HomeMy WebLinkAbout01-1428
TERRY L. JONES,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v,
CIVIL ACTION - LAW
200I-ILi;;1.? CIVIL TERM
JOHN F. JONES,
Defendant
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, DMSION 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 hearing
or business before the court. You must attend the scheduled conference or hearing.
TERRY L. JONES,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2001- 11/..21 CIVIL TERM
JOHN F. JONES,
Defendant
IN DIVORCE
COMPLAINT m DIVORCE PURSUANT TO SECTION 3301(c)
QE THE DIVORCE CODE
NOW comes the plaintiff, Terry L. Jones, by her attorney, Douglas G. Miller, Esquire, and f1les
this complaint in divorce against the defendant, John F. Jones, representing as follows:
I. The plaintiff is Terry L. Jones, an adult individual residing at 150 Stone Church Road,
Carlisle, Cumberland County, Pennsylvania 17013.
2. The defendant is John F. Jones, an adult individual residing at 150 Stone Church 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 plaintiff and the defendant were married on June 28, 1972 in Potter County,
Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the parties.
6. There were three (3) children born to this marriage; namely, Christopher R. Jones, born April
3, 1980, age 20 years; Eric M. Jones, born January 29, 1985, age 16 years; and Zachary S. Jones, born
January 18, 1990, age I I years.
7. Pursuant to the Divorce Code, Section 330l(c), the plaintiff avers as the grounds upon which
this action is based that the marriage between the parties is irretrievably broken.
8, The plaintiff avers that she 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.
Respectfully submitted,
IRWIN, McKNIGHT & HUGHES
By: ~4~,e
Attorney for Plaintiff, Terry L. Jones
West Pomfret Professional Building
60 West Pomfret Street
Carlisle, Pennsylvania 17013-3222
(717) 249-2353
Supreme Court I.D. No. 83776
Date: March 12, 2001
VERIFICA nON
The foregoing Complaint is based upon information which has been gathered by my
counsel and myself in the preparation of this action. I have read the statements made in this
document 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.
~<A"('-t
TE~Y 00-;~ '
Date:
Karch 12th
,2001
TERRY L. JONES,
: IN THE COURT OF COMMON PLEAS OF
Plaintiff
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2001 -
CIVIL TERM
JOHN F. JONES,
Defendant
IN DIVORCE
PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT
The plaintiff, being duly sworn according to law, deposes and says:
I. 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
unsworn falsification to authorities.
Date: Karch 12th
,2001
TERRY L. JONES,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v,
CIVIL ACTION - LAW
2001-1428 CIVIL TERM
JOHN F, JONES,
Defendant
IN DIVORCE
ACCEPTANCE OF SERVICE
I, Stephanie E. Chertok, Esquire, attorney for the Defendant in the above-captioned
divorce action, accepted service of the Complaint in Divorce which was filed on March 12,2001,
on behalf of my client, John F. Jones.
.~~'~~
/' Stephanie E. Chertok, Esquire
Attorney for Defendant
61 West Louther Street
Carlisle, PA 17013
717-249-1177
Date: March , ~ ,2001
,.....<1...-...
'>
In The Court of Common Pleas of
Cumberland County, Pennsylvania
FileNo.
2001-01428
JONES TERRY L
vs
JONES JOHN F
STATEMENT OF INTENTION TO PROCEED
To rhe Court:
Plaintiff, Terry L_ Jones,
intends to proceed wirh rhe above captioned matter.
Dare: September 30. 2004
~~~~
Attorney fo Plaintiff
Supr~ne Court I.D. No. 83776
60 West pomfret Street
carlisle, PA 17013
(717) 249-2353
()
c
<:"'
-,") (:;'t
n16~:
;~:: ..;.,'
,;'f'
\,~'.J .L
i::;i;":
-c:- '","
~_::~( ,
!f;i:~~\
:;,:::.
:::;!
--.J
....,
<=>
~
~
--0
W
o
-0
::Jl;:
'>?
~
==2:n
m,....
~Z
::;:J~
(5.:d
-;.~~(")
C)rt1
--I
'>
::0
-<
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
TERRY L. JONES,
Plaintiff
2001- 1428 CIVIL TERM
JOHN F. JONES,
Defendant
IN DIVORCE
DEFENDANT'S AFFIDAVIT OF CONSEN12
1. A Complaint in Divorce under Section 330l(c) ofthe Divorce Code was filed on
March 12,2001.
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. 1 understand that 1 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 made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to
unsworn falsification to authorities.
Date: c2 I .A I, (J;
/
I
;:J)
r:.>
01
()'.
TERRY L. JONES,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2001-1428 CIVIL TERM
JOHN F. JONES,
Defendant
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDEU
SECTION 3301(c) OF THE DIVOUCE 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 made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
" .." 7 '
Date: .:;t" .r--i.(-'
/ /
:/(1/ /
F. JONES
efendant / '
i/
'I
:>J
\
(.>)
(+':
:;::
~.'~"
\--'-1
U"
Ci"
TERRY L. JONES,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
v.
CIVIL ACTION - LAW
2001- 1428 CIVIL TERM
JOHN F. JONES,
Defendant
IN DIVORCE
PLAINTIFF'S AFFIDAVIT OF CONSENT
I. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
March 12,2001.
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 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 made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to
unsworn falsification to authorities,
Date:
,AI <lIe ')'
I I
-""(1/, '
\. . ~.....
ut" z~'/ ).
TERRY 1.. J S
Plaintiff I '
;'
/l,c"c,
I
i
j
(..<,~,
l",)
en
()\
TERRY L. JONES,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2001- 1428 CIVIL TERM
JOHN F. JONES,
Defendant
IN DIVORCE
: 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 made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
Date:
,7 /"; !c 5-
I I
)'-
TERRY L. JON
Plaintiff i/
.'/f',
(..,'-;
j",,)
(IJ
0-'
,',
MARRIAGE SETTLEMENT AGREE ENT
THIS AGREEMENT made this 1St day of , 2005, by and between
TERRY L. JONES, (hereinafter referred to as "WIFE") and JOH F. JONES, (hereinafter
referred to as "HUSBAND"),
WITNESSETH:
WHEREAS, HUSBAND and WIFE were lawfully married on une 28, 1972; and
WHEREAS, diverse, unhappy differences, disputes and difficul ies have arisen between
the parties and it is the intention of HUSBAND and WIFE to live sep te and apart for the rest
of their natural lives, and the parties hereto are desirous of settlin fully and finally their
respective financial and property rights and obligations as between each ther, including, but not
limited to the settling of all matters between them relating to the 0 nership and equitable
distribution of real and personal property, the settling of all claims and possible claims by one
against the other or against their respective estates, and the equitable dis ibution of property and
alimony for each party.
The parties hereto agree and covenant as follows:
L
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 t e respective rights and
duties of the parties while they continue to Jive apart from each other.
2.
The parties have attempted to divide their matrimonial propert in a manner which
conforms to a just and right standard, with due regard to the rights of eac party, It is the intent
.'
of the parties that such division shall be final and shall forever deter ne their respective rights.
The division of existing marital property is not intended by the parties 0 constitute in any way a
sale or exchange of assets.
3.
Further, the parties agree to continue living separately and ap from the other at any
place or places that he or she may select as they have heretofore been ding. Neither pm1y shall
molest, harass, annoy, injure, threaten or interfere with the other party i any matter whatsoever.
Each party may carryon and engage in any employment, profession, bu iness or other activity as
he or she may deem advisable for his or her sole use and benefit. Ne'ther party shall interfere
with the uses, ownership, enjoyment or disposition of any property now wned and not specified
herein or property hereafter acquired by the other.
4.
The consideration for this contract and agreement is the mutual nefit to be obtained by
both of the parties hereto and the covenants and agreements of each of he parties to the other.
The adequacy of the consideration for all agreements herein contained s stipulated, confessed,
and admitted by the parties, and the parties intend to be legally bound her by.
Each party to the Agreement acknowledges and dec ares that he or she,
respectively:
a. Is represented by counsel of his or her own choosing, r if not represented by
counsel, understands that he or she has the right to counse : WIFE is represented
by Douglas G. Miller, Esquire of Irwin & McKnight; HU BAND is represented
by Stephanie Chertok, Esquire;
b. Is fully and completely informed of the facts relating t the subject matter of
this Agreement and of the rights and liabilities of the parties
2
c. Is entering into this Agreement voluntarily after receiving the advice of
counselor after choosing not to consult an attorney;
d. Has given careful and mature thought to the making . this Agreement;
e. Has carefully read each provision of this Agreement; d
f. FuIly and completely understands each provision of t is Agreement, both as to
the subject matter and legal effect of each provision.
This Agreement shaIl become effective immediately as of the date of ex cution.
5.
It is the purpose and intent of this Agreement to settle forever an comple~eIy the interest
and obligations of the parties in all property that they own separately, an 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 th mselves, their heirs and
assigns. The parties have attempted to divide their Marital Property in a anner that conforms to
a just and fair standard, with due regard to the rights of each party. he division of existing
Marital Property is not intended by the parties to constitute in any wa a sale or exchange of
assets, and the division is being effected without the introduction of utside fUnds or other
property not constituting a part of the marital estate.
It is the further purpose of this Agreement to settle forever and co pletely any obligation
under the Pennsylvania Divorce Code relating to spousal support or aIimo y.
6.
Each party represents and warrants that he or she has made a ful and fair disclosure to
the other of all of his or her property interests of any nature, including y mortgage, pledge,
lien, charge, security interest, encumbrance, or restriction to which any pr erty is subject. Each
party further represents that he or she has made a full and fair disclo ure of all debts and
3
ay become liable. Each
transfers for inadequate
obligations of any nature for which he or she is currently liable or
further represents and warrants that he or she has not made any gifts
consideration of Marital Property without the prior consent of the other.
Each Party acknowledges that, to the extent desired, he or she as had access to all joint
and separate State and Federal Tax Returns filed by or on behalf of eit er or both Parties during
marriage.
7.
REAL ESTATE: With regard to the marital residence located 150 Stone Church Road,
Carlisle, Cumberland County, Pennsylvania, HUSBAND and WIFE gree to list the property
for sale within six (6) months from the date of this Agreement and tr nsfer said property to a
third party at a purchase price which is agreeable to both parties. rther, HUSBAND and
WIFE covenant and agree that during the six (6) month period HUSB ND shall maintain the
property in conditions which would effectuate the sale of the propert as soon as practically
possible, and covenant and agree to use their best efforts to effectuate t e sale. lJ ntil such time
as the same is sold, HUSBAND agrees to be responsible for the any mo gage payments on said
property, and also responsible for the related costs to maintain the pro erty, including but not
limited to real estate taxes, insurance, and any regular maintenance and epair costs. After the
property is sold and the costs and expenses, including those expenses ou lined above, have been
paid in fuJI, the balance of the proceeds from the sale of the property ill be divided 60% to
HUSBAND and 40% to WIFE.
8,
SUPPORT: It is the mutual desire of the parties that HUSBAND will not be required to
pay spousal support, alimony, alimony pendente lite, or any other finan ial support to WIFE,
and that WIFE will not be required to pay spousal support, alimony, ali any pendente lite, or
any other financial support to HUSBAND. The parties thereby waive a y rights they have to
4
receive spousal support, alimony or alimony pendente lite payments fro the other either prior to
or following the entry of the Divorce Decree in this matter.
9.
PERSONAL PROPERTY: The parties agree that the per onal property has been
divided to the parties' mutual satisfaction. WIFE hereby waives al right, title and interest
which she may have in any personal property of the HUSBAND, HU BAND likewise waives
any right, title and interest which he has in the personal property of WI E. Hewceforth, each of
the parties shall own, have and enjoy independently of any claim or ri ht of the other party, all
items of personal property of every kind, nature and description and wh ever situated, which are
then owned or held by or which may hereafter belong to HUSBAND 0 WIFE with full power
to HUSBAND or WIFE to dispose of the same as fully and effectually, n all respects and for all
purposes as if he or she were unmarried,
10.
AUTOMOBILES: HUSBAND hereby waives all right, title an interest in any vehicle
that WIFE currently owns or may own in the future. WIFE shall hold USBAND harmless for
any and all liability associated with the use and purchase of any vehicle he may own, and shall
be solely responsible for all insurance and other financial responsibili y associated with said
vehicle. WIFE hereby waives all right, title and interest in any v hide that HUSBAND
currently owns or may own in the future. HUSBAND shall hold WIFE armless for any and all
liability associated with the use and purchase of any vehicle he may 0 n, and shall be solely
responsible for all insurance and other financial responsibility associated ith said vehicle, The
parties acknowledge that they have previously signed documentation t transfer vehicles into
5
"
their individual names. They further agree to execute any and all additional documentation
which may be necessary to confirm said transfers,
11.
MARITAL DEBTS: The parties recognize the existence of t e following credit cards,
loans, and debts:
I. Discover Card;
2. Pirst National Bank credit card; and
3. Sears credit card,
Since the date of separation, HUSBAND has made payments to ard the Sears credit card
and WIFE has made payments toward the other credit cards and debt, which obligations were
incurred during the marriage of the parties. The parties agree to conti ue making payments on
the above credit cards until they are paid in full.
In addition, it is mutually agreed by and between the parties th t WIFE shall assume all
liability for and pay and indemnify the HUSBAND against all debts in urred by WIFE after the
date of separation. WIFE represents and warrants to HUSBAND that since the parties' marital
separation she has not contracted or incurred any debt or liability for hich HUSBAND or his
estate might be responsible and WIFE further represents and warrant to HUSBAND that she
will not contract or incur any debt or liability after the execution of t is Agreement, for which
HUSBAND or his estate might be responsible. WIFE shall indemni y and hold HUSBAND
harmless from any and all claims or demands made against him by reas n of debts or obligations
incurred by her.
HUSBAND shall assume all liability for and pay and indemnif WIFE against all debts
incurred by HUSBAND after the date of separation. HUSBAND re resents and warrants to
WIFE that since the parties' marital separation he has not contracted or incurred any debt or
liability for which WIFE or her estate might be responsible and HUS AND further represents
and warrants to WIFE that he will not contract or incur any debt or lia ility after the execution
6
'.
of this Agreement, for which WIFE or her estate might be respo sible. HUSBAND shall
indemnify and hold WIFE harmless from any and all claims or dem nds made against her by
reason of debts or obligations incurred by him.
12.
INSURANCE AND EMPLOYEE BENEFITS: The parties acknowledge that WIFE
previously signed documentation waiving her interests in the 40l(k) PI of HUSBAND, and an
IRA with Commerce Bank in the name of both parties. The parti s also acknowledge that
decreasing term life insurance policies lapsed for lack of premium pa ments. The parties agree
that any remaining life insurance policies on the life of HUSBAN or WIFE or any other
employee benefits, including but not limited to retirement, profit shari g or medical benefits of
either party, shall be their own. WIFE waives all right, title and claim to HUSBAND'S
employee benefits, and HUSBAND waives all right, title, and cl 'm to any of WIFE'S
employee benefits.
13,
BENEFITS AND BANK ACCOUNTS: WIFE agrees to aive all right, title and
interest which she may have in the savings or checking or any oth r bank llccounts of the
HUSBAND and likewise HUSBAND agrees to waive all right, title d interest which he may
have in the savings or checking or any other bank accounts of WIFE.
14.
DIVORCE: The parties both agree to cooperate with each 0 her in obtaining a final
divorce of the marriage. It is agreed that the parties will execute and fi e the consents necessary
7
to obtain the divorce. Any party who fails to cooperate with obtainin the Divorce shaH pay all
the costs and legal fees of the party who is seeking the divorce,
15.
BREACH: If either party breaches any provisions of this A reement, the other party
shalJ have the right, at his or her election, to sue for damages for such reach or seek such other
remedies or relief as may be available to him or her, and the party br aching this contract shall
be responsible for payment of legal fees and costs incurred by the oth in enfoocing their rights
under this Agreement.
16,
ADDITIONAL INSTRUMENTS: Each of the parties shall rom time to time, at the
request of the other, execute, acknowledge and deliver to the other arty any and all further
instruments that may be reasonably required to give full force and effe t to the ptovisions of this
Agreement.
17,
VOLUNTARY EXECUTION: The provisions of this Agree ent and their legal effect
have been fully explained to the parties by their respective counsel, are fully understood by both
parties, and each party acknowledges that the Agreement is fair and uitable, that it is being
entered into voluntarily, and that it is not the result of any duress or u due influence, It is the
parties' intent that this Agreement does not merge with the Divorce Decree, but rather shall
continue to have independent contractual significance. Each part maintains his or her
contractual remedies or any other remedies provided by law or statut. Those rem(~dies shalI
include, but not be limited to, damages resulting from breach of t is Agreement, specific
8
enforcement of this Agreement and remedies pertaining to failure to comply with an order of
court or agreement pertaining to equitable distribution, alimony, aIim ny pendente lite, counsel
fees and costs as set forth in the Pennsylvania Divorce Code or oth r similar statutes now in
effect and as amended or hereafter enacted.
18.
ENTIRE AGREEMENT: This Agreement contains the en ire understanding of the
parties and there are no representations, warranties, covenants or und rtakings other than those
expressly set forth herein.
19.
APPLICABLE LAW: This Agreement shall be construed under the Laws of the
Commonwealth of Pennsylvania.
20.
PRIOR AGREEMENTS: It is understood and agreed th t any amd all property
settlement agreements which mayor have been executed prior to t e date and time of this
Agreement are nuJl and void and of no effect.
21.
PA YMENT OF COSTS: Each party shall be responsible for their own attorneys fees
and costs incurred in the settlement of the divorce and economic issues rrounding this divorce.
22.
WAIVER OF CLAIMS AGAINST ESTATES: Except as h ein otherwise provided,
each party may dispose of his or her property in any way, and each arty hereby waives and
9
<
'.
relinquishes any and all rights he or she may now have or hereafter ac uire, under the present or
future laws of any jurisdiction, to share in the property or the estate of he other as a result of the
marital relationship, including without limitation, dower, curtesy, stat tory allowance, widow's
allowance, right to take in intestacy, right to take against the Will of th other, and right to act as
administrator or executor of the other's estate, and each will, at the req est of the other, execute,
acknowledge and deliver any and all instruments which may be neces ary or advisable to carry
into effect this mutual waiver and relinquishment of all such interests, r ghts and claims.
IN WITNESS WHEREOF, the parties hereunto have set thei hands and seals the day
and year first above written.
WITNESSES:
"J'(l('il)Jr'yl~ ~ 1-
.~
e,?.L"J..~ )
/
{;/
10
(SEAL)
(SEAL)
,; ."
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
SS:
'J
PERSONALLY APPEARED BEFORE ME, this L d Y of
I Iv,/
j,-/F "
I
and County of
2005, a Notary Public, in and for the Commonwealth of Penn ylvania
Cumberland, TERRY L. JONES, known to me (or satisfactorily prov n) to be the person whose
executed the same for the purposes therein contained.
name is subscribed to the within Marriage Settlement Agreement, d acknowledges that she
IN WITNESS WHEREOF, I have hereunto set my hand and fficiaI seal.
COMMONWEALTH OF PENNS VANIA
NotariaJ Seal
K~ren S. Noel, Notary Public
CailSle ~oro' Cumberland County
My CommISSIon Expires Dec. 8, 2007
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
-,/
SS:
PERSONALLY APPEARED BEFORE ME, this Jd! d of ~~
2005, a Notary Public, in and for the Commonwealth of Penn ylvania and County of
Cumberland, JOHN F. JONES, known to me (or satisfactorily prove) to be the person whose
name is subscribed to the within Marriage Settlement Agreement, d acknowledges that he
executed the same for the purposes therein contained,
IN WITNESS WHEREOF, I have hereunto set my hand and ficial seal.
II
'{
N ARIA!. SE~!. -,
"" !: C"""'<"i",...!:,i';Cj~
i t.. L.',",.: '. ;,.....:_~;:.\.
L,:_ :::!?::::nmiss; fJ~roo ffctrdl 24fi, luc7 ~
~~IIIC~
,
(')
,--
(-,,'
::=:j
-<
"-,
{;.",:,>
=
<.."
o
-n
--l
fT."
'11,=
""t) -n
C,,?
~:3~~
(..~~ ~~)
::::o~ Lj.
(jrn
<:,'i
:;15
.,<
~.
"';'J
;::tJ
I
0'1
:u
-'.~
'Y
(J'l
OJ
TERRY L. JONES,
Plaintiff
IN THE COURT OF COM N PLEAS OF
CUMBERLAND COUNTY, ENNSYL VANIA
v.
CIVIL ACTION - LAW
2001-1428
CIVIL TERM
JOHN F. JONES,
Defendant
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
decree:
Transmit the record, together with the following information, to the c urt for entry of a divorce
Code.
I. Ground for Divorce: irretrievable breakdown under Section 330] c) and/or (d) of the Divorce
2. Date and manner of service of complaint: A certified copy of the omplaintin Divorce was
served upon the defendant, John F. Jones, through his attorney, Stephanie Ch rtok, Esquire, on or about
March 15, 200]. The Acceptance of Service was filed with the Prothontoary n or abOl.\t April 3, 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: February 9, 2005; by defendant: February 2], 2 05
Code:
(b)(]) Date of execution of the affidavit required by Sectio 3301 (d) df the Divorce
(b )(2) Date of filing and service of the plaintiffs affidavit u on the defendant:
4. Related claims pending: NONE.
5. Complete either (a) or (b).
(a) Date and manner of service of the Notice of Intentio to file Pr~ecipe to Transmit
Record, a copy of which is attached:
(b) Date plaintiffs Waiver of Notice in Section 3301(c) ivorce was filed with the
Prothonotary: March 3, 2005
Date defendant's Waiver of Notice in Section 330l(c Divorce was filed with the
Prothonolary: March 3, 2005
Date: April 6, 2005
Douglas G Miller,
Attorney for Plainti
n c-' 0
c:::'?
c-:. = -n
<.:fl
;::;.'" .-..\
~''''P
-":j cllF
:::;.\1 -0(1'
1 :~)t:?
0"'" '~i~')
--Zl '.~ .-{"\
~. I~~.~ r'l\
f";? ~::!\
. c~
01- ~,~
..t:J
--
:f.:+':ti:ti:ti:tiOf.Of.:f.:+':f.:+::ti:+:
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
:+::f.:+,:f.:ti:f.:+::+::ti;t'if.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
:+::ti:+::ti:f.;f.:+::ti:+':ti:f.
:f.:ti:f.:tiit-::ti:f.:tiOt.:ti:f.:+:
:+::ti;f.:f.:+::f.:+'~:+::f.:+::f.:f.:ti:f.;t':f.:+::ti
:f.:t::f.:+:
..
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF
PENNA.
TERRY L. JONES,
No.
2001-1428
Plaintiff
VERSUS
JOHN F. JONES.
Defendant
DECREE IN
DIVORCE
p-J:~.1t
,():x>{ , IT IS ORDERED
AND
AND NOW,
~
,3
DECREED THAT
TERRY L. JONES
, PLAINTIFF,
AND
JOHN F. JONES
, DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED;
The Marria~e Settlement A~reement dated Avril 1. 2005. and signed by
the
ecree but not mer ed.
.
.
.
.
.
.
.
.
.
.
.
.
:+':+:'+':ti'+'
B
.
.
Am"r!~
PROTHONOTARY
.
.
.
.
.
"'if.:+:i+::ti:+':f.:f.:f.
:ti:+'if.:+'if.:+':ti:f.:tiOt.Of.:+:Of.:+::f.:+::ti:+'~:f.;t:
:ti:+':ti:+':ti:+':ti:+':ti;t:;t::+:;t::+':f.:ti;+::+':+':f.~
.
.
..
. ..
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
J.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
:f.:f.:+:'f'if.T.
flYOY; fiv .;;; r-VH;W ':'/:;7fl,
~J"W; j):?J? Ppr,p~" ~~/F'~
5j (It I;
.;;;1 OC' 1-:
>