HomeMy WebLinkAbout99-02862F
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
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STATE OF PENNA.
... ..........KAREN..REBECCA.,GREENLUND
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............................. .__.............. .... ..... .... i
........ No ....... 19.9.9.-286.2 ...............
Vol-sus
.... .......... ICHAEL,_VERNON.HOUSE ....._.
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DE CRE E IN
DI VO RCE
ri AND NOW, .... .. .. ?.?..., Wl..\.1 it is ordered and y
decreed that ...... KAREN. REBECCA. GREENLUND ................ plaintiff,
and ........ , MICHAEL, VERNON,HOUSE ...... • , • , defendant,
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are divorced from the bonds of matrimony.
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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
P
i? been entered; None. The attached settlement Agreement is
incorporated, but not merged, into this Decree.
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Attest: J.
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/ Prothonotary ?•°'
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KAREN REBECCA GREENLUND,
Plaintiff
V.
MICHAEL VERNON HOUSE,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 1999 - 2862
CIVIL LAW - DIVORCE
SETTLEMENT AGREEMENT
THIS AGREEMENT, is made this 22nd day of November, 1999, by
and between KAREN REBECCA GREENLUND ("Wife") of Cumberland County,
Pennsylvania and MICHAEL VERNON HOUSE ("Husband"), of Dauphin
County, Pennsylvania.
W I T N E 8 8 E T H•
WHEREAS, the parties, currently Husband and Wife, will be
obtaining a decree in divorce; and
WHEREAS, by this Agreement, the parties have intended to
effectuate and equitably divide their marital property and marital
debts; and
WHEREAS, diverse unhappy differences, disputes and
difficulties have arisen between the parties and it is their
intention to live separate and apart for the rest of their lives
and to settle any and all claims by one against the other or
against their respective estates.
NOW THEREFORE, with the foregoing recitals being hereinafter
incorporated by reference and deemed as an essential part hereof
and in consideration of the premises and of the mutual promises set
forth herein and for other good and valuable consideration, receipt
of which is hereby acknowledged, the parties, each intending to be
legally bound hereby, covenant and agree as follows:
1. EFFECT QF DIVORCE DECREE.
The parties agree that unless otherwise specifically
provided herein, this Agreement shall continue in full force and
effect after such time as a Final Decree in Divorce may be entered
with respect to the parties. This Agreement shall be incorporated,
but not merged into the final decree in divorce.
2. FINANCIAL DISCLOSURE.
The parties confirm that each has relied on the
substantial accuracy of the financial disclosure of the other as an
inducement to the execution of this Agreement. No representations
have been made by either party to the other, or by anyone else, as
to the financial status of the other except as expressly set forth
in this Agreement.
3. ADVICE OF COUNSEL.
Wife has retained Kenneth F. Lewis, Esquire and Husband
has retained John J. Connelly, Jr. to advise each regarding this
Agreement. Both parties acknowledge this Agreement is, under the
circumstances, fair and equitable and that it is being entered into
freely and voluntarily, after having received independent legal
advice. The parties acknowledge this Agreement is not the result
of any duress or undue influence and is not the result of any
collusion or improper or illegal agreement or agreements.
4. DISCLOSURE AND WAIVER OF PROCEDURAL RIG=HTS.
The parties understand that each has the right to obtain
from the other party a complete inventory or list of all of the
property that either or both parties own at this time or owned as
of the date of separation, and that each party has the right to
have all such property valued by means of appraisals or otherwise.
Both parties understand they have the right to have a Court hold
hearings and make decisions on the matters covered by this
Agreement. Both parties understand that a Court decision
concerning the parties' respective rights and obligations might be
different from the provisions of this Agreement.
Both parties waive the following procedural rights:
a. The right to obtain an Inventory and
Appraisement of all marital and separate property as defined by the
Pennsylvania Divorce Code.
b. The right to obtain an Income and Expense
Statement of the other party as provided by the Pennsylvania
Divorce Code.
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C. The right to have the Court determine which
property is marital and which is non-marital and equitably
distribute between the parties that property which the Court
determines to be marital.
d. The right to have the Court decide any other
rights, remedies, privileges, or obligations covered by this
Agreement, including but not limited to possible claims for
divorce, spousal support, alimony, alimony pendente lite, counsel
fees, costs and expenses.
5. PERSONAL RIGHTS.
Husband and Wife, may and shall, at all times hereafter,
live separate and apart. They shall be free from any interference,
direct or indirect, by the other in all respects as fully as if
they were unmarried. They may reside at such place or places as
they may select. Each may, for his or her separate use or benefit,
conduct, carry on and engage in any business, profession or
employment which to him or her may seem advisable. Husband and
Wife shall not molest, harass, disturb or malign each other or the
respective families of each other nor compel or attempt to compel
the other to cohabit or dwell by any means or in any manner
whatsoever with him or her.
6. MUTUAL RELEASES.
Husband and Wife each do hereby mutually release and
forever discharge the other and the estate of the other of and from
any and all rights or claims in or against the property (including
income and gain from property hereafter accruing) of the other or
against the estate of the other, which he or she now has or at any
time hereafter may have against such other, the estate of such
other or any party thereof, whether arising out of any former acts,
or liabilities of such other or by way of dower or curtesy, or
claims in the nature of dower or curtesy or widow's or widower'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 laws of (a) Pennsylvania, (b) any State, Commonwealth or
Territory of the United States, or (c) any other Country, or any
rights which either party may have or at any time hereafter have
for past, present or future support or maintenance, alimony,
alimony pendente lite, counsel fees, equitable distribution, costs
or expenses, whether arising as a result of the marital relation or
otherwise, except, and only except, all rights and agreements and
obligations of whatsoever nature arising or which may arise under
this Agreement or for the breach of any provision thereof. It is
the intention of Husband and Wife to give to each other by the
execution of this Agreement a full, complete and general release
with respect to any and all property of any kind or nature, real,
personal or mixed, which the other now owns or may hereafter
acquire, except and only except all rights and agreements and
obligations of whatsoever nature arising or which may arise under
this Agreement or for the breach of any provision thereof.
7. PERSONAL PROPERTY.
The parties make the following disposition and
settlement with respect to their personal property.
a) Husband and Wife agree they shall equitably
divided all their personal property to each party's satisfaction.
Each party reserves the right to request the court to equitably
divide the marital personal property in the event the parties are
not able to agree with regard to same.
b) The parties own various photographs and videos
of the parties and/or their children within ten (10) days of the
date of this Agreement. The parties shall fairly divide these
photographs or, if they are not able to agree as to the division,
they shall share the cost of duplication of the photographs which
they both desire. Each party acknowledges that the other party
will have approximately one-half of the photographs and that he/she
will not simply demand most of the photographs, forcing the other
to share in the cost of duplication. The Affidavits of Consent
will be held by Wife's counsel until Wife complies with the terms
of this paragraph.
C) Husband shall be the owner of a painting of Wife
during her pregnancy entitled "True Blue." Wife shall have a life
estate, having possession of the painting during her lifetime.
Wife shall not sell or otherwise dispose of the painting without
written consent of Husband. If Wife predeceases Husband, the
painting shall go to Husband, who must give the painting to the
parties' children either by gift or through his Last will and
Testament. If Husband predeceases Wife, Wife must give the
painting to the parties' children through her Last Will and
Testament.
d) The and rights to any retirement e accounts the waive other may have through
their employment.
e) Wife 9 presentation, Husband ss allTesign tthe19title Mercur
and Sable
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documentation necessary to transfer the vehicle to Wife.
8• $'ER-ACOOIRED PERSONAL PROPERTY.
Each of
the independently Of any claim ori right shall of the other, all n items enjoy, yof
personal property, tangible or intangible, hereafter acquired by
him or her, 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 not married.
9. REAL ESTATE.
a) Wife shall retain the marital home located at
416 4th Street, New Cumberland, Pennsylvania. Upon presentation,
Husband shall execute a Deed transferring the home to Wife.
b) For a period of two years from the date of this
Agreement, Husband shall be solely responsible for the mortgage on
the home. In consideration for this payment, Wife agrees to forego
collecting child support for the same two year period. Should Wife
refinance or sell the property or in any other way end Husband's
financial responsibility with regard to the mortgage on the home,
this provision shall lapse.
C) After two years have passed, Wife shall take all
necessary steps to end Husband's financial responsibility with
regard to the mortgage, including refinancing the property or
placing the property for sale in the event she is not able to
refinance unless both parties agree in writing to extend provision
9b immediately above.
d) Should Husband not comply with the current
repayment plan or, following the completion of the repayment plan,
should he fail to make each mortgage payment within thirty (30)
days of its due date, or should the mortgage company notify either
party that the mortgage is in default, Wife may file for child
support and still have two years from the date of this Agreement
within which to refinance the mortgage or otherwise end Husband's
financial responsibility.
e) Should Wife file for child support while Husband
is making timely payments, she must immediately refinance the
mortgage, list the property for sale, or otherwise end Husband's
financial responsibility. Such a filing would end Husband's
responsibility to make mortgage payments.
5
f) Any mortgage payments made by Husband after Wife
files for child support shall be credited toward his support
obligations. It is the intention of the parties that Husband shall
not be obligated to pay child support and mortgage payments
concurrently.
g) Husband warrants that at the time of this
Agreement the agreed-upon payment plan with the mortgage company is
current. Husband is responsible and shall indemnify and defend
Wife against all mortgage payments and late charges existing at the
time of this Agreement. Further, Husband shall indemnify and
defend Wife against all mortgage payments and late charges for
which he is responsible under this Agreement.
h) As all mortgage information will continue to be
sent to Husband during his time of responsibility for the mortgage,
Husband shall send Wife a copy of each payment made pursuant to
this paragraph either by mail or by facsimile.
10. ALIMONY, ALIMONY PENDENTE LITE SPOUSAL SUPPORT.
The parties do hereby waive and surrender any rights
and/or claims they may have to interim or final alimony, alimony
pendente lite and spousal support.
11. ATTORNEYS FEES AND COSTS.
The parties do hereby waive and surrender any rights
and/or claims they may have to interim or final attorney's fees,
costs and expenses.
12. ARRMIRs TO EXISTING OBLIGATIONS.
Each party represents that he/she has not heretofore
incurred or contracted for any debt or liability or obligation for
which the estate of the other party may be responsible or liable
except as may be provided for in this Agreement. Each party agrees
to indemnify or hold the other, party harmless from and against any
and all such debts, liabilities or obligations of every kind which
may have heretofore been incurred, including those for necessities,
except for the obligations arising out of this Agreement.
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13. WARRANTIES TO FUTURE OBLIGATIONS.
Husband and Wife each covenant, warrant, represent
and agree that each will now and at all times hereafter save
harmless and keep the other indemnified from all debts, charges and
liabilities incurred by the other after the execution date of this
Agreement, except as'may be otherwise specifically provided for by
the terms of this Agreement and that neither of them shall
hereafter incur any liability whatsoever for which the estate of
the other may be liable.
14. INSURANCE.
a) Wife shall continue to provide health insurance
for the children as long as she is able to do so through her
employment. The parties shall equally share in the cost of all
medical expenses not covered by insurance. Husband shall reimburse
Wife for his share of any such medical expenses within thirty (30)
days of receiving a copy of the statement(s) for services. said
payments shall be made directly to Wife if the bill was paid by her
or to the service provider if Husband's 50% remains unpaid. This
provision is subject to modification by the Domestic Relations
Office.
b) As long as the parties are legally responsible
for supporting any of their children, they shall each maintain life
insurance and/or accidental death insurance benefits in an amount
of at least $25,000.00, listing the parties' children as the only
beneficiaries, the only exception being that Husband may also
include his daughter, Valerie J. House, to have a 25% share as a
beneficiary. Furthermore, should a party's policy provided for
herein not be in force and effect for any reason at the time of
said party's death and should any of the parties' children be
entitled to said proceeds pursuant to this paragraph, then in such
event, the parties' children shall be entitled to make a claim
against the deceased's estate for the amount of the proceeds which
they would have been entitled to receive if the policy had been in
force and effect. However, nothing in this paragraph shall relieve
each party's obligation to maintain a policy as provided for
herein.
15. TAX PROVISION. Wife shall be responsible for the
federal income tax due for the 1997 tax year in an amount of
approximately $1,500.00, plus any penalty or interest. Wife shall
indemnify and hold harmless Husband from any claims arising out of
this obligation.
7
16. 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 of any breach hereof or default hereunder shall be deemed a
waiver of any subsequent default of the same or similar nature.
17. BREACH.
It is expressly stipulated that if either party
fails in the due performance of any of his or her obligations under
this Agreement, the other party shall have the right at his or her
election to sue for damages for breach thereof, to sue for specific
performance, or to seek any other legal remedies as may be
available and said other party shall have the right to recover his
or her reasonable legal fees and costs for any services rendered by
his or her attorney.
18. MUTUAL COOPERATION.
Each party shall, at any time and from time to time
hereafter, take any and all steps and execute, acknowledge and
deliver to the other party any and all further instruments and/or
documents that the other party may reasonably require for the
purpose of giving full force and effect to the provisions of this
Agreement.
19. LAW OF PENNSYLVANIA APPLICABLE.
This Agreement shall be construed in accordance with
the laws of the commonwealth of Pennsylvania.
20. AGREEMENT BINDING ON HEIRS.
This Agreement shall be binding and shall inure to
the benefit of the parties hereto and their respective heirs,
executors, administrators, successors and assigns.
21. 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.
8
22. 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 of any provision hereof be
construed as a waiver of any subsequent default of the same or
similar nature, nor shall it be construed as a waiver of strict
performance or any other obligations herein.
23.
If any term or provision of this Agreement shall be
determined to be invalid, then only that term or provision shall be
stricken 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 any one
or more of the paragraphs herein, with the exception of the
satisfaction of the conditions precedent, shall in no way void or
alter the remaining obligations of the parties.
24. HEADINGS NOT PART OF AGREEMENT.
Any headings preceding the text of the 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.
GREENLUND
HOUSE
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KAREN REBECCA GREENLUND,
Plaintiff
V.
MICHAEL VERNON HOUSE,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 1999 - 2862
CIVIL LAW - DIVORCE
PRAECIPE TO TRANSMIT RECORD
To The Prothonotary:
Transmit the record, together with the following information,
to the Court for entry of a Divorce Decree:
1. Ground for divorce: irretrievable breakdown under Section
(* ) 33o1(c1 ( ) 3301(d) (1) of the Divorce Code.
2. Date and manner of service of the Complaint: Acceptance of
Service executed May 25 1999 and filed June 2 1999
3. Date of execution of the Affidavit of consent required by
Section 3301(c) of the Divorce Code: by the Plaintiff on
November 22. 1999; by the Defendant on November 22, 1999.
Date of execution of Waiver of Notice of Intention To
Request Entry of a Divorce Decree Under Section 3301 (c) of the
Divorce Code: by the Plaintiff on November 22 1999; by the
Defendant on November 22. 1929.
4. Related claims pending: none: the Parties are requesting
that terms of a Settlement Agreement dated November 22. 1999 be
incorporated but not merepd into the Decree.
KE NET F. LEWIS, ESQUIRE ' %3JG>
Attorney for Plaintiff
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KENNETH F. LEWIS, ESQUIRE
I.D. 069383
1101 North Front Street
Harrisburg, PA 17102
(717) 234-3136
Attorney for Plaintiff
KAREN REBECCA GREENLUND, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. it 1999 aO ?n
MICHAEL VERNON HOUSE,
Defendant CIVIL LAW - DIVORCE
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 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: Cumberland County Courthouse, let Floor, Carlisle,
PA 17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED,
YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
OFFICE OF THE COURT ADMINISTRATOR
COURTHOUSE, 4th FLOOR
CARLISLE, PA 17013
(717) 240-6200
KENNETH F. LEWIS, ESQUIRE
I.D. #69383
1101 North Front Street
Harrisburg, PA 17102
(717) 234-3136
Attorney for Plaintiff
KAREN REBECCA GREENLUND, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 1999--a e T
MICHAEL VERNON HOUSE,
Defendant CIVIL LAW - DIVORCE
COMPLAINT IN DIVORCE and CUSTODY
1. Plaintiff is Karen Rebecca Greenlund, who currently
resides at 416 4th Street, New Cumberland, Cumberland County,
Pennsylvania 17070.
2. Defendant is Michael Vernon House, who currently
resides at 4256A Wagonwheel Ct., Harrisburg, Dauphin County,
Pennsylvania 17109.
3. Plaintiff and Defendant have been bona fide residents
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 July 3,
1991 in Cumberland County, Pennsylvania.
5. There have been no prior actions of divorce or for
annulment between the parties.
6. The marriage is irretrievably broken.
7. Plaintiff has been advised that counseling is
available and that Plaintiff may have the right to request that the
court require the parties to participate in counseling.
WHEREFORE, Plaintiff respectfully requests this Court to
enter a Decree of Divorce pursuant to § 3301(c) of the Domestic
Relations Code.
8. Plaintiff hereby incorporates Paragraphs 1 through
7 of her Complaint as if fully set forth herein.
9. The parties are owners of marital property subject
to equitable distribution.
10. Plaintiff requests the court to equitably divide,
distribute or assign the marital property between the parties and
the marital debts of the parties without regard to marital
misconduct in such proportions as the Court deems just after
consideration of all relevant factors.
WHEREFORE, Plaintiff respectfully requests that this
Honorable Court enter an Order of Equitable Distribution of marital
property and marital debts pursuant to $3502 of the Domestic
Relations Code.
COUNT III - CUSTODY
11. Plaintiff hereby incorporates Paragraphs 1 through
10 of her Complaint as if fully set forth herein.
12. Plaintiff seeks primary custody of the parties'
children Jazz McGee House, born August 18, 1992, Rayne Evans House,
born February 16, 1994, and True Greenlund House, born December 24,
1996. The children were not born out of wedlock.
13. The children are presently in the custody of
Plaintiff, with Defendant having occasional partial periods of
custody.
14. The children have resided at the marital home, 416
4th Street, New Cumberland, Pennsylvania, all their lives. They
resided with both plaintiff and defendant until the parties
separated on July 20, 1997, at which time, defendant moved from the
marital home.
15. The relationship of the Plaintiff to the children is
that of the natural mother. The Plaintiff currently resides with
her children at the above address. She is married to the
Defendant.
16. The relationship of the Defendant to the children is
that of the natural father. The Defendant currently resides alone.
He is married to the Plaintiff.
17. Plaintiff has not participated as a party or
witness, or in any other capacity in other litigation, concerning
the custody of the children in this or another court.
Plaintiff has no information of a custody proceeding
concerning the children pending in any Court of this commonwealth.
Plaintiff 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.
18. The best interest and permanent welfare of the
children will be served by granting primary custody to Plaintiff as
she has been the primary caretaker since their births and will be
able to provide maximum stability for the parties' children.
19. Each parent whose parental rights to the children
has not been terminated and the person who has physical custody of
the children has been named as parties to this action.
20. It is hoped that the parties will be able to enter
into an custody agreement and will request the Court to enter their
agreement as an order of Court.
WHEREFORE, Plaintiff requests the Court to grant her primary
custody of the parties, children, with visitation rights to Father.
DATE:
KENNETH F. LEWIS, ESQUIRE
Attorney I.A. 169383
1101 North Front Street
Harrisburg, PA 17102
(717) 234-3136
Attorney for Plaintiff
YERIFICATION
I verify that the statements made in this Complaint 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.
DATED: ??12?199 / )c
KA EN REBECCA GREENLUND
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KENNETH F. LEWIS, ESQUIRE
I.D. #69383
1101 North Front Street
Harrisburg, PA 17102
(717) 234-3136
Attorney for Plaintiff
KAREN REBECCA GREENLUND,
Plaintiff
V.
MICHAEL VERNON HOUSE,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 1999 - 2662
CIVIL LAW - DIVORCE
I accept service of the Complaint.
DATE:
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KAREN REBECCA GREENLUND,
Plaintiff
V.
MICHAEL VERNON HOUSE,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 1999 - 2862
CIVIL LAW - DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce was filed under Section 3301
(c) of the Divorce Code on May 11, 1999.
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 in Divorce
after service of notice to intention to request entry of the
decree.
I understand that false statements herein are made
subject to the penalties of 18 Pa.C.S. Section 4904, relating to
unsworn falsification to authorities.
Dated: 11/22/99
KAREN REBECCA GREENLUND
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KAREN REBECCA GREENLUND, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 1999 - 2862
MICHAEL VERNON HOUSE,
Defendant CIVIL LAW - DIVORCE
1.
without notice.
2.
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER SECTION
3301 (o) OF THE DIVORCE CODE
I consent to entry of a final Decree of Divorce
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
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 the foregoing
document are true and correct. I understand that false statements
herein are made subject to the penalties of 18 Pa.C.S. Section
4904, relating to unsworn falsification to authorities.
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Dated: 11/22/99 /s /^
KAREN REBECCA GREENLUND
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KAREN REBECCA GREENLUND,
Plaintiff
V.
MICHAEL VERNON HOUSE,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 1999 - 2862
CIVIL LAW - DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce was filed under Section 3301
(c) of the Divorce Code on May 11, 1999.
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 in Divorce
after service of notice to intention to request entry of the
decree.
I understand that false statements herein are made
subject to the penalties of 18 Pa.C.S. Section 4904, relating to
unsworn falsification to authorities.
Dated: 11/22/99 qk ?, -
MIC L VERNON HOUSE
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KAREN REBECCA GREENLUND, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 1999 - 2862
MICHAEL VERNON HOUSE,
Defendant CIVIL LAW - DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUEBT
ENTRY OF A DIVORCE DECREE UNDER SECTION
3301 (a) OF THE DIVORCE CODE
1. I consent to 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
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 the foregoing
document are true and correct. I understand that false statements
herein are made subject to the penalties of 18 Pa.C.S. Section
4904, relating to unsworn falsification to authorities.
Dated: 11/22/99
MI,HA°L VERNON HOUSE
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KENNETH F. LEWIS, ESQUIRE
I.D. #69383
1101 North Front Street
Harrisburg, PA 17102
(717) 234-3136
Attorney for Plaintiff
KAREN REBECCA GREENLUND,
Plaintiff
V.
MICHAEL VERNON HOUSE,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 1999 - 2862
CIVIL LAW - DIVORCE/CUSTODY
O R D E R
AND NOW, this d SA day ofdtl , 1999
upon Stipulation of the parties attach hereto, it is hereby
ORDERED and DECREED as follows:
1. KAREN REBECCA GREENLUND ("Mother") shall have primary
physical custody of the parties' children, JAZZ McGEE HOUSE (born
August 18, 1992); RAYNE EVANS HOUSE (born February 16, 1994) and
TRUE GREENLUND HOUSE (born December 24, 1996). The parties shall
share legal custody.
2. MICHAEL VERNON HOUSE ("Father") shall have liberal
visitation rights with the parties' children, which shall not be
unreasonably withheld by Mother.
3. Father and Mother shall in no way interfere with the
children's rights to receive, initiate, or conduct telephone
communications with the other parent.
4. The parent having physical custody of the children
shall have the duty to immediately advise the other parent of any
unusual occurrence, illness or accident (other than e.g. minor
cold, minor injury).
5. Each parent shall cooperate with the other to the
maximum extent possible to assure that the best interests and
welfare of the children are served. The welfare and convenience of
the children shall be the prime consideration of the parties.
Neither parent shall attempt to alienate or destroy the affection
of the children for the other parent, but shall exert every
reasonable effort to foster a feeling of affection between the
children and both parents.
BY THE COUR .
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KENNETH F. LEWIS, ESQUIRE
I.D. #69383
1101 North Front Street
Harrisburg, PA 17102
(717) 234-3136
Attorney for Plaintiff
KAREN REBECCA GREENLUND, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 1999 - 2862
MICHAEL VERNON HOUSE,
Defendant CIVIL LAW - DIVORCE/CUSTODY
STIPULATION
KAREN REBECCA GREENLUND ("Mother") and MICHAEL VERNON
HOUSE ("Father") stipulate to the following provisions being made
an Order of Court:
1. Mother shall have primary physical custody of the
parties' children, JAZZ McGEE HOUSE (born August 18, 1992) ; RAYNE
EVANS HOUSE (born February 16, 1994) and TRUE GREENLUND HOUSE (born
December 24, 1996). The parties shall share legal custody.
2. Father shall have liberal visitation rights with the
parties' children, which shall not be unreasonably withheld by
Mother.
3. Father and Mother shall in no way interfere with the
children's rights to receive, initiate, or conduct telephone
communications with the other parent.
4. The parent having physical custody of the children
shall have the duty to immediately advise the other parent of any
unusual occurrence, illness or accident (other than e.g. minor
cold, minor injury).
5. Each parent shall cooperate with the other to the
maximum extent possible to assure that the best interests and
welfare of the children are served. The welfare and convenience
of the children shall be the prime consideration of the parties.
Neither parent shall attempt to alienate or destroy the affection
of the children for the other parent, but shall exert every
reasonable effort to foster a feeling of affection between the
children and both parents.
DATED 6/2,S
KAAE9 REBECCA GREENLUND
DATED: [U ?8
MICHAEL VERNON HOUSE
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JUN 25 199??,,
AUG 13
KAREN REBECCA GREENLUND, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. NO. 99-2862
MICHAEL VERNON HOUSE, CIVIL ACTION - LAW
Defendant CUSTODY
ORDER OF COURT
Guido, J. -
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AND NOW, this ?O day of August, 2001, upon consideration of the
attached Custody Conciliation Summary Report, it is hereby ordered and directed as follows:
1. Legal Custody. The parties, Karen Rebecca Greenlund and Michael Vernon
House, shall have shared legal custody of the minor Children, Jazz McGee House, born
August 18, 1992, Rayne Evans House, born February 16, 1994, and True Greenlund House,
born December 24, 1996. Each parent shall have an equal right, to be exercised jointly with
the other parent, to make all major non-emergency decisions affecting the Children's general
well-being including, but not limited to, all decisions regarding their health, education and
religion. Pursuant to the terms of Pa. C. S. § 5309, each parent shall be entitled to all records
and information pertaining to the Children including, but not limited to, medical, dental,
religious or school records, the residence address of the Children and of the other parent. To
the extent one parent has possession of any such records or information, that parent shall be
required to share the same, or copies thereof, with the other parent within such reasonable
time as to make the records and information of reasonable use to the other parent.
2. Physical Custody. Mother shall have primary physical custody subject to Father's
rights of partial physical custody which shall be arranged as follows:
A. Alternating weekends from Friday at 6:30 p.m. until Sunday at 6:30 p.m.,
to commence August 10, 2001.
B. Each Tuesday evening following Mother's custodial weekend from 5:30
p.m. until 7:30 p.m., to commence August 21, 2001:
C. Thursday evenings following Father's custodial weekend from 5:30 p.m.
until 7:30 p.m., to commence August 16, 2001. In the event the Father
cannot exercise any period of custody, Father will provide at least a
twenty-four-hour notice to Mother of such circumstance.
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No. 99-2862 Civil Term
3. H4UOm The following holidays shall be alternated between the parties: Labor
Day, Thanksgiving, Easter, Memorial Day and Independence Day. The rotation will begin with
Labor Day 2001 being enjoyed by Mother. The custodial period for these holidays shall run
from 6:30 p.m. the evening prior to the holiday until 6:30 p.m. the day of the holiday.
4. Christmas. Each year Father shall have custody during the Christmas school
holiday break from 6:30 p.m. the day school is recessed for the school break until 5:00 p.m. on
December 24" and December 261" at 10:00 a.m. until December 281h at 6:30 p.m. Mother
shall have the remaining times during the Christmas holiday school break. It is the parties'
intention that neither parent will have more than two consecutive weekends. Therefore, the
alternating weekend schedule after the school holiday shall begin each year with Father.
5. In the event that there is a Monday school holiday following Father's custodial
weekend, Father may extend his weekend until 6:30 p.m. on the Monday holiday. Father must
give Mother notice by the Thursday preceding the holiday if he intends to exercise this option.
6. Vacation. Each party is entitled to two weeks, which may be exercised
consecutively or non-consecutively, for the purposes of summer vacation. These weeks shall
include the parties' regularly scheduled custodial weekend. The parties shall provide written
notice thirty days in advance to each other of the weeks they intend to exercise their vacation
time. In the event of conflicting times, the party first providing written notice shall have the
option of the mutually sought after time.
7. Moth_ er's DayiFath_er's Day, The custodial period for these holidays shall be from
10:00 a.m. until 6:30 p.m. The Children shall be with Father on Father's Day and Mother on
Mother's Day.
8. Transportation. Father shall provide all transportation incident to his periods of
partial custody.
9. Illness/Iniurv. The parent having physical custody of the Child shall have the duty to
immediately advise the other parent of any unusual occurrence, illness or accident (other than
e.g. minor cold, minor injury).
10. 12i%Jpline. Neither party shall physically discipline the Child, nor permit anyone else
to do so.
11. Teleph ne. Mother and Father shall in no way interfere with the Children's rights to
receive, initiate or conduct telephone communications with the other parent.
No. 99-2862 Civil Term
12. Each parent shall cooperate with the other to the maximum extent possible to
assure that the best interests and welfare of the Children are served, The welfare and
convenience of the Children shall be the prime consideration of the parties. Neither parent
shall attempt to alienate or destroy the affection of the Children for the other parent, but shall
exert every reasonable effort to foster a feeling of affection between the Children and both
parents.
BY THE CO
Edward E. Guido, J.
Dist: John J. Connelly, Jr., Esquire, PO Box 650, Hershey, PA 17033
Kenneth F. Lewis, Esquire, 1101 N. Front Street, Harrisburg, PA 17102
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KAREN REBECCA GREENLUND,
Plaintiff
VS.
MICHAEL VERNON HOUSE,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-2862
CIVIL ACTION - LAW
CUSTODY
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE
1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Children who are the subject of this
litigation is as follows:
NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF
Jazz McGee House August 18, 1992 Mother
Rayne Evans House February 16, 1994 Mother
True Greenlund House December 24, 1996 Mother
2. The parties had their first Custody Conciliation Conference on August 6, 2001, with
the following individuals in attendance: the Mother, Karen Rebecca Greenlund, and her
counsel, Kenneth F. Lewis, Esquire; the Father, Michael Vernon House, and his counsel, John
J. Connelly, Jr., Esquire.
3. The parties reached an agreement in the form a Order as attached.
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Date Melissa Peel Greevy, Esquire
Custody Conciliator