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
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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
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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
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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
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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
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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( )
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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
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CIVIL ACTION - LAW
C1
_101
CASE NO.
TERM
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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
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COMMONWEALTH OF PENNSYLVANIA
[Notarial Seal
Sherry L Potteiger, Notary Public
Middlesex Twp" Cumberland County
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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 ~
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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:
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subscribed before me this the ~.f1aay of
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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
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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.
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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
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RACHEL KAY NACE
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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)
.
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EDWARD E, GUIDO
JUDGE
ONE COURTHOUSE SQUARE
CARLISLE, PENNSYLVANIA 17013-3387
U. . POSTAGE
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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
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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
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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:
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Charles Edward Nace, III, Defendant
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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
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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.
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Dated:
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Charles Edward Nace, III
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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
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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
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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,
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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
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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
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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: $
,.-..,
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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
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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
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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
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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
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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
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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
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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
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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
),
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o
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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
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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
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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
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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
...~" )
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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
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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
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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
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