HomeMy WebLinkAbout01-0068JOHN M. RItOADES, JR.,
.Plaintiff
REBECCA J. RHOADES,
Defendant
IN THE COURT OF COMMON PLEAS OF
:
: CUMBERLAND COUNTY, PENNSYLVANIA
._
CIVIL ACTION - LAW
: 2001- CIVIL TERM
,,
: IN DIVORCE
NOTICE
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 in 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 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, Cumberland County Courthouse, Carlisle, Pennsylvania 17013.
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
2 Liberty Avenue
Carlisle, Pennsylvania 17013
717-249-3166
1-800-990-9108
AMERICANS WITH DISABILITIES
ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with
the Americans with Disabilities Act of 1990. For information about accessible facilities and
reasonable accommodations available to disabled individuals having business before the court,
please contact our office. All arrangements must be made at least 72 hours prior to any heating
or business before the court. You must attend the scheduled conference or heating.
JOHN M. RHOADES, JR.,
Plaintiff
REBECCA J. RHOADES,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
2001- & ~ CIVIL TERM
1N DIVORCE
COMPLAINT IN DIVORCE PURSUANT TO SECTION 3301(c)
O~.F THE DIVORCE CODE
NOW comes the plaintiff, John M. Rhoades, Jr., by his attorney, Marcus A. McKnight, III,
Esquire, and files this Complaim in Divorce against the defendant, Rebecca J. Rhoades, representing
as follows:
1. The plaimiff is John M. Rhoades, Jr., an adult individual residing at 211 Pine School Road,
Gardners, Cumberland County, Pennsylvania 17324.
2. The defendant is Rebecca J. Rhoades, an adult individual residing at 951 North Middleton
Road, Carlisle, Cumberland County, Pennsylvania 17013.
3. The plaintiff has been a resident of the Commonwealth of Pennsylvania at least six months
prior to the filing of this action in divorce.
4. The plaimiff and the defendant were married on July 29, 1994, in Carlisle, Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the parties.
6. Pursuant to the Divorce Code, Section 3301(c), the plaintiff avers as the grounds upon which
this action is based that the marriage between the parties is irretrievably broken.
7. The plaintiff avers that he has been advised of the availability of counseling and that said
party has the right to request that the court require the parties to participate in counseling.
WHEREFORE, the plaintiff demands judgment dissolving the marriage between the two
parties.
Date: January 2, 2001
Respectfu~mbmitted,
By../:,
,M~us A.~ Mc~~ tsqmre
A~orney for P~ttiff
West Pomfret Professional Building
60 West Pomfret Street
Carlisle, Pennsylvania 17013-3222
(717) 249-2353
Supreme Court I.D. No. 25476
VERIFICATION
The foregoing Complaint in Divorce is based upon information which has been gathered
by my counsel and me in the preparation of this action. I have read the statements made in this
Complaint and they are true and correct to the best of my knowledge, information and belief. I
understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section
4904, relating to unsworn falsification to authorities.
HN M. RHOADES, JR. ~/
Date: January 2, 2001
JOHN M. RHOADES, JR.,
Plaintiff
REBECCA J. RHOADES,
Defendant
IN THE COURT OF COMMON PLEAS OF
;
: CUMBERLAND COUNTY, PENNSYLVANIA
:
CIVIL ACTION - LAW
:
2001-68 CIVIL TERM
:
IN DIVORCE
PLAINTIFF'S AFFIDAVIT OF CONSENT
1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on
January 3, 2001.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have
elapsed t~om the date of the filing of the complaint.
3. I consent to the entry of a final decree in divorce.
4. I understand that I may lose fights concerning alimony, division of property, lawyer's
fees or expenses ifI do not claim them before a divorce is granted.
I verify that the statements made in this affidavit are tree and correct. I understand that
false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to
unswom falsification to authorities.
Date: /-//- ~ ,2001
JOHN M. RHOADES, JR.,
Plaintiff
REBECCA J. RHOADES,
Defendant
: IN THE COURT OF COMMON PLEAS OF
:
: CUMBERLAND COUNTY, PENNSYLVANIA
:
CIVIL ACTION - LAW
:
2001-68 CIVIL TERM
:
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301(c) OF THE DIVORCE CODE
1. I consent to the entry ora final Decn'ee of Divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses ifI 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 tree and correct. I understand that
false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unswom falsification to authorities.
Date: ~/-- ~ ,2001
JOHN M. RHOADES, JR.,
Plaintiff
REBECCA J. RHOADES,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
CIVIL ACTION - LAW
:
2001-68 CIVIL TERM
:
IN DIVORCE
PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT
The plaintiff, being duly sworn according to law, deposes and says:
1. I have been advised of the availability of marriage counseling and understand that I
may request that the court require that my spouse and I participate in counseling.
2. I understand that the court maintains a list of marriage counselors in the Prothonotary's
Office, which list is available to me upon request.
3. Being so advised, I do not request that the court require that my spouse and I
participate in counseling prior to a divorce decree being handed down.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unswom falsification to authorities.
Date: ~//J ~ ,2001
M. RHOADES, JR. j
JOHN M. RHOADES, JR.,
Plaintiff
REBECCA J. RHOADES,
Defendant
IN THE COURT OF COMMON PLEAS OF
;
: CUMBERLAND COUNTY, PENNSYLVANIA
:
CIVIL ACTION - LAW
:
2001-68 CIVIL TERM
:
IN DIVORCE
DEFENDANT'S AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
January 3, 2001.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have
elapsed from the date of the filing of the complaint.
3. I consent to the entry of a final decree in divorce.
4. I understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses ifI 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 made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to
unswom falsification to authorities.
JOHN M, RHOADES, JR.,
Plaintiff
REBECCA J. RHOADES,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
2001-68 CML TERM
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUEST
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 ifI 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 tree and correct. I understand that
false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unswom falsification to authorities.
Date: ,2001
Defendant
JOHN M. RHOADES, JIL,
Plaintiff
REBECCA J. RHOADES,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
2001-68 CIVIL TERM
IN DIVORCE
DEFENDANT'S MARRIAGE COUNSELING AFFIDAVIT
The defendant, being duly sworn according to law, deposes and says:
1. I have been advised of the ava/lability of marriage counseling and understand that I
may request that the court require that my spouse and I participate in counseling.
2. I understand that the court ma/nta/ns a list of marriage counselors in the Prothonotary's
Office, which list is available to me upon request.
3. Being so advised, I do not request that the court require that my spouse and I
participate in counseling prior to a divorce decree being handed down.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
Date: ,2001
JOHN M. RHOADES, JR.
PLAINTIFF
REBECCA J. RHOADES,
DEFENDANT
: IN THE COURT OF COMMON PLEAS OF
:
: CUMBERLAND COUNTY, PENNSYLVANIA
:
CIVIL ACTION - LAW
2001-68 CIVIL TERM
IN DIVORCE
ACCEPTANCE OF SERVICE
I, Rebecca J. Rhoades, defendant in the above-captioned action, hereby agree to accept
service of the Complaint in Divorce, docket number 2001-68, which was filed on January 3,
2001.
Defendant
951 North Middleton Road
Carlisle, PA 17013
Date: /'-/,f'"~ . 2001
SOCIAL SECURITY INFORMATION SHEET
PURSUANT TO 23 Pa.C.S.A. SECTION 4304.1 (a) (3) ALL DIVORCES MUST
INCLUDE THE PARTIES SOCIAL SECURITY NUMBER
PLEASE FILL IN THE APPROPRIATE INFORMATION AND RETURN TO THE
PROTHONOTARY'S OFFICE
DATE: APRIL 10, 2001
DOCKET NUMBER: 2001-68 CIVIL TERM
PLAINTIFF~ SS# 166-66-6656
NAME: JOHN M. RHOADES, JR.
DEFENDANT~ SS # 205-62-5138
NAME: REBEGCA J. RHOADES
JOHN M. RHOADES, JR.,
Plaintiff
REBECCA J. RHOADES,
Defendant
IN TIlE COURT OF COMMON PLEAS OF
:
: CUMBERLAND COUNTY, PENNSYLVANIA
:
CIVIL ACTION - LAW
:
2001-68 CIVIL TERM
:
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
To the Prothonotaxy:
Transmit the record, together with the following information, to the court for enlry 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 complaint: A certified copy of the Complaint in Divorce was served upon
the defendant, Rebecca J. Rhoades, on January 15 2001, and is evidenced by the Acceptance of Service signed by
hot on that date and filed with the Court on January 23, 2001.
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: April 2, 2001; by defendant: April 6, 2001.
(b)(l) Date of execution of the affidavit required by Section 3301(d) of the Divorce Code:
(b)(2) Date of filing and service of the plaintiffs affidavit upon the defendant:
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 in Section 3301(c) Divorce was filed with the
Prothonotary: April 10, 2001.
Notice in Section 3 l(c) Divo e was filed with the
Prothonotary: April 10, 2001.
, ESQUIRE
Attorney for Piaf~t~f
M/IRRL4GE SETTLEMENT AGREEMENT
THIS AGREEMENT made this q~'/~ day of January, 2001, by and between
REBECCA J. RHOADES (hereinafter referred to as "WIFE") and JOHN M. RHOADES, JR.
(hereinafter referred to as "HUSBAND").
WITNESSETH:
WHEREAS, HUSBAND and WIFE were lawfully married on July 29, 1994, in
Cumberland County, Pennsylvania, and were separated on June 30, 1998.
The parties hereto agree and covenant as follows:
The parties intend to maintain separate and permanent domiciles and to live apart from
each other. It is the intent and purpose of this Agreement to set forth the respective rights and
duties of the parties while they continue to live apart from each other.
The parties have attempted to divide their matrimonial property in a manner which
conforms to a just and right standard, with due regard to the rights of each party, It is the intent
of the parties that such division shall be final and shall forever determine their respective rights.
The division of existing marital property is not intended by the parties to constitute in any way a
sale or exchange of assets.
Further, the parties agree to continue living separately and apart from the other at any
place or places that he or she may select as they have heretofore been doing. Neither party shall
molest, harass, annoy, injure, threaten or interfere with the other party in any matter whatsoever.
Each party may carry on and engage in any employment, profession, business or other activity as
he or she may deem advisable for his or her sole use and benefit. Neither party shall interfere
with the uses, ownership, enjoyment or disposition of any property now owned and not specified
herein or property hereafter acquired by the other.
The consideration for this contract and agreement is the mutual benefit to be obtained by
both of the parties hereto and the covenants and agreements of each of the parties to the other.
The adequacy of the consideration for all agreements herein contained is stipulated, confessed,
and admitted by the parties, and the parties intend to be legally bound hereby.
Each party to the Agreement acknowledges and declares that he or she, respectively:
a. HUSI~ANI) is represented by Irwin, McKnight & Hughes and WIFE chooses
not to be represented by counsel;
b. is fully and completely informed of the facts relating to the subject matter of
this Agreement and of the rights and liabilities of the parties;
c, enters into this Agreement voluntarily after receiving the advice of counsel or
chooses not to consult an attorney;
d. has given careful and mature thought to the making of this Agreement;
e. has carefully read each provision of this Agreement; and
f. fully and completely understands each provision of this Agreement, both as to
the subject matter and legal effect.
This Agreement shall become effective immediately as of the date of execution.
It is the purpose and intent of this Agreement to settle forever and completely the interest
and obligations of the parties in all property that they own separately, and all property that would
qualify as marital property under the Pennsylvania Divorce Code, Title 23, Section 401(e), and
that is referred to in this Agreement as "Marital Property", as between themselves, their heirs and
assigns. The parties have attempted to divide their Marital Property in a manner that conforms to
a just and fair standard, with due regard to the rights of each Party. The division of existing
Marital Property is not intended by the parties to constitute in any way a sale or exchange of
assets, and the division is being effected without the introduction of outside funds or other
property not constituting a part of the marital estate.
It is the further purpose of this Agreement to settle forever and completely any obligation
under the Pennsylvania Divorce Code relating to spousal support or alimony.
Each paxty represents and warrants that he or she has made a full and fair disclosure to the
other of all of his or her property interests of any nature, including any mortgage, pledge, lien,
charge, security interest, encumbrance, or restriction to which any property is subject. Each party
further represents that he or she has made a full and fair disclosure of all debts and obligations of
any nature for which he or she is currently liable or may become liable. Each further represents
and warrants that he or she has not made any gifts or transfers for inadequate consideration of
Marital Property without the prior consent of the other.
Each Party acknowledges that, to the extent desired, he or she has had access to all joint
and separate State and Federal Tax Returns filed by or on behalf of either or both Parties during
marriage.
MARITAL DEBTS & BANKRUPTCY: Each party will be responsible for their own
debt incurred after the date of separation. HUSBAND will be solely responsible for his
outstanding debts and agrees to hold WIFE harmless and indemnifies her for any debt incurred
after the date of separation. WIFE will be solely responsibility for her outstanding debts and
agree to hold HUSBAND harmless and indemnify her for any debt incurred after the date of
separation.
It is hereby understood and agreed by and between the parties that their obligations
pursuant to this agreement shall not be affected by any bankruptcy proceeding and shall not be
deemed to constitute or be a dischargeable debt ora bankruptcy. Both parties warrant that he/she
has not heretofore instituted any proceeding pursuant to the bankruptcy laws nor are there any
such proceedings pending with respect to him/her which have been initiated by others.
SUPPORT AND ALIMONY: HUSBAND will not provide spousal support or
alimony pendente lite to WIFE, and WIFE will not provide spousal support or alimony pendente
lite to HUSBAND. After the entry ora Divorce Decree, neither party will seek alimony from the
other.
PERSONAL PROPERTY: The parties agree that the parties have divided the personal
property as follows:
HUSBAND shall receive the following items:
a. The personal property in his current possession;
b. His bank accounts;
c. Any Life Insurance Policy;
d. Any retirement account; and
e. His employee benefits from employment.
WIFE shall receive the following items:
a. The personal property in her current possession;
b. Her bank accounts;
c. Any Life Insurance Policy;
d. Any retirement accounts; and
e. Her employee benefits from employment.
The WIFE hereby waives all right and title which she may have in any personal property
of the HUSBAND. HUSBAND likewise waives any interest which he has in the personal
property of the WIFE. Henceforth, each of the parties shall own, have and enjoy independently
of any claim or right of the other party, all items of personal property of every kind, nature and
description and wherever situated, which are then owned or held by or which may hereafter
belong to the HUSBAND or WIFE with full power to the ItUSBAND or the WIFE to dispose
of same as fully and effectually, in all respects and for all purposes as if he or she were
unmarried.
Each party agrees that neither will incur obligations, liens or liabilities on account of the
other and that from the date of this Agreement, neither party shall contract or incur obligations,
liens or any liability whatsoever on account of the other.
10.
AUTOMOBILES:
a. WIFE agrees to waive any and all interest which she may have in HUSBAND'S
motor vehicle.
b. HUSBAND agrees to waive any and all interest which he may have in WIFE'S
motor vehicle.
11.
INSURANCE AND EMPLOYEE BENEFITS: The parties agree that any life
insurance policies except as otherwise stated herein on the life of HUSBAND or any other
employee benefits, including but not limited to retirement, profit sharing or medical benefits of
either party, shall be his own. WIFE waives all fight, title and claim to HUSBAND'S employee
benefits. HUSBAND waives all right, title and claim to WIFE'S employee benefits, including
but not limited to retirement, profit sharing and medical benefits.
12.
BENEFITS AND BANK ACCOUNTS: WIFE agrees to waive ail right, title and
interest which she may have in the savings or checking or any other bank accounts of the
HUSBAND. The HUSBAND agrees to waive all interest which he has in the bank accounts of
the WIFE.
13.
DIVORCE: The parties both agree to cooperate with each other in obtaining a final
divorce of the marriage. It is agreed that the parties will execute and file the consents necessary
to obtain the divorce. Any party who fails to cooperate with obtaining the Divorce shall pay all
the costs and legal fees of the party who is seeking the divorce,
14.
BREACH AND COUNSEL FEES AFTER DIVORCE: The parties agree with respect
to counsel fees incurred after the divorce, as follows:
a. In the event that future legal proceedings of any nature may be necessary for the
interpretation or enforcement of this Agreement or any valid modifications hereof, the
prevailing party shall be entitled to reasonable counsel fees incurred.
b. Reasonable counsel fees hereunder shall be defined as reasonable hours expended
at the then hourly rate of counsel for the prevailing party.
c. Such counsel fees shall extend to any independent proceedings necessary to
collect counsel fees or to enforce any other judgment or decree in connection with this
Agreement.
d. Such counsel fees shall be payable as alimony so as to constitute an exception to
discharge in bankruptcy but shall not be deductible by the payor or taxable to the payee
for income tax purposes.
15.
ADDITIONAL INSTRUMENTS: Each of the parties shall from time to time, at the
request of the other, execute, acknowledge and deliver to the other party any and all further
instruments that may be reasonably required to give full force and effect to the provisions of this
Agreement.
7
16.
VOLUNTARY EXECUTION: The provisions of this Agreement and their legal effect
have been fully explained to the parties by their respective counsel, and each party acknowledges
that the Agreement is fair and equitable, and that it is being entered into voluntarily, and that it is
not the result of any duress or undue influence.
The provisions of this Agreement are fully understood by both parties and each party
acknowledges that the Agreement is fair and equitable, that it is being entered into voluntarily,
and that it is not the result of any duress or undue influence.
17.
ENTIRE AGREEMENT: This Agreenaent contains the entire understanding of the
parties and there are no representations, warranties, covenants or undertakings other than those
expressly set forth herein.
APPLICABLE LAW:
Commonwealth of Pennsylvania.
18.
This Agreement shall be construed under the Laws of the
19.
PRIOR AGREEMENTS: It is understood and agreed that any and all property
settlement agreements which may or have been executed prior to the date and time of this
Agreement are null and void and of no effect.
8
20.
WAIVER OF CLAIMS AGAINST ESTATES: Except as herein otherwise provided,
each party may dispose of his or her property i~ any way, and each party hereby waives and
relinquishes any and all rights he or she may now have or hereafter acquire, under the present or
future laws of any jurisdiction, to share in the property or the estate of the other as a result of the
marital relationship, including without limitation, dower, curtesy, statutory allowance, widow's
allowance, right to take in intestacy, right to take against the Will of the other, and right to act as
administrator or executor of the other's estate, and each will, at the request of the other, execute,
acknowledge and deliver any and all instruments which may be necessary or advisable to carry
imo effect this mutual waiver and relinquishment of all such interests, rights and claims.
IN WITNESS WHEREOF, the parties hereunto have set their hands and seals the day
and year first above written.
WITNESSES:
COMMONWEALTH OF PENNSYLVANIA :
: SS:
COUNTY OF CUMBERLAND :
!
PERSONALLY APPEARED BEFORE ME, this ~0¥3' day of d,~.,~ar y
2001, a Notary Public, in and for the Commonwealth of Pennsylvania and County of
Cumberland, REBECCA J. RHOADES, known to me (or satisfactorily proven) to be the person
whose name is subscribed to the within Marriage Settlement Agreement, and acknowledges that
she executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and official seal.
COMMONWEALTH OF PENNSYLVANIA :
: SS:
COUNTY OF CUMBERLAND :
PERSONALLY APPEARED BEFORE ME, this ¥"" day of,'J"-~//~/~-~
2001, a Notary Public, in and for the Commonwealth of Pennsylvania and Co~hty of
Cumberland, JOHN M. RItOADES, JR., known to me (or satisfactorily proven) to be the
person whose name is subscr/bed to the within Marriage Settlement Agreement, and
acknowledges that he executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and official seal.
Notadal Seal I
Martha L. Noel Notary Public I
Cadisle Bore, Cumberland County
My Commission Expires Sept. 18, 2003
MemDer, Pennsylvania Association el Notaries
10
IN THE COURT OF COMMON PLEAS
JOHN M. RHOADES, JR.,
Plaintiff
VEREUS
REBECCA O. RHOADES,
OF CUMBERLAND COUNTY
STATE OF ~.~. ~ PENNA.
NO. 2001-68 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
Defendant
AND NOW,
DECREED THAT
AND
DECREE IN
DIVORCE
JOHN M. RHOADES, JR.
REBECCA J. RHOADES
2001
, IT IS ORDERED AND
, PLAINTIFF~
, DEFENDANT,
ARE DIVORCED FROM THE BONDS OF mATriMoNY.
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
SEEN RAISED OF t:;[ECORD IN THiS ACTION FOR WHICH A FINAL OrDEr HAS NOT
YET BEEN ENTERED;
The Marriage Settlement Agreement dated January 9, 2001 and signed by the
parties is hereby incorporated into this Decree, hut not merged.
BY Th~
ATTEST:
PROTHONOTARY