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Clark County, Ohio
FILED
APR 22 2024
Common Pleas Court
Melissa M. Tuttle, Clerk
IN THE COMMON PLEAS COURT OF CLARK COUNTY, OHIO
DOMESTIC RELATIONS DIVISION
MARK LORD Case No. 24050 1 62
513 High Street
Waynesville, Ohio 45068
DOB: 11/04/1959
Judge
First Petitioner,
-VS.-
PATRICIA LORD PETITION FOR DISSOLUTION
5411 Ridgewood Road, East
Springfield, Ohio 45503
DOB: 04/15/1970
Second Petitioner.
Now comes Petitioners and hereby state as follows:
The Petitioners have been residents of the State of Ohio for at least six months, and
Second Petitioner, the County of Clark for at least ninety days, immediately preceding the
filing of this Petition. The parties agree to venue of this matter in Clark County.
Petitioners were married on May 22,1999, and there was one minor child born as issue of
said marriage, to wit, Philip Lord born June 12, 2009. Second Petitioner is not currently
pregnant. The parties are incompatible and have been separated since July 31, 2001.
Petitioners have agreed to and executed a Separation Agreement providing for a division
of all property, liabilities, spousal support, attorney fees, tax matters, and all rights related
to their minor child, as as any and all other matters, and the Separation Agreement is
attached hereto and incorporated herein.
WHEREFORE, the parties petition the Court for a Decree of Dissolution of their marriage,
incorporating their separation agreement.
Respectfully submitted
O
\ onboy II (0070073
ney for First Pe loner
Sta , Fisher& Caf boy L P
5613 Brandt Pike
Huber Heights, Ohio 45424
Phone: (937) 237-9485
Facsimile: (937) 237-1978
Email: aventconboy:u aol.com
LPO e ee
Mark Lord st Pet! oner
Nt aa tor
icia Lord, SecéndP ‘etitioner
SEPARATION AGREEMENT
This Agreement is made and entered into voluntarily at Clark County, Ohio
between Petitioner Patricia Lord (hereinafter referred to as “Wife”), and Petitioner Mark
Lord (hereinafter referred to as “Husband”).
Petitioners were married on May 22, 1999 and there was minor child born as issue
of said marriage to wit: Philip Lord born June 12, 2009. Wife is not currently pregnant.
The parties have been living separate and apart since July 31, 2001.
Due to differences that have arisen between them, the parties are incompatible.
Accordingly, the parties express and confirm their intention to terminate their marriage.
By this agreement the parties provide for a division of all property, marital or separate,
and their own rights and responsibilities, including each parties’ right to support and
maintenance.
Mark Lord has been independently advised by counsel of his rights, duties and
obligations and of the legal and practical effects of this agreement, and Patricia Lord has
been advised of her right to counsel and has declined the same. Each party has thoroughly
reviewed and fully understands all of the provisions of this Agreement and acknowledges
that it is fair and equitable.
Each party attests: (1) that prior to the execution of this Agreement, he or she has
fully disclosed and revealed to the other identification, fair market value, and location of
all separate and marital assets and liabilities; (2) that this full disclosure is a material
consideration of this Agreement; and (3) that in reliance upon this full disclosure, he or
she knowingly and voluntarily waive his or her right to discovery available in a divorce
action.
If it is later discovered that either party has possession or control of, or has
disposed of by gift or conveyance any undisclosed beneficial interest in any property,
such party on demand shall transfer and assign to the other party the sum equal to one-
half interest therein, or shall pay to the other party the sum equal to one-half of the fair
market value of said beneficial interest.
NOW THEREFORE, in consideration of the mutual promises and covenants
herein contained, it is hereby agreed by and between the parties as follows:
I SEPARATION
Each party shall hereinafter continue to live separate and apart from the other for the
rest of their natural lives and shall not interfere with the other party’s right to quiet
enjoyment and peaceful living. Each party releases the other from all duties of
cohabitation and fidelity. Neither party will molest, harass, interfere with or annoy the
other in any manner, directly or indirectly.
Il. CUSTODY
Mother will be the legal custodian of the parties’ minor child.
Ml. PARENTING TIME
Father will exercise parenting time with the minor child as agreed to by the parties. If
there is no agreement the parties will follow the Court’s standard order of parenting
time. The Court’s standard order of parenting time is attached hereto and incorporated
herein by reference as if fully set forth herein.
Iv. CHILD SUPPORT
There will be no child support paid by either party. The parties will be equally
responsible for any costs associated with the minor child.
Vv MEDICAL COVERAGE
Mother has access to health insurance for the minor child at a reasonable cost.
The parties will be equally responsible for any uninsured medical, dental,
orthodontal, and optical expenses as set forth above. Health insurance for the parties’
minor children is addressed in the parties’ shared parenting plan.
VI. INCOME TAX EXEMPTION/TAX DEDUCTION
The parties will file their taxes separately for the 2024 tax year and all subsequent tax
years. The parties will alternate claiming the minor child for tax purposes with Mother
claiming the child even years and Father claiming the minor child in odd years.
VIL. SPOUSAL SUPPORT
There will be no spousal support paid by either party. The Court will not retain
jurisdiction over the issue of spousal support.
Vill. MARITAL RESIDENCE
There was no real estate purchased or acquired during the marriage.
IX. MOTOR VEHICLES
Each party will retain the vehicles currently in their possession and control free and
clear of any claim by the other party. Both parties will execute all documentation
necessary to relinquish any rights to vehicles they are not retaining. The parties will
assume the debt on their respective vehicles they maintain and hold the other party
harmless.
X. HO SEHOLD GOODS
Each party will keep the personal property and household goods currently in their
possession and control.
XI. FINANCIAL ACCOUNTS
Each party will keep the accounts in their individual names free and clear of any
claim by the other party.
XII. DEBTS
Each party will be responsible for the debts in their name, as well as the specific debts
set forth and assigned herein, and hold the other party harmless. Neither party will
accumulate debt in the other parties’ name.
XU RETIREMENT ACCOUNTS
Each party will keep the retirement accounts in their individual names free and clear
of any claim by the other party, if any.
XIV. COURT COSTS/ATTORNEY FEES
Husband will pay the court costs in this matter. Each party will be responsible for
their own attorney fees.
XV. SEVERABILITY
If any provision or clause in this Agreement is held invalid, such invalidity shall not
affect any other provision of this Agreement.
XVI. APPLICA! LAW
All of the provisions of this Agreement shall be construed and enforced in accordance
with the laws of the State of Ohio.
XVII. MODIFICATION AND WAIVER
A modification or waiver of any of the provisions of this Agreement shall be effective
only if made in writing and executed with the same formality as this Agreement. The
failure of either party to insist upon strict compliance of any of the provisions of this
Agreement shall not be construed as a waiver.
ne
XVIII. INCORPORATION IN FINAL DECREE
This Agreement is made in contemplation that the parties will seek a dissolution of
their marriage, and it, along with any written amendments, with the approval of the
Court, shall be made part of any final dissolution decree. This Agreement shall remain in
effect as a binding contract on both parties even if the Court should deny the petition for
dissolution.
XIX. IMPLEMENTATION OF AGREEMENT
A. Upon the signing of this Agreement, each party shall deliver to the other party, or
permit the other party to take possession of all property to which he or she is
entitled under the terms of this Agreement.
Within thirty days of the Decree of Dissolution, each party shall sign and deliver
all deeds, conveyances, titles, certificates and other documents necessary to
effectuate all of the terms of this Agreement. Upon failure of either party to
execute and/or deliver any such deeds, conveyances, titles, certificates or other
documentation to the other party, this Agreement shall constitute and operate as
such properly executed document, and the county auditor and/or county recorder
and/or any and all public and private officials, shall be hereby authorized and
directed to accept this Agreement or properly certified copy of this Agreement, in
lieu of the document regularly required for such conveyance or transfer.
Mark and Patricia Lord hereby acknowledge their agreement with the provisions
of this Separation Agreement and all of the terms of this Agreement represent and
constitute the entire understanding , along with the Separation Agreement, between the
parties, and that each party has read this Agreement and finds the same to be in
accordance with his or her understanding, and that each does hereby voluntarily execute
this Agreement with the understanding that it shall be final and binding upon both parties,
their heirs, devisees, legatees, executors, beneficiaries, administrators, representatives and
assigns.
IN WITNESS WHEREOF, the parties have affixed their signatures on this
Separation Agreement on this 6 day of 2024.
— fA [7
py
Witness
Ree
1
ZN
1 Pras
Witness Patricia Lord
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Clark County, Ohio FILED APR 22 2024 Common Pleas Court Melissa M. Tuttle, Clerk IN THE COMMON PLEAS COURT OF CLARK COUNTY, OHIO DOMESTIC RELATIONS DIVISION MARK LORD Case No. 24050 1 62 513 High Street Waynesville, Ohio 45068 DOB: 11/04/1959 Judge First Petitioner, -VS.- PATRICIA LORD PETITION FOR DISSOLUTION 5411 Ridgewood Road, East Springfield, Ohio 45503 DOB: 04/15/1970 Second Petitioner. Now comes Petitioners and hereby state as follows: The Petitioners have been residents of the State of Ohio for at least six months, and Second Petitioner, the County of Clark for at least ninety days, immediately preceding the filing of this Petition. The parties agree to venue of this matter in Clark County. Petitioners were married on May 22,1999, and there was one minor child born as issue of said marriage, to wit, Philip Lord born June 12, 2009. Second Petitioner is not currently pregnant. The parties are incompatible and have been separated since July 31, 2001. Petitioners have agreed to and executed a Separation Agreement providing for a division of all property, liabilities, spousal support, attorney fees, tax matters, and all rights related to their minor child, as as any and all other matters, and the Separation Agreement is attached hereto and incorporated herein. WHEREFORE, the parties petition the Court for a Decree of Dissolution of their marriage, incorporating their separation agreement. Respectfully submitted O \ onboy II (0070073 ney for First Pe loner Sta , Fisher& Caf boy L P 5613 Brandt Pike Huber Heights, Ohio 45424 Phone: (937) 237-9485 Facsimile: (937) 237-1978 Email: aventconboy:u aol.com LPO e ee Mark Lord st Pet! oner Nt aa tor icia Lord, SecéndP ‘etitioner SEPARATION AGREEMENT This Agreement is made and entered into voluntarily at Clark County, Ohio between Petitioner Patricia Lord (hereinafter referred to as “Wife”), and Petitioner Mark Lord (hereinafter referred to as “Husband”). Petitioners were married on May 22, 1999 and there was minor child born as issue of said marriage to wit: Philip Lord born June 12, 2009. Wife is not currently pregnant. The parties have been living separate and apart since July 31, 2001. Due to differences that have arisen between them, the parties are incompatible. Accordingly, the parties express and confirm their intention to terminate their marriage. By this agreement the parties provide for a division of all property, marital or separate, and their own rights and responsibilities, including each parties’ right to support and maintenance. Mark Lord has been independently advised by counsel of his rights, duties and obligations and of the legal and practical effects of this agreement, and Patricia Lord has been advised of her right to counsel and has declined the same. Each party has thoroughly reviewed and fully understands all of the provisions of this Agreement and acknowledges that it is fair and equitable. Each party attests: (1) that prior to the execution of this Agreement, he or she has fully disclosed and revealed to the other identification, fair market value, and location of all separate and marital assets and liabilities; (2) that this full disclosure is a material consideration of this Agreement; and (3) that in reliance upon this full disclosure, he or she knowingly and voluntarily waive his or her right to discovery available in a divorce action. If it is later discovered that either party has possession or control of, or has disposed of by gift or conveyance any undisclosed beneficial interest in any property, such party on demand shall transfer and assign to the other party the sum equal to one- half interest therein, or shall pay to the other party the sum equal to one-half of the fair market value of said beneficial interest. NOW THEREFORE, in consideration of the mutual promises and covenants herein contained, it is hereby agreed by and between the parties as follows: I SEPARATION Each party shall hereinafter continue to live separate and apart from the other for the rest of their natural lives and shall not interfere with the other party’s right to quiet enjoyment and peaceful living. Each party releases the other from all duties of cohabitation and fidelity. Neither party will molest, harass, interfere with or annoy the other in any manner, directly or indirectly. Il. CUSTODY Mother will be the legal custodian of the parties’ minor child. Ml. PARENTING TIME Father will exercise parenting time with the minor child as agreed to by the parties. If there is no agreement the parties will follow the Court’s standard order of parenting time. The Court’s standard order of parenting time is attached hereto and incorporated herein by reference as if fully set forth herein. Iv. CHILD SUPPORT There will be no child support paid by either party. The parties will be equally responsible for any costs associated with the minor child. Vv MEDICAL COVERAGE Mother has access to health insurance for the minor child at a reasonable cost. The parties will be equally responsible for any uninsured medical, dental, orthodontal, and optical expenses as set forth above. Health insurance for the parties’ minor children is addressed in the parties’ shared parenting plan. VI. INCOME TAX EXEMPTION/TAX DEDUCTION The parties will file their taxes separately for the 2024 tax year and all subsequent tax years. The parties will alternate claiming the minor child for tax purposes with Mother claiming the child even years and Father claiming the minor child in odd years. VIL. SPOUSAL SUPPORT There will be no spousal support paid by either party. The Court will not retain jurisdiction over the issue of spousal support. Vill. MARITAL RESIDENCE There was no real estate purchased or acquired during the marriage. IX. MOTOR VEHICLES Each party will retain the vehicles currently in their possession and control free and clear of any claim by the other party. Both parties will execute all documentation necessary to relinquish any rights to vehicles they are not retaining. The parties will assume the debt on their respective vehicles they maintain and hold the other party harmless. X. HO SEHOLD GOODS Each party will keep the personal property and household goods currently in their possession and control. XI. FINANCIAL ACCOUNTS Each party will keep the accounts in their individual names free and clear of any claim by the other party. XII. DEBTS Each party will be responsible for the debts in their name, as well as the specific debts set forth and assigned herein, and hold the other party harmless. Neither party will accumulate debt in the other parties’ name. XU RETIREMENT ACCOUNTS Each party will keep the retirement accounts in their individual names free and clear of any claim by the other party, if any. XIV. COURT COSTS/ATTORNEY FEES Husband will pay the court costs in this matter. Each party will be responsible for their own attorney fees. XV. SEVERABILITY If any provision or clause in this Agreement is held invalid, such invalidity shall not affect any other provision of this Agreement. XVI. APPLICA! LAW All of the provisions of this Agreement shall be construed and enforced in accordance with the laws of the State of Ohio. XVII. MODIFICATION AND WAIVER A modification or waiver of any of the provisions of this Agreement shall be effective only if made in writing and executed with the same formality as this Agreement. The failure of either party to insist upon strict compliance of any of the provisions of this Agreement shall not be construed as a waiver. ne XVIII. INCORPORATION IN FINAL DECREE This Agreement is made in contemplation that the parties will seek a dissolution of their marriage, and it, along with any written amendments, with the approval of the Court, shall be made part of any final dissolution decree. This Agreement shall remain in effect as a binding contract on both parties even if the Court should deny the petition for dissolution. XIX. IMPLEMENTATION OF AGREEMENT A. Upon the signing of this Agreement, each party shall deliver to the other party, or permit the other party to take possession of all property to which he or she is entitled under the terms of this Agreement. Within thirty days of the Decree of Dissolution, each party shall sign and deliver all deeds, conveyances, titles, certificates and other documents necessary to effectuate all of the terms of this Agreement. Upon failure of either party to execute and/or deliver any such deeds, conveyances, titles, certificates or other documentation to the other party, this Agreement shall constitute and operate as such properly executed document, and the county auditor and/or county recorder and/or any and all public and private officials, shall be hereby authorized and directed to accept this Agreement or properly certified copy of this Agreement, in lieu of the document regularly required for such conveyance or transfer. Mark and Patricia Lord hereby acknowledge their agreement with the provisions of this Separation Agreement and all of the terms of this Agreement represent and constitute the entire understanding , along with the Separation Agreement, between the parties, and that each party has read this Agreement and finds the same to be in accordance with his or her understanding, and that each does hereby voluntarily execute this Agreement with the understanding that it shall be final and binding upon both parties, their heirs, devisees, legatees, executors, beneficiaries, administrators, representatives and assigns. IN WITNESS WHEREOF, the parties have affixed their signatures on this Separation Agreement on this 6 day of 2024. — fA [7 py Witness Ree 1 ZN 1 Pras Witness Patricia Lord