HomeMy WebLinkAbout95-02335
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
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STATE OF i~~~~ PENNA.
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JEFFREY T. ZERBE,
:\11. 95-2335
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Plaintiff
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RIIONDA ZERBE,
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Defendant
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DECREE IN
DIVORCE
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ANDNOW...A~~""'Soi"..,~...., 191.1:, it isorderoldand
JEFFREY T. ZERBE
'. plaintiff.
delendant,
decreed that ..'
, . . . . . . . . . . , .
d RHONDA ZERBE
an ................ ....
are divorced Irom the bonds 01 matrimony,
The court retains jurisdiction 01 the lollowing claims which have
been raised of record in this action lor which a final order has not yet
been entered;
~he .custody ~greement.and.Agreement for Distribution of Marital,Assets.dated
April 30, 1995, and attached to tile COl1plaint in Divorce filed in the above
'captioned 'matter 'are'iricorporatcid'hutri6t'merged'into this'oecree'in Divorce.
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EaSler. 'nllUlksgiving IUld Christmas Day. Mother shall have custody of the child from 9:00
11.111.103:00 p.m. 011 those days begilllling 1995 mId every olher year thereafter. Falher shall
huve custody of the child from 3:00 p.m. 10 9:00 p.m. on those days beginning 1995 IUld
every other year thereafter. Beginning 1996 lUId every other year thereafter Mother shall have
custody of the child from 3:00 p.m. to 9:00 p.m. lUId Father shall have custody from 9:00
a.m. to 3:00 p.m. on those days.
5. Once the child begins school. the Father lUId Mother will share custody of the
child during the child's school Christmas vacalion al times 10 be agreed upon by the parties.
6. The Father lUId Mother will share cuslody of the child on his birthday at times
to be agreed upon by the parties.
7. TIle Father will have custody of the child on the Father's birthday from 12:00
noon WItH 7:00 p.m. if on a weekend. lUId from 6:00 p.m. 109:00 p.m. if on a weekday.
8. The Father will have custody of the child on Father's Day from 12:00 noon
Wltil 7:00 p.m., lUId the Mother will have custody of the child on Mother's Day from 12:00
noon Wllil 7:00 p.m.
9. The Father will have custody of the child over the three-day Labor Day
weekend from 6:00 p.m. on Friday luttil 6:00 p.m. on Monday Wllil the child is eight (8)
years old~ upon Ihe child reaching eight. lhe visillltion shall extL'I1d 10 10:00 p.m.
10. The Mother will have custody of Ihe child over the three-day Memorial Day
weekend from 6:00 p.m. on Friday wItH 6:00 p.m. on Monday Wllil the child is eighl (8)
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ycurs old~ uJlon thc child rcnching cight. thc visilUtion shull cxtl,ld to 10:00 p.m.
II. l11c Fnthcr lUld Mothcr. by l11utuul ugrccmcnt. muy vary from this schcdulc at
IUlY timc. but such vurilUlcc shallnol opcrntc to invalidutc lUlY or all provisions of this
Agrccmcnt. IUld W1Y Ordcr of Coun shall rcmuin in cffcct pl'llding furthcr Ordcr of thc Co un.
12. TIIC Futhcr wId Mothcr will notify cach othcr of ullmcdical carc thc child
rcceivcs while \11 thnt parent's carc. Each parent will notify the othcr immcdiutcly of mcdical
emcrgencics which arisc whilc thc child is in thut purent's curc.
13. Thc Mothcr shall curry thc child on her mcdical insurlUlcc as long as she is
employed. lUld Mother lUld Father agree thatthcy will shure cquully lUlY major medical
expenses not covered by the Mothcr's iosurlUlce. TIlis shall not include the normul medicul
visit deductible expense.
14. The Mother shull c1uim the child us u dependent for purposes of fcderallUld
stnte income tux rctums.
15. TIlc punies realize that thcir child's wcll being is paramount to lUlY diffcrcnces
they might have. TIlerefore. they ugrcc thnt ncither puny shnll uct in such u way us to
estrlUlgc the child from the othcr pnrent. or injure the opinion of the child as to the other
pnrcnt. or humper thc free IUld nuturnl devclopment of the child's love or respect for the other
Pllfl'll.
J of.j
II; ulegul description of which is uttuched hereto us ExhibitIA";
b) One Ford RWlger XL T truck, Vehicle IdClltificlllion Number
IFTCRI5N6PPA87389. PCllnsylvwliu LicCllse Number WR 14589;
c) An interest in one leased VolkswagCII Jella automobile, Vehicle
IdClltification Number 3VWRC81 H55M032232. PCllnsylvWlia LicCllse
Number A VS 3088;
d) TIle personul property loeuted within the residence at 64 Pine Ridge Circle.
Enolu. CumberhUld COlU1\Y. PennsylvWliu 17025.
2. 111e following is an uccurate list of the muritul debts incurred by HusbWld Wld
Wife during the murriuge:
a) An installmCllt IOWl with 111;
b) All instulhllC11t 10Wl with Members First, AccOlUlI Number 139689.02;
c) A mortguge with Integra. AccolUlt Number 0100789. for the premises
locatcd lit 64 Pine Ridge Circle. Enola. Cumberhmd COlU1\y. Pennsylvania
17025
3. HusblUld lUld Wife hereby ugree to sell the property IUld residence locuted at 64
Pine Ridge Circle. Enolu. CumberllUlll COlUllY. PellnsylvlUliu 17025 lUld 10 distribute the proceeds
us follows:
u) I'uy Ihe full buhUlce of the Integnl Mortguge. ACCOlU1\ Number 0100789;
b) Puy the full buhUlce of the 1'11' instulhllL'1\ IOlUl; lUlll
c) (luy the full huhUlce of the Members First InslUlll1lellt LllIU1. AccolUll
Number 139689.02.
d) In the event that proceeds from the sale of the residence remain following
satisfaction of the debts listed above. Husblmd and Wife shall equally
divide the remainder.
e) In the e~entthat proceeds from the sale of the residence are insufficient to
satisfy all debts listed above. such debts shall be satisfied in order as listed
and any balance remaining on any loan shall be the joint responsibility of
HusbWld and Wife to be divided equally.
4. Husband shall retain sole ownership and possession of the Fort Ranger XL T truck.
Vehicle Identification I FTCRI5N6PPA87389. Pennsylvania License Number WR 14589.
5. Wife shall retain the lease and possession of the Volkswagen leUa automobile.
Vehicle Identification Number 3VWRCllI H55M032232. pennsylvania License Number A VS
3088.
6. Wife WId Husband shall equally divide the personal property located within the
residence at 64 Pine Ridge Circle. Enola, Cumberland COlUlly. Pennsylvania 17025 as the parties
may agree.
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WIIEHEAS. Ihe parties herehy direc\ Iheir Counsel 10 suhmil Ihis Slipulalioll h,
Ihe Court and usk Ihullhe Court enter u Cuslody Order udoplinglhe lenllS hereof.
NOW, TIIEHEFOHE, in consideralion of Ihe mUluul covenunls. prumises und
ugreemenls us hcreinuller sel forth und inlending III he lellally hound herehy, Ihe parties
s\ipulule und ugree us follows:
1. 1,1:2111 Custody. I'luinlilr und Delcndunl shull share legal euslody of Ihe
minor Child Jacob Zuehary Zerbe hom July 14, 1990. Euch parenl shull huvc un equul
righi, 10 be exereised joinlly und in consullulion wilh Ihe olher purenl, 10 muke ull mujur
non-emergency decisions u!recling Ihe Child's general well-being including. bul nol
Iimiled to, ull decisions ullcctinglhe Child's beullh, educu\ion, and religion. In uddilion.
Ihe purties ugree Ihul any decisions 10 change Ihe Child's currenl huir slyle or 10 have Ihe
Child's cars pierced, will be made joinlly belween Ihe parties. !'ursuunllo Ihe lenns of
l'u.C.S. ~5309, euch parenl shall be enlilled 10 ull records, including, bulnol limited 10.
school und medieul records und infonnalion, Ihe residence uddress of Ihe Child, und Ihe
residence uddress of Ihe olher paren\. To Ihe exlenlone purenl IIlIS possession of uny
such records or inlunnulion, Ihul parenl shull he required 10 shure Ihe sume. or copies
Ihereof. with Ihe other parenl within such reusonuble lime us 10 make Ihe reports and
infomlation of reusonuhle use to Ihe olher parent.
2. I'hvs\clll CustodY. !'Iainlill' und Defendunl shall shure physicul cuslody
of Ihc Child. l'luintilr und Delcndunt will detennine Ihe cuslody exchunge lime per
agreemcnt of Ihe purties. !'luintilr und l1c\cndunl ugree Ihul Ihe Child will conlinue 10
ultend school in Fulher's school dislrict.
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3. JlolidllVR. I'luinlitr and Defendanl shall shure holidays per agreemenlof
lhe parties.
4. Out of town IIddrfRs/phonc numhfr. In lhe evenl eilher party will be oul
of lown for a period of 411 hours or more wilh lhe Child. lhe cuslodial parenl will provide
the non-cuslodial parent wilh an address and lelephone number where they can be
located.
5. Tdfphonf fontlld. Each parent shull be enlitled to reasonuble telephone
contuct with the Child when in the custody oflhe cuslodial puren\.
6. No fonnlet lonf. Bolh parties shull eslablish a no-connict zone for lhe
Child and refrain from making derogatory commenls about the olher parent in the
presence of the Child und to the extent possible shall prevent third parties from making
such comments in the presence ofthe Child.
7. Alfoholldrul!. IIbusc. Neither parent shull possess or use illicit drugs or
abuse alcohol in the presence of the Child, and to the extent possihle, shall prevent third
parties from doing lhe samc whilc in the presence of the Child.
II. Contlld Informlltlon. The parties shall keep each other inthmled oftheir
respective current addresses and telephone numbers.
Each of the parties has carefully read lllld fully considered this Stipulation and all
of the statemenls. lenns. conditions. and provisions thereof prior to signing below. The
parties agree llml Ihis Slipulnlion will he made inlo un Order of Court which may be
modi lied by mutllal writlen agreement. In the ahsenee of a mutllnl writlen agreement. the
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JEFFREY T. ZERBE,
Plaintiff
:IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY , PENNSYLVANIA
v.
:CIVIL ACTION - LAW
:IN CUSTODY
RHONDA ZERBE,
Defendant
:NO. 95-2335
STIPULATION OF CUSTODY
THIS IS A STIPULATION entered into the day and year hereinafter set forth
below, by and between JEFFREY T. ZERBE (hereinafter referred to as "Plaintiff") and
RHONDA JANSEN, formerly known as Rhonda Zerbe (hereinafter referred to as
"Defendant").
WHEREAS, the parties are the parents of one (I) minor child, namely Jacob
Zachary Zerbe, born July 14, 1990 (hereinafter referred to as the "Child");
WHEREAS, the parties are presently divorced, living separate and apart and wish
to modify their custody agreement by an agreed upon Court Ordered arrangement relative
to the physical and legal custody of their Child;
WHEREAS, the Plaintiff and Defendant, after careful consideration and the
opportunity for the advice and assistance of couJlSel, have reached an agreement to
provide for the custody of this Child without the need to litigate the matter before this
Honorable Court and asks the Court to adopt this stipulation as its Order;
WHEREAS, it is the belief of the Plaintiff and Defendant that the agreement
reached herein provides for the best interest of this Child;
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WHEREAS, the parties hereby direct their Counsel to submit this Stipulation to
the Court and ask that the Court enter a Custody Order adopting the terms hereof.
NOW, THEREFORE, in consideration of the mutual covenants, promises and
agreements as hereinafter set forth and intending to be legally bound hereby, the parties
stipulate and agree as follows:
I. Lesral Custodv. Plaintiff and Defendant shall share legal custody of the
minor Child Jacob Zachary Zerbe born July 14, 1990. Each parent shall have an equal
right, to be exercised jointly and in consultation with the other parent, to make all major
non-emergency decisions affecting the Child's general well-being including, but not
limited to, all decisions affecting the Child's health, education, and religion. In addition,
the parties agree that any decisions to change the Child's current hair style or to have the
Child's ears pierced, will be made jointly between the parties. Pursuant to the terms of
Pa.C.S. ~5309, each parent shall be entitled to all rec)ords, including, but not limited to,
school and medical records and information, the residence address of the Child, and the
residence address of the other parent. To the extent one parent has possession of any
such records or information, that parent shall be required to share the same, or copies
thereof, with the other parent within such reasonable time as to make the reports and
information of reasonable use to the other parent.
2. PhvsicaI Custodv. Plaintiff and Defendant shall share physical custody
of the Child. Plaintiff and Defendant will determine the custody exchange time per
agreement of the parties. Plaintiff and Defendant agree that the Child will continue to
attend school in Father's school district.
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3. Holidavs. Plaintiff and Defendant shall share holidays per agreement of
the parties.
4. Out of town addresS/phone number. In th,~ event either party will be out
of town for a period of 48 hours or more with the Child, the custodial parent will provide
the non-custodial parent with an address and telephone number where they can be
located.
5. Telephone contact. Each parent shall be entitled to reasonable telephone
contact with the Child when in the custody of the custodial parent.
6. No conOict zone. Both parties shall establish a no-conflict zone for the
Child and refrain from making derogatory comments about the other parent in the
presence of the Child and to the extent possible shall prevent third parties from making
such comments in the presence of the Child.
7. Alcohol/droll abuse. Neither parent shall possess or use illicit drugs or
abuse alcohol in the presence of the Child, and to the extent possible, shall prevent third
parties from doing the same while in the presence of the Child.
8. Contact information. The parties shall keep each other informed of their
respective current addresses and telephone numbers.
Each of the parties has carefully read and fully considered this Stipulation and all
of the statements, terms, conditions, and provisions thereof prior to signing below. The
parties agree that this Stipulation will be made into an Order of Court which may be
modified by mutual written agreement. In the absence of a mutual written agreement, the
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terms of the Order shall control pending further Order of Court.
IN WITNESS WHEREFORE, the parties hereto intending to be legally bound by
the terms hereof, set forth their hands and seals the day and year set forth b
WITNESS:
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Date
1'/"g'Ds.:
Date
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Rhonda Jansen, formerly
known as Rhonda Zerbe
Defendant
COMMONWEALTH OF PENNSYLVANIA
: SS:
COUNTY OF
On this, the $ day Of~U':::.I-, 2005, before me, the undersigned officer,
personally appeared Jeffrey T. Zerbe, known to me (or satisfactorily proven) to be the
person whose name is subscribed to the within instrument, and acknowledged that he
executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I have hereunt0 set my hand and official seal.
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(SEAL)
Notarial Seal
DeIJra K. landis, NolaIy PubIlc
MktIe Paxton T.."., Dauphin County
My CommissIon Expires Dec. 30, 2006
Member. Petms~a Ass<da!Ion 01_
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COMMONWEALTH OF PENNSYLVANIA
COUNTY OF fJf~)
: SS:
On this, the / if! day Of~, 2005, beforl~ me, the undersigned officer,
personally appeared Rhonda Jansen, formerly known as Rhonda Zerbe, known to me (or
satisfactorily proven) to be the person whose name is subsclibed to the within instrument,
and acknowledged that she executed the same for the purposes therein contained.
IN WITNESS WHEREOF, j have hereunto set my band and official seal.
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Notary Public . (SEAL)
~ NOTARIAL SEAl
GERAlDINE J. SCRBACIC, Nola1y JIubIIc
City at Harrisburg, Daup/lln County
My Commission expires Nov. 20, 2006
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JEFFREY T. ZERBE,
Plaintiff
~ECE\VED SEP 08100s ty
:IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
v.
:CIVIL ACTION - LAW
:CUSTODY
RHONDA ZERBE,
Defendant
:NO.95-2335
ORDER
AND NOW, this 3/L day of ~ ~ r \ .
, 2005, after careful review of
the Stipulation of Custody entered into by the parties and attached hereto, and in
accordance with the parties' request that said Stipulation of Custody be entered as an
Order of Court, it is hereby ORDERED that the parties shall share legal and physical
custody oftheir minor child pursuant to the terms of said Stipulation of Custody.
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