HomeMy WebLinkAbout99-03737N
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OF CUMBERLAND COUNTY
STATE OF PENNA.
Versus
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N t -99.-. 373' .............. Its
DECREE IN
DIVORCE
AND NOW, ...........??!'?` .. ?Y 19.1Y..., it is ordered and
decreed that .... .!F-?s ... : • Q??O.N ............. plaintiff,
and .............. Z)ay.ik. Q:.. P.150 !N................ , defendant,
are divorced from the bonds of matrimony.
The court retains jurisdiction of the following claims which have
been raised of record in this action for which a final order has not yet
been entered;
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....................................................
By Th Court:
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Attest: J,
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Prothonotary ?
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JENNIFER S. OLSON, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 99-3737
DAVID 0.OLSON, CIVIL ACTION - LAW
Defendant DIVORCE and CUSTODY
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 (3301(c))of the Divorce Code.
pted
2. Date and manner of service of the complaint: Hand delivered June 21, 1999; service acce
June 21, 1999.
3. (Complete either paragraph (a) or (b))
(a) Date of execution of the affidavit of consent required by Section 301(c) of the Divorce
Code: by the plaintiff ICI - 13- 9 q ; by the defendant in - c,- 9 9 ;
(b) (1) Date of execution of the plaintiffs affidavit required by Section 3301 (d) of the Divorce
Code: N/A ;
(2) Date of filing and service of the Plaintiffs affidavit upon the defendant: N/A ;
4. Related claims pending: None
5. (Complete either (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, if the decree is to be entered under Section 3301 (d) (1) (i) of the
Divorce Code.
(b) Date Plaintiffs Waiver of Notice in Section 3301(c) Divorce was filed with the
Prothonotary 7-a6 -99
Date Defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary
-a6-99
Re??specctfully Submitted,
Date: By Glom m, Q4A of •n
Je fifer S. O n, Pro Se' ?
Plaintiff
509 Water Street
New Cumberland, PA 17070
(717) 728-4646
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JENNIFER S. OLSON, IN THE COURT OF COMMON PLEAS OF
Plaintiff DAUPHIN COUNTY, PENNSYLVANIA
V. NO. q 9 - 3 73 7
DAVID 0.OLSON, CIVIL ACTION- LAW
Defendant DIVORCE AND CUSTODY
SEPARATION AGREEMENT
THIS AGREEMENT, made this Ox i day of Z I.t r m 1? 1999, by and between
David 0. Olson, hereinafter referred to as "Husband" and Jennifer S. Olson, hereinafter referred to
as "Wife".
WITNESSETH:
WHEREAS, the parties hereto are Husband and Wife, having been married on May 4,
1996, in Wheeler, Wisconsin; and
WHEREAS, there was one child born of this marriage.
WHEREAS, differences have arisen between Husband and Wife, as a result of which it is
the desire of the parties after long and careful consideration, to amicably adjust, compromise and
settle all property rights in, to, or against each other's property or estate, including property
heretofore or subsequently acquired by either party, and to settle disputes existing between them
presently for maintenance, support and counsel fees; and
writing; and
NOW, THEREFORE, in consideration of the mutual promises, covenants, and agreements
hereinafter contained, each of the parties hereto, intending to be legally bound hereby promises,
covenants, and agrees as follows:
1) PARTIES TO RESPECT EACH OTHER'S PRIVACY
Neither party will molest the other, or compel the other to cohabit or in any way
harass or malign the other, nor in any way interfere with the peaceful existence of the other.
2) REAL PROPERTY
The parties owned a mobile home which was located in Regent Acres Mobile Home Park,
695 Salem Road, Lot #111, Etters, York County, Pennsylvania. Said mobile home has
reverted to the co-signer on the mortgage by mutual agreement of the parties.
3) PERSONAL PROPERTY
The parties agree that Husband shall retain such items of property personal to him
and Wife likewise as to such items as clothing, jewelry, sports equipment, etc. Husband and
Wife agree that the parties have between themselves their personalty with the exception of
the following items, which are in the possession of Husband:
a Wedding Video
b. Two (2) Kitchen Chairs (given by Wife's mother)
C. Baker's Rack (given by Wife's mother)
d. Wicker Shelves (given by Wife's mother)
e. Wooden Bathroom Shelf
Husband agrees to return to Wife Items "b through e" within fifteen (15) days of the
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execution of this document and have a copy of the Wedding Video made and give to Wife
within 90 days of the execution of this document.
Each party shall keep and be entitled to sole possession of their respective property.
Each of the parties does hereby specifically waive, release, renounce and forever
abandon whatever claims, if any, he or she may have to the sole and separate property of the
other, including IRA, pension and profit sharing plans held in the individual names of the
parties and Wife specifically waives any and all interest she may have in Husband's 401K
Plan with Swift Transportation, his present employer. The parties agree specifically to
execute any and all documents required to effectuate this release.
4) DEBTS
Husband shall assume and pay the parties ELAN Visa account with a current
outstanding balance of approximately $1,500.00 and Sears Credit Card in the amount of
approximately $2,500.00. The parties agree that both of these cards will be returned to the
respective companies and neither party will make additional charges on either card.
Both parties recognize their equal responsibility to Pauline B. Hatter, Wife's
maternal grandmother, with respect to their debt to her in the amount of $13,071.53. Each
party shall be liable for one-half (Y2) of the debt or $6,535.77 each.
Each party recognized and assumes sole liability for debts individually incurred after
separation. Each party recognizes and assumes sole liability for debts individually incurred
after separation. Each agrees to pay and indemnify and hold the other harmless from any
and all debts and liabilities after the date of separation incurred by the other without the
express written consent of the party.
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5) MUTUAL DISCHARGE
Wife relinquishes her inchoate intestate right in the estate of Husband and Husband
relinquishes his inchoate intestate right in the estate of Wife, and each of the parties hereto
by this presents for himself or herself, his or her heirs, executors, administrators or assigns
does remise, release, quitclaim and forever discharge the other party hereto, his or her heirs,
executors, administrators or assigns, or any of them, of any and all claims, demands,
damages, actions, causes of action or suits at law or in equity of whatsoever kind or nature
for or because of a matter or thing done, omitted or suffered to be done by said party prior to
and including the date hereof including alimony, support, alimony pendente lite, etc., except
that this release shall in no way exonerate or discharge either party hereto from the
obligations and promises made and imposed by reason of this Agreement. Furthermore, in
consideration of the mutual covenants contained herein, the parties agree to incur no debt or
obligation which may result in an obligation on the part of the other and hereby agree to
indemnify and hold harmless the other from any claims, cost or expense which may result
therefrom and furthermore agree to the specific performance of any of the covenants and
agreements contained herein in law or in equity along with the cost of compelling such
compliance including costs of suit and reasonable attorney's fees.
6) DIVORCE
The parties hereto agree to consent to a no-fault divorce and execute such consents,
if that shall be requested, as may be necessary to complete the divorce.
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7) CUSTODY
The issue of custody of the parties child, Steven C. Olson, born January 23, 1997, in
Camp Hill, Pennsylvania will be filed as a separate Stipulated Custody Agreement and
entered as an Order of Court.
8) EXECUTION OF DOCUMENTS
The parties hereto agree to execute and deliver all papers needed to effectuate the
terms and intentions of this Agreement.
9) CONSTRUCTION OF AGREEMENT
This Agreement encompasses all agreements between the parties concerning the
matters set forth herein and may not be altered or omitted except in writing executed by the
parties; the waiver of any term, condition or provision of this Agreement shall in no way be
deemed a waiver of any other terms, conditions, or provisions of this Agreement.
If any term, condition or provision of this Agreement shall be determined to be void
or invalid in law or otherwise, then only that term, condition or provision shall be stricken
from this Agreement, and in all other respects, this Agreement shall be valid and continue in
full force.
This Agreement shall be construed under the laws of the Commonwealth of
Pennsylvania.
This Agreement is intended as a final agreement as to all rights of the parties.
This Agreement is executed in triplicate and Husband and Wife, as parties hereto,
acknowledge the receipt of a duly executed copy hereof.
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10) AGREEMENT TO BE INCORPORATED IN DIVORCE DECREE
The parties agree that the terms of this Agreement may be incorporated into any
divorce decree, which may be entered with respect to them, however, it shall not be merged
with the said decree.
11) BREACH
If either party breaches any provisions of this Agreement, the other party shall have
the right, at his or her election, to sue for damages for such breach, or seek specific
performance or such other remedies or relief as may be available to him or her in law or in
equity, and the party breaching this Agreement shall be responsible for payment of legal
fees and costs incurred by the other in enforcing their rights under this Agreement.
12) VOLUNTARY EXECUTION
The parties hereto have had an opportunity to review this Agreement independently
of the other, and have been informed of the right to have this Agreement reviewed and
examined by an attorney of his or her own choice. Each party has been given an opportunity
to read and review this document, and have this document read and reviewed by his or her
attorney prior to the signing of this Agreement. Each party acknowledges that the
Agreement is fair and equitable and is being entered into voluntarily, and that it is not the
result of any duress or undue influence; that affixing their respective signature to this
Agreement is an indication that they have read this Agreement and are informed of its
content. Each party is satisfied that an equitable overall result is being accomplished by the
terms of this Agreement.
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IN WITNESS WHEREOF, the parties hereto have set their hands and seals the
date first above written.
WITNESS
David O. Olson \
qQ n1m t_Qo n ';? .
Jennifer S. n
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF
SS.
On this, the -;J-/ day of 1999, before me a notary public, the
undersigned officer, personally appeared Jennifer S. Olson, known to me (or satisfactorily proven)
to be the person whose name is subscribed to the within instrument, and acknowledged that she
executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
NOTARIAL SEAL
ALLAN M. WOLFE, Notary Public
Harrisburg, Dauphin CouMv
My Commission Explras March 5 2001
64V !G7
Notary Public
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COMMONWEALTH OF PENNSYLVANIA )
COUNTY OF
SS.
On this, the -04- day of 1999, before me a notary public, the
undersigned officer, personally appeared David 0. Olson, known to me (or satisfactorily proven) to
be the person whose name is subscribed to the within instrument, and acknowledged that he
executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
NOTARIAL SEAL
ALLAN M. WOLFE, Notary Public
Harrisburg, Dauphin Countyry
My Commission Explres March 5, 2001 i
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Notaryc
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JENNIFER S. OLSON, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 99 "37-3 -2
DAVID 0.OLSON, CIVIL ACTION - LAW
Defendant DIVORCE and CUSTODY
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in Court. If you wish to defend against the claims set forth in the following
pages, you must take action within twenty (20) days after this Complaint and Notice are served, by
entering a written appearance personally or by attorney and filing in writing with the Court your
dfenses or objections to the claims set forth against you. You are warned that if you fail to do so the
case may proceed without you and a judgment may be entered against you by the Court witthout
further notice for any money claimed in the Complaint or for any other claim or relief requested by
the Plaintiff. You may lose money or property or other rights important to you, including custody
or visitation of your children.
When the grounds 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 the Cumberland County Court House, Carlisle, Pennsylvania, 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.
CUMBERLAND COUNTY LEGAL SERVICES
COURT ADMINISTRATOR
4'n'FLOOR, CUMBERLAND COUNTY COURTHOUSE
ONE COURTHOUSE SQUARE
CARLISLE, PA 17013
(717) 240-6200
JENNIFER S. OLSON,
Plaintiff
V.
DAVID 0.OLSON,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 9 9. 3 9 9'7 ? ?:.Q 72,-
CIVIL ACTION - LAW
DIVORCE and CUSTODY
COMPLAINT IN DIVORCE and CUSTODY
TO THE HONORABLE, THE JUDGES OF SAID COURT:
AND NOW COMES, Jennifer S. Olson, Plaintiff, and states the following:
1) Plaintiff, Jennifer S. Olson, is an adult sui juris, who currently resides at 509 Water Street, New
Cumberland, York County, Pennsylvania 17070.
2) Defendant, David O. Olson, is an adult sui juris, who currently resides at 127 Summer Lane,
Enola, Cumberland County, Pennsylvania 17025.
3) Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania
for at least six months immediately previous to the filing of this Complaint.
4) The parties were married on May 4 1996, in Wheeler, Wisconsin.
5) That on January 23, 1997, Steven Chadwick Olson was bom of the marriage.
6) That a Custody Stipulation has been filed contemporaneously herewith having been executed by
the parties evidencing their mutual agreement with respect to custody.
7) There have been no prior actions of divorce or annulment between the parties in this or any
other jurisdiction.
8) Neither party is a member of the Armed Forces of the United States.
COUNT I - IRRETRIEVABLE BREAKDOWN
3301 (c) of the Divorce Code
9) Paragraphs 1 through 8 are hereby incorporated by reference and made apart hereof.
10) The marriage is irretrievably broken.
a) Plaintiff and Defendant have lived separate and apart since September 9, 1998.
11) Defendant has been advised as to the availability of counseling and that he may have the
right to request that the Court require the parties to participate in counseling.
12) Plaintiff requests the Court to enter a decree of divorce.
WHEREFORE, Plaintiff prays that a judgment be entered in favor of herself and against
the Defendant as follows:
a. As to Count I, that upon the Defendant's execution of an Affidavit consenting to a
divorce because the marriage is irretrievably broken, that a decree in divorce be
entered divorcing Plaintiff from the bonds of matrimony between the said Plaintiff
and Defendant.
Dater 1 r?0 IX ?i
Respectfully submitted,
By .
Je ' er SWOIPr?ii
Plaintiff
509 Water Street
New Cumberland, PA 17070
(717) 770-0646
VERIFICATION
Jennifer S. Olson hereby states that she is the Plaintiff in this action and that the statements
of fact made in the foregoing Divorce Complaint are true and correct to the best of her personal
knowledge, information and belief. The undersigned understands statements herein are made
subject to the penalties of 18 Pa. Cons. Stat. §4904, relating to unworn falsification to authorities.
Date LPno . 099 K 6• CJ
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JENNIFER S. OLSON, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. ?
99 3"I ?' j
DAVID 0.OLSON, CIVIL ACTION - LAW
Defendant DIVORCE and CUSTODY
ACCEPTANCE OF SERVICE
I, David O. Olson, Defendant in the above captioned divorce action, hereby accept personal
service at 127 Summer Lane, Enola, Pennsylvania, of the Complaint in Divorce, filed in the Court
of Common Pleas of Cumberland County and Docketed to No. 4 2323-/and file
ate.
Dated: ?o a 1- l
David O.Olson, Defendant
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JENNIFER S. OLSON, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 99-3737
DAVID 0.OLSON, CIVIL ACTION - LAW
Defendant DIVORCE and CUSTODY
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
3u?w of 1.0 1499 and served on Sut,v? ;al, 199
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have
elapsed from the date of filing the Complaint.
3. I consent to the entry of a final decree of divorce after service of notice of intention to
request entry of the decree.
I 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 unworn
falsification to authorities.
Dated: /n- I -? -'9 ?, 6. O-R l
Jibnnifer S. Olson, Plaintiff
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JENNIFER S. OLSON, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO.
DAVID 0.OLSON, CIVIL ACTION - LAW
Defendant DIVORCE and CUSTODY
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, lawyers' 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 the Court and that a
copy of the decree will be sent to me immediately after it is filed with the Prothonotary.
I VERIFY THAT THE STATEMENTS MADE IN THIS AFFIDAVIT ARE TRUE
AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE
SUBJECT TO THE PENALTIES OF 18 Pa.C.S. SECTION 494 RELATING TO
UNSWORN FALSIFICATION TO AUTHORITIES.
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Date: i-/ `ALP ,'r?1'a_A
femtifer S. Ison, Plaintiff
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JENNIFER S. OLSON, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 99 -3737
DAVID 0.OLSON, CIVIL ACTION - LAW
Defendant DIVORCE and CUSTODY
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
1A49 and served on rtp a
I ' /999
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have
elapsed from the date of tiling the Complaint.
3. I consent to the entry of a final decree of divorce after service of notice of intention to
request entry of the decree.
I 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 unswom
falsification to authorities.
David 0. Olson, De endant
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JENNIFER S. OLSON, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 9?-S73'7
DAVID 0.OLSON, CIVIL ACTION - LAW
Defendant DIVORCE and CUSTODY
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE
I. I consent to the entry ofa final decree of divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property, lawyers' 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 the Court and that a
copy of the decree will be sent to me immediately after it is filed with the Prothonotary.
I VERIFY THAT THE STATEMENTS MADE IN THIS AFFIDAVIT ARE TRUE
AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE
SUBJECT TO THE PENALTIES OF IS Pa.C.S. SECTION 494 RELATING TO
UNSWORN FALSIFICATION TO AUTHORITIES.
Date: 7-1,q-,?9' , COL
David 0. Olson, Defendant
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JENNIFER S. OLSON, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 99-3737
DAVID 0.OLSON, CIVIL ACTION - LAW
Defendant DIVORCE and CUSTODY
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 (3301(c))of the Divorce Code.
2. Date and manner of service of the complaint: Hand delivered June 21, 1999; service accepted
June 21, 1999.
3. (Complete either paragraph (a) or (b))
(a) Date of execution of the affidavit of consent required by Sect 301(c) of the Divorce
Code: by the plaintiff ) I e- 99 ; by the defendant - .? - q ;
(b) (1) Date of execution of the plaintiff's affidavit required by Section 3301 (d) of the Divorce
Code: N/A ;
(2) Date of filing and service of the Plaintiffs affidavit upon the defendant: N/A ;
4. Related claims pending: None
5. (Complete either (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, if the decree is to be entered under Section 3301 (d) (1) (i) of the
Divorce Code.
(b) Date Plaintiffs Waiv f Notice in Section 3301(c) Divorce was filed with the
Prothonotary ? `A
Date Defendant's Waiver Notice in Section 3301(c) Divorce was filed with the Prothonotary
Respectfully Submitted,
Date: By \t?snjna O-N cs 01D ?
Jennifer S. Olso Pro Se'
Plaintiff
509 Water Street
New Cumberland, PA 17070
(717) 728-4646
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JENNIFER S. OLSON,
Plaintiff
V.
DAVID 0.OLSON,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. `q 4 - -r) -? 7
CIVIL ACTION - LAW
DIVORCE and CUSTODY
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on?u
l ` and served on
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have
elapsed from the date of filing the Complaint.
3. I consent to the entry of a final decree of divorce after service of notice of intention to
request entry of the decree.
I 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 unswom
falsification to authorities.
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Dated: 7 / 1 rr , , i uT??'
Jennifer S Olson, Plaintiff
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JENNIFER S. OLSON, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO.
DAVID O. OLSON, CIVIL ACTION - LAW
Defendant DIVORCE and CUSTODY
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on , ,
/ r n and served on . rc.(1)L)
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have
elapsed from the date of filing the Complaint.
3. I consent to the entry of a final decree of divorce after service of notice of intention to
request entry of the decree.
I 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 unswom
falsification to authorities.
Dated: -7-1,9-99 L5eO
David O. Olson, Defendant
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JUN 2 2 1999v
JENNIFER S. OLSON, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. ?- 3-17 3?7
DAVID 0.OLSON, CIVIL ACTION - LAW
Defendant DIVORCE and CUSTODY
ORDER OF COURT
AND NOW, this v3 day of ., l ? 1999, upon agreement of the parties,
the attached Stipulation and Agreement of Custody is made an Order of Court.
BY THE COURT,
J.
JENNIFER S. OLSON,
Plaintiff
V.
DAVID 0.OLSON,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. ?9-,57,31T-
CIVIL ACTION - LAW
DIVORCE and CUSTODY
CUSTODY STIPULATION AND AGREEMENT
THIS AGREEMENT and Stipulation entered into the day and year hereinafter set forth, is by and
between Jennifer S. Olson (hereinafter "Mother") and David O. Olson (hereinafler "Father"), who aver as
follows:
1) Jennifer S. Olson, Plaintiff, is the natural mother and an adult sui juris, who resides at 509 Water
Street, New Cumberland, York County, Pennsylvania 17070.
2) David 0. Olson, Defendant, is the natural father, and an adult sui juris, who resides at 127 Summer
Lane, Enola, Cumberland County, Pennsylvania 17025.
3) Mother and Father are the parents of one (1) child Steven Chadwick Olson, born January 23, 1997.
4) The parties, Jennifer S. Olson and David O. Olson agree to the following custody terms regarding
custody of the minor child Steven C. Olson and request the terms be entered as an Order of Court:
a) Plaintiff Jennifer S. Olson and Defendant David O. Olson shall have joint legal of the minor child.
The parties shall share jointly in major decisions concerning the child's education, medical care and
spiritual upbringing.
b) The parties hereby agree to share equal joint custody of said Child, by the Child spending
alternating weeks with each parem, subject to the holiday schedule. As a result of such designation
each party alone shall have the right and duty to make all day-to-day parental decisions and act as
primary care parent to the Child.
c) The arrangements for the exchange of custody will be as follows:
i) Every Sunday at 6:00 o'clock p.m. unless previously agreed upon otherwise by both parties.
ii) On Easter, Memorial Day, Labor Day, Thanksgiving and Christmas from 9:00 o'clock am until
9:00 o'clock p.m. Therefore, in odd numbered years, Mother shall have physical custody on
Memorial Day and Thanksgiving Day. In even numbered years, Mother shall have physical
custody on Easter, Labor Day and Christmas Day.
iii) Mother shall have physical custody on Mother's Day from 9:00 o'clock a.m. until 9:00 o'clock
p.m.
iv) Father shall have physical custody on Father's Day from 9:00 o'clock a.rruntil 9:00 o'clock
p.m
v) Both parties shall have time with Child on Child's birthday, January 23, or as agreed upon the
day before or the day after.
vi) At all other times as mutually agreed upon by the parties.
d) At no time shall Mother nor Father take the Child outside the Commonwealth of Pennsylvania
unless the party provides at least thirty (30) days notice in writing, said notification to also provide
the following information:
i) the exact location to which the Child is to be taken
ii) the length of time which the Child is to be out of the Commonwealth
iii) A telephone number at which the non-custodial parent can reach the Child.
5) TAXES
Parties agree that Mother shall claim the Child as a dependent and Earned Income Credit, if
applicable, for the purpose of the 1999 Federal and State Income Tax filing and each odd filing year
thereafter.
6) ENFORCEMENT
If either party breaches any provision of this Agreement the other party shall have the right
at her or his election, to sue for damages for such breach or to seek other remedies or relief as may
be available to her or him, and the party breaching this Agreement shall be responsible for payment
of reasonable legal fees and costs incurred by the other in enforcing her or his rights under this
Agreement. Failure to seek a remedy for one or more breaches shall not be deemed a waiver of any
subsequent breach.
7) ORDER OF THE COURT
The parties agree that this Agreement shall be entered as an Order of Court and shall
continue in full force and effect until:
a) Further Order of Court, or
b) Stipulation of the parties.
8) ADDITIONAL INSTRUMENTS
Each of the parties shall from time to time, at the request of the other, execute,
acknowledge and deliver to the other any and all further instruments that may be reasonably
required to give full force and effect to the provisions of this Agreement.
9) ENTIRE AGREEMENT
This Agreement constitutes the entire understanding of the parties and supersedes any and
all prior agreements or negotiations between them with respect to Custody of the minor Child
Steven Chadwick Olson.
10) SUPPORT
This Agreement shall not affect any support order currently in force, nor shall it preclude
either party from seeking future support or seeking future modification of any support order in any
other state of appropriate jurisdiction if it shall become desirable or necessary.
IN WITNESS THEREOF, the parties have hereunto set their hands and seals on the day and year
first above written.
-? Q-??_
Jennifer S. OI ??
David 0. Olson
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF..lwsn ra , riT
SS.
On this, the _azk day of 1999, before me a notary public, the
undersigned officer, personally appeared Jennifer S. Olson, known to me (or satisfactorily proven)
to be the person whose name is subscribed to the within instrument, and acknowledged that she
executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
NOTARIAL SEAL ^14?
ALLAN M, WOLF, Notary public
Namsburp DauphlnCoun Notary Public
Ny Commission Explras March 2001
COMMONWEALTH OF PENNSYLVANIA )
COUNTY OF )
SS.
On this, the 12 / day of 1999, before me a notary public, the
undersigned officer, personally appeared David O. Olson, known to me (or satisfactorily proven) to
be the person whose name is subscribed to the within instrument, and acknowledged that he
executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
lic ,
2001
15W
&Z n'1 62e
Notary Public
M
r
a
n-
:•-
t`? cP C)
JENNIFER S. OLSON,
Plaintiff
VS.
DAVID O. OLSON,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
NO.: 99-3737
CUSTODY/VISITATION
ORDER
AND NOW, this _ I IL
- day of I?f 1999, upon
SEP 2 9
consideration of the within Petition and Stipulation, IT IS HEREBY ORDERED
as follows:
1. That this Court's Order of June 23, 1999, shall be and is hereby
vacated.
2. That primary physical custody of STEVEN CHADWICK OLSON, born
January 23, 1997, shall be and remain in his Father, DAVID O. OLSON.
3. It is the intention of the parties and the parties agree that they will
share joint legal custody of their minor child. The parties agree that major
decisions concerning the child, including, but not necessarily limited to, the
child's health, welfare, education, religious training and upbringing shall be
made by them jointly, after discussion and consultation with each other, with a
view toward obtaining and following a harmonious policy in the child's best
interests. Each party agrees not to impair the other party's right to shared
legal custody of the child. Each party agrees not to attempt to alienate the
affections of the child from the other party nor to permit any third person to
attempt to so alienate the affections of the child from the other party. Each
party shall notify the other of any activity or circumstance concerning the child
that could reasonably be expected to be of concern to the other. Day-to-day
decisions shall be the responsibility of the party then having physical custody.
With regard to any emergency decisions which must be made, the party having
physical custody of the child at the time of the emergency shall be permitted to
make any immediate decisions necessitated thereby. However, that party shall
inform the other of the emergency and consult with him or her as soon as
possible. Each party shall be entitled to complete and full information from
any doctor, dentist, teacher, professional or authority and to have copies of any
reports given to either party.
4. That the mother of the minor child, JENNIFER S. OLSON, shall have
liberal rights of temporary physical custody from time to time as the parties
shall hereafter agree.
5. That Father shall claim the minor child as a dependent for tax year
1999 and all subsequent years until further Order of Court.
BY THE
J.
V
? 4.
a
7
0
JENNIFER S. OLSON,
Plaintiff
VS.
DAVID O. OLSON,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO.: 99-3737
CUSTODY/VISITATION
PETITION TO MODIFY CUSTODY ORDER
NOW COMES the Defendant, DAVID O. OLSON, Pro Se, and respectfully
represents as follows:
1. That Defendant is DAVID O. OLSON, who currently resides at 127
Summer Lane, Enola, County of Cumberland, Pennsylvania.
2. That Plaintiff is JENNIFER S. OLSON, who currently resides at 140
Altoona Avenue, Enola, County of Cumberland, Pennsylvania.
3. That the parties are the natural parents of a minor child, STEVEN
CHADWICK OLSON, born January 23, 1997.
4. That on June 23, 1999, the Honorable Edgar B. Bayley entered an
Order of Custody granting joint custody to the parties. A copy of said Order is
attached hereto.
5. That the parties have entered into a Stipulation attached hereto
amending said Order.
6. That the parties desire that said Order of June 23, 1999, shall be
vacated and a new Order shall be entered in accordance with the attached
Stipulation.
WHEREFORE, Defendant respectfully requests that Your Honorable
Court vacate the Order of June 23, 1999, and enter a new Order in accordance
with the attached Stipulation.
Respectfully submitted,
DAVID O. OLSON, Pro Se
127 Summer Lane
Enola, Pennsylvania 17025
(717) 728-7535
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF DAUPHIN
I verify that the statements in the foregoing Petition are true and correct.
I understand that false statements herein are made subject to the penalties of
18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities.
DATE AVID O. OLSON
JENNIFER S. OLSON,
Plaintiff
VS.
DAVID O. OLSON,
Defendant
AGREEMENT, made this
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO.: 99-3737
CUSTODY/ VISITATION
STIPULATION
day of September, 1999, by and between
DAVID O. OLSON, hereinafter referred to as "Father," and JENNIFER
S. OLSON, hereinafter referred to as "Mother."
WHEREAS, the parties hereto are the natural parents of a minor child,
STEVEN CHADWICK OLSON, born January 23,1997; and
WHEREAS, an Order of Custody was entered by the Honorable Edgar B.
Bayley on June 23, 1999, a copy of which is attached hereto; and
WHEREAS, the parties desire to vacate said Order and to have the Court
enter a new Order; and
WHEREAS, the parties desire that their Stipulation setting forth the new
terms and conditions of custody be entered as an Order by the Court of
Common Pleas of Cumberland County, Pennsylvania;
NOW THEREFORE, intending to be legally bound, it is hereby agreed as
follows:
1. That this Court's Order of June 23, 1999, shall be and is hereby
vacated.
2. That primary physical custody of STEVEN CHADWICK OLSON, born
January 23, 1997, shall be and remain in his Father, DAVID O. OLSON.
3. It is the intention of the parties and the parties agree that they will
share joint legal custody of their minor child. The parties agree that major
decisions concerning the child, including, but not necessarily limited to, the
child's health, welfare, education, religious training and upbringing shall be
made by them jointly, after discussion and consultation with each other, with a
view toward obtaining and following a harmonious policy in the child's best
interests. Each party agrees not to impair the other party's right to shared
legal custody of the child. Each party agrees not to attempt to alienate the
affections of the child from the other party nor to permit any third person to
attempt to so alienate the affections of the child from the other party. Each
party shall notify the other of any activity or circumstance concerning the child
that could reasonably be expected to be of concern to the other. Day-to-day
decisions shall be the responsibility of the party then having physical custody.
With regard to any emergency decisions which must be made, the party having
physical custody of the child at the time of the emergency shall be permitted to
make any immediate decisions necessitated thereby. However, that party shall
inform the other of the emergency and consult with him or her as soon as
possible. Each party shall be entitled to complete and full information from
any doctor, dentist, teacher, professional or authority and to have copies of any
reports given to either party.
4. That the mother of the minor child, JENNIFER S. OLSON, shall have
liberal rights of temporary physical custody from time to time as the parties
shall hereafter agree.
5. That Father shall claim the minor child as a dependent for tax year
1999 and all subsequent years until further Order of Court.
IN WITNESS WHEREOF, the parties have hereunto set their hands and
DAVID O. OLSON
ENNIFE S.OLSON
official seals.
JENNIFER S. OLSON, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
NO. 9? - 3'737
DAVID 0.OLSON, CIVIL ACTION - LAW
Defendant DIVORCE and CUSTODY
ORDER' OF COURT
R
AND NOW, this J 3 day of c mac. 1999, upon agreement of the parties,
the attached Stipulation and Agreement of Custody is made an Order of Court.
BY THE COURT,
J.
... ?.., n--1e,1
I;en9
.3.... U, . Ta tom.... 19 / y
................ w......a..... ?u..._ _.
Prorhoaotary
JENNIFER S. OLSON, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO.
DAVID 0.OLSON, CIVIL ACTION-LAW r
v
Defendant DIVORCE and CUSTODY
CUSTODY STIPULATION AND AGREEMENT -
THIS AGREEMENT and Stipulation entered into the day and year hereinafter set forth, is by and
between Jennifer S. Olson (hereinafter "Mother") and David O. Olson (hereinafter "Father"), who aver as
follows:
I) Jennifer S. Olson, Plaintiff, is the natural mother and an adult sui juris, who resides at 509 Water
Street, New Cumberland, York County, Pennsylvania 17070.
2) David 0. Olson, Defendant, is the natural father, and an adult sui juris, who resides at 127 Summer
Lane, Enola, Cumberland County, Pennsylvania 17025.
3) Mother and Father are the parents of one (1) child, Steven Chadwick Olson, born January 23, 1997.
4) The parties, Jennifer S. Olson and David O. Olson agree to the following custody terms regarding
custody of the minor child Steven C. Olson and request the terms be entered as an Order of Court:
a) Plaintiff Jennifer S. Olson and Defendant David O. Olson shall have joint legs.( of the minor child.
The parties shall share jointly in major decisions concerning the child's education, medical care and
spiritual upbringing.
b) The parties hereby agree to share equal joint custody of said Child, by the Child spending
alternating weeks with each parent, subject to the holiday schedule. As a result of such designation
each party alone shall have the right and duty to make all day-to-day parental decisions and act as
primary care parent to the Child.
c) The arrangements for the exchange of custody will be as follows:
i) Every Sunday at 6:00 o'clock p.m unless previously agreed upon otherwise by both parties.
ii) On Easter, Memorial Day, Labor Day, Thanksgiving and Christmas from 9:00 o'clock am until
9:00 o'clock p.m Therefore, in odd numbered years, Mother shall have physical custody on
Memorial Day and Thanksgiving Day. In even numbered years, Mother shall have physical
custody on Easter, Labor Day and Christmas Day.
iii) Mother shall have physical custody on Mother's Day from 9:00 o'clock a.m. until 9:00 o'clock
p.m.
iv) Father shall have physical custody on Father's Day from 9:00 o'clock a.m. until 9:00 o'clock
P.M.
v) Both patties shall have time with Child on Child's birthday, January 23, or as agreed upon the
day before or the day after.
vi) At all other times as mutually agreed upon by the parties,
d) At no time shall Mother nor Father take the Child outside the Commonwealth of Pennsylvania
unless the party providgs at least thirty (30) days notice in writing, said notification to also provide
the following information:
i) the exact location to which the Child is to betaken
ii) the length of time which the Child is to be out of the Commonwealth
ill) A telephone number at which the non-custodial parent can reach the Child.
5) TAXES
Parties agree that Mother shall claim the Child as a dependent and Earned Income Credit, if
applicable, for the purpose of the 1999 Federal and State Income Tax filing and each odd filing year
thereafter.
6) ENFORCEMENT
If either party breaches any provision of this Agreement the other party shall have the right
at her or his election, to sue for damages for such breach or to seek other remedies or relief as may
be available to her or him, and the party breaching this Agreement shall be responsible for payment
of reasonable legal fees and costs incurred by the other in enforcing her or his rights under this
Agreement. Failure to seek a remedy for one or more breaches shall not be deemed a waiver of any
subsequent breach.
7) ORDER OF THE COURT
The parties agree that this Agreement shall be entered as an Order of Court and shall
continue in full force and effect until.
a) Further Order of Court, or
b) Stipulation of the parties.
S) ADDITIONAL INSTRUMENTS
Each of the parties shall from time to time, at the request of the other, execute,
acknowledge and deliver to the other any and all further instruments that may be reasonably
required to give full force and effect to the'provisioa of this Agreement.
9) ENTIRE AGREEMENT
This Agreement constitutes the entire understanding of the parties and supersedes any and
all prior agreements or negotiations between them with respect to Custody of the minor Child
Steven Chadwick Olson.
10) SUPPORT
This Agreement shall not affect any support order currently in force, nor shall it preclude
either party from seeking future support or seeking future modification of any support order in any
other state ofappropriate jurisdiction if it shall become desirable or necessary.
IN WITNESS THEREOF, the parties have hereunto set their hands and seals on the day and year
first above written.
S. OW &
David O.
COMMONWEALTH OF PENNSYLVANIA )
COUNTY OFY
SS.
On this, the -0 day of 1999, before me a notary public, the
undersigned officer, personally appeared Jennifer S. Olson, known to me (or satisfactorily proven)
to be the person whose name is subscribed to the within instrument, and acknowledged that she
executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
NDTARIALSEAL C
ALLAN M. WDLFE, Notary Public GG?GL« k. 4/
Harrisburg, Dauphin County Notary Public
My Commission Expires March 5.20b•
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF
SS.
On this, the -,I/ day of ? 1999, before me a notary public, the
undersigned officer, personally appeared David O. Olson, known to me (or satisfactorily proven) to
be the person whose name is subscribed to the within instrument, and acknowledged that he
executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
NOTARIAL SEAL
EuHamr?r4jstrVg OLFS,
.DauphiOppPm?ybii?
ion Expires March 5, y001
Notary Public
C1)
C) ",
i CL
cr)
f, 4.•
G' -
U ?? U
MAR 2 9 2000
JENNIFER S. OLSON, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. CIVIL ACTION - LAW
DAVID 0. OLSON, : NO.: 99-3737
Defendant : CUSTODY/VISITATION
ORDER
AND NOW, this "3(3'day of r%,,? 2000, upon consideration of
the within Petition and Stipulation, IT IS HEREBY ORDERED as follows:
1. That this Court's Order of October 4, 1999, shall be and is hereby vacated.
2. That primary physical custody of STEVEN CHADWICK OLSON, bom
January 23, 1997, shall be and remain in his Father, DAVID 0. OLSON.
3. It is the intention of the parties and the parties agree that they will share
joint legal custody of their minor child. The parties agree that major decisions
concerning the child, including, but not necessarily limited to, the child's health,
welfare, education, religious training and upbringing shall be made by them jointly,
after discussion and consultation with each other, with a view toward obtaining and
following a harmonious policy in the child's best interests. Each party agrees not to
impair the party's right to shared legal custody of the child. Each party agrees not to
attempt to alienate the affections of the child from the other party nor to permit any
third person tp attempt to so alienate the affections of the child from the other party.
Each party shall notify the other of any activity or circumstance concerning the
I. .
?;rr.F?},
child that could reasonably be expected to be of concern to the other. Day-to day
decisions shall be the responsibility of the party then having physical custody.
With regard to any emergency decisions which must be made, the party having
physical custody of the child at the time of the emergency shall be permitted to
make any immediate decisions necessitated thereby. However, that the party shall
inform the other of the emergency and consult with him of her as soon as possible.
Each party shall be entitled to complete and full information from any doctor,
dentist, teacher, professional of authority and to have copies of any reports given to
either party.
4. That the Mother of the minor child, JENNIFER S. OLSON, shall have
partial physical custody of said child as follows:
A. Every other weekend starting with March 24, 2000.
B. On Easter, Memorial Day, Labor Day, Thanksgiving and
Christmas from 9:00 o'clock a.m. until 8:00 o'clock p.m.. Therefore, in odd number
years, Mother shall have physical custody on Memorial Day and Thanksgiving Day.
In even numbered years, Mother shall have physical custody on Easter, Labor Day
and Christmas Day.
C. Mother shall have physical custody on Mother's Day from 9:00
o'clock a.m. until 8:00 o'clock p.m..
D. Father shall have phsical custody on Father's Day from 9:00
o'clock a.m. until 8:00 o'clock p.m..
E. Both parties shall have time with Child on Child's birthday,
January 23, or as agreed upon the day before or the day after.
F. Mother shall have partial physical custody for a period of one (1)
week out of the summer.
G. At all other times as mutally agreed upon by both parties.
5. At no time shall Mother nor Father take the Child outside the
Commonwealth of Pennsylvania unless the party provides at least thirty (30) days
notice in writing, said notification to also provide the following information:
A. The exact location to which the Child is to be taken
B. The length of time which the Child is to be out of the
Commonwealth
C. A telephone number at which the non-custodial parent can reach
the Child.
6. That Father shall claim the minor as a dependent for tax year 2000 and all
subsequent years until further Order of Court.
7. That both parties shall at all times have full knowledge of child care
provider. This knowledge includes but is not limited to:
A. Name, address and phone number
RV THE COURT.
JENNIFER S. OLSON,
Plaintiff
VS.
DAVID O. OLSON,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO.: 99-3737
CUSTODY/VISITATION
PETITION TO MODIFY CUSTODY ORDER
NOW COMES the Plaintiff, JENNIFER S. OLSON, Pro Se, and respectfully
represents as follows:
1. That the Plaintiff is JENNIFER S. OLSON, who currently resides at 447
South Third Street, Apartment #3, Lemoyne, County of Cumberland,
Pennsylvania.
2. That the Defendant is DAVID 0.OLSON, who currently resides at 127
Summer Lane, Enola, County of Cumberland, Pennsylvania.
3. That the parties are the natural parents of a minor child, STEVEN
CHADWICK OLSON, born January 23, 1997.
4. That on October 4, 1999, the Honorable Edgar B. Bayley entered an
Order of Custody granting primary custody to the Defendant. A copy of said Order
is attached hereto.
5. That the parties have entered into a Stipulation attached hereto amending
said Order.
6. That the parties desire that said Order of October 4, 1999, shall be vacated
and a new Order shall be entered in accordance with the attached Stipulation.
WHEREFORE, Plaintiff respectfully requests that Your Honorable Court
vacate the Order of October 4, 1999, and enter a new Order in accordance with the
attached Stipulation.
Respectfully submitted,
1
J :NNIFER . OLSON, Pro Se
447 South Third Street
Apartment #3
Lemoyne, Pennsylvania 17043
(717) 770-1511
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
1 verify that the statements in the foregoing Petition are true and correct. 1
understand that false statements herein are made subject to the penalties of 18
Pa.C.S. Section 4904, relating to unswom falsification to authorities.
DATE JENNIF 2 S. OLSON
JENNIFER S. OLSON, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. CIVIL ACTION -LAW
DAVID 0.OLSON, : NO.: 99-3737
Defendant : CUSTODY/VISITATION
STIPULATION
h
AGREEMENT, made this c? day of March, 2000, by and between
JENNIFER S. OLSON, hereinafter referred to as "Mother, and DAVID O.
OLSON, hereinafter referred to as "Father."
WITNESSETH:
WHEREAS, the parties hereto are the natural parents of a minor child,
STEVEN CHADWICK OLSON, bom January 23, 1997; and
WHEREAS, an Order of Custody was entered by the Honorable Edgar B.
Bayley on October 4, 1999, a copy of which is attached hereto; and
WHEREAS, the parties desire to vacate said Order and to have the Court
enter a new Order; and
WHEREAS, the parties desire that their Stipulation setting forth the new
terms and conditions of custody be entered as an Order by the Court of Common
Pleas of Cumberland County, Pennsylvania;
NOW THEREFORE, intending to be legally bound, it is hereby agreed as
follows:
1. That this Court's Order of October 4, 1999, shall be and is hereby vacated.
2. That primary physical custody of STEVEN CHADWICK OLSON, born
January 23, 1997, shall be and remain in his Father, DAVID 0. OLSON.
3. It is the intention of the parties and the parties agree that they will share
joint legal custody of their minor child. The parties agree that major decisions
concerning the child, including, but not necessarily limited to, the child's health,
welfare, eduacation, religious training and upbringing shall be made by them
jointly, after discussion and consultation with each other, with a view toward
obtaining and following a harmonious policy in the child's best interests. Each
party agrees not to impair the other party's right to shared legal custody of the child.
Each party agrees not to attempt to alienate the affections of the child from the other
party nor to permit any third person to attempt to so alienate the affections of the
child from the other party. Each party shall notify the other of any activity or
circumstance concerning the child that could reasonably be expected to be of
concern to the other. Day-to-day decisions shall be the responsibility of the party
then having physical custody. With regard to any emergency decisions which must
be made, the party having physical custody of the child at the time of the emergency
shall be permitted to make any immediate decisions necessitated thereby. However,
that the party shall inform the other of the emergency and consult with him or her as
soon as possible. Each party shall be entitled to complete and full information from
any doctor, dentist, teacher, professional or authority and to have copies of any
reports given to either party.
4. That the Mother of the minor child, JENNIFER S. OLSON, shall have
partial physical custody of said child as follows:
A. Every other weekend starting with the weekend of March 24,
2000.
B. On Easter, Memorial Day, Labor Day, Thanksgiving and
Christmas from 9:00 o'clock am until 8:00 o'clock p.m., Therefore, in odd
numbered years, Mother shall have physical custody on Memorial Day and
Thanksgiving Day. In even numbered years, Mother shall have physical custody on
Easter, Labor Day and Christmas Day.
C. Mother shall have physical custody on Mother's Day from 9:00
o'clock a.m. until 8:00 o'clock p.m..
D. Father shall have physical custody on Father's Day from 9:00
o'clock a.m. until 8:00 o'clock p.m..
E. Both parties shall have time with Child on Child's birthday,
January 23, or as agreed upon the day before or the day after.
F. Mother shall partial physical custody for a peroid of one (1) week
out of the summer.
G. At all other times as mutually agreed upon by both parties.
5. At no time shall Mother nor Father take the Child outside the
Commonwealth of Pennsylvania unless the party provides at least thirty (30) days
notice in writing, said notification to also provide the following information:
A. The exact location to which the Child is to be taken
B. The length of time which the Child is to be out of the
Commonwealth
C. A telephone number at which the non-custodial parent can reach
the Child
6. That Father shall claim the minor as a dependant for tax year 2000 and all
subsequent years until further Order of Court.
7. That both parties shall at all times have full knowledge of child cane
provider. This knowledge includes but is not limited to:
A. Name, address and phone number
IN WITNESS WHEREOF, the parties have hereunto set their hands and
l
*EN S.OLSON
C 1
DAVID O. OLSON
official seals.
ti
T ? 7J
1
.
1-? U
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
Plaintiff
(? AA VS.
YJaiUC1 ?. 0
Defendant
File No. 1? - '2) (I l
IN DIVORCE
NOTICE TO RESUME PRIOR SURNAME
Notice is hereby given that the Plaintiff /Defendant in the
above matter, having been granted a Final Decree in Divorce on the
H ` day of C C'"nVJ} r , 19?, hereby elects to resume the
prior surname of ,?n1tJ j F N k -,and gives
this written notice pursuant to the provisions of 54 P.S. S 704.
DATE: I - 't- O 1 - M!" lr ignature ?-
40 in Q us ZE; • _:? t M?
Signature f name being re med
COMMONWEALTH OF PENNSYLVANIA:
SS.
COUNTY OF CUMBERLAND
On the _Rik day of V# P- L- , k ?' before me, a
Notary Public, personally appeared the a ove affiant known to me to
be the person whose name is subscribed to the within document and
acknowledged that he/she executed the foregoing for the purpose
therein contained.
seal. In Witness Whereof, I have hereunto set my hand and official
.
Notary Public
ry NOTARIAL SEAL
JOHN F CONNOLLY Notary Pudic
City Of Carlisle, Cumberland County
M Commission Expires Feb. 26. 2001
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JENNIFER S. FUNK, IN THE COURT OF COMMON PLEAS OF AUG
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
vs. : CIVIL ACTION -LAW
DAVID 0.OLSON, : NO.: 99-3737
Defendant : CUSTODY/VISITATION
ORDER
AND NOW, this Wday of 2003, upon consideration of
the within Petition and Stipulation, IT IS HEREBY ORDERED as follows:
1. That this Court's Order of March 30, 2000, shall be and is hereby vacated.
2. That primary physical custody of STEVEN CHADWICK OLSON, born
January 23, 1997, shall be and remain in his Mother, JENNIFER S. FUNK.
3. It is the intention of the parties and the parties agree that they will share
joint legal custody of their minor child. The parties agree that major decisions
concerning the child, including, but not necessarily limited to, the child's health,
welfare, education, religious training and upbringing shall be made by them jointly,
after discussion and consultation with each other, with a view toward obtaining and
following a harmonious policy in the child's best interests. Each party agrees not to
impair the party's right to shared legal custody of the child. Each party agrees not to
attempt to alienate the affections of the child from the other party nor to permit any
third person tp attempt to so alienate the affections of the child from the other party.
Each party shall notify the other of any activity or circumstance concerning the
child that could reasonably be expected to be of concern to the other. Day-to day
decisions shall be the responsibility of the party then having physical custody.
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With regard to any emergency decisions which must be made, the party having
physical custody of the child at the time of the emergency shall be permitted to
make any immediate decisions necessitated thereby. However, that the party shall
inform the other of the emergency and consult with him of her as soon as possible.
Each party shall be entitled to complete and full information from any doctor,
dentist, teacher, professional of authority and to have copies of any reports given to
either party.
4. That the Father of the minor child, DAVID 0.OLSON, shall have
partial physical custody of said child as follows:
A. Every other weekend starting with August 8, 2003.
B. On Easter, Memorial Day, Labor Day, Thanksgiving and
Christmas from 9:00 o'clock a.m. until 8:00 o'clock p.m.. Therefore, in odd number
years, Father shall have physical custody on Memorial Day and Thanksgiving Day.
In even numbered years, Father shall have physical custody on Easter, Labor Day
and Christmas Day.
C. Father shall have physical custody on Father's Day from 9:00
o'clock a.m. until 8:00 o'clock p.m..
D. Mother shall have phsical custody on Mother's Day from 9:00
o'clock a.m. until 8:00 o'clock p.m..
E. Both paities shall have time with Child on Child's birthday,
January 23, or as agreed upon the day before or the day after.
F. Father shall have partial physical custody for a period of one (1)
week out of the summer.
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G. At all other times as mutally agreed upon by both parties.
5. At no time shall Father nor Mother take the Child outside the
Commonwealth of Pennsylvania unless the party provides at least thirty (30) days
notice in writing, said notification to also provide the following information:
A. The exact location to which the Child is to be taken
B. The length of time which the Child is to be out of the
Commonwealth
C. A telephone number at which the non-custodial parent can reach
the Child.
6. That Mother shall claim the minor as a dependent for tax year 2003 and all
subsequent years until further Order of Court.
7. That both parties shall at all times have full knowledge of child care
provider. This knowledge includes but is not limited to:
A. Name, address and phone number
BY THE COURT.
JENNIFER S. FUNK, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 99-3737
DAVID O. OLSON, CIVIL ACTION - LAW
Defendant DIVORCE and CUSTODY
STIPULATION
AGREEMENT, made this
day of August, 2003, by and between JENNIFER
S. FUNK, hereinafter referred to as "MOTHER", and DAVID 0.OLSON, hereinafter referred
to as "FATHER".
WITNESSETH:
WHEREAS, the parties hereto are the natural parents of the minor child, STEVEN
CHADWICK OLSON, born January 23,1997; and
WHEREAS, an Order of Custody was entered by the Honorable Judge Kevin A. Hess on
March 30, 2000, a copy of which is attached hereto; and
WHEREAS, the parties desire to vacate said Order and to have the Court enter a new
Order: and
WHEREAS, the parties desire that their Stipulation setting forth the new terms and
conditions of custody be entered as an Order by the Court of Common Pleas of Cumberland
County, Pennsylvania;
NOW THEREFORE, intending to be legally bound, it is hereby agreed as follows:
1. That this Court's Order of March 30, 2000 shall be and is hereby vacated.
2. That primary physical custody of STEVEN CHADWICK OLSON, born January 23,
1997, shall be and remain with his MOTHER, JENNIFER S. FUNK.
3. It is the intention of the parties and the parties agree that they will share joint legal
custody of their minor child. The parties agree that major decisions concerning the child,
including, but not necessarily limited to, the child's health, welfare, education, religious
training and upbringing shall be made by them jointly, after discussion and consultation
with each other, with a view toward obtaining and following a harmonious policy in the
child's best interests. Each party agrees not to impair the other party's right to shared
legal custody of the child. Each party agrees not to attempt to alienate the affections of
the child from the other party nor to permit any third person to attempt to so alienate the
affections of the child from the other party. Each party shall notify the other of any
activity or circumstance concerning the child that could reasonably be expected to be of
concern to the other. Day-to-day decisions shall be the responsibility of the party then
having physical custody. With regard to any emergency decisions, which must be made,
the party having physical custody of the child at the time of the emergency shall be
permitted to make any immediate decisions necessitated thereby. However, that party
shall inform the other of the emergency and consult with him or her as soon as possible.
Each party shall be entitled to complete and full information from any doctor, dentist,
teacher, professional or authority and to have copies of any reports given to either party.
4. The FATHER, DAVID O. OLSON, shall have liberal rights of temporary physical
custody of the minor child, from time to time, as the parties shall hereafter agree.
5. That the MOTHER, JENNIFER S. FUNK, shall claim the minor child as a dependent for
the tax year 2003 and all subsequent years until further Order of Court.
IN WITNESS WHEREOF, the parties have herunto set their hands and official seals.
WITNESS
ENNIFF S. FUNK
VID 0. OLSON
MAR 2 9 201Q
JENNIFER S. OLSON, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. CIVIL ACTION -LAW
DAVID 0. OLSON, : NO.: 99-3737
Defendant : CUSTODYNISITATION
ORDER
AND NOW, this &th day of 030-rc
2000, upon consideration of
the within Petition and Stipulation, IT IS HEREBY ORDERED as follows:
1. That this Court's Order of October 4, 1999, shall be and is hereby vacated.
2. That primary physical custody of STEVEN CHADWICK OLSON, bom
January 23, 1997, shall be and remain in his Father, DAVID 0.OLSON.
3. It is the intention of the parties and the parties agree that they will share
joint legal custody of their minor child. The parties agree that major decisions
concerning the child, including, but not necessarily limited to, the child's health,
welfare, education, religious training and upbringing shall be made by them jointly,
after discussion and consultation with each other, with a view toward obtaining and
following a harmonious policy in the child's best interests. Each party agrees not to
impair the party's right to shared legal custody of the child. Each party agrees not to
attempt to alienate the affections of the child from the other party nor to permit any
third person tp attempt to so alienate the affections of the child from the other party.
Each party shall notify the other of any activity or circumstance concerning the
child that could reasonably be expected to be of concern to the other. Day-to day
decisions shall be the responsibility of the party then having physical custody.
With regard to any emergency decisions which must be made, the party having
physical custody of the child at the time of the emergency shall be permitted to
make any immediate decisions necessitated thereby. However, that the party shall
inform the other of the emergency and consult with him of her as soon as possible.
Each party shall be entitled to complete and full information from any doctor,
dentist, teacher, professional of authority and to have copies of any reports given to
either party.
4. That the Mother of the minor child, JENNIFER S. OLSON, shall have
partial physical custody of said child as follows:
A. Every other weekend starting with March 24, 2000.
B. On Easter, Memorial Day, Labor Day, Thanksgiving and
Christmas from 9:00 o'clock a.m. until 8:00 o'clock p.m.. Therefore, in odd number
years, Mother shall have physical custody on Memorial Day and Thanksgiving Day.
In even numbered years, Mother shall have physical custody on Easter, Labor Day
and Christmas Day.
C. Mother shall have physical custody on Mother's Day from 9:00
o'clock a.m. until 8:00 o'clock p.m..
D. Father shall have phsical custody on Father's Day from 9:00
o'clock a.m. until 5:00 o'clock p.m..
G. Both parties shall have time with Child on Child's birthday,
January 23, or as agreed upon the day before or the day after.
F. Mother shall have partial physical custody for a period of one (1)
week out of the summer.
G. At all other times as mutally agreed upon by both parties.
5. At no time shall Mother nor Father take the Child outside the
Commonwealth of Pennsylvania unless the party provides at least thirty (30) days
notice in writing, said notification to also provide the following information:
A. The exact location to which the Child is to be taken
B. The length of time which the Child is to be out of the
Commonwealth
C. A telephone number at which the non-custodial parent can reach
the Child.
6. That Father shall claim the minor as a dependent for tax year 2000 and all
subsequent years until further Order of Court.
7. That both parties shall at all times have full knowledge of child care
provider. This knowledge includes but is not limited to:
A. Name, address and phone number
BY THECOURT.
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and the seal of ,arlisle, Pa.
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JENNIFER S. FUNK,
Plaintiff/ Respondent
VS.
DAVID O. OLSON,
Defendant/ Petitioner
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IN THE COURT OF COMMON PLEAS OFO:X
CUMBERLAND COUNTY, PENNSYLVAI
CIVIL ACTION - LAW
NUMBER: 99-3737 ?p
CUSTODY'
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MOTION TO TRANSFER VENUE -<
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NOW COMES the Defendant/ Petitioner, DAVID O. OLSON, by and
through his attorney, Charles E. Petrie, and respectfully represents as
follows:
1. Defendant/ Petitioner is DAVID O. OLSON, who currently
resides at 51 Fairview Road, New Cumberland, County of York,
Pennsylvania, since 2011.
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2. Plaintiff/ Respondent and the minor child have been residents of
the County of Dauphin for a period of more than six months having
moved to Harrisburg, Pennsylvania in August, 2009; therefore,
jurisdiction of the subject minor child should be in Dauphin County.
3. That at the time of the original filing of the Complaint for
Custody both parties and the subject minor child resided in Cumberland
County, Pennsylvania.
4. The Plaintiff/ Respondent and the subject minor child are now
residents of the County of Dauphin and have been for a period of more
than six months.
5. That Defendant/ Petitioner's Counsel is a resident of Dauphin
County.
6. Dauphin County is a more appropriate forum for the parties.
WHEREFORE, Plaintiff respectfully requests that Your Honorable
Court enter an Order transferring venue to the Court of Common Pleas of
Dauphin County, Pennsylvania, and directing that the Prothonotary of
Cumberland County transfer the case file to the Prothonotary of Dauphin
County.
Respectfully submitted,
Charles E. Petrie
3528 Brisban Street
Harrisburg, PA 17111
(717) 561-1939
Attorney for Defendant/ Petitioner
JENNIFER S. FUNK, IN THE COURT OF COMMON PLEAS OF
Plaintiff/ Respondent CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
vs.
NUMBER: 99-3737
DAVID O. OLSON,
Defendant/ Petitioner : CUSTODY
CERTIFICATE OF SERVICE
I certify that I sent a copy of the foregoing Motion to Transfer
Venue to the Plaintiff/ Respondent at 5101 Haverford Road, Harrisburg,
Pennsylvania 17109, on May 26, 2011, by U.S. First Class Mail, postage
prepaid.
Respectfully Submitted,
Charles E. Petrie
3528 Brisban Street
Harrisburg, PA 17111
(717) 561-1939
Attorney for Defendant/ Petitioner