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HomeMy WebLinkAbout07-3463JODY L. ECKENRODE, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 07 -3q6 3 CIVIL TERM RODNEY S. ECKENRODE, : ACTION IN DIVORCE Defendant 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 JODY L. ECKENRODE, Plaintiff V. RODNEY S. ECKENRODE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 7 - 3 y 3 CIVIL TERM : ACTION IN DIVORCE COMPLAINT IN DIVORCE COUNT I - DIVORCE 1. Plaintiff is Jody L. Eckenrode, a competent adult individual, who has resided at 8 Verna Drive, Newville, Pa. 17241, since June 8, 2007. 2. Defendant is Rodney S. Eckenrode, a competent adult individual, who has resided at 20 Allison Lane Shippensburg, Cumberland County, Pennsylvania, 17257, since 1994. 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 August 20, 1988 in Cumberland County, Pennsylvania. 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, Brittany N. Eckenrode, date of birth, June 16, 1991, and Noah S. Eckenrode, date of birth, January 14, 1997. 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 any of its allies. 10. The Plaintiff avers that the grounds on which this action is based are: that the marriage is irretrievably broken pursuant to 23 Pa.C.S. 3301(c); WHEREFORE, Plaintiff requests the court to enter a decree in divorce. COUNT II - CUSTODY 11. Sections 1. - 10. are herein incorporated by reference. 12. The parties are the natural parents of Brittany N. Eckenrode, date of birth, June 16, 1991, and Noah S. Eckenrode, date of birth, January 14, 1997. 13. The parties have been unable to enter a custody stipulation in writing. 14. A custody complaint is being filed contemporaneously with this complaint. WHEREFORE, Plaintiff prays this Honorable Court, to enter a custody Order regarding the child. COUNT III - EQUITABLE DISTRIBUTION OF PROPERTY 15. Paragraphs 1 - 14. are herein incorporated by reference. 16. During the course of the marriage, the parties have acquired numerous items of property, both real and personal, which are held in joint names and in the individual names of each of the parties hereto. 17. Plaintiff and Defendant have been unable to agree as to an equitable division of said property. WHEREFORE, Plaintiff prays this Honorable Court, after requiring full disclosure by the Defendant, to equitably divide the property, both real and personal, owned by the parties hereto as marital property. COUNT IV - ALIMONY PENDENTE LITE 18. Paragraphs 1 - 17 are herein incorporated by reference. 19. Plaintiff lacks sufficient property to provide for her reasonable means and is unable to support herself through appropriate employment. 20. Plaintiff requires reasonable support to adequately maintain herself in accordance with the standard of living established during the marriage. 21. Defendant enjoys a substantial income and is well able to contribute to the support and maintenance of Plaintiff during the course of this action. WHEREFORE, the Plaintiff requests that this Honorable Court enter an award of Alimony Pendente Lite until final hearing. COUNT V - ALIMONY 22. Paragraphs 1 through 21 of the Complaint are incorporated herein by reference as though set forth in full. 23. The Plaintiff will require Alimony after the entry of the Divorce Decree by reason of her limited economic circumstances. 24. The Defendant is financially able to provide for the reasonable needs of the Plaintiff. WHEREFORE, Plaintiff requests this Honorable Court to enter an award of alimony after the entry of the Decree. Respectfully submitted, Date: 6' o(No. 79465 South Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF VERIFICATION 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. Date: ? ??+ ? Jo .E encode, Plaintiff A 1 \ „? ?..? 111 4111 o ld W SJ a V`? o o c C ? i- tb W C y_. T l- ril j;-7 _? fA JODY L. ECKENRODE, Plaintiff V. RODNEY S. ECKENRODE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. d 7- :06 6 3 CIVIL TERM ACTION IN DIVORCE PETITION FOR ALIMONY PENDENTE LITE 1. Petitioner, Jody L. Eckenrode, is a competent adult individual, who resides at 8 Verna Street, Newville, Cumberland County, Pennsylvania, 17241. 2. Petitioner's date of birth is February 7, 1966, and her social security number is: 160- 62-2598. 3. Respondent, Rodney S. Eckenrode, is a competent adult individual, whose address is 20 Allison Lane, Shippensburg, Cumberland County, Pennsylvania, 17257. 4. Respondent's date of birth is February 4, 1964, and his social security number is: 191-60-2350. 5. A divorce complaint containing counts for Divorce, Equitable Distribution, Alimony, and Alimony Pendente Lite was filed under the above-captioned docket number. A true and correct copy of the Divorce Complaint is attached to this petition. Respectfully submitted, Date: 6. u, Jane Adams, Esquire W /No. o. 79465 6 South Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PETITIONER VERIFICATION 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. Date: 6 ' a -0-7 Jod . E encode, Plaintiff Q ?. ? _.. w?- -r .. ? s c: y "`. r?? - c? r `S PV ? ?) F ._ .`? .:.° 7 " r n ? _- r,._ , t.? t ?? v _-C • " ";'r "? ?y V JODY L. ECKENRODE, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 4163 CIVIL TERM RODNEY S. ECKENRODE, : ACTION IN DIVORCE Defendant 1. Plaintiff is Jody L. Eckenrode, a competent adult individual, who has resided at 20 Allison Lane Shippensburg, Cumberland County, Pennsylvania, 17257, from 1994 through June 8, 2007. 2. Defendant is Rodney S. Eckenrode, a competent adult individual, who has resided at 20 Allison Lane Shippensburg, Cumberland County, Pennsylvania, 17257, since 1994. 3. Plaintiff is the Mother of the following children and seeks a custody order regarding the following children: NAME DOB/AGE ADDRESS Brittany N. Eckenrode 6/16/91(16) 8 Verna St. Newville, Pa. 17241. Noah S. Eckenrode 1/14/1997 (10) 8 Verna St., Newville, Pa. 17241. Mother and Father married on August 20, 1988. Mother currently has primary physical custody of the children. CUSTODY COMPLAINT During the past five years, the children have resided with the following persons and at the following addresses: NAME ADDRESSES DATES Jody L. Eckenrode Rodney S. Eckenrode 20 Allison Lane Shippensburg, Pa. 17257. 2002 - 2007 Jody L. Eckenrode 8 Verna Lane 6/8/07 - present maternal grandparents Newville, Pa. 17241. The mother of the children is Jody L. Eckenrode. She currently resides at 8 Verna Street, Newville, Pa. 17241. She is married to Rodney S. Eckenrode. The father of the children is Rodney S. Eckenrode. He currently resides at 20 Allison Lane, Shippensburg, Pa., 17257. He is married to Jody L. Eckenrode. 4. The relationship of plaintiff to the children is that of Mother. The plaintiff currently resides with maternal grandparents and the children. 5. The relationship of defendant to the children is that of Father. The defendant currently lives alone. 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 any child 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 any child. 7. The best interest and permanent welfare of the children will be served by granting the relief requested because: The parties separated on June 8, 2007, when Mother left the marital home with the children. She is currently, leg; with family members. Mother works part-time and is able to spend substantial amounts of time caring: for the children. Mother has been the primary caretaker of the children since birth and is seeking a custody order which provides that the parties have shared legal custody, and that Mother has primpa physical custody of the children. This Order would be in the best interest of the children because it would provide stability and security for the children. 8. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children has been named as parties to this action. WHEREFORE, Plaintiff requests the court to enter a custody order regarding the children. Respectfully submitted, Date: G • a - c)-7 \11 , Esquire J Ad779S465 oSouth 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. -t /. &C k, 4, ? Date: ^ lo? - 0 7 y L c enrode, Plaintiff C? ?? _ m _ -ri ?' _S,? ? .:a ?``? ?; C -? ',, ?.3 I `?? ? ,f_ ? JODY L. ECKENRODE, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 07 - 3463 CIVIL TERM RODNEY S. ECKENRODE, : ACTION IN DIVORCE Defendant AFFIDAVIT OF SERVICE AND NOW, this June 18, 2007, I, Jane Adams, Esquire, hereby certify that on or about June 16, 2007, a certified true copy of the Notice to Defend, Divorce Complaint, Custody Complaint and Petition for Alimony Pendente Lite were served upon the Defendant, via certified mail, restricted delivery, return receipt requested at the following address: Rodney S. Eckenrode ' 20 Allison Lane Shippensburg, Pa. 17257 DEFENDANT ¦ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: RODNEY S ECKEARODE 20 ?ALLISON LN _5HIPPENSBURG PA 17257 A. Signature - X ? /gent ? Addressee B,rteceived by Pdnted Name) w C. pate of Delivery D. Is delivery address different from Item 17 ? Yes If YES, enter delivery address below: ? No 3. litpe Mail 0 EWess Mail , Registered O Return Receipt for Merchandises O Insured Mail ? C.O.D. 4. Rntricted DelivW (Prim Fee) Yea I 2. Article Number 7007 0220 0002 2522 -2274 (Transfer from sandoa frael) PS Form 3811, February 2004 Domestic Retum Receipt 1025ss424A-1 54d Respectfully Submitted: J Adams, Esquire No. 79465 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF U ? ? r t ? ? ' ? _? cxa ?, ?_, 1? + .? ? _ ^? ! ??? ? ? ? f ;.? ? --G or l JODY L. ECKENRODE PLAINTIFF V. RODNEY S. ECKENRODE DFFF.NDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 07-3463 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Wednesday, June 20, 2007 , 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 Thursday, July 12, 2007 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. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custodv orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT. By: /s/ ac ueline M. Verne Es q. 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 -^ovl- i*-? L? Or - rl JODY L. ECKENRODER, THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE NO. 07-3463 CIVIL TERM RODENY S. ECKENRODE, IN DIVORCE Defendant/Respondent PACSES CASE NO: 533109290 ORDER OF COURT AND NOW, this 9th day of July, 2007, upon consideration of the Petition for Alimony Pendente Lite and/or counsel fees, it is hereby directed that the parties and their respective counsel appear before R.J. Shadday on July 30, 2007 at 10:30 A.M. for a conference, at 13 N. Hanover St., Carlisle, PA 17013, after which the conference officer may recommend that an Order for Alimony Pendente Lite be entered. YOU are further ordered to bring to the conference: (1) a true copy of your most recent Federal Income Tax Return, including W2's as filed (2) your pay stubs for the preceding six (6) months (3) the Income and Expense Statement attached to this order, completed as required by Rule 1910.1 IC (4) verification of child care expenses (5) proof of medical coverage which you may have, or may have available to you If you fail to appear for the conference or bring the required documents, the Court may issue a warrant for your arrest. BY THE COURT, Edgar B. Bayley, President Judge Copies mailed to: Petitioner Respondent Jane Adams, Esq. Date of Order. July 9, 2007 R. J. S day, onference Officer YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND REPRESENT YOU. 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 MAY GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVE. CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 cc361 . _ TI r? JUL 13 2007 01 JODY L. ECKENRODE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2007-3463 CIVIL ACTION - LAW RODNEY S. ECKENRODE, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this 12th day of July, 2007, the parties having reached a stipulated agreement, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, ??V Jac eline M. Verney, Esquire, ustody Conciliator All 0 S:( lid E 1 I€ P LOOZ JODY L. ECKENRODE, Plaintiff V. RODNEY S. ECKENRODE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07 - 3463 CIVIL TERM : ACTION IN DIVORCE STIPULATION AND CUSTODY AGREEMENT This Stipulation and Custody Agreement is made thi3v day of 2007, by and between JODY L. ECKENRODE, (Hereinafter referred to as "Mother"). of Newville. Cumberland County, Pennsylvania. and RODNEY ECKENRODE, (Hereinafter referred to as "Fatherr"), of Shippensburg, Cumberland County, Pennsylvania; WHEREAS, Mother and Father are the natural parents of two children, namely, Brittany N. Eckenrode, born June 16, 1991; and Noah S. Eckenrode, born January 14, 1997, 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. Physical Custody of the children, as that term is defined in the custody act, shall remain primarily with Mother. Father shall have periods of partial custody as mutually agreed by the parties. 3. Representation of Counsel. Mother has employed and has had the benefit of counsel of Jane Adams, Esquire as her attorney. Father has employed and has the benefit of counsel of Lindsay Dare Baird, Esquire. Both parties have carefully and completely read this agreement and are aware of its contents and legal effect. 4. Transportation and Exchange. The transportation shall be shared equally by the parties, with the parent who is to receive custody at the time of the exchange to provide for transportation from the residence or location of the other parent. At all times, all children shall be secured in appropriate passenger restraints. Neither party shall be under the influence of alcohol or illegal drugs when they have custody of their minor children. 5. Ongoing Relationship. Neither party shall attempt to undermine the mutual love and affection that the child(ren) may have for the other parent and neither parent shall, in the presence of the child(ren) 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(ren). 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 each 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. 10. Enforcement. The parties agree that this Agreement may be adopted as an Order of Court without the necessity of a Court hearing. 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: J e Adams, Esquire 4 S. Pitt St. Carlisle, Pa. 17013 (717) 245-8508 Attorney for Mother Jo , E nrode, Mother 7???5• d7 Lin say Dare Baird, Esquire 37 S. Hanover St. Rodney S ckenrode. Father Carlisle. Pa. 17013 (717) 243-5732 Attorney for Father '° a ?i " ?? r r"" ?? ? -•?. t,a t? ?,i ?c ??? -v a ? ? w •. ? ..-i ? c? I All JODY L. ECKENRODE, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 07 - 3463 CIVIL TERM RODNEY S. ECKENRODE, : ACTION IN DIVORCE Defendant ORDER AND NOW, this 3 ( Sc day of "1 2007, having reviewed the attached agreement between the parties dated July 28, 2007, it is hereby ORDERED and DECREED as follows: 1. Jody L. Eckenrode and Rodney S. Eckenrode shall have joint legal custody of their children, Brittany N. Eckenrode and Noah S. Eckenrode. 2. Jody L. Eckenrode shall have primary physical custody of the children and Rodney S. Eckenrode shall have periods of partial custody with the children as agreed by the parties in their stipulation. 3. The parties' stipulation, dated July 28, 2007, shall be entered as an Order of Court. cc: 4!5'ne Adams, Esquire, for mother ,X'insday Dare Baird, Esquire, for father 1 VIN'dAIASWId is .oi wit` I - onV t00Z A iIU?6b4o- u JODY L. ECKENRODE, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 07 - 3463 CIVIL TERM RODNEY S. ECKENRODE, : ACTION IN DIVORCE Defendant STIPULATION AND CUSTODY AGREEMENT This Stipulation and Custody Agreement is made this?v day of 2007, by and between JODY L. ECKENRODE, (Hereinafter referred to as "Mother"). of Newville, Cumberland County. Pennsylvania. and RODNEY ECKENRODE, (Hereinafter referred to as "Fatherr" ), of Shippensburg, Cumberland County, Pennsylvania; WHEREAS, Mother and Father are the natural parents of two children, namely, Brittany N. Eckenrode, born June 16, 1991; and Noah S. Eckenrode, born January 14, 1997; 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. Physical Custody of the children, as that term is defined in the custody act, shall remain primarily with Mother. Father shall have periods of partial custody as mutually agreed by the parties. 3. Representation of Counsel. Mother has employed and has had the benefit of counsel of Jane Adams, Esquire as her attorney. Father has employed and has the benefit of counsel of Lindsay Dare Baird, Esquire. Both parties have carefully and completely read this agreement and are aware of its contents and legal effect. 4. Transportation and Exchange. The transportation shall be shared equally by the parties, with the parent who is to receive custody at the time of the exchange to provide for transportation from the residence or location of the other parent. At all times, all children shall be secured in appropriate passenger restraints. Neither party shall be under the influence of alcohol or illegal drugs when they have custody of their minor children. 5. Ongoing Relationship. Neither party shall attempt to undermine the mutual love and affection that the child(ren) may have for the other parent and neither parent shall, in the presence of the child(ren) 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(ren). 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 each 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. 10. Enforcement. The parties agree that this Agreement may be adopted as an Order of Court without the necessity of a Court hearing. 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: J e Adams, Esquire 4 S. Pitt St. Carlisle, Pa. 17013 (717) 245-8508 Attorney for Mother /Jo. nrode, Mother 7 - 2?S5 • d 7 Lin say Dare Baird, Esquire 37 S. Hanover St. Rodney S ckenrode. Father Carlisle. Pa. 17013 (717) 243-5732 Attorney for Father C, Crr ff IL Ct co M JODY L. ECKENRODE, IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE NO. 07-3463 CIVIL TERM RODNEY S. ECKENRODE, IN DIVORCE Defendant/Respondent . PACSES Case Number: 533109290 ORDER OF COURT - RESCHEDULE A CONFERENCE AND NOW, this 5th day of September 2007, upon consideration of the Petition for Alimony Pendente Lite and/or counsel fees, it is hereby directed that the parties and their respective counsel appear before R.J. Sbaddav on October 25. 7 at 10:30 A.M. for a conference, at 13 N. Hanover St., Carlisle, PA 17013, after which the conference officer may recommend that an Order for Alimony Pendente Lite be entered. This date replaces the prior conference date of July 30, 2007. YOU are fiuther ordered to bring to the conference: (1) a true copy of your most recent Federal Income Tax Return, including W-2's as filed (2) your pay stubs for the preceding six (6) months (3) the Income and Expense Statement attached to this order, completed as required by Rule 1910.110 (4) verification of child care expenses (5) proof of medical coverage which you may have, or may have available to you (6) IF you fail to appear for the conference or bring the required documents, the Court may issue a warrant for your arrest. BY THE COURT, Edgar B. Bayley, President Judge Date of Order: September 5.2007 Copies mailed to: Petitioner Respondent Jane Adams, Esq. Lindsay D. Baird, Esq. or J. Officer l YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND REPRESENT YOU. 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 MAY GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVE. CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 cc361 `ms ` - -j ? C/? ,- r I ` _ . c-n r:_ i In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION JODY L. ECKENRODE ) Docket Number 07-3463 CIVIL Plaintiff ) VS. ) PACSES Case Number 533109290 RODNEY S. ECKENRODE ) Defendant ) Other State ID Number ORDER AND NOW, to wit on this 27TH DAY OF NOVEMBER, 2007 IT IS HEREBY ORDERED that the Q Complaint for Support or Q Petition to Modify or ® Other ALIMONY PENDENTE LITE REQUEST filed on JULY 9, 2007 in the above captioned matter is dismissed without prejudice due to: NO ACTION BEING PURSUED THROUGH THE DOMESTIC RELATIONS SECTION SINCE THE REQUEST FOR APL WAS FILED. Q The Complaint or Petition may be reinstated upon written application of the plaintiff petitioner. BY THE C T: • FDWAM E. GUIDO, JUDGE DRO: R.J. SHADDAY Form OE-506 Service Type M Worker ID 21005 -rs rr b p J[ cn G} ? "D ? + 4 JODY L. ECKENRODE, Plaintiff V. RODNEY S. ECKENRODE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07 - 3463 CIVIL TERM ACTION IN DIVORCE STIPULATION REGARDING MARITAL HOME THIS AGREEMENT is made this day of 2007, BY and BETWEEN Jody L. Eckenrode, of 20 Allison Lane, Shippensburg, Cumberland County, Pa., 17257; hereinafter referred to as "Mother" A N D Rodney S. Eckenrode, of Cumberland County, Pennsylvania, hereinafter referred to as "Father". RECITALS 1. The Parties hereto were husband and wife joined in marriage on August 20, 1988 in Cumberland County, Pennsylvania; and 2. The Parties hereto are the natural parents of two (2) minor children, namely, Brittany Nichole Eckenrode, date of birth, June 16, 1991; and Noah Scott Eckenrode, date of birth, January 14, 1997. 3. The Parties hereto separated on or about June 8, 2007, and 4. The Parties have reached a partial agreement with regard to these matters; and 5. Upon execution hereof, the Parties desire that this Stipulation and Agreement may be adopted as an Order of Court. NOW THEREFORE, with the aforegoing recitals being hereinafter incorporated by reference and deemed an essential part hereof and in consideration of the covenants and promises hereinafter to be mutually kept and performed by each Party, as well as for other good and valuable consideration, receipt of which is hereby acknowledged, and the parties, intending to be legally bound, hereby agree as follows: (1) Husband has vacated the marital home. The parties have agreed that Wife may move back into the marital home and Wife shall have sole and exclusive possession of the marital home. Husband waives all interest in the marital home. Wife will pay the first and second mortgages on the home. (2) Wife will make all reasonable efforts to refinance the loan obligation on the marital home in her name alone within ninety (90) days. Husband will cooperate with signing all documents, including a spousal waiver, to effectuate this transfer. (3) This Agreement constitutes the entire understanding between the parties and there are no covenants, conditions, representations, or agreements, oral or written, of any nature whatsoever, other than those herein contained. J f IN WITNESS WHEREOF, the parties hereto, intending to be legally bound hereby, have hereunto set their hands and seals to this Agreement the day and y year first above written. WITNESS: 4t indsay ar Bair , Esquire 37 S. Hanover St. Carlisle, Pa. 17013 (717) 243-5732 Attorney for Father Rodney . Eckenrode, Husband Date: // /3-7 ne Adams, Esquire 4 S. Pitt St. Carlisle, Pa. 17013 (717) 245-8508 Attorney for Mother iJ.,. y ckenrode, Wife Date: / ? - /I ; cy 7 -T CD ? ?:_ 4 JODY L. ECKENRODE, Plaintiff V. RODNEY S. ECKENRODE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07 - 3463 CIVIL TERM ACTION IN DIVORCE AFFIDAVIT OF CONSENT 2007. 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on June 12, 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: J y L. enrode, Plaintiff WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 43301(c) AND 63301(d) 0F THE DIVORCE CODE 1. 1 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: 0 C?J / /Jy nrode, Plaintiff ?_ t?- 1' ?' Z f?= y .. . ?' ?` . l ? ? =?': . ?.:.% ?? «?. .? _ JODY L. ECKENRODE, Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 07 - 3463 CIVIL TERM RODNEY S. ECKENRODE, Defendant 2007. : ACTION IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on June 12, 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: m 1110 8 J. C Rodney S. Eck nrode, Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 43301(c) AND §3301(d) OF THE DIVORCE CODE 1. 1 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: 6 ! aI /C-, 8 A" J . &kw,.tQ Rodney S. ckenrode, Defendant ) C C TI y ? v PROPERTY SETTLEMENT AGREEMENT THIS IS AN AGREEMENT made thisaay of June, 2008, by and between Rodney S. Eckenrode, of 5 Travis Avenue, Shippensburg, Pennsylvania, (hereinafter referred to as Husband) and Jody L. Eckenrode, of 20 Allison Lane, Shippensburg, Pennsylvania, (hereinafter referred to as Wife). WHEREAS, Husband and Wife were married on August 20, 1988, in Cumberland County, Pennsylvania; and WHEREAS, various differences have arisen between Husband and Wife, whereby they have been living separate and apart since June 8, 2007; and WHEREAS, the parties have agreed to maintain separate and permanent domiciles and to live apart from each other; and WHEREAS, the parties desire to enter into an amicable settlement to provide for all of the property rights of the parties and to dispose of the rights and obligations of each to the other in respect to support, maintenance, alimony, counsel fees, equitable distribution, and all other rights and obligations under the Divorce Code of 1980, as amended, and it is the intention and agreement of the parties that this Agreement be a full, complete and final settlement of all of those rights and obligations under said Divorce Code; and NOW, THEREFORE, for and in exchange of mutual considerations, and intending to be bound by the provisions hereof, the parties agree that their recitals form a part of this Agreement and waive any right to counseling under the Divorce Code of 1980, as amended, and right to counsel fees, costs, alimony, support, maintenance, and any other rights under the said Divorce Code not provided for herein and agree as follows: 1. SEPARATION. The parties agree that it shall be lawful for each party, at all times hereafter, to live separate and apart from the other, at such place or places as he or she may, from time-to-time, choose or deem fit. Each party shall be free from interference, authority or contact by the other, as fully as if he or she were single and unmarried, except as may be necessary to carry out the provisions of this Agreement and ,as may be necessary to exchange information that pertains to the parties' minor child. Neither party shall molest the other or attempt to endeavor to molest the other, nor compel the other to cohabit with the other, or in any way harass or malign the other, nor in any way interfere with the peaceful existence, separate and apart, from the other. 2. REAL ESTATE. Husband and Wife jointly owned the marital residence located at 20 Allison Lane, Shippensburg, Pennsylvania. Husband has deeded any rights, title and interest he has in the marital residence to Wife. Wife has remortgaged the property and shall solely bear the financial responsibility for the property. Wife shall be solely responsible for all mortgage payments, liabilities, taxes, assessments, insurance and the cost of maintenance on the marital residence. Wife shall indemnify and hold Husband harmless from any liability, claims, causes of action, suits, or litigation for money owed, damages, indirect or consequential, including legal fees, arising out of failure of Wife to so pay such liens and encumbrances. 3. PERSONAL PROPERTY. The parties have divided or have agreed to a division of their personal property which includes bank accounts, certificates of deposit, life insurance policies, jewelry, clothing, furniture and other personal items. After the aforesaid division of the personal property is complete, any and all property in the possession of Husband shall be his sole and separate property. Any and all property in the possession of Wife shall be her sole and separate property. Each party forever renounces whatever claims he/she may have with respect to the property which the other is taking. Each party understands that he/she has no right or claim to any property acquired by the other after the signing of this Agreement. 4. PENSION/RETIREMENT PLANS. Wife hereby releases any and all claims or demands she may have on Husband's pension, retirement plan or 401k. Husband hereby releases any and all claims or demands he may have on Wife's pension, retirement plan or 401 k. 5. DEBTS. The parties represent and warrant to each other that neither has incurred any other debts nor made any other contracts for which the other or his/her estate may be liable, from date of separation forward. Neither party shall contract nor incur any debt or liability for which the other or his/her property or estate might be responsible and agrees to indemnify the other from any claims made against the other because of debts/obligations not incurred by the other. 6. ALIMONY, ALIMONY PENDENTE LITE, SUPPORT OF SPOUSE. The parties waive any and all right to receive from the other any payment of alimony, alimony pendente lite, and/or spousal support. 7. EFFECTIVE DATE. The effective date of this Agreement shall be the date of execution by the parties if they had each executed the Agreement on the same date. Otherwise, the execution date of this Agreement shall be defined as the date of execution by the party last executing this Agreement. 8. DIVORCE. A divorce action was initiated and filed at docket number 2007-3463 Civil Term in the Court of Common Pleas of Cumberland County on June 12, 2007. Both parties agree to execute any and all affidavits or other documents necessary for the parties to obtain an absolute divorce pursuant to Sections 33010 ) of the Divorce Code including waiver of all rights to request Court ordered counseling. 9. INCORPORATION INTO DECREE. Should a decree, judgment or order of separation or divorce be obtained by either of the parties in this or any other state, country, or jurisdiction, each of the parties hereby consents and agrees that this Agreement and all of its covenants shall not be affected in any way by any such separation or divorce; and that nothing in any such decree, judgment, order or further modification and revision thereof shall alter, amend or vary any term of this Agreement, whether or not either or both of the parties shall remarry, it being understood by and between the parties hereto that this Agreement shall survive and shall not be merged into any decree, judgment, or order of divorce or separation. It is specifically agreed, however, that a copy of this Agreement or the substance of the provisions thereof, may be incorporated by reference into any divorce, judgment or its decree. This incorporation, however, shall not be regarded as a merger, it being the specific intent of the parties to permit this Agreement to survive any judgment and to be forever binding and conclusive upon the parties. 10. MUTUAL RELEASE. Husband and Wife do hereby mutually remise, release, quit claim or forever discharge the other and the estate of such other, for all time to come, and for all purposes whatsoever, from any and all rights, title and interest, or claims in or against the estate of such other, of whatever nature and wherever situate, which he or she now has or at anytime hereafter may have against such other, the estate of such other or any part thereof, whether arising out of any former acts, contracts, engagements or liabilities of such other or by way of dower or curtesy of claims in the nature of dower or curtesy, or widow's or widower's rights, family exemption or similar allowance or under the intestate laws; or the right to take against the spouse's will; or the right to treat a lifetime conveyance by the other as testamentary or all or other rights of the surviving spouse to participate in a deceased spouse's estate, whether arising under the laws of Pennsylvania, any state, commonwealth or territory of the United States, or any other country or any right which either party may now have or at anytime hereafter have for past, present or future support or maintenance, alimony, alimony pendente lite, counsel fees, costs or expenses, whether arising as a result of the marital relation or otherwise, except and only except all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provision thereof. It is the intention of Husband and Wife to give to each other by the execution of this Agreement a full, complete and general release with respect to any and all property of any kind or nature, real, personal or mixed, which the other now owns or may hereafter acquire, except and only except all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provision thereof. 11. COUNSEL FEES. Each party individually covenants and agrees that he or she will individually assume the full and sole responsibility for legal expenses for his or her attorney and court costs in connection with any divorce action which may be brought by either party and shall make no claim against the other for such costs or fees. 12. ADDITIONAL INSTRUMENTS. Each of the parties shall, from time-to-time, at the request of the other, execute, acknowledge and deliver to the other party any and all further instruments or documents that may be reasonable required to give full force and effect to the provisions of this Agreement. 13. MODIFICATION OR WAIVER. A modification or waiver of any of the provisions of this Agreement shall be effective only if made in writing and executed with the same M ? 1 •? formality as this Agreement. The failure of either party to insist upon the strict performance of any of the provisions of this Agreement shall not be construed as a waiver of any subsequent default of the same or similar nature. 14. ENTIRE AGREEMENT. This Agreement contains the entire understanding of the parties and there are no representations, warranties, covenants or undertakings other than those expressly set forth herein. 15. SEPARATE PARAGRAPHS. It is specifically understood and agreed by and between the parties thereto that each paragraph hereof shall be deemed to be a separate and independent agreement. 16. BREACH. If either party breaches any provision of this Agreement, the other party shall have the right, at his or her election, to sue for damages for such breach or seek such other remedies or relief as may be available to him or her and the party breaching this Agreement shall be responsible for payment of legal fees and costs incurred by the other in enforcing the rights under this Agreement, or in seeking such other remedies or relief as may be available to him or her. 17. CONTROLLING LAW. This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania. 18. INVALIDITY OF PROVISIONS. If any term, condition, clause or provision of this Agreement shall be determined or declared to be void or invalid in law or otherwise, then only that term, condition, clause or provision shall be stricken from this Agreement, and, in all other respects, this Agreement shall be valid and continue in full force, effect and operation. 19. BINDING NATURE. Except as otherwise set forth herein, this Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective heirs, executors, administrators, successors and assigns. IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the day and year first above written. WITNESS Rodney S. ckenrode J L. enrode j' dsay D. Bair , Es wire !A3 f? : Ct ,y4 JODY L. ECKENRODE, Plaintiff V. RODNEY S. ECKENRODE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 07 - 3463 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: served via certified mail restricted delivery, return receipt requested, accepted on June 16, 2007. 3. Date of execution of the affidavit of consent required by 3301(c) of the Divorce Code: By Plaintiff By Defendant: June 21, 2008. June 21, 2008. 4. Related claims pending: None. 5. Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: Contemporaneously with this praecipe. Date Plaintiffs Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: Contemporaneously with this praecipe. Date: to 7 Respectfully Ja! Adams, Esquire I N10.79461 17 South St. rlisle, Pa. 17013 Attorney for Plaintiff P7 } ??? SwJ - l c.7 "{-d Fr c CD Ca;? ' C IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. Jody L. Eckenrode, Plaintiff N O. No. 07 - 3463 Civil Term VERSUS Rodney S. Eckenrode Defendant DECREE IN DIVORCE AND NOW, ? `?- IT IS ORDERED AND DECREED THAT _ Jody L Eckenrode , PLAINTIFF, AND Rodney S. Eckenrode 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; None; The marriage settlement agreement which was signed by the parties on June 25, 2008 shall be incorporated and not merged into this Decree. g' C ATTEST: J. PROTHONOTARY ol, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CNIL ACTION -LAW ~.c1 L ~ ~ cl~en rods Plaintiff ~ FILE NO. O 7' 3 ~~ ~ ~ , 20 _ VS. IN DNORCE `` P ~ c5', ~ l~~ n r~~ n ~ ~ p _, „/ r. Defendant ~~ m r :- ~ r~ -r ni -'-_ NOTICE TO RESUME PRIOR SURNAME ~`Y"~ - Notice is hereby given that the Plaintiff/Defendant in the above m atter, ~av iii~' -: been granted a Final Decree in Divorce on the ~ 5'r day of O ~ hereby elects to resume the prior surname of rn ~ I , and gives this written notice pursuant to the provisions of 54 P.S. 704. DATE: 6 -o~s ~ ~ COMMONWEALTH OF PENNSYLVANIA oC ~ ~, Signature Sign re o me being resumed SS. COUNTY OF CUMBERLAND On the ~,~ day of ~,~~ 20 l(~ ,before me, a Notary Public, personally appeared the above 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. In Witness Whereof, I have hereunto set my hand and official seal. COMMONVVEALTtI OF PENNSYLVANU ~~~ ~~u=~-~ ~~~ SEAL Notary Public KATHYA. BURIO:iT, NOTARY PUBLIC ~/~ 00 /D °(- 1°~~ CARLISLE BOROUGH, CUMBERLAND COUNTY MY COMMISSION EXPIRES MAY 23, 2012 ~k.sh _____ _.._..__.____.____. 2~a.y~1~~y