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HomeMy WebLinkAbout95-01623 ~ ~ rJ -; I 1 I ~ I a) i to- ~ i j ! rJ i , i \ ! \,. / r ! 1 I € I ~ 1 l J N')i n1 ~I KATHERlNEJAN JARRETT, Plaintiff ) ) ) ) ) ) ) ) vs GREGORY A. JARRETT, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANlA CIVIL ACTION - LAW NO. 95-1623 CIVIL TERM IN DIVORCE ORDER FOR PAYMENT OF ALIMONY AND NOW, this ~ 'I' day of ])1'(' (,..,... , 199 S, upon the stipulation of the parties' counsel, we hereby enter the following Order obligating the Defendant, Gregory A, Jarrett (hereinafter "Husband") to pay alimony to the Plaintiff, Katherine Jan Jarrett (hereinafter "Wife") on the following tenns: Husband shall pay Wife alimony in the amount of $900.00 per month, commencing on the first day of the first month following the entry of a final decree in divorce in the action now pending between the parties. Such alimony shall be subject to the following tenns and conditions: A. The alimony shall continue for a period of 36 consecutive months, until the death of Wife, or until Wife's cohabitation with a man not related by blood to her, or upon Wife's remarriage, whichever first occurs. OtheIWise, the tenn and duration of the alimony shall not be subject to modification. B. The amount of alimony shall be modified only if Husband's income falls below $40,000.00 per year or exceeds $80,000.00 per year or if Wife's income falls below $22,000,00 per year or exceeds $45,000.00 per year. In the event of any of those occurrences, the parties may renegotiate the amount of alimony to be paid by Husband and, if the parties cannot reach agreement for a modification of the alimony amount, either party may petition the Court of Common Pleas of Cumberland County, Pennsylvania, to seek a modification of such alimony and the parties will accept and be bound by any modification ordered by said court. Otherwise, the amount of alimony payable by Husband to Wife shall not be subject to modification. C, Both parties shall treat the payments made pursuant to this paragraph as alimony. Husband shall be entitled to deduct those payments in accordance with the applicable tax law and regulations and Wife shall report such payments as income pursuant to the law and regulations then in effect. D, Husband shall provide insurance on his life in the total death benefit amount of at least $33,000,00, naming Wife as the sole and exclusive beneficiary, and continue such insurance as long as he is obligated to pay alimony hereunder. Husband shall provide proof to Wife, at least every six months, that such insurance remains in full force and effect and that Wife is the sole and exclusive beneficiary of at least $33,000.00 of the death benefits of such insurance. E. The alimony payments provided for herein shall be made directly from Husband to Wife as long as he is not in default of the alimony obligation under this Order, In the event that he fails to make any alimony payment within ten days of the date it is due, however, on Wife's sole election, the Domestic Relations Office shall enforce this Order by collecting payments from Husband, through a wage attachment if necessary, for the forwarding of such payments KATHERlNEJAN JARRETT, Plaintiff ) ) ) ) ) ) ) ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW vs GREGORY A. JARRETT, Defendant NO. 95-1623 CIVIL TERM IN DIVORCE STIPULATION AND JOINT MOTION FOR ENTRY OF ORDER FOR PAYMENT OF ALIMONY AND NOW come the above-named parties, by their respective attorneys signed below, and jointly move this Court to enter the alimony order which is attached to this motion and stipulate and agree that the Court shall enter such order pursuant to the agreement of the parties. ~ ~~ ",. . v if' sam~ Andes - tbfv "'; II /3 .'It- Attorney for Plaintiff . , ULfU. <' .C. <. - L '/ \ . K thleen C. Daley - /(~ /I .' V . 3 'f" Attorney for Defendant7' 2 Co UQL~A9~ I SAMUEL L. ANDES ATTORNEY AT LAW DaD NORTH TWltLJPTJI STItEET P. O. BOX 100 LEMOYNE, PENNSYLVANIA 17043 0': "" Fr:''Lr:D--{)::PL''~ j I'. /,...,,. '-'"1; e '''' :; ITJ.!"'.'./O?!. ~ '~"" ' It~qy J C(",~ ? 7 "'. .. A,': 10: 17 /'!/.--':"'!" ....,,-:.: ~. !I ,.., , f'" ....... "'ll C"~/" ..\.,/,.\ "'I"TY ...I,j' ":'1l1'~.'I'~ . ...........'\ 5. To accommodate the marital property distribution between the parties, it is hereby Ordered, Adjudged and Decreed as follows: A. The Bell Savings Plan previously referenced is marital property. ;1 B. Subject to the finalization of the divorce, the execution of the documents as required by the administrator of the Bell Savings Plan and the tenns of said Plan, the following portion shall be awarded to the Alternate Payee as her sole and exclusive property subject to the tenns and limits of said Plan: I: r: :: (I) All interest held by the Participant in the U.S. Equity , i i ! Index Fund and all interest held by the Participant in the International Equity Index Fund. (2) A further distribution from Bell Atlantic shares held by the Participant so as to distribute to the Alternate Payee an aggregate sum of$35,OOO.00 as of December 31, 1995. (3) Any interest or dividends accruing or paid on this distribution after December 31, 1995, shall be the property of the Alternate Payee. This is the total value to be distributed to the Alternate Payee. (4) The parties are directed to submit in a timely fashion to the Bell Savings Plan all documents including releases that are required to finalize this Order. KATHERINE JAN JARRm'l', IN lllE roJRT OF ClMoD'I PLEAS OF ClMBERLAND COONI'Y, PENNSYLVANIA NO. 95-1623 CIVIL It vs. GREXDRY A. JARRm'l', 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. Grounds for divorce: irretrievable breakdown under Section 3301 (c) 330l (d)(l) of the Divorce Code. (Strike out inapplicable section) 2. Date and manner of service of the complaint: 30 March 1995 by personal service 3. Complete either Paragraph A. or B. A. Date of execution of the affidavit of consent required by Section 3301 (c) of the Divorce Cooe: by the plaintiff 21 December 1995 by the defendant 18 Decanber 1995 B. (1) Date of execution of the plaintiff's affidavit required by Section 3301 (d) of the Divorce Code: (2) Date of service of the plaintiff's affidavit upon the defendant: . 4. Related claims pending: None . 5. Indicate date and manner of service of the notice of intention to file praecipe to transmit record, and attach a copy of said notice under Section 3301 (d)(l)(i) of the Divorce Code ~-q~~ Attorney for Plaintiff/~ Samuel L. Andes - . KATHBRINB JAN JARRETT Plaintiff IN THE COURT OF COHHON PLEAS OF CUHBERLAND COUNTY, PENNSYLVANIA vs. GRBGORY A. JARRETT Defendant CIVIL At~ION - LAW NO. 95- /~'"J-jCIVIL TERK IN DIVORCB NOTICE TO DBFEND AND CLAIM RIGHTS You have been sued in court. If you wisb to defend against the claims set fortb in the foregoing pages, you must take prompt action. You are warned tbat if you fail to do so, tbe case may proceed witbout you and a decree in divorce or annulment may be entered against you by tbe 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. Wben 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: Office of the Prothonotary Cumberland County Court House Carlisle, Pennsylvania 17013 IF YOU DO NOT FILE A CLAIH FOR ALIHONY, DIVISION OF PROPBRTY, LAWYBR'S FBBS OR BXPBNSBS BEFORE A DIVORCB OR ANNULHBNT IS GRANTBD, YOU HAY LOSE THB RIGHT TO CLAIM ANY OF THBH. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYBR OR ICANNOT AFFORD ONE, GO TO OR TBLEPHONE THE OFFICE SBT FORTH BELOW TO FIND OUT WHBRE YOU !CAN GET LBGAL HBLP. !i Court Administrator, Fourth Floor Cumberland County Court House Carlisle, Pennsylvania 17013 Telephone: (717) 240-6200 ;: 1 ~~''-'''''---._-'--'. ---!..~ J'f'71 SUITS, 19CfD Case # -S 3943 Date of Entry: November 14 1 9 90 at M. Appearances: Plaintiff: Gregory A. Jarrett Defendant: Katherine J. Jarrett Entry by Summons ) Complaint ( x Petition ( Appeal ( Revival ( ( March 28, 1991, Praecipe, filed. Please discontinue the above captioned divorce action. By: Kathleen Carey Daley, Esq. Action in Assumpsit ) Trespass ( Habeas Corpus ( Divorce ( x Grounds Equity Mortgage Foreclosure Ejectment Quiet Title Replevin Condemnation Service by SHF: Date of ~ Return: Taxation of Costs ,h,Ct; _' oJ... ~~. '-,', Receipt of Fees Plaintlff's Exhibit ~ l" > 01 X " ~ 0 " tl -: " tll :t. :I. > y: l" 0 ~ " ;A .. .. ~ 0 01 ~ ~ >' :t. ~ :t. ~ 1. 01 0 <1J 0 -: -: ~ " <1J - S ... ~ g ~ II: :> " :t. <1J ~ ~ ~ > .. " ~ to ::; " " > 0 .. z ~ 0 III ~~~~ ~\' """-J S ~ -...:. - e: .0 "'.. ~ CY) I""'} -- . ~.' '.' ~. ~ - (-\..; ,-, ",", = ~ .. "" '" u ....., c::> c:-' (b .... -.J --.. ,"-- "- U'.~ ~ :;:;..;:. (." C"'\ r V\ -. ...; ~ c..n "-" \ ... KATHERINE JAN JARRETT, . IN THE COURT OF COMMON PLEAS . Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . . CIVIL ACTION - LAW . v. . . . NO. 95-1623 . GREGORY A. JARRETT, . . Defendant . IN DIVORCE . AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 330l(c) of the Divorce Code was filed on March 30, 1995. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing of the Complaint. 3. I consent to the entry of a final decree of divorce. 4. I understand that if a claim for alimony, alimony pendente lite, marital property, counsel fees, or expenses has not been filed with the Court before the entry of a final decree in divorce, the right to claim any of them will be lost. 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.A. Section 4904 relating to unsworn falsification to authorities. Date: 2l ...\)(l("~~/ (fu" , / '?v~ laJ.ntJ.ff n U) 0 s:; I'JI -n !.~... c::, ::J "'1jr':'J r-" i;l~ OlE: '"' "'-..: r-) ~ ;:- l:~ -.; -'J en..:, 0 .....: ~i'::'. :;;J :?:;o ~ ;5:8 -(.. '2 ~?;~ >(= ~ - s! w ~ KATHERINE JAN JARRETT, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 95-l623 v. GREGORY A. JARRETT, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 330l(c) of the Divorce Code was filed on March 30, 1995. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing of the Complaint. 3. I consent to the entry of a final decree of divorce. 4. I understand that if a claim for alimony, alimony pendente lite, marital property, counsel fees, or expenses has not been filed with the Court before the entry of a final decree in divorce, the right to claim any of them will be lost. 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.A. Section 4904 relating to unsworn falsification to authorities. Date: \'2- ,9 By: / /G (") \.0 ? 1.; <.n .- "=' 'i':n ~iil "1 ~lrl .-;, iTl,- <..:"1 - -C'. N ..,(J') OL~: ..... "JIj' .::; ~;, ::>0 .......\,..,.i ~ J~ ~~; -. .~'.. (...... - t,~C: ~ ~ '-:->C 0 .~ <:.! ~ - '0 w :.: (") \,':' (") C 'JI :7= '11 ;pm '::> ::;1 ;..., l~rn ,-, i'n:t1 ~:n ",- .;,...c.. :--, -n~ (~"j..r~ -.J -f} ~cj 0 ,."., -j '-..':0 ::.:: :'r-=rJ =2CJ ~ 9~ ""'-~C" <5' ~ - b! -..;; <:.) ~ (") \.0 ~ (- (JI -:: "'=' I:ltrJ ''1 =? (")0..7 ."") i;:;:D ::~r~ ~ g~ r~;; .'";' -.J ~.'~. ~~; ".., :~:C-l :::: a~ (;0 ~ t5 -.t... -;; :;! ~ - ~ <:.) -. JJ02l688.DOC . PRIORITY ONE ATTORNEYS' MESSENGER SERVICE JoHph F. JohnlOfl, Ownar . Subpoen.. .. ClUtlona for All courtll . Sarvlng U.S.A. .. Canada It 8. Camaron 8treat P.O. Box 454 Harrlaburg, PA 17108-0454 (717) 257-1385 ORDI!R NO. PROOF OF SERVICE ANDES VAUGHN . BANGS SAMUEL L. ANDES, ESQ. 525 N 12TH STREET LEMOYNE, PA 17043 PROCESS TO liE SERVED IIY: DOCUMENTS p I VOF~CE COMPLA I NT WITNESS FEE: DATE Rl::CEIVED DATE REASSIGNED CASE NO'~5-1523 CIVIL KATHERINE JANE JARRETT PUINTIFF -vs- GREGORY A. JARRETT DEFENDANT TO BE SERVED: GREGORY JARRETT TELEPHONE PIONEERS BELL ATLANTIC OrrICE POINT SHOPPING MALL HARRISBURG, PA 17111 ACCEPTED BY: GREGORY JARRETT TELEPHONE PIONEERS BELL ATLANTIC OrrICE DATE SERVED: TIME: . PROCESS SERVER'S NAME JOSEPH r. JOHNSON 3-30-'35 12:20 P [ I Black Hair [ I Brown Hair [ I Blonde Halr [ I Gray Halr b4 Red Hair t I White Hair [ I Balding 1><1 White Skin ! /1 ) Black Skin I I 14.20 Yrs. I I Yellow Skin I I 21.35 Yrs. I I Brown Skin 1><r 36.50 Yrs. I ] Red Skin 1 1 51.65 Yrs. I ] Over 65 Yrs. I ] Under 5'0" I ] 5'0" . 5'3" [ I 5'4" .~ 1>4:.5'9" ~ I ) Over 6'0 I ) Under 100 Ibs. I ) 100.130 Ibs. I ) 131.160 Ibs. I ) 161.200 lbs. .x Over 200 Ibs. [ ) Kilitary Service Other Identifying Features: i b<l" Kale f ] Female ~ Koustache P<1 Beard ~ GlaBBes NON. SERVICE INFO [ ) Not Known [ ) Evading Service [ ) No Such Address I ) Koved I ) No Longer Employed I ) Never in But Address Has Been V.rlfled .-. -- -r' ....' (UEIJ/./ j:: :J(~JJJ1J ~ v SI' belng duly swonl according to law, deposes and says that he/sh~ i~ process server herein named; and that the f.~t~ . ~~rein set forth above are true and correct t..' e bes of their edge, information and hAlief. sworn~ and subscribed before me this i~ 41 day of I1.fJA./.-I . ~~~"~~ p-.-J Notary Public Server Commissio KlI'Iln L GnIon. Nol3Jy N*= Hantstug, ~_Ccullv My Commis,*", Expics Dee. 30, 1996 - . :coo ,., ..., ;~... :0 ',1", J _ ,,~; "f1 ,::I....~ ~~ 7 ,'lI ,,": h. '~; .... .- ....,.., -< :.:, N c. .... -0 ::J: - u:> .." ;:':~: : ' ~ -' :;.1::'; ,,\f, ;\_1J~ ", ' .; j , ,DALEY,LAW~()FfieE . - '.~ LAW OFRCES 1029 SCENERVDRIVE' HARRiSBuRG. PENNSYlVANIA .17109 , (717) 657-4795 . .