or
lien holder.
3. BANK ACCOUNTS
The parties had joint checking and savings accounts with Members First. The parties herby
agree all of the funds contained in their joint checking and savings accounts have been used to payoff all
marital debt. These accounts have been closed.
The parties agree that they will execute any documents necessary to effectuate the provisions of
this Paragraph on execution date.
4. RETIREMENT INTEREST
Husband has a retirement/pension plans with Dauphin County, Pennsylvania, and Cumberland
County, Pennsylvania. Wife herby agrees to specifically release and waive any and all interest, claim or
right she may have in Husband's retirement/pension account with Dauphin County. Pennsylvania; and
with Cumberland County. Pennsylvania. Wife herby agrees to specifically release and waive any and all
interest, claim or right she may have in Husband's Social Security Benefits.
Wife has no retirement/pension plans.
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5. SALE OF MARITAL RESIDENCE I DIVISION OF EQUITY
Marital Residence!Value The marital residence at 855 Acri Road, Mechanicsburg,
Pennsylvania, 17050, has been sold. All mortgages, costs, expenses, and fees associated with the
marital residence have been paid. Husband agrees ALL monies remaining from the sale of the marital
residence, less the Wife's 1995 Nissan Quest payoff, shall be the sole property of Wife.
6. APARTMENT LEASE
Apartment Lease Husband agrees to take over all responsibility for the apartment Wife has
leased at 28 Evergreen Street. C-3, Thompsontown, P A 17094. Husband has signed a new lease with
the landlord, in Husband's name only.
7. JOINT DEBTS AND LIABILITIES
The parties have no significant marital debt apart from the debt associated with the marital
residence, which has now been sold.
Husband and Wife had a joint VISA account which had a small balance. The parties have paid
this account in full and the account has been closed.
Wife had an Old Navy, Kohls and Capital One account in her name only. Wife has paid these
accounts in full and has closed them with the exception of her Capital One account.
The parties have separated and/or closed their individual and joint credit card accounts. The
parties have agreed to assume full responsibility for each of their individual credit card accounts.
Each party warrants to the other that he/she does not have any credit cards in joint names. Any
obligations incurred by either party in his or her individual name, whether incurred before or after the
parties' separation, and including credit cards. are'the sole responsibility of the party in whose name the
debt or obligation was incurred.
8. CHILDREN'S BONDS AND SAVINGS ACCOUNTS
Husband shall maintain the children's savings bonds and savings accounts at Members 1st which
are in his name and the children's names. for the children's education.
Mother shall maintain the children's saving accounts and savings bonds which are in her name
and the children's names, for the children's education.
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9. SEPARATE ASSETS
A. Release: The parties hereby agree that as to each of their separate assets, as that term is
defined herein, the party not having title to or possession of any particular separate asset hereby waives,
releases. relinquishes and forever abandons any and all claim therein, and acknowledges that hereafter
the party having title to or possession of a separate asset is the sole and exclusive owner thereof.
B. Limitation to Assets Disclosed: The above release is subject to the provision that it shall be
effective only as to those assets disclosed to the other party, although such assets need not be
specifically named or disposed of in this Agreement. Neither party intends by the execution hereof to
release any claim. which he or she may have in assets, which have not been disclosed.
C. Definition: The term "separate asset" is defined for purposes ofthis Agreement as
designating any asset of any kind (whether real, personal or mixed, tangible or intangible) which is
presently titled either in the sole name of a party hereto or jointly with one of the parties hereto and a
third party or parties. The term also includes any untitled asset which is presently in the sole possession
of one of the parties hereto. The term shall further include any business interests owed by either party,
whether individually or together with a third party or parties.
D. Indemnification as to Expenses: Each of the parties hereby gnarantees to indemnify and hold
the other harmless from any liability, cost or expense, including attorneys' fees and interest, which either
may be in the future or has been previously incurred with respect to the parties' separate assets as
defined herein.
10. AFTER-ACQillRED PROPERTY
Each of the parties shall hereafter own and enjoy. independently of any claim or right of the
other. all items of property, be they real, personal or mixed, tangible or intangible. which are acquired by
him or her after execution of this Agreement, with full power in him or her to dispose of the same as
fully and effectively. in all respects and for all purposes, as though he or she were unmarried.
11. RELEASE OF SUPPORT AND ALIMONY I
ACKNOWLEDGMENT OF ADEQUACY
The parties herein acknowledge that by this Agreement they have each respectively secured
sufficient financial resources to provide for his or her own comfort, maintenance and support. The
parties do hereby acknowledge that inflation may increase or decrease, that their respective incomes and
assets may substantially increase in value. that either may be employed at various times in the future,
and that notwithstanding these or other economic circumstances, which may be changes in
circumstances of a substantial and continuing nature. the terms of this Agreement are just and
reasonable. Therefore, except for the provisions of this Agreement, the parties hereby expressly waive.
discharge and release any and all rights and claims which they may now or hereafter have, by reason of
the parties'marriage, to alimony, alimony pendente lite. support or maintenance, and they further release
any rights ~bey may have to seek modification of the terms of this Agreement in a court oflaw or equity,
it being understood that the foregoing constitutes a final determination for all time of either party's
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obligation to contribute to the support and maintenance of the other. It shall be, from the execution date
of this Agreement. the sole responsibility of each of the respective parties to sustain themselves without
seeking any support from the other party.
12. INCOME TAX RETURNS
Husband and Wife have fIled joint income tax returns while married. If the parties are entitled to
a refund and/or incur any liability as a result of joint income tax returns filed during the parties'
marriage. the liability shall be equally divided between them. Husband will be solely responsible for the
liability if it occurs as a result of him making an error (s) on a joint income tax return while married.
The 2002 refund shall be the sole property of the Wife. Husband and Wife agree to promptly make
available to each other all records and information necessary or helpful for the preparation of any tax
returns, any claim for refunds, and defense of any tax audit.
13. COUNSEL FEES AND EXPENSES
Husband and Wife agree to be responsible for all their individual counsel fees and expenses
incurred in connection with the parties' marital dissolution, and neither shall seek any further
contribution thereto from the other party except as otherwise expressly provided herein.
Each of the parties has carefully read and fully considered this Agreement and all of the
statements, terms, conditions and provisions thereof prior to signing below.
IN WITNESS WHEREOF, intending to be legally bound hereby, the parties hereto have
set their hands and seals the day and year first written above.
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JO IEBETHKLINE '.
WIFE
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WITNESS
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PAuf:s-di~
HUSBAND
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COMMONWEALTH OF PENNSYLVANIA
SS:
COUNTY OF
On this, the d.~ 'f' day of \"e.'aN ~'::t- .2003. before me. a Notary Public for the
Commonwealth of Pennsylvania, the undersigned officer, personally appeared JODIE BETH KLINE.
known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Marital
Property Settlement Agreement. and acknowledged that she executed the same for the purpose therein
contained.
IN WITNESS WHEREOF, I have set my hand and notarial seal.
BARBARALvrEfl,OlST~ JUSTICfi
PO BOX 7. vOllRl'HOUSEANNEX
MIFl=UNT0WN, PA 17Ol11l
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Notary Public (,
My <:;ty_~if6ll ~.~ First Monday, Jan, 2008
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COMMONWEALTH OF PENNSYLVANIA
SS:
COUNTY OF
On this, the ,.:?!J--M day of ~Ud ~ ' 2003, before me. a Notary Public for the
Commonwealth of Pennsylvania. the undersigned 0 lcer, personally appeared PAUL JOSEPH
GEFFERT. known to me (or satisfactorily proven) to be the person whose name is subscribed to the
within Marital Property Settlement Agreement, and acknowledged that he executed the same for the
purpose therein contained.
IN WITNESS WHEREOF, I have set my hand and notarial seal.
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No Public
My Commission Expires:
NOTARIAL SEAL
Julia E. Nace, Notary Public
City of Harrisburg, County of Dauphin
My Commission Expires Nov. 'Z'I,2004
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JODIE BETH KLINE,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
VS,
: No, 01-06804
PAUL JOSEPH GEFFERT,
Defendant
: CIVlLACTION-ATLAW
: IN DIVORCE/CUSTODY
PRARCTPR TO TRANSMIT RF,C-:ORn
To the Prothonotary:
Transmit the record, together with the following information, to the Court for entry
of a divorce decree:
1. Ground for Divorce: Irretrievable breakdown under S 3301 (c) S J301(J:)(1) of the
Divorce Code. (Strike out inapplicable section)
2. Date and Manner of service of the Complaint:
Service by certified mail 7001 0320 000 7646, delivered on the 18th of December 2001. See
attached Acceptance of Service.
3. (Complete either paragraph (a) or (b).)
(a) Date of execution of the affidavit of consent required by S 3301(c) of
the Divorce Code: by the Plaintiff ?/?1/m: by the Defendant?/?1/01
(b) Date of execution of the affidavit required by S 3301(d) of the Divorce
C~de: ,
Date of filing of the Plaintiff's affidavit upon the respondent:
Date of service of the Plaintiff's affidavit upon the respondent:
4. Relate~ claims pending: Kinnly in"m:por"tp" witnont mp.cgP,r, tnp, "tt""np,n M"rit"l
Propp,rty Sp,ttlp,m<int Agrp,p,mp,nt n"tp,n Fp,nmmy ?4. ?Om. into tnp, Dp,,,rp,p,
5. (Complete either paragraph (a) or (b).)
(a) Date and manner of service of the Notice of Intention to File Praecipe to
Transmit Record, a copy of which is attached
(b) Date Plaintiff's Waiver of Notice in S 3301(c) Divorce was filed with the
prothonotary: indnnp,n np,rp,;n
. Date Defendant's Waiver of Notice in S 33 l(c) Divorce was filed with the
pr?thonotary: ' . .
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Date:
J/IJ/13
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Matthe J. Esh !man, Esquire
2108 Market S eet, Aztec Building
Camp Hill. Pennsylvania 17011-4706
ill # 72655Tel (717)763-1800
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JODIE BETH KLINE,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: No. 01 - 6804
PAUL JOSEPH GEFFERT,
Defendant
: CNIL ACTION - AT LAW
: IN DNORCE/CUSTODY
CONSENT ORDER
AND NOW, thi~)day O~03, upon consideration of the attached
Stipulation of the parties in the above-captioned matter, consisting of 10 pages and bearing the
written consent of the parties,
AND upon direction of this court that the parties need not be present before the court in
order to incorporate their Stipulation into a consent order,
IT IS ORDERED that said Stipulation is incorporated herein by reference as if set forth in
full and approved as a Consent Order pursuant to Pennsylvania Rule of Civil Procedure, Rule
1915.7.
---
BY TH&c6
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PLAINTIFF
: IN THE COURT OF COMMON PLEAS
:OF CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: NO. 01-6804 CIVIL TERM
: CIVIL ACTION -LAW
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PAUL JOSEPH GEFFERT.
DEFENDANT
: ACTION FOR CUSTODY
STIPULATION FOR AGREED ORDER OF CUSTODY
NOW THEREFORE. the parties, intending to be legally bound, agree as follows:
Plaintiff is JODIE BETH KLINE (hereinafter sometimes referred to as "Mother") who currently
resides at RR 1 Box 1880, McAlisterville, Juniata County, Pennsylvania, 17049.
Defendant is PAUL JOSEPH GEFFERT (hereinafter sometimes referred to as "Father") who
currently resides at 28 Evergreen Street, C-3. Thompsontown, Juniata County, Pennsylvania, 17094.
EVAN DAVID KLINE-GEFFERT, born on October 8,1994. and OWEN PAUL KLINE-
GEFFERT, born on May 19,1999. are the natural children of the Mother, JODIE BETH KLINE, and the
Father. PAUL JOSEPH GEFFERT, and are the subjects ohhis Stipulation for Agreed Order of Custody.
It is Mother and Father's belief that it is in the best interests of their minor children to have a
meaningful ongoing relationship with both their Mother and Father, provided the children are in a safe
environment.
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WHEREFORE, Plaintiff, JODIE BETH KLINE, and Defendant, PAUL JOSEPH GEFFERT.
have entered into a mutual agreement regarding the custody of their children,
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EV AN DAVID KLINE-GEFFERT and OWEN PAUL KLINE-GEFFERT. and respectfully request this
Honorable Court to enter the following Order:
1. Plaintiff and Defendant shall share Legal Custody (as defined in 23 Pa. C.SA Section 530)
of their minor children. EV AN DAVID KLINE-GEFFERT and OWEN PAUL KLINE-
GEFFERT.
2. All decisions affecting their children's growth and development including. but not limited to:
choice of camp. if any; choice of day care provider; medical and dental treatment; psychotherapy,
psychoanalysis, or like treatment; decisions relating to actual or potential litigation involving their
children, directly or as beneficiary. other than custody litigation; education, both secular and religious;
scholastic athletic pursuits and other extracurricular activities shall be considered major decisions and
shall be made by Father and Mother. jointly, after discussion and consultation with each other and with a
view towards obtaining and following a harmonious policy in their children's best interest. Neither
Mother nor Father may make unilateral. arbitrary decisions in these areas.
3. Mother and Father agree to keep the other informed of the progress of their children's
education and social adjustments. Mother and Father agree not to impair the other's right to shared legal
or physical custody of their children. Mother and Father agree to give support to the other in the role as
parent and to take into account the consensus of the other for the physical and emotional well-being of
their children.
4. While in the presence of their children. neither Mother nor Father shall make or permit any
other person to make, any remarks or do anything which could in any way be construed as derogatory or
uncomplimentary to the other parent. It shall be the express duty of each parent to uphold the other
parent as one whom their children should respect and love.
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5. It shall be the obligation of each parent to make their children available to the other
in accordance with the physical custody schedule and to encourage their children to participate in the
plan hereby agreed and ordered.
6. Each parent shall have the duty to notify the other of any event or activity that could
reasonably be expected to be of significant concern to the other parent.
7. With regard to any emergency decisions which must be made, the parent with whom the
children are physically residing at the time shall be permitted to make the decision necessitated by the
emergency without consulting the other parent in advance. However, that party shall inform the other of
the emergency and consult with him or her as soon as possible. If either parent should be unreachable at
their office or residence, then that party shall provide the other party with the necessary information to
facilitate notification of an emergency. Day-to-day decisions of a routine nature shall be the
responsibility of the parent having physical custody at the time.
8. Mother and Father shall be entitled to complete and full information from any doctor, dentist,
teacher or authority and have copies of any reports given to them as a parent. Such documents include,
but are not limited to, medical reports. academic and school report cards, birth certificates, etc. Both
parents may and are encouraged to attend school conferences and activities. Both Father and Mother's
names shall be listed with the school as the parent to be contacted in the event of an emergency and to
be notified regarding school events. Mothers residence will be the primary address.
9. Neither Mother nor Father shall schedule activities or appointments for their children which
would require their attendance or participation at said activity or appointment during a time when their
children are scheduled to be in the physical custody of the other parent without that parent's express
prior approval.
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10. The parties shall Share Physical Custody of their children, EVAN DAVID KLINE-
GEFFERT and OWEN PAUL KLINE-GEFFERT, according to the following schedule.
A. Father and Mother shall cooperate in sharing the children for approximately three
(3) to four (4) day periods of time. The purpose of this schedule is to prevent either parent from
being away from the children for any significant period of time. Father and Mother may agree to
change this three (3) to four (4) day schedule as the children's activities and Mother's work
schedule require. Mother shall have the children four days out of seven during the school year.
Father shall have the children three days out of seven during the school year. Father shall have
the children four days out of seven every other week during the summer. Mother shall have the
children four days out of seven every other week during the summer. All aforementioned days
include overnights.
B.
Mother and Father shall alternate weekends with the children beginning
Friday after school and/or child care through Monday morning. Mother's
weekends with the children shall always occur on the weekends her
mother, Mrs. Swauger. is not working. Mother may also choose to give a
weekend she is required to work to Father. Mother's request to Father to
watch the children on "her" weekend, when she must work, shall not
prejudice Mother from having weekend visitation with the children. Father
agrees to cooperate and allow Mother to have the children on weekends
when Mother is not working;
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C. The parties shall alternate and share the following holidays. The following is a
baseline schedule the parties have agreed upon. However, the parties have also agreed it may be
necessary to vary from this schedule to accommodate Mother's work schedule. When a variance
is necessary. the parties agree the changes shall always be made with the goal of sharing the
holidays with the children between the parties. Father shall have the odd numbered holidays and
Mother the even numbered holidays in the even numbered years, to alternate annually thereafter;
1) New Year's Eve and Day (this holiday shall be determined by the year in which
the New Year's Eve occurs);
2) Memorial Day;
3) Independence Day (this day may be extended later in the evening to attend
fireworks);
4) Labor Day.
D. Easter: Mother and Father shall alternate Easter with Father getting Schedule A in
the even numbered years and Mother getting Schedule B in the even numbered years, to alternate
annually thereafter.
A.
To begin Saturday evening before Easter Sunday at 6:00
p.m. through Easter Sunday at 1:00 p.m.
B.
To begin Easter Sunday at 1 :00 p.m. through the Monday
after Easter at 6:00 p.m.
E. Thanksgiving Day: Mother and Father shall alternate Thanksgiving Day with
Father getting Schedule A in the even numbered years and Mother getting Schedule B in the
even numbered years, to alternate annually thereafter.
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A. To begin Wednesday evening before Thanksgiving Day at 6:00
p.m. through Thanksgiving Day at 2:00 p.m.
B. To begin Thanksgiving Day at 2:00 p.m. through the Friday
after Thanksgiving Day at 6:00 p.m.
F. Christmas. Mother and Father shall alternate Christmas with Mother getting
Schedule A in the even numbered years and Father getting Schedule B in the even numbered
years, to alternate annually thereafter.
A. To begin Christmas Eve at 6:00 p.m. through Christmas Day at
1:00 p.m.
B. To begin Christmas Day at 1:00 p.m. through the day after
Christmas at 6:00 p.m.
G. Father shall have the children on Father's Day and Mother shall have the children
with her on Mother's Day;
H. Mother and Father shall each have the option of requesting one to two (1-2) non-
consecutive weeks of vacation during the year with their children. providing a minimum of thirty
(30) days' notice of the time requested is given to the other party.
1. All holidays, vacations, and specially designated times for visitation with their
children shall supersede the regularly scheduled visitation. Holidays shall begin at 5:00 p.m. the
evening before the holiday and extend through 8:00 p.m. the day of the holiday, unless the
parties agree to other times.
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J. Mother and Father agree if on any holiday either parent has the opportunity to
visit with a special "out-of-town" relative. the other parent will allow the children to visit with
that special "out-of-town" relative for that holiday. regardless of the designated holiday schedule
in the custody order. The parent receiving the additional holiday time shall agree to provide the
other parent with additional time to provide "make-up" time for the missed holiday.
11. Mother and Father agree to contact each other in a timely manner to give each other "Right
of First Refusal" for any time when they will not be with their children for more than four (4) hours.
12. Father agrees to pick up and return children to Mother's residence for his periods of
visitation. Mother agrees to take the children to school, all the time, regardless of which parent has
custody of the children on that day.
13. Mother and Father agree to be responsible for any ordinary everyday expenses which occur
during their individual custody periods with their sons. The parties agree to discuss sharing the costs of
any extraordinary expenses for their sons.
14. Father agrees in lieu of child support to pay for: One Hundred Percent (100%) of the
children's day care expenses; and carry medical insurance for the children and pay for One Hundred
Percent (100%) of any uncovered medical, dental, orthodontia, and psychological expenses for the
children; and pay for sports and school fees, camping summer programs, music lessons; and help pay for
both children's college education.
15. The parent with physical custody of their sons agrees to keep the other parent fully aware and
informed of any successes, difficulties, activities, emergencies. etc., in which their son have become
involved.
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16. Mother and Father agree to provide each other with current information regarding the day
care provider and any other individuals and/or activities in which their sons are in the care of an adult
other than the agreed upon caregiver. Mother and Father also agree to have each other listed as an
emergency contact with that adult and/or agency.
17. Father shall have the income tax deduction for his sons, Evan David Kline-Geffert and Owen
Paul Kline-Geffert.
18. Neither party shall consume any alcoholic beverages while they have custody of their
children.
19. Neither party shall relocate to any residence further than a thirty (30) mile radius from their
present residence, while the children are in school. Kindergarten through 12th grade; and Mother and
Father both agree that the children will attend Thompsontown Delaware Elementary School and East
Juniata High School, Kindergarten through 12th grade.
20. The parties are encouraged to discuss and cooperate with each other when sharing and
making requests for changes in periods of visitation. All permanent changes in periods of custody from
those contained in this custody agreement shall be made in writing and signed by both parties.
21. The parties shall be free to mutually agree to alter and/or change the terms ohhis agreement.
If the alteration and/or agreement is permanent and/or a change which will occur on numerous
occasions, the parties agree the alteration and/or change shall be in writing and signed by both parties.
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Each of the parties has carefully read and fully considered this Agreement and all of the
statements, terms, conditions and provisions thereof prior to signing below.
IN WITNESS WHEREOF, intending to be legally bound hereby, the parties hereto have set their
hands and seals the day and year first written above.
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FATHER
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COMMONWEALTH OF PENNSYLVANIA
SS:
COUNTY OF
On this, the rl4~ day of \:e\n-l'\\cu'-'i ,2003. before me. a Notary Publicfor the
Commonwealth of Pennsylvania. the undersigned officer, personally appeared JODffi BETH KLINE,
known to me (or satisfactorily proven) to be the person whose name is subscribed to the within
Stipulation For Agreed Order Of Custody, and acknowledged that she executed the same for the purpose
therein contained.
IN WITNESS WHEREOF, I have set my hand and notarial seal.
BARBARA LvrER, t'lSTRlCT JUSTICE
PO BOX 7. GOllRTHOllSEANNEX
MlFFUNTulAllli, f'A 17058
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Notary Public "-
My C~~_~l!I;e First Monday, Jan, 2006
COMMONWEALTH OF PENNSYLVANIA
SS:
COUNTY OF
On this. the ~~ day of oLhn.w...r .2003. before me, a Notary Public for the
Commonwealth of Pennsylvania. the undersigne ficer, personally appeared PAUL JOSEPH
GEFFERT, known to me (or satisfactorily proven) to be the person whose name is subscribed to the
within Stipulation For Agreed Order Of Custody, and acknowledged that he executed the same for the
purpose therein contained.
IN WITNESS WHEREOF, I have set my hand and notarial seal.
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ary Public
My Commission Expires:
10
NOTARIAL SEAL
Julia E. Nace, Notary Public
City of Harrisburg, Coui1ly 01 Dauphin
My ComminlOn Expires Nov. 27, llOO04
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JODIE BETH KLINE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
No. 01 - 6804
PAUL JOSEPH GEFFERT,
Defendant
CIVIL ACTION - AT LAW
IN DIVORCE/CUSTODY
ACCEPTANCE OF SERVICE
I, Paul Joseph Geffert, Defendant in the above-captioned
matter, accept service of the COMPLAINT IN DIVORCE pursuant to
Pennsylvania Rule of Civil Procedure, Rule 1930.4(d).
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Date:
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JODIE BETH KLINE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
No. 01 - 6804
PAUL JOSEPH GEFFERT,
Defendant
CIVIL ACTION - AT LAW
IN DIVORCE/CUSTODY
PLAINTIFF'S AFFIDAVIT OF CONSENT
UNDER SECTION 3301(0) OF THE DIVORCE CODE
1. A complaint in divorce under Section 3301 (c) of the
Divorce Code was filed on December 5, 2001.
2. The marriage of the plaintiff and the Defendant is
irretrievably broken and ninety days have elapsed from the date of
filing and service of the Complaint.
3. I consent to the entry of a final decree of divorce after
service of notice of intention to request entry of the decree.
4. I verify that the statements made in this affidavit are
true and correct.
I understand that false statements herein are
made subject to the penalties of 18 Pa. C.S. ~ 4904 relating to
unsworn falsification to authorities.
DATE: 02 ~.(3-D;:)
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ODIE BETH KLINE
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JODIE BETH KLINE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
No. 01 - 6804
PAUL JOSEPH GEFFERT,
Defendant
CIVIL ACTION - AT LAW
IN DIVORCE/CUSTODY
PLAINTIFF'S WAIVER OF NOTICE OF INTENTION
TO REQUEST ENTRY OF A DIVORCE DECREE
UNDER SECTION 3301(0) 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.
4. I verify that the statements made in this affidavit are
true and correct.
I understand that false statements herein are
made subject to the penalties of 18 Pa. C.S. ~ 4904 relating to
unsworn falsification to authorities.
DATE:02 -~ ~O~
Signatu=, \Jot, " ~. .
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JODIE BETH KLINE,
plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
No. 01 - 6804
PAUL JOSEPH GEFFERT,
Defendant
CIVIL ACTION - AT LAW
IN DIVORCE/CUSTODY
DEFENDANT'S AFFIDAVIT OF CONSENT
UNDER SECTION 3301{c) OF THE DIVORCE CODE
1. A complaint in divorce under Section 3301 (cl of the
Divorce Code was filed on December 5, 2001.
2. The marriage of the Plaintiff and the Defendant is
irretrievably broken and ninety 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.
4. I verify that the statements made in this affidavit are
true and correct.
I understand that false statements herein are
made subject to the penalties of 18 Pa. C.S. ~ 4904 relating to
unsworn falsification to authorities.
DATE:
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JODIE BETH KLINE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
No. 01 - 6804
PAUL JOSEPH GEFFERT,
Defendant
CIVIL ACTION - AT LAW
IN DIVORCE/CUSTODY
DEFENDANT'S WAIVER OF NOTICE OF INTENTION
TO REQUEST ENTRY OF A DIVORCE DECREE
UNDER SECTION 3301(c} OF THE DIVORCE CODE
1. I consent to the entry of a final decree of divorce
without notice.
2. I understand that I may lose rights concerning alimony,
division of property, lawyer's fees, or expenses if I do not claim
them before a divorce is granted.
3. I understand that I will not be divorced until a divorce
decree is entered by the Court and that a copy of the decree will
be sent to me immediately after it is filed with the prothonotary.
4. I verify that the statements made in this affidavit are
true and correct.
I understand that false statements herein are
made subject to the penalties of 18 Pa. C.S. ~ 4904 relating to
unsworn falsification to authorities.
DATE:
~ -~:? -03
PAk ~kt1E~F
Signature:
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JODIE BETH KLINE,
PLAINTIFF
: IN THE COURT OF COMMON PLEAS
: OF CUMBERLAND COUNTY,
: PENNSYLVANIA
VS.
: NO.01-6804 CIVIL
PAUL JOSEPH GEFFERT,
DEFENDANT
: CIVIL ACTION . LAW
: ACTION FOR DIVORCE I CUSTODY
AFFIDAVIT OF SERVICE CERTImED MAIL
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COMMONWEALTH OF PENNSYLVANIA
SS:
COUNTY OF CUMBERLAND
Be it known, that on the 31s'r day of OuO~~ .2001, before me, the
subscriber, a Notary Public, personally appeared SUSAN KAY CANDIELLO, who, being duly
sworn according to law, did depose and state as follows:
1. I am an attorney licensed to practice law in the Commonwealth of Pennsylvania.
2. I represent Jodie Beth Kline, Plaintiff in the above-captioned matter.
3. On December 17,2001. a true and correct copy of the Complaint for No-Fault
Divorce Under Section 3301(c) ofthe Divorce Code was deposited for delivery with the U.S.
Postal Service in Mechanicsburg. Pennsylvania. being Certified/First Class Mail, restricted
delivery. return receipt requested. Article No. 700103200000 31117646. and addressed to the
Defendant, Paul Joseph Geffert, at 855 Acri Road. Mechanicsburg, PA 17050.
4. The return receipt card signed by the Defendant, Paul Geffert, showing a date of
service of December 19.2001. is attached hereto as Exhibit "A".
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5. Service by certified mail meets the reqnirements of Pa.R.c.P. 404(2) and
Pa.R.C.P.403.
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SWORN TO AND SUBSCRIBED before me. a Notary Public, this 3/5t- day of
~ .2001.
~"C\\W~~l~ \L~~
Notary Public
My Commission Expires:
Notarial Seal
Kimberly R. Hanford. Notary Public
Mec:I1anICSburg Bora. cumbeIllind County
My CommiSSion Expires Apr. 4, 2005
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. AIlach this card to the back of the mailpiec '0
or on the front if space permits. /{/
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4. Restricted Delivery? (Extra Fee) b( Yes
2. Ar1Icle Number
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JODIE BETH KLINE
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v,
01-6804 CIVIL ACTION LAW
PAUL JOSEPH GEFFERT
DEFENDANT
IN CUSTODY
ORDER OF COURT
AND NOW,
Tuesday, December 04, 2001
, upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator,
at 214 Senate Avenue, Suite 105, Camp Hill, PA 17011 on Tuesday, January 15, 2002 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, Failure to appear at the conference may
provide grounds for entry of a temporary or permanent order.
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT,
By: Isl
Melissa P. Greevy. Esq. 6fl
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans
with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations
available to disabled individuals having business before the court, please contact our office, An 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 TillS 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
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
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JODIE BETH KLINE,
PLAINTIFF
: IN THE COURT OF COMMON PLEAS
: OF CUMBERLAND COUNTY,
PENNSYLVANIA
VS.
NO.OI-~CIVIL
CIVIL ACTION - LAW
ACTION FOR DIVORCE I CUSTODY
PAUL JOSEPH GEFFERT,
DEFENDANT
ORDER
AND NOW, this day of ,2001, upon consideration of the attached
Complaint, it is hereby directed that the parties and their respective counsel appear before
, the conciliator. at
on the day of ,2001, at_ o'clock_.m., 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. All children age five or older shall also be present at the conference. Failure to appear at the
conference may provide for entry of a temporary or permanent order.
FOR THE COURT,
BY:
Custody Conciliator
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 WIU:RE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle P A 17013
(717) 249-3166
1-800-990-9108
AMERICANS 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 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.
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JODIE BEm KLINE,
PLAINTIFF
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
V8.
: NO.OI~1.11::Jf CIVIL
:
PAUL JOSEPH GEFFERT,
DEFENDANT
: CIVIL ACTION . LAW
: ACTION FOR DIVORCE I CUSTODY
NpTICE 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 at the Cumberland County Courthouse, One Courthouse Square, Carlisle. PA 17013-3387.
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 RIGfIT 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 FINl> OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle PA 17013
(717) 249-3166
1-800-990-9108
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JODIE BETH KLINE,
PLAINTIFF
: IN THE COURT OF COMMON PLEAS
: OF CUMBERLAND COUNTY,
: PENNSYL VANIA
vs.
: NO.OH.iby CIVIL
: CIVIL ACTION - LAW
: ACTION FOR DIVORCE I CUSTODY
PAUL JOSEPH GEFFERT,
DEFENDANT
COMWLMNTFORNO~AULTDNORCE
UNDER SECTION 3301(S) OF THE DIVORCE CODE
AND NOW, comes the Plaintiff, JODIE BETH KLINE, by and through her counsel,
Susan Kay Candiello, Esquire, of the Law Firm of Susan Kay Candiello, P .C., and makes the
following consolidated complaint in divorce for divorce and custody.
1. Plaintiff is JODIE BETH KLINE, an adult individual, who currently resides at
855 Acri Road, Mechanicsburg, Cumberland County, Pennsylvania, 17050. The Plaintiffhas
resided in Cumberland County for over thirteen (13) years.
2. Defendant is PAUL JOSEPH GEFFERT, an adult individual, who currently
resides at 855 Acri Road, Mechanicsburg, Cumberland County, Pennsylvania, 17050.
3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at
least six months immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were lawfully married on April 7, 1990.
5. There have been no prior actions of divorce or for annulment between the parties
except this Complaint filed for divorce.
6. The marriage is irretrievably broken.
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7. Plaintiff has been advised of the availability of counseling and of the right to
request that the court require the parties to participate in counseling. Plaintiff has chosen not to
engage in, or to request any counseling.
8. Neither Plaintiff nor Defendant was a member of the United States Military
Services.
9. Plaintiff and Defendant have two (2) children from their marriage, EVAN
DAVID KLINE-GEFFERT, born October 8, 1994, and OWEN PAUL KLINE-GEFFERT,
born May 19, 1999.
COUNT I - REOUEST FOR NO-FAULT DIVORCE
UNDER ~ECUQN 3iOl(c) OF THE D!VOR~E CODE
10. Paragraphs 1 through 9 of this Complaint are incorporated herein by reference
thereto.
11. After ninety (90) days have elapsed from the date of filing of this Complaint,
Plaintiff intends to file an Affidavit consenting to the divorce. Plaintiff believes Defendant may
also file such an affidavit.
WHEREFORE, if both parties fIle affidavits consenting to a divorce after ninety (90)
days have elapsed from the date of filing of this Complaint, Plaintiff, JODIE BErn KLINE,
respectfully requests the court to enter a Decree of Divorce pursuant to section 3301 (c) of the
Divorce Code.
COUNT n - REQUEST FOR SPOUSAL SUPPO~T A&>/OR ALIMONY
UNDER ~ECTION 3701(3) and 3702 9F THE DIVOR9; COD~-E
12. Paragraphs 1 through 11 of this Complaint are incorporated herein by reference
thereto.
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13. Plaintiff is unable to sustain herself during the course of litigation.
14. Plaintiff lacks sufficient property to provide for her reasonable needs and is
unable to sustain herseIfthrough appropriate employment.
15. Plaintiff requests the Court to enter an award of spousal support until final hearing
and thereupon to enter an order of alimony in her favor pursuant to Section 3701(a) and 3702 of
the Divorce Code.
WHEREFORE, Plaintiff, JODIE BETH KLINE, respectfully requests the Court to
enter an award of spousal support until fmal hearing and thereupon to enter an order of alimony
in her favorpursuantto Section 3701(a) and 3702 of the Divorce Code.
COUNT ill - REQ~T FOR EOU\IABLE DI~~WJON Ot
MARITAL PROPERTY'UNDER SECTION 3502(a) OF THE DIVORCE CODE
16. Paragraphs 1 through 15 of this Complaint are incorporated herein by reference
thereto.
17. The Plaintiff requests the Court to equitably divide, distribute or assign the marital
property between the parties without regard to marital misconduct in such proportion as the Court
deems just after consideration of all relevant factors.
WHEREFORE, Plaintiff, JODIE BETH KLINE, respectfully requests the Court to
enter an order of equitable distribution of marital property pursuant to Section 3502(a) of the
Divorce Code.
COUNT IV - REO~ST FOR CONFIRMATION OF CUSTODY
UNDER SECTIONS 3104(8)(2) and 3~23(b) OF TUE DIVORCE CODE
18. Paragraphs 1 through 17 of this Complaint are incorporated herein by reference
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19. The parties are the parents of the following unemancipated children who reside
with the Plaintiff:
NAME
AGE SEX
DATE OF BIRTH
EVAN DAVID KLINE-GEFFERT
7 years Male
October 8, 1994
OWEN PAUL KLINE-GEFFERT
2 1/2 years Male
May 19, 1999
20. During the past five (5) years the children have resided with the parties and at the
addresses herein indicated:
WITH WHOM
ADDRESS
FROM I TO
Plaintiff and Defendant
6106 Locust Lane
Mechanicsburg, P A
Birth to January, 1998
Plaintiff and Defendant
35 Hazelwood path
Mechanicsburg, P A
January, 1998 to February, 2001
Plaintiff and Defendant
855 Acri Road
Mechanicsburg, P A
February 2001 to Present
21. Plaintiff has not participated in any other litigation concerning the children in this
or any other state.
22. There are no other proceedings pending involving custody of the children in this
or any other state.
23. Plaintiff knows of no person not a party to these proceedings who has physical
custody of the children or who claims to have custody, partial custody or visitation rights with
respect to the children.
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24. The best interests of the children will be served if both Plaintiff and Defendant
have Shared Legal Custody, with Plaintiff having Primary Physical Custody and Defendant
having Partial Physical Custody of their children.
WHEREFORE, Plaintiff, JODIE BETH KLINE, respectfully requests that, pursuant to
Sections 3104(a)(2) and 3323(b) of the Divorce Code, the Court enter an order confirming
Shared Legal Custody with Plaintiff, JODIE BETH KLINE, and Defendant, PAUL JOSEPH
GEFFERT, Primary Physical Custody with Plaintiff, JODIE BETH KLINE, and Partial
Physical Custody with Defendant, PAUL JOSEPH GEFFERT, of the parties' two (2) minor
children, EVAN DAVID KLINE-GEFFERT and OWEN PAUL KLINE-GEFFERT.
Respectfully submitted,
LAW FIRM OF SUSAN KAY CANDIELLO, P.c.
Dated: November tl, 2001
Susan Kay
Counsel fa
PAI.D.# 8
5021 East Trin
Suite 100
Mechanicsburg P A 17050
(717) 796-1930
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VERIFICATION
The undersigned hereby verifies that the facts averred in the foregoing document are true
and correct to the best of her knowledge, information, and belief. This verification is made
DATED:
subject to the penalties of 18 Pa. C.S.A. ~4904 relating to unsworn falsification to authorities.
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JO IE BETH KLINE
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Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01-6804 CIVIL TERM
JODIE BETH KLINE,
v.
CIVIL ACTION - LAW
PAUL JOSEPH GEFFERT,
IN CUSTODY
Defendant
ORDER TO RELINQUISH JURISDICTION
AND NOW, this 25th day of March, 2002, the counsel for parties having requested a thirty
(30) day continuance on February 19, 2002, and the Conciliator having received no further request
for the Custody Conciliation Conference to reconvene, hereby relinquishes jurisdiction of the above
captioned matter.
BY:
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
JODIE BETH KLINE,
PLAINTlFF,
: DOCKET No. 01 - 6804
PAUL JOSEPH GEFFERT,
DEFENDANT
: PREVIOUSLY ASSIGNED: N/A
: CNIL ACTION - AT LAW
: IN DNORCE/CUSTODY
ENTRY OF APPEARANCE AND REQUEST FOR NOTICES
To the Prothonotary:
Kindly enter my appearance as attorney of record for the Defendant in the above-captioned
matter, and withdraw the appearance of prior counsel, Richard Rupp.
Further, the undersigned hereby requests that all notices and other docwnents required to be
served upon parties in interest, whether sent by the Court or any other party in this case, be served
upon the undersigned attorney at the address listed below.
~,
;
Date: dfb(o 3
Matthew . Es ehnan, Esquire
Law Offices 0 atrick F. Lauer, Jr.
2108 Market Street, Aztec Building
Camp Hill, Pennsylvania 17011-4706
ID# 72655 TeL (717) 763-1800
ACCORD, DEFENDANT:
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