HomeMy WebLinkAbout95-03095
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: IN THE COURT OF COMMON PLEAS :
8 OF CUMBERLAND COUNTY .
. .
. STATE OF iaIof PENNA. ..
: ~ ~
. .
. RIIONDA K. IIERNANDEZ:! .
. I Ntl.JO~:L,,,,,,, ,,,,,,,o.f.,,,, 11) 95,
i ..
. V,",',,," .
. WILLIAM IIERNANDEZ ,I ..
.: ...
" ,I
. I
i
8 DECREE IN ..
~ DIVORCE ~
· n"A_ J ·
; AND NOW, ....,~~.. ~~...,.... 19 ,l},l?.. It I. ordered and .
iIIi.,:, decreed that,.., .R~.o,N.oA. ,K,., .H.F.,~~"~~F.,~. ,.., . ........., ....., .... plaintiff, ~
!II/ and. .,.. .. .. , .., ,\o!l~q~.I,I~~~i,\~~~~.. , .. , .. , , .... ' ,.. .. , ...... defendant, ;
: are divorced from the bond. of matrimonv. "
,.,' The court retains lurlsdlctlon of the following claim. which have ~
been raised of record in this action for which a final order hat not vet
. been entered; ,
. ..
, ,",' .liQijl;" ,TI,II.uI~\\JTt\\.. SH'j'U:M~N'j', MlR~:m'W{f, JlJ\.TJ-:.IJ. D.E.llF.MI\ER ,3., .L'1'16. .IS.. .
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M t\IUl'...AL-ti...:Lr.LliM I'; NT AG 1\ gl';M NNr
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'I'JIlS ACIIUmMgN'I', IIllldllthis --;,tl( dllY of Dccember, 1006, by and between
IlHONDA II1mNANIJI~Z or 1()7liA Huron Drive, Harrisburg, Dauphin County,
I'onnsylvuniu, 17111 Olllwinnfter "WIFI~") IInll WILLIAM IIImNANIJI~Z of 5078
Stocey Drive EIIst. Apllrlnwnt 20", Hllrrisburg, DlluJlhin County, Pennsylvania, 17111
(herelnafler "HUSBAND");
WIT N J'; S S I~ 'f II:
WIIEREA.'i. Iho 11IIrties horoto were mnrriod on April 27, 1080 at lIorrisburg.
Dauphin County, I'IHlnsylvllnill; lInll
wnEIlFAS, tho pllrtics nro tho naturnl parents ofWl11lntn Hernandez, Jr.,
born on Morch 211, \!llll; nnd
WlmlmAS. IIlVlJrllllunhop(1y IHfTllroneos, llisputes nnd dilliculties have orisen
between the snld (1nrtill!lllnl1 it is thereforo their intention to live separato Rnd apart
fill' tlw r(!8tllf Uwir IlV!'8 IInll to HolUe fully lInd nnlllly Uw1r nnnncinl nnd property
righls III1lI ohlignlion8 lH'tw!'1'1l 1!lIl:h otlwr,
NOW 'l'I11';lmFOIlE, in onnsidorntion of the oovennnts onll promises
Ill1roinllliN 1011(1 kOllt fIIlll pOl'forn1l'll hy onch pnrty lIIHIllltending 10 be legally bound
hlll"l'hy, Iho (111I'1108 ,In IIl'l'ohy lIgrr!llllB fO\lOW8:
I'ngo 1 of II
I. ^DVICg OF COUNSgJ,
Both 111I1'liPRncknowlmlgo thntlhoy hnvo hoon nlTordl!llthe oJlJlortunity
to consult wilh nn nllorney of their choico Jlrior to signing this ^greement. HUSBJ\ND
is reproRenlod by Dohrn A Donison, gsqnire. WlFg is cognizlInt of her right to legnl
reJlresentnlion nnd declnres thnt it is her eXJlress voluntnry and knowing intention not
to nvnil herself of her right to counsel nnd chooses inslend to reJlresent herself with
resJlect to tho prepnrnLion IInd execution of this ^groomenl.
The pnrlies further declnro thnt onch is executing the ^greoment freely
nnd voluntnrily hnving either obtnined sufficient knowledge nnd disclosure of their
resJlcctivo legnl right..q nnd ohligntlons or, if counsol hns not been consulted, expressly
wniving the right to obtllin such knowledge. Tho pnrlies onch ncknowlodgo thnt this
Agrooment is fnir nnd equitnble nnd is not tho result of nny frnud, coercion, duross,
undue influence or collusion.
2. SUnSF,QUEN'I' DIVORCE
An nction Ill,oking the dissolulion of tho mllrringe is Jlelllling in the
Cumberlnnd County Court of Common Plens nnd bellI'S docket number 95.3095.
HUSBAND nllll WIFE ncknowledge thnt Ihe marringe is irretrievnbly broken nnd each
ngroe to IIXlIcute both nil Affidnvit of ConsllIlt for divorce nl1ll n Wnivor of Notice of
Intontion to Hoquest gntry of n Divorce Docroo concurrently with this Mnritnl
Settlement All'reoment nq Ihe ninety (DO) dny wnltir1ll' period provided for under the
Divorco Code hllRexpired. Thill Agroomontls to ho incorporatod, hut not merged with
tho llivorco decree.
I'ngo 2 of 0
:1. SI<:1'AHNI'ION illiD NONINTF:m"lmF:NCF:
Il will ho Inwfullilr onch (lnl'ty ntnlllillles herenftor 10 live sepnrnte nnd
upnrt from Ihe othor (lnrty nt such plnce or plnces ns ho or she mny from lime to lime
dlllosn or dl'OIll lit..
gnch Plll.ty shnl1 ho I'rcn frolll inlol'fel'ence, nuthorlty nnd control, direct
or indired, by the other, ns fully ns ifhe or she were single nnd unmnrried. Neither
shnll bother the other or cOlllpel or endenvor to compel the other to cohnbit er dwell
with hilll or her.
4. jWrF:CTIVF. ONI'F:
This Agrcement shnll be elfective on the date above first written if both
parties sign on the snllle dnte; olhorwise, it shall become effective upon the signing by
the Inst pnrty 10 do so.
u. W AltRAN'I'V OF DJSCLOSUH1~
F:nch pnl't.y 11l11'l!hy conlirllls thnt hI' or she fully understnnds the torms,
conditions nnd provisions hcrool' nnd holiovos snllle 10 be fnir, just, ndequnte Rnd
rensonnble undor the oxislinl{ fnclllnnll circulllstnnces. '{'he pnrties further declare
thnt onch ill execul.inl{ IIIP A~I't'l'llIl'nt. ('r(,I,ly IIIIlI voluntnrily, hnving oHher obtnlned
sufficicnt knowledl{e nnd disdosul'C or their rl!Slwctive legnlrighls nnd obligations or,
II' counsol hils not Iwon consultlHI. I'xprl1ss1y wnlving t.ho I'il{hl to obtain such
knowlodl{l1. Thn pnl'ties t'IlI,h Ilcknowh!lIl{o thntlhis Agroclllnnt is fnir nnd equltnble
nnd is 1I0t the result or IlIlY 1"'11\111, cucreiun, durcss, unlluo influence or collusion.
Pnge 3 of 0
".
(I. rnllB.QNMLrltQfiaITY
WII~I'; 11111111 USHAND hllVll proviollMly IIlfrN'lllo tl\l! lIistrilmtioll of 1111
items of personlllllroperly. WIFE IIlfrres Ihllt 1111 such property In the possession of
HUSBAND shllll ho Iho solo IInllsppnrnto proporly of HUSBAND. HUSBAND IIgrees
thllt 1111 Much pl'ollUrty ill pOHHeHMioll or WI 1<'1'; shnll he tho sole IIIl1lsopllrlllo proporty
of WIFE. Elich or tl\l! 11IlIth-s dOllS IlL'l'eby spccifiClllly wllive, relellso IInd renounco any
rUl'tlll'r c:lllillls with I'PSllPd to saill ilpllIs,
7. HgAL I'ROl'lmTY
WIFI'; IImlH USHAND IlI'fl!hy IIcknowled!fo that thoy IIro tho owners of
cel'tllln 1'(1111 pl'OlllH'ty loclltl'd lit 222 Soulh Seconll Streel, Wormleyshurg, Cumberlllnd
Coullty. Pl'lInsylvllllill 17043, SlIid IlIm;tnl resilience has been plllcod into foreclosure
procoodin!fs 111111 hilS IH'I'II IIRIlUIllOII hy Iho hllllk.
II. IlMUUmr,:rCY FILtN.Cl AND D1mT
Bolh plIl'lil'H hllv(' filplI Sl'plIl'lIl.1' hllllkrllplcy fII:l.ions 1'111' both joint nntl
intlivillllllllll'hts,
IIUSBAND rl'presl'lIts 11I111 Wllrrllllts to WIFI~ Ihat slnco tho scparllUon
ho hilS nllt, 11111\ ill IIII' I'lIlul'l' III' wlllllot. eonlrl1l:lllr illcur III1Y lIebt or IInbllity for
whkh WIFI'; or 111'1' I'stull! llIiJ.:ht III! I'PIlIHlIlSihlll. IInlllw shllll illlll!lllllify nnllsllvo WIFE
hnl'llIll'lls f'I'llIllIlIlY ullllulI c:luimll llI' dOlllflllll.H mnllo n!fllillst hor hy rl)ASOn of such dobts
Ilr ohlilflltiolls illcurrl'll hy him HiIlCl! tho dnto of sl\iclsopllrlltioll, oxcollt liS othorwlso
sot fllrlh IlI'fl.in.
I'nl{o 4 of 0
..
WII~g fl!JlrI'Hl'ntsllnll WlIl'l'lInts to HUSBAND thllt. since the sellllratlon
she hilS not, IInd inl.he fllllll'o Rho will not. contrm:t or incur IIny debt or liability for
which HUSBAND 01' hiA osllltlll1li~ht ho I'c!RJlonslblo. IIllllshe shll11 indemnify IInd sllve
HUSBAND hlll'mll'RH fl'olll IIny IIl1clllll c1l1il1HIOr clmnlll1ds mllcle IIgllil1st him by rellson
of sllch debts or obli~lItions inclIl'!'ed hy Iwr since the dnte of slIlelseJlllrlltien, except as
otherwise set fOl'th hOl'ein.
9. VlmlCLgS
HUSBAND IIgrees thnt WIFE shnl1 retllin possession of IInd receive liS her
solollnd seJllIl'lIto Jll'oJlc!l'ty tho !!l8B Dodgo Shndow. WIFE shallllssumo responsibility
for pllyment of IIny outstllncling indebtednoss pertllining theroto and insurance
thoroon. WIFE shnIl inclemnify IInd hohl HUSBAND and his proporty harmloss from
any lillbility. costs, or expel1se. including attorney's fees incurrod in conncctlon with
snid vohlclo.
WII~E lIgl'lWS thllt HUSBAND shlll1 retnin possession of and receive as his
solo IInd Hl'plll'lIto JlI'oJWl'ty Uw 1!1!12 Nisslln Mllximn. HUSBAND shllll IIssumc
responsibility for JlnYJllont of IIny outstnnding indebtcclness pertnining thereto IInd
insurnnco thereon. HUSBAND shnll indemnify and hold WIFE IInd hor property
hllrmloss frolll IIny Iillbilit.y. costA, or eXJllJnse, including IIttorney's foos incurred in
connection with slIlel vohielu.
Pago /} of 0
Ill. 1'1';NSIOtulli12JlliT.lUl~MEI'.'I'I'I'I.ANS
HUSBAND IlI'l'l'hy wniwH nllll rl'linquislwR nny lillo, right or internsl to
WIFE's 40 IK retirement plnn, tl033 I Ii 13.110, Ihrough the Penllsylvnnin Medicnl Socioty
nlld WIFE's Jlellsioll plnn through tho 1'Illlllsylvllnin Mellicnl Society Linbllity
Illsurnllco ComJlnny. HUSBAND hns no IWIlHioll 01' relirmnellt benefits.
II. SPOUSAL SUPPOHT. AJ.1MONY PF:NDRNTR LI'I'K AND ALIMONY
WIFE IIlld HUSBAND do IlIlreby wnive, relollso, dischnrge nnd give up
nny rights which either mny hnve ngninst t.ho other to receive sJlO\lsnlsupport, alimony
penlhmt.1! lito 01' lllilllony,
12. 'I'AX 1'1lOVISIONS
The pnrtills hnVl! ngrcml thnt for Income Tax 11\I1')10Ses, WIFE shllll dL'CIaro
WilIlnm Hernnndez, .Jr.. ns II delllmdllncy exmnption.
13. Nlvl'OIlNIW FlmS. CaUlt'I' COSTS
Ench Jlllrty shnll be respenslhlo for t.holr own lognl fees, costs, nnd
eXJlenscs incurred in connoclion with thoir sepnrntion nn(l/or tho dillsolution of their
mlll'l'ingp. 1II111thp IlrPllllrlltioll 111111 ('"pelltion of' thiH AgrnPllwllt.
14. MQDlElCf\TION
No mmlifklltioll. rescission, nt. IInHlIHll1Ient 10 t.his AgrcHlll1ent shnll be
olTl'ctivo uul(!IlH in writing sigllpd hy !'lIch 111I1'ty 10 t.his Agrl'oll\l!nt.
Pngl! 11 of ()
Ir;. MUTUAL Iml,Jo:ASI';
WWI': IIl1d IltlSIIAND do hereby relonse ench olhcr from nny oUler c1nims
with rCBpect to thc mllritlllllnd non.mllrillll asscts of the parties. Additionally, each
pnrty hCrl!hy rolnllsl'H IIny illtnrl'st thllt ho or sho JIIny havc in the estale of the other.
16. MUTUAL COOPlmA1'ION
WWI~ IInd HUSBAND shlllllllutulllly cooperllte wilh cnch other in order
10 cllrry through tho ll!l'Il1S of this AI,'l'OOlllcnt. including but not limited to, the signing
of docuJllcnts.
17. J3RJo:ACII OF AOJmJo:MEN1'
WIFE nnd I IUSBAND hcrcby nJ,'l'ce thnt if either pnrty breaches any of
tho torlllll of thill Agrl!l!llInnt II III I II e1nilll or furthor legal nction is required, the
brellching pnrty shnl1l'lJimburse the other nlllegnl fees and costs incurred ns a result
of snltllll'llllch or c1nllll.
18. AOlUmMENT BINDING ON HEIRS
Thill Agl'lH'lIIollt cOlllllilutes the linnl 1IJ,'l'eelllent of the pnrties and is
bindinl,' upon thoir lll'il'lI, nllllil,'nll nllll 1I11l:CI'ssors in interest.
22. VOID CLMLSES
[f' IIny lpl'lIl, conelition. e1I1UIl0 or provillion of this AlfrcOlllollt shnll be
e1ntprlllilll'e1 or ,1I.e1I1l'pelto Ill' voill 01' illvlllill in IlIw or otherwillo, IllI'n ollly thnt lorm,
Pnl,'n 70fO
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.---......
REAOER . ADLER. PC
ATTORNEVS AT LAW
23]1 MARKET STREET
CAMP Hill. PA ITa 11
'f.H; 183.'313
<-..
RHONDA K. HERNANDEZ,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: DAUPHIN COUNTY, PENNSYLVANIA
v.
NO. 95-3095 CIVIL
WILLIAM HERNANDEZ,
Defendant
CIVIL ACTION - DlVORCFJCUSTODY
PRAECIPE TO TRANSMIT RECORD
TO THE PROTHONOTARY:
Transmit the record, together with the following information, to the court for entry of an
appropriate divorce decree:
I. Ground for divorce: Irrelrlevable breakdown under SectIon 3301(c) orthe Divorce
Code.
2. Date and manner ofservlce of complaint: The Com..lalnt wa. med on June', 1995,
and wa.served on Ddendant Wll1Iam Hernandez on June II, 1995.
3. Date of execution ofthe affidavit of consent required by Section 3301(c) ofthe Divorce
Code: by Plalnll" December 3,1996; by Defendanl December 3,1996.
4. Dale of execution of the waiver of notice of intention to request entry ora divorce decree
required by Section 3301(c) of the Divorce Code: by Plalntl" December 3, 1996; by Derendaat
December 3, 1996.
S. Related Economic Claims Pending: There are no economic claim. pendln.a. tla.
dlstrlbullon or all penonal and real property has been settled by a.rument or the partl...
Respectfully Submitted,
REAGER" ADLER, PC
\
Date: December 4, 1996 By: ~A. ~i1~iSON' ESQUIRE
Atlom.IlY 10: No. 66378
2331 Market Street
Camp Hili, PA 17011-4642
Telephone No. [717) 763-1383
Attorneys for Defendant
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-.-
RHONDA HERNANDEZ, IN THE COURT OF COMMON PLEAS
PLAINTIFF OF CUMBERLAND COUNTY,
PENNSYLVANIA
V NO. fi'j.109>''ctVIL -rt...~
CIVIL ACTION - LAW
WILLIAM HERNANDEZ,
DEFENDANT ACTION FOR DIVORCE / CUSTODY
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 by the court. A judgement may also be entered
against you for anr other claim or relief requested in these
papers by the plaint ff. You may lose money or property or other
rights important to you, includlng custody or visitation of your
children.
When the ground for the divorce is indignities or
irretrievable breakdown of the marriagei you may request marriage
counseling. A list of marriage counse ora is available in the
Office of Prothonotary at the Cumberland county Courthouse, 1
Courthouse Square, Carlisle, Pennsylvania, 17013.
IF YOU DO NOT FILE
PROPERTY, LAWYER'S FEES
ANNULMENT IS GRANTED, YOU
THEM.
A CLAIM FOR
OR EXPENSES,
MAY LOSE THE
ALIMONY,
BEFORE
RIGHT TO
DIVISION
A DIVORCE
CLAIM ANY
OF
OR
OF
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP
Cumberland Count~ Lawyer Referral Service
Cumberland county Courthouse
Court Administrator
1 Courthouse Square
Carlisle. Pennsylvania, 17013
(717)-240-6200 .
'--' l~ 1I1n -
Dated: ~LI..\.U2_ (\ I 1:L:J.':> B .
.
RHONDA HERNANDEZ, I IN THE COURT OF COMMON PLEAS
PLAINTIFF OF CUMBERLAND COUNTY,
PENNSYLVANIA
V NO. CIVIL
CIVIL ACTION - LAW
WILLIAM HERNANDEZ,
DEFENDANT ACTION FOR DIVORCE I CUSTODY
t!oTl~E_Qr_RIQ1i'LTO COUN~liQ.
You are one of the parties in the above captioned action in
Divorce. By virtue of Section 202 of the Pennsylvania Divorce
Code, tt is the duty of the Court to advise both parties of the
availability of counseling and upon r~quest to provide both
parties a list of qualified professionals who provide such
services.
Accordingly, if you desire counseling. please advise in
writing promptly by replying to: Prothonotary, Cumberland County
Courthouse, 1 courthouse Square, Carlisle, Pennsylvania, 17013.
Prothonotary
.
RHONDA HERNANDEZ,
PLAINTIFF
IN TilE I:OllRT OF GOMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
NO. CIVIL
CIVIL ACTION - LAW
ACTION FOR DIVORCE / CUSTODY
V
WILLIAM HERNANDEZ,
DEFENDANT
COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE
1. Plaintiff is RHONDA HERNANDEZ, who currently resides at 223
South Second Street, Wormleysburg, Cumberland County,
Pennsylvania, 17043, and has resided in CUmb~rland County for
over four (4) years.
2. Defendant is WILLIAM HERNANDEZ, who currently resides at 267 B
North Arlington Avenue, Dauphin County, Pennsylvania, 17109, and
has resided in Dauphin County for four (4) months.
3. Plaintiff and Defendant have been bona fide residents in the
Commonl~ealth for at least six (6) months immediately previous to
the filing of this Complaint.
4. The Plaintiff and Defendant are husband and wife, and were
lawfully married on April 27, 19S9, in Harrisourg, Pennsylvania.
5. There have been no prior actions of divorce or for annulment
between the parties except this Complaint filed for divorce.
(,. Th. 1III1IIII1UI' 1/1 Illplllf'Vilhly lllukell.
7. Plltlltlfl Inll lJehndant have been advised of the availlbility
nl cl1l1na"llnu. and 111 I he Ilulll to request that the Court requi re
lhll PAlt11l1l 111 pllllicll'alll ill counseling.
O. TIa. lIIarlllYII Is Ilrelrlevably broken.
9. Nalther Plaintiff nor Defendant is in the military or naval
lelVlce of the Uniled Slates or its allies within the provilions
of the Soldiers' and SlIilolS' Civil Relief Act of the Congress of
1940 Ind ita amendments.
10. The Parlies IallVe one childl William lIernandez. Jr..
CQIJIiT _ I
REOU~ST FO~ A NO-FAULT DIVORCE
UNDER SECTION 33Gl(c) OF THE DIVORCE CODE
11 . The
h,r.in by
prior parlgraphs of
reference thereto.
this
Complaint are
incorporated
12. After ninety (90) days have elapsed from the dlte of filing
of thil Compllint. Plaintiff intends to file en Affidavit
cona.ntln9 to a Divorce. Plaintiff believes that Defendant may
allo fll. auch an Affidavit.
Wherefore, Plaintiff respectively requests if both parties
file affidavits consenting to a divorce after ninety (90) days
have elapsed from the date of filing of this Complaint, this
Honorable Court enter a decree of divorce pursuant to Section
3301 (c) of the Divorce Code.
C9JJll.'LU
RJ;QlJ.!Hl.r_l"QR CQJjf'.tRM1\T I ON Of' GlJ ~TJJ..P,(
UNDJ;.!LJLE&'U91L2.1Q LQf_.THILJlJ VQR,g]:, COm;
13. The
herein by
prior paragraphs of
reference thereto.
this
Complaint are
incorporated
14. Plaintiff seeks Primary
following minor childl
NAME
WILLIAM HERNANDEZ, JR.
Legal and Physical Custody of the
PRESENT RESIDENCE
223 South Second Street
Wormleysburg, PA 17043
AOE
8/D-3/29/91
4 years
The child was not born out of wedlock.
The child is presently in the custody of the Plaintiff, who
resides at 223 South Second Street, Pennsylvania, 17043.
The minor child since his birth has resided with the
following persons and at the following addressl
NAME ADDRESS DATES
RHONDA HERNANDEZ
WILLIAM HERNANDEZ
223 South Second street
Wormleysburg, PA 17043
3/29/91 to
2/25/95
RHONDA HERNANDEZ
223 South Second street
Wormleysburg. PA 17043
2/25/95 to
Present
15. The Mother of the minor child is RHONDA HERNANDEZ,
ourrently residing at 223 South Second Street, Wormleysburg, PA
17043.
She is married, but separated.
The Father of the minor
ourrently residing at 267 B North
Pennsylvania, 17109.
He is married, but separated.
child is WILLIAM HERNANDEZ,
Arlington Avenue, Harrisburg,
16. The
of Mother.
relationship of Plaintiff to the minor
The Plaintiff currently resides with
child is that
the following
persons:
NAME
WILLIAM HERNANDEZ, JR.
RELATIONSHIP
son
The relationship of the Defendant to the minor
of Father. The Defendant currently resides with
persons I
ohild is that
the following
NAME
None Known
RELATIONSHIP
17. Plaintiff has not participatpd an a palty or witness. or
another capacity. in other litigation concerning the custody of
the child in this or another court.
18. Plaintiff has no information
concerning the child pending in a court
of a custody proceeding
of this Commonwealth.
19. Plaintiff does not know of a person not a party to the
proceedings who has physical custody of the chi Id, or claims to
have custody or visitation rights with respect to the child.
20. The best interest and permanent welfare of the child
will be served by granting the relief requestedl
a. Plaintiff has the great desire and ability to give her
minor ohild the care and love. to nurture and assist with the
development of her child, in a warm. loving environment.
Plaintiff has no desire nor inclination to keep the parties child
from the Defendant. but recognizes the important role a Father
plays in the development of a child. Plaintiff respectfUlly
requests Plaintiff and Defendant be awarded Shared Legal custody
of their child.
b. Plaintiff respectfully requests that Primary Physical
Custody of her child be awarded to her. with the Defendant being
awarded the Partial physical custody of his minor child according
to the following schedu1el
c. Alternating weekends the Pather shall enjoy visitation
with his minor child:
d. The following holidays shall be shared between the
parties as the parties can mutually agree to:
New Year's Day Independence Day
Easter Labor Day
Memorial Day Thanksgiving Day
e. Father shall have the child on Christmas Day at times
mutually agreed to between the pnltje".
f. Father shall enjoy Father's Day and Mother shall enjoy
Mother's Day with their minor child from 9100 A.M. until 8100
P.M. :
g. Either party shall have the ability to request a two (2)
week uninterrupted vacation with their minor child, with thirty
(30) days notice to the other party:
h. The
visitation as
parties shall be free to further
they can mutually agreed upon.
schedule
such
WHEREFORE, Plaintiff requests this Honorable Court grant
Shared Legal Custody of the parties minor child to Plaintiff and
Defendant, Primary Physical Custody to Plaintiff with Partial
Physical custody to the Defendant as requested in the above
paragraphs.
~ '1~, Iqq!,)~
Respectfullyaubmitted,
C~ G~~(~~"
Susan K:~Jndiello
Id, No. li4998
110 South Carlisle street
P,O. lIox 670
NeW nloomfieldi PA 17068
Attorney for P aintiff
RHONDA HERNANDEZ,
PLAINTIFF
IN TilE COURT OF COMMON PLEAS
I OF CUMBERLAND COUNTY,
PENNSY1,vANIA
NO. CIVIL
CIVIL ACTION - LAW
I ACTION FOR DIVORCE I CUSTODY
V
WILLIAM HERNANDEZ,
DEFENDANT
nBU.lQA'UOli
1, RHONDA HERNANDEZ, verify I am the Plaintiff in the
foregoing aotion, that the attached complaint for Divorce and
cuatody ia baaed upon information which has been gathered by my
oounael in the preparation of this lawauit. The language of the
Complaint is that of my counael and not mine. 1 have read the
Complaint and to the extent that it ia baaed upon information
whioh 1 have given to my counael, it ia true and correct to the
be.t of my knowledge, information and belief. To the extent that
the oontenta of the Complaint is that of oounael, I have relied
upon counael in making thia Verification.
1 underatand that 1 am subjeot to the penalties of 18 Pa.
C.S. .eotion 4904 relating to unaworn falsification to
authorities for any false statements that I have made in the
foregoing Complaint.
DATE 51:~)CJ... 5"
. .
RIIONDA
HERNANDEZl
PLAINT FF
V
IN TilE COURT OF COMMON PLEAS OF
CUMBERLANO COUNTY,
PENNSYLVANIA
I NO,
CIVIL ACTION LAW
ACTION FOR DIVORCE / CUSTODY
WILLIAM HERNANDEZ,
DE~'ENDANT
C;)i;BTH'ICI\'I'E Uj" S!!:RVlCI':
I, Susan Kay Candiello. Esquire, hQreby certify that a true
and correct copy of the foregoing COMPI,IIINT ~'Oll DIVORCE / CUSTODY
was served by first class mail, postag~ prepaid upon!
Mr. William Hernandez
267 B North IIrlington Avenue
lIarrisburg, PA 17109
Date~
?
. 1995
~
PA 17068
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: IN THE COURT OF COMMON PLEAS
: CUlIUE~.LANIJ COUNTY, PENNSYLVANIA
RHONOA K. HERNANDEZ,
v,
NO, 95-3095 CIVIL
WILLIAM HERNANDEZ,
Defendant
CIVIL ACTION - OIVORCFJCUSTOOY
AFFIDA VIT OF CONSENT
1. A Complaint in divorce under section 330J(c) of the Divorce Code was flied on June 8,
1995.
2, The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have
elapsed from the date oft1l1ng the Complaint,
3. I consent to the entry of a t1nal decree of divorce after service of notice of Intention to
request entry of the decree,
4. I understand that I may lose rights concerning alimony, division of property, lawyer's fee.
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 subjcctto the penalties of 18 Pa,C,S, ~ 4904 relating to unsworn fa1s1l1cation
to authorities.
Dated: ,a/.~ /4l.P
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ATTORNEVS AT lAW
2331 MARKET STREET
CAMP Hill. PA 11011
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RHONOA K. HERNANDEZ,
IN THE COURT OF COMMON PLEAS
CUMUERLAND COUNTY. PENNSYl.vANIA
Plaintiff
v,
NO, 95-3095 CIVIL
WILLIAM HERNANDEZ,
Defendant
CIVIL ACTION - D1VORCFJCUSTOOY
A"'FIDA VIT OF CONSENT
I. A Complaint in divorce under section 3301(c) of the Divorce Code was flied on June 8,
1995,
2, The marriage ofPlaintiO'and Oefendsnt is Irretrievably broken and ninety (90) days have
elapsed lfom the date offlling the Complaint.
3, I consent to the entry of a final decree of divorce after service of notice of intention to
request entry of the decree,
4. I understand that 1 may lose rights concerning alimony, division of property, lawyer's fees
or ellpenses if! do not claim them before a divorce Is granted,
I verify that the statements made in this affidavit are true snd correct. I understand that false
statements herein are made subjcctto the penalties of 18 Pa,C, S. ~ 4904 relating to unsworn tIlslflcatlon
10 authorities.
Dated: D~:CEMUER 3. 1996
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RHONDA K. HERNANDEZ.
IN THE COURT OF COMMON PLEAS
CUHIIERI.Atm COUNTY, 1'~:NNflYl.v^NIA
Plsintiff
v,
NO, 95-3095 CIVIL
WILLIAM HERNANDEZ.
Defendant
CIVIL ACTION - D1VORCFJCUSTOOY
WAIVER OF NOTICE OF INTENTION TO REOUEST
ENTRY OF A DIVORCE DECREE
UNDER SECTION 330UC' OF TilE DIVORCE CODE
4, I consent to the entry ofa final decree of divorce without notice.
5, 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.
6, 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.
I veritY that the statements made in this affidavit are true and correct. I understand that tilae
statements herein are made subject to the penalties of 18 Pa,C.S. fi 4904 relating to unsworn falsification
10 authorities,
Dated: J ~Jj/q f"
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RIIONOA K. IIERN'ANDEZ.
PlalntllT
IN TilE COURT OF COMMON PLEAS
: CllMU~:l\LANIl COUNTY I i'~;NNSYLVANIA
v,
NO, 95-3095 CIVIL
WillIAM HERNANDEZ,
Defendant CIVIL ACTION. DlVORCfJCUSTOOY
WAIVER OF NOTICE OF INTENTION TO REOUEST
ENTRY OF A DIVORCE DECREE
UNDER SECTION 330UC) OF TilE DIVORCE CODE
I, 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 e1lpenses 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 l1Ied with the Prothonotary.
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 10 unsworn falsification
to authorities,
Dated: 12-3-1996
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RHONDA HERNANDEZ,
PLAINTIFF
V.
I N THE ';OllHT OF COMMON PLEA!:!
OF CUMBERLAND COUNTY,
PENNSYLVANIA
NO.7)' :Ji"l\ CIVIl, 'l'.l"'~
CIVIL ACTION - LAW
CUSTODY / VISITATION
WILLIAM HERNANDEZ,
DEFENDANT
ORDER OF COURT
AND NOW, this ,j...vy I'; /(1"( upon consideration of the
attached complaint, It is hereby directed that the parties and
their respective counsel appear before 5"",,"'/ l f}f1('~'1 {..~,
the conci 1 iator. at ~f(}S 11(. fC)111 51. ("fh"WI(
,
on the ~ day of ~d y ,1995, at ~
olclock~,M.. for a Prehearing Custody Conference, At such
conference. an effort will be made to resolve the issues in
dispute: or if this cannot be accomplished, to define and narrow
the issues to be heard by the court, and to enter into a
temporary order. Either patty may bring the child/children who
are the subject(s) of thia custody action to the conference. but
the child/children's attendance is not mandatory. Failure to
appear at the conference may prOVide grounds for entry of a
temporary or permanent order.
FOR TilE COURT:
BY: .
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER
HAVE A LAWYER OR CANNo1' AFFORD ONE. GO TO
SET FORTH BELOW TO FIND OUT WHERE YOU CAN
'~t I
AT ONCE. IF YOU DO ~J
OR T~L~PHONE THE OFFICE
GET LEGAL HELP.
OFFICE OF TilE COURT ADMINISTRATOR
CUMBERLAND COUNTY COURTIIOtJSE, FOURTH FLOOR
CARL I aLE, PENNtJYJ,VAN lA, 1701l
(717) . 240 - 6200
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IP '19. tj( V1~ -ma.J;; $ 4/f.
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RHONDA HERNANDEZ, IN THE COURT OF COMMON PLEAD
PLAINTIFF OF CUMBERLAND COUNTY,
PENNSYLVANIA
V NO. CIVIL
CIVIL ACTiON - LAW
WILLIAM HERNANDEZ,
DEFENDANT ACTION FOR DIVORCE / CUSTODY
COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE
1. Plaintiff is RHONDA HERNANDEZ, who currently resides at 223
South Second Street, Wormleysburg, cumberland County,
Pennsylvania. 17043. and has resided in Cumberland County for
over four (4) years.
2. Defendant is WILLIAM HERNANDEZ, who currently resides at 267 B
North Arlington Avenue, Dauphin county, Pennsylvania, 17109, and
has resided in Dauphin County for four (4) months.
3. Plaintiff and Defendant have been bona fide residents in the
Commonwealth for at least six (6) months immediately previous to
the filing of this Complaint.
4. The Plaintiff
lawfully married
and Defendant are husband and wife, and were
on April 27, 1989, ln Harrisburg, Pennsylvania,
5. There have been no prior actions of divoroe or for annulment
between the parties except this Complaint filed for divorce.
6. The marriage is irretrlevably broken,
7. Plaintiff and Defendant have been advised of the availability
of counsellng, and of the rlghl to request that the Court require
the parties to participate in counseling,
8. The marriage is irretrievably broken.
9, Neither Plaintiff nor 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.
10. The Parties have one child: William Hernandez, Jr..
QQQli'Ll
REQUEST FOR A NO-FAULT DIVORCE
UNDER SECTION 3301(c) OF THE DIVORCE CODE
11. The prior paragraphs of this Complaint are incorporated
herein by reference thereto.
12. After ninety (90) days have elapsed from the date of filing
of this Complaint. Plaintiff intends to file an Affidavit
consenting to a Divorce. Plaintiff believes that Defendant may
also file such an Affidavit.
Wherefore, Plaintiff respectively requests if both parties
file affidavits consenting to a divorce after ninety (901 days
have elapsed from the date of filing of this Complaint, this
Honorable Court enter a decree of divorce pursuant to Section
3301 (c) of the Divorce Code.
COV.N't.._U
11!1;Q.u!,;Il.Tf'Q~ CQIH".lR!1bTHl,N Of' \;;VJ?.'r.QP''i
!.!li.P.E.ILM;~'U.illi,.liQl...Qf.....'rH.F;Jl I VORCE Com;
13 . The
herein by
prior paragraphs of
reference thereto.
this
Complaint are
incorporated
14. Plaintiff seeks Primary
following minor childl
NAME
WILLIAM HERNANDEZ, JR.
Legal and physical custody of the
PRESENT RESIDENCE
223 South Second Street
Wormleysburg, PA 17043
AGE
B/D-3/29/91
4 years
The child was not born out of wedlock,
The child is presently in the custody of the Plaintiff, who
resides at 223 South Second Street, Pennsylvania, 17043.
The minor child since his birth has resided with the
following persons and at the following addrossl
NAME ADDRESS DATES
RHONDA HERNANDEZ
WILLIAM HERNANDEZ
223 South Second Street
Wormleysburq. PA 17043
3/29/91 to
2/25/95
RHONDA HERNANDEZ
223 South Second street
Wormleysburg, PA 17043
2/25/95 to
Present
15. The Mother of the minor child is RHONDA HERNANDEZ,
currently residing at 223 South second Street, Wormleysburg, PA
17043.
She is married, but separated.
The Father of the minor
currently residing at 267 B North
Pennsylvania, 17109,
He is married, but separated.
child is WILLIAM HERNANDEZ,
Arlington Avenue, Harrisburg,
16, The
of Mother.
relationship of plaintiff to the minor child is that
The Plaintiff currently resides with the following
persons:
RELATIONSHIP
NAME
WILLIAM HERNANDEZ. JR.
eon
The relationship of the Defendant to the minor
of Father. The Defendant currently resides with
personal
child is that
the following
NAME
RELATIONSHIP
None Known
17. Plaintiff has not participated as a party or witness, or
another capacity, in olher litigation concerning the custody of
the child in this or another court.
18. Plaintiff has no information of a custody proceeding
concerning the child pending in a CO'lrt of this Commonwealth.
19. Plaintiff does not know of a person not a party to the
proceedings who has physical custody of the child, or claims to
have custody or visitation rights with respect to the child.
20. The best interest and permanent welfare of the child
will be served by granting the relief requested:
a. Plaintiff has the great desire and ability to give her
minor child the care and love, to nurture and assist with the
development of her child, in a warm. loving environment.
Plaintiff has no desire nor inclination to keep the parties child
from the Defendant, but recognizes the important role a Father
plays in the development of a child. Plaintiff respectfully
requests Plaintiff and Defendant be awarded Shared Legal Custody
of their child.
b. Plaintiff respectfully requests that Primary Physical
Custody of her child be awarded to her, with the Defendant being
awarded the Partial Physical Custody of his minor child according
to the follOWing schedule:
/
c. Alternating weekends the Father shall enjoy visitation
with his minor child;
d. The following holidays shall be shared between the
parties as the parties can mutually agree to;
New Year's Day Independence Day
Easter Labor Day
Memorial Day Thanksgiving Day
e. Father shall have the child on Christmas Day at times
mutually agreed to between tho parties.
f. Father shall enjoy Father's Day and Mother shall enjoy
Mother's Day with their minor child f~om 9:00 A.M. until 9:00
P.M. ;
g. Either party shall have the ability to request a two (2)
week uninterrupted vacation with their minor child, with thirty
(30) days notice to the other party;
h. The parties shall be free to further schedule such
visitation as they can mutually agreed upon.
WHEREFORE, Plaintiff requests this Honorable Court grant
Shared Legal custody of the parties minor child to Plaintiff and
Defendant. Primary Physical Custody to Plaintiff with Partial
Physical Custody to the Defendant as requested in the above
paragraphs,
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Cern.~ndi e 11 0
susanN K\4998 . 1 street
Id. o. h Carlls e
110 SB~~ 670 PA 17068
P'O'Bloomfieldpiaintiff
New for
Attorney
. .
RHONDA HERNANDEZ, IN THE COURT OF COMMON PLEAS
PLAINTIFF OF CUMBERLAND COUNTY,
PENNSYLVANIA
V NO. CIVIL
CIVIL ACTION - LAW
WILLIAM HERNANDEZ,
DEFENDANT I ACTION FOR DIVORCE / CUSTODY
VERIFICATION
I, RHONDA HERNANDEZ, verify I am the Plaintiff in the
foregoing action, that the attached Complaint for Divorce and
CUltody il based upon information which has been gathered by my
counsel in the preparation of this lawsuit. The language of the
Complaint il that of my counlel and not mine. I have read the
Complaint and to the extent that it is based upon information
which I have given to my counsel, it is true and correot to the
belt of my knowledge, information and belief. To the extent that
the contents of the Complaint is tnat of counsel, I have relied
upon counsel in making this Verification.
I understand that I am subject to the penalties of 18 Pa.
C.S. section 4904 relating to unsworn falsification to
authorities for any false statements that I have made in the
foregoing Complaint.
DATE
5 ho/q" ')
,
, ' '.
RHONDA HERNANDEZ.
PLAINTIFF
V
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,
PENNSYLVANIA
NO.
CIVIL ACTION - LAW
ACTION FOR DIVORCE / CUSTODY
WILLIAM HERNANDEZ,
DEFENDANT
C;:ERT I F I CI\.T&".Qf_~j!;RY~E
I, Susan Kay candiello, Esquire, hereby certify that a true
and correct copy of the foregoing COMPLAINT FOR DIVORCE / CUSTODY
was served by first class mail, postage prepaid upon:
Mr. William Hernandez
267 B North Arlington Avenue
Harrisburg, PA 17109
Date~'
, 1995
~
Susan a
110 Bout
P.O. Box 6
New Bloomfield,
PA
17068
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1991,..-'
PLEAS OF
RHONDA HERNANDEZ,
PLAINTIFF
V
IN THE COURT OF COMMON
CUMBERLAND COUNTY,
PENNSYLVANIA
NO, 95-3095
CIVIL ACTION - LAW
ACTION FOR CUSTODY
WILLIAM HERNANDEZ.
DEFENDANT
QRPJ;:R Qf COURT
AND NOW, this 'is day of September, 1995, upon
presentation and consideration of the attached Stipulation for
Agreed Order of custody, it is hereby ORDERED AND DECREED. that
the said stipulation, as submitted and executed by the parties,
shall be lncorporated lnto and made a part of this order, thereby
giving said Stipulation the full force and effect as an Order of
this Court,
BY THE
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RHONDA HERNANDEZ,
PLAIllTH'f'
V
WILLIAM HERNANDEZ,
DEFENDANT
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
PENNSYLVANIA
NO. 95-3095
CIVIL ACTION - LAW
IN CUSTODY
STIP~~ATIQN fOB ^OR~~P QRP~B Qf GY~1QPY
Plaintiff is RHONDA HERNANDEZ, who currently resides at, 223
south
Second st t'eet,
Wormleysburg,
Cumberland
County,
Pennsylvania, 17043.
Defendant is WILLIAM HERNANDEZ, who currently resides at 267
B North Arlington Avenue, Dauphin County, Pennsylvania, 17109.
WILLIAM HERNANDEZ JR., who is the subject of this Custody
Agreement, is the natural child of the Plaintiff and Defendant,
Wi II lam Hernandez Jr., was born on March 29, 1991.
It is Plaintiff's and Defendant's belief it is in the best
interests of their mlnor child to have a meaningful ongoing
relationship with both his Mother and Father, provided the child
is in a uafe environment.
WHEREFORE, Plaintiff. RHONDA HERNANDEZ,
and Defendant,
WILLIAM HERNANDEZ. have entered lnto a mutual 8\lreement regarding
the custody of their child and tespectfully request that this
Honorable Court enter the folloWln\l Order:
-
1. Plaintiff and Defendant shall share
defined in 23 Pa.C.S.A. sectIon 5302), of
William Hernandez Jr..
Legal Custody, (As
their minor child,
2, Primary Physical Custody of William Jr" shall be with
the Plaintiff, Rhonda Hernandez, while Defendant, William
Hernandez, shall enjoy Partial Physical Custody of William Jr..
3. Plaintiff and Defendant have mutually agreed to
cooperate and work together in scheduling visitation their child.
Defendant shall enjoy Partial Physical Custody of William Jr. as
follows:
(a) Defendant shall have William Jr. on alternating
weekends for Visitation;
(b) The parties shall share the following holidays;
New Year's Day, Easter, Memorial Day, Independence Day, Labor
Day, and ThanksgiVing Day. The parties shall communioate with
each other a minimum of two ( 2 ) weeko prior to the holiday, to
decide a schedule, thus enabling each party to make appropriate
plans for the holiday;
(c) Defendant shall have William Jr. on Christmas Day,
at such times as the parties can agree to;
(d) Defendant shall have William Jr. on Father's Day
and Plaintiff shall have William Jr. on Mother's Day, from 9:00
A,M. until 8:00 P.M.;
(e) Either party shall have the ability to request up
to a maximum of a two (2) week uninterrupted vacation with
William Jr., with thirty (30) days notice in writing to the other
party, and that party's mutual agreement;
(f) The parties shall be free to mutually agree to
further visitation and schedule alterations of visitation with
William Jr..
4. Plaintiff shall have William Hernandez Jr. as an Income
Tax Deduction.
DATE:
o-)d.1J,,5
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