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Home My WebLink About95-00781 / I - , , .\J ,.'~ ~:'<'~ '(\J j -(j' 'cf. -j ',I' \ E ~. J -- Co r-- I i,ln , Q- . I:' Cd ~'" " '11 .QC, 1\ \.11\.1 J.,J MICHAEL R. PAQUETI'E, :IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA . . v. :CIVIL ACTION. LAW DOROTHY E. PAQUETI'E, :NO. 95.781 CIVIL TERM Defendant :IN CUSTODY STIPULATION FOR CUSTODY AND RELEASE OF MARITAL CLAIMS NOW COME, the parties in the above matter and agree and stipulate as follows: 1. A Complaint in Divorce was filed in this matter on February 13, 1995, including a count for child custody. The parties are the parents of two minor children born to the marriage, JENNIFER LEE PAQUETI'E, born March 23, 1980, presently age 15, and ROBERT JOSEPH PAQUE1TE, born October 2, 1984, presently age 10. 2. The parties have reached an agreement regarding the custody and best interests of their minor children, 3, The parties agree that the best interests and welfare of their children will be served by the following: a. Legal custody of the parties' minor children, JENNIFER LEE PAQUETI'E and ROBERT JOSEPH PAQUETI'E, will be shared by the parties. b. Primary physical custody of the parties' minor children shall be with their father, MICHAEL R. PAQUETrE, The primary residence of ROBERT shall be with Father, and the primnry residence of JENNIFER at this time shall be at Musonic Homes, Elizabethown, PA, where she is presently residing, or with her father if she leaves the Musonic Homes, c. Defendant, DOROTHY E. PAQUETTE, shall have periods of partial physical custody of the parties' son, ROBERT JOSEPH PAQUETTE, for the purpose of visitation on a regular basis, with exact times to be determined upon mutual agreement of the parties, and for such other times including holidays and vacation periods, us the parties may determine upon mutual agreement and consent. d. Defendant, DOROTHY E. PAQUETl'E, shall el\ioy such periods of partial physical custody of the parties' daughter, JENNIFER LEE PAQUETTE, as may be appropriate under the circumstances while she is residing at the Musonic Homes, If JENNIFER leaves Masonic Homes, Defendant shull have periods ofpartiul custody of JENNIFER for the purpose of visitation on a regular buais, with exact times to be determined upon mutuul agreement of the parties, and for such other times including holidays and vacation periods, us the parties may determine upon mutuul agreement and consent, 4. The terms of this Stipulation shall be submitted to the court with a request that it be made part of an Order of Court for custody in the above-captioned matter. 5, The parties hereto release ull other marital claims against each other, and agree to proceed in this matter upon the grounds of irretrievable breakdown of their marriage and mutual consent to the entry of a divorce decree in this matter. '. The Plnintiff and Defendant do verify that the foregoing statements arc true and correct to the best of their knowledge and information and belief, The Plnintiff and Defendant understand that false statements herein arc made subject to the penalties of 18 Pa, a.s. Section 4904, relating to unsworn falsification to authorities. IN WITNESS WHEREOF, the parties and their counsel hereto have set their hands and seals as of this '2.'3,!day of Sl'\)-k",[),>~, 1995, and intend to be legnlly I bound hereby. ~. Ut~iL SALLY J WINDER, ESQ. Attorney or Defendant ANDREA a, A BSEN, EEQ. Attorney for Plnintiff \~ " .r~ :1 i 1~ }c., '1 ~ . '" I." ";::-- ~ " 11""1 ~n ." ~. ,-- ;.l .,) .'j ,. f- " = ." MICHAEL R. PAQUETTE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v. DOROTHY E. PAQUETTE, Defendant 95-781 CIVIL TERM AND NOW, ORDER OF COURT this \~tiday of October, 1995, upon consideration of the Praecipe To Transmit Record filed in the above-captioned case, and the proof of service being inadequate to show proper service of the complaint upon Defendant, a divorce decree will not be entered at this time, without prejudice to the right of either party to submit a new praecipe upon Defendant's filing an acknowledgment of service of the complaint as of an appropriate date or upon proof of proper service. By the Court, ANDREA C. JACOBSEN, ESQUIRE _ 52 East High street Carlisle, PA 17013 i__) ,., " \':.: 'O/I'i$/1S: ,J,p. r' ~, ", c -', ::.:: wcy (..r; <.n ---------~~--------~~~~~~--~~~ ~ @ ~ " , " ~ ~ ~ ~ e ~ s .:i ~ ~ M ,,~ ~.~ ~ $ P.9!lC!Qf{HI::'Hl't\Q\1I~lJ!~.. . . ...H..............H........ ~ ~ "'H'" H..HH......Defendant . ... H..H.... " ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ e ~ ~ .' ~ ~ " ~ ~ ~ -' .' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF '*' PENNSYLVANIA r-gqli\E.LR. ,p.t\QUE'rm. .' H H' H. ......... ........H.......... I II I N (), ~?:,?.~1-........,.. Q~YJk...... 1995 ...,.............. .... ............. Plaintiff ....,............ ........... Versus DECREE IN DIVORCE AND NOW,..JJp.y,(.\"Ik,U..Z.I....." 19,'1$... it is ordered and decreed that .".,.",.., ~I.I~!JAE.~ ,~" .~l\Ql!I::l:l:"i . , , , . . , . . . . . . . . . " plaintiff, and.........,..,........ .OOB<mJY.e. .I'~QIJIn'm................. 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: NONE. ........ .......... .......... .... ...................... ...................., .......... .... .................. ........................, Dy The Court: ~ ,/J~ Aii~~i.;....,lJj~.L ...- .';. /L2!;H{:;;' ~J: .U """~l~-"",""L:.. e.(J.?A;(J!,P. ...~-(';'j~~..(Q. '~1?1l;2 K ~&:;.J;'7"" .... Hf?'.. J Prothonotary ~ ", a '. ~ ~ , ~ ~ ~ ~ ~ ~ ~ ~ ~ ., io! f Yo " ~ ~ ~ ~ 8 ~ ., ~ ~ ~ ~ ;,: ~ " iol ,. ., ill " ., ~ ii! ,. g ,.; ~ ~ !:"' :', ~ ~ " ~ ~ 'I ~ .'. ~ -. .. MICHAEL R. PAQUETrE, :IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA . . v. : CIVIL ACTION. LAW DOROTHY E. PAQUETTE, : NO. 95.781 CML TERM Defendant : IN DIVORCE i , ! ' 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 the divorce is irretrievable breakdown under the Section of 3301(c) of the Divorce Code. 2. An Affidavit of Service was filed on March 16, 1995. 3, Affidavits of Consent required by Section 3301(c) of the Divorce Code was executed by the Plaintiff on September 23, 1995, and by the Defendant on October 13, 1995. .. '" 4. There are 110 relnted clnlms pending. A Stipulntion for Custody nnd Rolense of Marital Clnlms nnd Stipulntion for Support of Minor Child of the pnrties dnted September 23, 1995, hnve been executed by the parties nnd are before the Court in this mntter, DATE: / I 10 (. '( I Respectfully submitted, ./] ~ ' (!. lAte-V. 0. BY: Andren C{ JucobSql , Esq, JACOBSEN & MI.1KES 52 Enst High Street Carlisle, PA 17013 (717) 249.6427 Attorney No. 20952 --... ,...., ,-. IN THE COURT OF COMMON PLEAS OF CUMBEllLAND COUNTY, PENNSYLVANIA MTCHAF.T, R PAOIl~ PLAINTIFF FAMILY DIVISION V!l. NO. 15- 7f1j (j~j~/<\. DOROTHY E. PAOUETTF. 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 hy the court. 11 jUdgment may also be nntered 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 grounds for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER 1 S FEES OR EXPENSES B1;FOIlE A DIVORCE OR ANNULHENT IS GRANTED, YOU MAY LOSE TilE RIGlIT 1'0 CLAIM ANY OF TIlEM. YOU SIIOULD 1'AKE 1'1115 PAPlm 'fa YOUR IJA~IYER A1' ONCE. IF YOU 00 NO'!' HAVE A LAWYEH OR r.ANNO'1' AFFORD ONE, GO 1'0 OR 1'ELEPlIONE THE OFFICE SE1' FOR'l'l1 [JELOW 1'0 FIND OUT ~llIERE YOU CAN GET LEGAL !IF:LI'. COURT ADMINISTRATOR CUMBERLAND CO COURTIIOUSE 4th FLOOR 1 COURTIIOUSE SQUARE CARLISLE I'A 17013 3387 (717) 240 6200 .. ... IN THE COURT OF COMMON PLBAS OF CqMBERLAND COUNTY, PENNSYLVANIA M;I;ClIAEL R. PAQUE'r'rE PLAINTIFF FAMILY DIVISION CASE NO. vs. COMPLAINT IN DIVORCE FILED ON BEHALF OF: DORO'rHY E. PAQUETTE DEFENDANT pl1h'ifb'l.l11 R. PAQUETTE 26 East Main St. WALNUT BOTTOM, PA 17266 Address 11'''1\ ~ 4. The Parties were married on JULY17, 1978 in NORFOLK, VIRGINIA 5. The Plaintiff avers that: (a) The Defendant has offered such indignities to the person of the Plaintiff, the injured and innocent spouse, as to render BER condition intolerable and life burdensome; and (b) The marriage between the parties is irretrievably broken. 6. No prior action for divorce or annulment has been filed in this or any other jurisdiction. , '.' 7. Plaintiff avers that this action is not collusive. 8. The Plaintiff avers that SBE has been advised of the availability of counseling and that SBE may have the right to request that the court requirp. the par.ties to participate in counseling. 9. WHEREFORR, Plaintiff requests this Honorable Court to enter a Decree of Divor.ce. Page 2 of Complaint in DivorcA t''''~ ,..., I , !' Count 2 - Child custody and .~'N'R,.t ~. plnintiff incorporates by reference Paragraphs 1 through ..2- of the Complaint in Divorce as though fully set forth herein. \ \ \ -Lt. The following children have been born or adopted of this marriage, and their names, dates of hirth, social security numbers and address of residence respectively are: JENNIFER LEE PAQUETTE, 3/23/1980, 044-82-1936 ROBERT JOSEPH PAQUETTE, 10/2/1984.044~82-1657 BOTH CHILDREN LISTED ABOVE RESIDE AT: MASONIC HOMES, 1 MASONIC DRIVE, ELIZABETHTOWN, PA ~. WHEREFORE, Plaintiff requests this Honorable Court to order custody, visitation, care, control and support of the said children to be awarded as follows: CUSTODY, SUPERVISED VISITATION (supervised visitation until either the MASONIC HOMES DIRECTOR OR MICHAEL PAQUETTE SEE'S THAT DOROTHY PAQUETTE SHOWS THAT SHE WILL STAY IN PERMANENT CONTAC'l' WITH TilE KIDS, TIIEN I WIlL CHANGE VISITATION.) That starting on and continuing on the day of each month thpreafter, should pay to , for each of said minor child(ren) which are not in custody, the sum of per month per each of said children for support and maintenance until each such child attains legal age or is emancipated or enters the military or until further order of the court. Pllf;I.3 (11 t>_'lrr,]..irll 'n lJivot"CI" ,1'"'"] ,.... IN THE COURT OF COMMON PLEAS OF C'IIMIH'IH,MoJn COUNTY, PENNSYLVANIA MICHIIF.T, R _ PIIOllF.'J"rr,: ) PLAINTIFF ) NO. ) vs. ) AFFIDAVIT REGARDING THE UNIFORM ) DOROTHY E. PIIQUETTE ) CHILD JURISUICTION ACT DEFENDANT ) STATE OF PENNSYLVANIA ) COUNTY OF CUMBERLAND ) ss. MICHAEL R. PAQUETTE oath, deposes and says: being first duly sworn an , 1. I am the ~LAINTIFF in the above-cited action. 2. That my spouse and I have 2-- child(ren) as a result of this marriage. The name and date of birth of this/these child (ren) are: JENNIFER LEE PAOUETTE 3/23/80- 044-82-1Q36 ROBERT JOSEPH PIIOUETTE 10/2/84 044-82-1657 3. That the aforementioned child(ren) presently reside/ resides as follows: MASONIC HOMES, 1MASONIC DRIVE, ELIZABETHTOWN, PA -I BOTH CHILDREN HAVE RESIDED AT MIISONIC HO~IES FOR THE PAST THREE YEARS FROM OCT 1988 UNTIL AUGUST OF 199~ THE CHILDREN LIVED WITH M. PAQUETTE 4. That neither the Plaintiff nor the Defendant have participated as a party, witness, or in any other capacity, in any litigation concerning the custody of this/these children in this or any other state. 5. That there is no custody procoeding concerning this/these child(ren) pending in any Court in this state or any other state, 6. That there is no other person, not a party to these proceedings, who has physical custody of the child(ren) herein who claims to have custody or visitation rights with respect to the minor children. Subscribed and sworn bE'fore "Ie this _ day of , 19_ Notary PUblic for My commiflsion nxpii::os-- . . ,.....'" .~ jf)!ft/;t11 P J verify that the statements and averments made in this Complaint in Divorce are true and correct. J understand that false st~tements herein are made subject to the pen~lties of 18 Pa. C.S. Section 4904r relating to unsworn falsification to authorities. Datod-M,1);5- ~ f:.1:~ I'" II ')1 (', 'll'll!:1 . !II II] lli 1/(11'(:" ~ 1 1 ~ ~ ~ ,- '" "- "=tt .,., , ~ ~ ~ :?' '" ~'\ , i~~ r") \ .. " ,~ -, y)~~ ~ _._- I' V, , , ,'" - ~ . ! 'n i \)-. i ........ -~_/ . . ! MICHAEL R. PAQUETI'E, Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION. LAW v. DOROTHY E. PAQUETI'E, : NO. 95-781 CIVIL TERM Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on February 13, 1995. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing the 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, lawyer's fees or expenses if I do not claim them before a divorce is granted, In addition, I specifically acknowledge that a Stipulation for Support and a Stipulation for Custody and Release of Marital Claims with regard to the claims raised in the above action, have been entered into between the Plaintiff and Defendant by written agreements dated '21,'~ '6 S(y\e_H'Ib.-rZ ,1995, I verify that the statements made in the Affidavit arc 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: CJ.b~/clt(" tf>Ic/) ~ ~u." / '/ " ~/I}[~ ( It /1.' t'- / If (I ; }(--- .' MICHAEL R. PAQUETTE, Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION . LAW v, DOROTHY E. PAQUETTE, : NO, 05.781 CML TERM Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on February 13, 1995. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce. 4. I understand that I may lose rights concerning nlimony, division of property, lawyer's fees or expenses If I do not claim them before a divorce is granted. In addition, I specifically acknowledge that a Stipulation for Support and a Stipulation for Custody and Marital Claims with regard to the claims of custody, support, and marital claims have been entered into between the Plaintiff and Defendant by written agreements dated 2.'1 rA "V Sep'k,ttb "It- , 1995. I verify that the statements made in the 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. ~~~7:~~ Date: , .' . . IN Tim COURT OF COmlON l-...I~flS OF CIIMRI~Rr.AN() COv~TY, PENNSYLVANIA .Ml~\1illL Il. PAOUF.'I"I'F. l'LflIN'l'lFF VB. . 'iJ L NO. 9"-. 79/ (l,tI.-U Ulm'L QQROTIIY E.._.EMllJE'I"I'E llEFI;NDflwr AFFIDAVIT OF SERVICE COHMUNWJ';IIIJrll OF rF.NNSVLVflNIfI 55. COUN'rY OF CUMBEIlLIIND Before me, the undersigned authority, personally appeared ~IICIIIIEI. Il. PflQUE'I"l'E , Plaintiff, who, being duly sworn accordIng t.o law, deposes and saya that: on 3/ f?/95 he snnt: by Certified Hall, Return Roceipt Requested, Restricted DAllvnry. R trup and correct copy of the Complaint in Divorce and other Relief UI1l1f"l' the nivorce Code of 1900 filed in the .. abovn-captioned case to the Defendant. Said Complaint was rece i vetl by DORO'I'IIV E. PIIQUETTE r Defendant, on The Return Recoirt ~lich was signed by the Defendant is hE' ro to at t.Rched . DflTf::3 J/6/C;(/ I , SWOIlN TO fiND SUD5CllIDED BEFORE ME ON '1'1115 IlflV OF , 19_ ....... '" ---No'I'il'TiYrlilif.Ic .. .... .. SE DER: . ~ . Compl,"Il.ml I Indlar :z tor .ddillon.1 ",vle... !I . Compl,l' 11,m. 3. .nd A. . b. r: . p,Int ~ou' n.m. ,nd .ddr... on th. "Vlt'l olthi. form 10 that w. Cln G IIlurn Ihls u,,,, - _1_" e . Alllch thl. 'DIm 10 'he honl of thl m.lIpl.CI, or on Iht blck If .pleI do., nOl Pfrmlt. .s . WIlt. "A.lurn A.Cllpl AteNIII.d" on thl m.npllCl below 1'" 'rtlcle number . The A,turn A'Ctlpt wlll .how 10 whom the .rtlel. w.. d.~.r.d.nd tkl d.11 g d.lh,tl.d.: Consult oltmDstar for foe. ~ 3/J~ICI. Addr.. .d 10: 4.." u-;?J;'" 4.'-!!.jl. Numb '" ~ {L/" r~ 4b, S.rvlc. Typ. .... Il . //]-)~. 0 R.gl.tered 0 In.ur.d III / --- . . .rtltl.d 0 COD :3 . ;, 0 Expr... M.II 0 R.turn R.cl .1 = . 2 . 7. D.t. 01 D.llv.ry ct ~ 6, Slgn.tur. (Addr...e.1 ~ = 6, ~ il .. PS .!l I .1.0 wl.h 10 rec.lve lh. I.llowlng .ervlc.. 1101 .n .xtr. le.l: 1, 0 Addre....'. Add,... ~I !, Ii al ll!' I II fo~ !II ~: ill 6, Addr...e... Addr...IDnly It r.qu..'.d ~"I .nd Ie. I. p.ld) I . I ~'~M~~TIC RETURN RECEIPT! 2. 0 Restrlcl.d Dellv.ry .... ... ,. ..~ _~ ~__._.__ ~... ....__.~ _,._._ __.'....A.~-._..- __.____. II II II II I! I I I ,I II Ii II II fr ",J' j " J'~'~'~'1 Ii clr./1-p.f.o/li'...I... I! --- ' ii 1r'/"'..JrJ~~~,t.J1J-I 1 \ r.'IJ'If'_';'., [7t<( "In i 1 'I i: (117) SJMJ,6' : : i il I i I I, I' MICHAEL It I'AQUE'ITE, . IN TilE COURT 011 COMMON PLEAS OF CUMBERLAND COUNTY J, Ii Ii I ,I I' :1 I' II " " Ii II I' I; ! 1'lnilltilT vs CIVIL ACTION - LAW NUMBElt: 95-781 CIVIL TERM DOROTHY E. PAQUE'ITE, IN DIVORCE Dcrclldnnt ACCEPTANCE OF SERVICE I, DOItOTIIY E. PAQUE'ITE. do acknowlcdgc that I havc rcccivcd a true bnd corrcct copy of the Complaint in Divorce and Notice and Plaintiffs Affidavit in the above-captioncd divorce and acccpt thc scrvice thcreof on March 08, 1995, ( verify that the statcments madc in this Acccptance of Scrvice are truc and correct, I understand that falsc statcmcnts hcrcin are made subjcct to the pcnaltics of 18 Pa,C,S, Section 4904 relating to unsworn falsification to authoritics, Date: {O. . ~ 5. 9 5 i' -. . " 4. 'l'here ill'e no reluted c1uiUl!! pelll1lng, A Stipulution for Custody and Release of Marital Claima and Stipulation for Support of Minor Child or the partie!! duted September 23, 1995, have been executed by the parties and are before tho Court in this matter, DATE: Respectfully submitted, c) 17 )?)" B~:~"D' E.q JACOBSEN & MILKES 52 East High Streot Carliale, PA 17013 (717) 249-6427 Attorney No. 20952