HomeMy WebLinkAbout05-1814
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. ()!;-/PfL-/ Clo~Ci0L.l
: CIVIL ACTION - LAW
JANE OWENS,
v.
JON OWENS,
: IN DIVORCE
Defendant
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 of 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,
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, 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 MAYBE
ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY
OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO
FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
32 S, Bedford Street
Carlisle, Pennsylvania 17013
(717) 249-3166 or (800) 990-9108
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Jay R. Braderman, Esquire
1.0. No, 07047
126 Locust Street
p, O. Box 11489
Harrisburg, P A 17108-1489
(717) 232-6600
Attorney For Plaintiff
JANE OWENS,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. O~ - tPtLj C;U~LLr~)
: CIVIL ACTION - LAW
v.
JON OWENS,
: IN DIVORCE
Defendant
COMPLAINT
DIVORCE UNDER SECTION 330I(c) and (d)
OF THE DIVORCE CODE
AND NOW COMES Plaintiff, Jane Owens, by her attorney, Jay R. Braderman,
Esquire, and respectfully represents as follows:
1. Plaintiff, Jane Owens, is an adult individual residing at 508 Walton Court,
Lemoyne, Cumberland County, Pennsylvania, 17043.
2. Defendant, Jon Owens, is an adult individual residing at 508 Walton Court,
Lemoyne, Cumberland County, Pennsylvania, 17043.
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3. Plaintiff and Defendant have been bona fide residents in the Commonwealth
of Pennsylvania for at least 6 months immediately previous to the ftIing of this Complaint.
4. Plaintiff and Defendant were married on February 15, 1992 in Mount Joy,
Pennsylvania.
5. There was one child born of this marriage, Laura Owens, age 10, born
February I, 1995.
6. Plaintiff has been advised of the availability of counseling and that the
Plaintiff may have the right to request that the Court require the parties to participate in
counseling.
7, The Defendant is not a member of the Armed Services of the United States
or any of its Allies.
8. The causes of action and sections of the Divorce Code under which Plaintiff
is proceeding are:
A. Section 330 I (c). The marriage of the parties is irretrievably broken.
After ninety (90) days have elapsed from the date of filing this
Complaint, Plaintiff intends to file an Affidavit consenting to a divorce.
Plaintiff believes that Defendant may also file such an Affidavit.
B. Section 3301 (d). The marriage of the parties is irretrievably broken.
The date of separation was on or about April 2004.
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WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter a
Decree in Divorce from the bonds of matrimony.
Respectfully Submitted,
ra rman, Esquire
I. 0.07 47
26 Locust Street
P. O. Box 11489
Harrisburg, P A 17108-1489
(717) 232-6600
Attorney For Plaintiff
3
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JANE OWENS,
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
: NO.
v.
: CIVIL ACTION - LAW
JON OWENS,
IN DIVORCE
Defendant
AFFIDA VII
JANE OWENS, 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 by the
Court.
r understand that false statements herein are made subject to the penalties of 18
Pa. C.S. Section 4909 relating to unsworn falsification to authorities.
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VERIFICATION
Upon my personal knowledge or information and belief, I hereby verify that the
facts averred in the foregoing Complaint are true and correct to the best of my knowledge,
information, and belief. I understand that false statements herein made are subject to the
criminal penalties of 18 Pa.C.S. ~ 4904, relating to unswom falsification to authorities,
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I verify that I have reviewed this form with my client and to the best of my
knowledge the allegations herein are true and correct.
Attorney For Plaintiff
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MARITAL SETTLEMENT AGREEMENT
THIS A GREEMENT, made this 1-+"- day of :5:.>-\ \.1
, 2005, by and
between Jon Owens, hereinafter called "Husband," and Jane Owens, hereinafter called "Wife."
WITNESSETH:
WHEREAS, Husband and Wife were legally married on February 15, 1992; and
WHEREAS, one child was born of this marriage, Laura Owens, born February 1, 1995;
and
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WHEREAS, differences have arisen between Husband and Wife m consequence of
which they desire to live separate and apart from each other; and
WHEREAS, Husband and Wife desire to settle and determine their rights and
obligations.
NOW THEREFORE, in consideration of the premises and covenants contained herein, it
is agreed by and between the parties hereto that:
1. SEPARATION
It shall be lawful for each party at all times hereafter to live separate and apart from each
other at such place as he or she from time to time shall choose or deem fit. The foregoing
provision shall not be taken as an admission on the part of either party of the lawfulness or
unlawfulness of the causes leading to their living apart. The parties agree that they have been
living separate and apart at least since April 1, 2004.
2. INTERFERENCES
Each party shall be free from interference, authority and control by the other, as fully as if
he or she were single and unmarried, except as may be necessary to carry out the provisions of
this Agreement. Neither party shall molest or attempt to endeavor to molest the other, or in any
way harass or malign the other, nor in any other way interfere with the peaceful existence,
separate and apart from the other.
3. DIVISION OF REAL PROPERTY
a) The parties own real estate, the marital home, located at 508 Walton
Court, Lemoyne, Cumberland County, Pennsylvania, 17043. Said real estate to be listed for sale
on or before June 1, 2005. The net sale proceeds (after deducting costs of sale, including
brokerage commission, if any, satisfaction/payoff of mortgage and liens and tax pro-ration) shall
be distributed 65% to Wife and 35% to Husband.
b) Husband owns rental real estate titled in his name only; identified as 1334
North 14th Street, 1918 Holly Street, 1429 Naudain Street, 1814 North Street and 556 Radnor
Street all in the City of Harrisburg, Pennsylvania. Said real estate shall remain titled in and the
exclusive property of Husband. Wife irrevocably waives any interest, claim or title she has or
may have in those properties. Husband and Wife are both mortgagors on the 1334 North 14th
Street, 1918 Holly Street and 556 Radnor Street properties. Husband agrees to be solely
responsible for all costs and expenses associated in maintaining those properties including
payment of mortgages, liens and taxes thereon and Husband agrees to indemnify and hold Wife
harmless for any obligations associated with said properties. Husband agrees to remove Wife as
a mortgagor should Wife be unable to obtain a mortgage for purchase of a property by her.
4. DIVISION OF PERSONAL PROPERTY AND ACCOUNTS
The parties have already satisfactorily divided all their furniture, furnishings, and other
personal property. The parties have already satisfactorily divided their checking accounts.
2
5. EQUIT ABLE DISTRIBUTION
Except as specifically provided for in this Agreement, the parties agree that they have
satisfactorily equitably divided all their marital property.
6. PENSIONS
Each party shall retain and claim as their sole and separate property their own
pensions or retirement accounts.
7. MOTOR VEHICLES
The parties agree that Husband will retain as his sole and separate property the Ford
vehicle titled in his name. Husband shall assume and be solely responsible for any debt due on
his vehicle. Wife will retain as her sole and separate property the Mitsubishi vehicle titled in her
name. Wife shall assume and be solely responsible for any debt due on her vehicle.
8. CREDIT CARDS
Each party shall assume sole responsibility and pay for all credit cards in their own name.
There are no jointly held credit cards.
9. LIFE INSURANCE
Each party shall retain any life insurance policies in their names individually including
any cash value related thereto and each party shall have the right to name beneficiaries of life
insurance proceeds, except as set forth as follows:
a) Husband is the owner of life insurance having a face value of
$400,000.00. Husband agrees to permanently maintain said life insurance and agrees to name
the parties' daughter, Laura Owens, as beneficiary of at least $162,500.00 of life insurance
proceeds insuring Husband's life.
3
b) Wife is the owner of life insurance having a face value of $200,000.00.
Wife agrees to permanently maintain said life insurance and agrees to name the parties'
daughter, Laura Owens, as beneficiary of at least $100,000.00 of life insurance proceeds insuring
Wife's life.
c) Either Husband or Wife may request of the other an annual statement
evidencing the insurance in force, named beneficiaries and amount of benefit.
10. 2005 TAX RETURN
For tax year 2005 and thereafter, the parties will file separate tax returns.
11. CUSTODY AND CHILD SUPPORT
The parties are the parents of one minor child, Laura Owens.
a) The parties shall share legal and physical custody of their child.
b) Child support shall be paid as the parties may agree.
c) The parties agree to equally pay the tuition for their daughter's attendance at the
Circle School.
12. BREACH
If either party breaches any provision of this Agreement, the other party shall have the
right, at his or her election to sue for damages for such breach. The party breaching this contract
shall be responsible for the payment of legal fees and costs incurred by the other in enforcing his
or her rights under this Agreement, or seeking such other remedy or relief as may be available to
him or her.
4
13. ALIMONY
The parties acknowledge and agree that no alimony, alimony pendente lite or spousal
support is due or should be paid by one party to the other; and each irrevocably waives
entitlement, if any, thereto.
14. FULL DISCLOSURE
Husband and Wife each represent and warrant to the other that he or she has made a full
and complete disclosure to the other of all assets of any nature whatsoever, and of all other facts
relating to the subject matter of this Agreement to which such party may reasonably require to
make an informed decision regarding this Agreement.
15. ADDITIONAL INSTRUMENT
Each of the parties shall on demand execute and deliver to the other any documents
necessary or desirable to effectuate the provisions and purposes of this Agreement. If either
party fails on demand to comply with this provision, that party shall pay to the other all
attorneys' fees, costs and other expenses reasonably incurred as a result of such failure.
16. WIFE'S DEBTS
Wife represents and warrants to Husband that since the parties' separation she has not
and in the future she will not contract or incur any debt or liability for which Husband or his
estate might be responsible and Wife shall indemnify and save Husband harmless from any and
all claims or demands made against him by reason of debts or obligations incurred by her.
17. HUSBAND'S DEBTS
Husband represents and warrants to Wife that since the parties' separation he has not and
in the future he will not contract or incur any debt or liability for which Wife or her estate might
5
be responsible and Husband shall indemnify and save Wife harmless from any and all claims or
demands made against her by reason of debts or obligations incurred by him.
18. WAIVERS OF CLAIMS AGAINST ESTATES
Except as herein otherwise provided, each party may dispose of his or her property in 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,
curtsy, 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, to the request of the other, execute, acknowledge, and deliver any and all instruments which
may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all
such interests, rights and claims.
19. REPRESENTATION
The provisions of this Agreement and their legal effect have been fully explained to Wife
by her attorney, Jay R. Braderman, Esquire. Husband chooses not to be represented by counsel
but is of full age and sui juris. The parties acknowledge that they fully understand the facts and
have been fully informed as to their legal rights and obligations, and they acknowledge and
accept that this Agreement is, in the circumstance, fair and equitable and that it is being entered
into freely and voluntarily, after having received such advice and with such knowledge and that
execution of the Agreement is not the result of any duress or undue influence and that it is not
the result of any collusion or improper or illegal agreement or agreements.
6
20. T AX PROVISIONS
The parties believe and agree that the division of property heretofore made by this
Agreement is a non-taxable division of property between co-owners rather than a taxable sale or
exchange of such property. Each party promises not to take any position with respect to the
adjusted basis of the property assigned to him or her or with respect to any other issue which is
inconsistent with the position set forth in the preceding sentence on his or her federal or state
income tax returns.
The parties have in the past filed joint federal and state tax returns. Both parties agree
that in the event any deficiency in federal, state or local income tax is proposed, or any
assessment of any such tax is made against either of them, each will indemnify and hold
harmless the other from and against any loss or liability for any such tax deficiency or
assessment and any interest, penalty and expense incurred in connection therewith. Such tax,
interest, penalty or expense shall be paid solely and entirely by the individual who is finally
determined to be the cause of the misrepresentations or failures to disclose the nature and extent
of his or her separate income on the aforesaid j oint returns.
21. ENTIRE AGREEMENT
This Agreement contains the entire understanding of the parties and there are no
representations, warranties, covenants or undertakings other than those expressly set forth herein.
22. PRIOR AGREEMENT
It is understood and agreed that any and all property settlement agreements which mayor
have been executed prior to the date and time of this Agreement are null and void and of no
effect.
7
23. MODIFICATION AND WAIVER
Any modification or waiver of any provision of this Agreement shall be effective only if
made in writing and executed with the same formality as this Agreement. The failure of either
party to insist upon strict performance of any of the provisions of this Agreement shall not be
construed as a waiver of any subsequent default of the same or similar nature.
24. GOVERNING LAW
This Agreement shall be governed by and shall be construed in accordance with the laws
of the Commonwealth of Pennsylvania.
25. INDEPENDENT SEPARATE COVENANTS
It is specifically understood and agreed by and between the parties hereto that each
paragraph hereof shall be deemed to be a separate and independent covenant and agreement.
26. VOID CLAUSES
If any term, condition, clause, or provision of this Agreement shall be determined or
declared to be void or invalid in law or otherwise, then only that term, condition, clause or
provision shall be stricken from this Agreement and in all other respects this Agreement shall be
valid and continue in full force, effect and operation.
27. ENTRY AS PART OF DECREE
It is the intention of the parties that this Agreement shall survive any action for divorce
which may be instituted or prosecuted by either party and no order, judgment or decree of
divorce, temporary, final or permanent, shall affect or modify the financial terms of this
Agreement. This Agreement shall be made a part of, but shall not merge with, any such
judgment or decree of final divorce.
8
28. DIVORCE ACTION
The parties, after 90 days have elapsed from serVIce of the Divorce Complaint on
Husband, shall execute documents pending under said action, indexed to No. 05-1814, Civil
Term, in the Court of Common Pleas, Cumberland County, Pennsylvania, as well as Affidavits
of Consent and Waivers of Counseling and Waivers of Notice of Intention to Request Entry of a
Divorce Decree.
29. DOMESTIC RELATIONS CODE OF THE COMMONWEALTH OF
PENNSYL VANIA
Except as specifically provided in this Agreement, each party waives any claim they may
have against the other under the Domestic Relations Code or other laws of the Commonwealth of
Pennsylvania including, but not limited to, spousal support, alimony, alimony pendente lite,
counsel fees, costs and equitable distribution of marital property.
IN WITNESS WHEREOF, the parties hereto, intending to be legally bound hereby,
have hereunto set their hands and seals the day and year first above written.
WITNESS:
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Jo~ Ow ns
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Jane Owens
9
COMMONWEAL TH OF PENNSYLVANIA
COUNTY OF (!umw!Clnd
On this, the rJft) day of l , 2005, before me, a Notary Public,
personally appeared Jon Owens, known to e t be the person whose name is subscribed to the
within Marital Settlement Agreement and acknowledged that he executed the same for the
purposes therein contained.
ss.
NOTARIAL SEAL
SUZANNE M. DEDERER, Notary Public
Camp Hill Boro, Cu~berland County
My Commission Expires Aug. 20, 2005
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
COMMONWEAL TH OF PENNSYLVANIA
COUNTY OF Cvrnbo/and
On this, the ~ day of , 2005, before me, a Notary Public,
personally appeared Jane Owens, known to e to e the person whose name is subscribed to the
within Marital Settlement Agreement and acknowledged that she executed the same for the
purposes therein contained.
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IN WITNESS WHEREOF, I hereunto set my hand and official seaL!
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NotavtibliC
NOTARIAL SEAL
SUZANNE M. DEDERER. Notary Public
Camp Hill Bora, Cumberland County
My Commission Expires Aug. 20, 2005
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CERI'IFICATE OF SERVICE
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SENDER. COMPLETE THIS SECTION
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. Complete items 1, 2, and 3. Also complete
item 4 if Restricted Delivery is desired.
. Print your name and address on the reverse
so that we can return the card to you.
. Attach this caW back of the mailpiece,
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If YES, enter delivery address below:
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4. Restricted Delivery? (Extra Fee) Yes
2. Article Number
(Transfer from service label)
PS Form 3811, February 2004
7003 1680 0006 5638 1044
Domestic Return Receipt
102595-02-M-1540
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CERTIFIED MAILTM RECEIPT
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FEDERAL SQUARE STATION
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171089998
4134870115-0095
04/08/2005 (717)238-2202 08:55:40 AM
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JANE OWENS,
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
: NO. 05-1814 Civil Term
v.
CIVIL ACTION - LAW
JON OWENS,
IN DIVORCE
Defendant
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
April 7, 2005.
2. The marriage between 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 in 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 and 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
unsworn falsification to authorities.
Date:~
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Jane Owens
SSN: 164-58-8173
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JANE OWENS,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
: NO. 05-1814 Civil Term
v.
CIVIL ACTION - LA W
JON OWENS,
IN DIVORCE
Defendant
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
April 7,2005.
2. The marriage between Plaintiff and Defendant is irretrievably broken and ninety
(90) days have elapsed from the date of filing and service ofthe Complaint.
3. I consent to the entry of a final decree in divorce after service of Notice ofIntention
to Request Entry of the Decree.
4. I understand that I may lose rights concerning alimony, division of property,
lawyer's fees and 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
unsworn falsification to authorities.
Date:~
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JANE OWENS,
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
: NO. 05-1814 Civil Term
v.
: CIVIL ACTION - LAW
JON OWENS,
: IN DIVORCE
Defendant
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! 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 understand 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 unsworn
falsification to authorities.
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JANE OWENS,
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
: NO. 05-1814 Civil Term
v.
: CIVIL ACTION - LA W
JON OWENS,
: IN DIVORCE
Defendant
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the following information, to the Court for entry
of a Divorce Decree:
1. Ground for divorce: irretrievable breakdown under Section 3301(c) of the
Divorce Code.
2. Date and manner of service of the Complaint: April 15, 2005 by U.S. Certified
Mail, Restricted Delivery, Return Receipt Requested, No. 7003 168000065638 1044. A copy of
which is attached hereto.
3. Date of execution of the Affidavit required by Section 3301(d) of the Divorce
Code: July 18,2005 by Plaintiff. By Defendant, July 18,2005. Both Affidavits of Consent
are being filed simultaneously with this Praecipe.
4. There are no related claims pending.
5. Indicate date and manner of service of the Notice oflntention to File Praecipe
to Transmit Record, and attach a copy of said Notice under Sections 3301(c) or
3301(d)(1)(i) of the Divorce Code: Plaintiffs Waiver executed on July 18, 2005.
Defendant's Waiver executed on July 18, 2005. Both Waivers are being filed
simultaneously with this Praecipe.
Date:
Respectfully submitted,
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Attorney For Plaintiff
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF
PENNA.
JANE OWENS
NO. 05-1814 Civil Tenn
VERSUS
JCt'l OWENS
DECREE IN
DIVORCE
AND NOW,
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, we.,> , IT IS ORDERED AND
Z7
DECREED THAT
Jane <:Mens
, PLAINTIFF,
AND
Jon Chiens
, 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 attached Marital Settlerrent Agreement is incXJrporated but not
rrerged into this Decree in Divorce.
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By THE COURT:
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PROTHONOTARY
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