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HomeMy WebLinkAbout10-1356 CA PV O o __ i i 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNF?,;w' PENNSYLVANIA N u ,t. CIVIL ACTION-LAW Richard Jerome Dixon Plaintiff Pro Se, NO /a- 13 . , vs. Regina Charles Dixon Defendant Pro Se. 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 Cumberland County Courthouse, S. Hanover St., Carlisle, PA 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. 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/lLAWYERS REFERRAL SERVICE 1, ?r,6t?/a?1 6aw 1. Telephone: X 1 7 2 0 L to 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 .3 Q._c0/Y.12# ea,,.tl Notice to Defend and Claim Rights n-tA ?3 ?g Page 1 of 2 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW Richard Jerome Dixon 244 Marshall Rd Carlisle, PA 17013 Plaintiff Pro Se, vs. Regina Charles Dixon 244 Marshall Rd Carlisle, PA 17013 Defendant Pro Se. COMPLAINT IN DIVORCE UNDER §3301(c) OF THE DOMESTIC RELATIONS CODE Count I-Divorce Plaintiff, Richard Jerome Dixon, pro se, respectfully represents: 1. Plaintiff, Richard Jerome Dixon, currently resides at 244 Marshall Rd, Carlisle, PA 17013. 2. Defendant, Regina Charles Dixon, currently resides at 244 Marshall Rd, Carlisle, PA 17013. 3. Plaintiff and Defendant are sui juris, and Plaintiff and Defendant have has/have been resident(s) of the Commonwealth of Pennsylvania for a period of more than six (6) months immediately preceding the filing of this Complaint. 4. The parties were married on 05/04/2004, in Richmond, TX. 5. The parties were separated on 02/10/2010. 6. Plaintiff is in the military or naval service of the United States or its allies within the provisions of the Service Members' Civil Relief Act of 2003. No. 10' 7. The following children were born to the parties: Name Age Sex Charles Jerome Dixon Grace Richelle Dixon Mae Elizabeth Dixon Date of Birth Residence 9 male 12/27/2000 3 female 02/24/2006 2 female 10/17/2007 Mother Mother Mother Complaint in Divorce Page I of 2 8. There have been no prior actions of divorce or for annulment between the parties. 9. The parties have entered into a written agreement as to equitable distribution of marital property, alimony, alimony pendent lite, spousal support, child support, custody, visitation, fees and costs. 10. Plaintiff has been advised of the availability of counseling between the parties and Plaintiff acknowledges the right to request that the court require the parties to participate in such counseling in certain instances. 11. Plaintiff waives the right to request that the court require the parties to participate in counseling. 12. Plaintiff alleges the following grounds for the dissolution of marriage: The marriage is irretrievably broken and Plaintiff believes Defendant will consent to the divorce. If a divorce based on consent cannot be granted, Plaintiff further alleges in the alternative that the marriage is irretrievably broken and the parties will have been separated for two years or more at the time of final disposition of this case. WHEREFORE, Plaintiff requests this Honorable o era decree in divorce pursuant to Section 3301(c) of the Divorce Code. Rich ome Dixon, Plaintiff Pro Se VERIFICATION Plaintiff verifies that the statements made in this Com t in Divorce are true and correct. Plaintiff understands that false statements her ' are made s ject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsific on to authorities. Plaintiff Pro Se Date: ZaAfff Z- b Complaint in Divorce Page 2 of 2 FkjBT BEND COUNTI?' .......... f ............. ...........................: O e `4??G ?EfJa29 ?zr.CG ? ? ?. '" fF ?p i?rf'/'?e YOU ARE HEREBY AUTHORIZED TO CELEBRATE TN,F, f.,41 A, T, b .L . =l? •i t1' ?1 7' t J Between RICHARD JEROME DIXON JR & REGINA CHARLES DIXON andmake due return to the Cle?.. f ? o the --, County Court of- ::,? ?: .. c ? ? ount within dirty days thereafter cert(yi ' y ang your action untfe r,1 f`ris License Witness my off cial signature a ntf.st; ofo f office at Office in Richmond 2";has, the 3AD dayof MA Y ., ;fIT). 2004 (Dr. (Dianne %jfjor; C'Ounty Clem, Forst Bend County, 4,7i.ras By ?- -m _ CHRISTINA MAC EZdz eputy I hereby cert6 tha'the?_day of united in 911arn?age the parties .above named. Witness my hand this M day -MY Ceremony ?'erf©nned in - ,;- . (:AR9 A t Signture o pe?oo fKrt?rming ceny PbRT RFnm _ county - ? Type?Srint Aar title of erg} 301 7?St S1'RFRT ?.?,F person psrtirrming ceremony gT °m . p.,s........a ... , ., aae.,..._..._-- __-- rsG6 a"a faea for record the io License No: 04-0786-04 B Ym 40&Deputy License returned to. REGINA DixoN & RICHARD DIXON 3101 VISTA DR # 4201 ROSENBERG TX 77471 nat ??og ctremOny day ofy zoo,; _? in Marriage Records of Fort Bend C uo my Dr. Dianne Wilson, County Clerk This license cannot bc' used prior to: 051062004 at 03:27 PH and must be used bepre. 0410212004 IN THE Richard Jerome Dixon Plaintiff Pro Se, vs. Regina Charles Dixon Defendant Pro Se. THIS AGREEMEr between PLAINTIFF, ] and Defendant, Regina :T OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW No. ~ - l 35 (~ • C3 c~ ~ • t - ~ -"~ ,-,' t. _ _ ~ t, -- ~.; ~, - ~<~~~ :'AL PROPERTY SETTLEMENT AGREEMENT ,_,';. '`- .', --~ __, _ _ < ~- made this I ~~' day of ~ ~tt~ir , 20~-- ~ j~' , .hard Jerome Dixon residin at 244 arshall Rd Carlisle P~(~I3 g > iarles Dixon, residing at 244 Marshall Rd, Carlisle, PA 17013. WITNES SETH WHEREAS, the WHEREAS, the WHEREAS, the were married on 05/04/2004; filed for 3301(c) Divorce on ~C. ~rlA~~ ~ ~ ~ o~ ~ i ~ ; hereto desire to settle their property rights; WHEREAS, both p ies agree to relinquish any and all claims which either may have against any property no owned or belonging to the other or which may hereinafter be acquired by either of them by pur hase, gift, devise, bequest, inheritance, or otherwise, except as to the obligations, covenants, d agreements contained herein; and, WHEREAS, both p ies each have had an opportunity to seek the benefit of competent and independent legal advice by separate counsel. NOW, THEREFO follows: 1. INCORPORATI The recitals on Each paragraph agreement. the parties, intending to be legally bound, do covenant, and agree as OF RECITALS 1 of this Agreement are incorporated herein as if set forth in full. ~f shall be deemed to be a separate and independent covenant and Marital Property Settlement Agreement Page 1 of 7 .~ 2. APPLICABLE L.d~W This agreement shall be construed under the laws of the Commonwealth of Pennsylvania. 3. PROPERTY TO $E RETAINED BY WIFE. Husband and Wi a agree that, unless otherwise indicated in this Agreement, the Wife shall keep all of er personal clothing and effects; and that the following property shall also be retained b Wife: BANK ACCOU~TS: -USAA Checkin and Savings 4. PROPERTY TO BE RETAINED BY HUSBAND. Husband and Wi agree that, unless otherwise indicated in this Agreement, the Husband shall keep all of is personal clothing and effects; and that the following property shall also be retained b Husband: REAL ESTATE: -7224 Sunset Av NE Bremerton, WA 8311 Wife agrees to tr sfer title of the property to Husband. 5. DEBTS TO BE PAID BY WIFE. Husband and Wife agree that the Wife shall pay the following debts and will not at any time hold the Hu and responsible for them: -USAA Masterc d USAA $17,000 -Toyota Sienna inivan USAA $19,500 6. DEBTS TO BE P1AID BY HUSBAND. Husband and Wi~e agree that the Husband shall pay the following debts and will not at any time hold the Wife responsible for them: REAL ESTATE EB7 -7224 Sunset Av NE Bremerton, WA 8311 Marital Property Settlement Agreement Page 2 of 7 DEBT: -MBNA Credit -USAA Visa -Home Depot -USAA AMEX -Toyota Camry Wells Fargo $325,693 Bank of America $16,700 USAA $17,000 Home Depot $3,000 USAA $4,000 Wachovia $25,696 7. ALIMONY, ALIMONY PENDENTE LITE, SPOUSAL SUPPORT, EXPENSES AND ALL MARITAL GHTS. Each of the parti~s hereto release the other from subsequent claims for alimony, alimony pendente lite, or pousal support, except as set forth as follows: No spousal maintenance shall be awarded to either party. 8. JOINT DEBTS. Husband and Wi a warrant and certify to each other that there are no individual or joint marital obligatio s outstanding, other than those listed in paragraphs 5 and 6. 9. CHILD CUSTO Y. The Plaintiff and efendant are the parents of 3 unemancipated child(ren): Name DOB Awe Gender Charles Jerome ixon 12/27/2000 9 male Grace Richelle D xon 02/24/2006 4 female Mae Elizabeth Di on 10/17/2007 2 female In the past five years, the parties' children have resided at the following locations: Child Location Charles Jerome ixon Living with Mother 244 Marshall Rd Carlisle, PA 17013 Grace Richelle D xon Living with Mother 244 Marshall Rd Carlisle, PA 17013 Mae Elizabeth Di on Living with Mother 244 Marshall Rd Carlisle, PA 17013 Marital Property Settlement A Bement Page 3 of 7 Name Charles Jerome Grace Richelle Mae Elizabeth ] a. Weekly Time Custody of the above-listed children will be as follows: Legal Custody Physical Custody joint Mother joint Mother joint Mother The non-primary~hysical custodian shall have at a minimum the following rights of parenting time/vi itation with the minor child(ren): Weekend Parenti g Time Other: Weekend :Charles: Friday after school until Sunday 4pm Weekend 2: Charles, Grace, Mae: Frid y after school to Sunday 4pm. Weekend 3: Grace and Mae: Saturday 11 am to Sunday ace 4pm. For purposes of is parenting plan, weekend parenting time will start at Friday Spm and end at Sunday 4p Weekday Parenti g Time Other: Father's V sitation: Charles, Grace, Mae: Tuesday and Thursday, from 5 to 8 pm. For purposes oft is parenting plan, weekday parenting time will start at Spm and end at Spm. b. Vacation Pare~ntin~ Time All vacation peri~ds defined below do not include the parenting time schedule for major holidays, which ay occur during the vacation period. Winter vacations all be defined as the period beginning on the day and at the time school is recesse in December and ending on the day and at the time school resumes in January of the fol owing year. No special winter vacation parenting time schedule will apply and parenti g time will remain as stated in 9a and 9c except as follows: none Summer vacation shall be defined as the period beginning on the day and at the time school is recesse at the end of the school year and ending on the day and. at the time school resumes a the beginning of the following school year. No special summer vacation parentin time schedule will apply and all parenting time will remain as stated in 9a and 9c, except as follows: none Spring vacations all be defined as period beginning on the day and at the time school is recessed in them nth of April and ending on the day and at the time school resumes as designated by the child's school calendar. No special spring vacation parenting time schedule will app y and all parenting time will remain as stated in 9a and 9c, except as follows: none Marital Property Settlement A~reement Page 4 of 7 c. Major Holida~ Schedule MOTHER FATHER New Year's ay Even Odd Martin Luthe King Day Even Odd Presidents' D y Odd Even Memorial Da Even Odd July 4th Odd Even Labor Day Even Odd Veterans' Da Odd Even Thanksgiving Day and Friday Even Odd Christmas Ev Odd Even Christmas Da Odd Even Mother's Day Every Father's Day Every Mother's Birt day Even Odd Father's Birth ay Odd Even Charles's Bi day Odd Even Grace's Birth ay Even Odd Mae's Birthd Even Odd Each desi; (X) Holidays (X) Holidays (X) Other: Fo follows: dated holiday above will start and end as follows: hat fall on Friday will include the following Saturday and Sunday hat fall on Monday will include the preceding Saturday and Sunday purposes of this parenting plan, a holiday shall begin and end as begin: 7 pm day before holiday end: 7 pm day of holiday 10. CHILD SUPPORT, INSURANCE, AND TAX EXEMPTION. a. Child Sup ort Plaintiffs all pay support in the amount of $2,181 per month for the support and care of th parties' minor child(ren). b. Insurance Health c e coverage for the minor child(ren) shall be provided by Plaintiff as long as su h coverage is available at a reasonable cost on anemployment-related or other g oup basis. Any health costs not covered by insurance shall be shared equally. c. Tax Exem tion For feder 1, state, and local income tax purposes the mother shall claim the child(ren) ually beginning the tax year that the divorce is finalized. Marital Property Settlement A~reement Page 5 of 7 11. DIVORCE. Husband and Wi~e agree that the marriage is irretrievably broken and will proceed with said Divorce and r 23 Pa. C.A. Section 3301(c). 12. NAME Does not apply. 13. TAX ADVICE. The transfers set forth herein may result in income, inheritance, estate, and other tax consequences to the parties. 'The parties specifically acknowledge that no attorney involved in the egotiating or drafting of this Agreement has provided any tax advice regarding the di positions contained herein. The parties have been advised to seek separate tax coon el concerning the Divorce distributions. Marital Property Settlement A~reement Page 6 of 7 14. INCORPORATION OF PROPERTY SETTLEMENT INTO DECREE. Husband and Wi~e agree to the incorporation of the Property Settlement Agreement into the Decree. IN WITNESS HEREOF, the parties have hereunto set their hands and seals the day and year first written above. Jerome On this `~ day of ~ 200 , before me, a Notary Public, the undersigned officer, pers lly apl eared Richard Jerome Dixon, Plaintiff, known to me to be the person whose name is s bscribed to the written instrument, and acknowledged that he or she executed the same for th purposes therein contained. IN W~TESS WHEREOF, I hereunto set my hand and official seal. 'ARY Notadtal ~~ ,Notary Pt~lic Cau Ji,ty », zoto Member, Pennsylvania As ociation of Notaries Regina C'Fiarl~s Dixon, On this ~ day of 20 (~, before me, a Notary Public, the undersigned officer, pers n y app aced Regina Charles Dixon, Defendant, known to me to be the person whose name i subscribed to the written instrument, and acknowledged that he or she executed the same forth purposes therein contained. IN WI SS WHEREC ARY PUBLIC COMMONWEALTH Letme Fepdn ~I ~My kxrBoror .Member, Penn~sylNania ~ I hereunto set my hand and official seal. Seal ---"'~ >~Ptd~lic -es July ~ t, zoC 10 y ~sociatiora of Notari~S Marital Property Settlement A~reement Page 7 of 7 IN THE COURT OF Richard Jerome Dixon Plaintiff Pro. Se, vs. Regina Charles Dixon Defendant Pro Se. To the Prothonotary: Transmit the divorce decree: MMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW NO. ~ ~ ' ~ ~JS~P C~ n ~: -., : - ~ ~- - _ -r, T _ "~.~ _ ...~ ~.. . t._ PRAECIPE TO TRANSMIT RECORD t~_ tr-' '".~ G3 together with the following information, to the Court for entry of a 1. Ground for Divor e: irretrievable breakdown under Section 3301(c)io(f the Divo~~r(ce Code. 2. Date and manner f service of the Complaint: on or about ~/ ~`~ / ~ UJ via Certified Mail 3. Date of execution of the Affidavit of Consent: by Plainti ~/ 1 / 201 ); by Defendant ~/ ~.Q / COI O). 4. Related claims 5. Date of filing of Section 3301(c) by Plaint. None. Waiver of Notice of Intention to Request Entry of Divorce Decree Under 'the Divorce Code: (~_/~/ 2p t ~ ); by Defendant ~/ LQ / 0201 l~). Richard Jerome Dixon, Plaintiff Pro Se 244 Marshall Rd Carlisle, PA 17013 717-254-3974 Praecipe to Transmit Record ~ Page 1 of l IN THE CO Richard Jerome Dixon Plaintiff Pro Se, vs. Regina Charles Dixon Defendant Pro W 1. 2. I consent to the OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW N ^ c-- ~ -„ ri _ -~ -pry !__. • ~LZ . _ -r~;, ~- OF NOTICE OF INTENTION TO REQUEST _ ~'i -- t_. CRY OF A DIVORCE DECREE UNDER ~- ~ ~" § 3301(c) OF THE DIVORCE CODE of a final decree of divorce without notice. I understand that may lose rights concerning alimony,. division of property, lawyer's fees or expenses f I do not claim them before a divorce is granted. 3. I understand that that a copy of the Prothonotary. I verify that the false statements unsworn falsific Date: ~ ~D J ~L will not be divorced until a divorce decree is entered by the Court and lecree will be sent to me immediately after it is filed with the vents made in this affidavit are true and correct. I understand that n are made subject to the penalties of 18 Pa.C.S. §4904 relating to to.~authorities. 1 ~ ~ _ v ~v "L.. Regina Charles Dixon, Defendant Defendant's Waiver of Notice ~f Intention Page 1 of 1 IN THE Richard Jerome Dixon Plaintiff Pro Se, vs. Regina Charles Dixon Defendant Pro Se. A Complaint in D ia`~ is ~ broken and ninety (90) d~ contained within the attar information, and belief. It is my desire to Marital Property Settlem~ conditions as set forth wi OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW c~ o t ~ t~. -~,; ~.~ _ t__. . ; c. S .~ -O d ~` - DEFENDANT'S ACKNOWLEDGMENT 'y , ~'' `~ ~' ~. TR ~ ~., e =< ivorce under Section 3301(c) of the Divorce Code was filed on I agree that the marriage of the Plaintiff and Defendant is irretrievably iys have elapsed from the date of filing the Complaint. All information hed documentation is true and correct to the best of my knowledge, with the Cumberland County Court of Common Pleas the attached Agreement and to be bound fully and completely by the terms and i said Marital Property Settlement Agreement documentation. Regina C arses Dixo ,Defendant Pro Se On this ~ day of 20~, before me, a Notary Public, the undersigned officer, pers n ly ap eared Regina Charles Dixon, Defendant, known to me to be the person whose name is subscribed to the written instrument, and acknowledged that she executed the same for the purposes therein contained. IN WITNF~S WHEREO~, I hereunto set my hand and official seal. PUBLIC Laura Faodn Cay Medianic~ug Bao. AAy Car-miss~ E.x Member, Pennsylvania PE6ViV~YL' wry Pubilc 0 iberlar~d Courriy July 11,2010 aatien of Notaries Defendant's Acknowledgment ~I Page 1 of 1 IN THE COU T OF COMMON PLEAS OF CUMBERLAND COUNTY , PENNSYLVANIA CIVIL ACTION-LAW Richard Jerome Dixon , Plaintiff Pro Se, vs. N NO. ~ l~- ~',~Slp o ~ Regina Charles Dixon : = ' ~ ~_ -- . Defendant Pro Se. --- ,, ,z ~- ._ ~ ~_. ~ .: ~~ PLAINTIFF'S ACKNOWLEDGMENT ~ "~' :-< ~ ~. 2 A Complaint in 'vorce under Section 3301(c) of the Divorce Code was filed on /~/ 2©1 C~ I agree that the marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) d ys have elapsed from the date of filing the Complaint. All information contained within the atta hed documentation is true and correct to the best of my knowledge, information, and belief. It is my desire to ><le with the Cumberland County Court of Common Pleas the attached Marital Property Settlem nt Agreement and to be bound f co letely by the terms and conditions as set forth wi 'n said Marital Property S ement Agree nt documentation. Richard Jerome Dixon, Plaintiff Pro Se On this ~ day of 20~~, before me, a Notary Public, the undersigned officer, pers lly ap eared Richard Jerome Dixon, Plaintiff, known to me to be the person whose name is su scribed to the written instrument, and acknowledged that she executed the same for the purposes therein contained. IN WIT~SS WHEREOF, I hereunto set my hand and official seal. 1`~OTAR~T ItltNt='ALrH o PENNSYLVANIA r~ Wotarial eal Laura Faodn ,Notary Public MecFtanicsburg Born, and Cotxrty MY Corrurr~sion July 11,2010 Member, Pennsylvania A sociation of Notaries Plaintiff s Acknowledgment Page 1 of 1 I IN THE COURT OF COMMON PLEAS OF ~~„~ ~ `~ :CUMBERLAND COUNTY, PENNSYLVANIA AND NOW, , bonds of matrimom Any existing alimony pendente I The court re' for which a final orc claims remain Indic 1 NO. 1 LJ DIVORCE DECREE a"~ , ~~~ , it is ordered and decreed that ~ x~~ . J ~ • ,plaintiff, and C, ~ j XC~ ,defendant, are divorced from the support order shall hereafter be deemed an order for if any economic claims remain pending. ns jurisdiction of any claims raised by the parties to this action has not yet been entered. Those claims are as follows: (If no "None.") NoN~- B ourt, Att ~, C Prothonotary 7~~ ~ ~ o ~Q~~ ~ t ~ ~ ~ ~~~ ~~-~-.