HomeMy WebLinkAbout94-00574
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MARITAL SE'M'LEMENT AGREl':MENT
THIS AGREEMENT Is made thi~ldllY of Mllt!.m~r; 19915, by and
betweon BRl':NDA G. JONES ("Wife") and JEFFREY JONES ("Husband").
WHEREAS, the parties were mnrried on November 12, 1983, nnd have
remained married since that time; and
WHEREAS, certain differences have arisen between the parties and, Il8
a consequence, they have lived Beparate and apart from each other since June
1993; and
WHEREAS, the parties ure the parents of two children born to their
marriage, ASHLEY JONES, born November 17, 19815, and ALYSIA JONES,
born June 22, 1988; and
WHEREAS the parties wish to set forth certain covenants and
understandings regarding their separation, their children, and their respelltive
property rights; and
NOW THEREFORE, in cOllsideflltfon of the mutual promiBes and
undertakings contained herein, the parties hereto, intending to be legally bound,
covenant and agree as follows:
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1. VOLUNTARY AGREEMENTI It iH Ilcknllwledged by the parties
that this Agreement is entered into volunturily and after due deliberution by
ouch of them,
2. SEPARATION AND NON.INTERFERENCEl It Hhall be lawful
for Husband and Wil'e at 011 times hereafter to live separate and apart from ellCh
other and to reside from time to time at such place or pluces as they shall
respectively deem fit, free from any control, restraint, hurassment or
interference, indirect or direct, from each other, The foregoing provisions shall
not be taken to be un udml8sion on the part of either party of tho luwfulness or
unlawfulness of the causes leading them to live apurt,
3. DIVORCE ACTIONl The purties acknowledge that an action for
divorce between them has been med by Wife in the COU\'t of Common PleM of
Cumberland County, Pennsylvaniu, JoneB v. .10llI1B, No, 074 Civil 1994, In
Divorl,le, The parties hereby acknowledge their intention and agreement to
proceed in said action to obtain Il flnal decree in divorce by mutual COllsent on
the grounds that their marriage ill irretrievably broken, and to settle amicably
and fully hereby all claims which might be raised by either party in the divorce
action. The partie8 acknowledge that thoy willllxecute simultaneously hel'owith
tho nocessal'y Affidavits of COllsent for the entry of a flnal divorce decree in the
pending action,
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4. CUSTODY OF CHILDRENl The parties acknowledge that they
have entered Into a Stipulation for Custody, whereby they have afll'lled to IIhare
legal custody of their minor children, and grant Wife primary physical custody
of the children, subject to Husband's rights of partial physical custody for tho
purpose of vlsitfiltion on a liberal schedule. The parties acknowledge that the
terms of their custody agreement have been entered us an Order of Court in
Cumberland County.
The parties acknowledge that the terms of the said Order of Court for
custody of the children is always subject to review by Il court of competent
jurisdiction based upon the best interests of the children.
Each party agree~ to cooperate to the maximum extent possible to allow
the other party access to the children when they are not in the custody of such
parent and to undertake their best effort to serve the best Interest of their
children in their parenting,
5. CHILD SUPPORT AND MAINTENANCE: Both parties
ackno.vledge their obligation and intent to contribute toward the support of
their minor children. On the basis of the parties' present Income, Husband
agrees to pay to Wife as child support for ASHLEY and ALYSIA, and Wife
agrees to accept f'rom Husband, the sum of $406.00 per month. Wife agrees to
accept such payment from Husband on a voluntary basis without court
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intervention, as long such pllymontK IIro rogular and timely. Nonotheloss, it is
acknowledged that the obligation for and tho amount of' child support is always
subject to review by a Court of competent. jurisdiction and may be modllled
either up or down frqm tho amount set forth above and that, the parties agree
that any Iluch modification shull in fuct be the amount of support due and
payable under the terms of this agreement. If Husband shall fail in his
obligation, Wife shall seek an order of court directing the payment of child
support on the basis of the respectivo incomes and needs 01' the parties as
determined under applicable law and support guidelines. The parties
acknowledge that the terms of this Agreement with regard to child support,
including the costs of providing Ihr health insurance or medical expenses of the
children, are always subject to review by a court of competent jurisdiction.
6. COLLEGE EXPENSESI The parties hereto acknowledge and
ngree that it is their hope and expectation that t.heir children will attend
undergraduate college or its equivalent after high school. They agree that they
shall contribute equally to the expeme of their education in accordance with the
needs of their children and their rcspoctive incomes and abilities at the time.
Neither part.y shall be obligatod under the terms of this provision to pay more
than the other party towards a child's education and both parties shall have the
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full right to participate in the decision UK to the undergraduate colhlge which
either of their children may attend Ilnd tho further right to approve of tho
undergradullte collego llolocted by Kllld child, which approval Bhall not be
unreaCllonably denied.
7. WEDDING EXPENSESI The partieB hereto acknowledge their
hope and expectation that their daughters will, nt an appropriate age, bo
married. The parties agreo that they shall contr.ibute equally to the relillonable
expenses of the weddings of their daughters In Ilccordance with their IncomeB
and abilities at the time, Neither party shull he obligated under the terms of
this provision to pay morc than the other purty townrds a child's wedding Ilnd
both parties shall have tho right to participate In the decision us to the wedding
arrangoments for said child.
8. MEDICAL AND HOSPITALIZATION INSURANCEI The
parties agreo that the parent who can provide the medical Ilnd hospitalization
Insurance for the benefit of their children at the lenat COBt nnd greateBt benefit
will do BO. In addition, the purties ugree to shure allunlnBured modlcal, dental,
optical and orthodontal exponse Incurred by the children with each paying a
portion of said uninsured expenses based on u percentage of their respective
IncomeB, A8 of the date of the execution of this agreement, Wife through her
employment is providing the medical und hospitalization insurance referred to
herein.
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9. RF.AL PROPERTYI
11. The partle8 ncknowledge that they are the joint ownerll of 11
certain hou8e and real property at 3/1 Locust Drive, Newburg, Cumberland
County, PA, which was acquired by them during the mlU'rlage, and constitutes
marital propel'ty. The partie8 acknowledge that, during the la8t two yean,
HUllband has enjoyed exclu81ve p08se8slon of the jointly titled premises and hf18
paid all tax a88essments, lions, mortgage and/or equity loan Indebtedness or
other obligations related to the house and r"al property during the period of his
residency. With regard to 8uch payments made to date, and to all future
expen8es and obligations related to the said mnrltal premlse8. HU8band hereby
Indemnltie8 Wife and hold8 her harmless,
b. Husband agrees that he 8hall refinance the existing mortgage
and home equity loans secured against the premlse8 In his name alone, or
otherwl8e arrange to have Wife's name removed of record, or be marked
8ati8fied with regard to the said obllgation8.
c. In consideration of Husband's covenants under thiB Agreement,
and upon his sati8factlon, In particular, of' hl8 obligation under paragraph 11
hereof, Wife agree8 to release to Husband any Interest, title or claim she may
have In the 8ald property at 3/1 Locust Drive, Newburg, Cumberland County,
PA, and will execute any documents Including any deeds, relellBos, or
Batisfaction pieces presented to her to confirm such release,
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d. The partieK acknowledge nnd certify that they own no other
real property either jointly or individually.
10. PERSONAL PROPERTYI The parties acknowledge that there
hlUl been distribution between them of their items of personal, tangible and
intangible property, including various bank accounts, m.otor vehicles, stocks,
bonds, and other securities, and they agree that the divillion thereof is to their
mutual satisfaction, subject to the modifications set forth on Addendum 1,
which is attached horeto and made a part hereof. Except as provided for within
this Agreement, each of the partieB shall hereafter own and enjoy, independently
of any claim or right of the other party, all items 01' personal, tangible and
intangible property now or heroafter owned or held by her or him with full
power to dispose of the same effectively and for all purposes as if she or he were
unmarried.
11. PAYMENT TO W1FEI As a means of distributing the financial
interests of the parties not addressed more speciflcally in this agreement,
Husband agrees to pay to Wife the Bum of FIFTY THOUSAND DOLLARS
<.150,000.00). It is understood by the parties hereto, that in order for Husband
to pay Wife the sum referred to herein, it will be necessary for Husband to
refinance the existing mortgage nnd obtnin a new mortgage on the home
referred to in paragraph 9 hereof. Husband agrees that within four (4) business
days of his receipt of an executed copy of this Marital Settlement Agreement, he
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wllJ make application to a londing InMtitution in (lrdor to obtain a mortiBie
lIutllcient to pay the above amount and to pay oil' the exlllting mortgBie llIld/or
home oqulty loanll, and IIhall diligently pursue such financing and Bireell to
cooperate with the lending Inatitution and provide tho lending InBtltutlon with
any and all necellBary Information in Il timely fll8hlon, Wife Bhull not be
obligated to e,xecute and deliver to Husband a Deed for the real property
referred to In paragraph 9 hereof until such time all HUBband IB BlmultaneouBly
therewith able to pay to Wife the Bum of FIFTY THOUSAND DOLLARS
($00,000.00) as referred to herein.
12. PENSION RIGHTSI The parties agreo that they each waive any
IlIld ull clalmB to or IntereBt In any pension righh or retirement fundB of the
other party,
13. INCOME TAX. HUBband and Wife agree to file separate Federal
Income Tax returns for 1995, with each assuming full responsibility for the
accuracy of their respective returns and for the amount of any and ull taxeB,
penalties or interest that mllY be nrrenred or due. In the event such
documentation shall be necessary, Husbnnd ngreoB to execute such documents
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as may be needed to allow Wife to claim the partiell' daughter, ALYSIA, 88 her
dependent for federnl income tax purposes for 1995 and for each year thereafter
until ALYSIA reaches an age or circumstance Buch thnt Bhe Is unnble to be
claimed.
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b. The parties IIltreo thnt they will not in tho future contrllCt or
Incur any dobt or liability for which tho other party, hill or her property or
olltate, might be responsible Ilnd oach further agreell to IndemnifY and Have
harmlellll tho other party against any claims that may be ollserted by onyone
ogalnllt the other party by r0080n thereof,
liS. NON.MERGER IN DIVORCE DECREE, The parties agree that
In the event of absolute divorce between them, they shall nonethelells continue
to be bound by all the terms of this Agreement, and neither this Agreement, nor
the terms hereof, shall be deemed to hove been merged in any decree or
judgment granted in the divorce action, but shall survive and be forever binding
upon the parties,
16. EXECUTION OF DOCUMENTS, Each of the parties shall, from
time to time at the request of each other, execute, acknowledge nnd deliver to
the other pnrty nny and all further instruments thnt may rellsonably be required
in order to give full force and effect to the provisions of this Agreement.
17. MUTUAL RELEASE AND COUNSEL FEESI
a. Except as provided for in this Agreement, the parties hereby
remise, release, quit-claim and forever discharge each other and the estate of
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each other, for all time to come, and for 0.11 purposes whatsoever, from any and
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every claim, including alimony, alimony pendente lite, spousal support, equitable
distribution of marital property, counllel fees or C08tll under the Divorce Reform
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Act, or otherwiHe, thut they make or hereafter make in and to or ogoinHt euch
other'H estates or any part'" thereof, whether by woy or dower or curtesy, or
under the intostote h.\WH, or the right to toke or elect ogai08t the other'B will,
except only such rightlll ntl accrue pursuant to this Agreement,
b. Each party hereto ogrees that he or Hhe HlllIll individually be
reBponBiblo for nny and all counsel fees and expenses incurred by him or her in
connection with the prepnration of this Agreement and the divorce between the
pnrtios.
18, NON.WAIVER: The fnilure ofeithor party to insist in ony one Or
more instances upon the Btrict performance of any of the terms hereof in this
Agreement shall not be conBtrued aB a waiver or relinquishment of Buch term
or termB in the future,
19. RECONCILIATIONI The purtieB agree thllt in the event of a
reconciliation between them, this Agreement shall continue in full force nnd
effect unleBB terminated by mutual written consent.
20. BREACHI In the eVl!nt that either party breaches any provision
of this Agreement, he or she shall bo responsible for nny nnd all costs incurred
to enforce the Agreement, including, but not limited to, court costs and counsel
fees of the other party. In the event of bronch, the other party shnll have the
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right, at his or her election, to I:!Ul' for dllOloRoS for I:!uch breach or to Boek Buch
other and odditlonal remedies 011 muy be ovulluble to him or her, including
. equitable onf'orcement of the Agreement.
21. ENFORCEMENTl The partiel:! agree that thil:! Agreement or ony
part or parts hereof may be enforced In uny court of competent jurisdiction.
22. APPLICABLE LAW AND EXECUTIONI The purtles hereto
agree that this Agreement shall be construed under the laws of the
Commonwealth of Pennsylvania, und shall bind the parties hereto, and their
respective heirs, executors and assigns. This Agreement shull be executed Il8
original in triplicate.
23. ENTIRE AG REEMENTl The parties acknowledge and agree that
this Agreement contains the entirl! understonding of the partles and supersedes
any prior agreement between them. There are no other representations,
warranties, promises, covenants or understandings between the parties other
than those expresl:!ly set forth heroin,
24. INCORPORATION IN .JUDGMENT FOR DlVORCEl In the
event that either Husband or Wife at llny time hereafter obtain a divorce, this
Agreement and all of Its provision!! shall be incorporated into any such judgment
for divorce, either directly or by reference. The court, on entry of judgment for
divorce shall retain the right to enforce the provisions and the terms of the
Agreement,
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COMMONWEALTH OF PENNSYLVANIA
COUNTY O}<' CUMBER~
On this, th\l29lAia~ /.&zt ,1991'S, before me, a Nl)tary Public in
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and for the aforesaid CommQnwenlth and CQunty, persQnally appeared BRENDA
G. JONES, known to me, or satisfactorily proven, to be the person whoBe nome
18 subscribed to the within instrument and acknowledged that Bhe executed the
same for the purpose therein contained.
TNESS WHEREOF, I hereunto sot my hand and official Beal.
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Y PUBLIC I NI)r^~I^l Moll.
e ~1~aINIA M ~A\';:,y NorMY PUBLIC
./' ~'Ri I,~lr. aORI) CUI.\/lliII.IVIO CO M
M C I I E I MY COMM/5510N tIf'IRr3 '/OYl~BI!il , 19l1'
Y ,omm Bf:! on xp res. .
COMMONWEALTH OF' PENNSYLVANIA
COUNTY OF CUMBERLAND
: SS:
On thia, the ~ ~day of' 7/~"M""''-, 199'l, before me, 0 Notary Public in
and for the aforesaid Commonwealth and County, personally appeared
JEFFREY JONES, known to me, or satisfactorily proven, to be the person
whoBe name is subscribed to the within instrument and acknowledged that he
executed the some for tho purpose therein contained,
IN WITNESS WHEREOF, I hereunto set my hand and official senl.
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t "'/('f'.~ ~ tit t A.......
NOTARY PUBLIC
My Commission Expires:
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1"11 NO, I ,,111 ,,,.\. 110' AllY NDlIe 14
:," ".11 ~'~"') "IIMllI,Ri,mD COIINTY
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ADDENDUM 1
The partloll agroe that Bt'onda Joncl! will rocelvo the Items of porsonal
property lillted below which are prescntly locutod in tho marital premisos at SO
Locust Drive, Newburg, Cumberland County, PA, or titled in the namell of tho
parties further agree that it shall bo Wifo's obligation to remove the listed items
from the marital premillclI, or arrange for the transfer of title to her 1I01e name,
111 may be appropriate, within 60 days of tho signing of this Marital Settlement
Agreoment. All other personal items in the murltal premises shall remain and
shull be the sole and exclusiw property of Husbond,
1. Wood stove
2. Riding lawn mowor
3. Burial lots at Memorial Gardens, Chambersburg, PA
4. Swing from porch
15. Pay phone
6.. Organ
7. Picture of Jesus
8. Horse picture
9. Jewelry boxes
10. Old records
11. Wedding dress and other gowns hanging in bag In 'cloSlIt
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J111t:NIlA G, JONES
PI.IIIIIJrr
I IN 'I'm: COUH'I' OF COMMON PLEAS
I ClIMm:J1J.ANI> COUNTY, I'ENNSYI.VANIA
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CIVII.II)'H
Jt:nm:y JONt:S,
Il~fellllllnl
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I IN J)JVOIlCE
I'Il~ECIPJo: '1'0 'I'HANSMI'I' HECOIIII
To Iho PrulhonoldrYI
'l'f'II/1M/llh Ihe r~~orll, IOI!~lh".' wllh IIII~ followllll! IlIform8110/l, 10) Ih~ Court for efury I)f a
divorce 1Il'llrmH
I. Gmn/lll for Ih" IlIvol'O~ 1M Il'r~II'I"vllhll! hr~lIk<lowlI und~r Sl!l!llo/lllf 3301(c) 3301(d) of
Ihe l>l vorc~ Co,II!,
2, '111l! Compllliul WIIR ~~rv~d UI)IIII Ihc Dl!fllll<llllll, 1I11l11l11 Acknowledgemc/lt wpn
I!xl!culed hy J>.:f'lIldlllll, Oil Il~c~mh~r :.!:.!, \l)l)r),
3, Plllltulfr~ A(rldllvlt of COIIRCIII rco\ulrml hy Seellflll :1301(~) Ilr ,1.101(<1) of Ihe l>lvurce
CUll I! WIIR cx~cul~d by till! 1'IIIIIIIIff ')11 lJee~mher 22, 199r), 1111<1 by Ilefelldll/lt un December 22,
19l}t'\,
1\, '111t!rl~ 1I1'1! 110 rdlllell dlliml pCIICII"!!, The pllrlll!~ IIgre.! lu IIIl! entry uf Ihe Marital
Selllenltml Agrl!em'lIll dlllt!d Novcmher :.!4, 1l}95, 10 hc Inco'1lorlllcd fnlo Ihc ffnnlllecree of
[)Ivorel: hClween Ihcm,
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AND tEA ;, JACOBSEN, ESQ,
JACOBSEN ,\ MILKES
t'\:.! Eal' IIIllh :-ilrel!1
Cnrll~lc, PA 1701:1
(717) :.!41).M.:.!7
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I IN THF. COURT OF COMMON PLBAS
I CUMBmRLAND COUNTY, PENNSYLVANIA
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NO. .)/'1
CIVIL
BRaNDA G. JONES
Plaintiff
JBrrRBY JONES,
Defendant
IN DIVORCE
COIIPLll.IIIT
AND NOW COMES the Plaintiff, and allegel a. follow.1
Plalntltl'. rir.t Cau.. ot Actlon - Qivorae
l. The Plaintiff t. Brenda G. Jonee, who currently reeide. .at
427 Newville Road, Newburg, Cumberland County, PA 17240, .inee
June 14, 1993.
2. The Defendant ie Jeffrey Jonell, who currentl.y reeide. at
3~ Locuat Drive, Newburg, Cumberland County, PA 17240, sinoe 1983.
3. Plaintiff hal resided in thQ Commonwealth of penn.ylvania
in excess of eix months immediately previoue to the filinq of thi.
Complaint.
4. Plaintiff and Defendant were lawfully married on November
12, 1983, in Shippenlburq, Cumberland County, Pennsylvania.
5. There have been no prior aotiona of divorce or for
annulment between the parties in this or any other juri.diotion.
6. NeithQr party to thi. aotion in divorce i. currently a
member of the Armed Forces of the United States of America.
7. Plaintiff has been adviled that counseling is available
and that the Plaintiff may have the right to request that the Court
require the partie. to participate in counseling.
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8. The marriage between the partiel hereto ie irretrievably
broken.
9. Plaintiff requelltl the Court to enter I divorce decree
divorcing the partie..
Pla1ntiff'l Second Caule ot Aotion - Cu.tody
10. Paragraph. 1-8 are incorporated herein.
11. Plaintiff .eek. ehared legal and primary physical cu.tody
of A.h1ey Jones, age 8, and Alysia Jonell, age 5, who currently
re.ide at 427 Nowville Road, Newburg, Cumberland County, PA 17240.
12. The children were not born out of wedlook.
13. The ohJ.ldren are prelently in the cUIt;ody of their mother,
the Plaintiff.
During the past five years, the ohildren have resided with the
following persons and at the following addresle.1
From January 1989 until June 1993, the childt'en resided with
both parties at 35 Loou.t Drive, Newburg, Cumberland County, PA
17240.
Since June 1993, the children have reeided at 427 Newville
Road, Newbu~g, Cumberland County, PA, with tho Plaintiff.
14 . The mother of the child1'8n is the Plaintiff. She 18
married to the Defendant and reeides with the children.
15. The relationship of the Defendant to the ohild is that of
biologioal father. Defendant resides alone.
16. Plaintiff has not partioipated ae a party or witne.., or
in another capacity, in other litigation concerning the custody of
the ohildren in thil or another oourt. Plaintiff hKI no
infoxmation of a oustody prQceeding concerning the children pending
in a court of thie Commonwealth.
17. Plaintiff doel not know of 11 penon not a party to the
proceeding. who hAI phy.ical custody of the children or claims to
have cu.tody or visitation right. with re.p.ct to the children.
lS. The be.t intere.t and permanent welfare of the children
will be served by granting the relief requelted because the
Plaintiff il a loving parent we~l able to care for her children,
who will Assure their oontinued regular contAot with their father.
'l'he grant of primary oUltody to Pl.aintiff will afford the children
the maximum Itability in their home environment.
19. PlAintiff requests the Court to grant the partie. shared
legal cuetody of the children, and to Award the Plaintiff primary
phy.ioal cu.tody of the ohildren, subject to the Defendant'. right
of partial phy.ical custody for the purpoee of vi.itation, on a
liberal ba.is, with the exaot times to be determined by mutual
agreement of the parties.
Plaintiff's ~hird Cause ot Aotion - Bquitable DistributiQn
20. Paragraphs 1 through 19 Are inoorporAted herein.
21. The parties are the owners of real and perlonal property
eubject to equitable distribution between them as marital property
and are jointly obligated on marital debt. and liabilitie..
22. The Plaintiff reque.ts the Court to equitably divide euch
item. of marital property and maritalliabilitie. between them.
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I hereby verifY that the Itatementl made In the foregoing are true and
correct, I undentand that falle Itatementl herein are made lubJect to the penaltlel
of 18 Pa,O,S. Section 4904, relatin, to unlworn fall18cation to authorltlel.
Dated: ,!)/.)./1J!
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BRENDA Q, JONES
Plaintiff
: IN 'I'mJ COURT OF COMMON PLEAS
I CUMDEHLAND COUNTY, PFJNNSYLVANIA
I
: NO, /574 CIVIL 1994
: IN DIVORCE
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JEFFREY JONES,
Defendant
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AFFIDAVIT 01" CONSENT
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1. A Complaint in Dlvorco undor tho Dlvorco code waB flied on February 7,
, .
1994, on the groundB that the marriage of the partieB iB irretrievably broken.
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2, The marriage of Plaintiff and Defendant iB irretrievably broken and
ninety days have elapBed fl'om the date of filing the Complaint,
3, I conBent to the entry of a nnol decree of divorce,
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4, I understand that I may I08<a rightB concerning alimony, diviBion of
property, lawyer'B fees or expenBeB if I do not claim them beforll a divorce i.
granted,
In addition, I specifically Ilcknowllldge that a full and nnol Bettlement of all
property and other rights of the partio8 has been entered between the Plaintiff and
Defendant by a MlU'itol Settlement Agreement dated November 24, 19915,
I verily that the BtatementB made in the Affidavit are true and correct, I
understand that fWBe Btatements herein are made Bubject to the penaltieB of 18
Pa,C,S, ~ 4904 rlllating to UllBworn fWBification to authoritieB.
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BR~NDA (j, JONES,
Plaintiff
Defendant
IN THE COURT OF COMMON PLEAS or
CUMBERl,AND COUNTY, PENNSYLVl\.NIA
CIVIL ACTION - LAW
NO,S /i/ CIVIL 1994
IN CUSTODY
v,
JEFFREY JONES,
AND NOW, this
OIDia O~llBt
2f' day of ____.l-n....,.c.
-'
1994,
having reviewed the Custody Complaint and the parties'
Stipulation in this matter, the Court is satisfied that the best
interests of the minor children of the parties, ASHLIY JOHl8 and
ALYSIA JOHlS, will be served by said Stipulation and it is
ORDIRID AND DleRllD that,
1, Shared legal custody of the minor children of the
parti.es, ASHLIY JONIS and ALYSIA JOHl8, is hereby awarded to the
Plaintiff and the Defendant,
2. Primary physical custody of the said children is hereby
awarded to the Plaintiff, subject to periods of partial physical
custody by Defendant, for the purpose of visitation, on a liberal
reasonable schedule with the exact times to be determined by
mutual agreement by the parties,
3, This Order shall be a temporary order, but shall remain
in effect until further order of this Court, Either party may
petition the Court for a modification of thia Order without
showing a change in circumstances.
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L;'WH),' "1,:1
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J.
BRENDA Q, JONES,
Plaintiff
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO, CIVIL 1994
IN CUSTODY
v.
JEFFREY JONES,
BTIPUL~TION RIQARD~Na CUBTODY-VISITAT~ON
WKIRIAS, the parties hereto are husband and wife, having
been married on November 12, 1983; and
WKIRIAS, there were two children born of this marriage,
ASHLIY JONlS, born November 17, 1985, and ALYSIA JONlB, born June
22, 1988, and
WKIRIAS, certain differences have arisen between the parties
and, as a consequence, they have agreed to live separate and
apart from each other, and
WKlItIAS, t.he Plaintiff and Defendant have reached an
agreement regarding the best interests of their minor ohildren.
NOW TRlalrOal, the parties hereto do stipulate and agree
that the best interests and welfare of their said children will
be served by the following:
1, The parties will share legal custody of the children.
2, Plaintiff shall have primary physical custody of the
children.
3. Defendant shall have partial physical custody of the
children, for the purpose of visitation, on a liberal schedule
with the exact times to be determined by mutual agreement of the
parties,