HomeMy WebLinkAbout06-5481
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Patrice M. Ross,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
~ NO. 06- .rlJPl CIVIL TERM
v.
Rhody K. Ross,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in Court. If you wish to defend against the claims set forth
in the following pages, you must take prompt action. You are warned that if you fail to
do so, the case will proceed without you and a decree in divorce or annulment may be
entered against you for any other claim or relief requested in these papers by the
Plaintiff. You may lose money or property or other rights important to you, including
custody or visitation of your children.
When the ground for the divorce is indignities or irretrievable breakdown of the
marriage, you may request marriage counseling. A list of marriage counselors is
available in the Office of the Prothonotary at the First Floor, Cumberland County
Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL
PROPERTY, LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE IS GRANTED,
YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
(717) 249-3166
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Patrice M. Ross,
Plaintiff
v.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 06- S'IPI CIVIL TERM
: CIVIL ACTION - LAW
: IN DIVORCE
Rhody K. Ross,
Defendant
COMPLAINT IN DIVORCE
1. Plaintiff is Patrice M. Ross, an adult individual, currently residing at 907
Spring Circle, Mechanicsburg, Cumberland County, Pennsylvania.
2. Defendant is Rhody K. Ross, an adult individual, currently residing at 907
Spring Circle, Mechanicsburg, Cumberland County, Pennsylvania.
3. Plaintiff and Defendant are bonafide residents of the Commonwealth of
Pennsylvania and have been so for at least six months immediately previous to the filing
of this complaint.
4. Plaintiff and Defendant were married on August 24, 1985 in Hershey
Dauphin County, Pennsylvania.
5. There have been no prior actions for divorce or annulment between the
parties.
6. The Defendant is not a member of the Armed Forces of the United States
of America, or its Allies.
7. The Plaintiff has been advised of the availability of counseling and the
right to request that the Court require the parties to participate in counseling. Knowing
this, the Plaintiff does not desire that the Court require the parties to participate in
counseling.
--/1-
8. Plaintiff and Defendant are citizens of the United States of America.
9. The parties have lived separate and apart since November 28, 2002 and
continue to live separate and apart as of the date of this Complaint; although each
resides in the same residence currently there has been a period of separate residency.
10. The parties' marriage is irretrievably broken.
11. Plaintiff desires a divorce based upon the belief that Defendant will, after
ninety days from the date of the filing of this Complaint, consent to this divorce.
WHEREFORE, Plaintiff requests your Honorable Court to enter a decree In
divorce.
COUNT II
EQUITABLE DISTRIBUTION
12. Paragraphs 1 through 11 are incorporated herein by reference as if set
forth in their full text.
13. Plaintiff and Defendant are joint owners of various items of personal
property, furniture and household furnishings acquired during their marriage, which are
subject to equitable distribution.
14. Plaintiff and Defendant have incurred debts and obligations during their
marriage, which are subject to equitable distribution.
WHEREFORE, Plaintiff requests your Honorable Court to enter a decree
equitably dividing the parties' property and equitably apportioning the debts incurred by
the parties.
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COUNT III
CUSTODY
15. Paragraphs 1 through 14 are incorporated herein by reference as if set
forth in their full test.
16. Plaintiff seeks custody of her child Evan C. Ross, born on November 21,
1990.
17. The child is presently in the custody primarily of plaintiff and defendant.
18. The child has lived at the following addresses:
Name
Evan C. Ross
Address
907 Spring Circle
Mechanicsburg, PA
Dates
Birth - Present
19. The relationship of the plaintiff to the child is that of natural mother.
20. The relationship of the defendant to the child is that of natural father.
21. The plaintiff has not participated as a party or in any other capacity in
other litigation concerning the custody of the child in this or any other Court.
22. Plaintiff has no information of a custody proceeding concerning the child
pending in a Court of this Commonwealth.
23. Each parent whose parental rights to the child have not been terminated
and the person who has physical custody of the child have been named as parties to
this action.
24. No other persons are known to have or claim to have any right to custody
or visitation of the child other than the parties to this action.
25. The best interest and permanent welfare of the child will be served by
granting the relief requested because the Plaintiff is the primary care giver with respect
to the child.
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26. Each parent whose parental rights to the child have not been terminated
and the person who has physical custody of the child have been named as parties to
this action.
WHEREFORE, plaintiff requests your Honorable Court to schedule a conciliation
conference and subsequently grant the plaintiff's requests for shared legal custody and
primary physical custody of the child to the plaintiff with partial physical custody of the
child to the defendant.
Respectfully Submitted
TURO LAW OFFICES
q JI'i )O/R
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Date
en R. Waltz, Es
28 South Pitt Str
Carlisle, PA 17013
(717) 245-9688
Attorney for Plaintiff
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VERIFICATION
I verify that the statements made in the foregoing Divorce Complaint are true and
correct. I understand that false statements herein made are subject to the penalties of
Pa.C.S. 94904 relating to unsworn falsification to authorities.
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Date
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Patrice M. Ross
PT
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CERTIFICATE OF SERVICE
I, Galen R. Waltz, Esquire hereby certify that I served a true and correct copy of
the Complaint in Divorce, by depositlf same in the United ~tates Mail, Certified Return
Receipt Requested on the /4} day of ~ ~- L~-, 2006, from Carlisle,
Pennsylvania, addressed as follows:
Rhody K. Ross
Better Deal Cellular
2152 Palomino Road
Dover, PA 17315
TURO LAW OFFICES
alen R. Waltz, Esquir
28 South Pitt Street
Carlisle, PA 17013
(717) 245-9688; FAX 717.245.2165
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Patrice M. Ross,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
~ NO. 06- 5 L.j t { CIVIL TERM
v.
Rhody K. Ross,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
COMPLAINT FOR CUSTODY
1. Plaintiff is Patrice M. Ross, an adult individual. currently residing at 907
Spring Circle, Mechanicsburg, Cumberland County. Pennsylvania.
2. Defendant is Rhody K. Ross. an adult individual, currently residing at 907
Spring Circle. Mechanicsburg, Cumberland County, Pennsylvania.
3. Plaintiff seeks custody of her child Evan C. Ross, born on November 21,
1990.
4. The child is presently in the custody primarily of plaintiff and defendant.
5. The child has lived at the following addresses:
Name
Evan C. Ross
Address
907 Spring Circle
Mechanicsburg, PA
Dates
Birth - Present
6. The relationship of the plaintiff to the child is that of natural mother.
7. The relationship of the defendant to the child is that of natural father.
8. The plaintiff has not participated as a party or in any other capacity in
other litigation concerning the custody of the child in this or any other Court.
9. Plaintiff has no information of a custody proceeding concerning the child
pending in a Court of this Commonwealth.
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II
10. Each parent whose parental rights to the child have not been terminated
and the person who has physical custody of the child have been named as parties to
this action.
11. No other persons are known to have or claim to have any right to custody
or visitation of the child other than the parties to this action.
12. The best interest and permanent welfare of the child will be served by
granting the relief requested because the Plaintiff is the primary care giver with respect
to the child.
13. Each parent whose parental rights to the child have not been terminated
and the person who has physical custody of the child have been named as parties to
this action.
WHEREFORE, plaintiff requests your Honorable Court to schedule a conciliation
conference and subsequently grant the plaintiff's requests for shared legal custody and
primary physical custody of the child to the plaintiff with partial physical custody of the
child to the defendant.
Respectfully Submitted
TURO LAW OFFICES
Cf:) '1/ CJ ,
Date
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VERIFICATION
I verify that the statements made in the foregoing Custody Complaint are true
and correct. I understand that false statements herein are made subject to the penalties
of 18 Pa.C.S. ~4904 relating to unsworn falsification to authorities.
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Date
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Patrice Ross
CERTIFICATE OF SERVICE
I, Galen R. Waltz, Esquire hereby certify that I served a true and correct copy of
the Custody Complaint, by depositing same in the United States Mail, certified return
receipt request, postage paid on the / q 1A. day of ,., s..~-:fcz,...., ~.r , 2006, from
Carlisle, Pennsylvania, addressed as follows:
Rhody K. Ross
Better Deal Cellular
2152 Palomino Road
Dover, PA 17315
TURO LAW OFFICES
.
en R. Waltz, Es uire
28 South Pitt Street
Carlisle, PA 17013
(717) 245-9688; FAX 717.245.2165
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PATRICE M. ROSS
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
06-5481 CIVIL ACTION LAW
RHODY K. ROSS
DEFENDANT
IN CUSTODY
ORDER OF COURT
AND NOW,
Monday, September 25,2006
, upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator,
at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, October 24, 2006 at 10:30 AM
for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or
if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary
order. All children age five or older may also be present at the conference. Failure to appear at the conference may
provide grounds for entry of a temporary or permanent order.
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearinl?;.
FOR THE COURT,
By: /s/
Jacqueline M. Verney. Esq.
Custody Conciliator
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The Court of Common Pleas of Cumberland County is required by law to comply with the Americans
with Disabilites Act of 1990. For infonllation 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.
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
HA VE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
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SEPARATION AGREEMENT AND
PROPERTY SETTLEMENT
This Agreement, made and entered into this J 1 th day of (Tanu.llrY
200', between Patrice M. Ross, of 907 Spring Circle, Mechanicsburg, Cumberland
County, Pennsylvania, herein referred to as "Wife," and Rhody K. Ross, of 907 Spring
Circle, Mechanicsburg, Cumberland County, Pennsylvania, hereinafter referred to as
"Husband."
WHEREAS, the parties hereto are now Wife and Husband, having been lawfully
married to each other August 24, 1985 in Dauphin County, Pennsylvania;
WHEREAS, there have been two children born of this marriage between
Husband and Wife, to wit: Connor M. Ross, date of birth May 9, 1988 and Evan C.
Ross, date of birth November 21. 1990.
WHEREAS, the parties hereto are now living separate and apart, albeit at the
same residential address, and desire to enter into an Agreement respecting their
property rights regardless of the actual separation or other character thereof and their
other rights, including the Wife's right to support and maintenance;
WHEREAS, both and each of the parties hereto have been advised of their legal
rights and the implications of this Agreement and the legal consequences that may and
will ensue from the execution hereof, and each has had the opportunity to consult with
his or her own competent legal counsel independent of each other;
WHEREAS, each party warrants, as part of the consideration of this Agreement,
that each has fully and completely disclosed all information of a financial nature
requested by the other, and that no information of such nature has been subject to
distortion or in any manner being misrepresented; and
WHEREAS, other than as set forth herein, Wife desires finally and forever to
relinquish all of her rights to be supported by Husband and all of her rights of dower,
rights as heir or surviving spouse or otherwise, actual, currently existing, or inchoate, in
and to the real and personal property of the Husband, now owned by him or which in
the future may be owned by him, and all rights to counsel fees, or expenses and, other
than as set forth herein, Husband likewise wishes to relinquish all his rights of curtsey,
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rights as heir or surviving spouse or otherwise, actual and currently existing or inchoate
in and to the real and personal estate of the Wife, currently owned by her or which she
may own in the future;
NOW THEREFORE, the parties hereto intending to be legally bound hereby do
hereby mutually agree as follows:
1. Separation: Husband and Wife do hereby mutually agree and consent to live
separate and apart and do further agree that it shall be lawful for the Husband and Wife
at all times hereafter to live separate and apart from each other, and to reside, from time
to time, at such place or places as they respectfully shall deem fit, free from any control
or restraint or interference, direct or indirect, by each other.
2. Mutual Power and Estate Waiver: Except as otherwise expressly set forth
herein, in which event such express provision shall take precedence over this
paragraph, the parties hereto intend that from and after the date of this Agreement,
neither shall have any spouse's rights in property or estate of the other, and to that end
both parties waive, relinquish and forbear the rights of dower of curtsey, rights to inherit,
rights to claim or take the Husband or Wife's or family exemption or allowance, to be
vested with letters of administration or letters testamentary, or to take against any will of
the other, and each agrees with the other if either should die intestate, his or her share
shall descend to vest in his or her heirs at law, personal representatives, and next of
kin, excluding the other as though he or she had died a widow or widower. And each
further agrees that should the other die testate, his or her property shall descend to and
vest in those persons set forth in the other's Last Will and Testament as though the
spouse so designated as beneficiary had predeceased the testator. The parties further
agree that they may and can hereafter, as though married, without any joinder by him or
her, sell, convey, transfer or encumber any and all real estate and personal property
which either of them now or hereafter own or possess and further agree that the
recording of this Agreement shall be conclusive evidence to all of his or her right to do
so. The said Husband and Wife do hereby irrevocably grant, each to the other, should
the exercise of this power hereby given be necessary, the right and the power to
appoint one or more times any person or persons whom the Husband or Wife shall
designate to be the attorney-in-fact for the other, in their name and in their stead, to
execute and acknowledge any deed or deeds, releases, quit claims, or satisfactions,
2
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under seal or otherwise, to enable either party hereto to alienate his or her real personal
property, but without any power to impose personal liability for breach of warranty or
otherwise. Each of the parties hereto further waives any right of election contained in
Chapter 22 of the Pennsylvania Probate Estates and Fiduciaries Code, and any right to
seek or have an equitable distribution or married property ordered by the Court
subsequent to Section 3502 of the Divorce Code. Each of the parties hereto further
agrees that neither shall hereafter be under any legal obligations to support the other,
pay any expenses for maintenance, funeral, burial, or otherwise for the other, and to
that end each of the parties hereto does hereby waive any right to receive support,
alimony, alimony pendente lite, counsel fees, expenses, or any type of financial
assistance whatsoever from the other, except as otherwise expressly provided for
herein.
3. Child Custody: The parties have mutually agreed to attain flexibility within the
custody of the minor child, Evan C. Ross, and therefore agree to continue shared
custody by allowing the child to select visitations and residence according to his choice.
Wife agrees to withdraw the Custody Complaint filed at 06-5481.
4. Support:
a. Child Support.
support.
b. Medical Care for the Children. The parties agreed that the children shall
be carried upon the employer sponsored medical insurance programs provided to
Husband/Wife. Husband/Wife agrees to pay one-half of any yearly deductible under
said plan, as well as one-half of any year fee assessed to Husband/Wife for the
operation of the plan. The parties further agree that any medical or dental expenses for
the children not covered by insurance shall be divided equally between them.
5. Distribution of Marital Assets:
a. The parties agree that the items of personal property shall be divided
equally and evenly. All other personal property obtained by the parties during the
marriage shall be sole and exclusive property of the Husband/Wife. Henceforth, each of
the parties shall own, have and enjoy, independently of any claim of right of the other
party, all items of personal property of every kind, nature and description and
wheresoever situated which are now owned or held by or which may hereinafter belong
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The wife has agreed to not seek court ordered child
"
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to the Husband or Wife respectively, with full power to the Husband or Wife to dispose
of the same as fully and effectually in all respects and for all purposes as if he or she
were unmarried.
b. The parties agree that the 1991 Honda Accord, Vin. No.
1HGCB7650MA140182 shall be the sole and separate property of the Husband. The
parties agree that the 1998 Subaru Legacy, Vin. No. 4S3B6756W7201287 shall be the
sole and separate property of the Wife. The parties are also owners of a pet;
Hound/German Shepard named "Paige" which shall be shared 50/50 by the parties. The
parties shall share all costs and expenses for the pet "Paige" 50/50.
c. Personal effects. All items of personal effect such as but not limited to
jewelry, luggage, sports equipment, hobby collections and books but not including
furniture or any other property, personal or otherwise specifically disposed of pursuant
to this Agreement shall become the absolute and sole property of the party who has had
the principal use thereof or tow whom the property was given or from whom it was
purchased, and each party hereby surrenders and interest he or she may have in such
tangible personal property of the other.
6. Debt: Wife's debts are solely her responsibility and Husband's debts are solely
his responsibility. Each shall hold the other harmless from liability from his/her debts.
Wife agrees to assume Husband's debt to Wife's mother pending Husband's
documentation for home improvements. Husband agrees to assume his debts to his
parents and sister.
7. Future Debts: The parties further agree that neither will incur any more future
debts for which the other may be held liable, and if either party incurs a debt for which
the other will be liable, that party incurring such debt will hold the other harmless from
any and all liability thereof.
8. Real Property:
a. The parties agree that the real property located at 907 Spring Circle,
Mechanicsburg, Cumberland County, Pennsylvania shall be deeded solely into Wife's
name. The outstanding Mortgage is with Members 1st Credit Union, P.O. Box 24146,
Fort Worth, Texas, 76124, Account No. 177015-01 with a balance as of 12/06/2006 of
$64,000. An appraisal for the property was performed October 10, 2006 and valued the
property at $184,000. Wife agrees to refinance the 907 Spring Circle property solely in
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4
her name. Wife shall pay to Husband $45,000 after refinancing. Husband shall execute
all documents necessary for the successful transfer and refinancing of the 907 Spring
Circle, Mechanicsburg, Pennsylvania property to Wife. Shall wife subsequently decide
to sell the residence; Husband will be given right of first refusal. The sales agreement
will be a part of wife's last will and testament. Wife shall have payment made to
husband in the amount of $45,000.00 at the time of refinancing.
b. Upon Payment to Husband of $45,000.00, Husband shall have up to 30
days to remove all of his personal property from the home and relinquish all rights to
remain within the residence. Husband agrees to pay a prorated rent to wife in the
amount of $500.00 per month. Husband will be given 15 days to vacate the residence
following the settlement. If additional time is needed, Husband agrees to pay Wife
$500.00 for an additional 15 days, not to exceed those 30 days.
9. Alimony: In consideration of the mutual agreement of the parties voluntarily to
live separate and apart and the provisions contained herein for the respective benefit of
the parties and other good and valuable consideration, the parties agree to waive any
and all claims for any alimony.
10. Pension: Both parties agree to waive any claims they may have to any pension
or employment benefits of any kind, earned during the marriage, by the other party.
11. Counsel Fees and Court Costs: Each party agrees to pay their own attorney
fees and cost incurred in the preparation of this document, as well as the preparation
and filing of the divorce action captioned at 2006-5481 Civil Term and the Custody
Complaint filed at the same number. If either party incurs any other legal fees or court
costs, those costs will be borne by the party exclusively.
12. Divorce: The parties acknowledge that an action for divorce between them has
been filed by Wife and is presently pending a divorce between them in the Court of
Common Pleas of Cumberland County to the caption Patrice M. Ross v. Rhody K.
Ross, 2006-5481 Civil Term. The parties acknowledge their intention and agreement to
proceed in said action to obtain a final decree in divorce by mutual consent on the
grounds that their marriage is irretrievably broken, and to settle amicably and fully
hereby all claims raised by either party in the divorce action. The parties
acknowledged they have executed simultaneously herewith the necessary Affidavits of
Consent for the entry of a final divorce decree in that action.
5
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13. Breach: In the event that either party breaches any provision of this Separation
and Property Settlement Agreement, he or she shall be responsible for any and all costs
incurred to enforce the terms hereof, including, but not limited to, court costs and
reasonable counsel fees of the other party. In the event of breach, the other party shall
have the right, at his or her election; to sue for damages for such breach or to seek such
other and additional remedies as may be available to him or her.
14. Enforcement: The parties agree that this marital settlement agreement or any
part or parts hereof may be enforced in any Court of competent jurisdiction.
15. Applicable Law and Execution: The parties hereto agree that this Marital
Settlement Agreement shall be construed under the laws of the Commonwealth of
Pennsylvania and shall bind the parties hereto and their respective heirs, executors and
assigns. This document shall be executed as original and multiple copies.
16. The Entire Agreement: The parties acknowledge and agree that this Marital
Settlement Agreement contains the entire understanding of the parties and supersedes
any prior agreement between them. There are not other representatives, warranties,
promises, covenants or understandings between the parties other than those expressly
set forth herein.
17. Additional Instruments: Each of the parties shall on demand or within a
reasonable period thereafter, execute and deliver any and all other documents and do
or cause to be done any other act or things that may be 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 attorney's fees,
costs, and other expenses reasonably incurred as a result of such failure.
6
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IN WITNESS WHEREOF, the parties have set their hands and seals the day and
year first written above.
WITNESSES:
0~7~o.M~i07
/ Patrice M. Ross /
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SENDER: COMPLETE THIS SECTION
. Complete items 1, 2, and 3. Also complete
item 4 if Restrictecl Delivery is desirecl.
. Print your name and address on the reverse
so that we can return the card to you.
. Attach this card to the back of the mail piece.
or on the front if space permits.
1. Article Addressed to:
RnodLj K 1<05S
1:>-eifer JJpoj {e If uja r
c2l.5a P()L!om,'n6 Rd
DOVey po- /73/5
2. Article Number
(Transfer from service labelj
PS Form 3811 , February 2004
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COMPLETE THIS SECTION ON DELIVERY
D. Is delivery address different from Item 1?
If YES, enter delivery address below:
3. .~1YPe
~Ifled Mall 0 Express Mall
[J Registered 0 Return Receipt for Merchandise
o Insured Mail 0 C.O.D.
4. Restricted Delivery? (Extra Fee) 0 Yes
7005 0390 0003 2638 2709
102595-Q2-M-1540
Domestic Return Receipt
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Patrice M. Ross,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 06-5481
CIVIL TERM
Rhody K. Ross,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under ~3301 (c) of the Divorce Code was filed on
September 19, 2007.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety
(90) days have elapsed from the date of the filing of the Complaint.
3. I consent to the entry of the final Decree in Divorce after service of Notice
of Intention to request entry of the decree.
I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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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~'Wk-
atrice M. Ross
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Patrice M. Ross,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 06-5481
CIVIL TERM
Rhody K. Ross,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under 93301 (c) of the Divorce Code was filed
on September 19, 2007.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety
(90) days have elapsed from the date of the filing of the Complaint.
3. I consent to the entry of the final Decree in Divorce after service of Notice of
Intention to request entry of the decree.
I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT
ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN
ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. 94904 RELATING TO
UNSWORN FALSIFICATION TO AUTHORITIES.
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Patrice M. Ross,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 06-5481
CIVIL TERM
Rhody K. Ross,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
WAIVER OF INTENT!ON TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
~ 3301 (g 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 THE FOREGOING AFFIDAVIT
ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN
ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. 94904 RELATING TO
UNSWORN FALSIFICATION TO AUTHORITIES.
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Patrice M. Ross,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 06-5481
CIVIL TERM
Rhody K. Ross,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
WAIVER OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
~ 3301 (9 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 THE FOREGOING AFFIDAVIT
ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN
ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. 94904 RELATING TO
UNSWORN FALSIFICATION TO AUTHORITIES.
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Patrice M. Ross,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY. PENNSYLVANIA
v.
: NO. 06-5481
CIVIL TERM
Rhody K. Ross,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
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 9 (3301 (c)) of the
Divorce Code.
2. Date and manner of service of the complaint: Certified, Returned Receipt
mail delivered on or about September 20, 2006
3. Date of execution of the Affidavit of Consent required by 93301 (c) of the
Divorce Code.
By Plaintiff: January 18, 2007 By Defendant: January 19, 2007
4. Related claims pending: None.
Date the Waiver of Notice in 93301 (c) divorce was filed with the
Prothonotary:
By Plaintiff: January 22, 2007
By Defendant: January 22, 2007
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IN THE COURT OF COMMON PLEAS
OFCUMBERLANDCOUNTY
STATE OF
PENNA.
Patrice M. Ross
Plaintiff
No. 06-5481
VERSUS
Rhody K. Ross
Defendant
DECREE IN
DIVORCE
AND NOW,
<1,-" 'i
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Patrice M. Ross
L]J
IT IS ORDERED AND
2007
DECREED THAT
, PLAI NTI FF,
AN D Rhody K. Ross
, 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;
Separation and Property Settlement Agreement is incorporated
herein but not merged in the Divorce Decree.
PROTHONOTARY
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JAM 19
PATRICE M. ROSS,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
V.
: NO. 2006-5481 CIVIL ACTION - LAW
RHODY K. ROSS,
Defendant
: IN CUSTODY
ORDER OF COURT
AND NOW, this 19th day of January, 2007, the Conciliator being notified that the
parties have reached an agreement, the Conciliator hereby relinquishes jurisdiction in this
matter.
FOR THE COURT,
y Conciliator
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