Loading...
HomeMy WebLinkAbout07-32164, CHERYL M. BEAUDOIN, Plaintiff vs. GREGORY K. PICKEL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : No. d?- 3R /CP Civil Term : ACTION IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. Where the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available at the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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 Bar Association 32 South Bedford St. Carlisle, Pa. 17013 (717) 249-3166 F, CHERYL M. BEAUDOIN, Plaintiff VS. GREGORY K. PICKEL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : No. 01 - 3.216 Civil Term ACTION IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Cheryl M. Beaudoin, a competent adult individual, who resides at 420 Croghan Drive, Carlisle, Cumberland County, Pennsylvania, 17013. 2. Defendant is Gregory K. Pickel, a competent adult individual, who resides at 420 Croghan Drive, Carlisle, Cumberland County, Pennsylvania, 17013. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on November 7, 1992, in Winchester, Virginia. 5. There have been no prior actions of divorce or for annulment between the parties. 6. 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. 7. Plaintiff and Defendant have two children together, namely Elizabeth Beaudoin, date of birth, January 26, 1998, and David Beaudoin, date of birth, May 26, 1994. 8. Plaintiff and Defendant are both citizens of the United States of America. 9. Neither Plaintiff or Defendant are a member of the Armed Forces of the United States of America or any of its allies. 10. The Plaintiff avers that the grounds on which this action is based are: That the marriage is irretrievably broken. WHEREFORE, Plaintiff requests the court to enter a decree in divorce. 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. k--1A • a er c?-?? Cher ? . Beaudoin, Plaintiff Respectfully submitted, Date: 6 ,2 7 07- ne Adams, Esquire D. No. 79465 64 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF W O rx?, ?r 5 P z N 0 a CAI O co OO C CHERYL M. BEAUDOIN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION -LAW GREGORY K. PICKEL, NO. 07-3216 CIVIL TERM Defendant IN DIVORCE ACCEPTANCE OF SERVICE I, Hannah Herman Snyder, Esquire, represent Gregory K. Pickel in the above captioned matter. I hereby accepted service of the Notice to Defend and Complaint in Divorce on or about the date listed below, which was filed by Plaintiffs attorney under the above captioned number and I hereby affirm I was authorized to do so. DATE: (p-Ia--6l N, txy%ftk°gg%Mftn-SA m,An Hannah Herman-Snyder, Esquire GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 C? ?_ ' ?, ..,, t ` 5 ..9 - ? ?? i. ?.' '.?,e f' .? ,.. -"? ?! CHERYL M. BEAUDOIN, Plaintiff VS. GREGORY K. PICKEL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 07 - 3216 Civil Term ACTION IN CUSTODY CUSTODY COMPLAINT 1. Plaintiff is Cheryl M. Beaudoin, whose current address is 420 Croghan Drive, Carlisle, Cumberland County, Pennsylvania, 17013. 2. Defendant is Gregory K. Pickel, who currently resides at 420 Croghan Drive, Carlisle, Cumberland County, Pennsylvania, 17013. 3. Plaintiff is the Mother of the following children and seeks a custody order regarding the following children: NAME DOB/AGE ADDRESS Elizabeth Beaudoin January 26, 1998 420 Croghan Drive, Carlisle, Pa. David Beaudoin January 26, 1998 420 Croghan Drive, Carlisle, Pa. Mother and Father married on November 7, 1992. Mother and Father currently share legal and physical custody of the children. During the past five years, the child has resided with the following persons and at the following addresses: NAME ADDRESSES DATES Cheryl M. Beaudoin 420 Croghan Drive 2002 - present Gregory K. Pickel Carlisle, Pa. 17013 The mother of the child is Cheryl M. Beaudoin. Her current address is 420 Croghan Drive, Carlisle, Pa., 17013. In August 2007, she is planning on moving to Winchester, Virginia with the children. She is currently married to Gregory K. Pickel. A divorce has been filed under the above-captioned docket number but is not final. The father the child is Gregory K. Pickel. His current address is 420 Croghan Drive, Carlisle, Pa., 17013. He is currently married to Cheryl M. Beaudoin. A divorce has been filed under the above-captioned docket number but is not final. 4. The relationship of Plaintiff to the children is that of Mother. The plaintiff currently resides with the children and the father in the marital home, but has also started taking steps towards moving with the children to Winchester, Virginia. During the summer, the children have been staying both at the marital home in Carlisle and in Winchester, Virginia. 5. The relationship of Defendant to the children is that of Father. The defendant currently lives with Mother and the children. 6. Plaintiff has not participated as a party or witness, or in another 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 a court of this Commonwealth. Plaintiff does not know of a party to the proceedings who has physical custody of a child or anyone who claims to have custody or visitation rights with respect to either child. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because: The parties entered a custody stipulation on July 16 2007, whereby the parties agreed that Mother would retain primary custody of the children and move to Winchester, Virginia. Mother has taken steps towards her move and anticipates finalizing her move in August 2007. The parties are requesting that their stipulation be entered as an Order of Court. Entry of the Order would be in the best interest of the children because it provides stability for the children and liberal time with both parents 8. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child has been named as parties to this action. WHEREFORE, Plaintiff requests the court to enter a custody Order regarding the children, pursuant to the parties' stipulation. Respectfully submitted, Date: e Adams, Esquire I.D. No. 79465 64 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF VERIFICATION I verify that the statements made in this Custody 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. Date: '71 '7 lp? Cheryl . Beaudoin, Plaintiff -tit 4 1-4 CJ -?v r CHERYL M. BEAUDOIN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 07 - 3216 Civil Term GREGORY K. PICKEL, ACTION IN CUSTODY Defendant STIPULATION AND CUSTODY AGREEMENT This Stipulation and Custody Agreement is made this 14 day of , 2007, by and between Cheryl M. Beaudoin, (Hereinafter referred to as "Mother"), oCumberland County, Pennsylvania, and Gregory K. Pickel, (Hereinafter referred to as "Father"), of Carlisle, Cumberland County, Pennsylvania; WHEREAS, Mother and Father are the natural parents of two children, namely, Elizabeth Beaudoin date of birth, January 26, 1998; and David Beaudoin, date of birth, May 26, 1994; WHEREAS, Mother and Father have reached an agreement relative to the future care, custody, and visitation of their children, the terms of which agreement both parties desire to set forth in the present Stipulation and Custody Agreement, and; WHEREAS, Mother and Father desire the provisions of the present Stipulation and Custody Agreement be approved by the Honorable Court of Common Pleas of Cumberland County and entered as a Court Order, with the same force and effect as though said Order had been entered after Petition, Notice and Hearing. There is no previous Order of Court concerning the children. NOW THEREFORE, the parties, intending to be legally bound, and in consideration of the mutual promises and agreements contained herein, hereby agree as follows: 1. Legal Custody. Mother and Father shall have joint legal custody of their children. Joint legal custody means both parents have the right to control and share in making of decisions of importance in the life of each child, including educational, medical, and religious decisions. Both parents shall be entitled to equal access to each child's school, medical, dental, and other important records. As soon as practicable after the receipt by a party, copies of a child's school schedules, special events notifications, report cards, and similar items shall be provided to the other party. Each shall notify the other party of any medical, dental, optical and other appointments of a child with healthcare providers, sufficiently in advance thereof so that the other party can attend. Notwithstanding that both parents shall share legal custody, non-major decisions involving the child's day-to-day living shall be made by the parent then having physical custody, consistent with the other provisions of this Agreement and subsequent Order. 2. Physical Custody. Primary Physical Custody of the child, as that term is defined in the custody act, shall be with Mother. Mother has informed Father of her desire to move Winchester, Virginia on or before August 20, 2007. The parties agree that Mother may move to Winchester, Virginia, with the children, and she shall retain primary custody of the children after her move. At least seven (7) days before her final move, Mother shall provide Father with a telephone number and address of her new residence. 3. Partial Custody. Partial physical custody is the right to take possession of a child away from the custodial parent for a certain period of time. Father shall have liberal periods of partial custody with the children as follows: A. Alternating Weekends. Every other weekend beginning on Friday at 6:00 p.m. through Sunday at 6:00 p.m. If a school or other holiday falls on the Monday G,r,b after Father's weekend, F ther may keep the childre until 6:00 p, Mo day iclr 4 l + 1ae 6444?ers Weee?.,[-e,.,Ck ?k-S G,_}????ol? ? B -summer Boher an fatTier ma%ave?t e children for `mac;ne 0A Fe ' 4XS Y or non-consecutive weeks during the summer, provided sixty (60) days 7-4 0-S cla Y • notice is given to the other party. far fie. ?lvT Siff -5 c4- 4-k,3 S-e C,4?0# 9J?10 w-e S1AQJ4 car s? S+- o lv averAlls A-fS • c,?? ?hJ C. School Break. Mother and Father shall have equal blocks of time with the S children over their Christmas Break, and Easter Break and/or Spring Break. For 2007, Father shall have the first segment of the holiday, as agreed, and the parties shall alternate thereafter. D. Christmas and Easter. (i) Christmas shall be divided into Blocks A and B. Segment A shall last from Christmas Eve at 12:00 p.m. through Christmas Day at 9:30 a.m. Segment B shall last from Christmas Day at 9:30 a.m. through December 26`h at 12:00 p.m. On odd numbered years, Father shall have the children for Block A And Mother shall have the children for Block B. On even numbered years, Mother shall have the children for Block A and Father shall have the children for Block B. (ii) Easter shall be divided into Blocks A and B. Segment A shall last from the Saturday before Easter at 12:00 p.m. through Easter Day at 9:30 a.m. Segment B shall last from Easter Day at 9:30 a.m. until 6:00 p.m. On odd numbered years, Father shall have the children for Block A And Mother shall have the children for Block B. On even numbered years, Mother shall have the children for Block A and Father shall have the children for Block B. E. Thanksgiving. Thanksgiving shall be divided into two blocks, Block A shall last from Wednesday at 12:00 p.m. through Friday at 12:00 p.m. and Block B shall last from Friday at 12:00 p.m. through Sunday at 6:00 p.m. In odd numbered years, Mother shall have Block A and Father shall have Block B, in even numbered years, Father shall have block A and Mother shall have Block B. F . Mother and Father's Day. Mother shall always have the children on Mother's Day from 9:00 a.m. through 6:00 p.m. and Father shall always have the children on Father's Day from 9:00 a.m. through 6:00 p.m. G. Telephone Contact. Each parent shall have reasonable telephone contact with the children, when the children are in the other parent's physical custody. H. Modification. Nothing in this stipulation shall prevent the parties from making other arrangements upon mutual agreement. 4. Transportation and Exchange. The transportation shall be shared equally by the parties. At all times, all children shall be secured in appropriate passenger restraints. 5. Ongoing Relationship. Neither party shall attempt to undermine the mutual love and affection that the child may have for the other parent and neither parent shall, in the presence of the child make any disparaging or negative remarks concerning the other parent. Each party shall confer with the other on all matters of importance relating to the child's health, maintenance, and education with a view toward obtaining and following a harmonious policy in the child's education and social adjustment. Each party agrees to keep the other informed of his or her residence and telephone number to facilitate communication concerning the welfare of the child and visitation period. Each party agrees to supply the name, address, and telephone numbers of any person in whose care the child will be in for a period in excess of forty-eight (48) hours, and for each person or entity which may provide daycare for the child. 6. Illness of a Child. Emergency decisions regarding a child shall be made by the parent then having custody. However, in the event of any emergency or serious illness of a child at any time, any party then having custody of the child shall communicate with the other party by telephone or any other means practicable, informing the other party of the nature of the illness or emergency, so the other parent can become involved in the decision making process as soon as possible. The term "serious illness" as used herein shall mean any disability which confines a child to bed for a period in excess of seventy-two (72) hours and which places the child under the direction of a licensed physician. During such illness, each party shall have the right to visit the child as often as he or she desires, consistent with the medical care of the child. 7. Welfare of the Child to be Considered. The welfare and convenience of the child shall be the prime consideration of the parties in any application of the provisions of this Agreement. Both parents are directed to listen carefully and consider the wishes of the children in addressing the custodial schedule, any changes to the schedule, and any other parenting issues. 8. Binding Effect and Modification of Order. This Agreement and all of its terms and conditions shall extend to and be binding upon the parties hereto and their respective heirs, personal representatives, and assigns. The parties are free to modify the terms of this Agreement but in order to do so both parties must be in complete agreement to any new terms. That means both parties must consent on what the new terms of the custody arrangement or visitation schedule shall be. 9. Governing Law. This Agreement shall be governed and controlled by the laws of Pennsylvania. -?' PAPSI ?? Jftsck"an kNAtl UNJ L t-e,f?"t 0`rOykr aFO?r'F' 10. Enforcement. The parties agree that this Agreement may be adopted as an Order of S Court without the necessity of a Court hearing.' 1 V '^' C'tin?o 11. Entire Agreement. This Agreement contains the entire understanding between the parties concerning the subject matter hereof, and no representations, inducements, promises or agreements, oral or otherwise, not embodied herein shall be of any force or effect. This Agreement supersedes any and all prior agreements, written or oral, between the parties hereto relating to the subject matter of this Agreement. IN WITNESS WHEREOF, the parties have hereto duly executed the present Stipulation and Custody Agreement the day and year first above written. WITNESS: Hannah Herman-Snyder, Esq ire 200 N. Hanover St. Carlisle, Pa. 17013 (717) 243-5551 Attorney for Father a S?Ztams, Esquire . Pitt St. Carlisle, Pa. 17013 (717) 245-8508 Attorney for Mother Grego . Pic el, Father ,)//4/0-) - Cheryl Beaudoin, Mother 7 11610 c {fix G. 1 icj v -c 'JUL i 12007 ? CHERYL M. BEAUDOIN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 07 - 3216 Civil Term GREGORY K. PICKEL, ACTION IN CUSTODY Defendant ORDER AND NOW, this 31 r` day of IL. , 2007, having reviewed the attached agreement between the parties dated July 16, 2007, it is hereby ORDERED and DECREED as follows: 1. Cheryl M. Beaudoin and Gregory K. Pickel shall share legal custody of their children, Elizabeth Beaudoin, and David Beaudoin. 2. Cheryl M. Beaudoin shall have primary physical custody of the children, and Gregory K. Pickel shall have periods of partial custody as provided by the parties' agreement. 3. The parties' agreement, dated July 16, 2007, shall be entered as an Order of Court. cc: ne Adams, Esquire, for mother --Hann Herman-Snyder, Esquire, for father A ?bb? f C CHERYL M. BEAUDOIN, Plaintiff V. GREGORY K. PICKEL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-3216 CIVIL TERM IN CUSTODY PETITION FOR CONTEMPT AND NOW, comes Gregory K. Pickel, the above named Defendant, by and through his attorney of record, Hannah Herman-Snyder, Esquire, and the law firm of Griffie & Associates and petitions the Court as follows: 1. The Petitioner is Gregory K. Pickel, the above named Defendant, and the Respondent is Cheryl M. Beaudoin, the above named Plaintiff. 2. The parties are the natural parents of two (2) children, Elizabeth Beaudoin, born January 26, 1998, and David Beaudoin, born May 26, 1994. 3. The children are the subject of an Order of Custody entered on July 31, 2007 incorporating the parties' Stipulation and Agreement of July 16, 2007, both of which are attached hereto and marked as Exhibit "A". 4. As of December 14, 2007, Respondent willfully failed to comply with the terms of said Order by failing to turn the children over to Petitioner for his scheduled period of partial physical custody. 5. Petitioner requested Respondent to comply with the Court Order and she purposefully did not do so resulting in the children missing their grandmother's 85th birthday party. 6. There has been no prior Court involvement, except for the signing of the Order incorporating the parties' Stipulation and Agreement of July 16, 2007, which was signed by the Honorable Kevin A. Hess. WHEREFORE, Petitioner prays this Honorable Court adjudge the Respondent in the contempt of its Order of July 31, 2007; to impose such sanction and its penalties as the Court deems appropriate to assure the Defendant's future compliance with this Court's Orders in this matter; that Petitioner be awarded compensatory custodial time for the time wrongfully deprived from him by Respondent, and that Petitioner be awarded attorney's fees which the Court deems equitable and just. Respectfully Submitted, Hannah Herman-Snyder, Esqui - Attorneyfor Petitioner GRIFFIE AND ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 VERIFICATION 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 falsifications to authorities. DATE: 07 GREG Y K. P CKEL, Defendant CHERYL M. BEAUDOIN, Plaintiff V. GREGORY K. PICKEL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-3216 CIVIL TERM IN CUSTODY CERTIFICATE OF SERVICE I, Hannah Herman-Snyder, Esquire, hereby certify that I did, the )"day of December, 2007, cause a copy of Defendant's Petition for Contempt to be served upon Respondent's counsel by first-class mail, postage prepaid at the following address: Jane Adams, Esquire 64 South Pitt Street Carlisle, PA 17013 DATE: 1.) _ t4- o Hannah Herman-Snyder, Esq' ire Attorney for Defendant GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717)243-5551 (800)347-5552 JUL 31 tuot M CHERYL M. BEAUDOIN, IN THE COURT OF COMMON PLEAS Plaintiff. CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 07 - 3216 Civil Term GREGORY K. PICKEL, ACTION IN CUSTODY Defendant ORDER AND NOW, this 3 S ?' day of , 2007, having reviewed the attached agreement between the parties dated July 16, 2007, i s hereby ORDERED and DECREED as follows: 1. Cheryl M. Beaudoin and Gregory K. Pickel shall share legal custody of their children, Elizabeth Beaudoin, and David Beaudoin. 2. Cheryl M. Beaudoin shall have primary physical custody of the children, and Gregory K. Pickel shall have periods of partial custody as provided by the parties' agreement. 3. The parties' agreement, dated July 16, 2007, shall be entered as an Order of Court. I'S I njy M* AiA4..) J. 1 -7 cc: Jane Adams, Esquire, for mother Hannah Herman-Snyder, Esquire, for father R1'rF_ " 71777:?RQ in T sfrr,c ;'t my hand an a seG, CHERYL M. BEAUDOIN, IN THE COURT OF COMMON PLEAS . PENNSYLVANI CUMBERLAND COUNTY Q Plaintiff , V p vs. No. 07 - 3216 Civil Term s rte- 3? GREGORY K. PICKEL, ACTION IN CUSTODY Defendant ?-C:7 m r 9 ? -c STIPULATION AND CUSTODY AGREEMENT d 52007, This Stipulation and Custody Agreement is made this 14 day of T by and between Cheryl M. Beaudoin, (Hereinafter referred to as "Mother"), of Carlisl , Cumberland County, Pennsylvania, and Gregory K. Pickel, (Hereinafter referred to as "Father"), of Carlisle, Cumberland County, Pennsylvania; WHEREAS, Mother and Father are the natural parents of two children, namely, Elizabeth Beaudoin date of birth, January 26, 1998; and David Beaudoin, date of birth, May 26,1994; WHEREAS, Mother and Father have reached an agreement relative to the future care, custody, and visitation of their children, the terms of which agreement both parties desire to set forth in the present Stipulation and Custody Agreement, and; WHEREAS, Mother and Father desire the provisions of the present Stipulation and Custody Agreement be approved by the Honorable Court of Common Pleas of Cumberland County and entered as a Court Order, with the same force and effect as though said Order had been entered after Petition, Notice and Hearing. There is no previous Order of Court concerning the children. NOW THEREFORE, the parties, intending to be legally bound, and in consideration of the mutual promises and agreements contained herein, hereby agree as follows: 1. Legal Custody. Mother and Father shall have joint legal custody of their children. Joint legal custody means both parents have the right to control and share in making of decisions of importance in the life of each child, including educational, medical, and religious decisions. Both parents shall be entitled to equal access to each child's school, medical, dental, and other important records. As soon as practicable after the receipt by a parry, copies of a child's school schedules, special events notifications, report cards, and similar items shall be provided to the other party. Each shall notify the other party of any medical, dental, optical and other appointments of a child with healthcare providers, sufficiently in advance thereof so that the other party can attend. Notwithstanding that both parents shall share legal custody, non-major decisions involving the child's day-to-day living shall be made by the parent then having physical custody, consistent with the other provisions of this Agreement and subsequent Order. 2. Physical Custody. Primary Physical Custody of the child, as that term is defined in the custody act, shall be with Mother. Mother has informed Father of her desire to move Winchester, Virginia on or before August 20, 2007. The parties agree that Mother may move to Winchester, Virginia, with the children, and she shall retain primary custody of the children after her move. At least seven (7) days before her final move, Mother shall provide Father with a telephone number and address of her new residence. 3. Partial Custody. Partial physical custody is the right to take possession of a child away from the custodial parent for a certain period of time. Father shall have liberal periods of partial custody with the children as follows: A. Alternating Weekends. Every other weekend beginning on Friday at 6:00 p.m. through Sunday at 6:00 p.m. If a school or other holiday falls on the Monday C,r?,6 after Father's weekend Father may keep the cl?ldre until 6:0P p-m Monday cc??,,',tawer?i ?t motMana? fatTiserumay v,?eha 'e?ti'ec ti'l ren or ?f dt `boa cnsecu t e B--Summer ?' ?? . oher or non-consecutive weeks during the summer, provided sixty (60) days n'v ?u notice is given to the other party. f?z_>r -HAx. Fvr Ses v?- 44t is S-e C,4?vQ(?b i4- iv-ee L S1oA coo w;, 9-- 0V b ovey-'&,Ts hip - . C. School Break. Mother and Father shall have equal blocks of time with the S children over their Christmas Break, and Easter Break and/or Spring Break. For 2007, Father shall have the first segment of the holiday, as agreed, and the parties shall alternate thereafter. D. Christmas and Easter. (i) Christmas shall be divided into Blocks A and B. Segment A shall last from Christmas Eve at 12:00 p.m. through Christmas Day at 9:30 a.m. Segment B shall last from Christmas Day at 9:30 a.m. through December 26 h at 12:00 p.m. On odd numbered years, Father shall have the children for Block A And Mother shall have the children for Block B. On even numbered years, Mother shall have the children for Block A and Father shall have the children for Block B. (ii) Easter shall be divided into Blocks A and B. Segment A shall last from the Saturday before Easter at 12:00 p.m. through Easter Day at 9:30 a.m. Segment B shall last from Easter Day at 9:30 a.m. until 6:00 p.m. On odd numbered years, Father shall have the children for Block A And Mother shall have the children for Block B. On even numbered years, Mother shall have the children for Block A and Father shall have the children for Block B. E. Thanksgiving. Thanksgiving shall be divided into two blocks, Block A shall last from Wednesday at 12:00 p.m. through Friday at 12:00 p.m. and Block B shall last from Friday at 12:00 p.m. through Sunday at 6:00 p.m. In odd numbered years, Mother shall have Block A and Father shall have Block B, in even numbered years, Father shall have block A and Mother shall have Block B. F . Mother and Father's Day. Mother shall always have the children on Mother's Day from 9:00 a.m. through 6:00 p.m. and Father shall always have the children on Father's Day from 9:00 a.m. through 6:00 p.m. G. Telephone Contact. Each parent shall have reasonable telephone contact with the children, when the children are in the other parent's physical custody. H. Modification. Nothing in this stipulation shall prevent the parties from making other arrangements upon mutual agreement. 4. Transportation and Exchange. The transportation shall be shared equally by the parties. At all times, all children shall be secured in appropriate passenger restraints. 5. Ongoing Relationship. Neither party shall attempt to undermine the mutual love and affection that the child may have for the other parent and neither parent shall, in the presence of the child make any disparaging or negative remarks concerning the other parent. Each parry shall confer with the other on all matters of importance relating to the child's health, maintenance, and education with a view toward obtaining and following a harmonious policy in the child's education and social adjustment. Each parry agrees to keep the other informed of his or her residence and telephone number to facilitate communication concerning the welfare of the child and visitation period. Each party agreee to supply the name, address, and telephone numbers of any person in whose care the child will be in for a period in excess of forty-eight (48) hours, and for each person or entity which may provide daycare for the child. 6. Illness of a Child. Emergency decisions regarding a child shall be made by the parent then having custody. However, in the event of any emergency or serious illness of a child at any time, any party then having custody of the child shall communicate with the other party by telephone or any other means practicable, informing the other party of the nature of the illness or emergency, so the other parent can become involved in the decision making process as soon as possible. The term "serious illness" as used herein shall mean any disability which confines a child to bed for a period in excess of seventy-two (72) hours and which places the child under the direction of a licensed physician. During such illness, each party shall have the right to visit the child as often as he or she desires, consistent with the medical care of the child. 7. Welfare of the Child to be Considered. The welfare and convenience of the child shall be the prime consideration of the parties in any application of the provisions of this Agreement. Both parents are directed to listen carefully and consider the wishes of the children in addressing the custodial schedule, any changes to the schedule, and any other parenting issues. 8. Binding Effect and Modification of Order. This Agreement and all of its terms and conditions shall extend to and be binding upon the parties hereto and their respective heirs, personal representatives, and assigns. The parties are free to modify the terms of this Agreement but in order to do so both parties must be in complete agreement to any new terms. That means both parties must consent on what the new terms of the custody arrangement or visitation schedule shall be. 9. Governing Law. This Agreement shall be governed and controlled by the laws of Pennsylvania. ?,Aa? tiep A AJ??c an tNA ii rep", A VIC* V6 \l)),I; A vti? L Fv?L e-r p5ree,?t trr Oyz er 4-Oux r1-. 10. Enforcement. The parties agree that this Agreement may be adopted as an Order of ` S Court without the necessity of a Court hearing. ?tM?1o 11. Entire Agreement. This Agreement contains the entire understanding between the parties concerning the subject matter hereof, and no representations, inducements, promises or agreements, oral or otherwise, not embodied herein shall be of any force or effect. This Agreement supersedes any and all prior agreements, written or oral, between the parties hereto relating to the subject matter of this Agreement. IN WITNESS WHEREOF, the parties have hereto duly executed the present Stipulation and Custody Agreement the day and year first above written. WITNESS: Hannah Herman-Snyder, Esq ire 200 N. Hanover St. Carlisle, Pa. 17013 (717) 243-5551 Attorney for Father Esquire qSte.Ada?ms, St. Carlisle, Pa. 17013 (717) 245-8508 Attorney for Mother Grego {. Pic el, Father ?? - Che .l . Beaudoin, Mother ?;)116/0 7 N O 3 C. Q? 0/y 96) Tw V' { ^* ?o tom" ~ CHERYL M. BEAUDOIN IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. GREGORY K. PICKEL DEFENDANT 2007-3216 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Thursday, January 03, 2008 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Monday, January 28, 2008 at 8:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ ac uelrne M. Verne Es q. jjrA Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ?rj r-vr/v/v ZI-I dl; 19 :1 Wd C- NVr 8001 t FEB 1 2 2008q+y CHERYL M. BEAUDOIN, Plaintiff VI. GREGORY K. PICKEL, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2007-3216 CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this I"' day of dear tst, , 2008, upon consideration of the attached Custody Conciliation Repo , it is ordered and directed as follows: 1. Father hereby withdraws his Petition for Contempt. 2. The prior Order of Court dated July 31, 2007 shall remain in full force and effect with the following modifications. 3. Father shall have physical custody of the children on Monday, February 18, 2008 and Thursday, June 26, 2008. 4. Paragraph 3B of the prior Order shall include the following provision. Six consecutive days shall be from Friday to Friday. 5. Paragraph 31)(i) shall be modified such that all exchange times for Christmas shall be 3:00 p.m. 6. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control cc: Hannah Herman-Snyder, Esquire. ?1ane Adams, Esquire, Counsel for Mother a21/ sloe Oe% tc ink c BY THE COURT, H1rrl NIN--ad ry d ry ? -"? `-r 11?' 1 J 9 0 :8 WV S ! 933 BOBZ h`tt'V!.ONi.i IOW 3Hl ?O 301-2-?{M, R CHERYL M. BEAUDOIN, Plaintiff V. GREGORY K. PICKEL, Defendant PRIOR JUDGE: Kevin A. Hess, J. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2007-3216 CIVIL ACTION - LAW : IN 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 Elizabeth Beaudoin January 26, 1998 Mother David Beaudoin May 26, 1994 Mother 2. A Conciliation Conference was held in this matter on February 11, 2008, with the following in attendance: The Father, Gregory K. Pickel, with his counsel, Hannah Herman-Snyder, Esquire, and the Mother, Cheryl M. Beaudoin, with her counsel, Jane Adams, Esquire. 3. A prior Order of Court was entered by the Honorable Kevin A. Hess dated July 31, 2007 providing for shared legal custody, Mother having primary physical custody and Father having partial physical custody. 4. Father filed a Petition for Contempt 5. The parties agreed to an Order in the form as attached. '2- -//-air, Date Jacq eline M. Verney, Esquire Custody Conciliator CHERYL M. BEAUDOIN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION -LAW GREGORY K. PICKEL, NO. 07-3216 CIVIL TERM Defendant IN DIVORCE NOTICE TO PLEAD You are hereby notified to file a written response to the within Petition for Economic Relief within twenty days (20) days from service hereof or a judgment may be entered against you. CHERYL M. BEAUDOIN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW GREGORY K. PICKEL, NO. 07-3216 CIVIL TERM Defendant IN DIVORCE PETITION FOR ECONOMIC RELIEF AND NOW, comes Petitioner, Gregory K. Pickel, by and through his counsel, Bradley L. Griffie, Esquire, and the law firm of Griffie & Associates, and petitions the Court as follows: 1. A Complaint in Divorce was filed in the above captioned matter on May 30, 2007. 2. The only claims made in the Complaint were a request for a no-fault or Section 3301(d) divorce. 3. Plaintiff and Defendant are joint owners of various items of personal property, furniture, and household furnishings acquired during their marriage which are subject to equitable distribution. 4. Plaintiff and Defendant are joint owners of real estate located at 420 Croghan Drive, Carlisle, Cumberland County, Pennsylvania, which was acquired during their marriage and which is subject to equitable distribution. 5. Plaintiff and Defendant have incurred debts and obligations during their marriage which are subject to equitable distribution. WHEREFORE, Plaintiff requests your Honorable Court to enter a decree equitably dividing the parties' property and equitable apportioning the debts incurred by the parties. Respectfully submitted, ey L. Griffie, Esquire Attorney for Petitioner 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 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 unworn falsification to authorities. DATE:') /? (XEG20 K. PIC L L i '> G CHERYL M. BEAUDOIN, Plaintiff VS. GREGORY K. PICKEL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : No. 07 - 3216 Civil Term ACTION IN CUSTODY STIPULATION AND CUSTODY AGREEMENT WHEREAS, the parties desire to amend the custody stipulation, and subsequent Order, entered Juiv 31, 2007. pursuant to their agreement as foiiows: Section D(ii) shall be amended as follows: (ii) Easter. In even years, Father will exercise custody of the children from Friday at 6:00 p.m. until Sunday at 6:00 p.m. In odd years, Father will exercise custody of the children from the Thursday prior to Easter at 6:00 p.m. until Friday at 6:00 p.m. with the understanding that if Good Friday is a school day, Father will be granted a make-up date with the children during the summer. IN WITNESS WHEREOF, the parties have hereto duly executed the present Stipulation the day and year first above written. WITNESS: e Han er St. 3c wdle y l?^ G r Acy Carlisle, Pa. 17013 t yr rc (717) 243-5551 Attorney for Father Ja dams, Esquire IT, W South St. C 1' le, Pa. 17013 (717) 245-8508 Attorney for Mother Gre K. P'ckel, Father Cheryl . Beaudoin, Mother CHERYL M. BEAUDOIN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. : CIVIL ACTION -LAW GREGORY K. PICKEL, NO. 07-3216 CIVIL TERM Defendant IN DIVORCE MOTION FOR APPOINTMENT OF MASTER GREGORY K. PICKEL (Plain) (Defendant), moves the court to appoint a master with respect to the following claims: (X) Divorce (X) Distribution of Property () Annulment () Support O Alimony O Counsel Fees () Alimony Pendente Lite Q Costs and Expenses and in support of the motion states: (1) Discovery is complete as to the claims (s) for which the appointment of a master is requested. (2) The Plaintiff (has) (met) appeared in the action (pefsefiallg) (by her attorney, Jane Adams, Esquire). (3) The Statutory ground(s) for divorce (is) (are) §3301(c) and &3301(d). (3) Delete the inapplicable paragraph(s): a. The et n'os'e'' b. An agreement has been reached with respect to the following claims: Divorce C. The action is contested with respect to the following claims: All of the above except divorce. (4) The action (ifwelyes) (does not involve) complex issues of law or fact. (5) The hearing is expected to take one (ls) (days). (7) Additional information, if any, relevant to the motion: None Date: 3-/S'6 i- r0 fie, A orney for (RlainW (Defendant) ORDER APPOINTING MASTER AND NOW, 12008, master with respect to the following claims: _ Esquire is appointed By the Court: J. CHERYL M. BEAUDOIN, Plaintiff vs. GREGORY K. PICKEL, Defendant MAY ! 1m r t? IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 07 - 3216 Civil Term ACTION IN CUSTODY ORDER AND NOW, this Z -3'4 day of r--#l , 2007, having reviewed the attached agreement between the parties dated May 15, 2008, it is hereby ORDERED and DECREED that the prior custody Order of July 31, 2007, shall be amended as follows: Section D(ii) shall provide: (ii) Easter. In even years, Father will exercise custody of the children from Friday at 6:00 p.m. until Sunday at 6:00 p.m. In odd years, Father will exercise custody of the children from the Thursday prior to Easter at 6:00 p.m. until Friday at 6:00 p.m. with the understanding that if Good Friday is a school day, Father will be granted a make-up date with the children during the summer. J. cc: Jane Adams, Esquire, for mother Brad Griffie, Esquire, for father /? :01 zZ ?` 8(lZ CHERYL M. BEAUDOIN, Plaintiff vs. GREGORY K. PICKEL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : No. 07 - 3216 Civil Term ACTION IN CUSTODY STIPULATION AND CUSTODY AGREEMENT WHEREAS, the parties desire to amend the custody stipulation, and subsequent Order, entered July 31, 2007, pursuant to their agreement as Toiiows: Section D(ii) shall be amended as follows: (ii) Easter. In even years, Father will exercise custody of the children from Friday at 6:00 p.m. until Sunday at 6:00 p.m. In odd years, Father will exercise custody of the children from the Thursday prior to Easter at 6:00 p.m. until Friday at 6:00 p.m. with the understanding that if Good Friday is a school day, Father will be granted a make-up date with the children during the summer. IN WITNESS WHEREOF, the parties have hereto duly executed the present Stipulation the day and year first above written. WITNESS: 'e Han, er St. ?Nadle Carlisle, Pa. 17013 S?V 1 rc (717) 243-5551 Attorney for Father Ja dams, Esquire I i W South St. C 1' le, Pa. 17013 (717) 245-8508 Attorney for Mother Gre K. P'ckel, Father Cheryl .Beaudoin, Mother V?a d? ===c r z °r7 t'YT l.0 1 MAY 2 2 200f CHERYL M. BEAUDOIN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. : CIVIL ACTION -LAW GREGORY K. PICKEL, NO. 07-3216 CIVIL TERM Defendant IN DIVORCE MOTION FOR APPOINTMENT OF MASTER GREGORY K. PICKEL (PlainW (Defendant), moves the court to appoint a master with respect to the following claims: (X) Divorce () Annulment 0 Alimony () Alimony Pendente Lite and in support of the motion states: (X) Distribution of Property ( ) Support () Counsel Fees () Costs and Expenses (1) Discovery is complete as to the claims (s) for which the appointment of a master is requested. (2) The Plaintiff (has) (l et) appeared in the action (pefsemlly) (by her attorney, Jane Adams, Esquire). (3) The Statutory ground(s) for divorce (is) (are) 43301(c) and 43301(d). (3) Delete the inapplicable paragraph(s): a. The ae4ien is not eefAest&d. b. An agreement has been reached with respect to the following claims: Divorce C. The action is contested with respect to the following claims: All of the above except divorce. (4) The action (ielves) (does not involve) complex issues of law or fact. (5) The hearing is expected to take one (ls) (days). (7) Additional information, if any, relevant to the motion: None Date: r ie, Atforney for (P46nfift) (Defendant) ORDER APPOINTING MASTER AND NOW, a3 , 2008, ? • e?+rit? J _?,,.?Esquire is appointed master with respect to the flowing claims:, 4- ?2? a.G9L? J. 4 i -7 of i...... C-I `• ?.?.... 1 v i ?i r. ti C-4 ""'^a CHERYL M. BEAUDOIN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION -LAW GREGORY K. PICKEL, NO. 07-3216 CIVIL TERM Defendant IN DIVORCE INVENTORY AND APPRAISEMENT OF DEFENDANT, GREGORY K. PICKEL Gregory K. Pickel, Defendant, files this inventory of all property owned or possessed by either party at the time this action was commenced and all property transferred within the preceding three years. Gregory K. Pickel, Defendant, verifies that the statements made in this inventory are true and correct. Plaintiff further understands that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. R , RY . PICKEL, Defendant i ASSETS OF PARTIES Gregory K. Pickel, Defendant, marks on the list below those items applicable to the case at bar and itemizes the assets on the following pages. ( ) 1. Real property (X) 2. Motor vehicles (X) 3. Stocks, bond, securities and options ( ) 4. Certificates of deposit (X) 5. Checking accounts, cash (X) 6. Savings accounts, money market and savings certificates ( ) 7. Contents of safe deposit boxes (X) 8. Trusts ( } 9. Life insurance policies (indicate face value, cash surrender value and .current beneficiaries) ( } 10. Annuities ( ) 11. (lifts ( ) 12. Inheritances ( ) 13. Patents, copyrights, invention, royalties ( ) 14. Personal property outside the home ( ) 15. Business (list all owners, including percentage of ownership, and officer/director positions held by a party with company) ( ) 16. Employment termination benefits-severance pay, worker's compensation claim/award ( ) 17. Profit sharing plans (X) 18. Pension plans (indicate employee contribution and date plan vests) (X) 19. Retirement plans, Individual Retirement Accounts ( ) 20. Disability payments ( ) 21. Litigation claims (matured and unmatured) ( ) 22. MilitaryN.A. benefits ( ) 23. Education benefits ( ) 24. Debts due, including loans, mortgage held ( ) 25. Household furnishings and personalty (include as a total category and attach itemized list of distribution of such assets is in dispute) (X) 26. Other LIABILITIES OF PARTIES Gregory K. Pickel, Defendant, marks on the list below those items applicable to the case at bar and itemizes the liabilities on the following pages. SECURED ( ) 1. Mortgages ( ) 2. Judgments ( } 3. Liens ( ) 4. Other Secured Liabilities UNSECURED (X) 5. Credit Card Balances ( } 6. Purchases ( ) 7. Loan Payments ( ) 8. Notes Payable ( ) 9. Other Unsecured Liabilities CONTINGENT OR DEFERRED ( ) 10. Contract or Agreements ( } 11. Promissory Notes ( ) 12. Lawsuits ( ) 13. Options ( ) 14. Taxes ( ) 15. Other Contingent or Deferred Liabilities W O o ? +=? O O o o 0 o o o a? all Q oll ?. 0 ?. '? z z ? z z z z z ? z ? _ ?,' ff3 a nj M C O O z 0 a C z 0 0 00 0 00 t- n n r- o o r o A N N O O O o Cl O O O O O O O O O 0 O N N N ' O ? ? N N ? N t? M c. O ? N M cc ca 0 0 v 1 ?o r 00 Ef} M to 00 O ?_ In f? O N [? ~ ON O O M M N N N O O N O vi CIA 4q (Al cs3 F13 Qs </3 kr) C O it •? v V' Q O V ? bn ? oa ? ct do cu ? on bn on c^C ? a on rn a E E E N L bA to 1 t11? bD w OD b4 W bb y to L L (?„? L L. L L L L L O 'L S-"i Q Q Q ? Q Q Q Q D ? A p Q a.. ?? 3 z x 3 ti 3 ti x 3 3 z 3 ? z a cz U U? ON U O cG ? O °N a L O ?? ? ?O Q ? ¢ Q ? Q + ' 3 p, c7 a o o I o o va F- U c L c w Ln 1 cd Ms -Se 1 N n 1 N •-, [/? a? O O 4 v O '- s +L G N W O v LL ai , iz to, - o n? ? Z z Q °' a N r E 3 A U ? ? ? ? W Q o ? sS ?i 00 ors cd Qom a + .+ Z N N M kn vl \O 00 00 . Q? o ? ? c. .Z 0 0 0 c- oa [ C? ob p ? N ? N ? N v ? .1 N ? n ; N G a ,? M ,. U U p ? s, o o . r <r cn o o N ? M oo r r N n r p ..- ? (f3 k'n N `?.? N `". p C'- bA r oa Q Ga p 3 x ? x bA cd cad by G G? 3 r ?t' us ? '? ?' O Ri ,7 U p N J ? ? .w a 31 ? Pr ? d o ? pa N V2 N 4Z? Eii?y Q O © V O ? W h..q O .b ? c C 'ar+ U _a U A ?z C: CI IERYL M. BEAUDOIN. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION LAW GREGORY K. PICKEL, NO. 07-3216 CIVIL TERM Defendant IN DIVORCE AFFIDAVIT OF CONSENT A Complaint in Divorce under §3301 (c) of the Divorce Code was filed on May 30, 2007, and service was made on June 19, 2007 by Acceptance of Service. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree of Divorce after service of notice of intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATF.MI NI'S 111181`1N ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. §4904 RELA'T'ING TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE: GREG-V K. PI(KEI- Defendant 5-7 r' t ? ? CHERYL M. BEAUDOIN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION LAW GREGORY K. PICKEL, NO. 07-3216 CIVIL TERM Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST THE ENTRY OF A DIVORCE DECREE UNDER 0301(c) OF THE DIVORCE CODE I consent to the entry of a final decree in divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately alter it is filed with the Prothonotary. I VERIFY THAT THE STATEMENTS MADE IN THE' FOREGOING AFFIDAVIT AIZE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS Hl?REIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. §4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE: ?/? _ - t r CZ) .? r- 1? CHERYL M. BEAUDOIN, Plaintiff vs. GREGORY K. PICKEL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 07 - 3216 Civil Term : ACTION IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on May 30, 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing and service of the Complaint. 3. 1 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 also understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. Date: C M. Beaudoin, Plaintiff WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 43301(c) AND 4-3301(d) OF THE DIVORCE CODE 1. I consent to entry of a final decree of divorce without notice. 2. 1 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. 1 understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: Ch M. Beaudoin, Plaintiff -?:;? i ,,: _? _ ?? CHERYL M. BEAUDOIN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 07 - 3216 Civil GREGORY K. PICKEL, Defendant IN DIVORCE ORDER OFP4 OURT AND NOW, this day of? 2009, an agreement having been reached between the parties resolving all claims raised in the proceedings, the agreement, at the request of counsel (see counsel's letter of March 24, 2009, attached hereto), not to be made part of the record, the appointment of the Master is vacated and counsel can file a praecipe transmitting the record to the Court, along with the affidavits of consent and waivers of notice of intention to request entry of divorce decree signed by the parties, requesting a final decree in divorce. BY T URT, 7C?Al1 Edgar B. Bayley, P.J. Cc: /__? e A dams torney for Plaintiff Jannah Herman-Snyder Attorney for Defendant C*Q ..-t r` l S.S.. r -CC .. LL CT N CHERYL M. BEAUDOIN, Plaintiff vs. GREGORY K. PICKEL, Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 07 - 3216 Civil Term ACTION IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Please accept this request to transmit the record, together with the following information to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under §3301(c) of the Divorce Code. 2. Date and manner of the service of the Complaint: Acceptance of service filed: service accepted by Defendant's attorney, on June 19. 2007. 3. Date of execution of the affidavit of consent required by 3301(c) of the Divorce Code: By Plaintiff: March 23. 2009. By Defendant: October 9 2008. 4. Related claims pending: None-, all claims were resolved by a marriage settlement agreement between the parties. 5. Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: October 17. 2009 Date Plaintiffs Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: March 24. 2009. Date: 7/0 9 Respectfully S Ja Adams, Esquir I o. 79465 gakrfisle, . South St. Pa. 17013 (717) 245-8508 Attorney for Plaintiff C. C=3 ? fed • ??5-} / ' ? t .l Lo . y f ?Y IN THE COURT OF COMMON PLEAS OF CHERYL M. BEAUDOIN CUMBERLAND COUNTY, PENNSYLVANIA • V. GREGORY K. PICKEL : NO. 07 - 3216 CIVIL TERM DIVORCE DECREE AND NOW, it is ordered and decreed that CHERYL M. BEAUDOIN plaintiff, and GREGORY K. PICKEL , defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") None; the marriage settlement signed by the parties dated March 23, 2009 it hereby incorporated and not merged into this Decree. By the Court, rothonotary jv - dA , of fit/` C " 4 4 ? q-g--,L-.Oq -ootce W-a ?- 4 44 #?e?? CHERYL M. BEAUDOIN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION -LAW GREGORY K. PICKEL, NO. 07-3216 CIVIL TERM Defendant IN DIVORCE STIPULATION AND AGREEMENT By and between, Gregory K. Pickel, Defendant, and Cheryl M. Beaudoin, Plaintiff, WITNESSETH: WHEREAS, the parties, intending to be legally bound and waiving their right to be present when this Agreement and Order are presented and signed by the Court, hereby stipulate and agree that the Court may enter the attached Order of Court. IN WITNESS WHEREOF, the parties, intending to be bound by the terms and conditions of this Agreement, execute this Agreement by signing below: Hannah Herman-Snyder, Es ire Attorney for Defendant Adams, Esquire nev for Plaintiff r/ Giregl. P ckel, Defendant " Cheryl M. Beaudoin, Plaintiff I verify that the statements made in this Stipulation and Agreement are true and correct. 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: `I o9 c; ?? a ?' I-e': 14 e7? Gre t,P ckel, Defendant I verify that the statements made in this Stipulation and Agreement 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: 3' D31 P 9 7 Che . Beaudoin, Plaintiff . 1' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHERYL M. BEAUDOIN V. GREGORY K. PICKEL : NO. 07 - 3216 CIVIL TERM DIVORCE DECREE AND NOW, ?.1 zoo 9 , it is ordered and decreed that CHERYL M. BEAUDOIN plaintiff, and , GREGORY K. PICKEL , defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") None; the marriage settlement signed by the parties dated March 23, 2009 i5 hereby incorporated and not merged into this Decree. By the Court, Attest- J. rothonotary r; C a ? +..: W ..' .? t CONSENTED TO: Date: -3 // 2 1.2- de Date: 37 1 IT? Date: ?3? ©?? Date: D?) 1 57 Gre ry ickel, Defendant _ Iii QTr.n .? J? - ? In Hannah Herman-Snyder, Esqu re Attorney for Defendant 5si j-%-j ? Cheryl W. Beaudoin, Plaintiff Adams, Esquire :ney for Plaintiff l' APR 2 9 2009 a CHERYL M. BEAUDOIN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION -LAW GREGORY K. PICKEL, NO. 07-3216 CIVIL TERM Defendant IN DIVORCE QUALIFIED DOMESTIC RELATIONS ORDER AND NOW, this day of /tie 2009, it appearing to the Court that: I. The parties to the Divorce Action. The parties to this action are Gregory K. Pickel, ("Participant") and Cheryl M. Beaudoin ("Alternate Payee"). 1.1 Participant's name, address, social security number and date of birth are as follows: Name: Gregory K. Pickel Address: 1236 North Pitt Street Carlisle, PA 17013 Soc. Sec. No.: xxx-xx-6995 (An addendum will be provided to the Plan Administrator with the full social security number so as to protect the privacy of the parties.) Date of Birth: September 15, 1952 1.2 Alternate Payee's name, address, social security number and date of birth are as follows: Name: Cheryl M. Beaudoin Address: 1213 Caroline Street Winchester, VA 22601-2903 Soc. Sec. No.: xxx-xx-4381 (An addendum will be provided to the Plan Administrator with the full social security number so as to protect the privacy of the parties.) Date of Birth: April 28, 1963 4 The parties were divorced by Order of this Court (a copy attached hereto) on April 15, 2009. The Decree has not been amended. • 2. Plan. This Order applies to the Nationwide 457(b) Plan of Gregory K. Pickel, Employer number 638003. The administrator responsible for determining whether the Order constitutes a Qualified Domestic Relations Order as described below is Nationwide Retirement Solutions, P.O. Box 182797, Columbus, Ohio, 43218. Interpretation and Construction of Order. 3.1 The parties intend this Order (the "Order") to constitute a "Qualified Domestic Relations Order", within the meaning of Section 414(p) of the Internal Revenue Code of 1986, as amended (the "Code") and Section 206(d)(3)(B) of the Employee Retirement Income Security Act of 1974, as amended, (" BRISA"). The provisions of this Order shall be administered and interpreted in conformity with Section 414(p) of the Code and Section 206(d)(3)(B) of ERISA. 3.2 Nothing in this order shall be construed to require the Plan to provide: 3.2.1 Any type or form of benefit, or any option, not otherwise provided under the Plan. 3.2.2 Benefits to Alternate Payee (as defined in Paragraph 4) in an amount that exceeds the amount of benefits that the Plan would be required to pay with respect to the Participant. 3.2.3 Benefits to Alternate Payee which are required to be paid to another alternate payee under another order previously determined to be a qualified domestic relations order. IT IS ORDERED, ADJUDGED, AND DECREED as follows: 4. Alternate Payee. This Order creates or recognizes the existence of the right of Alternate Payee (as hereinafter defined) to receive all or a portion of the benefits payable with respect to Participant under the Plan. For purposes of this Order, Alternate Payee is: X 4.1 Former Spouse Amount of Distribution and Form of Distribution to the Alternate Pavee. The distribution to Alternate Payee contemplated by this Order shall be made in the form of a transfer of $10,308.18, from the aforesaid Nationwide 457 (b) plan of Gregory K. Pickel, Employer Number 638003, to a qualified account on behalf of Cheryl M. Beaudoin. 6. Distribution Date. The distribution to Alternate Payee contemplated by this Order shall be made as soon as administratively practicable following the Company's determination that this Order is a Qualified Domestic Relations Order. 7. Death of Participant or Alternate Payee. The death of Participant before all benefits to which Alternate Payee is entitled under this Order have been paid shall not affect the right of Alternate Payee to benefits from the Plan as described in this Order. Should Alternate Payee die before benefits have been distributed to her, Alternate Payee's designated beneficiary shall receive any and all benefits remaining to be paid, with her estate receiving any portion not designated specifically by her. 8. Continuing Jurisdiction. The Court shall retain jurisdiction to amend this Order for the purpose of carrying out the intent of the Parties as reflected in this Order and to establish or maintain the status of the Order as a Qualified Domestic Relations Order. Either party to this Order may apply to the court for such amendment. IT IS INTENDED that this Order shall qualify as a Qualified Domestic Relations Order under the Retirement Equity Act of 1984. The Court retains jurisdiction to amend this Order as might be necessary to establish or maintain its status as a Qualified Domestic Relations Order under the Retirement Equity Act of 1984. By the Court, J. z ? C? 4-1.- PT