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HomeMy WebLinkAbout08-7488V/ J KAREN LYNN PARDOE ) IN THE COURT OF COMMON PLEAS PLAINTIFF, ) CUMBERLAND COUNTY, PENNSYLVANIA V. ) CIVIL DIVISION JEFFREY ALAN PARDOE ) NO. ?I V t I T'? V m DEFENDANT NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIM SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE PROMPT ACTION. YOU ARE WARNED THAT IF YOU FAIL TO DO SO, THE CASE MAY PROCEED WITHOUT YOU AND A DECREE OF DIVORCE OR ANNULMENT MAY BE ENTERED AGAINST YOU BY THE COURT. A JUDGMENT MAY ALSO BE ENTERED AGAINST YOU FOR ANY OTHER CLAIM OR RELIEF REQUESTED IN THESE PAPERS BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU INCLUDING CUSTODY OR VISITATION OF YOUR CHILD(REN). WHEN THE GROUND FOR THE DIVORCE ARE 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 PENNSYLVANIA. IF YOU DO NOT FILE A CLAIM FOR ALIMONY; DIVISION OF PROPERTY, LAWYERS FEES, OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYERS REFERRAL SERVICE For Petitiafer ' Address: 125 Sholly Drive MechanicsbtM PA 17055 Telephone: 717-697-1915 IKREN LYNN PARix PLAINTIFF, V. MFMY AI,A PARDOE DEFENDANT. (IN THE COURT OF COMMON PLEAS OF ( ( ERL NAT COUNTY, PENNSYLVANIA (CIVIL DIVISION ( (No: D 8- y g ?L- COMPLAMT IN DIVORCE AND NOW COMES, the Petitioner, Lv? p by FILING PRO SE, who files this Complaint in Divorce statement of which is as follow: 1. The Petitioner is Lvffi Pantie and adult individual caunvedy residing at 125 Shoily flrive iur.?•]...a..a..,... D ? 1-Mr r 2. The Defendant is hbka Alan Pardoe and adult individual currently residing at 914 Wakefield Ave Mec]?snio.t.n. o pA 17055 3. The Petitioner has been a bona fide resident of the Commonwealth of Pennsylvania for at least six (6) months previous to the filing of this Complaint. 4. The Petitioner and Respondent were married on date: 02-26-1994 in the State ofP?ylvania 5. Then (is) is 2 minor chikknn) born of this Name(s)l.ksav KW pardoe and iCvle r.ff.,r p Birthdate(s): 02-07-1996 and 07-02-1998 6. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940and its amendments. 7. There has been no prior action for divorce or annulment instituted by either of the parties in this or any othorlurisdiction. 8. The marriage is irretrievable broken. 9. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 10. After ninety (90) days have elapsed from the commencement and service of this action, Plaintiff intends to file an affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an affidavit. ? -ft KAREN LYNN PARDOE PLAINTIFF, V. JEFFREY ALAN PARDOE DEFENDANT. (IN THE COURT OF COMMON PLEAS OF ( (CUMBERLAND COUNTY, PENNSYLVANIA ( (CIVIL DIVISION (NO: AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF: C[AIBERLAND ss: ) Before me, the subscriber, a Notary Public in and for said Commonwealth and County, personally appeared KAREN LYNN PA_RDOE who being duly sworn according to law, deposes and says that the facts mined within the foregoing Complaint in Divome are true and correct to the best of his/her knowledge, information, and belief, and that he/she is authorized to make this Affidavit. b0o . this Sworn -- ?y of 2110 . f N Y 7PUBLIC COMMONWEALTH OF PENNSYLVANIA Notarial Seal Judith A. Walter, Notary Public Upper Allen Twp., Cumberland County My Commission Expires May 12, 2010 N Member, Penns}4)';a le Association of Notaries S q r? c-5 ! # 47 :r KAREN LYNN PARDOE ) PLAINTIFF, ) V. ) JEFFREY ALAN PARDOE ) DEFENDANT ) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NO. W- MILITARY AFFIDAVIT I, JEFFREY ALAN P RDOE ,`fall legal name}, Defendant, being sworn, certify that the following information is true: [Marls all that apply] I am not on active duty in the armed services of the United States. I understand that I am swearing or affirming under oath to the truddililness of the claims made in this affidavit and that the punishment for knowingly making a false statement includes fines and/or imprisonment. DATED: 1 Za/ o g STATE OF PENNSYLVANIA COUNTY OF 0MUKRLAND WD- Printed Name: Arm Alan Pardoe Address: 914 Wak _ Ave. City, state, zip: Mechanicslxurg PA 17055 Telephone Number. 717-943-3417 Fax Number. On the day of 200 before me, a Notary Public, personally appeared ZFEREY ALAN PARMF known to me to be the person whose name is subscribed to the within document and acknowledged that she executed the forgoing for the purpose therein contained. IN WITNESS WHEREOF, I have set my Imnd and X COMMONWEALTH OF PENNSYLVANIA Notarial Seal - 1 - Judith A. Walter, Notary Public Upper Allen Twp., Cumberland County My Commission Expires May 12, 2010 Member. Penns,ivo. J,, A'-sociation of Notaries m <w? ?. c `s rr? E5 r-, I *'' KAREN LYNN PARDOE ) PLAINTIFF, ) V. ) JEFFREY ALAN PARDOE ) DEFENDANT ) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NO. D- Alf INCOME AND EXPENSE STATEMENT OF DEFENDANT Defendant files this income and expense statement showing all income and expenses as of this date. Defendant verifies that the statements made in the income and expense statement are true and correct. Defendant understands that false statements herein are made subject to 18 PA. C.S. Section 4904 relating to unswom falsification to authorities. Date: I V-40 INCOME AND EXPENSE STATEMENT OF DEFENDANT Name: JEFFREY ALAN PARDOE Date of Bk 02-19-1970 SS# 167-52-8830 Phone No.: 717-943-3417 Home Address : 914 Wakefield Ave. Mechani PA 17055 Drivers License #: 22361721 E er. Borders Distribution Position: Maintenance Address; 1301 Distribution Dr. Suite I Carlisle, PA 17013 Phone: 717-243-2400 Date Employed- Other Emloyment Health Insurance Compaw Name: Poll #: Address G #: 1. GROSS INCOME ?S?v15 s ?' _ S P 3. OTHER INCOME (LIST) 2. DEDUCTIONS Federal Income Tax Social Security State Income Tax Local Income Tax Health Insurance Union Dues Pension Contributions Credit Union Other Deductions S 00 a 8 0 0 $ oc S . 0 o s °150. o o S S S Total Deductions - s_ t3 8 Subtract Totals from Gross 1wow s D 7 NET COME S s $ s TOTAL OTHER INCOME S 4. DEDUCTION FOR TAXES FROM OTHER INCOME Federal Income Tax $ Social security S State Income Tax $ Local Income Tax $ Health insurance $ Union Dues $ Pension Contributions f Credit Union $ Other Deductions f Total Deductiow - S Subtract Totals fmm Gross Other Income S NET OF OTHER INCOME TOTAL ALL INCOME: RN,eekly $ L Mtxithly $ 3 Q .4-T. © c 'b e Co KAREN LYNN PARDOE PLAINTIFF, v. JEFFREY ALAN PARDOE DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CngL DIVISION NO. ACCEPTANCE OF SERVICE AND ENTRY OF APPEARANCE PLEASE take notice that I, _ JEFFREY ALAN PARDOE Defendant, was provided with a Copy of the Notice to Defend and Claim Rights and Complaint for Divorce and do accept service of same. I further enter my appearance in this action for all purposed. Address: 914 Wakefield Ave. Mechanicsburg, PA 17055 Tl ril KAREN LYNN PARDOE ) IN THE COURT OF COMMON PLEAS PLAINTIFF, ) CUMBERLAND COUNTY, PENNSYLVANIA V. ) CIVIL DIVISION JEFFREY ALAN PARDOE ) NO. _ DEFENDANT ) INCOME AND EXPENSE STATEMENT OF PLAINTIFF Plaintiff files this income and expense statement showing all income and expenses as of this date. Plaintiff verifies that the statements made in the income and mgxme statement are true and correct. Defendant understands that false statements herein are made subject to 18 PA. C.S. Section 4904 relating to unworn falsification to authorities. ) Date: ?- Plaintiff l r INCOME AND EXPENSE STATEMENT OF PLAINTIFF Name: KAREN LYNN PARDOE Date of Birth: 05-02-1968 SS#.- 183-02-0124 Phone No.: 717-697-1915 Home Address : 125 Sho Drive Mcchwksbur% PA 17055 Drivers License #: 20525345 E er B & S T Position: School Van Driver Address: 2217 Old Gettysburg Rd. I Camp H' PA 17011 Phone: 717-697-9109 Date Employed: Other Employment Health Insurance Company Name: PoG #: Address: tiro #: 1. GROSS INCOME $ --ago w 3. OTHER INCOME (LIST) 2. DEDUCTIONS $ s Federal Income Tax $ $ Social Security S $ State income Tax $ Local Income Tax S L 2 -? TOTAL OTHER INCOME $ Health Insurance s [ 4. DEDUCTION FOR TAXES FROM OTHER Union Dues $ G INCOME Pension Contnbutions $V' Credit Union $ 0 Federal Income Tax $ Other Deductions $ 0 Social Security $ Total Deductions - $ State Income Tax $ Subtract Totals from Gross Income Local Income Tax $ $ He" Insuuance $ NET INCOME Union Dues $ Pension Contributions S Credit union $ Other Deductions $ Total Deductions - S Subtract Totals from Gross Other Income S NET OF OTHER INCOME TOTAL ALL INCOME: ? Weekly s lamm hiy $ VX f r m . C--j f ! 7 ,T. _da 4• KAREN LYNN PARDOE PLAINTIFF, V. JEFFREY ALAN PARDOE DEFENDANT. (IN THE COURT OF COMMON PLEAS OF ( (CUMBERLAND COUNTY, PENNSYLVANIA (CIVIL DIVISION ( (NO:'n?7,90,F - 0 7q CUSTODY AGREEMENT And now, this 2_?p day of 20 in aclmowledgment of the agreement of the parties, it is hereby ORDERED and DECREED as follows: Karen Lynn Pardoe shall have primary custody of the child(ren): Lindsay Kay Pardoe DOB: 02-07-1996 Kyle Jeffrey Pardoe DOB: 07-02-1998 2. Jeffrey Alan Pardoe shall have visitation of the above named children) as follows: Both children will be in primary custody of Karen Lynn Pardoe. Jeffrey Alan P!ardoe will have the children every other weekend from Friday at 4 P.M. until Sunday at 6 P.M. Major holidays of Thanksgiving, Christmas, New Years Day and Easter will be split days with each parent. 1 _ G -Y1 1, A17 Plai ff Date: / - -2-6 - 0z -5 fa Ke,,A hAe Me, 4f T?r to 2;z6dq/ a ?5? COMMONWEALTH OF PENNSYLVANIA Notarial Seal Judith A. Walter, Notary Public Upper Allen Twp., Cumberland County My Commission Expires May 12, 2010 Date: By Order of the Court: Member. Pennsylvania Aszzociation of Notaries i .I K ARRN i VNN PARDOE (IN THE COURT OF COMMON PLEAS OF (CUbMWELAND COUNTY, PENNSYLVANIA u_ E ( CIVIL DIVISION E cx> 0 a ? >EX ALAN PARDOE (No: 7Y kk DEFENDANT. CtMTOM CONB4 AWF AND Now COMM the Petitioner, Kf1e' L "a Pardoe . by FILING PRO SE, vAwf9mthisPodt mfoFCry ofvd"isast'ollow - 1. The Petitioner m Kin i M Paid= . and a&& ffidi?ridnsl cwms ly mdit 2. The Defoddaat is , jeffm Ain Pudoe . and aloft 'md'ivAW ae u* reeding at 914 o AvL PA 17M 3. Pl auff socks prm=Y aatD y of dw Mow" Chikxnn). L r Kay Pw" DOB: 02-07--1996 Kyle J0007 Padoc DOB: W-02-1999 Both children will be m primary ousbody of Karen Lym Pardoe. Jeffrey Alm Pardoe will have dw du-Mm avoy other wedmd imm FA ft at 4 P.M. antes SWWW at 6 P.M. Major holidays of Thaidsgivingi Cksh aa, New Yeaas Day and EmW will be days with each parent. WHEREFORE, P)ambff mquwb this court SmM Mmwy custody of do child(ren) to PbjntUE ?, ? ?7 ?? r: ? ?? r - ' ' .? - ; ? 4. r?z . ?: :µ% V F2 0 2 2090 KAREN LYNN PARDOE (IN THE COURT OF COMMON PLEAS OF PLAINTIFF, ( (CUMBERLAND COUNTY, PENNSYLVANIA V. (CIVIL DIVISION JEFFREY ALAN PARDOE (NO: a J- - 7 q DEFENDANT. CUSTODY AGREEMENT And now, this 2. V day of ?AAUOWU 20 Q? in acknowledgment of the agreemad of the parties, it is hereby ORDERED and REED as follows: Karen Lynn Pardoe shall have primary custody of the child(ren): Lindsay Kay Pardoe DOB: 02-07-19% Kyle Jeffrey Pardoe DOB: 07-02-1998 2. Jeffrey Alan Pardoe shall have visitation of the above named child(ren) as follows: Both children will be in primary custody of Karen Lynn Pardoe. Jeffry Alan Pardoe will have the children every other weekend from Friday at 4 P.M. until Sunday at 6 P.M. Major holidays of Thanksgiving, Christmas, New Years Day and Easter will be split days with each parent. /r Pl ` ff Date: / - Cv - -5i'?',Ke' he&e' me, J R('0 avoq/ COMMONWEALTH OF PENNSYLVANIA Notarial Seal Judith A. Walter, Notary Public Upper Allen Twp., Cumberland County My Commission Expires May 12, 2010 Fc6. ? 09 Date: Member, Pennsvivanias Associatinn of Notaries Itio U-T,- jily VA4 ,.ran,!7 f". r .: ,,. - 9 Z =£ Wd - 933 60OZ ill ?o KAREN LYNN PARDOE ) IN THE COURT OF COMMON PLEAS PLAINTIFF, ) CUMBERLAND COUNTY, PENNSYLVANIA V. ) CIVIL DIVISION JEFFREY ALAN PARDOE ) NO. ArC/r' 07 DEFENDANT ) !? MN?LILTk A complaint in Divorce under Section 3301(c) of the Divorce Code was filed on /.2 .2 ?4- - Y . I agree that the marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the dale of filing the Complaint. All information contained within the attached documentation is true and correct to the best of my knowledge, information, and belief it is my desire to file with the C3MERLAND County Court of Common Pleas the attached Marital Property Settlement Agreemea and to be bound fully and completely by the terms and conditions as set forth within said Marital Property Settlement Agreement documentation. IN WITNESS WHEREOF I set my hand and seal this day of (`??a? r e- h , 200_. N NAME: Jeffrey Alan Pardoe On this day of m rx , 20p , before me, a Notary Public, the undersigned officer, personally appeared IL,fgq Alan Pardoe , known to me to be the person whose name is subscribed to the written instrurnent, and acknowledged that he/she executed the same for the purposes therein contained IN WITNESS WHEREOF I hereunto set my hand and official seal. d- r6 otary blic O" PE.NNSYLVNN A Notarial Seal Judith A. Walter, Notary Public Upper Allen Twp., Cumberland County My Commission Expires May 12, 2010 Member, Penn v;v c,.snociation of Notaries ?'; ? . _y. is-`? : ry (,'?t 11 µ1y! t9? ?q!+7. T t/l '; ? . Lii? 1 ?AL1 04 4Z. t .,_ '? l '? J r ? KAREN LYNN PARDOE ) IN THE COURT OF COMMON PLEAS PLAINTIFF, ) CUMBERLAND COUNTY, PENNSYLVANIA V. } CIVIL DIVISION JEFFREY ALAN PARDOE ) NO. o2UUr? ??7 DEFENDANT ) A complaint in Divorce under Section 3301(c) of the Divorce Code was filed on /J -Ij 4- a r . I agree that the marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed Alm the date of filing the Complaint. All information contained within the attached documentation is true and correct to the best of my knowledge, information, and belief It is my desire to file with the CUMBERLAND County Court of Common Pleas the attached Marital Property Settlement Agreement and to be bound fully and completely by the terms and conditions as set forth within said Marital Property Settlement Agreement documentation. IN WITNESS WHEREOF I set my hand and seal this day of 4714 ?h , 20e-?. j etrl- S A NAME: Ka*n Lynn Pardoe on this day of ifl , 20 before me, a Notary Public, the undersigned officer, personally appeared known to me to be the person whose name is subscribed to the written instrument, and acknowledged that he/she executed the same for the purposes therein contained. IN WITNESS WHEREOF I hereunto set my hand and official seal. COMMONWEALTH OF PENNSYLVANIA Notarial Seal Judith A. Walter, Notary Public Upper Allen Twp., Cumberland County My Commission Expires May 12, 2010 Member, Pennsylvaoi, Assnoiation of Notaries KAREN LYNN PARDOE ) IN THE COURT OF COMMON PLEAS PLAINTIFF, ) v. JEFFREY ALAN PARDOE DEFENDANT ) CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NO. ,,7064- - 0-7 q,?' E' AFFIDAVIT OF CONSENT 1. A complaint in Divorce under Section 3301(c) of the Divorce Code was filed on Z,,L) -2, 9 -ok- (date:). 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and Complaint. I consent to the entry of a final decree of Divorce after service of notice of intention to request entry of the decree. WAIVER OF NOTICE OF INTENTION TO RBOUESP SZCMN Mlfel OF THE D1VO S= I consent to the entry of a final decree of Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of properly, 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 here-in are made subject to the penalties of 18 Pa C.S. Section 4904 relating to unworn falsification to authorities. Date: 3/a 6?? 09 ?- -14? f B6fmdWiVJeffl6y Alan Pardoe i KAREN LYNN PARDOE ) IN THE COURT OF COMMON PLEAS PLAINTIFF, ) CUMBERLAND COUNTY, PENNSYLVANIA V. ) CIVIL DIVISION JEFFREY ALAN PARDOE ) NO. ?,?Lyk- C, "7 DEFENDANT ) AFFIDAVIT OF CONSENT 1. A complaint in Divorce under Section 3301(c) of the Divorce Code was filed on (date:) /.,,2 - ? Ct _v 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and Complaint. I consent to the entry of a final decree of Divorce after service of notice of intention to request entry of the decree. WAIVER OF NOTICE OF INTENDIO• N TOE LNTRYY OF ,A DIVORCE 1DECREE UNDER SEC'= Miff) O? THE DIVORCE CODE 1. I consent to the entry of a final decree of Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees, or expenses if I do not claim them before a Divorce is granted. 3 I understand that I will not be divorced until a Divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately alter it is filed with the prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements here-in are made subject to the penalties of 18 Pa C.S. Section 4904 o unworn falsification to authorities, Date: J3 -? ?o . l1 / Lynn Pfirdoe `°. ? ? _ ,?, ?:?1 - __ ? rs .-? . f ?- .?,. t ` : ?, rz t ? ,,,,, ,i. ` ? ' ,k -;. r' ? `. 'r ,,, . ';'.? ..+:. 4? p 9'- 74/?k (-!, , MARITAL SETTLEMENT AGREEMENT FOR DIVORCE WITH DEPENDANT OR MINOR CWLD(REN) AND PROPERTY We, KAREN LYNN P RDOE and JEFFREY ALAN PARDOE, being sworn, certify that the fallowing statements are true: 1. We were married on: 02-26-9. 2. Because of irreconcilable differences in our marriage (no chance of staying togelher), we have made this agreement to settle once and fir all what we owe to each other and what we can expect to receive from each other. Each of us states that noti*g has been held back, that we have honestly included everything we could #** of in listing our assets (everything we own and that Is owned to us) and our debts (everything we owe), and that we befieve that the other has been open and honest In writing this agreement. 3. We have both tiled a Financial Affidavit. Because we have voluntarily made full and fair disclosure to each other for all our assets and debts, we waive any further disclosure. 4. Each of us agrees to execute and exchange any papers that might be needed to complete this agreement, including deeds, title ceatitrcates, etc. SECTION i. MARITAL ASSETS AND LIABILITIES A. Division of Assets. We divide our assets as follows: Any personal item(s) not listed below is the property of the party currently in possession of the Hem(s). 1. Wife shall receive as her own and Husband shads have no further rights or responsibilities regarding these assets: Vehicle: 2003 Ford Explorer Personal Property: Green living room furniture tables and lamp All dining room furniture and knickknacks All kids bedroom ftaniture All MasW bedroom furniture Kitchenware TV and entertainment unit in family room Any items not taken or wanted by either party will be sold and proceeds divided equally. Home Computer and all in One Copy, Print Fax and Scanner 2. Husband shall receive as his awn and Wife shall have no further fights or, nsibillfies regarding these assets: Vehicle: 2004 Ford Taurus Personal Properly: 42" Flat screen Surround sound and TV stand Tools in garage Blue couch, Chair and and tables and lamps in Family room Small refrigerator in family room Life Insurance: AN life insurance for Jeff is through his employer. The coalitions of that policy will be taken we of through his empigw Retirement Plan: 401 K policy. Karen Pardoe will not receive any proceeds from Jdfmy Pardoe's 401 k policy. B4 Division of Ltabiiitiss/0ebts. We divide our liabilities as follows: Wfe shall pay as her own the fallowing and will not at any time ask Husband to lay these debtstbills: All debts will be paid from proceeds of sale of house. If either pasty chooses not to pay off a debt, they assume the debt. 2. Husband shall pay as his own the 1611ming and will riot at any time ask Wde to pay these debtslbNis: All debts will be paid from proceeds of sale of house. If either party chooses not to pay off a debt, they assume the debt. SECTION 0. PROPERTY. Real Property: 125 Shelly Drive Mechanicsburg, PA 17055 Legal Description: Property Wvision: All outstanding bills shall be paid from the profit of the home. The balance will be spilt 50/50. N one chooses not to pay a debt, they will acquire that debt. 2 SECTION 0. SPOUSAL SUPPORT (ALMAOWY). Each of us forever gives up any right to spousal support (alimony) that we may have. SECTION IV. CHILD CUSTODY, PARENTAL RESPONS1NUM AND VISITATION. 1. The minor children common to both parties are: Nam Lindsay Kay Pandoe Kyle Jeffrey Pardoe Birth Date ft 02-07-1986 F 07-02-1998 M 2. Parernbl RsspornsibI'M for the minor child(ren) will be: a. Shared by both Father and Mother. 3. Primary Residential Parent (Custody). it is in the best interests of the child that the primary residential parent be the Mother. 4. Secondary Residential ResponsIlAty, Visitation, or Time Sharing will be as bkvws: Both Children will be in primary custody of their mother, Karen Pardee. Jeffrey Pardoe will have both children every other weekend. Jeffrey Pardoe will pick up the children at 4:00 pm on Fridays and return them to Karen Pardoe at 6:00 pm on Sundays. Major holidays of Thanksgiving, Christmas, New Years day and Easter will be half days at each parent. SECTION V. CHILD SUPPORT 1. NO CHILD SUPPORT IS REQUESTED. Until our house is sold, we will not be filing for child support. All frurds at this time are being pooled to manage household bills. 2. Heekh Insurance. The will maintain Health Insurance for the parties' minor child(ren). The party providing coverage will provide insurance cards to the other party showing coverage. 3. Dental Insurance. The vAd maintain Dented Insurance for the panties' minor child(ren). The party providing coverage will provide insurance cards to the other party showing coverage. 4. Life Insurance. The will maintain Life Insurance for the parties' minor c t iid(ren). The party providing coverage will provide insurance cards to the other party showing coverage. 5. IRS Tax Deductions. The parent granted primary residential responsibility of the parties' minor child(ren) shall have the benefit of any tax deductions for the child. SECT10M V1. OTHER PROVISIONS. Karen agrees to not taking 50% of Jeffrey Pardoe's 401k as a condi w for Karen Pardoe taking the 2003 Ford EWkxw. We cw y that we have been open and honest In entwft kft this soM meet agroement. We are sadsflsd with this agrownent and Wand to be bound by it. DATED: .3 Karen L Pardoe 125 Sh6Dy Drive Medwics urg, PA 17055 717$97-1915 to and subs ed befo me on th::s day at A my apmmWsion expires: COMMONWEALTH OF PENNSYLVANIA Notarial Seal Judith A. Walter, Notary Public Upper Allen Twp., Cumberland County My Commission Expires May 12, 2010 Member, Pennsvivania Association of Notaries DATED: _ ? / A Lam/ ° 9 G2_ ?7 7 Je"AW Pardoe 914 Wake" Ave. Medtl ksbur$, PA 17055 717-943-3417 Sworn tO and subscribed belom me on this day of PU iC My Commission exires: COMMONWEALTH OF FF-;N v= Notarial Sea! Judith A. Walter, Notary Public Upper Alen Twp., Cumberland County My Commission Expires May 12, 2010 Member, Pennsylvania µF?urciratl;? of Pdotaricvs 4 FILE '; n t~t 9 , f? h ., I.., KAREN LYNN PARDOE ) IN THE COURT OF COMMON PLEAS PLAINTIFF, ) CUMBERLAND COUNTY, PENNSYLVANIA V. ) CIVIL DIVISION JEFFREY ALAN PARDOE ) NO. DEFENDANT PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Kindly Transmit the Record, together with the following information, to the Court for entry of a divorce decree: 1. Grounds for Divorce: irretrievable breakdown under Section ® 3301(c) orE] 3301(d) of the Divorce Code. (Check applicable section.) 2. Date and manner of service of the Complaint: on or about (GIVE DATE): i( gq- 4E_ via (check one) [) Personal Service or (l Certified Mail. 3. (Complete either paragraph (a) or (b).) (a) Date of execution of the Affidavit of Consent/Consent Waiver required by Section 3301 (c) of the Divorce Code: by Plaintiff ( ) by Defendant ( ).. (b) (1) Date of execution of the Plaintiffs Affidavit required by Section 3301(d) of the Divorce Code: (2) Date of service of the Plaintiff's Affidavit required by Section 3301(d) of the Divorce Code: 4. Related claims pending: None. Plainfit Address: 125 ly Drive Mechanicsburg, PA 17055 Phone: 717-697-1915 5. Bate and manner of service of the Notice of Intention to file Praecipe to Transmit Record, a copy of which is attached, if the Decree is to be entered under Section 3301(d) of the Divorce Code. -1- -Ti ,-y KAREN LYNN P V. JEFFREY A. PARDOE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2008 - 7488 CIVIL TERM ORDER OF COURT AND NOW, this' between the filing and consent, the request for day of APRIL, 2009, it appearing that only 85 days elapsed of the complaint and the execution of the affidavits of entry of a final divorce decree is DENIED without prejudice. the Court, Edward E. Guido, J. Karen Lynn Poe 125 Sholly Drive Mechanicsburg, Pa. 17055 Jeffrey Alan Pardoe 914 Wakefield Avenue Mechanicsburg, Pa. 17015 :sld 126F tET e7a LL h .8 4 ?1 1 d 6002 ??3y0t-,' ??? a b KAREN LYNN PARDOE ) IN THE COURT OF COMMON PLEAS PLAINTIFF, ) CUMBERLAND COUNTY, PENNSYLVANIA V. ) CIVIL DIVISION JEFFREY ALAN PARDOE ) NO. „?C/os- 7 y DEFENDANT ) PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Kindly Transmit the Record, together with the following information, to the Court for entry of a divorce decree: 1. Grounds for Divorce: irretrievable breakdown under Section ® 3301 (c) or [] 3301 (d) of the Divorce Code. (Check applicable section.) 2. Date and manner of service of the Complaint: on or about (GIVE DATE): L-cl - U !V via (check one) ? Personal Service or [] Certified Mail. 3. (Complete either paragraph (a) or (b).) (a) Date of execution of the Affidavit of Consent/Consent Waiver required by Section 3301 (c) of the Divorce Code: by Plaintiff ( Z2 - )s/ -U ?- ) by Defendant ( 1,2- - ?1 • U -• (b) (1) Date of execution of the Plaintiffs Affidavit required by Section 3301(d) of the Divorce Code: et- ?- ae (2) Date of service of the PlaintifFs Affidavit required by Section 3301(d) of the Divorce Code: 2' .1.-0i- Az( 4. Related claims pending: None. Plain 'ff Address: 125 holly Drive Mechanicsburg, PA 17055 Phone: 717-697-1915 5. Date and manner of service of the Notice of Intention to file Praecipe to Transmit Record, a copy of which is attached, if the Decree is to be entered under Section 3301(d) of the Divorce Code. -1- FILED F?:OE L r '?.T ,, 2449 APIR 16 F'? : 33 ` ?- z IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. L"n NO. DIVORCE DECREE rt"k-a" -;- 1 &!?0'6 5 3erto.41. , it is ordered and decreed that D NOW1 plaintiff, and defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") Attest: J. Prothonotary y as ? 09 ?