HomeMy WebLinkAbout02-4660
ANDREW L. SHOEMAKER,
Plaintiff,
IN THE COURT OF COMMON PLEAS
. CUMBERLAND COUNTY, PENNSYL VANIA
NO ()J. - 4~ fRo ~
v.
CIVIL ACTION - LAW
BETTY J SHOEMAKER,
IN DIVORCE
Defendant.
NOTICE TO DEFEND AND CLAIM RIGHTS
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims
set forth in the following pages, you must take prompt action. You are warned that if you fail to
do so, the case may proceed without you and a decree in divorce or annulment may be entered
against you by the Court. A judgment may also be entered against you for another 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 ground for the divorce is indignities or irretrievable breakdown of the
marriage, you may request marriage counseling. A list of marriage counselors is available in the
Office of the Prothonotary, Cumberland County Courthouse, Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF
PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT
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.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
Carlisle, P A 17013
(717) 249-3166
ANDREW L. SHOEMAKER,
Plaintiff,
. IN THE COURT OF COMMON PLEAS
· CUMBERLAND COUNTY, PENNSYLVANIA
v.
. NO: /I."'} 11/
\-"~ - 7"'(,. '"
BETTY J. SHOEMAKER,
. CIVIL ACTION - LAW
. IN DIVORCE
Defendant.
COMPLAINT IN DIVORCE
AND NOW, comes the Andrew L. Shoemaker, by and through his attorneys,
Mancke, Wagner & Tully and files the following Complaint in Divorce:
I. The Plaintiff, Andrew L. Shoemaker, is an adult individual currently
residing at 101 Lawrence Lane, Apt. #1, Carlisle, Cumberland County,
Pennsylvania,
2, The Defendant, Betty 1. Shoemaker, is an adult individual currently
residing at 18 Running Pump Road, Newville, Cumberland County, Pennsylvania.
3. Plaintiff and Defendant have both been bona fide residents of the
Commonwealth of Pennsylvania for at least six (6) months prior to the filing of this
Complaint.
4. Plaintiff and Defendant are husband and wife having been married on or
about October 12, 1985, in Shippensburg, Franklin County, Pennsylvania.
5, There have been no prior actions of divorce or annulment between the
parties in this or any other jurisdiction,
6. Neither Plaintiff nor Defendant are members of the Armed Forces of the
United States or any of its Allies,
7. Plaintiff has been advised of the availability of counseling and that he has
the right to request that the Court require both parties to participate in counseling.
8. The Plaintiff avers as grounds on which this action is based are:
A. That the marriage is irretrievably broken pursuant to ~3301(c) of the
Divorce Code;
B. That as of July 25, 2004, the parties will have lived separate and apart
for a period of at least two (2) continuous years pursuant to ~ 3301(d)
of the Divorce Code.
WHEREFORE, Plaintiff prays this Court to enter a Decree in Divorce.
-2-
COUNT I
EQUITABLE DISTRIBUTION
9, Paragraphs 1 through 8 above are incorporated herein by reference and
made a part hereof.
10. During the marriage, Plaintiff and Defendant have acquired various items
of marital property, both real and personal, which are subject to equitable
distribution under ~40 I of the Divorce Code of ] 980.
COUNT II
CUSTODY
11. Paragraphs 1 through 10 above are incorporated herein by reference and
made a part hereof.
]2. The parties are the natural parents of Jamie L. Shoemaker, born March
22,1988, and Nathan A. Shoemaker, born January 2,1991.
13. The Plaintiff herein is the natural father of the aforementioned children;
the Defendant herein is the natural mother of the aforementioned children.
-3-
14. For the last five (5) years, the children have resided with both Plaintiff
and Defendant at 18 Running Pump Road, Newville, Cumberland County,
Pennsylvania; but as of September 6, 2002, the son, Jamie, has resided primarily
with the Plaintiff, and the son, Nathan, primarily with the Defendant at the addresses
respectively contained in paragraphs 1 and 2 above.
15. The Plaintiff knows of no other party asserting custodial rights to either
of the children,
16, The children were born during wedlock.
17. Plaintiff believes and therefore avers that it is in the best interest of the
children for the parties to have shared legal custody of both children; primary
custody of Jamie L. Shoemaker in the Plaintiff herein, and primary custody of the
son, Nathan Shoemaker, in the Defendant herein.
18. Plaintiff further believes and avers that it is in the best interest of the
children to grant liberal and reasonable periods of partial custody of each of the two
children with each of the parents.
-4-
WHEREFORE, Plaintiff prays this Court to grant the relief requested,
Respectfully submitted,
Mancke, Wagner & Tully
B
. . ard Wagner, sqUire
I.D. #23103
2233 North Front Street
Harrisburg, P A 17110
(717) 234-7051
Attorneys for Plaintiff
Date: q/;'3/t))...
I I
-5-
VERIFICATION
I verify that the statements made in the foregoing
document 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,
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ANDREW L. SHOEMAKER
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v,
02-4660 CIVIL ACTION LAW
BETTY J. SHOEMAKER
DEFENDANT
IN CUSTODY
ORDER OF COURT
AND NOW,
Thursday, October 03, 2002
, upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator,
at 301 Market Street, Lemoyne, P A 17043 on Monday, November 04, 2002 at 12:30 PM
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.
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing.
FOR TIlE COURT,
By: Isl
Melissa P. Greevy. Esq. y
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans
with Disabilites 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 TIllS PAPER TO YOUR ATIORNEY AT ONCE. IF YOU DO NOT
HAVE AN ATIORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TIlE OFFICE SET
FORTIl BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP,
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 170 I 3
Telephone (717) 249-3166
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DEC~02
ANDREW L. SHOEMAKER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 02-4660 CIVIL TERM
v.
BETTY J. SHOEMAKER,
CIVIL ACTION - LAW
Defendant
IN CUSTODY
ORDER OF COURT
AND NOW, this -1 '1+-- day of December, 2002, upon consideration of the
attached Custody Conciliation Summary Report, it is hereby ordered and directed as
follows:
1. Legal Custody. The parties, Andrew L. Shoemaker and Betty J. Shoemaker,
shall have shared legal custody of the minor children, Jamie L. Shoemaker, born March 22,
1988, and Nathan A. Shoemaker, born January 2, 1991. Each parent shall have an equal
right, to be exercised jointly with the other parent, to make all major non-emergency
decisions affecting the children's general well-being including, but not limited to, all
decisions regarding their health, education and religion. Pursuant to the terms of Pa. C. S.
95309, each parent shall be entitled to all records and information pertaining to the children
including, but not limited to, medical, dental, religious or school records, the residence
address of the children and of the other parent. To the extent one parent has possession of
any such records or information, that parent shall be required to share the same, or copies
thereof, with the other parent within such reasonable time as to make the records and
information of reasonable use to the other parent.
2. Physical Custody. The following status quo physical custody parenting
arrangement will continue:
A. Jamie shall reside primarily with Father.
B. Nathan shall reside primarily with Mother.
C. Father shall have periOds of custody with both children on
Tuesdays overnight to Wednesday morning.
D. Mother shall have periods of custody with both children on
Wednesdays overnight to Thursday morning.
NO. 02-4660 CIVIL TERM
E. The parents shall alternate weekends from Friday after school
until Monday morning when the children are returned to school. Father's next
custodial weekend under this schedule shall commence on Friday, December
6 2002. Mother's next custodial weekend under this schedule shall
,
commence on Friday, December 13, 2002.
3. Christmas Holiday.
A. Christmas 2002 Custodial Plan. Father shall have custody for
the period from December 20th when school is dismissed through December
25th at 3:00 p.m. Mother shall have custody from December 25th at 3:00 p.m.
until January 1st at 3:00 p.m. Additionally, Mother shall have custody for
approximately four (4) hours to commence in the afternoon of December 22nd
2002 for the purposes of attending a family Christmas gathering with Mother's
extended family. Unless otherwise agreed, Father will provide transportation
to and from this gathering. Mother will contact Father when the activities for
the family celebration are concluded on December 22, 2002. Mother will
provide transportation incident to the custodial exchange at 3:00 p.m. on
Christmas Day by picking up the children at the home of the paternal
grandparents.
4. Telephone Calls. Each parent shall be entitled to receive telephone calls from
their children to occur between 8:00 a.m. and 10:00 a.m. on Saturday and Sunday of the
custodial parent's weekend. The children will initiate the call to the non-custodial parent.
5. The children will meet with a therapist, social worker or psychologist via
lnterworks, or another agreed upon provider, for the purposes of assisting the parents in
understanding and considering the children's wishes with regard to the parenting schedule
in the process that the parents must undertake in making the decisions about that schedule.
The funds necessary to pay for these services shall come from the parties' Gartmore Money
Market Account.
NO. 02-4660 CIVIL TERM
6. The Custody Conciliation Conference shall reconvene on Monday,
February 3, 2003 at 11 :00 a.m. at the office of the Custody Conciliator, Melissa Peel
Greevy, Esquire, 301 Market Street, Lemoyne, PA 17043.
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Dist: ~ P. Richard Wagner, Esquire, 2233 N. Front Street, Harrisburg, PA 17110
r/' Rebecca R. Hughes, Esquire, 60 W, Pomfret Street, Carlisle, PA 17013-3222
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Dye 2002
ANDREW L. SHOEMAKER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 02-4660 CIVIL TERM
v.
BETTY J. SHOEMAKER,
CIVIL ACTION - LAW
Defendant
IN CUSTODY
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE
1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the children who are the subject of this
litigation is as follows:
NAME DATE OF BIRTH
CURRENTLY IN THE CUSTODY OF
Jamie L. Shoemaker March 22, 1988
Nathan A. Shoemaker January 2, 1991
Father
Mother
2. A Custody Conciliation Conference was held on December 2, 2002 following
Father's September 27, 2002 filing of a Complaint in Custody. Present for the conference
were: the Father, Andrew L. Shoemaker, and his counsel, P. Richard Wagner, Esquire; the
Mother, Betty J. Shoemaker, and her counsel, Rebecca R. Hughes, Esquire.
3.
The parties reached an agreement in the ~
of an Order as attached.
Id-~/)J/) v
Date
~
Melissa Peel Greevy, Esquire
Custody Conciliator
:165957
FES 1 4 2003 ~
ANDREW L. SHOEMAKER,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
NO. 02-4660 CIVIL TERM
v.
CIVIL ACTION - LAW
BETTY J. SHOEMAKER,
IN CUSTODY
Defendant
ORDER OF COURT
AND NOW, this J-t>"""^ day of February, 2003, upon consideration of the attached
Custody Conciliation Summary Report, it is hereby ordered and directed as follows:
1. Leqal Custody. The parties, Andrew L. Shoemaker and Betty J. Shoemaker,
shall have shared legal custody of the minor children, Jamie L. Shoemaker, born March 22,
1988, and Nathan A. Shoemaker, born January 2, 1991. Each parent shall have an equal
right, to be exercised jointly with the other parent, to make all major non-emergency
decisions affecting the children's general well-being including, but not limited to, all
decisions regarding their health, education and religion. Pursuant to the terms of Pa. C. S.
95309, each parent shall be entitled to all records and information pertaining to the children
including, but not limited to, medical, dental, religious or school records, the residence
address of the children and of the other parent. This Order contemplates that the parties
shall share information, to include report cards, regarding the children's educational
progress. They shall additionally cooperate with providing each other with the opportunity
for input into educational decisions regarding the children, to include course selection. To
the extent one parent has possession of any such records or information, that parent shall
be required to share the same, or copies thereof, with the other parent within such
reasonable time as to make the records and information of reasonable use to the other
parent.
2. Physical Custody. The following status quo physical custody parenting
arrangement will continue:
A. Jamie shall reside primarily with Father.
B. Nathan shall reside primarily with Mother.
C. Father shall have periods of custody with both children on
Tuesdays overnight to Wednesday morning.
NO. 02-4660 CIVIL TERM
D. Mother shall have periods of custody with both children on
Wednesdays overnight to Thursday morning.
E. The parents shall alternate weekends from Friday after school
until Monday morning when the children are returned to school. Father's next
custodial weekend under this schedule shall commence on Friday, February
14, 2003. Mother's next custodial weekend under this schedule shall
commence on Friday, February 21, 2003.
3. Summer. To begin the first Friday and including the Friday that school is
dismissed, the custodial schedule shall be changed. The sequence of alternating weekends
shall remain the same. However, the schedule shall be modified as follows:
A. The parent with weekend custody shaU have custody from Friday
after work until Sunday no later than 10:00 p.m. In the event that it is
Mother's custodial weekend, her custodial period shall commence at 6:00 p.m.
The parent who did not have the custodial weekend shall have a period of
custody from Sunday at 10:00 p.m. until Monday at 10:00 p.m. .
4. Vacation. During the Summer school recess each parent shall be entitled to
two (2) nonconsecutive weeks of custody for the purpose of vacation. A week shall be
defined as seven (7) continuous calendar days. The parties shall provide each other with at
least thirty (30) days of their intended vacation plans. In the event that there is a conflict in
the vacations that have been planned, the party first providing written notice to the other
parent shall have the first choice of vacation time.
5. Holidays. The holiday schedule shall supercede the regular schedule.
A. Alternating holidays will be Memorial Day, Independence Day,
Labor Day and New Year's Day. In odd numbered years, Father will have
custody for Memorial Day and Labor Day and in even numbered years, Mother
will have custody for Memorial Day and Labor Day. In odd numbered years,
Mother will have custody for Independence Day and New Year's Day and in
even numbered years, Father will have custody for Independence Day and
New Year's Day. The custodial period for these holidays shall be defined as
follows: For Memorial Day, Independence Day and Labor Day, from 10:00
p.m. the evening before the holiday until 10:00 p.m. the day of the holiday. For
NO. 02-4660 CIVIL TERM
New Year's Day, the holiday shall be deemed to commence at 6:00 p.m. on
New Year's Eve and continue until 10:00 p.m. on New Year's Day.
B. Easter. Easter shall be divided into two segments, Segment A
and Segment B. Segment A shall be from Saturday before Easter at 9:00 p.m.
until 3:00 p.m. on Easter Sunday. Segment B shall be from 3:00 p.m. on
Easter Sunday until 9:00 p.m. on Easter Sunday. In odd numbered years,
Mother shall have Segment A and Father shall have Segment B. In even
numbered years, Mother shall have Segment B and Father shall have
Segment A.
C. Thanksqivinq. Thanksgiving shall be divided into two segments,
Segment A and Segment B. Segment A shall be from Wednesday after
school is dismissed until Thanksgiving Day at 3:00 p.m. Segment B shall be
from Thanksgiving Day at 3:00 p.m. until Friday following Thanksgiving at
10:00 p.m. In odd numbered years, Father shall have Segment A and Mother
shall have Segment B. In even numbered years, Father shall have Segment B
and Mother shall have Segment A.
D. Christmas. Christmas shall be divided into two segments,
Segment A and Segment B. Segment A shall be from Christmas Eve at 3:00
p.m. until Christmas Day at 3:00 p.m. Segment B shall be from Christmas Day
at 3:00 p.m. until December 26th at 10:00 p.m. In odd numbered years,
Mother shall have Segment A and Father shall have Segment B. In even
numbered years, Mother shall have Segment B and Father shall have
Segment A.
E. Mother's Day and Father's Day. The custodial period for these
holidays shall be from 10:00 p.m. the night before the holiday until 10:00 p.m.
the day of the holiday. Mother shall have custody of the children on Mother's
Day. Father shall have custody of the children on Father's Day.
F. Children's Birthdays. Provided that Mother does not have
custody on the children's birthdays, Mother shall have custody from after work
until 8:00 p.m. In the event that Jamie has a baseball game on his birthday,
Mother will take responsibility for getting him to the baseball game and
bringing him home afterwards.
NO. 02-4660 CIVIL TERM
6. Transportation. Transportation shall be shared by the parties by the parent
receiving custody providing transportation incident to the custodial exchange. When Father
is providing transportation, the custodial exchange shall occur at Mother's home. When
Mother is providing transportation, the custodial exchange shall occur at Father's place of
employment, unless otherwise agreed.
Dist:
BY
J.
p, Richard Wagner, Esquire, 2233 N. Front Street, Harrisburg, PA 17110
Rebecca R. Hughes, Esquire, 60 W. Pomfret Street, Carlisle, PA 17013-3222
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ANDREW L. SHOEMAKER,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
NO. 02-4660 CIVIL TERM
v.
CIVIL ACTION - LAW
BETTY J. SHOEMAKER,
IN CUSTODY
Defendant
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE
1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the children who are the subject of this
litigation is as follows:
NAME
DATE OF BIRTH
CURRENTLY IN THE CUSTODY OF
Jamie L. Shoemaker
Nathan A. Shoemaker
March 22, 1988
January 2, 1991
Father
Mother
2. A Custody Conciliation Conference was held on February 3, 2003 by
agreement of the parties which was reached at the Custody Conciliation Conference on
December 2, 2002. Present for the conference were: the Father, Andrew L. Shoemaker,
and his counsel, P. Richard Wagner, Esquire; the Mother, Betty J. Shoemaker, and her
counsel, Rebecca R. Hughes, Esquire.
3. The parties reached an agreement in the form of an Order as attached.
.2/; 'L-I 03 LA~;; / '-f.. ~
Date Melissa Peel Greevy, quire
Custody Conciliator
:200419
ANDREW L. SHOEMAKER,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL, ACTION - LAW
2002-4.)60 CIVIL TERM
BETTY J. SHOEMAKER,
Defendant
IN DIVORCE
PLAINTIFF'S AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
September 27, 2002.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have
elapsed from the date of the filing of the complaint.
3. I consent to the entry of a final decree in divorce.
4. I understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses if I do not claim them before a divorce is granted.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein made are subject to the penalties of 18 1>>a. C. S. Section 4904 relating to
unsworn falsification to authorities.
Date: November ~2004
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ANDREW L. SHOEMAKER,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2002-4660 CIVIL TERM
BETTY J. SHOEMAKER,
Defendant
][N DIVORCE
PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT
The defendant, being duly sworn according to law, deposes and says:
1. I have been advised of the availability of marriage counseling and understand that I
may request that the court require that my spouse and I participate in counseling.
2. I understand that the court maintains a list of marriage counselors in the Prothonotary's
Office, which list is available to me upon request.
3. Being so advised, I do not request that the cow1 require that my spouse and I
participate in counseling prior to a divorce decree being handed down.
I verify that the statements made in this affidavit are true and correct. 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.
Date: NovemberZ , 2004
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ANDREw.(. SHOEMAKER
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ANDREW L. SHOEMAKER,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLANJ[) COUNTY, PENNSYLVANIA
v.
CIVIJL ACTION - LAW
2002-41660 CIVIL TERM
BETTY J. SHOEMAKER,
Defendant
IN DIVORCE
DEFENDANT'S AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
September 27, 2002.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have
elapsed from the date of the filing of the complaint.
3. I consent to the entry of a final decree in divorce.
4. I understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses if I do not claim them before a divorce is grant'ed.
I verify that the statements made in this affidavit are true and correct. 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.
, 2004
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Date: November
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ANDREW L. SHOEMAKER,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2002-4660 CIVIL TERM
BETTY J. SHOEMAKER,
Defendant
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301(c) 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 expenses if I do not claim them before a divorce is grant(~.
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 filed with the
Prothonotary.
I verify that the statements made in this affidavit are true and correct. 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.
Date: November /
, 2004
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ANDREW L. SHOEMAKER,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLANO COUNTY, PENNSYLVANIA
v.
CIVIl, ACTION - LAW
2002-4660 CIVIL TERM
BETTY J. SHOEMAKER,
Defendant
IN DIVORCE
DEFENDANT'S MARRIAGE COUNSEL,ING AFFIDAVIT
The defendant, being duly sworn according to law, deposes and says:
1. I have been advised of the availability of marriage counseling and understand that I
may request that the court require that my spouse and I participate in counseling.
2. I understand that the court maintains a list of marriage counselors in the Prothonotary's
Office, which list is available to me upon request.
3. Being so advised, I do not request that the court require that my spouse and I
participate in counseling prior to a divorce decree being handed down.
I verify that the statements made in this affidavit are true and correct. 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.
Date: November I
, 2004
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ANDREW L. SHOEMAKER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAKD COUNTY, PENNSYLVANIA
vs.
NO. 02 - 4660 CIVIL
BETTY J. SHOEMAKER,
Defendant
IN DIVORCE
ORDER OF COURT
AND NOW, this
3^cL
day of ';tIUA f~b-I
2004, the economic claims raised in the proceedings having been
resolved in accordance with a marriage settlement agreement
dated November 1, 2004, the appointment of the Master is
vacated and counsel can file a praecipe transmitting the record
to the Court requesting a final decree in divorce.
BY THE COURT,
cc: ~. Richard Wagner
Attorney for Plaintiff
III
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MARRIAGE SETTLEMENT ~TREEMENT
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THIS AGREEMENT made this -L- day of November, 2004 by and between BETTY
J. SHOEMAKER, (hereinafter referred to as "WIFE") and ANDREW L. SHOEMAKER,
hereinafter referred to as "HUSBAND").
WITNESSETH:
WHEREAS, HUSBAND and WIFE were lawfully married on October 12, 1985, in
Shippensburg, Franklin County, Pennsylvania. HUSBAND filed a Complaint in Divorce in
Cumberland County, Pennsylvania, docketed at 2002-4660 Civil Term on September 27, 2002
and separated on July 24,2002. The parties hereto agree and covenant as follows:
1.
The parties intend to maintain separate and permanent domiciles and to live apart from
each other. It is the intent and purpose of this Agreement to set forth the respective rights and
duties of the parties while they continue to live apart from each other.
2.
The parties have attempted to divide their matrimonial property in a manner which
conforms to a just and right standard, with due regard to the rights of each party. It is the intent
of the parties that such division shall be final and shall forever determine their respective rights.
The division of existing marital property is not intended by the parties to constitute in any way a
sale or exchange of assets.
3.
Further, the parties agree to continue living separately and apart from the other at any
place or places that he or she may select as they have heretofore been doing. Neither party shall
molest, harass, annoy, injure, threaten or interfere with the other party in any matter whatsoever.
Each party may carry on and engage in any employment, profession, business or other activity as
he or she may deem advisable for his or her sole use and benefit. Neither party shall interfere
with the uses, ownership, enjoyment or disposition of any property now owned and not specified
herein nor property hereafter acquired by the other.
4.
The consideration for this contract and agreement is thc~ mutual benefit to be obtained by
both of the parties hereto and the covenants and agreements of each of the parties to the other.
The adequacy of the consideration for all agreements herein contained is stipulated, confessed,
and admitted by the parties, and the parties intend to be legally bound hereby.
Each party to the Agreement acknowledges and declares that he or she, respectively:
a. is represented by counsel of his or her own choosing;
b. is fully and completely informed of the facts relating to the subject
matter of this Agreement and of the rights and liabilities of the parties;
c. enters into this Agreement voluntarily after receiving advice of counsel;
d. has given careful and mature thought to the making of this Agreement;
e. has carefully read each provision of this Agretment; and
f. fully and completely understands each provision of this Agreement,
both as to the subject matter and legal effect.
This Agreement shall become effective immediately as of the date of execution.
2
5.
It is the pUIpose and intent of this Agreement to settle forever and completely the interest
and obligations of the parties in all property that they own separately, and all property that would
qualify as marital property under the Pennsylvania Divorce Code, Title 23, Section 401(e), and
that is referred to in this Agreement as "Marital Property", as between themselves, their heirs and
assigns. The parties have attempted to divide their Marital Property in a manner that conforms to
a just and fair standard, with due regard to the rights of each Party. The division of existing
Marital Property is not intended by the parties to constitute in any way a sale or exchange of
assets, and the division is being effected without the introduction of outside funds or other
property not constituting a part of the marital estate.
It is the further purpose of this Agreement to settle forever and completely any obligation
under the Pennsylvania Divorce Code relating to spousal support or alimony.
6.
Each party represents and warrants that he or she has made a full and fair disclosure to the
other of all of his or her property interests of any nature, including any mortgage, pledge, lien,
charge, security interest, encumbrance, or restriction to which amy property is subject. Each party
further represents that he or she has made a full and fair disclosure of all debts and obligations of
any nature for which he or she is currently liable or may become liable. Each further represents
and warrants that he or she has not made any gifts or transfers for inadequate consideration of
Marital Property without the prior consent of the other.
Each Party acknowledges that, to the extent desired, he: or she has had access to all joint
and separate State and Federal Tax Returns filed by or on behalf of either or both Parties during
marnage.
3
7.
REAL ESTATE: The parties own the two (2) tracts of land with improvements known
as 18 Running Pump Road, Newville, Pennsylvania 17241. HUSBAND agrees to convey his
right, title and interest in the properties to WIFE. WIFE agrees to immediately refinance the
mortgage into her own name within sixty (60) days of signing this Agreement.
8.
DEBTS: HUSBAND will be solely responsible for hils own debts. WIFE will be solely
responsible for her debts. HUSBAND will indemnify and hold hannless WIFE from all
obligation related to his debts. WIFE will be solely responsible and will indemnify and hold
harmless HUSBAND from any claim made against him related to her debts.
9.
SPOUSAL SUPPORT AND ALIMONY: The parties hereby agree that neither party
will pay spousal support prior to the divorce becoming final or any alimony after the divorce
becomes final.
10.
PERSONAL PROPERTY: The parties agree that the personal property shall be divided
as follows:
HUSBAND shall receive the following items:
a. The personal property in his possession;
b. His bank accounts;
c. Any life insurance policy owned by HUSBAND;
d. His employee benefits;
e. His insurance agency;
f. All his financial accounts;
g. Jamie's two (2) Gartmore accounts to be maintained by HUSBAND;
h. Jamie's bedroom furniture to be moved to HUSBAND'S address by
HUSBAND at HUSBAND'S expense; and
i. All joint financial accounts currently open in 1he names of the parties.
4
WIFE shall receive the following items:
a. The personal property in her current possession;
b. Her bank accounts;
c. Any life insurance policy owned by WIFE;
d. Her employee benefits;
e. All her IRA accounts;
f. The pop-up travel trailer to which HUSBAN]() will sign
over the title to WIFE;
g. The Nationwide life insurance policy owned by WIFE on the life of
HUSBAND;
h. The sum ofTen Thousand and no/100 ($10,000.00) Dollars upon the signing
of this Agreement; and
i. HUSBAND will transfer Nathan's two (2) Gartmore accounts over to WIFE.
The WIFE hereby waives all right and title which she may have in any personal property
of the HUSBAND. HUSBAND likewise waives any inter1est which he has in the personal
property of the WIFE. Henceforth, each of the parties shall own, have and enjoy independently
of any claim or right of the other party, all items of personal property of every kind, nature and
description and wherever situated, which are then owned or held by or which may hereafter
belong to the HUSBAND or WIFE with full power to the HUSBAND or the WIFE to dispose
of same as fully and effectually, in all respects and for all purposes as if he or she were
unmarried. Each party agrees that neither will incur obligations, liens or liabilities on account of
the other and that from the date of this Agreement, neither party shall contract or incur
obligations, liens or any liability whatsoever on account of the other.
11.
AUTOMOBILES:
a. HUSBAND agrees to waive any and all interest which he may
have in the automobiles in possession of the WIFE.
5
b. WIFE agrees to waive any and all interest which she may have
in the automobiles in possession of the HUSBAND.
They each waive any claim which they have in any automobiles owned by the other party.
12.
INSURANCE. EMPLOYEE AND OTHER BENE:FITS: The parties agree that any
life insurance policies on the life of HUSBAND or WIFE or any other employee benefits,
including but not limited to retirement, profit sharing or medical benefits of either party, shall be
their own. Unless otherwise specified, WIFE waives all right, title and claim to HUSBAND'S
employee benefits and his insurance business, and HUSBAND waives all right, title, and claim
to any of WIFE'S employee benefits and her own business investements.
13.
BENEFITS AND BANK ACCOUNTS: WIFE agrees to waive all right, title and
interest which she may have in the savings or checking or any other bank accounts of the
HUSBAND. The HUSBAND agrees to waive all interest which he may have in the savings or
checking or any other bank accounts of the WIFE.
14.
DIVORCE: The parties both agree to cooperate with each other in obtaining a final
divorce of the marriage. It is agreed that the parties will execute and file the consents necessary
to obtain the divorce. Any party who fails to cooperate with obtaining the Divorce shall pay all
the costs and legal fees of the party who is seeking the divorce.
6
15.
BREACH: If either party breaches any provisions of this Agreement, the other party
should have the right, at his or her election, to sue for damages for such breach or seek such other
remedies or relief as may be available to him or her, and the party breaching this contract will be
responsible for payment of legal fees and costs incurred by the other in enforcing their rights
under this Agreement.
16.
ADDITIONAL INSTRUMENTS: Each of the parties shall from time to time, at the
request of the other, execute, acknowledge and deliver to the other party any and all further
instruments that may be reasonably required to give full force and effect to the provisions of this
Agreement.
17.
VOLUNTARY EXECUTION: The provisions of this Agreement and their legal effect
have been fully explained to the parties by their respe:ctive counsel, and each party
acknowledges that the Agreement is fair and equitable, and that it is being entered into
voluntarily, and that it is not the result of any duress or undm: influence. The provisions of this
Agreement are fully understood by both parties and each party acknowledges that the Agreement
is fair and equitable, that it is being entered into voluntarily, and that it is not the result of any
duress or undue influence.
18.
ENTIRE AGREEMENT: This Agreement contains the entire understanding of the
parties and there are no representations, warranties, covenants or undertakings other than those
expressly set forth herein.
7
19.
APPLICABLE LAW: This Agreement shall be construed under the Laws of the
Commonwealth of Pennsylvania.
20.
PRIOR AGREEMENTS: It is understood and agreed that any and all property
settlement agreements which mayor have been executed prior to the date and time of this
Agreement are null and void and of no effect.
21.
PAYMENT OF COSTS AND LEGAL FEES: The parties agree to pay for their own
costs and legal fees required to obtain and complete the divorce.
22.
WAIVER OF CLAIMS AGAINST ESTATES: Except as herein otherwise provided,
each party may dispose of his or her property in any way, and each party hereby waives and
relinquishes any and all rights he or she may now have or hereafter acquire, under the present or
future laws of any jurisdiction, to share in the property or the estate of the other as a result of the
marital relationship, including without limitation, dower, courtesy, statutory allowance, widow's
allowance, right to take in intestacy, right to take against the W'ill of the other, and right to act as
administrator or executor of the other's estate, and each will, at the request of the other, execute,
acknowledge and deliver any and all instruments which may be necessary or advisable to carry
into effect this mutual waiver and relinquishment of all such interests, rights and claims.
8
IN WITNESS WHEREOF, the parties hereunto hav€: set their hands and seals the day
and year first above written.
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. SHOEMAKER
(SEAL)
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~/ ANDREW L~ MAKER
9
COMMONWEALTH OF PENNSYLVANIA
SS:
COUNTY OF CUMBERLAND
.~
PERSONALLY APPEARED BEFORE ME, this _ J.4 day of November, 2004, a
Notary Public, in and for the Commonwealth of Pennsylvania and County of Cumberland,
BETTY J. SHOEMAKER, known to me (or satisfactorily proven) to be the person whose name
is subscribed to the within Marriage Settlement Agreement, and acknowledges that she executed
the same for the purposes therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and official seal.
COMMONWEALTH OF PENNSYLVANIA
NolartaI Seal
Mdla L Noel, NoIary Public
CaItisIe 8010. On1beI1atld County
My CommIssIon Expires Sept 18, 2007
Member, Pennlylvanla Association Of Notaries
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COMMONWEALTH OF PENNSYLVANIA
SS:
COUNTY OF CUMBERLAND
t):f;;.,.,
PERSONALLY APPEARED BEFORE ME, this 2__ day of November, 2004, a
Notary Public, in and for the Commonwealth of Pennsylvlmia and County of Cumberland,
ANDREW L. SHOEMAKER, known to me (or satisfactorily proven) to be the person whose
name is subscribed to the within Marriage Settlement Agre;ment, and acknowledges that he
executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and official seal.
COMMONWEAl. TH OF PENNSYLVANIA
NotM8I Se8I
..... L Noel. Nc*ryP\.dC
CaI1IsIe 8010. Q.mbII18lId CCLrlty
My Com ,iIIIan ElcpN Sept. 18, 'JJX1'I
Member, Pennlylvania AllOCIlllon Of NcUtI..
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Columbus OH 43218-2205
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ANDREW L SHOEMAKER
CUST NA THAN A SHOEMAKER
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18 RUNNING PUMP AD
NEWVILLE PA 172419684
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Maintenance Statement
10/12/2004
Page 1 of 1
Dealer Number:
Branch Number:
Rep. Number:
99999
999999999
999999999
Dealer Address
NATIONWIDE SECURITIES INC.
CO-Q5-23
5525 PARK CENTER CIRCLE
DUBUN OH 43017
R CUSTOMER SERVICE:
~ INTERNET:
1-800-848-0920
wwW.gartmorefunds.com
This statement is being provided to you for recent updates made to your aCcourtt. Please review this document for
accuracy. Any necessary corrections should be noted directly on the form. Plea:se Initial any changes and return the
form in the envelope enclosed for your convenience. If no additional co"ection!l are needed. this form may be retained
for your records. Should you have any questions or concerns, feel free to contal:t a Service RepresentatiVe at the
number listed above.
ACCOUNT UPDATE
Account Number:
Account Owner:
2330036607
ANDREW L SHOEMAKER
CUST NATHAN A SHOEMAKER
UGMA .p
321 UNION HALL RD
CARLISLE PA 17013-8300
The registration for the above account has been updated with the following information.
Former Registration
ANDREW L SHOEMAKER
CUST NATHAN A SHOEMAKER
UGMA -P
18 RUNNING PUMP RD
NEWVILLE PA 172419684
New Registration
ANDREW L SHOEMAKER
CUST NATHAN A SHOEMAKER
UGMA -P
321 UNION HALL RD
CARLISLE PA 17013-8300
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ANDREW L SHOEMAKER
CUST NATHAN A SHOEMAKER
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18 RUNNING PUMP RD
NEWVILLE PA 172419684
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Maintenance Statement
10/12/2()04
Page 1 of 1
Dealer Number:
Branch Number:
Rep. Number:
99999
999999999
999999999
Dealer Address
NATIONWIDE SECURITIES INC.
Co-05-2:3
5525 PARK CENTER CIRCLE
DUBLIN OH 43017
R CUSTOMER SERVICE:
m!j INTERNET:
1.800.848-0920
www.gartmorefunds.com
This statement is being provided to you for recent updates made to your aCcourllt. Please review this document for
accuracy. Any necessary corrections should be noted directly on the form. Plealse initial any changes and return the
form in the envelope enclosed for your convenience. If no additional corrections: are needed, this form may be retained
for your records. Should you have any questions or concerns, feel free to contae:! a Service Representative at the
number listed above.
ACCOUNT UPDATE'
Account Number:
Account Owner:
1330038600
ANDREW L SHOEMAKER
CUST NATHAN A SHOEMAKER
UGMA .p
321 UNION HALL RD
CARLISLE PA 17013-8300
The registration for the above account has been updated with the following information.
Former Registration New Registration
ANDREW L SHOEMAKER
CUST NA THAN A SHOEMAKER
UGMA -P
18 RUNNING PUMP RD
NEWVILLE PA 172419684
ANDREW L SHOEMAKER
CUST NATHAN A SHOEMAKER
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321 UNION HALL RD
CARLISLE PA 17013-8300
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ANDREW L. SHOEMAKER,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLV IA
Plaintiff,
v.
NO:
2002-4660 CIVIL
CIVIL ACTION - LAW
BETTY J. SHOEMAKER,
IN DIVORCE
Defendant.
CERTIFICATE OF SERVICE
I, Debra K. Spinner, Secretary in the law firm of MANCK
WAGNER and SPREHA, do hereby certify that on this date a cop
the COMPLAINT IN DIVORCE was served upon the following perso
in the manner indicated below, which service satisfies the
requirements of the Pennsylvania Rules of Civil Procedure, b
depositing the same in the United States mail, Harrisburg,
Pennsylvania, certified, restricted delivery, return receipt
requested, and addressed as follows:
,
of
and
Ms. Betty J. Shoemaker
18 Running Pump Road
Newville, PA 17241
By
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Debra K. r, Secretary
MANCKE, WAGNER & SPREHA
2233 North Front Street
Harrisburg, PA 17110
P. Richard Wagner, Esquire
Attorney for Plaintiff
DATE: 10/05/02
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item 4 jf Restricted Delivery is desired.
. Print your name and address on the reverse
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. Attach this card to the back of the mailpiece,
or on the front if space permits.
1. ~:icle Ad~ressed. to: ./ J ~
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.~\\- ~r."err-ake"
C. Signatu
O. Is delivery address different from item 1?
If YES, enter delivery address below:
o Agent
o Addressee
DYes
o No
3. . Service Type
)i Certified Mail
o Registered
o Insured Mail
o Express Mail
o Return Receipt for Merchandise
DC.a.o.
2. Article Number
(Transfer from service label)
PS Form 3811, March 2001
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Domestic Return Receipt
102595-01-M-142&
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ANDREW L. SHOEMAKER,
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYL V IA
Plaintiff,
v.
: NO: 2002-4660 - CIVIL TERM
: CIVIL ACTION - LAW
BETTY 1. SHOEMAKER,
: IN DIVORCE
Defendant.
PRAECIPE TO TRANSMIT THE RECORD
TO THE PROTHONOTARY:
TRANSMIT the record, together with the fullowing infonnation, to the Court for entry of a
Divorce Decree:
1. Ground for divorce: irretrievable breakdown under Section 3301(c), Y.l61(.1) of the Divor
Code. (Strike out inapplicable section.)
2. Date and manner of service of the Complaint: October 5, 2002, certified mail, restricted
delivery, return receipt requested.
3. (Complete either paragraph (a) or (b):
(a) Date of execution of the Affidavit of Consent required by Section 3301(c) of
Divorce Code: By Plaintiff: November 2, 2004
By Defendant: November 1,2004
(b)
(I)
Date of Execution of the Plaintiff's Affidavit required Section 330l(d) f
the Divorce Code: NIA
(2) Date of service of the Plaintiff's Affidavit unto the Defendant:
4. Related claims pending: None
5. (Complete ether (a) or (b).)
(a) Date and manner of service of the Notice ofIntention to File Praecipe to Transmi
the Record, and attach a copy of said Notice under Section 330 I (d) (l)(i) of the
Divorce Code:
(b) Date Plaintiff's Wavier of Notice was filed with the Prothonotary: 11102/04
(c)
Date Defendant's Waiver of Notice was filed with the "prothonotary: 11102/04
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IN THE COURT OF COMMON PLEA
OFCUMBERLANDCOUNTY
STATE OF
PEN NA,
ANDREW L. SHOEMAKER
No, 2002-4660 CIVIL
.
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.
VERSUS
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BETTYJ.SHOEMAKER
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DECREE IN
DIVORCE
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N ~ \ V JtiJf , IT IS ORDERED
ANDREW L. SHOEMAKER
AND NOW,
ND
DECREED THAT
, PLAI NTI FF,
BETTY J, SHOEMAKER
.
.
.
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.
AND
, DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY,
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THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH AVE
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS OT
VET BEEN ENTERED;
NONE
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