Loading...
HomeMy WebLinkAbout09-1347to KATHY L. JONES, Plaintiff VS. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. Oq-13N7 ?ivi t Tery" JASON JONES, Defendant CIVIL ACTION - AT LAW - IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the following.pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you, and a decree of divorce, or annulment may be entered against you 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 Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 L KATHY L. JONES, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : No. 06'_ / 3 X17 ?tvw- JASON JONES, CIVIL ACTION - AT LAW - IN DIVORCE Defendant The Plaintiff, Kathy L. Jones, by and through her attorneys, the Law Offices of Patrick F. Lauer, Jr., L.L.C., makes the following Complaint in Divorce: COUNT I - NO-FAULT DIVORCE - §§ 3301(c) or 3301(d) 1. The Plaintiff, Kathy L. Jones, is an adult individual who currently resides at 931 W. Old York Road, Carlisle, Cumberland County, Pennsylvania 17015. 2. The Defendant, Jason Jones, is an adult individual who currently resides at 931 W. Old York Road, Carlisle, Cumberland County, Pennsylvania 17015. 3. The parties have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The parties were married on November 1, 1980, in Carlisle, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties except Cumberland County Docket Number 02-1344, which was terminated on November 14, 2005. 6. The marriage is irretrievably broken. s 7. The Plaintiff has been advised that counseling is available and that the Plaintiff may have the right to request that the court require the parties to participate in counseling. 8. This action is not collusive. WHEREFORE, the Plaintiff requests this Honorable Court enter a Decree of Divorce in this matter. COUNT H - SPOUSAL SUPPORT AND/OR ALIMONY PENDENTE LITE, AND ALIMONY 9. Paragraphs one (1) through eight (8) of this Complaint are incorporated herein by reference as if set forth specifically below. 10. Plaintiff is unable to sustain herself during the course of litigation. 11. Plaintiff lacks sufficient property to provide for her reasonable needs and is unable to sustain herself through appropriate employment. 12. Plaintiff requests the Court to enter an award of spousal support and/or alimony pendente lite until final hearing and thereupon to enter an order of alimony in his favor pursuant to Section 3701(a) and 3702 of the Divorce Code. WHEREFORE, Plaintiff respectfully requests the Court to enter an award of spousal support and/or alimony pendente lite until final hearing and thereupon to enter an order of alimony in his favor pursuant to Section 3701(a) and 3702 of the Divorce Code. COUNT III - EQUITABLE DISTRIBUTION - § 3502(a) 13. Paragraphs one (1) through twelve (12) of this Complaint are incorporated herein by reference as if set forth specifically below. IV 14. During the course of the marriage, the parties acquired property and incurred debt, titled jointly, individually, or both, which remains in the possession of the individual parties. WHEREFORE, the Plaintiff respectfully requests the Court to equitably divide, distribute or assign the marital property between the parties in such proportion as the Court deems just after consideration of all relevant factors and thereby enter an order of equitable distribution of marital property pursuant to § 3502(a) of the Divorce Code. Respectfully Date: 3 3 Marlin L. ey, Esquire La s of Patrick F. Lauer, Jr., L.L.C. 2108 M ket Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 ID# 84745 Tel. (717) 763-1800 KATHY L. JONES, . Plaintiff VS. JASON JONES, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. CIVIL ACTION - AT LAW - IN DIVORCE VFRIFIC'ATInN I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworn falsification to authorities. Date: Signature: Ka y "L- Jo tb . (? (?1 o c ? U) 1. 00 •Q ??, ?' 1 co r KATHY L. JONES, Plaintiff VS. JASON JONES, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 09-1347 - Civil Term CIVIL ACTION - AT LAW - IN DIVORCE Defendant AFFIDAVIT OF SERVICE TO THE PROTHONOTARY: I, Marlin L. Markley, Esquire, verify the Complaint in Divorce has been served upon the Defendant indicated above by first class, certified mail # 7002-2410-0002-0986-1192, restricted delivery, return receipt requested, prepaid postage, pursuant to the requirements of Pa ILC,_".'1L1 A A b Fn 4 f S Icted Delivery is deed. t P*A your name and address on the reverse _ so that we can return the card to you. t Aftach this card to the back of the mailpiec:e, ., or on the front if space permits. 1. Article Addressed to: `i :37(xSow- Tones Q 31 W. Did ? pe K Roca w X B. ecelved by (Pri Name) C. W6 of Ddmy D. Is delivery address dMerent from item) 1? D tta If YE address below: ? No Cr 1 S l c-> ?A I -1 o 5 74FRes ? an v Express Mail O Retum Reoeipt far NMala-i N d Mail 0 C.O.D. d Delivery? (Extra Fee) Alftle #600W 7002 2410 0002 0986 1192 pe po" W 1, now ry am DonrssMc Ram Racalpt ,aaslr+l?r ?Me Date: 3 1 v 2U(q Marlin L. M , squire Law O lees Patrick F. Lauer, Jr., LLC 2108 Market et, Aztec Building Camp Hill, Pennsylvania 17011-4706 ID# 84745 Tel. (717) 763-1800 r I4 t T` t-? P"a KATHY L. JONES, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : No. 09-1347 Civil Term JASON JONES, CIVIL ACTION - AT LAW - IN DIVORCE Defendant I, Jason Jones, Defendant in the above-captioned matter, accept service of the COMPLAINT IN DIVORCE pursuant to Pennsylvania Rule of Civil Procedure, Rule 1930.4(d). --? J"" Q"' Jason nes 3,16 2?_2 Date: f F ?'i i KATHY L. JONES, Plaintiff/Petitioner V. JASON JONES, Defendant/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : No. 09-1347 -Civil Term : CIVIL ACTION - AT LAW - IN DIVORCE PETITION FOR ALIMONY PENDENTE LITE AND NOW, comes the Plaintiff, Kathy L. Jones, by and through his attorney's, the Law Offices of Patrick F. Lauer, Jr., L.L.C., and files this Motion and in support thereof, avers as follows: 1. Petitioner, Kathy L. Jones is an adult individual residing at 264 West Penn Street, Carlisle, Cumberland County, Pennsylvania. Petitioner's date of bith is May 13, 1964, and her social security number is 186-54-6472. Respondent, Jason Jones is an adult individual residing at 931 W. Old York Road, Carlisle, Cumberland County, Pennsylvania. Respndent's date of bith is October 6, 1957, and his social security number is 175-48-4090. 2. The petition of Kathy L. Jones respectfully represents that on March 4, 2009, Petitioner filed Divorce Complaint including a Count for Spousal Support and/or Alimony Pendent Lite, and Alimony. A copy of the Divorce Complaint is attached to this petition. WHEREFORE, Petitioner requests that the Court order alimony pendente lite. Respectfully Date: Q Pck F. Lau E _ L 4,w Offices of Patrick F. Lauer, Jr., LLC 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 ID# 46430 Tel. (717) 7631800 KATHY L. JONES, Plaintiff/Petitioner V. JASON JONES, Defendant/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 09-1347 - Civil Term CIVIL ACTION - AT LAW - IN DIVORCE VERIFICATION I verify that the statements made in this Petition for Alimony Pendente Lite are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unworn falsification to authorities. Date Id KATHY L. JONES, - Plaintiff. VS. JASON JONES, . Defendant : IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA :No. 09 - 1341 0_ivi i e' 1 CIVIL ACTION - AT LAW - IN DIVORCE NOTICE. TO DEFEND AND CLAIM RIGHTS You have been sued in court. If .you. wish to defend against the claims set forth in the following.pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you, and a decree of divorce, or annulment may be entered against you by the court. A judgment may also be entered against you for any other clam 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 Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD. TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU-DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. ' CUMBERLAND. COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 o (717) 249-3166 C KATHY L. JONES, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA . VS. No. JASON JONES, CIVIL ACTION - AT LAW - IN DIVORCE Defendant DIVORCE COMPLAINT The Plaintiff, Kathy L. Jones, by and through her attorneys, the Law Offices of Patrick F. Lauer, Jr., L.L.C., makes the following Complaint in Divorce: COUNT I - NO-FAULT DIVORCE - §§ 3301(c) or 3301(d) 1. The Plaintiff, Kathy L. Jones, is an adult individual who currently resides at 931 W. Old York Road, Carlisle, Cumberland County, Pennsylvania 17015. 2. The Defendant, Jason Jones, is an adult individual who currently resides at 931 W. Old York Road, Carlisle, Cumberland County, Pennsylvania 17015. 3. The parties have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The parties were married on November 1, 1980, in Carlisle, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties except Cumberland County Docket Number 02-1344, which was terminated on November 14, 2005. 6. The marriage is irretrievably broken. 7. The Plaintiff has been advised that counseling is available and that the Plaintiff ma; have the right to request that the court require the parties to participate in counseling. 8. This action is not collusive. WHEREFORE, the Plaintiff requests this Honorable Court enter a Decree of Divorce in this matter. COUNT II - SPOUSAL SUPPORT AND/OR ALIMONY PENDENTE LITE, AND ALIMONY 9. Paragraphs one (1) through eight (8) of this Complaint are incorporated herein by reference as if set forth specifically below. 10. Plaintiff is unable to sustain herself during the course of litigation. 11. Plaintiff lacks sufficient property to provide for her reasonable needs and is unable to sustain herself through appropriate employment, 12. Plaintiff requests the Court to enter an award of spousal support and/or alimony pendente. lite until final hearing and thereupon to enter an order of alimony in his favor pursuant to Section 3701(a) and 3702 of the Divorce Code. WHEREFORE, Plaintiff respectfully. requests the Court to enter an award of spousal support and/or alimony pendente lite until final hearing and thereupon to enter an order of alimony in his favor pursuant to Section 3701(a) and 3702 of the Divorce Code. COUNT III - EQUITABLE DISTRIBUTION - § 3502(a) 13. Paragraphs one (1) through twelve (12) of this Complaint are incorporated herein by reference as if set forth specifically below. 14. During the course of the marriage, the parties acquired property and incurred debt titled jointly, individually, or both, which remains in the possession of the individual parties. WHEREFORE, the Plaintiff respectfully requests the Court to equitably divide, distribute of assign the marital property between the parties in such proportion as the Court deems just aftei consideration of :all'relevant factors 'and thereby enter an order of equitable distribution of marital property pursuant to § 3502.(a) of the Divorce Code. Date: 31,3JOI Respectfully Marlin ret ey, Esquire La atrick F. Lauer, Jr., L.L.C. 2108 M. eet, Azt ec Building Camp Hill, Pennsylvania 17011-4706 IN 84745 Tel. (717) 763-1800 1 KATHY L. JONES; . Plaintiff vs. JASON JONES, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA No. CIVIL ACTION - AT LAW - IN DIVORCE YXRM(''ATfinN I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to. the penalties of 18 Pa.C.S. § 4904, relating to unworn. falsification to authorities. Dater Signature: K y L. Jo V ..,a Y 3 •r KATHY L. JONES, PlaintifflPetitioner V. JASON JONES, Defendant/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : No. 09-1347 -Civil Term : CIVIL ACTION - AT LAW - IN DIVORCE PACSES Case: 627110768 -ORDER OF COURT AND NOW, this 31 st day of march 2009, based upon the consideration of the attached Petition to Modify Alimony Pendente Lite, it is hereby directed that the parties and their respective counsel appear before R J Shaddayon 0441 I409 at 10: 30AM for a conference, after which the conference officer may recommend that an order for Alimony Pendente Lite be entered. You are further ordered to bring to the conference: (1) a true copy of your most recent Federal Income Tax Return, including W-2's as filed. (2) your pay stub for the proceeding six (6) months. (3) the Income and Expense Statement attached to this order, completed as required by Rule 1910.1 1(c). (4) verification of child care expenses. (5) proof of medical coverage which you may have, or may have available to you. If you fail to appear for the conference or to bring the required documents, the court may issue a warrant for your arrest. BY THE COURT, )T,.,B,. Baylor sident Judge Date of Order MAR 3 12009 .,, . J. d , Conference O YOU S HOULD TAKE THIS PAPER TO YOUR LA R AT ONCE. IF YOrj HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFI E SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland. County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 FILED r,4.F OF ! HE FR 2009 MAR 31 Pl l 2: L, 2 CUI , TV P. Richard Wagner, Esquire PA Supreme Court I.D. #23103 Mancke, Wagner, Spreha & McQuillan 2233 North Front Street Harrisburg, PA 17110 Telephone (717) 234-7051 Fax(717)234-7080 Attorney For Petitioner KATHY L. JONES, Plaintiff, Respondent, V. JASON JONES, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: 09-1347 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE Defendant/Petitioner. PETITION FOR SPECIAL RELIEF AND NOW, comes the Defendant/Petitioner, by and through his attorneys, Mancke, Wagner, Spreha and McQuillan, and files the following Petition For Special Relief: 1. Your Petitioner, Jason Jones, is the Defendant in the above-captioned matter. 2. The Respondent, Kathy L. Jones, is the Plaintiff in the above-captioned matter. 3. The parties are owners of joint property situate at 9931 W. Old York Road, Carlisle, Cumberland County, Pennsylvania (the marital home). 4. The Plaintiff/Respondent herein removed herself from the marital home without cause, and without justification. 5. The Plaintiff/Respondent moved from the marital home in approximately March of 2009 and moved to an address with another man not a blood relative. 6. From time to time, she has returned to the marital home and removed items of personal property from the home, said personal property being marital property in nature. 7. Defendant/Petitioner is not at home during the day, operates a farm, and cannot be vigilant as to the removal of property from time to time that has been occurring. 8. Defendant/Petitioner believes and therefore avers that the Plaintiff/Respondent is removing personal property that is marital in nature for which the Defendant/Petitioner has no remedy to prevent. WHEREFORE, Defendant/Petitioner requests the Court to grant relief in the form of directing that the Plaintiff/Respondent refrain from removing or transferring any personal property from the marital home, pending equitable distribution of the same through the appropriate legal proceedings. P. Richard Wagner, Esquire I.D. #23103 2233 North Front Street Harrisburg, PA 17110 Attorneys For Defendant/Petitioner Date: " ?' -2- VERIFICATION I verify that the statements made in the foregoing document 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: 3 `? 0 OF THE: pl-?^-p Y'IY)TARY 2009 APR -6 Fs 3: 06 KATHY L. JONES, VS. JASON JONES, THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE NO. 09-1347 CIVIL TERM IN DIVORCE PACSES CASE NO: 627110768 AND NOW, this 13th d and/or counsel fees, it is hereby c May 7.2009 at 1:30 P.M. for a officer may recommend that an date of April 13, 2009. of April 2009, upon consideration of the Petition for Alimony Pendente Lite acted that the parties and their respective counsel appear before R.J. Shaddav on nference, at 13 N. Hanover St., Carlisle, PA 17013, after which the conference ler for Alimony Pendente Lite be entered. This date replaces the prior conference YOU are further ordered jo bring to the conference: (1) a true copy of your st recent Federal Income Tax Return, including W-2's as filed (2) your pay stubs for the six (6) months (3) the Income and Expe se Statement attached to this order, completed as required by Rule 1910.11© (4) verification of child are expenses (5) proof of medical cov rage which you may have, or may have available to you (6) IF you fail to appear for warrant for your arrest. conference or bring the required documents, the Court may issue a BY THE COURT, Edgar B. Bayley, President Judge Date of Order: April 13, 2009 Copies mailed to: Petitioner Respondent Marlin L. N P. RichardI YOU HAVE THE RIGHT TO REPRESENT YOU. IF YOU ] TELEPHONE THE OFFICE HELP. , -fi /I ///, ? , /' 0 ?r ( J. S ray, onference Officer Esq. Esq. LAWYER, WHO MAY ATTEND THE CONFERENCE AND 1 NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR T FORTH BELOW TO FIND OUT WHERE YOU MAY GET LEGAL BERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVE. CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 cc361 FI a TNttY 2009 APR 13 PM 3: 22 cu N 1NVA A ,w w APR 0.7'20006 P. Richard Wagner, Esquire PA Supreme Court I.D. #23103 Mancke, Wagner, Spreha & McQuillan 2233 North Front Street Harrisburg, PA 17110 Telephone (717) 234-7051 Fax(717)234-7080 Attorney For Petitioner KATHY L. JONES, V. Plaintiff, Respondent, JASON JONES, Defendant/Petitioner. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO: 09-1347 CIVIL TERM CIVIL ACTION - LAW : IN DIVORCE ORDER AND NOW, thi day of 2009, upon Petition of the Defendant, Jason Jones, a Rule is hereby issued upon the Plaintiff to show cause why, if any, the (Z,4 / ?dN 6-s y relief requested should not be granted. RULE RETURNABLE BY T: J. D' bution: y1 R1'chard Wagner, Esq., 2233 North Front St., Harrisburg PA 17110 , ,Arlin L. Markley, Esq., 2108 Market St., Camp Hill PA 17011 O Court Adminstrator 0 t:? f +". E? t '? ? l f ?? E i ?d ? 600Z KATHY L. JONES, VS. IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : No. 09-1347 Civil Term JASON JONES, Defendant : CIVIL ACTION - AT LAW - IN DIVORCE PRAECIPE TO WITHDRAW AS COUNSEL Kindly withdraw my appearance as counsel for Kathy L. Jones, Plaintiff with regard to the above-captioned matter. Date: 4- t 7- 2 a a l Marlin E. arkley, Esquire Law Offic of Patrick F. Lauer, Jr., L.L.C. 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 ID# 84745 Tel. (717) 763-1800 Attorney Withdrawing PRAECIPE TO ENTER APPEARANCE AS COUNSEL Kindly enter my appearance on behalf of Kathy L. Jones, Plaintiff with regard to the above captioned matter. Date: ? - 1 ? 2 ?1- 0 Marlin L kley, Esquire Attorney ,YD. No. 84745 112 Market Street, 6t' Floor Harrisburg, PA 17101 Telephone (717) 236-9391 Facsimile (717) 236-6602 Attorney Entering Appearance FILED-- ., r ; OF THE "-?, ,"' 'CRY 2009 APR 2 1 Are : 2 0 FENN SYs.lA A r? KATHY L. JONES, Plaintiff/Petitioner VS. JASON L. JONES, Defendant/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE NO. 09-1347 CIVIL TERM IN DIVORCE PACSES Case No: 627110768 ORDER OF CQURT AND NOW, this 20th day of May 2009, based upon the Court's determination that the Petitioner's monthly net income/earning capacity is $ 1,551.57 and the Respondent's monthly net income/earning capacity is $ 5,63 it is hereby ordered that the Respondent pay to the Pennsylvania State Collection and Disbursement Unit One Thousand Six Hundred and 00/100 Dollars ($ 1,600.00) per month payable monthly as follows: $ 1,600.00 per month for Alimony Pendente Lite and $ 0.00 per month on arrears. First payment due: in accordance with Respondent's pay schedule. The effective date of the order is March 27, 2009. Arrears set at $ 3,463.01 as of May 20, 2009. Failure to make each payment on time and in full will cause all arrears to become subject to immediate collection by all of the means as provided by 23 Pa.C.S.§ 3703. Further, if the Court finds, after hearing, that the Respondent has willfully failed to comply with this Order, it may declare the Respondent in civil contempt of Court and, at its discretion, make an appropriate Order, including, but not limited to, commitment of the Respondent to prison for a period not to exceed six months. Said money to be turned over by the PA SCDU to: Kathy L. Jones. Payments must be made by check or money order. All checks and money orders must be made payable to PA SCDU and mailed to: PA SCDU P.O. Box 69110 Harrisburg, PA 17106-9110 Payments must include the Respondent's name with their PACSES Member Number or Social Security Number in order to be processed. Do not send cash by mail. cc360 The monthly support obligation includes cash medical support in the amount of $250 annually for unreimbursed medical expenses incurred for the obligee. Unreimbursed medical expenses of the obligee that exceed $250 annually shall be allocated between the parties. The party seeking allocation of unreimbursed medical expenses must provide documentation of expenses to the other no later than March 31" of the year following the calendar year in which the final medical bill to be allocated was received. The unreimbursed medical expenses are to be paid as follows: 78 % by the Respondent and 22 % by the Petitioner. [X] Respondent [] Petitioner to provide medical insurance coverage. Within thirty (30) days after the entry of this order, the [] Petitioner [X] Respondent shall submit written proof that the medical insurance coverage has been obtained or that application for coverage has been made. Proof of coverage shall consist of, at a minimum of: 1) the name of the health care coverage provide(s); 2) any applicable identification numbers; 3) any cards evidencing coverage; 4) the address to which claims should be made; 5) a description of any restrictions on usage, such as prior approval for hospital admissions, and the manner of obtaining approval; 6) a copy of the benefit booklet or coverage contract; 7) a description of all deductibles and co-payments; and 8) five copies of any claim forms. The Respondent is to report any direct payment to the Petitioner or any expenses that have been paid on her behalf since the filing date of March 27, 2009 that may be credited to the retroactive arrearage. The Respondent shall report to the Domestic Relations Officer a payment plan to liquidate any remaining arrears within ten (10) days from this date. This Order shall become final twenty (20) after the mailing of the notice of the entry of the Order to the parties unless either party files a written demand with the Prothonotary for a hearing de novo before the Court. Consented: Petitioner Respondent Petitioner's Attorney Respondent's Attorney Mailed copies on: May 20, 2009 to: Petitioner Respondent Patrick F. Lauer, Jr., Esq. P. Richard Wagner, Esq. DRO: R.J. Shadday BY THE COURT, KATHY L. JONES, Plaintiff/Petitioner VS. JASON L. JONES, Defendant/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE NO. 09-1347 CIVIL TERM IN DIVORCE PACSES Case No: 627110768 NOTICE OF RIGHT TO REQUEST A HEARING The parties are hereby advised that they have until June 12, to request a hearing do novo before the Court. File request in person at: Office of the Prothonotary 1 Courthouse Square Carlisle, PA 17013 Or mail to: Office of the Prothonotary 1 Courthouse Square Carlisle, PA 17013 CC363 ML9 4 ?,ni 22 Fw : 1, 6 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION KATHY L. JONES ) Docket Number 09-1347 CIVIL Plaintiff ) VS. ) PACSES Case Number 627110768 JASON L. JONES ) Defendant ) Other State ID Number ORDER TO CREDIT ARREARS AND NOW, on this 18TH DAY OF JUNE, 2009 IT IS HEREBY ORDERED that credit be given on the above captioned case in the amount of $ 8 0 0.0 0 There ® is O is not an agreement of the parties to the credit. This credit is for: ® Direct Payments. ? Purchases made or services performed by the Defendant on behalf of the Plaintiff or children. ? Time children resided with the Defendant as agreed upon by parties, or addressed in a partial custody order for the following time periods: From to From to From to ? Other: Plaintiff Defendant 18TH DAY OF JUNE, 2009 Date DRO: R.J. SHADDAY Service Type M Date Date BY THE COURT: • JUDGE Form FI-002 Rev. I Worker ID 21005 r r w, ?.r 2? 23 Pill " In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION KATHY L. JONES ) Docket Number 09-1347 CIVIL Plaintiff ) VS. ) PACSES Case Number 627110768 JASON L. JONES ) Defendant ) Other State ID Number Order AND NOW to wit, this JUNE 18, 2009 it is hereby Ordered that: PURSUANT TO THE MAY 20, 2009 ORDER AND THE RESPONDENT NOT RESPONDING WITH A PAYMENT PLAN TO LIQUIDATE THE RETROACTIVE ARREARS, DEFENDANT SHALL PAY AN ADDITIONAL SUM OF $100.00 PER MONTH ON THE CURRENT BALANCE OF $2,263.01 AS OF THIS DATE. DRO: R.J. SHADDAY Form OE-520 Service Type M Worker ID 21005 BY THE COURT: OF THE 2CC9 jE"4 25 P 3: 23 'v' ! ?:?,Ily KATHY L. JONES, Plaintiff/Petitioner VS. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE NO. 09-1347 CIVIL TERM c JASON JONES, IN DIVORCE -o: Defendant/Respondent PACSES CASE: 627110768 mrQn ?r - ORDER OF COURT -o A c'7 ? ?c:: ? --i N ? AND NOW to wit, this 8th day of April, 2011, it is hereby Ordered that the Alimony CD rnr- ?rn 00 --A C3 ?-n o-n- --trn :Z) Pendente Lite order is terminated, effective February 7, 2011, pursuant to the parties' Separation and Property Settlement Agreement. The account is closed with a credit in the amount of -$ 1,284.38. This Order shall become final twenty (20) days after the mailing of the notices of the entry of the Order to the parties unless either parry files a written demand with the Office of the Prothonotary for a hearing de novo before the Court. BY THE COURT: DRO: R.J. Shadday xc: Petitioner Respondent P. Richard Wagner, Esq. Marlin L. Markley, Esq. Form OE-001 Service Type: M Worker: 21005 "LED-OFFICE ` CE 6'Ct "THONOW-),y 2011 APR 21 AM 11: 2!-d CUMBERLAND COUNTY PENNSYLVANIA KATHY L. JONES, : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, : V. NO. 2009-1347 -CIVIL TERM CIVIL ACTION -LAW JASON JONES IN DIVORCE Defendant. AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on March 4, 2009.. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 4. 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. 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 unworn falsification to authorities. Date: OrLAIfy-1 )"n? Jason J es 2011 APR 21 AM 11: 25 C,UMB£RLAND COUNTY KATHY L. JONES, PENINSJ &COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, V. JASON JONES, Defendant. : NO. 2009-1347 -CIVIL TERM CIVIL ACTION - LAW : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unworn falsification to authorities. UC2.4? Jaso ones DATE: q' 13 - // KATHY L. JONES, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 09-1347 Civil Term JASON JONES, CIVIL ACTION - AT LAW - IN DIVORCE Defendant I, Jason Jones, Defendant in the above-captioned matter, accept service of the COMPLAINT IN DIVORCE pursuant to Pennsylvania Rule of Civil Procedure, Rule 1930.4(d). Date: y? Jason,16/nes ?' r John J. Mangan, Esquire Bayley & Mangan I.D.#87000 17 W. South Street Carlisle, PA 17013 (717) 241-2446 Attorney For Plaintiff KATHY L. JONES, Plaintiff, V. JASON JONES, Defendant. TO THE PROTHONOTARY: : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 2009-1347 - CIVIL TERM CIVIL ACTION -LAW IN DIVORCE PRAECIPE Please withdraw Counts II and III of Plaintiff's Complaint. Respectfully Submitted: Bayley & Mangan --- //// 1!e ............... By: Jo J. angan, Esq. I. r# 000 17 W. outh Street Carlisle, PA 17013 (717) 241-2446 r Cl Date: i• KATHY L. JONES IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL DIVISION JASON JONES NO. 2009-1347 CIVIL TERM PRAECIPE TO TRANSMIT RECORD rn rf, To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a di decree: C-) ? c> 1. Ground for divorce: Z: Irre 'evable breakdown under § (3301(c)) and -w N r.? C 1-T1 F C:) --r-P ?- F C) rr• § (33 1)) of the Divorce Code. (Stri a ou inapplicable section.) 2. Date and manner of service of the complaint: by Acceptance of Service, a copy of which is attached hereto. 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by § 3301(c) of the Divorce code: by plaintiffApril 4, 2011 ; by defendant April 13, 2011 (b) (1) Date of execution of the affidavit required by § 3301(d) of the Divorce Code: (2) Date of filing and service of the plaintiffs § 3301(d) affidavit upon the respondent opposing party: 4. Related claims pending: None 5. Complete either (a) or (b) (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: (b) Date plaintiffs Waiver of Notice was filed with the Prothonotary: April 15, 2011 Date defendant's Waiver of Notice was filed with the Prothonotary: April 19, 2011 A l me fendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KATHY L. JONES V. JASON JONES : NO. 2009-1347 - CIVIL TERM DIVORCE DECREE AND NOW, )-all , it is ordered and decreed that KATHY L. JO ES , plaintiff, and JASON JONES , 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 the Court, SN,i- Oerf . &py nxu led 4c a Maw, NOice +eoftj m,, led ?o &ttq wt?