The URL can be used to link to this page

Home My WebLink About06-6100 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, COMMONWEALTH OF PENNSYLVANIA SEAN C. JONES, PLAINTIFF, Civil Action---Divorce Docket No. 01- -I.. 160 C/(..{r~ V. KRISTIN M. JONES, DEFENDANT, NOTICE TO DEFEND AND CLAIM OF 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. 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 LA WYER 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 A VENUE Carlisle, Pennsylvania 17101 (717) 249-3166 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, COMMONWEALTH OF PENNSYL VANIA SEAN C. JONES, PLAINTIFF, Civil Action---Divorce Docket No. V. KRISTIN M. JONES, DEFENDANT, A VISO PARA DEFENDER Y RECLAMAR DERECHOS USTED HA SIDO DEMANDADO EN LA CORTE. Si desea defenderse de las quejas expuestas en las paginas siguientes, debe tomare accion con prontitud. Se Ie avisa que si no se defiende, el caso puede pro ceder sin usted y decreto de divorcio 0 anulaminento puede ser emitido en su contra por la Corte. Una decision puede tambien ser emitida en su contra por cualquier otra queja 0 compensacion rec1amados por el demandante. Usted puede perder dinero, 0 propiedades u otros derechos importantes para usted. Cuando la base para el divorcio es indignidades 0 rompimiento irreparable del matrimonio, usted puede solicitar consejo matrimonial. Una lista de consejeros matrimoniales esta disponible en la officina del Prothonotary, en la Cameron County Court of Common Pleas, East 5th Street, Emporium, Pennsylvania 15834. SI US TED NO RECLAMA PENSION ALIMENTICIA. PROPIEDAD MARITAL. HONORARIOS DEABOGADO U OTROS GASTOS ANTES DE QUE EL DECRETO FINAL DE DIVORCIO 0 ANULIAMIENTO SEA EMITIDO. USTED PUEDE PERDER EL DERECHO A RECLAMAR CUALQUIERA DE ELLOS.USTED DEBELLEV AR ESTE P APELA UN ABOGADO DE INMEDIATO SI NO TIENEPUEDEP AGAR UN ABOGADO. VA Y A 0 LLAME A LOFFICINAINDICADA ABAJO PARA A VERIGUAR DONDE PUEDE OBTENER AS IS TENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE Carlisle, Pennsylvania 17101 (717) 249-3166 AVAILABILITY OF COUNSELING THE DIVORCE CODE OF PENNSYL VANIA REQUIRES THAT YOU BE NOTIFIED OF THE AVAILABILITY OF COUNSELING WHERE A DIVORCE IS SOUGHT UNDER ANY OF THE FOLLOWING GROUNDS: 23 Pa.C.S. & 3301 (a)(6)-------Indignities 23 Pa.C.S. & 3301 (c)----------Irretrievable Breakdown; Mutual Consent 23 Pa.C.S. & 3301 (d)----------Irretrievable Breakdown; Two year separation where the court determines that there is a reasonable prospect of reconciliation. A list of marriage counselors is available in the Office of the Prothonotary Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013. reg S. quire A rney for Plaintiff West Main Street Mechanicsburg, Pennsylvania 17055 (717) 790-5500 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, COMMONWEALTH OF PENNSYL VANIA SEAN C. JONES, PLAINTIFF, Civil Action---Divorce Docket No. Ol- - tj 111 C;u~(Tw., V. KRISTIN M. JONES, DEFENDANT, COMPLAINT UNDER SECTION 330HC) OR 3301 (D) OF THE DIVORCE CODE PARTIES 1. Plaintiff is Sean C. Jones, an adult individual, sui juris an who currently resides at 3727 North 3rd Street, Enola, 17025 in the County of Cumberland, Commonwealth of Pennsylvania. 2. Defendant, is Kristin M. Jones, an adult individual, sui juris, who currently resides at 27 East North Avenue, Enola 17025 in the County of Cumberland Commonwealth of Pennsylvania. JURISDICTION & VENUE 3. Plaintiff has been a resident of the Commonwealth of Pennsylvania for a period of more than 6 months. 4. The parties were married on the May 20th, 1999 in the County of Baltimore, State of Maryland. 5. Neither the Plaintiff nor the Defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 6. There have been no prior actions for divorce instituted by the plaintiff or defendant in this Commonwealth. COUNT I GROUNDS FOR DIVORCE REQUEST FOR A NO-FAULT DIVORCE UNDER SECTION 3301 (d) OF THE DIVORCE CODE. 7. For the purposes of section 3301 (d) of the Divorce Code, the parties have been living separate since May 21 S\ 2006 8. The marriage is irretrievably broken, 9. Plaintiff has been advised that counseling is available and that the plaintiff may have the right to request that the court require the parties to participate in counseling. WHERFORE, plaintiff requests that the Honorable Court grant a decree of divorce pursuant to, and in conformity with 3301 (d) of the Divorce Code. 11. The parties do not have any biological children born within or outside of the marriage. 12. The parties have not heretofore entered into any written agreement as to support, Alimony, or property division. COUNT I GROUNDS FOR DIVORCE REQUEST FOR A NO-FAULT DIVORCE UNDER SECTION 3301 (C) OF THE DIVORCE CODE. 13. The prior paragraphs are incorporated herein by reference. WHEREFORE, provided the parties file affidavits consenting to a divorce after ninety (90) days have elapsed from the date of the filing and service of this Complaint, plaintiff respectfully requests the Court to enter a decree of divorce pursuant to section 330I(c) of . the Divorce Code. . , GREGORY S. HAZLETT, ESQUIRE VERIFICATION I verify that upon personal knowledge or information and belief that the statements made in this Complaint are true and cOt!ect. I understand that false statements herein are made subject to the penalties of 18 Pa C.S. ~ 4904, relating to unsworn falsification to authorities. ~e.~ Sean C. Jones, Plaintiff Date: q -1f3-CJt ~ ^t.l ~ , 6' ~ I () ~ ~ ~ ......... ..0 () . ~ p:J ~ '-I..... (') c <:: -0 eXl ITl rn z..., ~~ ;;.< ~.~" ~c .~ 8 :i>c ~ ~ ~ = C1' <::> ("") -f ~ ~:n fTl ""Qo :1;), 0(::>. .::r!" c3 :!J -",0 OIT'I .-l ')'........ :~ ex> -0 ::s: N .. (...) a. MARITAL SETTLEMENT AGREEMENT Sean C. Jones, referred to herein as HUSBAND, of 3727 N. 3rd Street, Harrisburg, Dauphin County, PA 17110 Kristin M. Jones, referred to herein as WIFE, of 27 E. North Avenue, Enola, Cumberland County, PA 17025 The parties were lawfully married on 20 May 1999 in Baltimore, Baltimore County, Maryland. There are no children born of the parties' marriage. Difficulties have occurred between the parties, and they have agreed to permanently live separate and apart from each other. The parties intend by this agreement to fully and finally settle all of their respective rights and obligations as between each other, including but not limited to the settling of all interests, rights and/or obligations between them or their estates, whether arising out of their marriage, including assets acquired by either party prior to or subsequent to the date of execution of this Agreement. The parties may seek legal advisors of their own choice regarding their legal rights and any disclosures made herein. The parties have made a complete disclosure to one another of financial matters and each is satisfied that they have had sufficient disclosure of the parties' individual and joint finances. The parties held no debt at the time of separation. Either party shall fully assume any debt they may have incurred since separation, and hold the other party harmless from the same. The parties agree to file their Federal Income Tax return for the tax year 2006 as "Married, Filing Separately" with each party being responsible for any tax debt owed to IRS for their return. Personal property of the parties had been equitably divided upon separation. Various small personal effects may later be identified and shall be returned to the rightful party. HUSBAND shall be responsible for the filing of required documents and costs necessary to obtain a divorce decree pursuant to relative Pennsylvania laws. HUSBAND shall maintain health insurance coverage for the WIFE. as provided by his current employer until the final divorce date. Both HUSBAND and WIFE agree to sign off of eachother's social security number. . IlL .. HUSBAND and WIFE hereby specifically release and waive any and all interest, claim, or right that he/she may have to any and all retirement benefits (including pension or profit sharing benefits) or other similar benefits of the other party. The parties shall execute any documents pursuant to the Retirement Equity Act or any similar Act that may be required from time to time to accomplish the purpose of this paragraph. HUSBAND and WIFE each have sufficient property and/or income to provide for hislher reasonable needs. Therefore, HUSBAND and WIFE expressly waive, discharge and release any and all rights or claims which he/she may have, now or hereafter, by reason the parties' marriage, to alimony, support, maintenance and/or other such benefits resulting from the parties' status as husband and wife. Each party acknowledges having received a fully executed original of this Agreement. In witness thereof, the parties hereto have set their hands and seals. Dated: 29 September 2006 Sean C. Jones, } HUSBAND ~ e, ~ Witness as to HUSBAND: Commonwealth of Pennsylvania, County of (' lj~~ On this 2~ day of September 2006, before me, a Notary Public for the Commonwealth of Pennsylvania, residing in 'VPf~(jCounty, personally appeared Sean C. Jones, known or proven to me to be the person whose name is subscribed to the within Agreement and acknowledged that he executed the same for the purposes therein contained. In witness wh eof, I have hereunto set my hand and official seal. I P NOTARiAl SEAL BRYAN J. KOLB, Notary Public East Pennsboro Twp., County of Cumberland My Commission Expires January 13, 2010 . . Kristin M. Jones, ~FE ~~~ Witnesses as to WIFE: State of Pennsylvania, County of ~,tS~Afi/{J /J~Y th.~ On this ~ay of September ~ before me, a Notary Public for the State of Pennsylvania, residing in4U?~ County, personally appeared Kristin M. Jones, known or proven to me to be the person whose name is subscribed to the within Agreement and acknowledged that she executed the same for the purposes therein contained. In witness whereof, I have hereunto set my hand and official seal. ~' Notary Public COMMONWEALTH OF PENNSYLVANIA r NOTARIA SEAL . MICHAEL R, CARANCI, Notary Public \ Lemoyne Boro, Cumberland County I My Commission Expires June 15.2010 1- :,. ":'." \i . 1 ' .,-', 'f. { r--:> C-' c...:> --' -n rr> c:' I C:, ~',., -- -"" r<> " ", .:~ '---:;:0."- '2 - 0' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, COMMONWEAL TH OF PENNSYLVANIA SEAN C. JONES, PLAINTIFF, Civil Action---Divorce Docket No. 06-6100 VS. KRISTIN M. JONES, DEFENDANT, CERTIFICATE OF SERVICE I, Gregory S. Hazlett, Esquire, hereby certify that on the 25TH, day of October, 2006 I made service of the foregoing Divorce Complaint and related documentation upon the defendant Kristin M. Jones by way of first class mail postage prepaid. DATED: 2/7/2007 GREGORYS.HAZLETT :;-g 0 .:...':=> 1"1 ----> ..., P"; '.....~..<i C) -0 r,) cr. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, COMMONWEALTH OF PENNSYLVANIA SEAN C. JONES, PLAINTIFF, Civil Action---Divorce Docket No. 06..~~V V. KRISTIN M. JONES, DEFENDANT, A~~RPTAN~R OF SRRVT~R I, Kristin M. Jones, accept service of the Complaint in Divorce, Notice to Defend and Notice of Availability of Counseling in the above-captioned matter. I acknowledge that I am the Defendant in said matter or that I am authorized to accept on behalf of the Defendant. IOhs;6es, , , Date ~~ 9J1. f}nM_-- Kristin M. Jones, Defen nt Q7 E. Nf}rt-h Aw-. Ennh J PA ) 7~s Mailing Address ~2 ~-:,,~. r-..,) = i..:;::... --.J -r: G""1 OJ I c,,, .J o ., :2: N 0''> IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, COMMONWEALTH OF PENNSYLVANIA SEAN C. JONES, Plaintiff, No. 06-6100 v. Civil Action - Divorce KRISTIN M. JONES, Defendant AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 330l(c) of the Divorce Code was filed on October 18th, 2006, and served upon defendant on October 25th, 2006 by way of an Acceptance of Service. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of service of the divorce Complaint. 3. I consent to the entry of a final decree of divorce. 4. I understand that I may lose rights concerning alimony, division of property, lawyers 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 are made subject to the penalties of 18 Pa. Cons. Stat. S 4904 relating to unsworn falsification to authorities. Date: :;. / d.. / 0 7 ~on:~ ~ ~ S -r'1 ~-rr~ c":.J \ -....... \.../.... IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, COMMONWEALTH OF PENNSYL VANIA SEAN C. JONES, Plaintiff, No. 06-6100 v. Civil Action - Divorce KRISTIN M. JONES, Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF 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 . 4. 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. & 4904 relating to unsworn falsification to authorities. Date: 1-/2 (t>f'"J .~ e.~ Sean c. Jones, aintiff 1""":> g 0 ........ ., """1 ::;:l r'f~j CCi CJ) -y-": ~,_-:, \"J C}''',:< IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, COMMONWEALTH OF PENNSYLVANIA SEAN C. JONES, Plaintiff, No. 06-6100 v. Civil Action - Divorce KRISTIN M. JONES, Defendant AFFIDAVIT OF CONSENT 1. A comrlaint in divorce under Section 330l( c) of the Divorce Code was filed on October 18t , 2006, and served upon defendant on October 25th, 2006 by way of an Acceptance of Service. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of service of the divorce Complaint. 3. I consent to the entry of a final decree of divorce. 4. I understand that I may lose rights concerning alimony, division of property, lawyers 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 are made subject to the penalties of 18 Pa. Cons. Stat. S 4904 relating to unsworn falsification to authorities. Date: 1j;;x{/07 ~ ~~" Kristin M. Jones, D dant - r--..:> (:::> c.::;:.::;;. .....J o 11 .." :-r1 Ci:;l I CO N en IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, COMMONWEALTH OF PENNSYL VANIA SEAN C. JONES, Plaintiff, No. 06-6100 v. Civil Action - Divorce KRISTIN M. JONES, Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF 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 . 4. 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. & 4904 relating to unsworn falsification to authorities. Date: f j:J-q /07 / I ~.iU~___ ristin M. Jones, endant G ~:';. r--..:> c:::l ~ -. g I CO ~ 0.... IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, COMMONWEAL TH OF PENNSYL VANIA SEAN C. JONES, PLAINTIFF, Civil Action---Divorce Docket No. 06-6100 VS. KRISTIN M. JONES, DEFENDANT, PRAECIPE TO TRANSMIT THE RECORD To the Prothonotary: Please 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. The complaint in Divorce was filed on the October 18th, 2006, day and served on the 25th, October, 2006 by way of Acceptance of Service on (attached hereto) 3. The plaintiff, signed his Affidavit of Consent and Waiver of Notice of Intention on the February 2nd, 2007. 4. The defendant signed his Affidavit of Consent and Waiver of Notice ofIntention to Request Entry of Divorce Decree on 29th day January 2007. 5. There are no related claims pending to the extent a Marital Settlement Agreement was signed between the parties on the 9th day of October 2006 which shall be incorporated into the Divorce Decree.. 6. The defendant signed a Waiver of Notice of Intention to Request Entry of Divorce Decree pursuant to Rule 1920.72 a copy of which is attached hereto Date: 2/7/2007 Atty. I.D. 69528 rc1 ~ t3 ~\ ~~;;~ \ c:) ~ '" "'''' '" '" "'''' '" ,.; '" ,.; '" itiiti iti;t; iti '" IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA. SEAN C. JONES NO. 06-6100 PLAINTIFF VERSUS KRISTIN M. JONES DEFENDANT DECREE IN DIVORCE l=~~ 2007 13. AND NOW, , IT IS ORDERED AND DECREED THAT SEAN C. JONES, , PLAINTIFF, KRISTIN M. JONES. AND , 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 Marital Separation Agreement executed on the 9TH day of October 2006 shall be Incorporated into the Divorce Decree and shall not merge. ATTE J. PROTHONOTARY ::f;+::f. ~:f. :+: ~;f. ~ iti ;t; '" '" "'''' "'iti '" '" "'''' "'iti '" '" '" '" "'''''''iti''''''''''''i+i'''i+i i+i"'i+ii+i i+i iti iti '" ~~ i+i '" ;f. ;f. ;f. ;f. Of' '" ;t' ;t' ;t' ;t' ;t' ;t' 'ii '" '" ;f. ~ ~ ~ . ~ .:Jl /f/~ 'ZY)t, (,(/. [1' e ~ P? I"?":'" 4; -nJ Ul' H' eo . ~.. :~:t-~