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Home My WebLink About95-04489 . . . . -------------~-~~~--)~~~---_._~ * ~ . ~-.-- ------~~--.- . ' : IN THE COURT OF COMMON PLEAS ~ 8 OF CUMBERLAND COUNTY 8 _ * 8 , ;; ~ STATE OF PENNA. : j ~. .. .~ . 8 " 8 il : i;, , No, "....\15"'.4,4,a9,..,J\XXl(~X '. ~ Julia. Lynn Holtz I . 8' . " \ l'l'~lI~ * ~ .i . 8 Jeffrey Allen Holtz II . .,. ,:, ~ 8 (, 8 DECREE IN ~ . ~ . DIVORCE ., ij \ n.-u.lA) ~ " AND NOW, ".d~', ,~,l...",. ,~,-". It Is ordered and 8 " 2 8 decreed that.. , . ,JulJ.,a ,Lynn. HoLtz.. , , , . .. , .. , , . . , , . , .. , , , '. plaintiff, ~ .. ~ ~ and. ,...', ,.., ,... ,J,Qff.r.~Y ,l\.l.l.~n, .H.QH~..."... , "" ,.., .., defendant, ~ ~ are divorced from the bonds of matrimony. . 8 " . The court retains jurisdiction of the following claims which have : . been raised of r~\or~ In this action for which a final order has not yet ~ ~ been entered; VJO\Af2.. 8 : ""'.'."'.."'.."""""".""".""'..'..."";/fI"."""'.."." : 8 "'" ,."""""""..""."" ", :i'';.('''''''''''' ..,.., : . . 1/ M ~ !' ~ . /ly 1~e e",:, ;' ~ 8 ~ ~ ~ AII.'I. ~ J, I:: "' ~ 8 I, ~ I'rnlhullolnl'Y i!! ~ .______.,,-___.___,."..""". , . ..)1 .~~~~-~~~-~-~*~*.~..~.~.~~.,~~..~.~~*~,*** '.,oi ." '. ~ 3()'Cif'i t1:~/. (lc;f:Jn~4/r,~ ~~1 h<t~ ;.. '_~Ia' Llt;t~... "",4;/ r.-~ 4.~:tJ Y4uda"lL . . . JULIA l YNN HOLTZ, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO, 95-4489 CIVil TERM : CIVil ACTION. LAW : IN DIVORCE V, JEFFREY ALAN HOLTZ. Defendant PR..,lCIPE TO TRANSIIIT RECORD To the Prothonotery: Transmit the record togethar with the following Informalion, to the Court for entry of a divorce decree: 1, Ground for e divorce: Irretrleveble breakdown under Section 3301 (c) olthe Divorce Code, 2, Date end menner of service of the Complaint: 0II/02lll5 . Certified Mell. 3, Complete either peragreph (a) or (b), (a) [,ate of execution of the affidavit of consent required by Section 3301 Ic) of the Divorce Coda: by the Plelntlff 06/02100, by the Defendent 05128/00. Ib) (1) Dete of execution olthe plaintiff's effldavlt required by Section 3301(c) ofthe Divorce Code: (2) Dete of service of the plaintiff's affidavit upon the Defendant: 4, Releted claim pending: All related clalmB heve been Bellied by Agreement. 5. Complete either (a) or (b) (a) Dete and manner of service of the notice of Intenlion to file praecipe to transmit record, a copy of which Is ettached, If the decree Is to be entered under section 3301 (d) of the Divorce Code: (b) Date Plelntlff's Waiver of Nolice In g 3301(c) Divorce was flied with the Prothonotery 08/05/00 Date Defendsnt's Waiver of Notice In g 3301 (c) was filed with the Prothonotary 05/31/00. '7 Date: roj,yoJ 1. Charles Rector, Esq Ire Attorney for the Plalnliff l(l .,.. ~. \ 1(. , i .. .- I, ("-,) , ') ~ ; , ..' , } :",~ , , .~. : " "', , :; ", , ,) ':\. I ~ ~.; \, ~ i (~\ , 1'0. .' , . i , ; " l~') (.J U Co, U 0:'" 0__ 11I1'4-'" Dl ~ ~ Iii I&. ~~;I~ Om~~~ h~h ~~I~I i~~~ . . ' JULIA LYNN HOLTZ, PlalntllT : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. , , : NO, 911. Lj 'i ~q CML TERM , JEFFREY ALLEN HOLTZ. Defendant : : DIVORCE/CUSTODY ORDER OF COURT AND NOW. thil ~ ~ or Al~',....J. f . 19911. upon conalderaUon or the attlll:hed Complaint, It ill hereby directed that the parties and their respective COUJl8e1 appear before ~ G~ \(oy ~, the conciliator, at ~~h 5\~ (,.~to, {a., 1~.Joon the.12!l1l:1 day of (-:-r 19911, at Io.~ for II Pre-HearIni Custody Conference, At IUCb Conference, an effort will be made to resolve the luuea In dispute; or If thla cannot be IICCOIIIp1Iahed, to detlne and nurow the luuea to be heard by the Court, and to enter Into a temporary order, All chUdren . lip Ove or older ~ a1ao be present at the Conference, Failure to IIppear at the Conference ~ provide p-ounda for entry of a temporary or permanent order, II II II !i i , ! FOR THE COURT, B" ~u,t,d~~t;",. Custody ConcIlIator ~ The Court of Common PI... or Cumberland County ill required by law to comply with the Americana with DlubWUea Act of 1990, For lnfortllllUon about IICCeIIIlble fadUUea and _ble lIllCOmmodaUona available to d1ubled Indlvldua1a havlni bualneu berore the Court, pl_ contact our ol1lce, All arranpmentl must be I\lIIde at I...t 72 houn prior to any hearlna or bllllneu before the Court, ., ! i You must IIttend the echeduled conference or hearlntr, Ii YOU SHOULD TAKE THI8 PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE 8ET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Office of the Court Administrator Cumberland County CourthoUle Fourth Floor Carlisle, PA 17019 (717) 240.0200 . , ",~'?f cU:~. M;w.A/ .z 'i7!ti:~~ (~.~JlUZa VJ1'a,..;I o-J" .,." i.i:J'r- ~'~f'~ 71~ ~)'~ ~~""11" t-at'95 ~ ~ 4iI #,.J/1J~ #- . ~ ':.1. .", Auc lB 2 II' rII '95 \ , f ,. I, , , 'OffiCE or ll'c I ;'MilON'JURY IJUflilll'l I,NO UllHY l'U/lISnV,IIlI. ~ ". JULIA LYNN HOLTZ, Pla1ntllT : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENN8YLVANIA v, . , : NO,95. CIVIL TERM JEFFREY ALLEN HOLTZ, Defendant : DIVORCE/CU8TODY NOTICE TO DEFEND AND CLAIM RIGHTS You have been IUed In Cowt, If you wiIh to defend eaalnatthe clalma let forth In the foUowinl JlIII", you mUlt take prompt action. You II/'tl W\II'lled that If you fall to do 10, the cue will I'fOCHd without you and a decree In divorce or lUUlulment may be entered eaalnat you for an,y other claim or reUef requeated In th_ papera by the Pla1ntllT, You may 10Ie money or property or other rl8hla Important to you, Includina cuatody or vllltatlon of your chDdren, When the around for the divorce IIlndipltlet or irretrievable breakdown of the 1lIIIl'riap, you may requeat IIl8I'I'iap coWllellna, A Jilt of IIl8I'I'iap coWllelon II available In the OffIce of the Prothonotary at the F1nt Floor, Cumberland County CourthOUle, South Hanover 8treet, Carllale, Pennaylvanla 17018, IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DM810N OF MARITAL PROPERTY, LAWYER'8 FEES, OR EXPEN8E8 BEFORE A DIVORCE 18 GRANTED, YOU MAY LOBE THE RIGHT TO CLAIM ANY OF THEM, YOU 8HOULD TAKE THI8 PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE 8ET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, Court Admlniltrator Cumberland County CourthoUle Fowth Floor earlJlle, Pelll1l)'1vanIa 17018 (717) 240.6200 JULIA LYNN HOLTZ, PlalntllT : IN TIlE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v, : NO,9/1. CIVIL TERM JEFFREY ALLEN HOLTZ, Defendant , . : DlVORCE/CUBTODY COMPLAINT AND NOW, comes Julla Lynn HOltl, Plalntur, by and throUjlh her attorney, Robert p, KlIne, &quire, and reepectl\illy statetl II foUows: 1, Plaintiff Ie Julla Lynn Haiti, an adult individual, currently I't!lIldlna at 202 Birch Lane, Carllele, Cwnberland County, Pennsylvania. 2, Defendant Ie Jef'lioey Allen Haiti, an adult individual, currently ree1dlna at 202 Birch Lane, Carl1ele, Cwnberland County, Pennsylvania, COUNT I . DIVORCE 8, Paraaraphl1.2 are Incorporated herein by reference II If eet forth In their l\aU tnt, 4, Plaintiff and Defendant are bonallde retlldents of the Commonwealth of Pennsylvania and have been 10 for at ItllIIt sill monthl bnmedlately previous to the I11lni of this Complaint, /I, Plaintiff and Defendant were married on June 21, 1986 In New Klnptown, Cumberland County, Pennsylvania. 6. There have been no prior actions for divorce or annulment between the parties. 7. The Defendant Ie not a member of the Armed Forces of the United Btates of America, or IlIlIllIetI, 8, The PlalntllT hall been advised of the ava/labUlty of COWlleUng and the rJaht to request that I the Court require the parties to participate In couneeUng. Knowing thie, the PlalntllT does not desire that i I I I 'I I i the Court require the parties to participate In counseling. 9, Plaintiff and Defendant are citizens of the United Blate. of America, 10, The parties nwrlage le Irretrievably broken, II II 11. Plalntlffdellrel a divorce baled upon a beUefthat Defendant will. af\er 90 daya from the date of the l11Ina of thla Complaint, cOl\lllnt to thla divorce, WHEREFORE, Plaintiff requelt. your Honorable Court to enter a decree In divorce, COUNT II . EQUITABLE DISTRIBUTION 12, PlI/'IIIlI'Ilpha 1.11 are Incorporated herein by reference till( eet forth In their fWI teat. 19, Plaintiff and Defendant are Joint ownera ofvarloUlltell\l of penonal property, f'urnlture, and a1ao furnlahlnp acquired durlna their marrIaae which are IUbject to equitable distribution, 14, Plaintiff and Defendant have Incurred debta and obUgaUolII durlna their marrIap wlUch are IUbject to equitable dIItributlon, WHEREFORE, Plaintiff requeltl your Honorable Court to enter a decree equitably dlvldIni the plU'tlee' property and equitably apportlonlna the debt. Incurred by the partiN, II I COUNT III . CUSTODY PartIlP'l'Pha 1.14 are Incorporated herein by reference till( eet forth In their fWI teat, Plaintiff seeke CUltod,y of her children. Jordan Anthon,y Holtl, bom June 22, 1987, and lIS, 16, JUltln Daniel Holtl, bom September 7, 1990, currently reeldlng at 202 Birch Lane, Carllale, Cumberland County, Penneylvanla. 17, The children are preeently In the cuatod,y of Plaintiff and Defendant, 18. Over the laat flve yearl, the children have rellded continuously at 202 Birch Lane, Carllale, Cumberland County, Penneylvanla, with both the Plaintiff and Defendant, 19, The natural mother of the children ia Julia Lynn HOItI, currently relldlna et the above- ltated addre8ll, 20, The natural fllther of the children ia Jeffrey Allen Holtl, currently relldlna at the above- etated addrel.. 21, The relatlonehlp of the Plaintiff to the children ia that of natural mother, 22, The relatlonehlp of tho Defendant to the children Ie that of natural father, 23, The PlalntUT hu not partlclJlllted III a party or In any other capacity, and other Utlptlon concel1linl the cUltody or the cblJd In thla or any other court, 24, PlalntUT baa no information or a cuatody proceedlna concernlna the chUdren pendlna In a court or thia Commonwealth, 211, The best Intereata and permanent welfare or the chUdren will be served by III'IIIItlna the reUer requested becauae the PlalntilT Ia the primary caregiver with reapect to the chUdren, 26. Each parent whOle parenlal riahta to the chUdren have not been terminated have been named u parties to thia IICtl0n, No other peraolll are known to have or claim to have any riahta to cuatod,y or vlaItatlon of the chUdren other than the parties to thla IICtlon, WHEREFORE, PlalntilTrequeatlyour Honorable Court to grant her primary, phyalcal cuatody of her chUdren, Jordan Anthon,y Holte and Justin DanIel Holta, aubject to reuonable riahta ofvlaltatlon and partial cuatody ror the nerendant, Jeffrey AUen HoIta. Reapectl\illy submitted, LAW OFFICES OF RON TURO 91 ~3/qS' Date ~ rp I~O' Robert p, KIlne, Esquire 32 South Bed/'ord Street Carllale, PA 17013 (717) 2411,9688 Attorney ror PlalntUT Q . . VERlFICA110N I verIfY that the ltatemenla made In the rOfelOlng Complaint II/'tl true and correct, I underatand that ralae ltatemenla herein made are IUbject to the penalties or 18 Pa.C.B,A, 14904 relating to UOIworn ralllflcatlon to authorities, ~I (}'d' 95 Date ~'1;$ if j)~ LA E ~ ~... ....... ..'" ''''Jc;~:--..J~ '2zc;~i:o \l.,OU"1 h.%':n:'" _ O..-.z.-~ . ,.....t".4 I') I.: JI" h,t""it-lo7. l;Jlu'.r. !. ..,-lllhJ .:;10.- ~~'~ 0'" ~ J1 g fi { ~ "R. ~ Ii. 13" J 1- o~ OOf) f..) In a \() 0.') If) V) . ci \fl 10 I'll) If:> -- () - ..- -.Jt'" (tI 'I.> 00 r- ns 7" 0- r- ~ " 11 ~ c;(. u - ,1'. . , JULIA LYNN HOLTZ, PIalnt1lT : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v, , , : NO, 95..41lO CML TERM JEFFREY ALLEN HOLTZ, Defendant . . : DIVORCE/CUSTODY AFFIDAVIT OF SERVICE I HEREBY CERTIFY THAT llerved a certlf1ed copy of the Complaint ffied In the above captioned cue upon Jel1'rey Allen Holll, by certified mal1. restricted deUvery, retum receipt requetted 011 Auauat 28, 1995 addreued to: Jel1'rey Allen Holll :10:1 Birth Lane Carlla1e, PA 17018 IIId JeI1'rey A1Ien Holtl dld thereafter receive lime .. evidenced by the attached Poet 0I'IIce receipt card elated September 2, 1995, I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT OF SERVICE ARE TRUE AND CORRECr TO THE BEBT OF MY KNOWLEDGE, INFORMATION AND BELIEF, I UNDERSTAND THAT FALSE STATEMENTS HEREIN MADE ARE sUWECI'TO THE PENALTIES OF 18 PAO,S, SEGI'lON 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHOIUTlEB, LAW OFFICES OF RON TURO Date ",.. q I(J!/q.~ ~~~~Vp-=-- bert p, KlIne, Esquire 82 South Bedford Street Car\lale, PA 17018 (717) 245.9688 Attorney for PlalntllT Z 010'1 1173 Ion 2 Receipt for , Certified Moll No Inlu,anco CO~1I'8UO Plllvldod ~u:".,,\ 00 not UIO for lntofllSllonal Mall ISou Revollo) rl"I~,..,1 'l-f .55 .10 !,>,"'I...,!loInl"'II' flt"'~.l,d 11.',...._ If''' I .. I I J t f\"UlI\ 11"'1:1 !lltO...."'1 luWt,n"" t/tlll [Wh_l'tftl fl.hll" Il'Cf"I" ~h~",'I'q 10 Vv""'I\ 0.11 ..n4 'uf;hUt'f'" Ao,".'" HHA' rDI"i}~ . , I.ot\ rUilll\al. IIf U~hl bi'~p'\q5 \R . !Ii 10 en ~'1. '" ,. -, - .". ..1 Ull . C::~t'::'; u. ~. 10 ~' . \,1 .... r- It. <on . JULIA l VNN HOLTZ. Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSVLVANIA : NO, 95-4489 CIVil TERM : CIVil ACTION - LAW : IN DIVORCE V, JEFFREV ALAN HOLTZ, Defendant AFFIDAVIT OF CONSENT 1, An Amended Complaint In Divorce under Section 3301(c) of the Divorce Code was filed on October 14,1997, 2, The marriage of Plaintiff and Defendant Is Irretrievably broken and ninety days hive elapsed from the date of filing and service of the Complaint. 3, I cansentto the entry of a final decree in divorce after service of notice of Intention to request entry of the decree. 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, Section 4904 relating to unsworn falsification to authorities. Date: ~Ol../DD ~ In ~ ... e ~ 1-- (~ :5~ 11'(;,' I.J',;_ ~) '.J:.e -, -- " (J.. )~! ,",1-' I' In d'') 1'0' I 1% " I .,. \4- " " ")'f! .-, 'DC I. e- l .. .,. 0 :j t.> ,;) CJ U a:a__ ~N-" ~i5il hm ~11~t I!~! . . ' .. ~ JULIA LYNN HOLTZ. Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v, , : NO. 95-4489 CIVIL TERM : CIVIL ACTION. LAW : IN DIVORCE JEFFREY ALAN HOLTZ. Defendant WAlV::' ~~ ~~~CE OF INTENTION TO REQUEST T _ DIVORCE DECREE UNDER SECTION 3301(~' OF THE DIVORCE CODE 1, 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 eKpenseslf 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 flied with the Prothonotary, I verify that the statements made herein are true end correct. I understand that false statements herein are made subJect to the penalties of 18 Pa,C.S, Section 4904, relating to unsworn falsification to authorities. Date: ~/;l/D() r- III ~; .~ C t'.- ,.-, t;'; 'l~)~r. Ill';! t.)t.'l 0,' :f: \ :- :.t' Ii:'; n.. ( '\ ~:j -)1 . 11 t.' ' .. In ": ;1) (" I 1.-. .i.: 'r" ~.. " - 'dill " ::.J '~Jo... j -, :3 I. CJ '-' C, 0 ~ u o:a__ ~liU Mn ~Wlil ill! . . JUI..IA LYNN HOW'Z, Plllilltiff : IN TI-m COUnT OF COMMON PLEAS : CUl\tBEHLAND COUNTY, PA v, : CIVIL ACTION. LAW : NO, 1l1i.,WI!l CIVil, '1'lmM JEFFm~Y ALAN HOLTZ Defelldllllt : DlVOHCl~ AFFIDAVIT OF CONSENT 1. A COlllplllillt in Divol'co lindeI' the DiVIJI'ce COlIc Willi filed on August 25, lllIJIi 011 the gl'oundll thllt tho 111 lII'1'ill 110 oCt he plIl'tiell ill il'l'ol1'ievllbly bl'Okell, 2, 1'ho Illlll'l'illlle of Plllilltiff 1I1l11 Defendllnt illll'l'etl'ievllbly bl'Oken IIl1d nillety dllYs hllve elllPlled fl'om the dllte of filing the Complllint, 3, 1 consent to the enll'y of n finlll decl'ee of diVOI'ce, 4, I undol'lltllnd thllt II1IIIY loso I'ights concOI'nillg ulimony, division of PI'olJorty, IlIwyol"S fees 01' expenllos iff do 1I0t clllim them bofOl'e II divOI'co is gl'nntod, In IIddition, Illpecificlllly IIcknowledlle thllt II fullllnd finlllsettlement of nil PI'OIJOI'ty IInd othOl' I'ights of tho 11Iu'tios hils been entered betwoen the Pluintiff nnd Dofendllnt by II Mlll'itlll SotUol1lent Agl'eol1lont. I vol'ify thllt tho Iltlltelllontll Illudo in tho Affidllvit 111'0 true IInd COI'l'ect, I undol'lltllnd thut flllso stutel1l0ntll hOI'oin 111'0 I1Il1de Illlhjoct to tho penultiell of 18 PII.C,S, ~ 'lIlll<1I'elllting to IInllWOI'n lillllilicllt!ln to IIl1thol'itios, Dllto: 4j~1J . , , . ....... JULIA LYNN HOVl'Z. Plllintiff : IN THE COUHT Ol~ COMMON PLEAS : CllMBI~IUJANJ} COUNTY, PA : GIVILAC'I'ION .IAW : NO, 1I/j.4'IHlI CIVil, TlmM v, JEFI~nEY ALAN HOLTZ Defendllnt : D1VOHCE WAIVER OF NOTICE OF IN1'ENTION "0 REQUEST ENTRY OF A DIVORCE DECREE }, I consent to the entry of a finnl decl'ee of divol'ce without notice, 2, I understnnd that I Illny lose rights conceming alimony, division of property, lawyel"s fees 01' expenses if I do not claim them before a divorce is granted. 3, I understand that I will not be divol'ced until a divorce decree is entered by the COU1't and that a copy of the decree will be sent to me immediately aftel' it is filed with the pl'othonotUl'y, I vel'ify that the statements made in this affidavit al'e true and conect. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S, fi4904 l'elating to unswom falsification to authOl'ities. Date: ~~ 1ltiE.~ li N ~ M fu b M 3~ ~.. ". E O~ I.~,i D.- C'! I., 50 :~~ ~E: M -\11 >- tfi~ r!: ~ ~ ~ 0 0 .JACOIISEN & MILKES 52 Enstlllllh Street Cnrllsle.I'A 171113.311K5 SUlIlllel W, Mllkes Andreu C, Jncnllscn Tel 717-249.6427 Fux 717-249.K427 Junu 7, :WUU E, Hobol't Elickol', II, Ellquil'u Offico of tho Divul'co l\tnlllol' {) NOl'th Hnnuvcl' Sll'ool Cnl'liRlo, PA 17U13 HE: Holtz v, Hultz No, llli.44tlll Civil 1'01'111 DOIll' MI', Elickol': Thill will confil'l11 OUl' convol'llntioll of (hill 1110l'ninlll'olluI'dinll tho nbovo cnso, I dillcusflod thill mnltol' with Chnl'liu Hoclol', nnd, with his nlll'oomont. IllIn sonding you hOl'owith U cOl'l'uctod fil'llt IlllllO of tho MUl'itnl Sottlol11ont Alll'ool11ont of tho JlIII'tioll which l'of1oclll tho COl'I'oct dlllu of thu IIgl'oumont. Wu IIllk thnt it bo llublltitUtUlI fO!' tho fil'st Jluge Jll'uviuullly f1ubmittod, Ploullo lutl110 know if thel'u ill IIny 11I'ohlell1 with Ihl8 I11nnnul'uf cOI'l'oction, Thnnk yuu, Sincul'uly. JACOBSEN & MILlmS ! ') C\ (. ..-'U~)J /~-------- BY: Alldl'UIlt/f;;';\ ACJ/mu Cc: Chnl'luH RuotOl', EHq, (curl')1I11117 Jo:llcllCr .1101 JULIA LYNN HOLTZ, plaintiff : IN TilE COURT OF COMMON PLEAS OF : CUMBERI,AND COUNTY, PENNSYLVANIA CIVIl, I\CTION - r,AW VB. JEFFREY ALAN HOLTZ, Defendant NO. 95 - 4489 CIVlIo 19 IN !JIVOIlCE STATUS SHEET DATE: - ACTIV1'J'lESI 2 19/99 p~etrial statements due 3/19/99. r./ !'. tJ~h;l;,()<i 110Y10;f{:'lir~,~..?~'~' .~'f~.A\I(.ua-.:Cfl;1t ',/1'0 ')').~ PREHEARING HELD, HEARING SET FOR MARCH 6, 2000, :...9- · , .: f:~~~ ~~.R ~~;~~ .~~~~~ iW1J ~~.~_....._~'t..~ ~7Jr1.~' ...-"..--- -. ,. . l c.- ~~,bD ~ /-, (;1utJu . . _~_~__.. _.._._+0_ _.____ ----.--~ -------------- -----.--..-------.. ....._--_._-_..,._-....~_.-- -..----.----------.. ----_..~ ...--....- ....- ____0_-.----..--. . .- . ....-.__...... --'--"--~-~ V\hrt,. '~~ ~, 1 ~~ 't)}c.\\- I.A)'I(, (~~\ ~[ 'rA, I (I D-l'?-- )~ ~(?;\~ ~. 'tD?- t> ~~H !;fvYz. CJW-\ i'J-\G. lj, \'7Q..\,), '. OPPICI OF DIVORCI MAlUR CUMBERLAND COUNTY COURT OF COMMON PLEAS 9 North Hanover Street Carlisle, PA 17013 (717) 240,6535 I. ......" IHok.,. II Divorce 1.111111 "801 .I. C.tv., 0I11e1 MMllllrlAlportlr W.., Ihore 697.0371 Ext. 6535 February 19, 1999 Charles Rector, Esq. 1104 Femwood Avenue, Ste, 203 Camp HlII, PA 1701\.6912 Andrea C, Jacobsen Allomey at Law Jacobsen & Milkes 52 East High Street Carlisle, PA 17013 RE: Julia Lynn Holtz v, JelTrey Alan Holtz No, 95-4489 Civil In Divorce Dear Mr. Rector and Ms, Jacobsen: By Order of Court of President Judge George E, Hoffer dated January 29, 1999, the full time Muter has been appointed in the above referenced divorce proceedings, The original motion for appointment of master has been misplaced by either myself or by the Prothonotary's office, COllsequently, I asked that counsel please provide me a copy of the motion that was filed, Tho docket shows that Judge HolTer appointed me on January 29, 1999, A divorce complaint was filed on August 23, 1995 raising grounds for divorce of Irretrievable breakdown oftho marriage. The complaint also raised the economic claim of equitable distribution, No other economic claims have been raised In the action, . . . Mr. Reclor and Ms, Jacobsen, Allomeys al Law 19 February 1999 PalZe 2 I am 80lnlllo proceed on Ihc basis Ihalllrounds for divorce are not an Issue and that the parties will eithcr sign arfidavits of conscnt or have been separated for a period in excess of two years, Based onthot assumption, I am dlrectinll each counsclto file a pre- trial statemenlln accordance with P.R,C,P I 920.33(b), on or before Friday, March 19. 1999, Upon receipt oflhe pre-trial statemcnts, I will hnmcdlately schcdule a pre-hearlnll conference with counsel to discuss (he issues, allll if necessary schedule a hearing. Very tnlly yours, E, Robert Elicker, II Divorce Master N01E Snnctlons for failure to liIe the pre-trial statements are set forth In subdivision (c) III1d (d) of Rule 1920,33. THE ORIGINAL PRE-TRIAL STATEMENT SHOULD BE FILED IN THE MASTER'S OFFICE AND A COpy SENT DlRECTL Y TO OPPOSING COUNSEL. JULIA LYNN HOLTZ. Plaintiff I IN THE COURT OF COMMON PLEAS OF I CUMBERLAND COUNTY, PENNSYLVANIA I I CIVIL ACTION - LAW I I NO. 95 - 4489 CIVIL I I IN DIVORCE VS. JEFFREY ALAN HOLTZ, Defendant NOTICE OF PRE-HEARING CONFERENCE TOI Charles Rector . counsel for plaintiff , counsel for Defendant Andrea C. Jacobsen A pre-hearing conference has been scheduled at the Office of the Divorce Master, 9 North Hanover street, Carlisle, pennsylvania, on the 23rd day of August, 1999, at 9130 a.m., at which time we will review the pre-trial statements previously filed by counsel, define issues, identify witnesses, explore the possibility of settlement and, if necessary, schedule a hearing. Very truly yours. Date of Noticel 4/13/99 E. Robert Elicker. II Divorce Master Charles Rector, Attorney for plaintiff, has not filed a pre-trial statement as of the date of this notice. Andrea C. Jacobsen, Attorney for Dsfendant, filed a pre-trial statement on Karch 19, 1999. JULIA LYNN HOLTZ, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 95 - 4489 VS. JEFFREY ALAN 1I0LTZ, Defendant CIVIL ACTION - LAW IN DIVORCE ORDER AND NOTICE SETTING IIEARING '1'01 Julia Lynn Holtz , plaintiff Charles Rector , Counsel for Plaintiff Jeffrey Alan 1I0ltz , Defendant Andrea C. Jacobsen , Counsel for Defendant You are directed to appear for a hearing to take testimony on the outstanding issues in the above captioned divorce proceedings at the Offics of the Divorce Master, 9 North Hanover Btreet, Carlip1n psnnsylvania on the 6th day of March , ~ at 9100 a.m., at which place and time you will be given the opportunity to present witnesses and exhibits in support of your case. E. 1I0ff r, President Judge Date of Order and Noticel 8/23/99 BYI Divorce Master IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE BET FORTII BELOW TO FIND OUT WIIERE YOU CAN GET LEGAL HELP. CUMOEIlI.AND COUNTY IlAIl MH10CIATION 2 J.IIlI-:JlTV AVENUE CAIlI.IHl,E, I'A 1701,1 'l'EI.EI'1I0Nl; ('/1'/) 24')' J 1 (Il. JULIA LYNN HOLTZ, plaintiff IN THE COUIlT m' COMMON PLEAS 01' CUMBERLAND COUNTY, PENNSYLVANIA NO, 95 - 4489 vs. CIVIL ACTION - I.AW JEFFREY AI.AN 1I01,TZ I Defendant IN DIVORCB OIlDEIl AND NO'i'ICB 5E'I"i'ING \IEAIlING 'fa: Julia Lynn Holtz Charles Rector . plaintiff , Counsel for Plaintiff Jeffrey Alan \Ioltz Andrea C. Jacobsen , Defendant , Counsel for Defendant You are directed to appear for a hearing to take testimony on the outstanding issues in the above captioned divorce proceedings at the office of the Divorce Mastar, 9 North Hanover Street. carlisiI.', pennsy IVllnia on the 29.th______. tlilY ,'f __-AugllJl.t.._--. 2000, nt .---9..lillL.. n.I11" ilt which pluce and t~ne you will be givcn the opportunity to present wltnopses nnd uxhibits in Bupport of your case. UY111C(trt: 'd~t( -\ I cjH~II' E. Ilull"'-, I'loBldellt .lllctgo Ihltu of order nnd !~ot I ell I _~L2.~LQQ---. I\y I III voi;co'MiltJ till: II' yOU UO NOT IlAVI'; A LAI'IYEH UIl ,.'.\NIWT AFFOHU ONE, (ill TO Oil TELEPHONE TIlE OFFICI'; BET FOIn'H IIEI,(>I'I TO FiND oUT V1IIEIlE 'lOU CAI~ lil;T LEGM. lIELP. ('lJt~III,HLMiI' ,','\lIITl' IIAIl Mi:;'"'I,\IIIIN " 1 1\llllTY AVINIIL ('II I'I I' ! I, 1'1\ 17111 \ 1'1-'111'11"111- ,/1 i, ..4'1 '\1,1, Law Omces of Charles Rector, Esquire, P.c. 1104 Femwood Avenue. Ste, 203 Camp 11111, PA 17011-6912 .''''011 . CR.clorl!"lq',ool,com Tammy S, Faust Paralegal (717) 761-8101 Fax (717) 761-2161 April 14, 2000 E, Robert Elicker, II. Esquire Office of Divorce Master 9 North Hanover Street Carlisle, PA 17013 Re: Holtz v. Holtz No. 85-44.8 Civil T.rm Dear Attorney Elicker: We have been unable to sellle the I:IaUI maller, Therefore, I respectfully requeslthatthe case be re-lIsted for a Master's Hearing, Very truly yo.urs, ~ ,,' (~..tL ) (uA; Charles Rector' CRltsf cc: Julia Holtz Andrea Jacobsen, Esquire JULIA LYNN HOLTZ, Plaintiff : IN TIlE COURT OF COMMON PLEAS : CUMIlERLAND COUNTY, I'ENNSYLV ANIA : NO, 95.4489 CIVIL TERM v, JEFFREY ALAN HOLTZ. Defendant : DIVORCE/CUSTODY J'lOTlCE TO IlEFEND 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 wanled that If you fall to do so, the case will proceed without you RI1d a decree in divorce or al1llUlmentmay 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, When the growld for the divorce is indignities or Irretrievable breakdown of the marriage, you may request marriage counseling, A list of marriage cOWlselors Is avallahle In the Office of the Prothonotary at the First Floor, CurnberlRl1d Cowlty Courthouse, South Hanover Street. Carlisle. Pennsylvania 17013, IF yOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL PROPERTY, LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. 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. Court Administrator Cumberland County Courthouse Fourth Huor Carllsle.I'ennsylvnnia 17013 (717) 240.6200 JULIA LYNN HOLTZ, Plaintiff : IN Tim COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO, 95-4489 CIVIL TERM v. JEFFREY ALAN HOLTZ, Defendant : DIVORCE/CUSTODY AMENDED COMPLAINT IN DIVORCE I. Plaintiff is JULIA LYNN HOLTZ, an adult individual, currently residing at 199 Birch Lane, Carlisle, Cumberland COWlty, I'ennsylvania 17013, 2, Defendant Is JEFFREY ALAN HOLTZ, an adult individual, currently residing at 202 Uirch Lane, Carlisle, Cumberland COWlty, Pennsylvania, COUNT I . DIVORCE 3. Paragraphs 1-2 are incorporatcd hcrein by reference as ifsct forth inthcir fullteKt, 4, Plaintiff and Defcndant are bonalldc residents of the commonwealth of Pennsylvania and have been so for at least siK months hnmcdlatcly previous to thc llling oflhls complaint. 5. I'laintll1' and Defcndant werc married on JWIC 21, 1986 In Ncw Kingstown, Cumberland COWlty, Pennsylvllnla, 6, '\llcre have been no prior actions for divorce or annulmcnt belwccnthe pllrtlcs. 7. TIlc Dcfendantls not IImcmber ofthc Anncd Forces of the United Stlltcs of Amcrlca, or Its Allies. 8, The Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in COWlsellng, Knowing this, the Plaintiff does not desire that the Court require the parties to participate In COUllseling, 9, Plaintiff and Defendant are citizens of the United States of America, 10, The parties have lived separate and apart since October 26, 1995 and continue to live separate and apart as ofthe date of this Complaint, II. The parties' marriage Is lnetrlevably broken, 12, Plaintiff desires a divorce based upon the beliefthat Defendant will, after ninety days from the date ofthe filing of this Complaint, consent to this divorce, WHEREFORE, Plaintiff requests your Honorable Court to enter a decree In divorce, gnJNT II. EQVlIAlIJ-E D1STRWlTION 13. Paragraphs I through 12 are IncOlporated herein by reference as If set forth in their full text, 14, Plaintiff and Defendant are joint owners of a mobile home presently located at 202 Birch Lane, Carlisle, Pennsylvania, and varloualtems of personal property, furniture, and household l\amlshlngs acquired during their manlage which are Bubject to equitable distribution, 15, Plaintiff and Defendant have Incurred debts and obligations during their marriage which are subject to equitable distribution, WIIEREFORE, l'lalntlff requests your Uonorable Court to enter a decree equitably dividing the parties' property and equitably apportioning the debts incurred by the parties, f COUNT III . CUSTODY 16, Paragraphs 1 through 15 are Incorpomted herein by reference as If set folth In their full text, 17. Custody In this mailer Is presently controlled by a series of Orders by the Hon, Edgar D, Dayley, the 1II0st recent of which is dated August 25, 1997. In filing this Amended Complaint pertaining to the divorce action, Plaintiff Is presently making no further claims for modification of the present custody arrangement at this time, Respectfully Submitted, )'/ ()e-r "91 Date r J ~}~Q-1r RODERT PETER KLINE, ESQUIRE 331 Drldge Street, Suite 350 Post Office Dox 461 New Cwnberland, PA 17070-0461 (717) 770-2540 Allomey for Plaintiff ,'f::~.f,-, ~'> ~ I verilY that the statements made in the foregoing Amended Complaint In Divorce arc true and correct. I wllterstand that falsc statements herein made arc subJect to the penalties of Pa,C.S, Section 4904 relating to W18wom falsification to authorities, /0 (')(1fQ 7- Date ~ 1,h~of5 JULIA LYNN H Z I hereby certifY that I served a tme and correct copy of the Amended Complaint In Divorce, upon Defendant, by depositing same in the United States Mall. first class, postage pre-paid on the J'I-nJ day of~, 1997, trom New Cumberland. Pennsylvania, addressed as follows: gl\TlFICA TE OF St:RVICE Andrea C. Jacobsen, Esquire Jacobsen &. Mllkes 52 E, High Street Carlisle, PA 17013 Attorney for Defendant r~ ' ROBERT PE~~QUlh 331 Bridge Street, Suite 350 Post Office BOll 461 New Cwnberland, P A 17070-0461 (717) 770-2540 Attorney for Plaintiff JULIA I.YNN HOLTZ, Plaintiff, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY. PENNSYLVANIA : NO. 95.4489 CIVIL TERM v, JEFFREY AI.AN HOLTZ, Defendant : CIVil. ACTION - DIVORCE/CUSTODY NOTICE TO TflE PEFENPANT If you wilh to deny any of the statements set forth in this Affidavit, you must file a C'nuoleraffidavit within twenty (20) davlafter this Affidavit has been served on you or the statements will be admitted, PLAINTIFF'S AFFIPA VIT l!MmJt SECTION 3~lIm Of TUE.PIVORCE COPE I. The parties to thil acllon separated on October 26, 1995 and have continued to live separate and apart for a period ofatleast two yean, 2. The marrilllo is lnctrlovably broken, 3, I Wlderstand that I may 10le rlshts concerning alimony, division of marital property, lawyer's fees or expenses if I do not claim them before a divorce il granted, I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE ANn C'ORRFCT, IlJNDERSTANDTHAT FALSE STATEMENTS HEREIN MAnE ARE SUBJECT TO THE PENALTIES GF PA, C,S, SECTlGN 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES, ~.J) JULIA LYNN H~-: _ J F< ';JO..o9.a- Ir JULIA L VNN HOLTZ. Plaintiff, : IN nlE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO, 95.4489 CIVIL TERM v, JEFFREY ALAN 1I0LTZ. Defendallt : CIVIL ACTION. DIVORCE/CUSTODY DEFENDANT'S COUNTERAFFIDA VIT liJllDER SECTION 330UPl OF THE PIVORCE COPE \. Check either (a) or (b) (a) I do not oppose entry of a divorce decree, (b) I oppose the entry of a divorce decree because (Check (I). (i1) or both): (I) The parties to this action have not lived separate and apart for a period of at least two years, (I\) The marriage ISllot Im:trlevably broken, 2, Cheek either (a) or (b): (a) I do 1I0t wish to make any claims for economic relief, I Wlderstand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses If! do not claim them before a divorce is granted, __(b) I wish to claim economic relief which may include alhnony, division of property, lawyer's fees or expenses or other Important rights, VERIFICATION I verify that the statements made In this Counteraffidavit lire tme IInd correct, I wlderstand that false statements herein are made subject to the penalties of 18 I)a. C,S. Section 4904 relating to unsworn falsltlcatlonto authorities, .---.---- ----.---...- Date JEFFREY ALAN IIOLTZ 1" ". r.: I . ,v:. , t,',\:; .. "-, - '. '" L: , , -L 1:1' t.. ,- y.;, {,1 frl~' ('oJ . .< u!., ' " .'1'" :...: ,,~ -- f~ ~ ....!-- .. P. C1 d U 1.--' ... ' JULIA LYNN HOLTZ, Plaintiff, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v, . : NO, 95-4489 CIVIL TERM : CIVIL ACTION - DIVORCE/CUSTODY JEFFREY ALAN HOLTZ, Defendant AFFIDAVIT OF SERVICE I, Robert Peter Kline, Esquire, hereby swear and affirm that on April 5, 19971 served a certified copy of the Petition for Modification of Custody Order filed In the above captioned case upon Jeffrey Alan Holtz, Defendant, by certified mall, retum receipt requested addressed to : Jeffrey Alan Holtz 202 Birch Lane Carlisle, PA 17013 The return receipt Is attached hereto and Incorporated herein as Exhibit "A", I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT OF SERVICE ARE TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE, INFORMATION AND BELIEF, I UNDERSTAND THAT FALSE STATEMENTS HEREIN MADE ARE SUBJECT TO THE PENALTIES OF 18 PA.C,S, SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES, , - cJ +-~ILl\ \.qcr:r Date ) . - '--' OBERT PETER KLINE, SQUIRE 331 Bridge Street, Suite 350 Post Office Box 461 New Cumberland, PA 17070.0461 (717) 770.2540 Attorney for Plaintiff t I \' !I :. II I' . to: : t J",Aly AlA,.) !lDl.rL.. " JAL "l1"~1<J i.1f All' : (J1ftC4."U r/l ,..,~~~ I ~~ I I I I &, , I 11 &, :. x j P8 Form . .~';",-..I"'_-' .~_"......,~. ._ ""'....... _llll'" _oI""lomloo..........."" IIiI _..,..., ._.... ........_ .....moIpiIc:I, Ofllll"'_'_ _ rd .e:::'.;..""""",, __"'... moIpiIc:I......1hI _1lIlIl'I>II. .TIII............... __.0......... _ __...... dill - 111Io wtIh 10 rectlvllhe foIowtng Nrvlce. (Iof III latraIHI: 1, [J AddmNI'. Addf... 2. [J ReItrIC\Id DelIvery ConIUI poIl'naIllr lor IN. y:( I. 'I IJIlIIIH lJ paid) I " EXHIBIT "A" J\ I: ): I: I' I; J: I , , ",. C) ~ Ir; '" ..., .. I' .. ~i " - (~J :) ~. ')- j:; 7: - f..t. Cl.. 'H~ ~-'. ,.... ..It , JfE Jt.. "(5 L fr: Iff! " .( ,. , r- :oj t m U . ' Law Omces 01 Charles Rector, Esquire, P.C. 1104 Fcmwood Avcnuc, SIc. 203 Camp Hill, PA 17011.6912 .,mail- CR"lorlloq@IOI,com Tammy S, FaUBI Paralcgal (717) 761.8101 Fax (717) 761.2161 Augu1119, 1999 E, Robert Elicker, II, Elqulre Omce of Divorce Maller 9 North Hanover Streel Carlllle, PA 17013 Re: Holtz v. Holtz No. .I-oUI. Civil TImI OUr Attorney Elicker: Enclosed plea.. find PlalnUfrs Pre. Trial SlIlemenlln lhe above-referenced maller, Very lruly yours, ("t (';'J. )5/ L~~.c\:tY' Charlel Rector CRlllf Enclolure co: Andrea Jacoblen, Elqulre plaintiff I : : : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. CIVIL 19 Defendant IN DIVORCE STIPULATION OF PARTIES AND COUNSEL A) plaintiff: Name, address, age, occupation Defendant: Name, address, age, oocupation B) When the method of servioe of the complaint has been by registered (certified) mail: The sianature on the return receint card is the siQnature of the Defendant. C) Date and place of marriage: 0) Plaintiff: Residenoes in the Commonwealth of Pennsylvania and length of time at eaoh residence Defendant: Residenoes in the commonwealth of Pennsylvania and length of time at eaoh residence E) Child or children I Name(s), age(s), residenoe of eaoh ohild and with whom child is residing. F) Grounds for divorce I We, parties and counsel in the above captioned divoroe proceedings have read the statements set forth above and agree that the information provided herein is true and correct, , and we etipulate that said faots oan be made part of the record as if speoifioallY testified to under oath at a hearing in the.. prooeedings. plaintiffl Datel counsel for Plaintiff I Defendant I Datel counsel for Defendantl ~ I IN THE COURT OF cOMMON PLEAS OF plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I VS. I NO. CIVIL 19 I I Dsfendant I IN DIVORCE STIPULATION OF PARTIES AND COUNSEL A) plaintiff I Name, address, age, occupation Defendantl Name, addrees, age, occupation B) When the method of service of the complaint has been by registered (certified) maill The siqnature on the return receiDt card is the siqnature of the Defendant. C) Date and place of marriage I . D) plaintiff I Residenoes in the commonwealth of Pennsylvania and length of time at eaoh residenoe Defendant I Residences in the commonwealth of pennsylvania and length of time at each residence E) Child or childrenl Name(s), age(s), residsnce of each child and with whom child is residing. F) Grounds for divorce I We, parties and counsel in the above captioned divorce proceedings have read the statements set forth above and agree that the information provided herein is true and correct, and we stipulate that said facts can be made part of the record as if specificallY testified to under oath at a hearing in the.e proceedings. plaintiff: Date: Counsel for Plaintiff: Defendant I Date: Counsel for Defendant: JULIA LYNN HOLTZ, Plaintiff, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO, 4489 CIVil 1995 v. JEFFREY ALAN HOLTZ. Defendant , : CIVil ACTION. LAW : CUSTODY AND NOW, comel Julia Lynn Holtz, Plaintiff, by and through her counlel, Robert Peter Kline, Elqulre, and relpectfully filel the following Pre-Hearing Memorandum with the Court In anticipation of the CUltody Hearing Icheduled for August 20, 1997: I. The parties are the parents of two children: Jordan Anthony Holtz, born June 22, 1987, and JUltln Daniel Holtz, born September 7, 1990, The parties separated In 1995 and, shortly after separation. a custody agreement wal reached at a conciliation conference which gave each parent primary cultody of their children on alternating weekl, At the time, based upon the Plaintiffs observatlonl and experlencel with the father's parenting ability, Ihe wal comfortable with thll arrangement. Since that time, however, Plaintiff has become Increallngly concemed regarding actlonl of the Defendant and the care of the children while they are In their father's cUltody, Thele concemslnclude Inattention to medical needl, an Increase In the frequency of the Defendant's drinking, drinking and driving with the children In the vehicle, the children being told to lie to their mother by their father, and conceml over the stability of Defendant's current glrifrlend, who hal a hlltory of mental health problems and brulhes with the law, Baled upon these concerns, It Is the position of Plaintiff that a change In the custody arrangement Is now Justified, II. The Issue before the Court Is whether or not the concerns to be raised by the Plaintiff, and summarized above, Justify changing the present custody arrangement. It Is the position of the Plaintiff that these concerns do, In fact, justify such a change and, therefore, she requests that she be granted primary physical custody of her children, with reasonable periods of visitation and/or partial custody to be granted to the Defendant. III, LI 1, Julia Lynn Holtz: The Plaintiff will testify as to her experiences In dealing with the Defendant and her children over the past two years, Her testimony will address directly her concerns raised above, as well as her direct contact with the Defendant, with his girlfriend, and as to statements made to her conceming Ihe Defendant by her children, 2. Stephanie Shade: Ms, Shade, the babysitter for the children when they are In both parents' care, will testify regarding her experiences with the children and both of their parents over the palt two years, including, but not limited to, Ihe behavior and appearance of the children while they are In the respective custody of each parent; statements made to her by the children over the past two years; statements made by each parent to her over the past two years; admissions by the father to his drinking; statements by the children that their father has told them to lie; and personal observations of the father that raise concems over his parenting ability and treatment of the children. 3, Viola M. Le.: Ms. Lee, a neighbor of both the father and the mother, will testify concerning her observations of the children and their respective parents over the past two years, 4, Jeffrey Alan Holtz, as on cross-examination: The Defendant will be requested to testify regarding his lack of attentiveness to the children's medical needs, his drinking, his statements to the children requesting that they lie, and other Issues of concern previously raised In this Memorandum, 5, Jodi Yohn, al on croll-examlnatlon: MI, Yohn, the Defendant'l current girlfriend, who lpend. Ilgnlficant time with the children while they are In their father'l cUltody, will be requelted to teltlfy al to her menta' health hOlpltallzatlon hlltOry, her hlltory In other cultody and protection from abule actlonl, and In her recent harallment and 1!lIklng chargel from February 1997. 6, Jordln Anthony Holtz Ind JUltln Dlnlel Holtz: Plalnllff relpectfully requeltl that the Court allow for a brief dllculllon, In Chambers, with each of the children to dllCUII their conceml about their flther'l drinking and lying, and to obtain a general feel for the chlldren'l thoughtl on thll matter, 6' ^~'"" I- IQ'i1- Oate Relpt'lctfully lubmltted, ~~ ?~'e ROBERT PETER KL NE, ESQUIRE 331 Bridge Street, Suite 350 POlt OffIce Box 481 New Cumberllnd, PA 1707Q..0461 (717) 770-2540 Attomey for Plaintiff I hereby certify that I served a true and correct copy of the Pre-Hearing Memorandum, upon Defendant, by depositing lame In the United States Mall, first ela.., postage pre-paid on the ~ day of ~~ t Cumberland, Pennsylvania, addressed as follows: , 1997, from New Andrea C, Jacobsen, Esquire Jacobsen & Mllkes 62 E, High Street Carll,le, PA 17013 Attorney for Defendant ~~ ROBERT PETER KLINE, ESQUIRE 331 Bridge Street, Suite 360 Post Office Box 481 New Cumberlsnd, PA 17070-0461 (717) 77Q.2540 Attorney for Plaintiff JULIA LYNN HOLTZ, PlaintitT : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PA v. : : CIVIL ACTION - LAW : NO, 95.4489 CIVIL TERM JEFFREY ALAN HOLTZ Defendant , , : DIVORCE/CUSTODY DEFENDANT'S PREBEARING CUSTODY MEMORANDUM Thil caBll il acheduled for a CUltOdy hearing before the Honorable Edgar B. Bayley, J., on Augult 20, 1997, at 8:45 a,m, The dilpute involvel CUltOdy of the two BOnl of the partie I, Jordan Anthony Holtz, born June 22, 1997, prellllntlyage 10, and JUltln Daniel Holtz, born September 7, 1990, who will be age 7 within the next month. Defendant mel thil memorandum in accordance with the Court Order of May 22, 1997, entered in thil matter. 1. Hiatol')' of CU8tody in tbla Cuel The parties, married June 21, 1986, are the parenti of two BOnl born to their marriage. Wife filed for divorce in Augult 1995 while the partlel ItUl resided together. Delpite attemptl at reconciUatlon and marriage counllllling, the partie I separated, At a CUltOdy conclllation conference in December 1995, the partlel agreed to the entry of a Ihared custody order that provided for a Ihared cUltOdy arrangement between the partie I, with the bOYI alternating between their parenti' home I, one week with one parent, the next week with the other parent, The parties live in the same trailer park, approximately three doorl away from each other, DeBplte Bome friction between the partleB, the bOYB have done weU under the present CUBtOdy arrangement, Father belleveB that, u between the partleB, he IB a more Btable Individual and IB better able to provide for the love, nurturing, and phYBlcal needB of the children, NonetheleBB, he alBO belleveB that the BtatuB quo Bhould be maintained for the pre Bent, He objectB to the cUBtody concerns raiBed by Mother u totally boguB, Btemming not from any factual bulB, but manufactured to a great part out of Mother'B wiBh for retaliation on account of Father's failure to accept Mother'B repeated propoBalB for the partleB' marital reconciliation, Father BOekB a continuation of the preBOnt Bhared cUBtody arrangement and IChedule primarily becauBe he belleveB that the diBruptlon to the bOYB that would be caulOd by a change would not be In hlB BOnB' beBt IntereBtB, In the alternative, If Mother tB not willing to continue the preBOnt Bhared arrangement, then Father BOekB primary phYBIca1 CUBtOdy of hlB BOnB, becaUBe he belleveB that the bOYB would be better oft'ln hiB primary cUBtody on account of hlB better ability to parent the bOYB, and hiB very cloBO relatlonBhlp with the bOYB. Moreover, hlB older BOn haa repeatedly Btated hiB preference that he live with Father, and Father belleveB that the cloBOneu of the bOYB to each other makeB It Important that the BlbllngB not be BOparated, I. Illuel before the Courtl Whether the cUBtody concernB of Mother have any factual bueB or are the productB of Mother'B wlBh to retaliate againBt Father for their marital diBcord, Whether there IB any JUBtlficatlon which warrantB a change In the bOYB' preBent living arrangementB. Whether, If primary cUBtody with one parent IB deemed preferable to the preBent Bhared cUBtody arrangement, Father Bhould be granted primary cUBtody of the children, 8. Iht of wltne... and lWDDIary of anticipated te.timOn)'1 Jeffrey Alan Holtz: Father will testifY regarding the parties' parenting of the boys over the IllBt two years, including activities, forms of discipline, sharing of responsibllltles by the parties, medical care to the boys, how the boys have been doing in IOhool, and llB to his belief llB to the custody arrangement that will best serve hi. son.' well-being. Father will respond to the accuBlltlons made against him by Mother and testifY llB to her repeated requests for reconclUation and his responses, PutDr Donald J, Seiple: Paetor Seiple, of St, Stephen's Lutheran Church, New Kingstown, PA, will testifY llB to his familiarity with the family, his observation. of the parents with their children, his opinion llB to the best Interests of the children, and hiB opinion of Father ae a person and ae a parent. He will testIfY ae to BtatementB made to him by Jordan Holtz regarding his preference to live with Father rather than with Mother. Jordan Anthon)' Holt. and Jutln Daniel Holtz: Defendant requests that the Court meet with the each of the children In Chambers to discuss the boys' feelinp about their present custody arrangement, their present experience in each parent'B home, and their preferences for the future custody arrangement, Respectfully submitted, G.r c ~,C -- BY: Andrea C,Jacobsen, Esq, JACOBSEN & MILKES 52 E, High Street Carlisle, PA 17013 (717) 249.6427 Attorney No, 20962 JULIA LYNN HOLTZ, Plaintiff : IN THE COURT OF COMMON PLEAS : OUMBERLAND COUNTY, PA v. . . : OIVIL ACTION. LAW : NO, 95.4489 CIVIL TERM JEFFREY ALAN HOLTZ Defendant , . : DIVORCE/CUSTODY PRAECIPE TO CORRECT CAPl'ION TO THE PROTHONOTARY: Pleue amend the caption In this matter to reDect the correct spelling of the Defendant's middle name u"ALAN," Indicated above, and amend the prior incorrect spelling of his name u"ALLEN." Respectl\illy submitted, ~~~~: JACOBSEN & MILKES 52 Eut HiSh Street Carlisle, PA 17013 (717) 249-6427 Attorney No. 20952 ~ - ""~ ~.." ~ . ,,';,. ,'O! :. ~., " ~ ~- ,.. (;) M .~) ~ '" J1 ~:.l_;' '.' ~ , JULIA l YNN HOLTZ, Plaintiff, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO, 95-4489 CIVil TERM : CIVil ACTION - DIVORCE/CUSTODY v. JEFFREY ALAN HOLTZ, Defendant ORDER OF COURT AND NOW, this ~ day of , 1997, upon consideration of the attached Petition for Modification of Custody Order, It Is hereby directed that the parties and their respective counsel appear before .2U-:;t'r i X. (;:'\Ilro'( , E.\;,qu\1(" ,theconclllator,at4tt"1Flcodut(\J\(("~J (~m1(nn+,(cu-~h[JJ~e _ onthe-1.S!'dayoU"-\O'j , 1997. at ~ : ~) A..M, for a Pre-Hearing 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, All children age five or older may also be present at the Conference, Failure to appear at the Conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, ,bq-. ClD,) ~ By: )1 \1 . Custody Conciliator The Court of Common Pleas of Cumberland County Is required by law to comply with the Americans with Disabilities Act of 1990. For Information about accessible facilities and reasonable accommodations available to disabled Individuals having business before the Court, please contact our office, All arrangements must be made at least 72 hours prior to any hearing or business before the Court, You must attend the scheduled conference or hearing, 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. Office of the Court Administrator Cumberland County Courthouse Fourth Floor Carlisle, PA 17013 (717) 240.6200 :\ .r':'r:-'F L ': ~.' " r " "',' I"l\~"l' 1'11~.'~ i)\l ",: ill: "..\.1 'j I,' t.. Hll)".' ell;,,,,- I' ,Iii' Ill+:; ,:,1 i'L/,\' ~ l\ J('c)(J. ~n t.JvI- .,~. mJ ;d ~ ,t:t;~ .IOK), 9) ;t~ 1If~ Z' ~. J ~ -7'/ t~t1 ~~ -- ,y' . J6i~ .;..a. JULIA LYNN HOLTZ, Plaintiff, v, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO, 95-4489 CIVIL TERM : CIVIL ACTION. DIVORCE/CUSTODY JEFFREY ALAN HOLTZ, Defendant Previous Custody Conciliator: Hubert X, Gilroy, Esquire Previous Judge Assigned: Edgar B, Bayley, J, mtIlQt-l FOR MODIFICATION OF CUSTODY 08QEB 1, Plaintiff Is JULIA LYNN HOLTZ, an adult Individual whose residence Is at 199 Birch Lane, Carlisle, Cumberland County, Pennsylvania, 2, Defendant Is JEFFREY ALAN HOLTZ, an adult Individual whose residence I. It 202 Birch Line, Carlisle, Cumberllnd County, Pennsylvania, 3, Plaintiff seeks prlmary physical custody of her children, Jordan Anthony Holtz, bom June 22, 1987, and Justin Daniel Holtz, bom September 7, 1990, currently residing at 202 Birch Lane, Carlisle, Cumberland County, Pennsylvania, 4, The children are presently subject to a shared physical custody arrangement between each of the parents pUrluant to a prlor order of this Court dated December 28, 1995, 5. The natural mother of the children Is Julia Lynn Holtz, Plaintiff, currently residing at the above-stated addre88, 6, The natural father of the children Is Jeffrey Alan Holtz, Defendant, currently residing at the above-stated addre88, 7, The relationship of the Plaintiff to the child Is that of natural mother, 8, The relationship of the Defendant to the child Is that of natural father, 9, Other than this present action, Plaintiff has not participated as a party or In any other capacity, In other litigation concerning the custody of the child In this or any other court. A copy of this Court's order of December 28, 1995 Is attached to this Petition. 10, Other than this present action, Plaintiff has no information of any other custody proceeding concerning the child pending in a court of this Commonwealth, 11 , The best Interests and permanent welfare of the children will be served by granting the relief requested because, since the entry of the Court's last order on December 28, 1995, Plaintiff has consistently demonstrated the ability to provide the children with a stable structure and nurturing home. During this period of time, Plaintiff has been primarily responsible for Insuring that the children's needs. Including medical needs, are met on a consistent basis, Defendant, on the other hand, has demonstrated a consistent Inability to provide for the best interests and permanent welfare of the children In that he: a) has consistently demonstrated either an Inability or a lack of concern for provision of medical care for the children; b) has consistently demonstrated an inability to provide any consistency or structure in the lives of the children while they are In his custody; c) has consistently demonstrated a lack of responsibility In regard to his own actions during periods of time when the children are in his custody; and d) has allowed the children to remain at times In the care of an Inappropriate adult caregiver with a history of mental heallh and legal problems. 12. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action, No other persons are known to have or claim to have any right to custody or visitation of the children other than the parties to this action, WHEREFORE, Plaintiff requeltl thll Honorable Court to modify the cUltody order of December 28, 1995, and grant to the Plaintiff, Julia Lynn Holtz, primary phYllcal cultody of her minor children, Relpectfully 8ubmltted, /0 ~tJ /q,(t'j Date r--: tA ~-* ~~ 0_- 0 ROBERT PETER KLINE, ESQUIRE 331 Bridge Street, Suite 350 POlt Office Box 461 New Cumberland, PA 17070-0461 (717) 770-2540 Attomey for Plaintiff ~ I verify that the statements made In the foregoing Petition for Modification of Custody Order are true and correct, I understand that false statements made herein are subject to the penalties of 18 PA C,S. 4904 relating to unsworn falsification to authorities, 3-Jf.4':J Olte ~LlMJ.:!-d~ - JUl NN HOLTZ -,.. 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COIPOUO 1I'\2 10TAL PAlO 100AY: ,'J Bum 11111\1I111 18000 Bum trt loon 16020 :~,UE UllooSh.wn C",,,O CrlOllC Aem FOIt 'lBoo Cheell- Rem~r_ot;efUrT1f!n o v,,, 0 MUIIICIIG "lIeclom . Law Office of Charles Rector, Esquire, P.C. 1104 Fcmwood Avenuc, SIc, 203 Camp Hill, PA 17011.6912 ..mail . CRCCIOrE"l@aol.com Tammy S, Wcabcr Paralcgal (717) 761-8101 Fax (717)761-2161 February 17, 1999 Curt Long, Prothonotary Cumberland County Courthouse One Courthouse Square Carlisle. PA 17013-3387 Re: Holtz v. Holtz No. 85-4418 Civil renn Dear Mr. Long: Enclosed for filing please find a dual praecipe which withdraws the appearance of Robert p, Kline. Esquire and enters the appearance of Charles Rector, Esquire. on behalf of the Plaintiff. Julia L. Holtz. In the above-referenced maher, If you have any questions regarding the above, please feel free to contact me or my paralegal. Tammy, ve: trul~ your~. ) (' ./1 )(. Charles Rector CRltsw Enclosure cc: Julia L. Holtz Andrea Jacobsen, Esquire E, Robert Elicker, II. Esquire ~(f))[P)~ JULIA LYNN HOLTZ, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO, 95.4489 CIVIL TERM V, JEFFREY ALAN HOLTZ, Defendant , : CIVIL ACTION. LAW : DIVORCE PRAECIPE TO WITHDRAW APPEARANCE Please withdraw my appearance on behalf of the Plaintiff, Julia Lynn Holtz, In ''--_malty ~ &t:3L,Q~ Robert P. Kline, Esquire PRAECIPE TO ENTER APPEARANCE Please enter my appearance on behalf of the Plaintiff. Julia Lynn Holtz, In the above-captioned maller, Date: ~ 1 -. JULIA LYNN HOLTZ, PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V, JEFFREY ALLEN HOLTZ. DEFENDANT , , : 954489 CIVIL TERM Q8P~R OF COURT AND NOW, thll 25th day of August, 1997, following a hearing on the meritt, and belng aatllfled that the best Interest and welfare of Jordon Anthony Holtz, bom June 22, 1987 and JUltln Daniel Holtz, bom September 7,1990, warrantl continuing the cUltocly arrangement let forth In the order of December 28, 1995, IT 18 ORDERED that the petition of Julia Lynn Holtz to modify that order, 18 DENIED. Robert P. Kline, Esquire For Plaintiff _ ~4J ,...~.t B}a.../'l'l. ).,1'. Andrea C, Jacobsen, Esquire For Defendant :888 -""0 F!l.rn-WI:E C: '1,'" "q,--.'!')TK1'f Q'l A\lG 2 G j\i: g: h G C\)' c' ' " "j:r\J h.. ~; I _' \_",)1.,,;,'111 r'Ii\i\~'IL\'/-:\Lt\ JULIA l YNN HOLTZ, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA , , V, JEFFREY ALAN HOLTZ, Defendant : NO, 95-4489 CIVil TERM , : CIVil ACTION - LAW : DIVORCE PRAECIPE TO WITHDRAW APPEARANCE Please withdraw my appearance on behalf of the Plaintiff, Julia Lynn Holtz, In the above-ceptloned matter ) . (" ~t3L,Q~ Robert p, Kline, Esquire PIIAECIPE TO ENTER APPEARANCE Please enter my appearance on behalf of the Plaintiff, Julia Lynn Holtz, In the above-captioned matter, Date: ~ ) ~I y , RESPECTF ~ -3 ~ N p~? {~ :,\.,. (J',; - ~ fOi :r.: CJ~l ~:'l' 0.. ~"):j }I.' . . l" ~ (Xl ':/g @ll< - ~.ll" _ "\.. . r;; 'lJ ~ ;21~ i-" .;.~ 14. en () 0\ 0 .... .' & U D:!!l ~~::iii ~ ~ 2 ~WI~i I!~; &.. Tcl 717.241).6427 I'u 717.241)-11427 .IACOBSI<:N & MILKI<:S n Ensllll"" Slr~~l Cnrllslc, I'A l71l \J.J()II~ SUl11ucl W, Mllkcs Andrcn C, Jncuhscn March 19, 1999 E, Robert Elicker, 11 Office of Divorce Muter 9 North Hanover Street Carllele, PA 17013 RE: Julia Lynn Holtz v, Jeffrey Alan Holtz No. 95.4489, Civil Term, Divorce Dear Mr. Elicker: EncloHd pleale find defendant's Pre-Trial Statement in the above-referenced matter. I look forward to the scheduling of the pre-hearing conference in this matter, Thank you. ACJ\me Enclolure CCI Charlee Rector, Esq, JelTrey Holtz (corrl0319.Uc,hol Sincerely, ~/'--- een JULIA LYNN HOLTZ, Plaintiff : IN THE COUR'r OF COMMON PLEAS : CUMBERLAND COUNTY, PA v. , . : OIVIL ACTION. LAW : NO. 95.4489 CIVIL TERM JEFFREY ALAN HOLTZ Defendant . . : DlVORCE/OUSTODY ANI\VER '1'0 CQ&lPLAINT IN DIVORQE COUNT I . DIVORCE COMES NOW, JEFFREY ALAN HOLTZ, Defendant in the above-captioned matter, by bil attorney, Andrea O. Jacobaen, JACOBSEN & MILKES, and offerl the foUowiDf Anlwer to the Divorce Complaint rued by Plaintiff: 1, Admitted. 2. Admitted, except 88 to lpeUing of Defendant'. middle name. 8. No Anlwer Required. 4. Admitted, 5. Admitted. 6. Admitted. 7. Admitted, 8. No anlwer required. 9, Admitted, 10. Denied, It II denied that the partlel' marriage II Irretrievably broken. To the contrary, It il userted that the partie I' differences are reconcilable, ,'''; 11. It iB admitted that a divorce complaint Willi med by PlaintlfT on Augullt 28, 1995, with the Prothonotary of Cumberland County, on the groundll of irretrievable breakdown of the partieB' marriage, It ill denied that there iB any relUlOn for Plaintiff to beHeve that the Defendant will conBent to the divorce, It ill further denied that Defendant will after 90 dayB from the date of the flHng of the Complaint conaent to the divorce. COUNT II. EQUITABLE DlSmmUTION 12. No AnBwer Required. 18. Admitted. 14. Admitted, OOUNT m . OUSTODY 115. No AnBwer Required, 16. Admitted, 17, Admitted, 18. Admitted, 19, Admitted, 20, Admitted, except IlII to Bpelllng of Defendant'B middie name. 21. Admitted, 22. Admitted, 28. Admitted. 24. Admitted, 26. Denied, It Is denied that Plaintiff Is the primary care giver with respect to the children, and It Is denied that the best Interest and permanent welfare of the children wlll be served by the relief requested by the Plaintiff, To the contrary It Is ul8rted that the relief sought will be adverse to the best Interest and permanent welfare of the children, 26, Admitted. By way of further reBponBe, Defendant aiBO UBerts 27. Defendant hu demonstrated over the course of the chlldren'slives that he i. but able to provide for the love, nurturing, and physIcal needs of the children, Plaintiff haa through courBC of conduct demonstrated that her actions are BOmetimes contrary to the emotional and phYBlcal needs of the children, and Bhe Is, therefore, not belt able to look after theBC interests, 28, AI set forth above, there IB no legal bulB to the divorce action brought by the Plaintiff, The custody claim Islikewil8 without baalB aB there Is no preaent caae or controverBY at hand, The parties continue to live together In the lIlUJle houl8hold with the minor children. There IB no claim that a move Is planned by either party er that they are not jointly parenting their children at this time, ThlB matter IB not ripe for conBlderatlon by the Court. 29, Should the Court assume jurlBdlction of the CUBtody Count Complaint and consider the pOBltionB of the partieB on their merits, Defendant respectfully requests the Court to award him prlmury physical custody or to award the parties joint legal custody pending Il move by either from the marital residence, os being In the best intereete of the children. WHEREFORE, Defendant requeets this Court to: a. Deny Plalntllfs prayer for a decree In divorce and dismiss this action for divorce 8B being without grounds; bo Deny Plalntlffe prayer for a grant of primary phyelcal custody of the children of the partlee; co Grant euch further relief 8B the Court shall deem proper and just. Reepectfully submitted, lol/u 'QS ~~ BY: Andrea. obsen, Eeqo JACOBSEN & MILKES 62 Eost High Street Carllele, PA 17013 (717) 249.6427 Attorney No. 20952 I hereby verify that the state mente made In the foregoing are true and correct. I understand that falee statemente herein are made eubject to the penalties of 18 PaoOoS. Section 4904, rolatlng to unsworn falsification to authorltleeo Dated: /0 f lU JCJ6 ,,,, - ... ~ ' l:R . ::r:: "'- .... ... N ,- o~o.t; . - ~ ~:; . I '.' to. 'We 2 { l:iU51J.. JULIA LYNN HOLTZ, Plaintiff IIN THE COURT OF COMMON PLEAS OF ICUMBERLAND COUNTY, PENNSYLVANIA I INO. 4489 - CIVIL - 1995 I I ICIVIL ACTION - CUSTODY v JEFFREY ALLEN HOLTZ, Defendant ,-'- AND NOli, this "'18 day of of the attach~ustody Conc directed as followsl 1. The Mother, Julia Lynn Holt., and the Father, Jeffrey Allen Holts, shall enjoy shared legal oustody of Jordan Anthony Holts, born June 22, 1987, and Justin Daniel Holt., born September 7, 1990. , 1995, upon consideration Report, it is ordered and 2. The parente shall also enjoy shared physloal custody of the minor children with custody alternated on a week-to-week basis and the exchange of custody being Honday of each week after the parent reoelving custody is out of work. In the event that Honday is a holiday, the exohange shall be at 3 P.H. The alternating week schedule shall start as of Deoember 4 with the Mother having custody for the week of December 4. 3. The parties shall alternate custody on the following holidays I Christmas Eve, Christmas Day, Easter, Memorial Day, July 4th, Labor Day, and Thanksgiving. The times shall be arranged between the parties. The parties may between themselves work out an agreement to split custody on the holidays or actually alternate the holidaye back and forth. 4. The Hother shall always have custody of the ohildren on Hother's Day and the Father shall always have custody of the children on Father's Day. The time frame shall be from 9 A.M. until 6 P.M. This provision shall supersede any other provision under this Order. 5. Each parent shall be afforded an opportunity to spend some time with the minor children on or near their birthday. The non-oustodial parent shall be afforded at least four hours on the respective child's birthday or the day before or the day after the child's birthday in order to oelebrate that event. >;'f'j" 6. Both parents shall insure that they will cooperate to afford both the maternal and paternal grandparents opportunities to visit with the children when the grandparents are in the Cumberland County area. 7. Both parties shall maintain a regular bedtime sohedule for the children and both parents shall insure that the necessary medical needs of the children are met. 8. This Order is entered pursuant to an agreement reached by the parties at a Custody Conciliation Conference. This Order may be modified upon appropriate petition of the parties to have the case again scheduled before the Conolllator. If the parties determine that this Order is unsatlsfaotory within the next four months, oounsel for the parties may contaot the Custody Conciliator to conduot a telephone oonferenoe to update the tatus of this ca.e after whloh the Conciliator oan arran . for the scheduling of a Hearing by this Court. .(. 1J../~./l/q.r. ..& f' 0 001 Robert P. Kline, Esquire _ Samuel w. Hilkes, Esquire ~ - ~ - T.': " .. '-'j ~Q CT\ L"1:1 ~ ~; (Jr: p. . -,' ."1 ' ..:.,. C'\ :J ~l;;' m :;.'. i~) ( I. 'ill-- t"-l ' , ~. I ."'_, [,;1" (-~ ti:~(w (:, l.".1 l:~U. t..i 1-' ~ . ' () In ;',) ,'::' U 10." .. JULIA LYNN HOLTZ, Plaintiff IIN THE COURT OF COMMON PLEAS OF ICUHBERLAND COUNTY, PENNSYLVANIA I INO. 4489 - CIVIL - 1995 I I ICIVIL ACTION - CUSTODY v JEFFREY ALLEN HOLTZ, Defendant CONCILIA'J'IOII CONn:RENCIl slM'fARY RIlPOR'J' IN ACCORDANCE fiITH CUHBBRLAND COUNTY CIVIL RULE OF PROCEDURB, 1915.3-8(b), the undersigned Custody Conolllator submit. the following reportl 1. fhe information pertaining to the ohl1dren who are the subjeot of this litigation 1. as follow., Jordan Anthony Holts, born June 22, 1987, and Justin Daniel Holts, born September 7, 1990. 2. A Custody Conol11ation Conferenoe was held on Deoember 8, 1995, with the following individual. in attendanoel The Hother, Julia Lynn Holt., with her oounsel, Robert P. Kline, Bsqulre, and the Father, Jeffrey Allen Holt., with his oounsel, Samuel fit Hllkes, Esquire. 3. The parties reaohed an agreement in the form a. set forth in the attaohed Order. ~ ."\ MAY 2 I tO~~tY JULIA LYNN HOLTZ, Pldntiff V I IN THE COURT OF CONNON PLEAS OF ICUHBBRLAND COUNTY, PENNSYLVANIA I ICIVIL ACTION - LAW I ,NO. 4489 - CIVIL - 1995 I IN CUSTODY JEFFREY ALLEN HOLT', Defendant COURi' ORDER AND NOli, this ~J~ d.y of M.y, 1997, upon conslderatlon of the att.ched custoayconcll1.t1on Report, it is ordered .nd dlreoted .s follOW" 1. A hearing is scheduled in Cou~t Room No. 2 of the Cumberland cou~t.t:.:> ~~urthou.el on the ..!lot.... _ d.y of n ~ud , 1997, .t c. <' m. at wh oh time t8it1iiiony will be tAken in the above o..e. At thl. he.ring, the Hother shall be the moving p.rty and shall prooeed initially with te.tlmony. Counsel for the p.rtie. shall file with the Court and oppo81ng ooun.el a memor.ndum .ettlng forth the hi.tory of ou.tody in thl. o..e, the 1..u" ourrently before the Court, . Hst of wltn...e. for e.ch party .nd a .ummary of the antiolpated testimony of e.oh ...ltne... 'J'hl. memorandum .hall be flIed at le..t ten d.y. prior to the he.rlng date. Pending further order of this Court, thl. Court'. prior Order of December 28, 1995 shall remain in effeot. 2. 001 Andrea C. Jaoobsen, Robert Peter Kline, / BY THE COUR7J( ~j / Edgar B .~ey Esquire ~ ~ J Esquire )/z.3/tl1 (J.I.A-V' J. .. JULIA LYNN HOLTI, PlalntUf V I IN THE COURT OF COMMON PLEAS OF ICUMBERLAND COUNTY, PEt.NSYLVANIA I ICIVIL ACTION - LAfi I INO. 4489 - CIVIL - 1995 I IN CUSTODY JEFFRBY ALLEN HOLTI, Defendant Prior Judgel Edgar B. Bayley, COBCILIA'J'IOlf CONJ'IlJUlNCIl SUHofARY RIlPOR'J' IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURB 1915.3-8(b), the undersigned Custody Conol1lator submits the following reportl 1. The pertinent information pertaining to the ohildren who are the subjeot of this litigation is as followsl Jordan Anthony Holt., born June 22, 1987, and Justin Daniel Holt., born September 7, 1990. 2. A Conciliation Conferenoe was held on May 15, 1997, with the following individuals in attendanoel The Hother, Julia Lynn Holt., with her oounsel, Robert Peter Kline, Esquire, and the Father, Jeffrey Allen Holt., with his oounsel Andrea C. Jacobsen, Esquire. 3. fhe partie. were before the Cono1l1ator in Deoember of 1995 at whioh time the parties agreed to the entry of a shared Custody Order thlt provided for a week on/week off oustody arrangement between the parties. The parties live in the same trll1er park approximately three doors away from eaoh other. 4. Hother now suggests that Father is not providing adequate oare for the children and Hother wants to be the prlmary ou.todlan. 5. Father suggests that he is doing a fine job with the ohl1dren. He also suggests that the ohlldren are very satisfied with the ourrent arrangement and, if the ohl1dren were required to state a preferenoe as to where they would like to live on a full-time basis, at least the older ohlld would state a preferenoe to live with the Father. 6. The parties oould not reaoh an agreement. A hearing is neoessary. A hearing should take not more than one day. 7. The Conoillator reoommends .(/';)01 q7 DATE re JULIA LYNN HOL TZo Plalnllff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA o . V. JEFFREY ALAN HOLTZ, Defendant : NO. 95-4489 CIVIL TERM . : CIVIL ACTION - LAW : IN DIVORCE P' &INTIFF'S PRE.TRIAL STATEMENT Date of Marriage: 6/21/88 Date of Separation: 10/95 t. AIIETI: 1976 Redman Mobile Home Apprallal' 9,233000 Loan Balance' 2.000.00' Equity . 7.233000 (W) Annuity Certificate ML . 379000 (H)MLlRA S 1,175.00 US Trealury Bondi . 675000 US Trealury Bond (Wedding Gift) S 50.00 Household Fumlehlngs & Bank AccountsZ II. EXPERT WITHE": None presently. However, Plaintiff reserves the right to call an appraiser on the mobile home owned by the parties. t Wrlllen verlflcallon Is needed on loan balance (10 yeer loen will be paid off In May 2000), I All bank accounts end furnishings heve previously been divided 10 the partleso sallsfacllon. $305.00 $ 66006 $285000 $ 69.00 $ 50.00 per week while In school -or- $ 75000 per week during summer vacation $Monthly Ballc Charge $ 35.00 per month on budget $ 50.00. $ 70.00 III. FACT WITNESSES: ao Plaintiff will testify about all matters relating to the allets of the partlee. the breakup of the marrlageo and the factors listed In the Divorce Code. b. Defendant, as on cross examination. Plaintiff reservel the right to call euch additional fact wltnessee as may be necelsary to relpond to evidence eubmltted by Defendant. IV. EXHIBITS: None anticipated at present with the exception of a NADA summary on the value of the mobile home. V. INCOME/EXPENSES: Weekly Income $394.00 Vlo PENSIONS: See Paragraph I. VII. COUNSEL FEES: No claim for counsel fees Is made In this action, VIII. MARITAL DEBTS: None except balance currently due and owing on tha mobile home. IX. PERSONAL PROPERTY: Already divided. lot Rent Conlolldatlon loan Carlosn 2nd Car loan Day Care Phone Gal Electric Xo PROPOSED RESOLUTION: Plaintiff proposel that the marital alsets be divided on a 60/40 basil with the eKceptlon of the mobile homeo Plaintiff requelll the mobile home be sold and that Ihe be provided with all of the proceedl derived therefrom following the satllfactlon of the lien, settlement and closing oostso Plaintiffs requaBt for equitable reimbursement Is based In large part on Plslntlffl enormoul contrlbutlonl as the famlly'slole breadwinner from July of 1991 through May of 1995. during which time Defendant attended college and ultimately obtained an undergraduate degree In BUllness Admlnlltratlon and Management. BY: ", ili kJ ~ ~^' \u ,db, Charles Rector. Esquire 1104 Femwood Avenue, Steo 203 Camp Hili, PA 17011 (717) 761.8101 Attomey for Plaintiff Date:_ I verify that the statemenll made herein are true and correct. I understand that falle statements herein are made subject to the penallleB 0118 Pa.C.S. Section 4904. relallng to unlwom falllflcatlon to authorities. M.,,-04-.. 111 UP "u i2 '. 121. ... P.OI JJU'" ~,f'Ut - - -- -.--- - .- -.. .- N.AollAo AVII"GF.IITAlo VALlII DATI "-fJ..,&DITIONI MO.~ no\Rlm RIOIONnt!.ITATJ'& M"i. R uJ """'-1.... . MODIL YL\Il'7' 11I7.1 I~ ~ /~ a.EVII WIIIR. ~,.. .tV ILACIClll.V.... ,/::J nu.ow. 3"~ OLlI.IIM \'lllo8lAl.l ;!iJ'; YIIJA)WC:HAUVAWEOJHOMI_."...__......_........ 7.:1 '741- IUA"'10011 n. OIlT... 11._ . pII. .. nl__ . TOTAl ........''''._........_........_.'''...........1..............................-. I ., i;l '7tf/ - nATlUK:AlI0NCODI X 1.01 AVllAGIIlITAIL lOOK V AI..1'1.....,...-.....I......-.............1 "JAr - I. 00 ")~.,~.... I. I~ ~;;~t1 - CONllne)N drcIIlllCl Dr.. G~'" ,a. IAL .. lit c:oJrIJlTION ADR"I'ID VAl.lJI.................._....II..............1 'AlK ,"1'INC1 .!.~D. 'HJlo~d lit 'AIK AUK:ATION ADlllnlD VALliE..................... I opnONALKQlll'MlNTI I. ".nWt-ILJ JI1I,.. . :, ,~ - 2. slijtJt~ i_j . ::; .:J I 30 . 4- . .. . " . ,. . L . TOTAL OP11OfilI I TUTAL VAL"t; 0' HUMa . 9:l33 - lie.... VQ../u' is ....;U, uJ~__.Jr a..,J CL'1I/II. rh~ Va../II' IS ~., app"o"'o"'I1.~;o" s-;.c.. =r; ",,-vll IVld. .., ~p(a.t.d to... hu..e. JULIA LYNN HOLTZ, Plalntlff : IN THE COURT Ol~ COMMON PLEAS : CUM8ERLAND COUNTY, PA : CIVIL AC'l'ION . LAW : NO. 95.4489 CIVIL TERM v. JEFFREY ALAN HOLTZ Defendant : DIVORCE DEFENDANT'S PRE.TRIAL STATEMENT UNDER PA RCP 1920.88 (b) AND NOW COMES Defendant, JEFFREY ALAN HOLTZ, Hueband, by hie counsel, Andrea C. JBcobeen, JACOBSEN & MILKES, and flies hie Pre. Trial Statement under Penneylvanla Rulee of Civil Procedure 1920.33(b), as followe: 1. A lIet of marital aBeete ie attached hereto. 2. Hueband doee not intend to call at trial any expert witneBe unleee tho partie I are unable to etlpulate aB to aBsete, valuation, and incomes of the pl1l'tlee. 3. HUBband anticipate. that there will be no witnel.e. except the partie.. 4. Hueband antlclpatee that the partlee will be able to etipulate ae to the marital/non. marital nature and ae to the valuee of the ml\lorlty of the partlee' aleetB, and aleo 88 to the Income information to be placed before the Master. Husband will eubmit a etatement of exhiblte to be presented subeequont to the pre. hearing conference In this matter. 60 Husband has rocontlystarted employment in tho parts department of L.B. Smith, auto dealership In Cump Hili, PAo Hie buso pay Is $13.00 por hour for 40 houre. Other than mJnimalinterest, ho hUB no othor incollleo HUlband antlclpatee that hie new job wl\l otTer Homo overtime work, but It III too BOon to form any roalletlc eetlmate of how much addltlonallncomo that will gonerato. Hueband wll1 provide curront Incomo Information prior to tho pro-honrlng conferonce in thle matter. 6. Husband Intonds to otTer teetlmony regarding his exponeoso Hueband will submit a current expenee Itatement prior to the pre-hearing conforence In this matter. 7. Hueband hae an IRA with Aid Aseoclatlon for Lutherane which wos obtained during the marrlago. The balance Is $1,176. Husband believes that wife aleo has an IRA and/or other ponelon or rotlrement bonem, the exact nature and value of which ie unknown at thle time. 8. At thle time, there Is no claim for couneel feee by husband. 9. Defendant Ie aware at this time of no dlepute aB to the description or valuation of tangible perlonal propertyo The partlee dlltrlbuted their eavlnpand checking accounte and their houeehold property at the time of eepnratlon. 10. The mnrltal debte of the parties Include the balance owed on the marital mobile home, (approximately $3,000) and debt for Improvomente to mobllo home, (approximately $1,600)0 11. Hueband propceee that the mobile home oftho partlee be eold and the net proceede, and afler deduction for coete of eale and Improvemente to the home, the balance be epllt equally between the partie eo Hueband aleo propoeee an equal diltrlbutlon of the retirement or penelon intereste of the partlee, BB well any othor marital aBsete, Including the treaBury bonde be divided equally between the partlee. Respectfully submitted, DaIod, -3 I~ }q~ CJ2~. BY: Andrea . Jacobsen, Eeq. JACOBSEN & MILKES 52 EBBt High Street Carllele, PA 17013 (717) 249.6427 Attorney No. 20962 HOLTZ v. HOLTZ No. 96.4489. Civil Term MARITAL ASSETS 1. Mobile Home -located at 202 Birch Lane, Carllele PAo - In mobile home park. Lot rent payable at $306 per montho Approximate balance on purchaBe money lien: $3,000; at leparatlon: $10,700. 2. U.S. TreaBury bonde purchaBed during marriage: $675 face value. 3. HUlband'e AAL IRA: $1,176. 4. Wife'l penllon or retirement intflreBte: Unknown value. JULIA LYNN HOLTZ, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY. PA v. . . : CIVIL ACTION. LAW : NO. 95.4489 CIVIL TERM JEFFREY ALAN HOLTZ DefendlUlt : DIVORCE AFFIDAVIT UNDER SECTION 880l(D) OF THE DIVORCE CODE 1. The partiee to thle action eeparated on or about October 16, 1996, and have continued to live separate and apart elnce that time for a period In exceel of at leaat two yearlo 2. The marrilllJe Ie Irretrievably broken. S. I underltlUld that I may lose rights concerning alimony. division of property, lawyer's feee or expensel if I do not claim them before a divorce Ie grantedo I verify that the etatemente made In the Affidavit are true and correct. I understand that Calee etatemente herein are made subject to the penaltiee of 18 Pa.CoSo II 4904 relating to uneworn falelllcation to authorltiee. ! Date: //21/ t:ft I 't~ Co' , ~ j' Co j_l .. " 't~ Y' .:J ,.10 .r' ~;' (.~.: )(, .~. >, ~-'f I '\ . II'" [" " . , t: ,.\. r 1\, I."'" t,J U V" JACOBSEN & MILKES 52 Eusl High SuccI Curllslco I'A 170\ 3-31185 Sumuel W. Mllkcs Andreu Co JucubSCII 'I'cI717-249,6427 Fux 717-249.8427 MUI'ch 3, 2000 E. Robert Elicker, II, Esquh'e Office of the Divorce Muster 9 North HonovOl' Street Corlisle, PA 17013 RE: Holtz v. Holtz Noo 95.4489 Civil Term Door Mr. Elicker: Thle will confirm our convel'sotlon of this morning where I odvised you thot the above IlOrtles ore seeking II genelool continunnce of the heoring set in this matter for Monday, Mnrch 6, 2000. We antlcipote that 0 settlemont hos been reached and wo will be withdrowing the economic clnims in the noar future. Thank YOUo Sincerely, JACOBSEN & MILKES ACJ/drc Cc: Jeff Holtz Chnl'lcs RcctOl', Esq. (corrl0303Ellckcr.ho\ FR01 : C.oarles Rector, Esqo ~~ NOo : 717+761+2161 Mar. IlJ 200Il 11 :SJI:I1 PI LIW Offices Or Charles Reclor, Elqulre, P.c. 1104 Femwood Avenue, Sic. 203 Camp Hill, PA 1701\-(1912 e.mail . CR,e'OIEIq@lol eom Tammy S. Flusl Paralcll.1 (717) 761-8101 Fax (717) 761-2161 Mlrch 30 2000 E, Robtn Elicker. II, Esquire ames 01 Divorce MI.ter 9 North Henov.r Streel Clrtlsleo PA 17013 Re: HoII6 v. Holtz No. II If. eMI Tenn Dllr AtlorMY Elicker: I confirm by thlaletter lhel Andree Jacob..n, Elqulre. end I hllve reached full end f1nel Htllemtnt of the l"un In the lIbove~f.renced matt.r, HoweYII'. I am loday fOlWlldlng the AgrMmtnll to Andrea and aht Ind her client have not had . c:hInce to rtVItW Ihtm. We therefor, rtlpectfulty requ..1 thallh. M..t....1 H.lrlng now .ch.duled for Monday, M.rch Cl, 2000. be postponed lIInerally 10 a.lo,1Iow ullome eddilional time to filllll&t the mattIII'. With kinde.t rtgard.o ti Chertn Reclor CRill' cc: Andr" Jlcobleno Esquire JULIA LYNN 1l0LTZ, Plaintiff IN '1'1lE COURT OF COMMON 1'1,~;I\S OF CUMIlERLI\ND COUNTY, PENNSYINI\N 11\1 NO. 95 - 4409 CIVIl. vs. JEFFREY ALAN HOLTZ, Defendant IN DIVORC~: ORDER OF COURT AlID NOW. th1. ~ "- d,y of ~ 2000, the economic claims raisod in the proceeding" having been resolved in accordance with a marriago Bottlemont agreement dated March 1, 2000, the appointment oC tho Mastor is vacated and counsel can file a praocipe transmitting the record to the Court requesting a final docreo in divorce. IlY TilE COUll'l', P.J. cc: Charles Rector Attorney for Plaintiff {!opl~a)muJJ f!k.d :un Mw .t.of(~ /, /;.r RKS Andrea C. Jacobson Attorney for Defendant -' '-. ,... ~. {J': (\,. 'L " ,. e; ',' ,.,1' .:~"1" , . - '. ",;j I. ~. r ' J ~_.~ ,', '.:+_i J '" ~ -", I":) , " l :':~ l, ;Inl ~J ' ~}fl.. 11 f':~) ::5 ,,) (.:.) \_) MAB.RIAG~_S.~Ilb~MEtRAgBEEMENT THIS AGREEMENT made this h~ day of \\\n';l( \"'\ between Julia Lynn Holtz (WIFE) and , 2000, by and Jeffrey Alan Holtz (HUSBAND) WITNESSETH: WHEREAS. the parties hereto are HUSBAND and WIFE, having been married on June 21,1986, In New Kingston, Cumberland County, Ponnsylvanla. There were two children born of this marriage, Jordan A, Holtz (DOB 6/22/67) and Justin Do Holtz (DOB 9/7/90). WHEREAS, diverse and unhappy differences, dlsputee and difficulties have arisen between the partlos and It is the Intention of HUSBAND and WIFE to live separate and apart for the rest of tholr naturolllvob, and the parties heroto are desirous of setlllng fully and finally their respoctlvo financial proporty rights and obligations as between each other Including, wllhoutllmltatlon by specification: the settling of all matters between them relating to the ownership and oqultable distribution of real and personal property; the sellllng of 011 mallere botween them rolatlng to the past, present and future support, alimony and/or malntonanco of WIFE by HUSBAND or of HUSBAND by WIFE; and In genoralo tho sollllng of eny and all claims and possible claims by one against tho other or against their rospectlve estates. NOW, THEREFORE, In consideration of tho promises and mutual promises, covenants and undertakings horelnafter sot forth and for other good and valuable 0, 0', " ~ ~ conslderallon, receipt of which 15 hereby acknowledged by each of the parties heretoo WIFE and HUSBAND, each Intending to be legally bound hereby. covenant and agree as follows: 1. INCORPORATION OF PREAMBLE. The recitals let forth In the Preamble of this Agreement are Incorporated herein and made a part hereof as If fully set forth In the body of the Agreement. 2. AGREEMENT NOT A BAR TO DIVORCE PROCEEDINGS. This Agreement shall not be considered to affect or bar the rights of HUSBAND and WIFE to an absolute divorce cn lawful grounds If such grounds now exist or shall hereafter exlet or to such defense as may be available to either party. This Agreement Is nctlntended to condone and shall not be deemed to be condonallon on the part of either party hereto of any act or acts on the part of the other party which have occasioned the disputes or unhappy differences which have occurred or may occur subsequent to the date hereof, The parties acknowledge that their marriage Is Irretrievably broken and that they shall secure a mutual consent no-fault divorce pursuant to the terme of Section 3301 (c) of the Divorce Code In WIFE'S Cumberland County divorce acllon docketed to number 95-4489. Upon the signing of this Agreemento the partlee shall execute and file all documents and paperso Including affidavits of consento necessary to finalize said divorce, 3. EFFECT OF DIVORCE DECREEo The parties agree that unless otherwise specifically provided herein, this Agreement shall continue In full force and effect after such lime as a final Decree In Divorce may be entered with respect to the parties. 2 , ~ . . ~o ~ 4. AGREEMENT TO BE INCORPORATED IN DIVORCE DECREE. The partlee agree that the terms of this Agreement shall be Incorporated Into any Divorce Decree which may be entered with respect to themo II. NON.YERGER. II Ie the parties' Intent that this Agreemenl doee not merge with the Divorce Decree, but rather shall continue to have Independent contractual slgnlftcanceo Each party maintains his or her contractual remedies as well as court crdered remedies as the resull of the afcresald Incorporation or as otherwise provided by law cr statuteo Those remedies shall Include, but not be limited to, damagee resulting from breach of this Agreement, specific enforcement of this Agreement and remedlss pertaining to failure to comply with an order of court or agreement pertaining to equitable dletrtbutlon, alimony, alimony pendente lite, counsel fees and costs as set forth In the Penneylvanla Divorce Code or other similar statutes now In effect and as amended or hereafter enacted. e. DATE OF EXECUTION. The "dale of execution" or "execution date" of this Agreement shall be defined as the date of execution by the party last executing thle Agreement. 7. DISTRIBUTION DATE. The transfer of property I funds and/or documents provided for herein shall only take place on the "distribution dale" which shall be defined as the date of execution of this Agreement unless otherwise specified herein. 8. ADVICE OF COUNSEL. The provisions of this Agreement and their legal effect have been fully explained to the parties by their respective counselo Charles Rector, Esquire for WIFE, and Andrea 3 '0 , " 0 Jacobseno Esqulreo for HUSBANDo The parties acknowledge that they have received Independent legal advice from counsel of their selection and that they fully understand the facts and have been fully Informed as to their legal rights and obllgallons and thay acknowledge and accept that this Agreement Iso In the circumstances, fair and equitable and that It Is being entered Into freely and voluntarily, alter having received such advice and with such knowledge and that execution cf this Agreement Is not the result of any duress or undue Influence and that It Is not the result of any collusion or Improper or Illegal agreement cr agreementso 8. FINANCIAL DISCLOSURE. The partlee confirm that each party has made a full and fair disclosure to the other of all of their aesets, debts and Incomee and that each has relied on the substantial accuracy of the financial disclosure of the other, as an Inducement to the execution of this Agreement. 10. PISCLOSURE AND WAIVER OF PROCEDURAL RIGHTS. Each party understands that he or she has the right to obtain from the other party a complete Inventory or list of all of the property that either or both parties own at this time or owned as of the date of separation, and that each party has the right to have all such property valued by means of appraisals or otherwise. Both parties understand that they have the right to have a court held hearings and make decisions on the matters covered by this Agreement. Both parties understand that a court decision concerning the partleso respective rights and obligations might be dlfferant from the provisions 01 this Agreement. 4 00 , t' .' , . , ' 000~ tf Each party hereby acknowledgee that this Agreement Is fair and equitable. that It adequately provides for his or her needs and Is In his or her bestlnterestso and that the Agreement Is not the result cf any fraud, dureseo or undue Influence axerclsed by elthar party upon the other cr by any other person or pareons upon either party. Both parties hereby waive the following procedural rights: a. The right to cbtaln an Inventory and appraisement of all marital and non- marital property as deflned by the Pennsylvania Divorce Code. b. The right to obtain an Income and expense statement of the other party al provided by the Pennsylvania Divorce Code. Co The rlghllo have property Idenllfled and appraleed. do The right to discovery as provided by the Pennsylvania Rulee of Civil Procedure. eo The right to have the court delermlne which property Is marital and which Is non-marital, and equitably dlltrlbute between the parties that property which the court determines 10 be marltalo and 10 eet aside 10 a party thai property which the court determlneeto be that parties' non-marital propertyo fo The right to have the court decide any other rlghtso remedies, prlvllegeeo or obllgallone covered by this Agreement and/or arising out of the marital relatlonshlpo Including but not limited to ponlble claims for divorce, child or spousal supporto allmonyo alimony Pendente Lite (temporary allmony)o equitable dlstrlbullon. custody, vlsltallono and counsel Ieee, costs and expenses. 5 ~ 11. PERSONAL PROPERTY. The parties acknowledge that they have previously agreed to a division of all of thel~ tangible personal property Includlngo but not limited Ito Jewelry, clothes, furniture, furnishings, rugs, carpets, household equipment and appliances, toolso pictures. bookso works of art and other tangible personal propertyo With respect to said division the parties agree that HUSBAND shall receive as his sole and separate property all Items currently In his possession and WIFE shall receive as her sole and separate property all Items of tangible personal property In her. possession. Each of the parties hereto does walveo releaseo and forever abandon any right and all title, Interest and clalmo In and to the tangible personal property to become the property of the other party pursuant to the terms of the paragraph. Except that HUSBAND waives all right, title and Interest he may have to WIFE In the antique bed frame and antique dresser and he shall make these Items available to WIFE within twenty.four (24) hours of execution of the Agreement. 12. AnER.ACQUIRED PROPERTY. Each of the parties shall hereafter own and enJoyo Independently of any claim or right of the other, all propertyo tangible or Intanglbleo real. personal or mixed, acquired by him or her, with or without non-marital assetso after the date of this Agreemento with full power In him or her to dispose of the same as fully and effectively, In all respects and for all purposes, as though he or she were unmarried and each party hereby waives. releases. renounces and forever abandons any rlghto title, Interest and claim In and to said after acquired property of the other party pursuant to the terms of this paragraph. 6 '. 13. DIVISION OF VEHICLES. With respect to the vehicles owned by one or both of the partles, or the net proceeds or value derived from any prior sale or trade In thereofo they agree as follows: WIFE waives ell rlghto title and Interest In and to the 1994 Subaru Legacy to HUSBAND and specifically the trade In value received by him on the Hyundal Sonata to facilitate his purchase of said vehlcleo In consideration thereof, HUSBAND shall assume full responsibility for the remaining loan obllgallon due and owing thereon to Membere First Federal Credit Union and shall Indemnify and save WIFE harmless from same. HUSBAND waives all rlght,tltle and Intereet he may have In WIFEoe 1997 Ford Escort and specifically any Interest derived from WIFE's trade-In of the 1990 Hyundal Sonata. WIFE shall assume full responsibility for the loan obligation due and owing on said vehicle and shall Indemnify and eave HUSBAND harmless from same. The titles or assignment of any lease agreements to said vehlclee shall be executed by the parties, If appropriate, for effectuating transfer as herein provided on the date of execution of this Agreement and said executed titles/assignments shall be delivered to the proper party on the distribution date. For purposes of this Paragraph the term 'title' shall be deemed to Include 'power of attorney' If the title or lease agreement to the vehicle Is unavailable due to f1nanclng arrangements or otherwise, In the event any vehicle Is subject to a lien, encumbrancE'o lease or other Indebtedness In the party receiving said vehicle as his or her property shall take It subject to said lien, encumbranceo lease or other Indebtedness and shall be solely responsible therefor and said party further agrees to Indemnlfyo protect and save the other party harmless from said lien, encumbrance. lease or other Indebtedness. Each of the parties hereto does 7 # ~ :# (jh specifically walveo releaseo renounce and forever abandon whatever rlghto title and Interest he or she may have In the vehlcle(s) that shall become the sole and separate property of the other pursuant to the terms of this Paragrapho 14. MOBilE HOME. , The partlee are owners as tenants by the entireties of a New Moon mobile home presently loceled at 202 Birch lane, Cart Isle, Pennsylvanlao 17013. WIFE agrees to waive all rtghto title and Interest ehe may have In said mobile home to HUSBAND. In conllderatlon thereofo HUSBAND agrees to assume full responelblllty for the loan payment due and owing thereon to PNC Bank and shall Indemnify and save WIFE harmless from payment of same. WIFE further agrees to execute any and all documents necessary to transfer tltle to said mobile home to HUSBAND and shall do so only after confirmation that the monetary payment outlined In Paragraph 15 Is escrowed In the account of HUSBANDoe attorney. In addition, HUSBAND shall pay all other debtso rentso fees. costso etco associated with maintenance of said mobile home now and In the future and ehalllndemnlfy and sava WIFE harmless from same. 15. MONETARY PAYMENT. In consideration of the WIFEos waiver of her Interest In the marital mobile homeo HUSBAND agrees to refinance the remaining loan obligation due and owing to PNC Bank (If, any only If. It has not already been paid off) and he shall, within thirty (30) days from the dale of execution of this Agreemento pay to WIFE the lump sum of $3,500.000 as and for a one time non-taxable equitable distribution payment. 8 .. ,. . .~ ~ 18. ~ACH PARTY RETAINS PENSION PLANS. Each of the parties does epeclncally waive, releaseo renounce and forever abandon all of his or her rlghto title, Interest or claim, whatever It may be, In any Pension Piano Retirement Plan, pront Sharing Plan, 401.K Plan, Keogh Plan, Stock Plan, Tax Deferred Savings Plan and/or any employee beneflt plan of the other party, whether acquired through saId partyoe employment or otherwlseo and hereafter said Penllon Plan, Retirement Plan, Savings Plan, Tax Deferred Savings Plan and/or any employee benefit plan shall become the eole and separate property of the party In whose name or through whose employment said plan Is carried. Speclncally, WIFE waives all right, title and Interest she may have In the Aid for Association for Lutherans IRA Account currently tilted In the name of HUSBAND and all United Statel Treasury Bonds currently In hll pOIBesslon and Bny employment beneflt he receives through LoB. Smith, Inc. HUSBAND waives all right, title and Interest he may have In WIFE's Benent Plan Including. but not limited to her Deferred Compeneatlon Plans through Schwane, Inc. and WIFE' annuIty certlflcate through the Aid for AIBoclatlon for Lutherans. 17, DIVISION OF BANK ACCOUNTS/STOCK/LIFE INSURANCE. The parties acknowledge and agrea that they have previously divided to their mutual satisfaction all of their bank accounts. certlncates of deposito IRA accountso bondso sharas of stock. Investment plans and life Insurance cash value and hereafter WIFE agrees that all said bank accountso certlflcates of deposito IRA accounts, bondeo shares of stocko Investment plans and life Insurance cash valua In the possession of HUSBAND shall becoma the sole and separate property of HUSBAND and HUSBAND agrees that all said bank accounts, certlflcates of deposit, IRA accountso bondso shares 9 , of stock, Investment plans and life Insurance cash value In the possession of WIFE shall become the sole and exclusive property of WIFE. Each of the parties does specifically walveo release, renounce and forever abandon whatever rlghto tille, Interest or claim, he or she may have In any bank account. certificates of deposllo IRA accounto bondso ehares of etock. Investment plans and life Insurance cash value that Is to become the eole and separate property of the other pursuant to the terms hereof. 18. MARITAL DEBTS. The parties acknowledge that they have previously divided the obligations and payments required thereof of any debts and obllgallons arising during the marriage and In accordance therewith any obllgallon being paid by a party shall continue to be 10 paid and said party shalllndemnlfyo protect and save the other party harmless therefrom. A liability not disclosed In this Agreement will be the eole responsibility of the party who has Incurred or may hereafter Incur II, and each agrees to pay It as the lame shall become due. Each party agrees to Indemnify and hold the other party and his or her property harmless from any and all such debtso obligations and liabilities assumed by a party pursuant to this Paragraph. From the date of execution of this Agreemento each party shall use only those credit cards and accounts for which the party Is Individually liable and the parties agree to cooperate in closing any remaining accounts which provide for joint liability. Speclflcallyo HUSBAND shall assume full responsibility for his outstanding student loan obligations to PHEM and all credit card obllgallons ~ Incurred by him following separation a.n~ he ,shall Indemnify and save WIFE h~rmless ~ from payment of said obligations, WI\~ ~\'C.l\\ q~~1\(;;. .s;J 1U6~~I\~I~\i~ \t:l!. nil tu&..t tu.1l\ (ib\I\'~l\\tA~.-\- cA~\/..LtJi\,t:. 1i\~U.RI2.~ h~ \.r..1L ~la':I~~ ~r-1.\t.t\\1lV\ c:wd ::'~CI\1 \"d~",\\,~ l\"~ ~c\4 \.-\\t)~ANb \\l'l2.Iwlm "C*~ ~U~~Q~ of.. <<:Att\ Ob\I~<\\llJ'~o -rNl.Il\~i~o C\.~\QL ~"'(\:\ ~Q. "-1J,'..,~1 ~O\~ 0\-'\1 ~\.\i'tl\ -1t) \:lh~uv~c tCL\d ~llqll hI/... 'SL'l~,.,~iiCl ~ll~ lui~\'. tlLcr ~ \,^CJl\~tllll.. vn~l\\<<!I\'" t~u.~ .lu h.l.!1<!. h~.N:U\\L\~~' \\ 19. WAIVER OF INHERITANCE. Each of the parties hereto does specifically walveo release, renounce and forever abandon any rlghto tltleo Interest or clalmo If anyo either party may have In and to any Inheritance of any kind or nature whatsoever previously or In the future received by the other party. 20. WIFE'S DEBTSo WIFE represents and warrants to HUSBAND that since the parties' marital leparatlon she has not contracted or Incurred any debt or liability for which HUSBAND or his estate might be responsible and WIFE further represents and warrants to HUSBAND that she will not contract or Incur any debt or liability after the eKecutlon of thle Agreemento for which HUSBAND or his estate might be responsible. WIFE shall Indemnify and save HUSBAND harmless from any and all claims or demands made against him by reason or obligations Incurred by her. 21. HUSBAND'S DEBTS. HUSBAND represents and warrants to WIFE that since the partie SO marital separation he has not contracted or Incurred any debt or liability for which WIFE or her estate might be responsible and HUSBAND further represents and warrants to WIFE that he will not contract or Incur any debt or liability after the eKecutlon of this Agreement, for which WIFE or her estate might be responsible. HUSBAND shall Indemnify and save WIFE harmless from any and all claims or demands made against her by reason of debts or obligations Incurred by him. \I ~ . ," 22. BANKRUPTCY The parties hereby agree that the provisions of this Agreement shall not be dischargeable In bankruptcy consistent with 11 use 52(a)5 and expressly agree to reaffirm any and all obllgallone contained herein. In the event a party flies such bankruptcy and pursuant thereto obtains a discharge of any obllgallons assumed hereunder, the other party shall have the right to terminate this Agreement In which event the division of the partleso marital assets and all other rights determined by this Agreement shall be subjected to court determination the same as If this Agreement had never been entered Into. 23. SOCIAL SECURITY BENEFITS. The partlee agree that subject to the rules and regulations of the Social Security Administration, each cf the parties ehall continue to be eligible for Social Security beneflls to which he or she would ordinarily be qualified as a party to a divorce after a marrlage of ten (10) years or more In duratlono If the parties' marriage Is determined to be of ten (10) or more years In duration. 24. INCOME TAX PRIOR RETURNSo The parties have heretofore flied Joint federal and state returns. Both parties agree that In the event any deficiency In federalo state or local Income tax Is proposed. or any assessment of any such tax Is made against either of lhemo each will Indemnify and hold harmless the other from and against any loss or liability for any such tax deficiency or assessment therewith. Such taxo Interesto penally or expense shall be paid solely and enllrely by the Individual who Is finally determined to be the cause of the 12 ~ \ " mlsrepresentallons or failures to disclose the nature and extent of his or her separate Income on the aforesaid Joint returns. 25. FINAL EQUITABLE DISTRIBUTION OF PROPERTY. The parties agree that the division of all property set forth In this Agreement Is equitable and In the event an action In divorce Is commenced (and/or finalized). both parties relinquish the right to divide said property In any manner not consistent with the terms set forth herein. It Is further the Intent. understanding and agreement of the parties that this Agreement Is a full, complete and equitable property division. 28. WAIVER OF ALIMONY, ALIMONY PENDENTE LITE, SPOUSAL SUPPORT. COUNSEL FEES. MAINTENANCE AND COSTS. The parties hereto agree and do hereby waive any right and/or clelm they may have, both now and In the future, against the other for alimony, alimony pendente lIIe, spousal support, maintenance, counsel fees and costs. 27. PERSONAL RIGHTS. HUSBAND and WIFE may and shall, at all limes hereaftero live separate and apart. They shall be free from any controlo restraint, Interference or authorltyo direct or Indlrecto by the other In all respects as fully as If they were unmarried. They may reside at such place or places as they may select. Each may 0 for his or her separate use or beneflto conducto carry on and engage In any buslnesso occupallono profession or employment which to him or her may seem advisable. HUSBAND and WIFE ehall not molesto harasso disturb or malign each other or the respecllve families of each other nor compel or allemptto compel the other to cohabit or dwell by any means or In any manner whatsoever with him or her. 13 o . 28. MUTUAL RELEASESo HUSBAND and WIFE each do hereby mutually remlee, release, quitclaim and forever discharge the other and the eetate of such other, for all time to comeo and for all purposes whateoever, from any and all rights. title and Interest, or claims In or against the property (Including Income and gain from property hereafter accruing) of the other or against the estate of luch other, of whatever nature and wheresoever situate, which he or she now has or at any time hereafter may have against such othero the estate of euch other or any part thereof, whether arising out of any former actso contracts, engagements or liabilities of luch other or by way of dower or courtesy, or claims In the nature of dower or courtesy or wldowol or widower's rights, family exemption or Ilmllar allowanceo or under the Intestate laweo or the right to take against the spouse's will; cr the right to treat a lifetime conveyance by the other as testamentary, or all other rights of surviving spouse to participate In a daceased spouse's estate, whether arising under the laws of (a) the Commonwealth of Pennsylvanlao (b) State, Commonwealth of territory of the United State So or (c) any other countryo or any rights which either party may have or at any time hereafter have for past, present or future support or maintenance, alimony. alimony pendente IIta, counsel fees, equitable dlstrlbutlono costs or expenses, whether arising as a result of the marital relation or otherwlseo excepto and only except, all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provision thereof. It Is the Intention of HUSBAND and WIFE to give to each other by the execution of this Agreement a full, complete and general release with respect to any and all property of any kind or natureo real, personal or mlxedo which the other now owns or may hereafter acqulreo except and 14 , . only except all rights and egreements and obligations of whatsoever nature arising or which may arlee under this Agreement or for the breach of any provisions thereof. 29. WAIVER OR MODIFICATION TO BE IN WRITING. ~ No modlflcallon or waiver of any of Ihe tarms hereof shall be valid unless In wrlllng and signed by both parties and no waiver of any breach hereof or default hereunder shall be deemed a waiver of any subsequent defaull of Ihe same or elmllar nature. 30. MUTUAL COOPERATION. Each party shall, at any time and from time to time hereafter, take any and all etepe and executeo acknowledge and deliver to the other party, any and all further Instruments and/or documente that the other party may reaeonably require for the purpoee of giving full force and effect to the provisions of this Agreement. 31; AGREEMENT BINDING ON HEIRS. Thle Agreementehall be binding and shall Inure to the benefit of the parties hereto and their respecllve helrso executorso administrators, successors and assigns. 32. INTEGRATION. This Agreement conslltules the entire understanding of the parties and eupersedes any and all prior agreements and negotiations between them. There are no representallons or warranties other than those expressly set forth herein. 33. OTHER DOCUMENTATIONo WIFE and HUSBAND covenant and agree that they will forthwith (and within at least twenty (20) days after demand therefor), execute any and all wrlllen Instruments, assigns. releaseso sallsfacllonso deeds, noleso slock cerllficaleso or such other wrlllngs IS , , ~ as may be necessary or desirable for the proper effectuation of this Agreemento and as their respective couneel shall mutually agree should be so executed In order to carry out fully and effectively the terme 01 this Agreement. 34. NO WAtVER OF DEFAULT. This Agreement shall remain In full force and effect unless end until terminated under and pursuant to the terms of this Agreement. The failure of either party to Insist upon strict performance of any of the provisions of this Agreement shall In no way affect the right to such party hereafter to enforce the same, nor shall the waiver of any subsequent defaull of the same or similar nature, nor ehalllt be construed as a waiver of etrict performance of any other obligations herein. 311. BREACH. If for any reason either HUSBAND or WIFE falle to perform his or her obllgallons hereunder owed to or for the benefit of the other party and/or otherwise breaches the terms of this Agreement, then the other party shall have the following rights and remedies, all of which shall be deemed to be cumulative and not In the alternatlveo unless said cumulative effect would have an Inconsistent result or would result In a wlndlallto the other party. (a) the right to specific performance of the terms of this Agreement, In which event the non-breaching party shall be reimbursed for all reasonable allorneyOs fees and costs Incurred as the result 01 said breach and In bringing the action for specific performance. 16 o. , # or (b) the right to damages arising out of the breach of the terms of this Agreament, which damages shall Include reimbursement of all attorney's fees and costs Incurred as the reeult cf the breach and In bringing the damage action. (c) the right to all remedies set forth In Section 3502(e) of the Pennsylvania Divorce Codeo 23 Pa.C.S,A. 3502(e)0 and any additional rights and remedies that may hereafter be enacted by virtue of the amendment of said Section or replacement thereof by any other elmllar laws, which remedies shalllncludeo but not be limited to: (1) the entry of judgement; (2) the authorization of the taking and seizure of goode and chattels end collection of rents and profits of real and personal and tangible and Intangible propertyj (3) the tranlfer and sale of any property required to obtain compliance with the obllgatlone undertaken by this Agreement; (4) the poetlng of security to Insure future paymentl to assure compliance with the obligations undertaken by this Agreement; (5) the Issuance of attachment proceedings and the holding of the Defendant to be In contempt and the making of appropriate order thereof Includlngo but not limited to, commitment of the breaching party to county jail for a period not to exceed elx (6) months; (6) the award of counsel fees and costs; (7) the attachment of the breaching party's wages. (d) Any other remedies provided for In law or In equity, 17 , '. , . . ~' 'C(v 38. SEVERABILITY . II any termo condition, clause or provision cl this Agreement shell be determined or declared to be void or Invalid In law or otherwise, then only that term, condltlono clause or provision shall be stricken from thle Agreement and In all clher respects this Agreement shall be valid and continue In lull Icrceo effect and operation. Likewise, the lallure 01 any party to meet his or her obligations under eny one or more 01 the paragraphs herein, with the exception 01 the eatlslactlon 01 the conditions precedent, shall In no way avoid or alter the remaining obligations cl the parties. 37. LAW OF PENNSYLVANIA APPLICABLE. This Agreement shall be construed In accordance with the laws 01 the Commonwealth of Pennsylvanlao 31. HEADINGS NOT PART OF AGREEMENT. Any heading preceding the text 01 the several paragraphs and subparagraphs hereol, are Ineerted solely lor convenience 01 reference and shall not constitute a part 01 this Agreement nor shall they affect Its meanlngo construction or effect. BY SIGNING THIS AGREEMENT, EACH PARTY ACKNOWLEDGES HAVING READ AND UNDERSTOOD THE ENTIRE AGREEMENTo AND EACH PARTY ACKNOWLEDGES THAT THE PROVISIONS OF THIS AGREEMENT SHALL BE AS BINDING UPON THE PARTIES AS IF THEY WERE ORDERED BY THE COURT AFTER A FULL HEARING. 18 . .' '.1 IN WITNESS WHEREOF, the parties hereto have set their hands and seals the day and year first above wrllteno WITNESS: 19 , , It . 0" STATE OF PENNSYLVANIA ( ( COUNTY OF CUMBERLAND (SS. On thlso the ;)(\0 day of 1f)'ZU.J1 0 20000 before me the undersigned officer, personally appeared Julia L. Holtz known to me (or sallsfaclorlly proven) to be the person whose name Is subscribed to the within Instrument, and acknowledged that he executed the same for the purposed therein contained. IN WITNESS WHEREOFo I have hereunto set me hand and seal. ~unLfl!aId- () NOTARIAL llEAI. L TNINY 8. FAUST, NolIIy NlIIc owor Allen r.p.. CumbtrtIixI CcxIIIv My Commlulon EJplrN June 22. 2(Q! STATE OF PENNSYLVANIA ( ( COUNTY OF ( SS. On thlso thec11~ay of ~ n ~ 020000 before me the undersigned officero personally appeared Jeffreyftoltz known to me (or sallsfactorlly proven) to be the person whose name Is subscribed to the wllhln Instrument, and acknowledged that she executed the same for the purposed therein contained. IN WITNESS WHEREOFo I have hereunto set me hand and seal, ,-r.,....... .. -....... ---"r" ~..' ," " ..., ''t'. ... ' .. ..,.1-:'; .1.. .' All I."' 20 JULIA LYNN HOL TZo Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTYo PENNSYLVANIA o o : NOo 95-4489 CIVIL TERM V. JEFFREY ALAN HOLTZ. Defendant . . : CIVIL ACTION. LAW : IN DIVORCE NOTICE OF ELECTION TO RESUME PRIOR NAME Notice Is hereby given thato a flnal decree In divorce having been granted on June 22, 2000, Plaintiff hereby elects to resume her prior name of Julia Lynn Boyanowlkl. and glvee thle written notice of her Intention In accordance with the provlslone of 54 Pa.C.S. 7040 -1utJrf ~ Julia Lo Holtz to be known al .-JJtA~:P P&.dL' Julia L. BoyanoWI Date: 3J-J"'~1 STATE OF ( ( COUNTY OF ( SS. ;}.li-r,'I-9'7"1 Ollthls,thtl 30 n. day 0140 LL.I 02001, befole me the undersigned officer, personally appeared Julia L. Holtz known to me (or sallsfactorlly proven) to be the person whose name Is sublcrlbed to the within Instrumento and acknowledged that she executed the same for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and seal. ~s.~~~ No ry Public NOTARIAL SEAL JODY S SMITH NOTARY PUBLIC Carllslo BOlO. Cumberland County My Com~lnn Expllas April ~o 2005 1. l.-. .( - i G' ~ ,1.. o " 00 " ]:to 'i .... . ) .. .. o..,:i .. " t1i )- ..... ~ ~ , , ~ . A " '" JULIA LYNN HOLTZ. Plalnllff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY. PENNSYLVANIA V. JEFFREY ALAN HOLTZ, Defendant . : NO. 95.4489 CIVIL TERM o : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF SOCIAL SECURITY NUMBERS Plalntlffo Julia Lynn Holtz: Defendant: Jeffrey Alan Holtz: Social Security Number 217-64-9781 Social Security Number 061-64.9641 By:Ua,l DJJGr /&( II Chartel Rector 0 Eequlre 1104 Fernwood Avenue, Ste. 203 Camp Hili. PA 17011-6912 (717) 761-6101 Attorney for Plalnllff Date: 6/13/00 '.. In .. il; ..' ~ I; I. .. , I I {',; ..:: . ;..J;. ,'.. , ':-.i , Il. .'. ( " ) "j "r I "'::. i)) I J . " " .' '\/HI I .')l~ i :-'1 II (7~1 el I. I U U ..' tl o:a__ iii N-1lI i ~g- ~8~i~ hW ~ W ijl i!~~ ~