Loading...
HomeMy WebLinkAbout03-5312 rR.EI)6vt\C\::. L ''VA.N ~EN \ 2q S. IV>.,NOVee. ~T) N>1C;> ~lJ. (.LE 'B'\ I, \) I:? -1,-1 ;;L45" 9/8 'I IN THE COURT OF COMMON PLEAS OF v. '/ E.LEIJA O. 'Jr,.,,,j '\:x,.1.L "" 'Sro S- W. JJM.TH ST CA~uSLa 1>A tlQI$ 117 Jllff? f/{!lZ- e;'rl) TERM NO . () 3- ') 3 J ::L 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 by the plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the grounds for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at IF YOU DO NOT FILE A CLAIM: FOR ALIM:ONY, DNISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DNORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Forms 20 AFFIDAVIT OF CONSENT Frederick L. Van Doren 129 S. Hanover St, Apt. D. Carlisle, Pa. 177013: :IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : Yelena O. Van Doren 365 W. North St. Carlisle, Pa. 17013 (717) 245-9184 : NO. 03-S'2/). e;C.I~L~82..~ AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on October 9, 2003. 2. The marriage of the Plaintiff and the Defendant is irretrievably broken. Ninety days have elapsed since the filing of the Complaint. 3. I consent to the entry of a final decree of divorce. WAIVER OF NOTICE OF INTENTION TO REQUESTS ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 (C) OF THE DIVORCE CODE> 1. I consent to the entry of a final Decree of Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorce until a Decree in Divorce is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. 4. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. o C ~:--~ ~~! .,:-,- ---j -, ....., = = .r- S r= 9 n ..... ::r:~ nl..~ r- -orn :0'-' aT :;j ~? (j:d :'.0 ,-=-C- r'i''l ;~ -< 0> ;z:,., -:.;.. \9 U1 1.0 AFFIDAVIT OF CONSENT Frederick L. Van Doren 1 29 S. Hanover St, Apt. D. Carlisle, Pa. 177013: :IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : Yelena O. Van Doren 365 W. North St. Carlisle, Pa. 17013 (717) 245-9184 :NO. 03 - S'J/).... dud.~ '--r-'irL~ AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on October 9, 2003. 2. The marriage of the Plaintiff and the Defendant is irretrievably broken. Ninety days have elapsed since the filing of the Complaint. 3. I consent to the entry of a final decree of divorce. WAIVER OF NOTICE OF INTENTION TO REQUESTS ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 (C) OF THE DIVORCE CODE> 1. I consent to the entry of a final Decree of Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorce until a Decree in Divorce is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. 4. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. 0 r--> r; = 0 = .c' " ,:.:tj '- ...... c.:: ::r::.." .- nl--' r~ -om 0" :n? ~_~C) :::-.. ;--c. =~-~: g~ >~:~ '!? :;:-1 :~ (..11 :n .0 -< Ci:3 - ~ 31.).. C;o~L~ ~ YELENA O. VAN DOREN Pro Se .AGREEMENT BETWEEN FREDERICK L. VAN DOREN and YELENA O. V AN DOREN FREDERICK L. VAN DOREN Pro Se Agreement made this j (., ~_ day oL..:.1-t~-=4--' 2004, by and between YELENA O. VAN DOREN (hereinafter known as "Wife"), currently residing at 365 W. North Street, Carlisle, Cumberland County, Pennsylvania, and FREDERICK L. VAN DOREN (hereinafter known as "Husband"), currently residing at 129 S. Hanover St., Apt. 0, Carlisle, Cumberland County, Pennsylvania. WITNESSETH: WHEREAS, the parties hereto are Husband and Wife, having been married November 18, 1982 in Moscow, Russia, USSR. There were eight children born of this marriage, said children being Yulia, a girl born September 16, 1983 and now emancipated; Sophia, a girl born July 3, 1987; Page 1 of 1 3 Natalia, a girl born April 27, 1989; Daniel, a boy born May 18, 1990; Sarah, a girl born June 18; 1993; Leah, a girl born December 21, 1 994; Aaron, a boy born November 10, 1996; and Eliyana, a girl born January 2, 1999. WHEREAS, the marriage has been irretrievably broken and it is the intention of Wife and Husband to live separate and apart, and the parties desire to settle their respective financial and property rights and obligations, including the equitable distribution or marital property, spousal support and alimony, child support, child custody and child visitation and all other claims that one party mi!~ht bring against the other or the other's estate, now or in the future. NOW, THEREFORE, the parties agree to be legally bound as follows: I. AGREEMENT WILL NOT PREVENT DIVORCE PROCEEDINGS This agreement shall not affect the right of the Wife or the Husband to a divorce on lawful grounds. The parties intend to secure a mutual Page 2 of 1 3 consent no-fault divorce pursuant to the provisions of Section 3301 (c) of the Divorce Code of 1980, as amended. II. EFFECT OF DIVORCE DECREE The parties agree that the provisions of this agreement, unless otherwise state, will continue after a Decree of Divorce is entered. III. AGREEMENT SHALL BE INCORPORATED IN DIVORCE DECREE The parties agree that the terms of the agreement shall be incorporated into any divorce decree that may be entered with respect to them, and this Agreement will be independent of any Decree in Divorce. The parties agree that all the provisions of this Agreement constitute a binding contract for the purposes of any enforcement action or proceedings. IV. DATE OF EXECUTION The date of execution of the Agreement is the day on which the Agreement is signed by both parties. V. DATE OF DISTRIBUTION Page 3 of 1 3 Any transfer of property, fund sand/or documents pursuant to the Agreement shall be made on the date of execution of this agreement, unless otherwise specified in this Agreement. VI. TERMINATION OF AGREEMENT If a final Decree of Divorce is not entered within one year of the date of execution of this Agreement, the Agreement shall automatically become null and void and the Agreement shall not be binding on the parties. Any property or funds distributed pursuant to the agreement shall be returned to the party holding the property or funds before the date of execution. VII. PRO SE REPRESENTATION Both parties are aware of their respective rights to seek advice of counsel, and the parties have chosen to reach this Agreement by themselves. The parties each acknowledge that they have made full and complete disclosures of all information relevant to a distribution of their property and to a determination of their respective marital rights and responsibilities. Each party understands the terms, conditions and provisions of this Agreement and believes them to be fair and reasonable. Page 4 of 13 Each party is entering into the Agreement freely and voluntarily and the execution of this Agreement is not the result of any duress, undue influence, collusion or improper or illegal agreement or agreements. VIII. EFFECT OF BANKRUPTCY In the event that either part becomes a debtor in any bankruptcy or financial reorganization proceedings of any kind while this Agreement is ins effect, that party waives any and all rights to any property held by the debtor and sought by the creditor-spouse in fulfillment of this agreement. The debtor will convey to the spouse any and all property necessary to fulfill this agreement. No obligations pursuant to this Agreement are dischargeable under any state or federal law. I X. CHILD SUPPORT Husband agrees to pay to Wife 178.00 per month per emancipated child for support. These payments will begin on September 1, 2004. These payments will continue for each child until each child is emancipated. Each child will be emancipated on (1) reaching age eighteen or (2) graduation from Page 5 of 1 3 high school, whichever is later, or (3) entry into the armed services, or (4) marriage, or (5) on becoming self-supporting. xx. CUSTODY Husband and wife will have shared legal and physical custody of Sophia, Natalia, Daniel, Sarah, Leah, Aaron and Eliyana. Wife will be the primary caregiver and the children will live with her. Husband will be the secondary caregiver and will take the children three days a week on an alternating schedule, as follows: Week 1: Tuesday, Wednesday, Thursday Week 2: Friday, Saturday, Sunday The parties can make adjustments to this schedule by agreement. XI. CHANGE OF RESIDENCE If either party desires to change residence, that party shall give the other party at least 90 days prior written notice in order to allow both parties to make new custody and visitation agreements if necessary. If the Page 6 of 1 3 parties are unable to make such an agreement, both parties agree that the Court of Common Pleas of Cumberland County, Pennsylvania, shall have jurisdiction to issue a custody and visitation order. XII. PERSONAL PROPERTY The parties have divided their personal property. Wife agrees that all personal property not otherwise identified in this Agreement now in Husband's possession is the sole property of Husband, and Husband agrees that all personal property not otherwise identified in this Agreement now in possession of Wife is sole property of Wife. XIII. MOTOR VEHICLES A. The 1996 Dodge Caravan, VIN 2B4GP45R5TR5Ei7465 shall be the sole property of Wife, free of liens and encumbrances. B. The 1995 Taurus, VIN 1 FALP5245SA30707527 shall be the sole property of Husband, free of liens and encumbrances. Page 7 of 1 3 XIV. BANK ACCOUNTS The parties agree that all funds in the bank account numbered 1 298240 at M& T Bank are the sole property of Husband, and Wife now waives any and all future claims to those funds. XIV. REAL ESTATE TRANSFER Husband shall sign and deliver to Wife all documents necessary to transfer title to Wife in the real estate known as 365 West North Street and situated at 365 North Street, Carlisle, Pennsylvania. This title shall be free of liens and encumbrances, except for the existing mortgage, which Wife assumes. Husband agrees to pay real estate taxes and hazard insurance for this property as long as any of the children, younger than 18, remain in the house, or until the property is sold. Wife agrees to indemnify and hold harmless Husband for any other liability and expense incurred in connection with this property. The documents necessary to carry out the provisions in this paragraph shall be delivered to Wife at 365 W. North Street on September 1,2004. Page 8 of 1 3 XVI. DEBTS, LIABILITIES AND OTHER OBLIGATIONS The parties agree to divide the responsibilities for paying their debts according to the list below. Each party further agrees to pay these debts in full and on time. Each party releases the other party from those debts not assigned to that party and releases that party from any penalties resulting in connection with these debts and liabilities. Each party agrees that no debts shall be incurred for which the other may be liable except as stated in this Agreement. DEBT Mortgage on 365 W. North St. Carlisle, PA PAYOR Wife Student Loan with U.S. Dept of Education Husband XVII. PROPERTY ACQUIRED AFTER SIGNING AGREEMENT Page 9 of 1 3 Any property acquired by either party after this Agreement is executed is the sole owner of that property, and any and all claims by the other party to that property are waived. XVIII. TAXES The parties agree that they will file a joint Federal Income Tax return for the 2003 tax year. State, federal and local income taxes for 2003 will be paid by Husband. Any refunds will be the property of Husband. XIX. METHOD OF PAYMENT All periodic payments to Wife, unless specified otherwise, shall be mailed to Wife at her residence at 365 W. North Street, Carlisle, Pennsylvania, or at her current residence if she moves. xx. CONSOLIDATION The agreement constitutes the entire and full agreement between the Page 1 0 of 1 3 parties. No other agreements have been made between the parties. XXI. SEVERABILITY If any clause is held unenforceable or found to be in any way unexecutable, or if a court alters or holds unenforceable any clause in this contract, this shall in no way affect or alter the other clauses in the agreement, which shall remain in full force. Each party has carefully read and fully understands all clauses, statements, provisions and conditions in this Agreement. IN WITNESS THEREOF, intending to be legally bound hereby, the parties have set their hands and seals the day and year first written above. L (/J/lIJ, =L ~), .V~/ ____~~/----~~=-------- (SEAL) WITNESS WIFE Page 1 1 of 1 3 ~.JU/V (SEAL) WITNESS HUSBAND COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND On this, the __~-- day of _..Ju~----' 2004, before me, a Notary Public of the Commonwealth of Pennsylvania, residing in the City of _tili..\isle-.- and the County of _~clatuiJ personally appeared Frederick L. Van Doren, known to me to be the person whose name is subscribed to the within Agreement and acknowledged that he executed the same for the purposes therein contained. IN WITNESS THEREOF, I have hereunto set my hand and official seal. _~--1U ~~~1~_ ~: COMMONWEALTH OF PENNSYLVANIA NOTARY PUBLIC NOTARIAL SEAL ANN NEIDIGH, NotIIly Public earnsle Bora, Cumberland County My Commission ExpiI8l Feb. 2, 2008 COMMONWEALTH OF PENNSYLVANIA Page 1 2 of 1 3 COUNTY OF CUMBERLAND On this, the ~__LilL--- day of ___J.~---_. 2004, before me, a Notary Public of the Commonwealth of Pennsylvania, residing in the City of -.L.ur \, slL- and the County of _.Jlunt~ personally appeared Yelena O. Van Doren, known to me to be the person whose name is subscribed to the within Agreement and acknowledged that she executed the same for the purposes therein contained. IN WITNESS THEREOF, I have hereunto set my hand and official seal. --b rJ~ NOT ARY PUBLIC COMMONWEALTH OF PENNSYLVANIA NOTARiAl SEAL ANN NEIDIGH, Not8IY NlIiC Carlisle eoro, Cumbelland CountY My Commission Expires Feb. 2, 2008 . Page 1 3 of 1 3 (") ,...., s; c:;::) ~ i;:-::) -"'" I"''; '- -.... (..~. :J:.." r:= ni.-~ ,- ,..,rTI 0-, 1-~~? ~::i ~:, :Do> -:--"1-, ::t::: ~);:: ~.r1 -\i~rl ::-1 ~.-., C--', .I.-'.. --< ::;, \L) -< hu.iJE:\Q..\L~ L. VA-v \)o.i.E"-' llCj S. HlWove;/2. ST ApI l> ) CA-ILL'Sl.-E- f'A nOI'S III ;)..4'5" {JI.?L/ v. '!ELENA O. V'ArJ D<>R.E"-' 3, I:: 0:;- vJ. NOR..:rn S 7 . CAR..Ll>L.E j)A i ( 0/ :s. '7 q '14'i J'-t82- :IN THE COURT OF COMMON PLEAS OF CW:J TERM NO. 03. S 3/,2.; COMPLAINT IN DIVORCE COUNT I REQUEST FOR DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE . . . Rt.::'\)E-I'tI~ L. c , 1\. . s: AP'T, 1. PlamtIffls Vrw~N ,whocurrentlyresidesat \)':l ~.~<>v~ Ii CAR-L \ Sus I PA I, <:> , 3- '/ELEtJA O. A' r 2. Defendant is VAr>J ~N , who currently resides at '3{,S""' w- 1\.tl1L'TH ::;, T. CAR..u S q=.. \ PA \ (\J I S. F~vE.~I<"'l<. L' 3. V f'N Do R-e. ^" has been a bona fide resident of the Commonwealth ! I i I I' ! i! !I " ., I' ,\ of Pennsylvania for a period of more than six (6) month immediately preceding the filing of this Complaint. 199,2... 4. The parties were married on the Il> ,,, day of NOv ,~_, at mosCoW, u:ssR . Attached I[ 1/ i hereto and marked Exhibit "A" is the certificate of marriage evidencing said marriage. Fonns 23 I ] . 1 " 5. Neither plaintiff not defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 6. There have been no prior actions for divorce or for annulment between the parties except 7. The defendant has been advised of the availability of counseling and the right to request that the Court require the parties to participate in Counseling. 8. The marriage of the parties is irretrievably broken. 9. After 90 days have elapsed from the date of the filing of this Complaint, Plaintiff intends to file an affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an affidavit. WHEREFORE, if both parties file affidavits consenting to a divorce after 90 days have elapsed from the date of filing of this Complaint, Plaintiff respectfully requests that a decree of divorce be entered pursuant to Section 3301 (c) of the Divorce Code dissolving the marriage between Plaintiff and Defendant. :~ Fonns 24 ! . c ,. .~".i 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. Section 4904, relating to unsworn falsification to authorities. f~/ti~ Plaintiff Date: 10!7!tJ 3 ["{...\-\\€'I\ A 1)3 USSR MARRIAGE CERTIFICATE Citizen Van Doren, Frederirk Little, born 9 February 1952, place of hirth USA, New Jersey; and citizen Zubareva. Ye1ena Olegevna, born 23 February 1960, place of birth Moscow Region, city of Balashikha have entered into marriage. which, in accordance with the Law was registered 11.18.B2 (November 18, 1982). After entering into marriage they have taken these surnames: Husband: Van Doren Wife: Van Doren Flace of registration: Palace of Marriages No.1. Civilian Registry Office of the executive committee of the Moscow City Council. Date of registration: 18 November 1982. This document has been legalized in the Consular Administration of the USSR Ministry of Foreign Affairs, 26 May 1983. (Si.gnature) Head of the department of Consular Administrati.on, MFA USSR. J11.. Galishniknv. No 572/989/2/w (Seal): USSR Ministry of Foreign Affairs S",a1 of the Moscow City Council of People's Deputies, Russian Soviet Federated Socialist Republic, USSR. DIZ-I-MJu. No. 008249. \ ~ ~. . ,.. -"'. E:'j..~-h'5\T A 2/3 --"~"_--"_--:-;""~"~'-""""""- ,...'.'. .,. . . , '"_;:,<,,_._;: ~'::'<: 0.;.....' ",:,:'.;:"":">c,,"'-.':::"':;'""..''''~,' ..,....-;:_:(,;:,.:,':,'.r"->':.:;.:,~~.... __........... .-_~ ':~;:"-t.~?:f:::.:~;:"i;~:~?~-c:; :.~._~. '. -. .:~frp~~ ~-~"--" ~ ~_J~;~,>1~ ~ ~ i~i .~- ~ ~ ~'I%ll!l<-'-~'t' ~ 6l ! _"5 ,~ ~ ill. ,. ~. ")0( ,~" - tt:::l;.. ~ ~ t -"d c= ~ ~~ '> /, ..,-.:>j.:~;: o .o<i':.-' ~ ,;,.-,.-);;;t;.. 'l:~ .. '~~ - ----. "":rn. ;:S;'" JIt' '" _:'~ "" , "_ _,~..,o -./~"'~'O'.. =,~_ ~-'-. '''''~*<~. $=~~~~:;;i;m.~ r<!F-'~ W- l j '", '"~",- ,'r ~'t.:=>, .~'.l",.=-.,.... ! .~7-t:. : j '( ~ ~ ~1 '.~~: .".: ':~"." '. , i ~"r . . !.'t:)' ! 1.& '<;i.\"~;'-'" i..... 1\$5.[ ".j;s:.'.:,-:"~:'~'", l:.f s.~: '!'. ..~...~~~':~~ . -i~ I, :':fi! .1 ." ','..'c:::::lI ..':.., iif,~] f"';llr ~: '~~~i . .' '= _: '. :~;I; (:" ~ . : ,,,,.,~ ~. ,.,...... ~: . i~ ~~!li... ,:...c -, E..s..'.." ," ,,.,, <~~J",':; ~; . '1 ~_ .. 1":.7.'~ i ., 'i ~ , .. s g ,'(1) .~.'" . "''''':''.'' ,'\I." ". ;;~;~~~~l'~~ t\;;;,i" ",.:;~~~!""~~:~/\::(~j,:',,...::;1!~,,':::' ,", - ~::!;"'f:~(~ .~/~<;J -C-;'~I.-"'~ ;'i.iT. "?:~~'- -~-- ,~.;...~.-'" - XI":CJ." .~> .... ;: .. .. ..;;; , "'j , , i 'i~''''~ ',I ;; = " = = :::',"'l -~"'<.' C'. t I L \ ~ '-, --- --,.:-- . E. i-\-\\,(/:7 \ T IL\ 3/3 ~ ~ '''0 .... ~OE:~lL~ L. VAv OCJt1..E..J \ 2q S. ~"'t\VEJt'ST} Ai>T P CAiZ-L<. SLE I fA \/0/3 (11 'd-4'5" '1184 IN THE COURT OF COMMON PLEAS OF v. '/8---6NA O. V,v" L\,it.EtV :3 f,<;"' IN. Nofl..n.j 5(. C.1\iLL.-lSLE f'A liO\3, 111 '-fl.fg /4'i!,'Z- ~ TERM No.03-53/;J.... COUNSELING NOTICE The Divorce Code of Pennsylvania requires that you be notified of the availability of counseling where a divorce is sought under any of the following grounds: year Section 3301 (a) (6) - Indignities (Section 3301 (~ - Irretrievable breakdown- Mutual Consent Section 3301 (d) - Irretrievable breakdown -TwoiTbree separation A list of qualified professionals is available for inspection in 1='(1:"'\"0,",0'1+\/2. "'l a FF l c..e;. Forms 26 ,:1 ,.': ~OE'''-lc\<..L. VAv i),~-v' 12q S l-fA"''''vE4 Sr ,.fWl1> CAv<.USu= (JA "OIS In ;).1t '5 '1 II? '-I IN THE COURT OF COMMON PLEAS OF v. 'fai2NA 0 \}..v 1)O/l..e;.N ';;{CoS- W NeIL.>-, 5, CA(l.L.>.sw=; rA 1/01.6 1~"1 4c.t '& fit 15 2- ~ TERM NO. 03- 5312. AFFIDAVIT OF NON-MILITARY SERVICE FI2E~/U:.1 . /?Iv L1tjO'0eing duly sworn according to Law, deposes and says thaQshe knows by his/her own personal knowledge and therefore avers that defen- '/ELEI\IA D. dant, VAN Do I1..E tV , is ..!L2. years of age; that he/she is employed by S EL t= Errl rl () ''f t.- \) and that he @s not in the military service of the United States or its allies, or otherwise within the provision of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940 and its amendments. y-/~/Y/fl Plaintiff Sworn to and subscribed before me this ~y of ~b.w-, 2063 CjQJuJ~Q. ~ '\T(lt~ry Public NOTARIAL SEAL CLAUDIA ^ BREWBAKER, NOTARY PUBLIC Carlisle Boro, Cumberland County My commission Expires April 4, 2005 !!II i' j" , 1:':. 'I i!l: Forms 27 0 C) -;[ ~ ~ 'J ~ f. ,-'") ~ .,1 -<::. '" .. " '- '" ~ '" ",:_) ~ .-<' I,; HtcOcvt.\c..t::. L. V~'" DOIZ..EAJ I J... q 5 HAAlDVffi S T) /t(J/ P CA.tL-l~U:: PA 1,0/3 1/1 :J-'1<:J 9J2'-1 IN THE COURT OF COMMON PLEAS OF v. (1;J TERM '1EL0'JA O. VAN DDCl...f=-,.J 3b~ W tvblLTH ST. CA1l-u S '--E (lA n 0 I 3- III 4<+8 Iqg?- NO. 03- SO J"v AFFIDAVIT AS TO SIGNATURE Hp:j)SIlIU L. ~ ~,,",being duly sworn according to law, deposes and says that he/she is the Plaintiff in the above-captioned divorce action; that he/she is familiar with the signature of the Defendant; and that the signature on the return receipt attached hereto as Exhibit "A" is the signature of the Defendant. / -k0~/ Plaintiff Sworn and subscribed before me this ~day of D eJ.n~ I r , 200:, ~ jo"rhoO. ~o"Mf Notary Public NOTARIAL SEAL CLAUDIAA. BREWBAKER, NOTARY PUBLIC Carlisle Bora. Cumberland County My Commission Expires April 4, 2005 F onus 29 c - ^ c._ 'tl:-\-\[3, I ( ,., m€DEt2.../CK L. !A,v LhtE'\l 129 S Hwvr::v6tl. S 1'", APT 1) ~Llf.LE.) I'A I/DI5 II. ~s: 9/8Lr IN THE COURT OF COMMON PLEAS OF v. YCl-.-'6N1', 0 VAN \)c:tl.6/V 3 tS kJ MI1.7T1 5r. CA(l..J..J.. s,l..E PA I 7 D I :s 717 '-H'8 /4'8<- (I~ A TERM NO. 03-53/.0 ACCEPTANCE OF SERVICE I hereby accept service of the Complaint in Divorce filed in the above-captioned matter. ad, ~, 20 c3 I ~~(~ Defendant Forms 28 j I J ~. . (") 0 0 C~ (..) --n ..""" c:> ;:J :~,,- vi,T-; C) ~'] [9~:r -i :;-1 r-n Z c y (.0 CD -< () r'- 1:: ~~ -" -- ,1 =).::; (~ Z C-? "jrn s:; '-i ::) SS -c 00 -< ... Frederick L. Van Doren, Plaintiff :IN THE COURT OF COMMON PLEAS :OF CUMBERLAND COUNTY, : PENNSYL VANIA vs. CIVIL ACTION - LAW CUSTODY Yelena O. Van Doren, Defendant : # 03.53/;), CIVIL TERM CUSTODY STIPULATION AND PARENTING AGREEMENT This Agreement and Stipulation entered into the day and year hereinafter set forth, is by and between FREDERICK L. V AN DOREN, natural father, by his attorney, Ruby D. Weeks, Esquire, and YELENA O. VAN DOREN, natural mother, by her attorney, Mark A. Mateya, Esquire, who aver as follows: I. Plaintiff is natural father and an adult sui juris, who resides at129 South Hanover Street, Apartment D, Carlisle, Cumberland County, Pennsylvania. II. Defendant is natural mother and an adult sui juris, who resides at 365 West North Street, Carlisle, Cumberland County, Pennsylvania,. - 2 - III. Mother and father are the parents ofthe following children: Yulia, a girl born September 16, 1983 and now emancipated; Sophia, a girl born July 3, 1987; Natalia, a girl born April 27 , 1989; Daniel, a boy born May 18, 1990; Sarah, a girl born June 18, 1993; Leah, a girl born December 21, 1994; Aaron, a born born November 10, 1996; and Eliyana, a girl born January 2, 1999. IV. The parents agree to the following terms regarding parenting ofthese children and request the terms be entered as an Order of Court: A. The parties shall have jointly, shared, legal custody of the children, with parents to share in decision making involving the children and the father having the ability to receive school, medical, and other records concemmg the children, to attend the children's activities and performances and to receive notice in advance of these. B. The mother shall have actual physical custody of the children, with periods of partial custody with to the father as follows: I. For a minimum of fifteen (15) hours per week with each child at times of his and the children's mutual choice, not necessarily to be taken consecutively and not necessarily with all children at one - 3 - time. The parents shall agree on specific times for the subsequent week by the preceding Saturday evening. 2. The father shall have the children on the first or second day of Rosh Hashanah, the first or second day of Passover, and for any of the eight days of Chanukkah that the father and the children agree. 3. (A) The father shall always have the children on Christmas Day. (B) The mother shall always have the children from 9 a.m. to 6 p.m. on Mother's Day, and the father on Father's Day. (C) The father shall have the children one week each year to vacation with the paternal grandparents in New Jersey. He shall provide the mother and children thirty (30) days advance notice of the dates. (D) Each parent shall have time with the children on the child's birthday and on the parents' birthday. The parents agree to work out the specific times between themselves. It is understood that this time is not to interfere with the children's attendance at school. - 4 - b (E) The father may have partial custody of children, ifboth parties agree, during such additional periods as the parties shall from time to time agree, without the need to modify the Order of Court entered as a result of this Stipulation. (F) The parties shall notify each other in a timely fashion if it is necessary due to an emergency or unforseen circumstance for him or her to be delayed or unable to keep any of the times set out herein. (G) The parties will notify and consult with the other party immediately in cases of medical emergencies that occur while the children are in their custody. (H) The parties agree that they shall keep each other advised of the children's whereabouts at all times, and to provide the other parent an emergency telephone number and address in the event they do take the children from Carlisle. Additionally, the mother agrees to inform the father when a child is left at home in the care of the maternal grandmother. This exchange of information is purely informational and gives neither parent veto power. - 5 - . (1) Neither parent shall do anything which may estrange the children from the other parent or injure the opinion of the children as to the other parent, or which may hamper the free and natural development of the children's love or affection for the other parent. (J) The parties agree that in making this Agreement, there has been no fraud, concealment, overreaching, coercion, or other unfair dealing on the part ofthe other. IN WITNESS WHEREOF, the parties hereto intending to be legally bound -:tit VlI1 by the terms hereof, set forth their hands and seals this ~ day of JlJf'-"-~05. 0~~~ Ruby D. eeks, Esquire Attorney for Father 10 West High Street Carlisle, PA 17013 Frederick L. Van D Father ~J2<- Yelena O. Van Doren Mother - 6 - .. COMMONWEALTH OF PENNSYL VANIA : ss COUNTY OF CUMBERLAND On this, the ~day of Mi1J ,2005 before me, a Notary Public, the undersigned officer, personally appeared Yelena O. Van Doren, mother, known to me to be the person whose name is subscribed to the within Custody Stipulation and Agreement, and acknowledged that she executed the same for the purposes therein contained. ~ Jlf) -e4f; ~ otary Public , TH NOTARIAL SEAL ANN NEIDIGH, Notary Public Carlisle Boro, Cumberland County My Commission Expires Feb. 2. 2008 COMMONWEALTH OF PENNSYL VANIA : ss COUNTY OF CUMBERLAND On this, the ;lhil- day of fi1af ,2005, before me, a Notary Public, the undersigned officer, personally appeared Frederick L. Van Doren, father, known to me to be the person whose name is subscribed to the within Custody Stipulation - 7 - .t. . and Agreement, and acknowledged that he executed the same for the purposes therein contained. of Pen NOTA!'!I~; ~EAI. NIIc SHlm.EY P. e'L ;.. ,-:R, Nolary . J ~'l ''''-''and~ C~'rll'" n "':!-r~ '<,,':"~"J_' My~J;' E:;pires May 14, - 8 - ~~,;??a",~ . Notary p lic tJ ~ ~ r:>~ ?- '" ~~JVJ t'6 ~'6 .....t:- c- .r:-_ , .~A ".. -,-.., ,~ .- Frederick L. Van Doren, Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, :PENNSYL VANIA vs. CIVIL TERM IN DIVORCE Yelena O. Van Doren, Defendant :NO. 03-5312 WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER ~ 3301 (c) OF THE DIVORCE CODE I. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. 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. S 4904 relating to unsworn falsification to authorities. Date: 5"khS- I I ~/k FREDERICK L. VAN DOREN, Plaintiff """ .'2:; 0 <:::,'") "n <-. C":: ~_..._"" I 1'\) - f\) a VI Frederick L. Van Doren, Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, : PENNSYLVANIA vs. CIVIL TERM IN DIVORCE Yelena O. Van Doren, Defendant :NO. 03-5312 WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER ~ 3301 (c) OF THE DIVORCE CODE I. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! 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 ofthe 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. S 4904 relating to unsworn falsification to authorities. Date: j -::J7 -19 J /~ L YELENA O. VAN DOREN, Plaintiff I f\:J -;") -' 0.) C) C.t; '::v ~.5 CJ"1 o " y i'<"i:G j--" -:-,j-,', "') :::1 ',:.?<~. , f='~ _,C-, (--, ::.0."1 Frederick L. Van Doren, Plaintiff :IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, :PENNSYL VANIA vs. :CIVIL TERM :IN DIVORCE Yelena O. Van Doren, Defendant :NO. 03-5312 ACCEPTANCE OF SERVICE I, Ye1ena O. Van Doren, Defendant in the above captioned divorce action, hereby accept personal service at 365 West North Street, Carlisle, Pennsylvania, of the Complaint in Divorce, docketed to No. 03-5312. .J ~ t.tt..t./II-e.., ;1- &1.f Ool-o~ "'LOO~ Dated: (P -:1. () r (:'%~ Yelena O. Van Doren, Defendant C) C"'" e_, = (,'::;'"':) <J, '- C.: o 'j -I -,- Fr'lp"~J I" c:~, , ,,~ N Frederick L. Van Doren, Plaintiff vs. :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, :PENNSYL VANIA CIVIL TERM IN DIVORCE Yelena O. Van Doren, Defendant . :NO. 03-5312 PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code dissolving the marriage between Plaintiff and Defendant. 2. Date and manner of service of the complaint: October 8, 2003 by Acceptance of Service dated June 2, 2005. 3. Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by the plaintiff May 25.3005'; by the defendant May 27.2005. 4. Related claims pending: NONE 5. Date plaintiff's Waiver of Notice in S 3301(c) Divorce was filed with the prothonotary: ~/'J/'{)~ . Date defendantlsWaiv~r of Notice in S 3301(c) Divorce was filed with the prothonotary: ~;':~I/!/;- . Dol" 6,l;/"'''' RUbY~~ Attorney for the Plaintiff N C) 0") ,....,.. ,::"~ ~, \__J -n .-{ ., nl :c: r-. -r:J,"'" :'r=J -) c__ c ..~.'''': I N ~ -. ,co'.,...., )fr'i S;,. ::0 -< . ... RECEIVED JUN 01 2rlI.Jr Frederick L. Van Doren, Plaintiff / :IN THE COURT OF COMMON PLEAS :OF CUMBERLAND COUNTY, : PENNSYL VANIA vs. CIVIL ACTION - LAW CUSTODY Yelena O. Van Doren, Defendant : # b3'53I~ CIVIL TERM ORDER OF COURT AND NOW, thi~ of ~005, upon agreement ofth~ parties, the attached Parenting and Support Stipulation and Agreement is made an Order of Court. BY TH~ COUR'T'f f" J. ..RUby D. Weeks, Esquire For Plaintiff --Mark /.. Mateya, ~O:J1]il f) fer Defc!lc!alit ~e.ft . " " f) ,cP 'Cf ,0 . uJ ~2 l..,.,_ l:") , .,-, ~7"i 2uJ U-::.:r: >-" D_ O CJ cn 9 N I :".-1 "'> ...C> c::7) C:;;:J c..... - I ~ Frederick L. Van Doren, Plaintiff :IN THE COURT OF COMMON PLEAS :OF CUMBERLAND COUNTY, : PENNSYL VANIA vs. CIVIL ACTION - LAW CUSTODY Yelena O. Van Doren, Defendant : # 03-53/;), CIVIL TERM CUSTODY STIPULATION AND PARENTING AGREEMENT This Agreement and Stipulation entered into the day and year hereinafter set forth, is by and between FREDERICK L. VAN DOREN, natural father, by his attorney, Ruby D. Weeks, Esquire, and YELENA O. VAN DOREN, natural mother, by her attorney, Mark A. Mateya, Esquire, who aver as follows: I. Plaintiff is natural father and an adult sui juris, who resides at129 South Hanover Street, Apartment D, Carlisle, Cumberland County, Pennsylvania. II. Defendant is natural mother and an adult sui juris, who resides at 365 West North Street, Carlisle, Cumberland County, Pennsylvania,. - 2 - III. Mother and father are the parents of the following children: Yulia, a girl born September 16, 1983 and now emancipated; Sophia, a girl born July 3, 1987; Natalia, a girl born April 27, 1989; Daniel, a boy born May 18, 1990; Sarah, a girl born June 18, 1993; Leah, a girl born December 21, 1994; Aaron, a born born November 10, 1996; and Eliyana, a girl born January 2, 1999. IV. The parents agree to the following terms regarding parenting of these children and request the terms be entered as an Order of Court: A. The parties shall have jointly, shared, legal custody of the children, with parents to share in decision making involving the children and the father having the ability to receive school, medical, and other records concernmg the children, to attend the children's activities and performances and to receive notice in advance of these. B. The mother shall have actual physical custody of the children, with periods of partial custody with to the father as follows: 1. For a minimum of fifteen (15) hours per week with each child at times of his and the children's mutual choice, not necessarily to be taken consecutively and not necessarily with all children at one - 3 - . - time. The parents shall agree on specific times for the subsequent week by the preceding Saturday evening. 2. The father shall have the children on the first or second day of Rosh Hashanah, the first or second day of Passover, and for any of the eight days of Chanukkah that the father and the children agree. 3. (A) The father shall always have the children on Christmas Day. (B) The mother shall always have the children from 9 a.m. to 6 p.m. on Mother's Day, and the father on Father's Day. (C) The father shall have the children one week each year to vacation with the paternal grandparents in New Jersey. He shall provide the mother and children thirty (30) days advance notice of the dates. (D) Each parent shall have time with the children on the child's birthday and on the parents' birthday. The parents agree to work out the specific times between themselves. It is understood that this time is not to interfere with the children's attendance at school. - 4 - - (E) The father may have partial custody of children, ifboth parties agree, during such additional periods as the parties shall from time to time agree, without the need to modify the Order of Court entered as a result of this Stipulation. (F) The parties shall notify each other in a timely fashion if it is necessary due to an emergency or unforseen circumstance for him or her to be delayed or unable to keep any of the times set out herein. (G) The parties will notify and consult with the other party immediately in cases of medical emergencies that Occur while the children are in their custody. (H) The parties agree that they shall keep each other advised of the children's whereabouts at all times, and to provide the other parent an emergency telephone number and address in the event they do take the children from Carlisle. Additionally, the mother agrees to inform the father when a child is left at home in the care of the maternal grandmother. This exchange of information is purely informational and gives neither parent veto power. - 5 - - . -. ~ (1) Neither parent shall do anything which may estrange the children from the other parent or injure the opinion of the children as to the other parent, or which may hamper the free and natural development of the 'children's love or affection for the other parent. (1) The parties agree that in making this Agreement, there has been no fraud, concealment, overreaching, coercion, or other unfair dealing on the part of the other. IN WITNESS WHEREOF, the parties hereto intending to be legally bound by tho leon, h"oof, "t forth tho;, h,od, ,od ,,~, thi, ,,;Q;;,y of ~05 RU~ F"d,"okL. V'nD Attorney for Father Father 10 West High Street Carlisle, PAl 70 I3 QfY'~ Yelena O. Van Doren Mother - 6 - - . COMMONWEALTH OF PENNSYL VANIA : 58 COUNTY OF CUMBERLAND On this, the ~day of ^11J , 2005 before me, a Notary Public, the undersigned officer, personally appeared Yelena O. Van Doren, mother, known to me to be the person whose name is subscribed to the within Custody Stipulation and Agreement, and acknowledged that she executed the same for the purposes therein contained. COMMONWEALTH OF PENNSYL VANIA : ss COUNTY OF CUMBERLAND rOF; NOTARIAL SEAL ANN NEIDIGH, Notary PubIc Carlisle Born, Cumberland COlInty My CommIssion Expires Feb. 2, 2008 On this, the ~~;# day of -:?J1~ ' 2005, before me, a Notary Public, the undersigned officer, personally appeared Frederick L. Van Doren, father, known to me to be the person whose name is subscribed to the within Custody Stipulation - 7 - -... - . -.. . - and Agreement, and acknowledged that he executed the same for the purposes therein contained. tl NOTARIAL SEAL SHIl11.EY P. CU;:,T;pi,'}EA, No1ary NIle ~ .'. '''''iand~ ,,^.,'~l^ ,,"r-r,l ',i~'\;!1..'.j, 4, uY~n Expinls May 1 - 8 - ~~;.77~ Notary P hc tJ 70' tfr -a. ~ ~ ~J\ .~ 'B ~ ~ -c:.. c- - .~ ~ ~ q s.:~ ~, r:.'"! C) c.? -n 0" ---' 5~~' ~..r: -n -<: p1;;;:;;o I"'" "~JJ.~ ()V , ;.-(\ r--,) ---' r:~ C,) :)~ "" :.;"':.;'" :';"':f.'" . .. . "''''''''''''' '" "':f."':f.:+; "'''':Ii .. . IN THE COURT OF COMMON PLEAS . . . . . . . . . . . . . . OF CUMBERLAND COUNTY PENNA. STATE OF rt FREDERICK L. VAN DOREN, #03-5312 CIVIL TERM . . . . . PLAINTIFF No. VERSUS . YELENA O. VAN DOREN, . . DRFRNDANT . . . . . . DECREE IN DIVORCE . . . . . ~Vv2~ ~GT FREDERICK L. V AN DOREN AND NOW, IS ORDERED AND . . . . . . DECREED THAT , PLAINTIFF, YELENA O. VAN DOREN . . . . . . . . . . . . AND , 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; \tk . . . ? / . . . . . . . PROTHO~OTARY . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .' ~ ~ :!l- ~ ~~'IJ-., yJ hi- /l #"" /'tf""'# 4"w p1J pl' ~/'? .' ... ........