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HomeMy WebLinkAbout07-6795b w -1 TAMMY EGE, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. Q -7 -- 6 7 -5 - G) ve l JASON EGE, : CIVIL ACTION - LAW Defendant : IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in. the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for 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, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE 32 South Bedford Street Carlisle PA 17013 (717) 249-3166 Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y pueda entrar una orden contra usted sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE 32 South Bedford Street Carlisle PA 17013 (717) 249-3166 L3 TAMMY EGE, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. ?7 -(9?Ct c1?? 1 -few JASON EGE, : CIVIL ACTION - LAW Defendant : IN DIVORCE COUNTI COMPLAINT FOR DIVORCE UNDER SECTION 3301(C) OR 3301(D) OF THE DIVORCE CODE AND NOW, comes the above-named Plaintiff, Tammy Ege, by her attorney, Mark A. Mateya, Esquire, and seeks to obtain a Decree in Divorce from the above-named Defendant upon the grounds hereinafter more fully set forth. 1. Plaintiff is Tammy Ege, is an adult individual who currently resides at 243 Hunters Road, Newville, Cumberland County, Pennsylvania. 2. All legal papers may be served on Plaintiff by service on her Attorney, Mark A. Mateya, Esquire with a mailing address of P.O. Box 127, Boiling Springs, PA 17007. 3. Defendant is Jason Ege, an adult individual who currently resides at 2893 Ritner Highway, Carlisle, Cumberland County, Pennsylvania 17015. 4. Plaintiff and Defendant are bona fide residents of the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 5. The Plaintiff and Defendant were married on October 9, 2005, in Carlisle, Cumberland County, Pennsylvania. 6. There have been no prior actions of divorce or for annulment of marriage between the Parties in this or any other jurisdiction. 7. The marriage is irretrievably broken. 8. Neither the Plaintiff nor the Defendant are members of the armed services of the United States or any of its allies. 9. 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. COUNT II CLAIM FOR EQUITABLE DISTRIBUTION OF MARITAL PROPERTY UNDER THE DIVORCE CODE 10. Plaintiff and Defendant are the owners of various items of real property, personal property, furniture and household furnishings that may be subject to equitable distribution by this Court. 11. Plaintiff and Defendant are the owners of various motor vehicles, bank accounts, investments, insurance policies and retirement benefits which may be subject to equitable distribution by this Court. WHEREFORE, Plaintiff requests the Court to enter a Decree: a. Dissolving the marriage between Plaintiff and Defendant; b. Equitably distributing all property owned by the parties hereto; C. In the event that a written Separation Agreement is reached between the parties hereto prior to the time of hearing on this Complaint, Plaintiff respectfully requests that pursuant to §304(a)(1) and (4) and §401(b) of the Divorce Code the Court approve and incorporate, but not merge such Agreement in the Final Divorce Decree; e. For such further relief as the Court may determine equitable and just. Respectfully submitted, Id By: i Mark A. Mateya Attorney I.D. No. 78931 P.O. Box 127 Boiling Springs, PA 17007 (717) 241-6500 Dated 6 V Attorney for Plaintiff VERIFICATION I, Tammy Ege, verify that the facts set forth in the foregoing Complaint for Divorce are true and correct to the best of my knowledge, information, and belief. I understand that false statements herein are subject to the penalties of 18 Pa.C.S. § 4904, relating to unworn falsification to authorities. DATED: 06 ? - yl a 7 ?/ T Ege v Q ^Q Q ? w n ? 5 n e ?a 4.?7 ?r rv tJ r- i,?Y ( )m TAMMY EGE, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : No. e 7 - lO 7 ??r C Jy? c?h. JASON EGE, : CIVIL ACTION - LAW Defendant : IN DIVORCE COUNT III COMPLAINT FOR CUSTODY AND NOW, comes Petitioner, Tammy Ege, by and through her attorney, Mark A. Mateya, and respectfully represents: 1. The Plaintiff is Tammy Ege, who presently resides at 243 Hunters Road, Newville, Cumberland County, Pennsylvania. 2. The Defendant is Jason Ege, presently residing at 2893 Ritner Highway, Carlisle, Cumberland County, Pennsylvania 17015 3. Plaintiff seeks custody of the following child: Name Present Residence Age D/OB Tason Ege 243 Hunters Road, Newville, PA 1 Yrs. 9/12/06 4. The child was not born out of wedlock. 5. The child is presently in the custody of Tammy Ege and Jason Ege. Jason Ege presently resides at 2893 Ritner Highway, Carlisle, Cumberland County, Pennsylvania. 6. During the past five (5) years the child has resided with the following persons at the following addresses: a. With Plaintiff and Defendant at 2893 Ritner Highway, Carlisle, Cumberland County, Pennsylvania. 7. The Father of the child, Jason Ege, is currently residing at 2893 Ritner Highway, Carlisle, Cumberland County, Pennsylvania, and he is married. 8. The Mother of the child is Tammy Ege who is currently residing at 243 Hunters Road, Newville, Cumberland County, Pennsylvania, and she is married. 9. The relationship of the Plaintiff to the child is that of natural mother. The Plaintiff currently resides with the child. 10. The relationship of the Defendant to the child is that of natural father. The defendant currently resides alone. 11. The Plaintiff has not participated as a party or witness, or in another capacity in other litigation concerning the custody of the child in this or any other Court. 12. Plaintiff has no information of a custody proceeding concerning the child pending in any Court of this Commonwealth or any other state. 13. Plaintiff does not know of a person not a party to the proceeding who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 14. The best interest and permanent welfare of the children will be served by granting shared physical custody of the child to Plaintiff and Defendant because: a. Plaintiff is the natural mother of the child; b. Plaintiff has been a primary caregiver of the child from the time of the child's birth to the present; C. Plaintiff is able to provide a stable home for the child. d. Defendant is the natural Father of the child; -2- e. Defendant has been involved with the child from the time of the child's birth to the present. WHEREFORE, Plaintiff requests this Honorable Court to schedule a custody conciliation at the Court's convenience. Dated: 7 v Respectfully submitted, W,k?t Mark A. Mateya Attorney I.D. No. 78931 P.O. Box 127 Boiling Springs PA 17007 (717) 241-6500 Attorney for Plaintiff -3- VERIFICATION I, TAMMY EGE, verify that the facts set forth in the foregoing COMPLAINT FOR CUSTODY are true and correct to the best of my knowledge, information, and belief. I understand that false statements herein are subject to the penalties of 18 Pa. C.S. §4904, relating to unworn falsification to authorities. T Y EGE DATED: t 06 1 A o?)j -4- ^? 1 QQ ?? N ?I o a O cl? ?? p ?? ?-- f,. ? t .??. ..: _:? 5--.,i ?_'; srA; C'?.) <-:? z! .__? i=? ? r? 17 7 _- ;, =?3 -?. TAMMY EGE, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 07-6795 JASON EGE, : CIVIL ACTION - LAW Defendant : IN DIVORCE AND CUSTODY AFFIDAVIT OF SERVICE AND NOW, this 13th day of November, 2007, comes Mark A. Mateya, Esquire, Attorney for Plaintiff, who, being duly sworn according to law, deposes and says that: 1. A Complaint for Divorce and Custody was filed to the above term and number on November 8, 2007. 2. On or about November 9, 2007, a certified copy of the Complaint in Divorce and Custody was mailed to the Defendant, via Certified Mail, Restricted Delivery, Return Receipt Requested. The Return Receipt was received by Plaintiff s counsel, Mark A. Mateya, Esquire on or about November 13, 2007, and was signed for by the Defendant on November 10, 2007. A copy of the Return Receipt is attached hereto as Exhibit "A" and is incorporated herein by reference. F'7 3. A certified copy of the Complaint was mailed to the Defendant via first class mail, postage prepaid on November 9, 2007. The Certificate of Mailing is attached hereto as Exhibit "B" and is incorporated herein by reference. Respectfully submitted, w , k7?:7- - Mark A. Mateya, uire Attorney I.D. No. 78931 P.O. Box 127 Boiling Springs, PA 17007 (717) 241-6500 (717) 241-3099 Fax Attorney for Plaintiff ru CERTIFIED MAIL RE CEIPT M ,. (Domestic Only, No In surance Coverage Provided) m For deliver inform ti i it b i C3 M y a on v s o Trl -` FT C ur we s te at www.usps.com,!,, IAL M ru Postage $ J-; j u . C3 C3 Certified Fee C3 Return Re'I Fee (E d t R r. Q PostmarkV CO Herd n orsemen equired) ? C3 0 t Restricted Delivery Fee (Endorsement Required) - ?? Q A$ ?p p Total Postage & Fees r` = 4 f , `! i , , . M p Sent To C3 J ft n --- soNWApr: No:;--------- 3 --R r7" N ?i2,---?-?--- --------------- or PO Box No. A x q -- City Stale NAT --- --------- --• -____-_-_ -r --- .. ¦ 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 malipieoe, or on the front If space permits 1. Article Addressed to: A893 k ?Ttiti214W/ a Ak,k,151-5 SPA 0015 a sg pro Agent Addresses B. by (Printed ) ?? G 1 L U U I D. Is delivery address dfiferent from item 17 ? Yes If YES, enter delivery address below: ? No 3. T Certified Mail ? Express Mail ? Registered ? Return Receipt for Mwchandlea ? insured mail ? C.O.D. 4. Restricted Delivery? (Extra Fee) Yes 2. Article Number 7003 0500 0004 2330 3932 (fiensfer 1?orr? servk?e ? Ps Form 3811, February 2004 Domestic Return Receipt 1025e5-02-M-ts40 U.S. POSTAL SERVICE CERTIFICAT , G MAY BE USED FOR DOMESTIC AND INTERNAT? OAS OT PROVIDE FOR INSURANCE-POSTMASTER F ?? O Received From. ATtjA, LAW P. 0. o'X IA 7 °s v ? QIL I A16 z5P,e /A)Gs PA-77007 One piece of ordinary mail addressed to: Guw? A 893 k i- vu- 41 TAP-k16?8 PA Q a Q ? r-, ?n Ln Lrr_- ?_ oL?a z C= a-...NOa; LLL9 X - L!I Z C <L ? J 2: O M ?g PS Form 3817, Mar. 1989 Billing Attu - none C) P1.11 ° -n ,Mrn C:) -? hp. =j ? 1 '„o m cn C', r TAMMY EGE PLAINTIFF V. JASON EGE DEFF,NDANT ' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2007-6795 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Wednesday, November 21, 2007 ,upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. the conciliator, for aPre-Hearing Custody Conference. At such conference an Thursday, December 20, 2007 _ effort will be made to resolve the issues at 9:30 AM if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter intoln dispute; or order. All children age five or older may also be present at the c provide grounds for entry of a temporary or permanent order °nference. Failure to appear at the a temporary conference may The court hereby directs the parties to furnish any and all Special Relief orders, and Custody orders to the conciliator existing Protection from Abuse orders, 48 hours prior to scheduled hearing. FOR THE COURT, By' Is- l Hubert X. Gilro Es ?ustOy Conciliator The Court of Common Pleas of Cumberland with Disabilites Act of 1990. For information about ac our is required by law to com 1 available to disabled individuals having business before the court, p y with the Americans sible facilities and reasonable accommodations must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled YOU SHOULD TAKE THIS PAPER TO YOUR eduled HAVE AN ATTORNEY OR CANNOT AFFORD ONE GO TO OR ATTORNEY AT TELEPHONE ONCE. THE IF YOU OFFICE SET DO N FORTH BELOW TO FIND OUT WHERE YOU CAN GET L NOT EGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 DEC 19 2007 TAMMY EGE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW JASON EGE, : NO. 2007-6795 Defendant IN CUSTODY COURT ORDER AND NOW, this day of December, 2007, the Conciliator being advised the parties have reached an agreement, the Conciliator relinquishes jurisdiction. Hubert . Gilroy, Esquire Custody Conciliator ! ? :C Wd OZ 330 i# OOZ AUvioiNi4 i' aoW 3HI JO 30!xI:0-- u TAMMY EGE IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. No. 07-6795 Civil Term JASON EGE Defendant : ACTION IN CUSTODY STIPULATED CUSTODY AGREEMENT AND NOW, this 50 day of _ , 2007, the parties to this proceeding, Jason Ege and Tammy Ege, agree to resolve the issue of child custody of their Child, Tason Ege, upon agreement to be entered as an Order of Court upon approval, as per the following: Plaintiff is Tammy Ege, (hereinafter "Mother"), who resides at 243 Hunters Road, Newville, PA 17241. Defendant is Jason Ege, (hereinafter "Father"), who resides at 2893 Ritner Highway, Carlisle, PA 17015. The Child that is the subject of this proceeding is Tason Ege, born 9/12/06. The Child was born in wedlock. The parties seek to resolve their issues by written Stipulated Custody Agreement to be entered as an Order of Court and they agree upon the following terms: Legal Custody: The Father, Jason Ege, and the Mother, Tammy Ege, shall enjoy shared legal custody of the minor child, Tason Ege, born 9/12/06. The parties shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding his health, education and religion. Pursuant to the terms of 23 Pa.C.S. §5309, each parent shall be entitled to all records and information pertaining to the Child including, but not limited to, medical, dental, religious or school records, the residence address of the Child and of the other parent. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to make the records and information of reasonable use to the other parent. Physical Custody: The Mother shall have primary physical custody of Tason subject to Father's partial physical custody pursuant to the following schedule. a. Father shall have physical custody of Tason every Wednesday evening from 6:00 pm until Thursday morning. 9:00 am. Father shall pick Tason up at day care and return him to daycare in the morning. b. Father shall have physical custody of Tason every other weekend from Saturday at 9:00 am until Monday at 7:00 am. Father shall pick up Tason at mother's residence. Father shall drop off Tason at the daycare. c. The parties may mutually agree to alter/expand this schedule as necessary or desired. The non-custodial parent shall be entitled to have reasonable liberal telephone contact with the Child. In the event of a medical emergency, the custodial party shall notify the other parties as soon as practicable after the emergency is handled. The parties are directed to utilize appropriate child restraints when transporting Tason. The parties are directed to notify one another of any change in address or phone number as soon as practicable. Neither parry may say or do anything nor permit a third party to do or say anything that may estrange the Child from the other party, or injure the opinion of the Child as to the other party, or may hamper the free and natural development of the Child's love or affection for the other party. During any periods of custody or visitation, the parties shall not possess or use controlled substances or consume/be under the influence of alcoholic beverages to the point of intoxication. No person transporting Tason shall consume alcoholic beverages prior to transporting Tason. No person transporting Tason shall be under the influence of any alcoholic beverages while transporting Tason. The parties shall likewise assure, to the extent possible, that other household members and/or house guests comply with this provision. All major holidays shall be alternated and arranged pursuant to the attached Holiday schedule. Tason's birthday shall be arranged as mutually agreed upon. Each parent shall have two weeks of vacation with Tason per year. The vacation periods shall not be consecutive for more than seven days. The requesting parent shall give the other parent 30 days advance notice of the requested time and this vacation week shall supersede the regular physical custody schedule. In the event the parties schedule conflicting vacations, the party first providing written notice shall have the choice of vacation. Prior to departure, the parties will provide each other with information regarding the intended vacation destination and a telephone number at which they can be reached during their vacation. The parties may expand this vacation time by mutual agreement. Relocation: The parties have negotiated the custody portions of this Agreement based upon the parties' residence in Cumberland County. If either party intends to establish residency outside of Cumberland County, he or she must give to the other parent at least ninety (90) days' written notice in advance of the proposed move, in order to allow the parties to confer prior to the move and to establish a mutually satisfactory arrangement in light of the changed circumstances. In the event the parties are unable to reach an agreement, the parties agree that the Court of Common Pleas of Cumberland County shall have jurisdiction over them to fashion an appropriate custody Order. Representation: In reaching this agreement, Father is represented by Mark Bayley, Esq. and Mother is represented by Mark Mateya, Esq. This agreement is binding and enforceable when signed by Jason Ege and Tammy Ege. Both parties agree that this Agreement and Stipulation shall be incorporated into an Order of Court. Wherefore, the parties ask this Honorable Court to enter an Order in accordance with this Stipulated Custody Agreement. Date Date 1 J_-J `' Date Date 2- Respectfully submitted, on Ege Tammy ge A 96L Mark Matey sq. HOLIDAYS AND TIMES EVEN ODD SPECIAL DAYS YEARS YEARS Easter Da From 9 am until 6 m Mother Mother Memorial Da -------------- - From 9 am until 6 m Mother Mother Independence Da From 9 am until 6 m Mother Mother Labor Da From 9 am until 6 m Mother Mother ------------ Halloween From one hour before trick or Mother Mother treating to one hour after trick or treating Thanksgiving I' From 8 am Thanksgiving Day to 3 Father Father Half m on Thanksgiving Da Thanksgiving 2" a From 3 pm on Thanksgiving Day to Mother Mother half noon the day after Thanksgiving Da Christmas Block A From noon 6 pm until 9 pm on Mother Father 12/24 and from 5 pm until 9 pm on 12/25 Christmas Block B From 9 pm on 12/24 until 5 pm on Father Mother 12/25 New Year's From 6 pm 12/31 until noon January Mother Father V (with the 12/31 year to control the even/odd determination Mother's Da From 9 am until 9 m Mother Mother Father's Da From M am until 9 m Father Father c--> p ->.. ?.. ?'" ? of ' ? ? ?? -?„ .- - r- ' ? t t?: ; C{'1 . -, a !:_? ?" ?-? JAN 10 2008 !'S' /?{ J l TAMMY EGE : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. No. 07-6795 Civil Term JASON EGE Defendant : ACTION IN CUSTODY ORDER AND NOW, this I y" day of January, 2008, upon consideration of the attached Custody Stipulation, the following Custody Order is entered: 1. The mother, Tammy Ege, and the father, Jason Ege, shall enjoy shared legal custody of Tason Ege, born September 12, 2006. 2. The mother shall enjoy primary physical custody of the minor child. 3. The father shall enjoy periods of temporary physical custody of the minor child as follows: a. Every Wednesday evening from 6:00 p.m. until Thursday morning at 9:00 a.m. Father shall pick the minor child up at day care and return him to day care in the morning. b. Every other weekend from Saturday at 9:00 a.m. until Monday at 7:00 a.m. Father shall pick up the minor child at mother's residence. Father shall drop the minor child off at day care. C. At such other times as the parties mutually agree to. d. Holidays - The parties shall alternate custody on the following holidays: Labor Day, Thanksgiving, Christmas as stated below, New Years Day, 4 Easter, Memorial Day, Fourth of July, Mother's Day and Father's Day. Mother shall have custody of the minor child in even numbered years and Father shall have custody of the minor child on odd numbered years. 1. The custodial parent shall have custody of the minor child on Easter, Memorial Day, Independence Day and Labor Day from 9:00 a.m until 6:00 p.m. 2. Halloween - The custodial parent shall have custody of the minor child from one hour before trick or treating to one hour after trick or treating. 3. Thanksgiving shall be divided in two halves with Father having the first half in even and odd numbered years - The first half shall commence from 8:00 a.m. Thanksgiving day to 3:00 p.m. on Thanksgiving Day. The second half of Thanksgiving shall commence from 3:00 p.m. on Thanksgiving Day to noon the day after Thanksgiving. Mother shall have custody of the minor child for the second half of the Thanksgiving holiday in both even and odd numbered years. 4. Christmas is to be divided into two pieces with Mother having part "A" in even numbered years which consists of Christmas Eve from noon until 9:00 p.m. and from 5:00 p.m. until 9:00 p.m. on Christmas Day; Part "B", which Father shall have in even numbered years, shall consist of Christmas Eve at 9:00 p.m. until 5:00 p.m. on Christmas Day; Mother shall have Part "A" in even numbered years and Father shall have Part "B" in even numbered years; 5. New Years - Mother shall have custody of the minor child on even numbered years from 6:00 p.m. New Year's Eve until noon January 1St. Father shall enjoy the same custody arrangement in odd numbered years. 6. Mother's Day - Mother shall have custodial rights with the minor child from 9:00 a.m. until 9:00 p.m. 7. Father's Day - Father shall have custodial rights with the minor child from 9:00 a.m. until 9:00 p.m. 8. Father and Mother shall mutually agree upon custody of the child on the child's birthday. e. Vacation - Each party shall be entitled to two (2) weeks of vacation with the child during the child's summer vacation. The party wishing to exercise his or her custodial vacation time with the child shall notify the other party, in writing, at least thirty (30) days prior to the intended vacation period. This vacation week shall supersede the regular physical custody schedule. f. At such other times as the parties mutually agree. 4. Neither parent shall consume alcohol or be under the influence of alcohol when they have custody of the minor child. 5. The parties shall have reasonable telephone contact with the child while the child is in the other parent's custody. 6. Neither party shall make any disparaging remarks regarding the other party in the presence of the child nor permit third persons to make disparaging remarks concerning the other party while in the presence of the child. 7. Father and Mother shall share transportation of the child. In the absence of an agreement to the contrary, the party gaining custody of the child shall be responsible for transportation. 8. Cumberland County Court of Common Pleas will retain jurisdiction in any disputes involving the child or custody of the child. 9. If either party intends to establish residency outside of Cumberland County, he or she must give to the other parent at least ninety (90) days' written notice in advance of the proposed move, in order to allow the parties to confer prior to the move and to establish a mutually satisfactory arrangement in light of the changed circumstances. BY THE COURT: -gj-c3t,w, ?ff-q h tv 4° - 80/trll f C0 :, H, ".1 ? I HIVF S0Cl TAMMY EGE, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 07-6795 JASON EGE, : CIVIL ACTION - LAW Defendant : IN DIVORCE AND CUSTODY AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) or (d) of the Divorce Code was filed on November 8, 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Tammy Ege -7/401 Plaintiff DATED: cap r-- orn cm TAMMY EGE, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 07-6795 JASON EGE, : CIVIL ACTION - LAW Defendant : IN DIVORCE AND CUSTODY AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) or (d) of the Divorce Code was filed on November 8, 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unworn falsification to authorities. E' 8 DATED: - Jason ge Defendant `??Z ? ??? r-'- ? ? J -.,. .?-`', ,., {- -? ..-? ??' `._ ? -? .? ? TAMMY EGE, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 07-6795 JASON EGE, : CIVIL ACTION - LAW Defendant : IN DIVORCE AND CUSTODY WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(c) OF THE DIVORCE CODE 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 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. -' / 0 ?i? DATE Jason Ege Defendant C7 eb j7, 7. ? r` TAMMY EGE, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 07-6795 JASON EGE, : CIVIL ACTION - LAW Defendant : IN DIVORCE AND CUSTODY WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 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 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 Tatum Ege Plaintiff C-) "cry cz3° p "fit r ` `l ? G TAMMY EGE, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 07-6795 JASON EGE, : CIVIL ACTION - LAW Defendant : IN DIVORCE AND CUSTODY PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: By certified mail on November 10, 2007 3. Complete either paragraph (a) or (b): (a) Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by Plaintiff July 4, 2008 ; by Defendant Ju-1 2, 2008 (b)(1) Date of execution of the Plaintiffs affidavit required by Section 3301(d) of the Divorce Code: (2) Date of service of the Plaintiff s affidavit upon the Defendant: 4. Related claims pending: None 5. (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: (b) Date Plaintiffs Waiver of Notice in §3301(c) Divorce was filed with the prothonotary: Simultaneously herewith. Date defendant's Waiver of Notice in §3301(c) Divorce was filed with the prothonotary: Simultaneously herewith. Each parry has filed a Waiver of the Notice of Intention to Request Entry of A Divorce Decree. 4? -?? Mark A. Mateya, squire P.O. Box 127 Boiling Springs, PA 17007 (717) 241-6500 Attorney for Plaintiff C7 C= t C„ aim m ,„ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. TAMMY EGE - No. 5795 2007 VERSUS DECREE IN DIVORCE AND NOW, ?/ ??` ZDO IT IS ORDERED AND DECREED THAT TAMMY EGE , PLAINTIFF, AND JASON EGE ARE DIVORCED FROM THE BONDS OF MATRIMONY. ,DEFENDANT, 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; The court retains jurisdiction of any claims raised by the parties to this action for which a fi-n*! order- has not yet been- entered. The Mai cage Settlement Agreement entered into by and between the parties is incorporated but not merged into the Divorce Decree. BY THE OURT: ATTE Sry: J. PROTHONOTARY 5 1 .? i 'a '. ?U 91-L ?? ? t .?