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HomeMy WebLinkAbout04-1176 IN THE COURT OF COMMON PLEAS OF THE JUDICIAL DISTRICT OF PENNSYLVANIA COUNTY CUMBERLAND Rachel Kay Nace, Plaintiff 210 West Allen St., Apt. 1 Mechanicsburg, Pennsylvania 17055 181-62-3850 ~ ~ ~ ~ ~ ~ ~ ~ ~ CIVIL ACTION - LAW ~ TERM CASE NO. P S' - /I? (, Charles Edward Nace, III, Defendant 4800 Charles Road, Unit L Mechanicsburg, Pennsylvania 17050 196-60-2994 IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in Court for divorce. If you wish to defend against the claims set forth on the other side of this page, you must take prompt action. You are wamed 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 this paper by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of you child or children. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the CUMBERLAND County Courthouse, in Mechanicsburg, PA. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE DIVORCE OF 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. Office of the Prothonotary CUMBERLAND County Courthouse Mechanicsburg, PA. Telephone( ) IN THE COURT OF COMMON PLEAS OF THE JUDICIAL DISTRICT OF PENNSYLVANIA COUNTY CUMBERLAND Rachel Kay Nace, Plaintiff 210 West Allen St., Apt. 1 Mechanicsburg, Pennsylvanie 17055 181-62-3850 ~ ~ ~ ~ ~ ~ ~ ~ ~ CIVIL ACTION - LAW TERM CASE NO. 0'1-/1,1. Charles Edward Nace, III, Defendant 4800 Charles Road, Unit L Mechanicsburg, Pennsylvania17050 196-60-2994 IN DIVORCE COMPI "'NT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Rachel Kay Nace who resides at; 210 West Allen St., Apt. 1; Mechanicsburg, Pennsylvania 17055. 2. Defendant is Charles Edward Nace, III who resides at: 4800 Charles Road, Unit L; Mechanicsburg, Pennsylvania 17050. 3. IIll Plaintiff andlor IIll Defendant have been a bona fide resident(s) of the Commonwealth of Pennsylvania for at least six months immediately prior to commencement of this action. 4. Plaintiff married Defendant on June 27, 2002 at Carlisle, Cumberland County, Pennsylvania. Attached hereto and marked as Exhibit "A" is the certificate of marriage evidencing said marriage. 5. Neither plaintiff nor defendant is in the military or naval service of the United States or its allies within the provisions of the Soldier's and Sailor's Civil Relief Act of Congress 1940 and its amendments. 6. There has been no prior action of divorce or for annulment between the parties. Complaint for Divorce; Page 1 7.The marriage is irretrievably broken. 8. After 90 days have elapsed rom the date of filing of this Complaint, Plaintiff intends to file an affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an affidavit. 9. Plaintiff has been advised that marriage counseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in marriage counseling. 10. The following children were bom to or adopted by the parties to this marriage: Name Kaylee Lynn Nace Birthdate January 27. 2003 Age o WHEREFORE, if both parties file affidavits consenting to a divorce after 90 days have elapsed form 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 the Plaintiff and Defendant. COUNT II REQUEST FOR INCORPORATION OF MARITAL SETTLEMENT AGREEMENT PURSUANT TO SECTIONS 3104(A)(1) AND (3) AND 3323(6) OF THE DIVORCE CODE. Paragraphs 1-10 are incorporated herein and made a part hereof by reference as though fully set forth. The parties have entered into a written Marital Settlement Agreement providing for the care, custody and support of their minor child(ren), a copy of which is attached hereto and incorporated by this reference the same as if fully set forth at length, and their agreement is in the best interest of the child(ren). Complaint for Divorce; Page 2 WHEREFORE, Plaintiff respectfully requests that this Court approve and incorporate the agreement reached between the parties into the final divorce decree. pursuant to Sections 3104(a)(1) and (3) and 3323(b) of the Divorce Code. Rachel Kay Nace I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to penalties of the 18 Pa.C.S. ::::~~7;i;;unswom falsification to aki ( k 7(~_ Rachel KeY Nace. Pro Per 1"'-_" , c..., L:...' , , IN THE COURT OF COMMON PLEAS OF THE JUDICIAL DISTRICT OF PENNSYLVANIA COUNTY CUMBERLAND Rachel Kay Nace, Plaintiff 210 West Allen St., Apt. 1 Mechanicsburg, Pennsylvania 17055 181-62-3850 Charles Edward Nace, III, Defendant 4800 Charles Road, Unit L Mechanicsburg, Pennsylvania17050 100-60-2994 ~ ~ ~ ~ ~ 9 9 ~ 9 CIVIL ACTION - LAW TERM CASE NO. oq- tr7 & IN DIVORCE COUNSELING NOTICE RULE 1920.45(a)*(1) 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: Section 3301 (a)(6) Indignities Section 3301 (c) Irretrievable breakdown Mutual Consent Section 3301 (d) Irretrievable breakdown TwolThree year separation A list of qualified professions is available for inspection in the Office of the Prothonotary CUMBERLAND County Courthouse Mechanicsburg, PA. Telephone( ) i--:'l C..-' ~ ,- ,-, ~ \..;:J ~ t .' " (...) ~ - ~ ~ "- ~ ~ ~ 0 -J \i r vl IN THE COURT OF COMMON PLEAS OF THE JUDICIAL DISTRICT OF PENNSYLVANIA COUNTY CUMBERLAND Rachel Kay Nace, Plaintiff 210 West Allen St., Apt. 1 Mechanicsburg, Pennsylvania 17055 181-62-3850 Charles EdWard Nace, III, Defendant 4800 Charles Road, Unit L Mechanicsburg, Pennsylvania17050 196-60-2994 ~ ~ ~ ~ ~ ~ ~ ~ ~ CIVIL ACTION - LAW C1 _101 CASE NO. TERM (jLj- II7LP IN DIVORCE AFFIDAVIT AS TO SIGNATURIE Rachel Kay Nace, being duly Sworn aCCOrding to law, deposes and says that Rachel Kay Nace is the Plaintiff in the above-captioned divorce action; that Rachel Kay Nace is familiar with the signature of the Defendant; and that the signature on the Acceplance of Service attached hereto as Exhibit "A" is the signature of the Defendant, Charles Edward Nace, III. Date: ~/;q/O(j & Rachel Kay N Sworn t(1d subscribed before me this the /CfI1. day of ~'~. ~OOi . ~~ .PA~{ "La I ~~ ~ ~ " No Public COMMONWEALTH OF PENNSYLVANIA [Notarial Seal Sherry L Potteiger, Notary Public Middlesex Twp" Cumberland County MyCanmlssioO Expires Nov, 22, 2007 Momber, Pennsylvania Association Of Notaries C) (" r--.> <= c:::::J ~ (..,~ c::: i'~- ...0 f-- :...:.:: 2~i ~"'I -<. :s () -n -J :1_""1""1 f'llp -or~~ 'oC;: ~~) ~.V~~' ~f;; -"',.. ~ .'.- .. o -, Charles Edward Nace, III, Defendant 4800 Charles Road, Unit L Mechanicsburg, Pennsylvania17050 196-60-2994 IN THE COURT OF COMMON PLEAS OF THE __ JUDICIAL DISTRICT OF PENNSYLVANIA COUNTY CUMBERLAND Rachel Kay Nace, Plaintiff ~ CIVIL ACTION _ LAW 210 West Allen S1., Apt. 1 ~ Mechanicsburg, Pennsylvania 17055 ~ 181-62-3850 ~ ~ ~ ~ ~ ~ u'vll TERM CASE NO. () G/, //7 (fl IN DIVORCE AFFIDAVIT OF NON-MILITARY SERVICE Rachel Kay Nace, being duly sworn according to Law, deposes and says that Plaintiff knows by Plaintiff's own personal knowledge and therefore avers that the defendant, Charles Edward Nace, III, is 22 years of age and that Defendant is not in the military service of the United States or its allies, or otherwis'B within the provision of the Soldier's and Sailor's Civil Relief Act of Congress 1940 and its amendments and that the defendant is employed by Triangle Fire Protection. Date: r/;q Jo Lf . , subscribed before me this the ~.f1aay of o ~-~t/.~~ ') - Nota Public CCIMMONWEALTH OF PENNSYLVANIA [Notarial Seal Sherry L. Potteiger, Notary Public Middlesex Twp" Cumberland County My Commission Expires Nov, 22, 2007 Member. Pennsylvania Association Of Notaries '"'" = = .;:- <- c:'~ \..0 c; ::::\ -~ o 'T1 -.:; ~...., rnr: :?J9 C.:'ICi :::t'~ :~-; :~:=;;f?\ ~~~'-\ ):;;. :.-<::. x:: - o RACHEL KAY NACE : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V, CHARLES E. NACE III : NO. 2004-1176 CIVIL TERlVl ORDER OF COURT AND NOW, this 22ND day of NOVEMBER, 2004, it appearing to the Court that Defendant's Affidavit of Consent and Waiver of Notice were not filed within thirty (30) days oftheir execution as required by Pa. Rule of Civil Procedure 1920.42 (b)(2), the request for the entry of a Divorce Decree is denied without prejudice. C- Edward E. Guido, J. Rachel Kay Nace 21 0 West Allen Street, Apt 1 Mechanicsburg, Pa. 17055 Charles E. Nace, III 4800 Charles Road, Unit L Mechanicsburg, Pa, 17055 - /I_:J.3-U'f ~A-l4 .4n~..et.. ~ :sld VlNV/YVSMHd AlNno:\ ('1~<v"-!3'3~~n~ I t :2 Wd 22 AON flOOZ AlN1CNOHlOCid 3Hl:lO 381::H0-<J31Ij '" r RACHEL KAY NACE v, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHARLES E, Nl\CE III NO, 2004,1176 CIVIL TERM ORDER OF COURT AND NOW, this 22ND day of NOVEMBER, 2004, it appearing to the Court that Defendant's Affidavit of Consent and Waiver of Notice were nof filed wifhin thirty (30) . . - EDWARD E, GUIDO JUDGE ONE COURTHOUSE SQUARE CARLISLE, PENNSYLVANIA 17013-3387 U. . POSTAGE ! I~ ~lj . I Rachel Kay Nace 21 0 West Allen Street, Apt. 1 Mechanicsburn ~~--m~ ~~~~ICIENT ADDRESS ~. .. , , O TTEMPTED NOT KNOWN 0 OTHER . C NO SUCH NUMBER/ STREET SO NOT DELIVERABLE AS ADDRESSED ,'." , UNABLE TO FORWARD ~ -:: .-.:- :-....'- ? li :-: ; :-: .. " ,_, ::>';( .:...,t::,-.: =-.':_> w~,"'';_::;.--;,. 1. ~I-, .\.'_'~ ''';'_'...~'.J 1",111",111"""/11,11,,,11,,,11,,,1,1,,11,1,1,,/,1,,1,1,,/ IN THE COURT OF COMMON PLEAS OF THE JUDICIAL DISTRICT OF PENNSYLVANIA COUNTY CUMBERLAND Rachel Kay Nace, Plaintiff 210 West Allen St., Apt. 1 Mechanicsburg, Pennsylvania 17055 181-62-3850 Charles Edward Nace, III, Defendant 4800 Charles Road, Unit L Mechanicsburg, Pennsylvania 17050 196-60-2994 s s s s s s s s s CIVIL ACTION - LAW TERM CASE NO. (XI- /1 Tic DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on the /7 day of .4J'~ , Z='l" 2. The marriage between the parties hereto is irretrievably broken. Ninety days have elapsed since the filing of the Complaint. 3. I am aware that marriage counseling is available and do not desire said counseling. 4. I state that I have read copies of the Complaint for Divorce Under Section 3301 (c) of the Divorce Code, and I understand said Complaint. I waive any pleading periods and notices there may be. 5. I hereby enter my consent to the entry of a final decree of divorce. 6. I understand that I may lose rights concerning alimony, division of property, I. lawyer's fees or expenses if I do not daim them before a divorce is granted. 7. 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. iC.S. Section 4904 relating to unsworn falsification to authorities. iDated: ~~r d~/~zzL Charles Edward Nace, III, Defendant ., i. , ]_:, (') r- ....> "'~ C? U"> C) -'1 ::;:1 ~< \.C .....,-j N \1 $0"' IN THE COURT OF COMMON PLEAS OF THE JUDICIAL DISTRICT OF PENNSYLVANIA COUNTY CUMBERLAND Rachel Kay Nace, Plaintiff 210 West Allen St., Apt. 1 Mechanicsburg, Pennsylvania 17055 181-62-3850 ~ ~ ~ ~ ~ ~ ~ ~ ~ CIVIL ACTION - LAW TERM CASE NO. O,-!. II 7(,.> Charles Edward Nace, III, Defendant 4800 Charles Road, Unit L Mechanicsburg, Pennsylvania17050 196-60,2994 IN DIVORCE AFFIDAVIT OF CONSENT 1. A com~int in Divorce under 3301 (c) of the Divorce Code was filed on 30'a C:7y . 2. The marriage of the plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and the service of the complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are true and correct. I understand that false statements contained herein are made subject to penalties of 18 Pa. C.S. 94904, ~~ii~~ to un~~~cation to authoritie~~ ~~.or- , Charles Edward Nace, III WAIVER OF NOTICE TO INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 93301 (c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without any 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. 94904 relating to unsworn falsification to authorities. ??~- Dated: ~ ?:;:7/~ .ffl' Charles Edward Nace, III ~-; C) r,,-':';::, -'I <;:.11 \..u {''.l .r.-" IN THE COURT OF COMMON PlEAS OF THE JUDICIAL DISTRICT OF PENNSYLVANIA COUNTY CUMBERLAND Rachel Kay Nace, Plaintiff 210 West Allen St., Apt. I Mechanicsburg, Pennsylvania 17055 717-648-2322 9 9 9 9 9 9 9 CIVIL ACTION - LAW TERM vs. Charles Edward Nace, III, Defendant 4800 Charles Road, Unit L Mechanicsburg, Pennsylvania 17050 717-648-2303 CASE NO. ()tf ~ !f7C1 MARITAL SETTLEMENT AGREEMENT THIS AGREEMENT made and entered into this the _ day of , between Rachel Kay Nace, residing at 210 West Allen St., Apt. I, Mechanicsburg, Pennsylvania 17055 and Charles Edward Nace, III, residing at 4800 Charles Road, Unit 1, Mechanicsburg, Pennsylvania 17050. WHEREAS we were married to each other at on June 27,2002 and lived as husband and wife until such time as we separated on May 18, 2003 and have remained in a bona fide state of separation since that time; WHEREAS there are the following unmarried child under the age of eighteen years born to or adopted by the parties; and for pmposes of this Agreement, "Child" shall include each child, whether one or more, who is a subject of this suit while that child is under the age of eighteen years and not otherwise emancipated. The following child under the age of eighteen years old was born to or adopted by the parties of the marriage: Name Age Birthdate Social Security No. 203-804947 Kaylee Lynn Nace o January 27,2003 WHEREAS a permanent breakdown of the marriage has arisen between us and we are now living separate and apart from each other; and WHEREAS we now intend, by this agreement, to make a final and complete settlement of all of our of our rights and obligations concerning division of property, spousal support, and employee retirement benefits; and WHEREAS in consideration of the premises and mutual promises and undertakings herein contained, and for other good and valuable consideration, the parties agree to the following: 1. THE PARTIES AGREE to live separate and apart from the other party, with the intention thereafter never again to resume the marital relationship, free from any control, restraint or interference, direct of indirect with the other party, and in all respects to live as if he or she were sole and unmarried. MUTUAL RELEASE: Wife and Husband from this date and at all time hereafter may purchase, acquire, own, hold, possess, encumber, dispose of and convey all classes and kinds of property both real and personal as though unmarried and free from the consent, joinder and interference of the other party, it being the understanding and agreement on the part of each of the parties hereto that in the sale, transfer and conveyance of any property hereafter, real or personal, it shall not be necessary in order for the grantee to have good title, that the other party hereto shall sign and execute to the grantee the deed, conveyance, deed of trust, mortgage or bill of sale conveying or selling the property; it being the agreement and covenant of the parties hereto that each has forever released and discharged the property of the other from all claims, interest and estate on his or her part, and that each shall be in the same position as if such party were single or unmarried. II. DIVISION OF PROPERTY: We agree to divide the property of our marital estate as follows: I. Rachel Kay Nace Transfers to Charles Edward Nace, III as sole and separate property, and Rachel Kay Nace is divested of all right, title, and interest in and to the following property: Household Furniture, etc. All household furniture, furnishings, fIxtures, goods, appliances, and equipment in the possession of or subject to the control of Charles Edward Nace, III. Clothing, etc. All clothing, jewelry, and other personal effects in the possession of or subject to the control of Charles Edward Nace, III. Cash. All cash in the possession of or subject to the sole control of Charles Edward Nace, III. Checking Accounts. All checking accounts at all banks or other fInancial institutions which stand in the sole name of Charles Edward Nace, III or from which Charles Edward Nace, III has the sole right to withdraw funds. 2. Charles Edward Nace, III Transfers to Rachel Kay Nace as sole and separate property and Charles Edward Nace, III is divested of all right, title, and interest in and to the following property: Household Furniture, etc. All household furniture, furnishings, fixtures, goods, appliances, and equipment in the possession of or subject to the sole control of Rachel Kay Nace. Clothing, etc. All clothing, jewelry, and other personal effects in the possession of or subject to the sole control ofRacbel Kay Nace. Cash. All cash in the possession of or subject to the sole control of Rachel Kay Nace. Checking Accounts. All checking accounts at all banks or other financial institutions which stand in Rachel Kay Nace's sole name or from which Rachel Kay Nace has the sole right to withdraw funds. DEBTS TO BE PAID BY Charles Edward Nace, III Charles Edward Nace, III shaD pay, as a part of the division of the estate of the parties, the following and shall indemnify and hold Rachel Kay Nace and Rachel Kay Nace's property harmless from any failure to so discharge these items: Any and all debts, charges, liabilities, and other obligations incurred solely by Charles Edward Nace, III from and after the parties date of separation unless express provision is made in this agreement to the control)'. All debt associated with any property awarded to Charles Edward Nace, III DEBTS TO BE PAID BY Rachel Kay Nace Rachel Kay Nace shaD pay, as a part of the division of the estate of the parties, the following and shall indemnify and hold Charles Edward Nace, III and Charles Edward Nace, IIrs property harmless from any failure to so discharge these items: Any and all debts, charges, liabilities, and other obligations incurred solely by Rachel Kay Nace from and after the parties' date of separation unless express provision is made in this agreement to the contrary. All debt associated with any property awarded to Rachel Kay Nace. III NOTICE Each party shall send to the other party, within three days of its receipt, a copy of any correspondence from creditor or taxing authority concerning any potential liability of the other party. IV. ALIMONY - MAINTENANCE: Both parties agree to waive any rights or claims that either may now have or in the future to receive alimony, maintenance, or spousal support from each other. Both parties understand the full import of this provision. V. NECESSARY DOCUMENTS: THE PARTIES AGREE TO EXECUTE AND DEliVER TO the other party any documents that may be reasonably required to accomplish the intention of this instrument and shall do all other necessal)' things to this end. VI. SUBSEQUENT DISSOLUTION OF MARRIAGE: It is agreed that this Agreement may be offered into evidence by either party in any dissolution of marriage proceeding, and if acceptable to the Court, this Agreement shall be incorporated by reference in any Final Judgment that may be rendered. However, notwithstanding incorporation in the Final Judgment, this Agreement shall not be merged in but shall survive the Final Judgement and be binding on the parties for all times. VII. PARENTING PLAN: JOINT LEGAL CUSTODY WITH PRIMARY PHYSICAL CUSTODY: Husband and Wife shaD each share jointly the legal cusrody and care of our minor children with Husband to have the primary physical custody of the children. Our parenting relationship shall be guided by the following terms and conditions: Both parents shaD have aD the rights and dnties of a parent at all times, including: the right to receive information from the other parent concerning the health, education and welfare of the child(ren); to confer with the other parent to the extent possible before making decisions concerning the health, education and welfare of the child(ren); of access to medical, dental, psychological and educational records of the child(ren); to consult with a physician, dentist or psychologist of the child(ren); the right to consult with school officials concerning the child(ren)'s welfare and educational status, including school activities; the right to attend school activities; the right to be designated on any records as a person to be notified in case of an emergency; and the right to manage the estate of the child to the extent the estate has been created by the parent or the parent's family. Both Parents shall confer with each other on all important matters concerning the health, education and welfare of the children. If matters arise that they are unable to agree upon, the issue shall be submitted to a professional for dispute resolution or arbitration. Both will encourage a positive relationship between the children and the other parent. Both Parents shall share jointly the following rights, duties, privileges, and powers at all timn; including; to direct the moral and religious training of the child(ren) during periods of possession; the duty of care, control, protection and reasonable discipline of the child(ren), including providing the child(ren) with clothing, food, shelter, and medical and dental care not involving an invasive procedure; and the power to consent to medical, dental and surgical treatment dwing an emergency involving an immediate danger to the health and safety of the child(ren). Husband shall be the primary custodial parent and shaD have sole right to establish the primary residence ofthe children, and further shall have the following exclusive rights and duties to: the power to consent to the marriage, to medical, dental, and surgical treatment involving invasive procedures, and to psychiatric and psychological treatment; the power to represent the child(ren) in legal action and make other decisions of substantial legal significance concerning the child(ren), except when a guardian of the child's estate or a guardian or attorney ad litem has been appointed for the child(ren), a power as an agent of the child(ren) to act in relations to the child's estate if the child(ren)'s action is required by a state, the United States, or a foreign government. Rachel Kay Nace, as the non-custodial parent, shall have the right to physical possession of the children, AT AI,L TIMES MUTUALLY AGREED upon by the parties and failing agreement, at such specific times and places as are set forth in the attached Schedule for Possession of Minor Children which is incorporated herein for all purposes by this reference. The non-custodial parent shall not interfere with the Custody of the child(ren) and shall return the child(ren) to the care of the primary custodial parent immediately upon the tennination of each period of possession to which the non-<:ustodial parent is entitled under the tenns of this agreement. The primary custodial parent shall surrender the child(ren) to the non-custodial parent at the beginning of each period of possession. AGREED CHILD SUPPORT: The basis of the agreed support for the benefit of our children established by this agreement is based on the following facts; We make this agreement freely without coercion, threat or duress. We declare that this agreement is in the best interest of our child(ren) and that the needs ofthe children will be adequately met by the agreed amount. We are fully informed of our rights concerning child support and of the guidelines for establishing child support put forth by the state and presumed to be in the best interest of the child(ren). The right to support has not been assigned to the office of the Attorney general in consideration for the receipt of payments from the state for the support of the children and no public assistance application is pending, As for child support: The parties are capable of supporting their minor child(ren) and neither parent shall pay child support to the other parent. MEDICAL HEALTH INSURANCE: For the term of the child support obligation for each child, husband/father shall cany and maintain medical health insurance for the benefit of said child(ren). The reasonable health care costs not covered by any policy of health insurance shall be paid as follows; Obligor shall pay _% and Obligee shall pay _ %. DEPENDENT CHILD EXEMPTION: Husband shall have the right to claim the dependency exemption for the child(ren). VII, AGREEMENT DESIGNED TO FACILITATE A DIVORCE OR DISSOLUTION OF THE PARTIES' MARRIAGE: This Agreement is entered into with the express intent to facilitate encourage, aid, and in any other manner lead to a divorce and or dissolution of the marriage between the parties hereto. VIII, SUBSEQUENT DISSOLUTION OF MARRIAGE: RespondentJDefendant herein, acknowledges receipt of a copy of the documents to be filed herein with this agreement of the parties attached as Exhibit "A", and states that he/she has read and understands the same. It is agreed that this Agreement shall be offered into evidence by either party in any dissolution of marriage proceeding, and if acceptable to the Court, this Agreement shall be incorporated by reference in any Final Judgment that may be rendered, and the parties shall be ordered to comply with all its provisions, and all warranties and remedies provided in this agreement shall be preserved. However, notwithstanding incorporation in the Final Judgment, this Agreement shall not be merged in but shall survive the Final Judgement and be binding on the parties for all times. IX. REPRESENTATION: The parties represent to each other: (a) Each had the right to independent counsel. Each party fully understands their legal rights and each is signing this Agreement freely and voluntarily, intending to be bound by it. (b) Each has made a full disclosure to the other of his or her current financial condition. (c) Each understands and agrees that this Agreement is intended to be the full and entire contract of the parties. (d) Each agrees that this Agreement and each provision of it is expressly made binding upon the heirs, assigns, executors, administrators, successors in interest and representatives of each party. X. WAIVER OF BREACH: No waiver of any breach by any party of the terms of this Agreement shall be deemed a waiver of any subsequent breach. XI, ENFORCEMENT OF THE AGREEMENT: Both parties agree that the Court granting the divorce, at the request of either party, insert in the Final Judgment a reservation of jurisdiction fur the purpose of compelling either party to perform this Agreement, or any part thereof. The prevailing party shall be entitled to attorney's fees in connection with such proceeding. XII. GOVERNING LAW: This Agreement shall be interpreted and governed by the laws of the State of Pennsylvania. SCHEDULE FOR POSSESSION OF MINOR CHILDREN A. MUTUAL AGREEMENT: The parents may have possession of the children at any and all times mutually agreed to in advance, and in the absence of mutual agreement, shall have possession of the children under the specified terms set out below. B. GENERAL TERMS AND CONDmONS: I. The PRIMARY CUSTODIAL PARENT, Charles Edward Nace, III, (hereafter CP) is ordered to surrender the minor child(ren) to the NON-CUSTODIAL PARENT, Rachel Kay Nace, (hereafter NCP) at the beginning of each period of the NCP's possession at the residence of the CP; and Charles Edward Nace, ill, (hereafter CP) is ordered to surrender the minor child(ren)to the NON-CUSTODIAL PARENT, Rachel Kay Nace, (hereafter NCP) at the beginning of each period of the NCP's possession at the residence of the CP . 2. If the NCP elects to begin a period of possession at the time the children's school is regularly dismissed, the CP is ORDERED to surrender the children to the NCP at the beginning of each such period of possession at the school in which the children are enrolled 3. The NCP is hereby ORDERED to return the children to the residence of the CP at the end of each period of possession; 4. Each Parent is ORDERED to return with the children the personal effects that the child brought at the beginning of the period of possession. 5. Each parent may designate any competent adult to pick up and return the children, as applicable, and a parent or designated competent adult is ordered to be present when the children is picked up or returned. 6. A parent shall give notice to the person in possession of the children on each occasion that the parent will be unable to exercise the parent's right to possession for any specified period. Repeated fuilure of a parent to give notice of an inability to exercise possessory rights may be considered as a factor in a modification of those possessory rights. 7. Written notice shall be deemed to have been timely made if received or pOSbnarked before or at the time that notice is due. 8. If a Parent's time of possession of a children ends at the time school resumes and for any reason the children will not be returned to school, the Parent in possession of the children shall immediately notify the school and the other Parent that the children will not or has not been returned to school. 9. Each party is ORDERED to give written notice of change ofaddress to the other party, stating the intended date of change and the address of new residence, and it shall be given at least sixty (60) days before the intended change or on the first day the party knows or should know of the change, whichever occurs first. 10. School means the primary or secondary school in which the child is enrolled, or if the child is not enrolled in primary or secondary school, the public school district in which the children resides. C. REGULAR WEEKLY SCHEDULE: I. When the NCP resides less than 100 miles from the primary residence of the children, the NCP shall have the right to possession of the children as follows: On weekends beginning at 6 PM on the first, third, and fifth Friday of each month and ending at 6PM on the following Sunday. 2. When the NCP resides more than 100 miles from the residence of the children, the NCP shall have possession of the children as follows: a) Either regular weekend possession on the first, third and fifth Friday of each month as provided under Subsection C and D. However, the NCP may choose an alternative schedule ONLY IF the NCP gives written notice to the CP within 90 days after the parties begin to reside more than 100 miles apart. In that case the NCP shall have possession as follows: One weekend per month of the NCP's choice beginning at 6PM on the day school recesses for the weekend and ending at 6PM on the day before school resumes after that weekend. PROVIDED mAT the NCP gives the CP seven days written or telephone notice preceding a designated weekend, and FURTHER PROVIDED THAT the weekend possession does not interfere with the vacation and holiday possession ofCP in Section E below. D. WEEKENDS EXTENDED BY HOLIDAY: If a weekend period of possession ofthe NCP coincides with a school holiday during the regular school term, or with a federal state or local holiday during the summer months when school is not in session the weekend possession shall end at 6PM on a Monday holiday or school holiday, as applicable. E. VACATIONS AND HOLIDAYS: The following periods of possession supersedes any conflicting weekend or Wednesday period of possession provided by subsections C and D above. The parents shall have rights of possession of the children as follows: I. CHRISTMAS: The NCP shall have possession of the children in odd numbered years beginning at 6PM on the day the children is dismissed from school for Christmas school vacation and ending at noon on December 26, and the CP shall have possession of the same period in even numbered years. 2. CHRISTMAS: The NCP shall have possession of the children in even numbered years beginning at noon on December 26th and ending at 6PM on the day before school resumes after that vacation, and the CP shall have possession of the same period in odd numbered years. 3. THANKSGIVING: The NCP shall have possession of the children in odd numbered years beginning at 6PM on the day the children is dismissed from school for Thanksgiving and ending at 6PM on the following Sunday, and the CP shall have possession of the children for the same period in even numbered years. 4. SPRING VACATION: The NCP shall have possession of the children in even numbered years beginning at 6PM on the day the children is dismissed from school for the school's spring vacation and ending at 6PM on the day before school resumes after that vacation, and the CP shall have possession of the same period in odd numbered years. When the NCP resides more than 100 miles from the residence of the children, the CP shall have possession of the children every year beginning at 6PM on the day before school resumes after that vacation. 5. SUMMER POSSESSION: If the NCP: a) gives the CP written notice by May I of each year specifYing an extended period or periods of summer possession, the NCP shall have possession of the children for 30 days beginning no earlier than the day after the children's school is dismissed for the summer vacation and ending no later than seven days prior to school resuming at the end of the summer vacation, to be exercised in no more than two separate periods of at least seven consecutive days each; or b) does not give the CP such notice, the NCP shall have possession of 30 consecutive days beginning at 6PM on July I and ending at 6PM on July 31. 6. LONG DISTANCE SUMMER POSSESSION: When the NCP resides more than 100 miles from the residence of the children, if the NCP: a)gives the CP written notice by May I of each year specifYing an extended period or periods of summer possession, the NCP shall have possession of the children for 42 days beginning no earlier than the day after the children's school is dismissed from the summer vacation and ending no later than seven days prior to school resuming at the end of the summer vacation, to be exercised in no more than two separate periods of at least seven consecutive days each; or b) does not give the CP such notice, the NCP shall have possession of the children for 42 consecutive days beginning at 6PM on June 15 and ending at 6PM on July 27. 7, If the CP gives the NCP written notice by June I, the CP shall have possession of the children on anyone weekend beginning Friday at 6PM and ending Sunday at 6PM during anyone period of possession of the NCP in sections 5 and 6 above, PROVIDED THAT the CP picks up the children from the NCP and returns the children to the same place. 8. a) EXEMPTION, if the CP gives the NCP written notice by May 15 of each year or gives the NCP 14 days written notice on or after May 16, the CP may designate one weekend beginning no earlier than the day after the children's school is dismissed for the summer vacation and ending no later than seven days prior to school resuming at the end of the summer vacation, during which an otherwise scheduled weekend period of possession by NCP will not take place PROVIDED THAT the weekend does not interfere with the NCP's summer possession as defined in sections 5 and 6 or with Father's Day if the NCP is the father of the children. b) LONG DISTANCE EXEMPTION: When the NCP resides more than 100 miles from the residence of the children, if the CP gives the NCP written notice by June I of each year the CP shall have possession of the children on anyone weekend beginning Friday at 6PM and ending the following Sunday at 6PM during anyone period of possession of the NCP under section 6 PROVIDED THAT the CP picks up the children from the NCP and returns the children to that same place and FURTHER PROVIDED that if the NCP shall have possession of the children for more than 30 days the CP shall have possession on any two non-consecutive weekends. c) CP'S DESIGNATION, When the NCP resides more than 100 miles from the residence of the children, if the CP gives the NCP written notice by May 15 of each year or gives the NCP 30 days written notice on or after May 16 of each year, the CP may designate 21 days beginning no earlier than the day after the children's school is dismissed for the summer vacation and ending no later than seven days prior to school resuming at the end of the summer vacation, to be exercised in no more than two separate periods of at least seven consecutive days each, during which the NCP shall not have possession of the children, PROVIDED THAT the designated time period does not interfere with the NCP's summer possession as defined in section 5 and 6 or with Father's day if the NCP is the father of the children. 9. Children'S BIRTHDAY: The parent not otherwise entitled under this standard order to present possession ofa children on the children's birthday shall have possession of the children beginning at 6PM and ending at 8PM PROVIDED THAT said parent pick up the children from the residence of the Parent entitled to possession and return the children to that same place. 10. FATHER'S DAY: If the Parent, the father shall have possession of the children beginning at 6PM on the Friday preceding Father's Day and ending at 6PM on Father's Day, provided that, ifhe is not otherwise entitled under this standard order to present possession of the children he picks up the children from the residence of the Parent entitled to possession and returns the children to that same place. II. MOTHER'S DAY: If a Parent, the mother shall have possession ofthe children beginning at 6PM on the Friday preceding Mother's Day and ending at 6PM on Mother's Day provided that if she is not otherwise entitled under this standard order to present possession of the children, she picks up the children from the residence of the Parent entitled to possession and returns the children to that same place. WEEKLY VISITATION SCHEDULE FOR Children UNDER THE AGE OF THREE YEARS AT ALL TIMES MUTUALLY AGREED UPON BY THE PARTIES and failing agreement, the non- custodial Parent shall have possession of the minor children under the age of three years as follows: I, Each Monday from 3PM until 6PM or from 6PM until 8PM 2. Each Wednesday from, 3PM until6PM or from 6PM until 8PM 3. Each Friday from 3PM until 6PM or from 6PM until 8PM 4. Each Saturday from 3PM untill2PM the following Sunday or Each Saturday from 9AM until 7PM, 5. Each year on the children's birthday from IPM until3PM or from 6PM unti18PM. 6. Holidays: CHRISTMAS: in even numbered years, the NCP shall have possession of the children from 9AM until 7PM on December 25th, and in odd numbered years the NCP shall have possession of the children from 9AM until 7PM on December 24th. THANKSGIVING: in odd numbered years, the NCP shall have possession of the children from 9AM until ?PM on Thanksgiving Day. XIII. WAIVER OF SERVICE OF PROCESS AND FILING AN ANSWER: Defendant herein, acknowledges receipt of a copy of the documents to be filed herein, and states that he/she has read and understands the same, hereby waives the issuance, service, and return of process upon himlher in this action enters a voluntary appearance in this cause, waiving all time and right to plead, answer or appear in this action, and consents that the same may be set down for trial and heard by the court at any time hereafter without notice to, and in the absence of, this Defendant. XIV. WAIVER OF EMPLOYEE AND/OR MILITARY RETAINER OR RETIREMENT BENEFITS: Both parties agree to waive any rights, interests, or claims, that either may now have or in the future to receive employee and/or military retainer or retirement benefits resulting from the past, present or future employment and/or selVice of the other party in the Armed Forces of the United States. Both parties understand the full import of this provision. XV. CHANGE OF NAME: The parties agree that the Wife may have her name changed or restored to Rachel Kav Weikert. SIGNED ON THIS THE I,,""dayof ,/I/_~r ,ZOO~ STATE OF Permsylvania ~ COUNTY OF Cumberland ~ss. Before me, the undersigned, a Notary Public, on this / (Jf1-.day of iJ~ d{i)l(. personally appeared the above named Defendant, Charles Edward Nace, III, to me known to be the identical person who executed the above and foregoing Marital Settlement Agreement and personally acknowledged to me that he/she read, understood and signed the same; and that he/she executed the same as hislher free and voluntary act and deed for the uses and purposes therein set forth. IN WITNESS WHEREOF, I have hereunto affixed my signature and official seal the day and date heretofore stated. ~L"~~ Charles Edward Nace, III, Defendant My Co~ssion expires: 1/7:J/07 I / ~eA,if2'-,~ ' Not blic l,;UMMUNWEAL TH OF PENNSYLVANIA Notarial Seal Sheny L Potteiger, NoIary Public Mddlesex Twp,. Cumber1and County My Commission Expires Nov. 22, 2007 Mt"!mber. Pennsylvania AssociatIon Of Notaries SIGNED ON TillS THE JJ2... day of 1Jf7lI~ 'Z&fJ t.f . ~~~~tiff STATE OF Pennsylvania * COUNTY OF Cumberland *ss. Before me, the undersigned, a Notary Public on this / ~y Ofi/tJI~, Jf):Jy. personally appeared the above named PetitionerlPlaintiff, Rachel Kay Nace, to me known to be the identical person who executed the above and foregoing Marital Settlement Agreement and personally acknowledged to me that he/she read, understood and signed the same; and that he/she executed the same as his/her free and voluntary act and deed for the uses and purposes therein set forth. IN WITNESS WHEREOF, I have hereunto affixed my signature and official seal the day and date heretofore stated. My commission expires: 1/ P:l~7 ~c;l~ijJ~ Notary Public COMMONWEALTH OF PENNSYLV IA _I Seal Sheny L Potteiger, NoIary Public MddIesex Twp" Cumberland County My Commissioo Expires Nov. 22, 2007 Member. Pennsvlvania Association Of Notartes IN THE COURT OF COMMON PLEAS OF THE JUDICIAL DISTRICT OF PENNSYLVANIA COUNTY CUMBERLAND Rachel Kay Nace, Plaintiff 210 West Allen St., Apt. 1 Mechanicsburg, Pennsylvania 17055 181-62-3850 Charles Edward Nace, III, Defendant 4800 Charles Road, Unit L Mechanicsburg, Pennsylvania17050 196-60-2994 ~ ~ ~ ~ ~ ~ ~ ~ ~ CIVIL ACTION - LAW ell/'; / TERM CASE NO. f) Lf _ /1 7 (, IN DIVORCE ACCEPTANCE OF SERVICE I, Charles Edward Nace, III, am the Defendant in the above entitled case and I do hereby accept service of the Complaint in Divorce filed in the above-captioned matter. 3? 8"~-'r Date ~?~~ Charles Edward Nace, III, defendant (_.... f"-.) "il ;-1, '_J-' r; C. IN THE COURT OF COMMON PLEAS OF THE JUDICIAL DISTRICT OF PENNSYLVANIA COUNTY CUMBERLAND Rachel Kay Nace, Plaintiff 210 West Allen St., Apt. 1 Mechanicsburg, Pennsylvania 17055 181-62-3850 !l !l !l !l !l !l !l !l !l CIVIL ACTION - LAW TERM CASE NO. () Lf - /17 ~ Charles Edward Nace, III, Defendant 4800 Charles Road, Unit L Mechanicsburg, Pennsylvania17050 196-60-2994 IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in Divorce under 3301 (c) of the Divorce Code was filed on 2. The marriage of the plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and the service of the complaint. 3, I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are true and correct. I understand that false statements contained herein are made subject to penalties of 18 Pa. C.S. !}4904, relating to uns oJll als' lcation to authorities. ~ eIr..d ~ ){jjn DATE: /1 /0 () ()jj ~ Ra I Kay Nace WAIVER OF NOTICE TO 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 any notice. 2. I understand that I may lose rights conceming 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. !l4904 relating to unsworn f Isification to authorities. .a _ Dated: I( IVl..I:1 IiL{% N(/!b '" L_. r~':- IN THE COURT OF COMMON PLEAS OF THE JUDICIAL DISTRICT OF PENNSYLVANIA COUNTY CUMBERLAND Rachel Kay N ace, Plaintiff 2 lOWest AlIen St., Apt, I Mechanicsburg, Pennsylvania 17055 717,648-2322 ~ ~ ~ ~ ~ ~ ~ CIVIL ACTION - LAW TERM vs, Charles Edward Nace, Ill, Defendant 4800 Charles Road, Unit L Mechanicsburg, Pennsylvania 17050 717,648,2303 CASE NO, U'-l ~ (I1tf INCOME AND EXPENSE STATEMENT OF Rachel Kay Naco, PLAINTIFF Plaintiff files the following Income and Expense Statement setting forth his/her income and expenses as of the date set forth below. Plaintiff verifies that the statements made in the Income and Expense Statement are true and correct. Plaintiff understands that false statements herein 3Te subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Dated:~ I %1 by JZWuJK~OU , Rachel Kay Nace DATE: INCOME AND EXPENSE STATEMENT OF Rachel Kay Nace, PLAINTIFF NAME: Rachel Kay Nace Rachel Kay Nace VS, Charles Edward Nace, III INCOME: Employer: Holy Spirit Hospital Address: 502 N 21st St, Camp Hil~ PA 1701 I Type of Work: Secretary Payroll No.: Social Security No,: 181-62,3850 Gross pay per pay period: $ Pay period 0 weekly 0 biweekly o monthly ITEMIZED PAYROLL DEDUCTIONS: Federal Withholding $ Local Wage Tax $ Retirement $ Credit Union $ Health Insurance $ Social Security $ Savings $ Stale Inc. Tax $ Life Insurance $ Other $ $ $ NET PAY per pay period: $ DATE: INCOME AND EXPENSE STATEMENT OF Rachel Kay N ace, PLAINTIFF NAME: Rachel Kay Nace Rachel Kay Nace VS, Charles Edward Nace, III OTHER INCOME Weekly Monthly Yearly Interest $ $ $ Dividends $ $ $ Pension $ $ $ Annuity $ $ $ Rents $ $ $ Royalties $ $ $ Social Security $ $ $ Expense Account $ $ $ Gifts $ $ $ Unemployment $ $ $ Workers' Compensation $ $ $ Other $ $ $ Other $ $ $ Total All Income: $ Per 0 Week o Month o Year DATE: INCOME AND EXPENSE STATEMENT OF Rachel Kay Nace, PLAINTIFF NAME: RachcI Kay Nacc Rachel Kay Nace VS, Charles Edward Nace, III PROPERTY OWNED Description Value Husband Wire Child Checking Account $ 0 0 0 Savings Account $ 0 0 0 Credit Union $ 0 0 0 Stocks/Bonds $ 0 0 0 Real Estate $ 0 0 0 Automobile $ 0 0 0 Other $ 0 0 0 INSURANCE Company Policy # Husband Wire Child Hospitalization # 0 0 0 Medical # 0 0 0 Health/Accident # 0 0 0 Disa biIity # 0 0 0 Dental # 0 0 0 DATE: INCOME AND EXPENSE STATEMENT OF Rachel Kay Nace, PLAINTIFF NAME: Rachel Kay Nace Rachel Kay Nace VS, Charles Edward Nace, III EXPENSES ALLOCATIONS HOME WeekIy Monthly Yearly Self Children Mortgage $ $ $ $ $ Rent $ $ $ $ $ Maintenance $ $ $ $ $ Gas $ $ $ $ $ Electric $ $ $ $ $ Telephone $ $ $ $ $ Water $ $ $ $ $ Sewer $ $ $ $ $ EMPLOYMENT Weekly Monthly Yearly Self Children Transportation $ $ $ $ -- $ Lunch $ $ $ $ $ Maintenance $ $ $ $ $ DATE: INCOME AND EXPENSE STATEMENT OF Rachel Kay Nace, PLAINTIFF NAME: Rachel Kay Nace Rachel Kay Nace VS. Charles Edward Nace. III EXPENSES ALLOCATIONS TAXES Weekly Monthly Yearly Self Chiklren Real Estate $ $ $ $ $ Personal Property $ $ $ $ $ Income $ $ $ $ $ INSURANCE Weekly Monthly Yearly Self Children Homeowners $ $ $ $ $ Auto $ $ $ $ $ Life $ $ $ $ $ Accident $ $ $ $ $ Other $ $ $ $ $ CAR Weekly Monthly Yearly Self Children Payments $ $ $ $ $ Fuel/Oil $ $ $ $ $ Repairs $ $ $ $ $ MEDICAL Weekly Monthly Yearly Self Children Doctor $ $ $ $ $ Dental $ $ $ $ $ Hospital $ $ $ $ $ Medicine $ $ $ $ $ Special $ $ $ $ $ DATE: INCOME AND EXPENSE STATEMENT OF Rachel Kay Nace, PLAINTIFF NAME: Rachel Kay Nace Rachel Kay Nace VS. Charles Edward Nace, III EXPENSES ALLOCATIONS SCHOOL Private School Weekly M ontbly Yearly Self $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $ Children $ $ $ Parochial School College Religious $ PERSONAL Weekly Monthly Yearly Self Children Clothes $ $ $ $ $ Food $ $ $ $ $ Hairdresser $ $ $ $ $ Barber $ $ $ $ $ Credit Paymen t $ $ $ $ $ Credit Cards $ $ $ $ $ Charge Accounts $ $ $ $ $ Dues $ $ $ $ $ CHILD CARE Weekly Monthly Yearly Self Cbildren Daycare $ $ $ $ $ Babysitter $ $ $ $ $ Other $ $ $ $ $ DATE: INCOME AND EXPENSE STATEMENT OF Rachel Kay Nace, PLAINTIFF NAME: Rachel Kay Nace Rachel Kay Nace VS. Charles Edward Nace, III EXPENSES LOANS Credit Union Other Weekly $ $ $ $ ALLOCATIONS Monthly Yearly Self Children $ $ $ $ $ $ $ $ $ --- $ $ $ $ $ $ $ Other Other MISC. Weekly M ontbly Yearly Self Children Papers $ $ $ $ $ Magazines $ $ $ $ $ Entertainment $ $ $ $ $ Pay T,V $ $ $ -- $ $ Vacation $ $ $ $ $ Gifts $ $ $ $ $ Legal Fees $ $ $ $ $ Con tributions $ $ $ $ $ Other Child Support $ $ $ $ $ Alimony $ $ $ $ $ Other $ $ $ $ $ Other $ $ $ $ $ Other $ $ $ $ $ TOTAL EXPENSES Weekly Monthly Yearly Self Children $ $ $ $ $ DATE: INCOME AND EXPENSE STATEMENT OF Rachel Kay N ace, PLAINTIFF NAME: Rachel Kay Nace Rachel Kay Nace VS. Charles Edward Nace, III SUPPLEMENTAL INCOME STATEMENT This page must be filed out if you: I) operate a business or practice a profession, or 2) are a member of a partnership or joint venture, or 3) are a shareholder in and are salaried by a closed corporation or similar entity Attach to this statement a copy of the following documents relating to the partnership, joint venture, business, professional corporation or similar entity: I) the most recent Federal Income Tax Return, and 2) the most recent Profit and Loss Statement Name of Business : Address of Business: Telephone: Nature of Business (lone) I) 0 partnership 2) 0 joint venture 3) 0 professional 4) 0 closed corporation 5) 0 other Name ofaeeountant, controller or other person in charge of financial records: Name: Address Telephone: DATE: INCOME AND EXPENSE STATEMENT OF Rachel Kay Nace, PLAINTIFF NAME: Rachel Kay Nace Rachel Kay Nace VS. Charles Edward Nace, III SUPPLEMENTAL INCOME STATEMENT (continued) Annual income from business: $ I) How often is the income received? 2) Gross income per pay period: $ 3) Net income per pay period $ 4) Specified deductions, ifany: $ ,.-.., c (. " INVENTORY AND APPRAISEMENT COVER SHEET IN THE COURT OF COMMON PlEAS OF THE JUDICIAL DISTRICT OF PENNSYLVANIA COUNTY CUMBERLAND Rachel Kay Nace, Plaintiff 210 West Allen St., Apt. I Mechanicsburg, Pennsylvania 17055 717-648-2322 ~ ~ ~ ~ ~ ~ ~ CIVIL ACTION - LAW TERM vs. Charles Edward Nace, III, Defendant 4800 Charles Road, Unit L Mechanicsburg, Pennsylvania 17050 717-648-2303 CASE NO. (J<{ - Wllf Rachel Kay Nace files the following inventory and appraisement of all property owned or possessed by either party at the time this action was commenced and all property transferred within the preceding year. Rachel Kay Nace verifies that the statements made in this inventory and appraisement are true and correct. Rachel Kay Nace understands that false statements herein are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Dated:-Mlo L1 KMM ~ 1aLL . Rachel Kay Nace IN THE COURT OF COMMON PlEAS OF THE JUDICIAL DISTRICT OF PENNSYLVANIA COUNTY CUMBERLAND Rachel Kay Nace, Plaintiff 210 West Allen St., Apt. I Mechanicsburg, Pennsylvania 17055 717-648-2322 ~ ~ ~ ~ ~ ~ ~ CIVIL ACTION - LAW TERM vs. Charles Edward Nace, III, Defendant 4800 Charles Road, Unit L Mechanicsburg, Pennsylvania 17050 717-648-2303 CASE NO. OLl~ f(1Lf INVENTORY AND APPRAISEMENT OF Rachel Kay Nace Rachel Kay Nace files the following inventory and appraisement of all property owned or possessed by either party at the time this action was commenced and all property transferred within the preceding year. Rachel Kay Nace verifies that the statements made in this inventory and appraisement are true and correct. Rachel Kay Nace understands that false statements herein are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Dated: .J.!t kfDCf I &.cJu( /~ff YI atf~ Rachel Kay Nace Plaintiff marks on the list below those items applicable to the case at bar and itemizes the assets on the following pages. IF an item has been appraised, a copy of the appraisal report is attached. D I. Real Property D 2. Motor Vehicles D 3. Stocks, bonds, securities and options D 4. Certificates of deposit D 5. Checking accounts, cash D 6. Savings accounts; money market and savings certificates D 7. Contents of safe deposit boxes D 8. Trusts D 9. Life insurance policies (indicate face value, cash surrender value and current beneficiaries) D 10. Annuities D II. Gifts D 12. Inheritance D 13. Patents, copyrights, inventions, royalties D 14. Personal property outside the home D 15. Business (list all owners, including percentage of ownership, and officer/director positions held by a party with the company. D 16. Employment termination benefits - severance pay, workman's compensation claim/award D 17. Profit sharing plan D 18. Pension plans (indicate employee contribution and date plan vests) D 19. Retirement plans; Individual Retirement Accounts D 20. Disability payments D 21. Litigation claims (matured and unmatured) D 22. MilitaIyN.A. benefits D 23. Educational benefits D 24. Debts due, including loans, mortgages held D 25. Household furnishings and personalty (including as a total category and attach itemized list if distribution of assets is in dispute. D 26. Other MARITAL PROPERTY Plaintiff lists aU marital property in w bich either or both spouses have a legal or equitable interest individually or with any other person as of the date this action was commenced: Use a separate sheet for each property item. Item Number I. Item Number 1. Item Number 1. Item Number Description of Properly Rachel Kay Nace Names of all Owners Date of Acquisition Cost or Value as of Date of Acquisition $ Value as of Date Action Commenced Amount of Any Lien $ $ Nature of Any Lien Mortgage Effective Date of Lien Holder of Lien Reason for Exc lusion from Marital Property MARITAL PROPERTY Plaintiff Usts all marital property in which either or hoth spouses have a legal or equitable interest individually or witb any other person as of the date tbis action was commenced: Use a separate sheet for each propcrty item. Item Number 1. Item Number 1. Item Number 1. Item Number Description Names of all of Properly Owners Charles Edward Nace, 11/ Date of Acquisition Cost or Value as of Date of Acquisition $ Value as of Date Action Commenced $ $ Amount of Any Lien Nature of Any Lien Mortgage Effective Date Holder of Lien of Lien Reason for Exclusion from Marital Property MARITAL PROPERTY Plaintiff lists all marital property in which either or hoth spouses ha ve a legal or equitahle interest individually or with any other person as of the date this action was commenced: Use a separate sheet for cach property item. Item Number Item Number 1. Item Number 1. Item Number Description of Properly Names of all Owners Rachel Kay Nace Date of Acquisition Cost or Value as of Date of Acquisition $ Value as ofDate Action Commenced $ Amount of Any Lien $ Nature of Any Lien Secured Purchase Money Effective Date of Lien Holder of Lien Reason for Exclusion from Marital Property MARITAL PROPERTY Plaintiff lists all marital property in which eIther or both spouses have a legal or equitable interest individually or with any other person as of the date this action was commenced: Use a separate sheet for each property item. Item Description Names of all Date of Number of Properly Owners Acquisition 1. Item Cost or Value as of Value as of Date Amount of Number Date of Acquisition Action Commenced Any Lien 1. $ $ $ Item Number 1. Nature of Any Lien Secured Purchase Money Effective Date of Lien Holder of Lien Item Number Reason for Exclusion from Marital Property MARITAL PROPERTY Plaintiff lists all marital property in wbich eltber or botb spouses bave a legal or equitable interest individually or with any other person as of the date this action was commenced: Use a separate sheet for each property item. Item Number Description of Property Names of all Owners Date of Acquisition Item Number Cost or Value as of Date of Acquisition Value as of Date Action Commenced Amount of Any Lien Item Number Nature of Any Lien Effective Date of Lien Holder of Lien Item Number Reason for Exclusion from Marital Property PROPERTY TRANSFERRED Plaintiff lists aU marital property in which either or both spouses have a legal or equitahle interest individually or with any other person and which has been transferred within the preceding three years. Use a separate sheet for each property itcm. item Number Description of Properly Namesofall Owners Date of Acquisition Item Number Cost or Value as of Date of Acquisition Value as of Date Action Commenced Amount of Any Lien Item Number Nature of Any Lien Effective Date of Lien Holder of Lien item Number Reason for Exclusion from Marital Property LIABILITIES OF PARTIES Plaintiff marks on the list below those items applicable to the case at bar and itemizes the liabilities on tbe following page. Secured o I. Mortgages D 2. Judgements o 3. Liens o 4. Other Secured Liabilities Unsecured o 5. Credit card balances o 6. Purchases o 7. Loan Payments o 8. Notes payable o 9. Other unsecured liabilities Continllent or Deferred o 10. Contracts or agreements o II. Promissory notes o 12. Lawsuits o 13. Options o 14. Taxes o 15. Other contingent or deferred liabilities LIABILITIES Plaintiff lists all liabilities of either or both spouses alone or with any other person as of the date this action was commenced. Item Number Description of Liability Names of All Creditors Debtors Item Number Date Liability Was Incurred Amounts of Liability on Date Incurred and Date Action Commenced Item Number Date Balance is Due Periodic Payment and Amount c~ ;- ~; c. ( , -1 r<~ -' IN THE COURT OF COMMON PLEAS OF THE JUDICIAL DISTRICT OF PENNSYLVANIA COUNTY CUMBERLAND Rachel Kay N ace, Plaintiff 210 West Allen St., Apt. 1 Mechanicsburg, Pennsylvania 17055 717-648-2322 ~ ~ ~ ~ ~ ~ ~ CIVIL ACTiON - LAW TERM vs. Charles Edward Nace, U1, Defendant 4800 Charles Road, Unit L Mechanicsburg, Pennsylvania 17050 717-648-2303 CASE NO. b L{". 117Cf INCOME AND EXPENSE STATEMENT OF Charles Edward N ace, III, Defendant Defendant files the following Income and Expense Statement setting forth his/her income and expenses as of the date set forth below. Defendant verifies that the statements made in the Income and Expense Statement are true and correct. Defendant understands that false statements herein are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Dated: 3//~~ " ~2"~~ - Charles Edward N ace, 11/ DATE: INCOME AND EXPENSE STATEMENT OF Charles Edward Nace, III, DEFENDANT NAME: Charles Edward Nace, III Rachel Kay Nace VS. Charles Edward N ace, III INCOME: Employer: Triangle Fire Protection Address: Roadway Drive, Carlisle, P A 17013 Type of Work: Engineer Payroll No.: Gross pay per pay period: $ Social Security No.: 196-60-2994 Pay period 0 weekly 0 biweekly 0 monthly ITEMIZED PAYROLL DEDUCTIONS: Federal Withholding $ Local Wage Tax $ Retirement $ Credit Union $ Health Insurance $ Social Security $ Savings $ State Inc. Tax $ Life Insurance $ Other $ $ $ NET PAY per pay period: $ DATE: INCOME AND EXPENSE STATEMENT OF Charles Edward Nace, In, DEFENDANT NAME: Charlcs Edward Nacc, 11/ Rachel Kay Nacc VS. Charles Edward Nace, 11/ OTHER INCOME Weekly Monthly Yearly Interest $ $ $ Dividends $ $ $ Pension $ $ $ Annuity $ $ $ Rents $ $ $ Royalties $ $ $ Social Security $ $ $ Expense Account $ $ $ Gifts $ $ $ Unemployment $ $ $ Workers' Compensation $ $ $ Other $ $ $ Other $ $ $ Total All Income: $ Per 0 Week o Month o Year DATE: INCOME AND EXPENSE STATEMENT OF Charles Edward Nace, III, DEFENDANT NAME: Charles Edward Nace, III Rachel Kay Nace VS. Charles Edward N ace, III PROPERTY OWNED Description Value Hushand Wife Child Checking Account $ 0 0 0 Savings Account $ 0 0 0 Credit Union $ 0 0 0 Stocks/Bonds $ 0 0 0 Real Estate $ 0 0 0 Automobile $ 0 0 0 Other $ 0 0 0 INSURANCE Company Policy # Husband Wife Child Hospitalization # 0 0 0 Medical # 0 0 0 Health/Accident # 0 0 0 Disability # 0 0 0 Dental # 0 0 0 DATE: INCOME AND EXPENSE STATEMENT OF Charles Edward Naee, III, DEFENDANT NAME: Charles Edward Nace, III Rachel Kay Nace VS. Charles Edward N ace, 11/ EXPENSES ALLOCATIONS I HOME Weekly Monthly Yearly Self Children Mortgage $ $ $ $ $ Rent $ $ $ $ $ Maintenance $ $ $ $ $ Gas $ $ $ $ $ Electric $ $ $ $ $ Telephone $ $ $ $ $ Water $ $ $ $ $ Sewer $ $ $ $ $ EMPLOYMENT Weekly Monthly Yearly Self Children Transportation $ $ $ $ $ Lunch $ $ $ $ $ Maintenance $ $ $ $ $ DATE: INCOME AND EXPENSE STATEMENT OF Charles Edward Nace, nI, DEFENDANT NAME: Charles Edward Nace, III Rachel Kay Nace VS. Charles Edward Nace, III EXPENSES ALLOCA nONS TAXES Weekly M uothly Yearly Self Children Real Estate $ $ $ $ $ Personal Property $ $ $ $ $ Income $ $ $ $ $ INSURANCE Weekly Monthly Yearly Self Children Homeowners $ $ $ $ $ Auto $ $ $ $ $ Life $ $ $ $ $ Accident $ $ $ $ $ Other $ $ $ $ $ CAR Weekly Monthly Yearly Self Children Payments $ $ $ $ $ -- Fuel/Oil $ $ $ $ $ Repairs $ $ $ $ $ MEDICAL Weekly Monthly Yearly Self Children Doctor $ $ $ $ $ Dental $ $ $ $ $ Hospital $ $ $ $ $ Medicine $ $ $ $ $ Special $ $ $ $ $ DATE: INCOME AND EXPENSE STATEMENT OF Charles Edward Nace, 01, DEFENDANT NAME: Charles Edward Nace, III Rachel Kay Nace VS. Charles Edward Nace, III EXPENSES ALLOCATIONS SCHOOL Weekly Monthly Yearly Self Children Private School $ $ $ $ $ Parochial School $ $ $ $ $ College $ $ $ $ $ Religious $ $ $ $ $ PERSONAL Weekly Monthly Yearly Self Children Clothes $ $ $ $ $ Food $ $ $ $ $ Hairdresser $ $ $ $ $ Barber $ $ $ $ $ Credit Payment $ $ $ $ $ Credit Cards $ $ $ $ $ Charge Accounts $ $ $ $ $ Dues $ $ $ $ $ CHILD CARE Weekly Monthly Yearly Self Chiklren Daycare $ $ $ $ $ Babysitter $ $ $ $ $ Other $ $ $ $ $ DATE: INCOME AND EXPENSE STATEMENT OF Charles Edward Nace, III, DEFENDANT NAME: Charles Edward Nace, III Rachel Kay Nace VS. Charles Edward Nace, III EXPENSES ALLOCATIONS LOANS Weekly Monthly Yearly Self Children Credit Union $ $ $ $ $ Other $ $ $ $ $ Other $ $ $ $ $ Other $ $ $ $ $ MISC. Weekly M oothly Yearly Self Children Papers $ $ $ $ $ Magazines $ $ $ $ $ Entertainment $ $ $ $ $ Pay T.V $ $ $ $ $ Vacation $ $ $ $ $ Gifts $ $ $ $ $ Legal Fees $ $ $ $ $ Contributions $ $ $ $ $ Other Child Support $ $ $ $ $ Alimony $ $ $ $ $ Other $ $ $ $ $ Other $ $ $ $ $ Other $ $ $ $ $ TOTAL EXPENSES Weekly Monthly Yearly Self Children $ $ $ $ $ DATE: INCOME AND EXPENSE STATEMENT OF Charles Edward Nace, III, DEFENDANT NAME: Charles Edward Nace, III Rachel Kay Nace VS. Charles Edward Nace, III SUPPLEMENTAL INCOME STATEMENT This page must be filed out if you: I) operate a business or practice a profession, or 2) are a member ofa partnership or joint venture, or 3) are a shareholder in and are salaried by a closed corporation or similar entity Attach to this statement a copy of the following documents relating to the partnership, joint venture, business, professional corporation or similar entity: I) the most recent Federallncome Tax Return, and 2) the most recent Profit and Loss Statement Name of Business: Address of Business: Telephone: Nature of Business (.{ one) I) 0 partnership 2) 0 joint venture 3) 0 professional 4) 0 closed corporation 5) 0 other Name of accountant, controller or other person in charge of financial records: Name: Address Telephone: DATE: INCOME AND EXPENSE STATEMENT OF Charles Edward Nace, III, DEFENDANT NAME: Charles Edward Nace, III Rachel Kay Nace VS. Charles Edward Nace, III SUPPLEMENTAL INCOME STATEMENT (continued) Annual income :lTom business: $ I) How often is the income received? 2) Gross income per pay period: $ 3) Net income per pay period $ 4) Specified deductions, if any: $ IN THE COURT OF COMMON PLEAS OF THE JUDICIAL DISTRICT OF PENNSYLVANIA COUNTY CUMBERLAND Rachel Kay Nace, Plalntlfl 210 West Allen St., Apt. 1 Mechanicsburg. Pennsylvania 17055 181-62-3850 ~ ~ ~ ~ ~ ~ ~ ~ ~ CIVIL ACTION - LAW CASE NO_ TERM {)I./- (/111 Charles Edward Nace, III. Defendant 4800 Charles Road. Unit L Mechanicsburg. Pennsylvania17050 196-60-2994 IN DIVORCE NOTICE OF INTENT TO FILE PRAECIPE TO TRANSMIT You are hereby given notice that ten (10) days following mailing of this notice. a Praecipe to Transmit Record, together with a proposed Final Decree of Divorce, will be filed in this matter with the Appointment Clerk's Office. Room at in _________, Pennsylvania. Exact copies of the Praecipe and the proposed Final Decree in Divorce are enclosed herewith. After the praecipe and proposed Final Decree in Divorce are filed, you will have a period of ten days during which you may file objections to the entry of the Final Decree based upon this Praecipe. If you dispute any of the information on the Praecipe or Final Decree you must act within that ten-day period. Any objections must be liled in writing with the Appointment Clerk's Office, Room _' , Pennsy1vania . If no objections are filed before the expiration of the ten-day period, this case will be submitted to the Court for entry of the Final Decree. Dated: IN THE COURT OF COMMON PLEAS OF THE JUDICIAL DISTRICT OF PENNSYLVANIA COUNTY CUMBERLAND Rachel Kay Nace, Plaintiff 210 West Allen St.. Apt. 1 Mechanicsburg, Pennsylvania 17055 181-62-3850 ~ ~ ~ ~ ~ ~ ~ ~ ~ CIVIL ACTION - LAW TERM CASE NO. 01.( -111 ~ Charles Edward Nace, III. Defendant 4800 Charles Road. Unit L Mechanicsburg, Pennsylvania17050 196-60-2994 IN DIVORCE NOTICE OF INTENT TO FILE PRAECIPE TO TRANSMIT You are hereby given notice that ten (10) days following mailing of this notice. a Praecipe to Transmit Record, together with a proposed Final Decree of Divorce, will be filed in this matter with the Appointment Clerk's Office. Room at in , Pennsylvania. Exact copies of the Praecipe and the proposed Final Decree in Divorce are encbsed herewith. After the praecipe and proposed Final Decree in Divorce are filed, you will have a period of ten days during which you may file objections to the entry of the Final Decree based upon this Praecipe. If you dispute any of the information on the Praecipe or Final Decree you must act within that ten-day period. Any objections must be Iiled in wr~ing with the Appointment Clerk's Office. Room _, . Pennsylvania . If no objections are filed before the exp~ation of the ten-<lay period. this case will be submitted to the Court for entry of the Final Decree. Dated: IN THE COURT OF COMMON PLEAS OF THE JUDICIAL DISTRICT OF PENNSYLVANIA COUNTY CUMBERLAND Rachel Kay Nace, Plaintiff 210 West Allen St.. Apt. 1 Mechanicsburg, Pennsylvania 17055 181-62-3850 Charles Edward Nace, III, Defendant 4800 Charles Road, Unit L Mechanicsburg, Pennsylvania17050 196-60-2994 ~ ~ ~ ~ ~ ~ ~ ~ ~ CIVIL ACTION - LAW TERM CASE NO. (? Lf ~ (( -, If IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, the Court for entry of a divorce decree: I. Ground for divorce: Irretrievable breakdown under Section 3301 (c) of the Divorce Code. 2. Date and manner of service of Complaint: the _ day of 2003 by Acceptance of Service 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 Rachel Kay Nace; by Defendant Charles Edward Nace, m. (b)(I) Date of execution of the affidavit required by Section ~330 I (d) of the Divorce Code: (b )(2) Date of filing and service of the Plaintiff's affidavit upon the respondent: 4. Related claims pending: 5. (Complete either (a) (b).) (a) date and manner of service of the notice of intention to file to transmit record, a copy of which is attached: (b) (1) Date Plaintiff's waiver of notice in ~3301(c) Divorce was filed with the prothonotaty: (b) (2) Date Defendant's waiver of notice in ~3301(c) Divorce was filed with the prothonotaty: 6. Attached hereto are: (a) A copy of the docket entries, certified by counsel ( or by clerk of courts - civil) to be a true and correct copy of the original docket entries; (b) The original proposed divorce decree (including a copy of the pre-nuptial agreement, which is requested to be incorporated by reference in said decree) ; (c) The completed form required by the commonwealth of Pennsylvania, Department of Health, Bureau of Vital Statistics; (d) The completed affidavit ofnon-militaty service under the Soldiers and Sailors Civil Relief Act of 1940,50 U.S.CA App. Sec. 520, if required by rule 1920.46. Rachel Kay Nace, Petitioner (-~ h") j'_1 -_I IN THE COURT OF COMMON PLEAS OF THE JUDICIAL DISTRICT OF PENNSYLVANIA COUNTY CUMBERLAND Rachel Kay Nace. Plaintiff 210 West Allen SI., Apt. 1 Mechanicsburg. Pennsylvania 17055 181-62-3850 ~ ~ ~ ~ ~ ~ ~ ~ ~ CIVIL ACTION - LAW Charles Edward Nace, III. Defendant 4800 Charles Road. Unit L Mechanicsburg, Pennsylvania17050 196-60-2994 TERM CASE NO. () 4 - II 7~ IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in Divorce under 3301 (c) of the Divorce Code was filed on 2. The marriage of the plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and the service of the complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are true and correct. I understand that false statements contained herein are made subject to penalties of 18 Pa. C.S. ~4904, relating to unsworn ~fication to authOritie~ ___ DATE: 7//;7. 07' 2 ~=-- Charles Edward Nace, III WAIVER OF NOTICE TO 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 any 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. 94904 relating to unsworn falsification to authorities. Dated: 7/~ dL .5 ~~ Charles Edward Nace, III ".;..' (.'; r",' IN THE COURT OF COMMON PLEAS OF THE JUDICIAL DISTRICT OF PENNSYLVANIA COUNTY CUMBERLAND Rachel Kay Nace, Plaintiff 210 West Allen St., Apt. 1 Mechanicsburg, Pennsylvania 17055 181-62-3850 Charles Edward Nace, III, Defendant 4800 Charles Road, Unit L Mechanicsburg, Pennsylvania17050 196-60-2994 9 9 9 9 9 9 9 9 9 CIVIL ACTION - LAW TERM CASE NO. (Yr'- //1& DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on the /'1 day of ,4/~ , 'Cs:>c>$" 2. The marriage between the parties hereto is irretrievably broken. Ninety days have elapsed since the filing of the Complaint. 3. I am aware that marriage counseling is available and do not desire said counseling. 4. I state that I have read copies of the Complaint for Divorce Under Section 3301 (c) of the Divorce Code, and I understand said Complaint. I waive any pleading periods and notices there may be. 5. I hereby enter my consent to the entry of a final decree of divorce. 6. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not daim them before a divorce is granted. 7. 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. Dated: ~~r L::V--L' ~ ~:zzL Charles Edward Nace, III, Defendant ), -.,,' y / ~) B\~ 'if " () c::: :", '" c.:> = en o "'T1 --< Mi~ -:-... ~~ I '0 " () ~',~ r;--? () i-i--\ ...- (.h v<.{ IN THE COURT OF COMMON PLEAS OF THE JUDICIAL DISTRICT OF PENNSYLVANIA COUNTY CUMBERLAND Rachel Kay Nace, Plaintiff 210 West Allen St., Apt. 1 Mechanicsburg, Pennsylvania 17055 181-62-3850 ~ ~ ~ ~ ~ ~ ~ ~ ~ CIVIL ACTION - LAW TERM CASE NO. 0'1. II h. Charles Edward Nace, III, Defendant 4800 Charles Road, Unit L Mechanicsburg, Pennsylvania17050 196-60-2994 IN DIVORCE AFFIDAVIT OF CONSENT 1. A~om~int in Divorce under 3301 (c) of the Divorce Code was filed on "":.oai1Y . 2. The marriage of the plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and the service of the complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are true and correct. I understand that false statements contained herein are made subject to penalties of 18 Pa. C.S. 94904, ~~~i~~ to un~~cation to authoritie~/ r~,pr- , Charles Edward Nace, III WAIVER OF NOTICE TO INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 93301 (c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without any 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. 94904 relating to unsworn falsification to authorities. Dated: r~~ ~ ?::7/~ f7J'" Charles Edward Nace, III 0 ....., 0 ~o r- 1:.;:;:) -n "'" .-< - ,- ~} ;.:.c:. ~:';1 ~. I lD -, , C_ C.~ f'0 ;.;--:; ---I -< ... );;) B~ ~, , OF PENNSYLVANIA COUNTY CUMBERLAND Rachel Kay Nace, Plaintiff 210 West Allen St., Apt. 1 Mechanicsburg, Pennsylvania 17055 181-62-3850 Charles Edward Nace, III, Defendant 4800 Charles Road, Unit L Mechanicsburg, Pennsylvania17050 196-60-2994 ~ ~ ~ ~ ~ ~ ~ ~ ~ CIVIL ACTION - LAW TERM CASE NO. Oll - 117VJ IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, the Court for entry of a divorce decree: I. 4. Ground for divorce: Irretrievable breakdown under Section 3301 (c) of the Divorce Code. Date and manner of service of Complaint: the '\ G.. day of ~'0\(\ 2003 by Acceptance of Service 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 Rachel Kay Nace; by Defendant Charles Edward Nace, III. (b)(I) Date of execution of the affidavit required by Section g3301(d) of the Divorce Code: (b )(2) ~~t~ of filing and service of the Plaintiff's affidavit upon the respondent: '\I.l\\.\,Nv~~ It) , 7_'$Ju.. . . Related claims pending: 2. 3. ..;;J\::,~~ , 5. (Complete either (a) (b).) (a) date and manner of service of the notice of intention to file to transmit record, a copy of which is attached: (b) (I) Date Plaintiff's waiver of notice in ~330 I (c) Divorce was filed with the prothonotary: '-\isSV-\.. r1\.. y~,- \ \::) , ';).~~ (b) (2) Date Defendant's waiver of notice in g3301(c) Divorce was filed with the prothonotary: ~\s\.JQ \'l\.>~tx \. \2> ~,d-\ . .. 6. Attached hereto are: (a) A copy of the docket entries, certified by counsel (or by clerk of courts _ civil) to be a true and correct copy of the original docket entries; (b) The original proposed divorce decree (including a copy of the pre-nuptial agreement, which is requested to be incorporated by reference in said decree) ; (c) The completed form required by the commonwealth of Pennsylvania, Department of Health, Bureau of Vital Statistics; (d) The completed affidavit of non-military service under the Soldiers and Sailors Civil Relief Act of 1940,50 U.S.C.A. App. Sec. 520, if required by rule 1920.46. ;?add /tat,- Rachel Kay Nace, Petitioner ...~" ) ;-1 :-1 '" C.I '" ("', O.J IN THE COURT OF COMMON PlEAS OF THE JUDICIAL DISTRICT OF PENNSYLVANIA COUNTY CUMBERLAND Rachel Kay Nace, Plaintiff 210 West Allen St., Apt. 1 Mechanicsburg, Pennsylvania 17055 717-648-2322 vs. Charles Edward Nace, III, Defendant 4800 Charles Road, Unit L Mechanicsburg, Pennsylvania 17050 717-648-2303 ~ ~ ~ ~ ~ ~ ~ CIVIL ACTION - LAW TERM CASE NO. ill- If 1 (;J NOTICE OF INTENTION TO RETAKE PRlORNAME Notice is hereby given that the Wife in the above matter, having been granted a Final Decree in Divorce, on the L day of fUJ , ! Li)<; , hereby elects to retake and hereafter use her previous name of Rachel Kay Weikelt and gives this written notice avowing her intention in accordance with the provisions of the Ad of December 16, 1982, P.L. 1309,54 Pa. C.S.A. Sec. 7~1uI ,;(i ~~ RaCh~y Nace TO BE KNOWN AS ~cU/u-( ;f a-<j 1A~/i~ Rachel Kay Weikert On th~5~y oC~ 1 ,.p t.t ' Oleos- ,before me, a Notary Public, personally appeared Rachel Kay Nace, known to me to be the person whose name is subscribed to the within document and acknowledged that she executed the foregoing for the pll1pose therein contained. IN WITNESS THEREOF, I have hereunto set my' hand and seal. a /II 11</170~}Jt /J'IjH~ ~ Notary Public COMMONWEALTH OF PEMNS'1LVANIA NOTARIAl SEA\. Jennifer L. 01 Sylveslltr, NoIIrY "'::: Derry T_hlp, DIlIllhln iO~llOI Commlllftn FtlI. I ;A:) -{q (") ...., 0 -;-:1 = C. = 'Tl <.n ~ C> '- --i I..,., () c m- r'- 0 --'il1 N -:':J\.~ F (Jl ,~:.) (t) -i.:::::. ........ .-:.,' 'I ~ " ;;"'.o;::n :::;;.: "~CoO 6"'- :jnl ~ ~ -, U .-:::":" ,.,:> ~ -~ N :f2 f5 -'.... .- -~ ^ � IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. Rachel Kay Nace Plaintiff No. 0/4-1176 VERSUS Charles Edward Nace III DECREEIN DIVORCE AND NOW, IT IS ORDERED AND DECREED THAT Rachel !�gy Nace PLAINTIFF, AND Charles Edward Nace III 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; ROTHONOTARY ' . , . , �.. - - ,.., :.�_ . � .:_ , ,�. ^' k _ � _ },: .