HomeMy WebLinkAbout09-0943JESICA A. SMITH,
V.
IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2009 - 9V_3 CIVIL TERM
CHRISTOPHER E. SMITH,
Defendant
CIVIL ACTION-LAW
IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in court. If you wish to defenel against the claims set forth
in the following pages, you must take prompt action. You are Warned that if you fail to
do so, the case may proceed without you and a decree of divorce or annulment may be
entered against you by the court. A judgment may also be entered against you for any
other claim or relief requested in these papers by the Plaintiff. You may lose money or
property or other rights important to you, including custody or visitation of your children.
When the ground for the divorce is indignities or irretrievable breakdown of the
marriage, you may request marriage counseling. A list of marriage counselors is
available in the Office of the Prothonotary at the Cumberland County Court House,
Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY,
COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF 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. THIS OFFICE CAN PROVIDE YOU WITH
INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS?OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES'THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
(717) 249-3166
JESICA A. SMITH, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 2009 - H3 CIVIL TERM
CHRISTOPHER E. SMITH, CIVIL ACTION-LAW
Defendant IN DIVORCE
DIVORCE COMPLAINT
1. Plaintiff is Jesica A. Smith, an adult individual who currently resides at 390
Stonehouse Road, Carlisle, Cumberland County, Pennsylvania;
2. Defendant is Christopher E. Smith, an adult individual who currently
resides at 390 Stonehouse Road, Carlisle, Cumberland County, Pennsylvania.
3. Plaintiff and Defendant have been bona fide residents in the
Commonwealth of Pennsylvania for at least six months immediately previous to the
filing of this Complaint.
4. The Plaintiff and Defendant were married on May, 13, 2005 in Mount Holly
Springs, Cumberland County, Pennsylvania.
5. There have been no prior actions of divorce or for, annulment between the
parties.
6. The marriage is irretrievably broken.
7. The Plaintiff has been advised of the availability of counseling and that
she may have the right to request that the court require the parties to participate in
Counseling.
8. Plaintiff requests the court to enter a decree of divorce.
WHEREFORE, the Plaintiff requests the court to enter a decree of divorce in
favor of the Plaintiff and against the Defendant.
COUNT I -EQUITABLE DISTRIBUTION
9. Plaintiff hereby incorporates by reference paragraphs 1 through 8 above.
10. The parties have acquired real estate, personal property, including
automobiles, bank accounts and other items of miscellaneous property during the
course of their marriage, some of which is marital property
WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a
decree which effects an equitable distribution of marital property.
COUNT II - CUSTODY
11. Plaintiff hereby incorporates by reference all of the averments contained in
paragraphs 1 through 10 of this Complaint.
12. The parties have two children of their marriage, Taylor L. Smith, born
October 9, 2001, age 7 and Bowen W. Smith, born March 2, 2005 age 3.
The children were born out of wedlock.
The children are presently in the custody of Plaintiff and Defendant at 390
Stonehouse Road, Carlisle, Cumberland County, Pennsylvania.'
During the past five years, the children have resided with the following
persons at the following addresses:
Persons Residences Dates
Jesica and 390 Stonehouse Road 2001-
Christopher Smith Carlisle, Pennsylvania Present
The natural father of the children is Christopher E. Smith, currently
residing at 390 Stonehouse Road, Carlisle, Cumberland County, Pennsylvania.
He is married to the Plaintiff.
The natural mother of the children is Jesica A. Smith, currently residing at
390 Stonehouse Road, Carlisle, Cumberland County, Pennsylvania.
She is married to the Defendant.
13. The relationship of the Plaintiff to the children is that of natural mother.
The Plaintiff currently resides with the following persons:
Names Relationship
Christopher E. Smith Husband
Taylor L. Smith Daughter
Bowen W. Smith Son
14. The relationship of the Defendant to the children is that of natural father.
The defendant currently resides with the following persons:
Names Relationship
Jesica A. Smith Wife
Taylor L. Smith Daughter
Bowen W. Smith Son
15. Plaintiff does not know of a person not a party to the proceedings who has
physical custody of the children or claims to have custody or visitation rights with
respect to the children.
16. Each parent whose parental rights to the child have not been terminated
and the person who has physical custody of the child have been named as parties to
this action. All other persons, named below, who are known to have or claim a right to
custody or visitation of the children will be given notice of the pendency of this action
and the right to intervene: none.
WHEREFORE, Plaintiff requests your Honorable Court to enter an Order
awarding the parties shared legal and the Plaintiff primary physical custody of the
children.
Respectfully submitted,
`° -LOO
Date:
O'BRIEN, BARIC & SCHERER
Michael A. Scherer, Esquire
I. D.# 61974
19 West South Street
Carlisle, PA 170,13
(717) 249-6873
Attorney for Plaintiff
VERIFICATION
I verify that the statements made in this Divorce Complaint are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §
4904, relating to unsworn falsification to authorities.
Date:
esica A. S ith
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JESICA A. SMITH,
Plaintiff
V.
CHRISTOPHER E. SMITH,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2009-943 CIVIL TERM
CIVIL-ACTION LAW
ACCEPTANCE OF SERVICE
AND NOW, this 3 day of e/ m , 2009, I, Christopher E. Smith
accept service of the Divorce Complaint in the above-captioned case.
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hristoph r E. Smith
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JESICA A. SMITH,
V.
IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
CHRISTOPHER E. SMITH,
Defendant
NO. 2009-943 CIVIL TERM
CIVIL ACTION-LAW
PLAINTIFF'S AFFIDAVIT OF CONSENT
AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE
1. A complaint in divorce under Section 3301(c) of the Divorce Code was
filed on February 13, 2009.
2. The marriage of the Plaintiff and Defendant is irretrievably broken and
ninety days have elapsed from the date of the filing of the Complaint.
3. 1 consent to the entry of a final decree in divorce without notice.
4. 1 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.
5. 1 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.
6. 1 have been advised of the availability of marriage counseling and
understand that I may request that the court require counseling. I do not request that
the court require counseling.
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.
Date: All _W 316R
... ?- ff- - -
RLED-CIMCE
OP THE PROTHONOTARY
2009 JUN i I PM 3,. 00
CUM lb 4:- i . , 60UN1Y
JESICA A. SMITH,
V.
IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
CHRISTOPHER E. SMITH,
Defendant
NO. 2009-943 CIVIL TERM
CIVIL ACTION-LAW
DEFENDANT'S AFFIDAVIT OF CONSENT, ACCEPTANCE OF
SERVICE AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE
1. A complaint in divorce under Section 3301(c) of the Divorce Code was
filed on February 13, 2009.
2. Defendant acknowledges receipt and accepts service of the Complaint on
February 23, 2009.
3. The marriage of the Plaintiff and Defendant is irretrievably broken and
ninety days have elapsed from the date of the filing of the Complaint.
4. 1 consent to the entry of a final decree in. divorce without notice.
5. 1 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.
6. 1 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.
7. 1 have been advised of the availability of marriage counseling and
understand that I may request that the court require counseling. I do not request that
the court require counseling.
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.
Date: _5?- 30 --0 9 _
ristopher . Smith
ALED-01+ICE
OF THE PROiF?NOTARY
2M9 JUN i 1 Pfd 3: 00
7ipid1. 1r.j is 'i 4J'r.14'NTY
PENNSYLVANI A
JESICA A. SMITH,
V.
IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
CHRISTOPHER E. SMITH,
Defendant
NO. 2009-943 CIVIL TERM
CIVIL ACTION-LAW
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the following information, to the court for entry of
a divorce decree:
1. Ground for divorce: irretrievable breakdown under Section 3301(c) of the
divorce code.
2. Date and manner of service of the complaint: Defendant signed an
Acceptance Of Service form on February 23, 2009.
3. (Complete either paragraph (a) or (b).)
(a) Date of execution of the affidavit of consent required under Section 3301(c)
of the divorce code: by the plaintiff May 22 2009 ;
by the defendant May 30. 2009
(b) (1) Date of execution of the plaintiffs affidavit required by Section 3301(d)
of the divorce code N/A
(2) Date of service of the plaintiffs affidavit upon the defendant
N/A
4. Related claims pending NONE
5. Indicate date and manner of service of the notice of intention to file praecipe
to transmit record, and attach a copy of said notice under section 3301(d)(1)(i) of the Divorce
Code: The parties signed Waivers of Notice of Intent to Request Entry of Divorce Decree
M cha 1 A. Scherer, Esquire
Attorney for Plaintiff
FILED-QIr C
OF THE P,4:)THC*WARY
2009 JUN I I PH 3: 00
ctn . 1,." -',,JU
PENNSYLVANIA
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
JESICA A. SMITH
V.
CHRISTOPHER E. SMITH
NO. 2009-943 CIVIL TERM
DIVORCE DECREE
AND NOW, ?J 2j?&, /& _, it is ordered and decreed that
JESICA A. SMITH
plaintiff, and
CHRISTOPHER E. SMITH , 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.")
None.
By Court,
Attest: J.
Prothonotary
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JESICA A. SMITH, IN THE COURT OF COMMON PLEAS
PLAINTIFF, CUMBERLAND COUNTY, PENNSYLVANIA
vs. No. 2009-943 CIVIL TERM c -
CHRISTOPHER E. SMITH, CIVIL ACTION - LAW „m c= `' _
DEFENDANT. : IN CUSTODY
OF COUNSEL WITHOUT LEAVE •--~c `'•
OF COURT (RULE 1012(b)(2)(ii)) c �-
PRAECIPE FOR ENTRY OF APPEARANCE ' -
To the Prothonotary:
Please enter my appearance on behalf of JESICA A. SMITH, Plaintiff. I hereby certify
that his change is not intended to, nor will it, delay this proceeding to the best of my knowledge,
information and belief. Papers may be served at the address set forth below.
Stone, Duncan, & Linsenbach, P.C.
8 N. Baltimore St.
Dillsburg, PA, 17019
P: (717) 432-2089
F: (717) 432-0158
Date: 7/. / i3
Lam D. Truong, Es
Bar ID# 309555
PRAECIPE FOR WITHDRAWAL OF APPERANCE
To the Prothonotary:
Please withdraw my appearance on behalf of JESICA A. SMITH, Plaintiff.
Date: 11 2-1 113
Mich. •1 A. Scherer, Esq.
Bar ID# cIri
Bark Scherer,LL
19 West South Street
Carlisle, PA 17013
JESICA A. SMITH, IN THE COURT OF COMMON PLEAS
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
,
vs. No. 2009-943 CIVIL TERM-t
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CHRISTOPHER E. SMITH, • CIVIL ACTION - LAW z
DEFENDANT : IN CUSTODY r—"
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AGREEMENT AND STIPULATION OF CUSTODY `==s
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THIS AGREEMENT, made this I 1 day of J tit hi , 2013, between
JESICA A. SMITH, hereinafter "Mother", and CHRISTOPHER E. SMITH, hereinafter
"Father", concerns the custody of their Children: TAYLOR L. SMITH, born October 9, 2001,
and BOWEN W. SMITH, born March 2, 2005, hereinafter "Children". Mother and Father
agree and stipulate to the following terms of this Agreement and Stipulation of Custody,
hereinafter"Agreement":
WHEREAS, Plaintiff is the natural mother of Children;
WHEREAS,Defendant is the natural father of Children;
WHEREAS, Mother is represented by Brian C. Linsenbach, Esquire, of Stone, Duncan,
& Linsenbach, P.C.;
WHEREAS, Father is unrepresented;
WHEREAS, Father acknowledges that Stone, Duncan, & Linsenbach, P.C. represents
only Mother's interests in this matter and has given him no legal advice other than that he should
seek the advice of legal counsel;
WHEREAS,the parties intend to be bound by the terms of this Agreement and intend for
this Agreement to be made an Order of Court.
NOW, THEREFORE, it is hereby agreed and stipulated by and between Mother and
Father, intending to be legally bound, as follows:
1. Recitals. The foregoing recitals are incorporated and adopted herein by reference and
form a material part of this Agreement.
2. Legal Custody. Mother and Father shall have shared legal custody of the Children. The
parties shall have an equal right to make all major non-emergency decisions affecting the
Children's general well-being including, but not limited to, all decisions regarding their
health, education, and religion. Pursuant to the terms of 23 Pa.C.S. § 5309, each parent
shall be entitled to all records and information pertaining to the Children including, but
not limited to, medical, dental, religious, or school records, the residence address of the
Children and of the other parent. To the extent one parent has possession of any such
records or information, that parent shall be required to share the same, or copies thereof,
with the other parent within such reasonable time as to make the records and information
of reasonable use to the other parent.
3. Physical Custody. Mother will have primary physical custody of the Children with
father having periods of custody, to coincide with Mother's work schedule, which
changes periodically. A current copy of Mother's work schedule is attached as Exhibit
"A", as an example; therefore, a corresponding schedule shall be, as follows:
a. Beginning Thursday at 7:00 p.m. until Sunday at 6:15 p.m.
b. Then Tuesday at 7:00 p.m. until Thursday at 6:15 p.m.
c. Next week will begin Sunday at 7:00 p.m. through Tuesday at 6:15 p.m.
d. Then Thursday at 7:00 p.m. through Sunday at 6:15 p.m.
2
4. Holidays. The parties shall resume the same schedule for holidays but with drop off
being earlier in the day so that Father has more time with the Children on the holidays.
5. Vacations. Each party shall notify the other party. within two weeks, of any out-of-state
vacation or trips.
6. Transportation. Transportation shall be shared by the parties, with the parent who is to
obtain custody at the time of exchange to provide for transportation from the residence of
the other parent, with the exception that Father shall drop off the child at daycare, if
daycare is needed. At all times, the child shall be secured in appropriate passenger
restraints and transported in a safe vehicle. No person transporting the Children shall
consume alcoholic beverages or illegal substances prior to transporting the Children. No
person transporting the Children shall be under the influence of any alcoholic beverages
or illegal substances while transporting the Children.
7. Late for Exchange. In the event any party is more than 20 minutes late for a scheduled
custody exchange, in the absence of a telephone call or other communication from the
parent picking up the Children, the other party may assume that the parent who is late has
chosen not to exercise that period of custody, the period will be forfeited, and the other
party will be free to make other plans with the Children.
8. Telephone Calls. Both parties are urged to use common sense in scheduling telephone
calls to talk to the Children. Both parties are hereby directed to refrain from preventing
the parent, who may be calling, from talking to the Children, or preventing the Children
3
from calling the other parent, provided that the phone calls are not excessively frequent
or too long in duration that they disrupt the Children's schedule.
9. Disparaging Remarks. Each of the parties and any third party in the presence of the
Children shall take all measures deemed advisable to foster a feeling of affection between
the Children and the other party. Neither parent shall do nor shall either parent permit any
third person to do or say anything which may estrange the Children from the other parent,
their spouse or relatives, or injure the Children's opinion of the other parent or which
may hamper the free and natural development of the Children's love and respect for the
other parent.
10. Financial Care of the Children. In the event that a significant matter arises with respect
to the medical care, education, or financial care of the Children, such as a change in
occupation, health insurance, educational expenses, or residence of the party, those
matters shall be discussed with the other parent before any change is made by either
parent.
11. Mutual Consultation. Each party shall confer with the other on all matters of
importance relating to the Children's health, maintenance, and education with a view
towards obtaining and following a harmonious policy in the Children's education and
social adjustments. Each party agrees to keep the other informed of his or her residence
and telephone number to facilitate communication concerning the welfare of the Children
in visitation. Each party agrees to supply the name, address and phone numbers of any
persons in whose care the Children will be in for a period in excess of seventy-two hours,
and for each person or entity which may provide day care for the Children.
4
12. Illness Of The Children. Emergency decisions regarding the Children shall be made by
the parent then having custody. However, in the event of any emergency or serious
illness of the Children at any time, any party then having custody of the Children shall
immediately communicate with the other party by telephone or any other means practical,
informing the other party of the nature of the illness or emergency, so the other parent
can become involved in the decision making process as soon as practical. During such
illness, each party shall have the right to visit the Children as often as he or she desires,
consistent with the proper medical care of the Children. The term "serious illness" as
used herein shall mean any disability which confines the Children to bed for a period in
excess of seventy-two (72) hours and which places the Children under the direction of a
licensed physician.
13. Welfare Of Children To Be Considered. The welfare and convenience of the Children
shall be the prime consideration of the parties in any application of the provisions of this
Order. Both parents are directed to listen carefully and consider the wishes of the
Children in addressing the custodial schedule, any changes to the schedule, and any other
parenting issues.
14. Illegal Drugs, Alcohol, And Tobacco. The parents shall not possess nor use any illegal
controlled substances in the presence of the Children. The parents shall refrain from
consuming alcoholic beverages to the point of intoxication in the presence of the
Children. The parents shall not use tobacco products in confined spaces while the
Children is present. The parents shall likewise assure that other household members
and/or house guests comply with this prohibition.
5
15. Modification. The parties may modify the terms of this Agreement by mutual consent. In
the absence of mutual consent, the terms of this Agreement shall control.
16. Certification Under 23 Pa.C.S. § 5329. Mother certifies that she has not been charged
with or convicted of an offense enumerated in 23 Pa.C.S. §5329 or an equivalent offense
in another jurisdiction. Father certifies that he has not been charged with or convicted of
an offense enumerated in 23 Pa.C.S. §5329, or an equivalent offense in another
jurisdiction.
17. Relocation. Relocation is defined as a change in a residence of the Children which
significantly impairs the ability of a non-relocating party to exercise custodial rights 23
Pa.C.S. §5322. No relocation shall occur unless every individual who has custody rights
to the Children consents to the proposed relocation or the court approves the proposed
relocation. If a party seeks to relocate, that party shall notify every other individual who
has custody rights to the Children. Both parties must follow the statutory requirements
contained in 23 Pa.C.S. §5337. Specifically, the relocating party must notify every other
individual who has custody rights to the Children by certified mail, return receipt
requested. The notice must then comply with the following requirements:
Notice must be sent no later than:
(1) the 60th day before the date of the proposed relocation; or
(2) the 10th day after the date that the individual knows of the relocation if the
individual did not know and could not reasonably know of the relocation
in sufficient time to comply with the 60 day notice requirement and it is
not reasonably possible to delay the date of relocation so as to comply
with the 60 day notice requirement.
Unless otherwise excused by law, the following information must be included in
the notice:
6
(1) The address of the intended new residence.
(2) The mailing address, if not the same as the address of the intended new
residence.
(3) Names and ages of the individuals in the new residence, including
individuals who intend to live in the new residence.
(4) The home telephone number of the intended new residence, if applicable.
(5) The name of the new school district and school.
(6) The date of the proposed relocation.
(7) The reasons for the proposed relocation.
(8) A proposal for a revised custody schedule.
(9) Any other information which the party proposing the relocation deems
appropriate.
(10) A counter-affidavit as provided under subsection (d)(1) which can be used
to object to the proposed relocation and modification of a custody order.
(11) A warning to the non-relocating party that if the non-relocating party does
not file with the Court an objection to the proposed relocation within 30
days after receipt of notice, that party shall be foreclosed from objecting to
the relocation.
If any of the aforementioned information is not known when the notice is sent but
is later made known to the party seeking the relocation, then that party shall promptly
inform every individual who received notice.
If the non-relocating parent objects to the proposed move, he/she must do so by
filing the counter-affidavit with the Court and the other party within 30 days. The notice
of objection to the opposing party must be sent by certified mail, return receipt requested.
If no objection is made in the manner set forth above, then it shall be presumed that the
non-relocating parent has consented to the proposed relocation and the Court will not
accept testimony challenging the relocation in any further review of the custodial
arrangements.
The Court shall hold an expedited full hearing on the proposed relocation after a
timely objection has been filed and before relocation occurs. The Court may permit
relocation before a full hearing if the Court finds that exigent circumstances exist.
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18. Medical Insurance. Mother shall continue to provide health insurance coverage for the
benefit of the Children so long as it is available through her employment and at a
reasonable cost.
WHEREFORE, the parties agree that this Agreement and Stipulation of Custody shall be
submitted to the York County Court of Common Pleas for entry as a Custody Order. Both
parties acknowledge that they have entered into this Agreement and Stipulation of Custody
voluntarily.
IN WITNESS WHEREOF, the parties hereto have set their hands and seals the day and
year first above written.
WITNESS JE: CA A. SMITH
WITNESS L/ CH STOP ' R E. SMITH
8
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JESICA A. SMITH, IN THE COURT OF COMMON PLEAS
PLAINTIFF, CUMBERLAND COUNTY,PENNSYLVANIA
VS. No.2009-943 CIVIL TERM
CHRISTOPHER E. SMITH, CIVIL ACTION - LAW
DEFENDANT. : IN CUSTODY
ORDER OF COURT
AND NOW, this day of , 2013, upon consideration of the
attached Custody Agreement, it is hereby ordered, adjudged, and decreed that the terms,
conditions, and provisions of the foregoing Custody Agreement, dated July 17, 2013, are
adopted as an Order of Court as if set forth herein at-length.
COURT.
Thomas A.Placey Judge
Common Pleas Jude
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