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foregoing provision shull not be tuken us un udmission on the part of either purty of the
lawfulness or unlawfulness of the cuuses leuding to their living upurt.
2, "'II!I'I~l'l!lIn-: Euch purty shull be free from interl'crence, uuthority, un.! contuct by the
other, us fully as if he or she were single or unmurried except us muy be necessary to curry out
the provisions of this Agrcemcnt.
3. WilL' ',\ D,-hIS: Wil'c reprcsents und wurrants to Husbtllld that she will not contract or
incur any debts or Iiubilities for which Husbund or his estate might be responsible and shall
indemnify and save harmless Husband from any and all claims or demands mode ugainst him by
reason of debts or obligations incurred by her other than those debts incurred pursuant to any
sections of this Agreement.
4, HI/sballd's Dl!bts' lIusband represents and warrants to Wife that he will not contract
or incur any debt or liability for which Wife or her estate might be responsible and shall
indemnify and save harmless Wife from any and all claims or demands made against her by
reason of debts or obligations incurred by him other than those debts incurred pursuant to any
section of this Agrecment.
5. 01/1.111I11<[;111{ Jvilll Dl!hls: Thc parties acknowledge that they have no outstanding
joint debts other than the encumbrance on the real estate jointly owned by them located at 308
East North Street, Carlisle, Cumberland County, Pennsylvania. Should it be detcnnined that
there arc any outstanding joint debts following the execution of this Agreement and the
finalization of the divorce proceedings between the parties, the party who has established any
such debt through the authorization of any credit card, charge card, line of credit, penonalloan,
or any other debt, shall be solely and exclusively responsible for the repayment of that debt aad
shall indemnify and hold the other party harmless from and against any and all demanda lOr
payment or collection activity of any nature whatsoever,
, '.
the uloresuid Deed with counsel f(lr I/ushund f(lr copies of executed documents re/utive 10 the
refinancing of the 1II0rtguge indiculing und referellclng the filct IIHlt Wile is IW longer all obligee
ill the: utoresuid lIlortguge.
For ulld ill considerutioll of Wife's inlerest ill the ul()resuid relll eslute us well as ullY other
muriluJ Ussels to which Wile wuives here inlcresl hercln, I/usbund shull COlllpensute Wite in lhe
UIIIOUIll of TWO TllOlI.\:-lND I-''''/:' IIl1N1JRf;D AND XVI/()O (S},50i),flO) DOLLARS. This
puymelll of $2,500,00 shull occur no luter Ihun ninely (90) duys from the dute of e,xeeution of
this Agreement by IIusb,llld, Wile shull not be obliguted to deliver the uloresaid Deed until such
time us Husbund hus delivered the $2,500,00 payment as required here:in.
10. 11l.1'll/'wICL'. Relll'emelll, alld Olhel' Bellefils' The parties agree that neither party shall
make any duim of any nature whatsoever concerning (jny illsurance benefits, retirement benefits,
profit sharing accounts or other simiJur aCcounls or bene/its that are available to or accruing to
either pany,
II. Waive,. (If Claims "I'alllsl FI'/ate,\': Excepl as herein otherwise provided, eaeh party
may dispose of his or her property in any way, and eaeh party hereby waives and relinquishes
any and all rights he: or she may have or hereatler 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, Curtesy, statutory allowsnee. widow's
allowance:. right to lake in intestacy, right to take against the will of the other, and right to act 18
adminislralor or cxeeUlor of the other's estatl" und each will, at the request of the other, exetute,
acknowledge, und deliver any and ull instrUlllents which may be necessary or advisable to clIT)'
into effect this mutual wuiver and relinquishment of ull such interests, rights, and clallllf, TIIit,
paragraph sh.11I not uffect either party's right or power to expressly include the other party In-.:y
will or other document, whcther written in the past or in the future.
12. Brl.'l/clr: If cithcr purty brcuchcs uny provisiun uf this Agrccmcnt, thc othcr purty
shull huvc thc right, ut his ur hcr clcctiun, tu suc lor damugcs Illr such brcuch. or scck such othcr
rcmcdics or rclicf us muy bc available tu him ur hcr,
13, CUlIIls,,1 !-"',,s: Thc partics ugrcc thaI should u divur,'c action bc muintuincd by
eithcr of thc partics to dissolve thcir marriagc. ncithcr party shall makc u claim for counscl fccs
from thc othcr party, Both purtics havc bccn fully informcd of un acknowlcdgc their right to
mukc a claim for rcasonable cuunsel Iccs in thc prescntly pcnding divorcc procccdings, but
hcrcby makc a full. complctc and voluntary waivcr uf that right.
14. [o;,('<)/,cl.'/IIelll: Thc partics agrcc that this Agrccmcntmuy bc mude a part of any final
divorec order or dccrec cntcred in this case, This Agreemcntmay be incorporated in but shall
not bc mcrged with uny such ordcr or dccrcc, In lhc cvcnt cithcr party fails to comply with the
tcmls of this Agrecmcnt. the othcr party may cnforcc this Agreement by filing a Petition for
Contempt if a party brcaches this Agrecmcnt the othcr purty, in pursuing enforcement of the
Agreemcnt, shall bc entitlcd to Allornc} 's Ices form the breaching party,
IN WITNESS WHEREOF, thc parties hereunto scttheir hands and seals the day and year
firstmcntioncd above.
WITNESS:
tl-,S-q '1
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CRYSTAL C. ELEDGE,
Plaintill'
VK.
IN HIE COURT 01' COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION. L.AW
CHARLES ELEDGE,
Defendunt
NO, '16.22'15 nVIL. TERM
IN DIVORCE
PRAECII'E '1'0 TRANSMIT RECORD
To Ihe Prolhonolury:
Transmit Ihe record, togelher with the lllllowing infomJUlion to lhe coun for entry of a
divorce decree:
1. Ground for divorce:
Irretrievuble breakdown under *3301(c)
2. Date and munner of service of the Complaint: By Acceptancc of Service by Mauhew J.
Eshelman, Esquire on April 3D, 19'16,
3, Complete either puragraph (a) or (b),
(a) Dute of execution of Ihc affidavit of consent rcquired by *3301 (c) of the
Divorce Code:
by pluintiff: November 5, 1'199 by defendant: October 25, 1999
(b) (I) Date of execution of the allidavit required by *3301 (d) of the Divorce
Code:
(2) Dale of tiling and service of the plainlifl's allidavit upon Ihe responden!:
4. Related claims pending: None
5, Complete either (a) or (b),
(a) Dale and manner of service of the notice of inteotion 10 tile praecipe 10
tlunsmit record, a copy of which is ullachcd:
(b) Date of plaintiffs Waiver of Notice in *3301 (c) Divorce wus tiled with the
"
Prothonotary: Signed: November 5, 199'1
Filed: November 5, 1999
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CRYSTAL C. ELEDGE,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
.
.
v.
: CIVIL ACTION - LAW
: 96-,.,1]'t5'CIVIL TERM
CHARLES ELEDGE,
Defendant
IN DIVORCE
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 will
proceed without you and a decree of divorce or annulment may be
entered against you by the court. A judgment may also be enterad
against you for any other claim or relie,f 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 at Cumberland County Courthouse,
Carlisle, Cumberland County, Pennsylvania, 17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL
PROPERTY, LANYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT
IS GRANTED, YOU HAY 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 Court Administrator
4th Floor
CUmberland County Courthouse
Carlisle, Pennsylvania 17013
(717) 240-6200
\
CRYSTAL C, ELEDGE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
v.
CHARLES ELEDGE,
Defendant
96- ),:l, 'I," CIVIL TERM
IN DIVORCll
~PLAINT IN DIVORCE
COUNT I
1. Plaintiff is Crystal C. Eledge, an adult individual
currently residing at 308 East North Street, Carlisle, Cumberland
County, Pennsylvania. Ms. Eledge has lived at this
residence
for four years.
2. Defendant is Charles Eledge, an adult individual
currently residing at 308 East North Street, carlisle, Cumberland
county, pennsylvania.
Mr. Eledge has lived at this for
four years.
3. Plaintiff is a bona fide resident of the Commonwealth
of Pennsylvania
and has been so for at least six months
immediately previous to the filing of this Complaint.
4. Plaintiff and Defendant were married in August 1983 in
Reno, Nevada.
5. There have been no prior actions for divorce or
annulment between the parties.
6. The Defendant is not a member of the Armed Force. of the
United States of America or its Allies.
7. Plaintiff has been advised of the availability of
counseling and the right to request that the court require the
parties to participate in counseling.
Knowing this, Plaintiff
does not desire that the Court require the partie. to participate
in counseling.
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CRYSTALC. ELEDGE.
Plnintilr
VS,
: IN HIE COURT OF COMMON PLEAS OF
: CUMBERLANDCOlJNTY, PENNSYLVANIA
: CIVIL ACTION. LA W
CHARLES ELEDGE,
Defendant
: NO, 1)6-2295 CIVIL TERM
: IN DIVORCE
WAIVER (U' NOTICE OF INTENTION TO REQUI-:ST
I-:NTRY OF A I>IVORC[ I>ECREE
UNDER SI-:CTION 3301 Ie) OF TIlE U1VORCE CODE
I. I consent to the entry of a tinal decree in divorce without notice,
2. I understand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses if I do 110t claim them before a divorce is granted,
3. I understand that I will not be divorced ul1til a divorce decree is entered by the
Court and that a copy of the decree will be sent to me immediately after it is tiled with
the Prothonotary,
I VERIFY THAT HIE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT
ARE TRUE AND CORRECT, I UNDERSTAND THAT FALSE STATEMENTS
HEREIN ARE MADE SUBJECT TO TilE PENALTIES OF 18 Pu. C.S, 4904
RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES,
DATE: J J- c::' - q C)
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. ELEDGE, Plaintift' <:l
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VI,
: IN THE COUR OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
CRYSTALC, ELEDGE,
Plalntlft'
CHARLES ELEDGE.
Defendant
: NO, 96-229S CIVIL TERM
: IN DIVORCE
MflDA VIT UNDER St:CTION 330Ud) OF THE DIVORCE CODE
I. The parties to thillCtion separated on November 2, 19% and have continued to live
llepll'ate and apart for a period of at least two years,
2. The marriage is irretrievably broken,
3, I understand 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,
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa,C,S. ~ 4904 relating to unsworn
fallification to authorities,
Date: '-: - U! - r; '1
'/'
(!(r { lo11~ {l, E./!..ut2.rag
CRYS1ALc. ELEDGE, Plaintiff
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CRYSTAL C. ELEOOE,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLV ANJA
: CIVIL ACTION. LAW
vs,
CHARLES ELEDGE,
Defendant
: NO, 96.2295 CIVIL TERM
: IN DIVORCE
AFFlDA VIT OF SERVICE
AND NOW, this /i!ii day of I ['ll/l\.. ,1999, comes Bradley L. Griffie,
Elquire, attorney for Plaintiff. Crystal C, Eledge, and stales that he mailed by certified
mail, rutricted delivery, return receipt requested, a true and correct copy of the Plaintifrs
Affidavit Under Section 3301(d) of the Divorce Code, as luached, to Defendant, Charles
Eledge, which was received on March 13, 1999, as noted on the attached return receipt.
Respectfully submitted,
GRIFFIE & ASSOCIATES
II
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( or aintiff'
200 North Hanover Street
Carlisle, P A 17013
(717) 24J.S55 I
(800) 347-5552
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Sworn and 1U~lCribed
totlJis 17('(dayof,
/J(..Hd. ,199.
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CRYSTAL C. ELEDGE,
Plaintiff
IN Tm COURT OF COMMON PLEAS OF
CUMIlFRLANI) COUNTY. PENNSYLVANIA
,
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YOU SIIOULDTAKE TillS PAPER TO YOUR LAWYER AT ONCE. ,IF YOU DO :,
NOT IIA VI' A LAWYER OR CANNOT AFFORD ONE, GO TO OR TliLEPHON.B'ffla' ::
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN OETLEOALHILt;,",i' 1/",
Cumberland County Bar Association' ,:,;.I'it",\';'n!i:J/.:'~:,~:'i~:f{.)~tl"2;)i\;:iY;
Two Libcrty Avenue
Carlisle. Pennsylvania 17013
(717) 249.3166
v,
CIVIL ACTION -l.AW
CIIARLES ELEDGE.
Defenuant
NO. 'ih - 22')) CIVIL Tl'RM
IN IlIVOi{CI;
NOTICE TO UEFEND AND CLAIM RIGHTS
You have been sued in Court. If you wish 10 defend againslthe claims setl,JrIh in the
1l,IIoIVing pages. you must take prolllpt a.:tioll. You arc IVunled that if you Ihilto do so. the
case will procccd without you and a dccr.:e of divorce llI' annulmcnt may be entered against
you for any e1aim or relief r.:yuest.:d inth.:se papcrs by th.: Plaintiff, You llIay lose money or
property or other rights importalllto you. including cllstody or visitation of your children,
Wh.:n the ground l'or the divur.:c is indignities or irretrievable breakdown of the
marriagc, you may request marriage counseling, A list of marriage counselors is available in
the Oftice of the Prothonotary at Cumberland County Courthouse, Carlisle, Cumberland
Cuunty, Pcnl1sylvania. 17013.
IF YOU DO NOT FILE ^ CLAIM FOR ALIMONY, DIVISION OF MARITAL
PROPERTY. LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR
ANNULMENT IS CiRANTED. YOU MAY LOSE THE RIGHT TO CL,AIM ANY OF
TIII'M,
CRYSTAL C. ELEDGE,
Plaintiff
v,
IN HIE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
CHARLES ELEDGE,
Defendant
NO. l)6 -1295 CIVIL TERM
IN DIVORCE
I'
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PlnJTIQN FOil ECO~OMIC RELlE~
AND NOW comes Petitioner, Crystal C'. Elcdge. by and through her counsel of
record, Brndley L. Grime, Esquire. and Petitions the eOllrtas follows:
I. Your Petitioner tiled a Complaint in Divorce in the above captioned action on
April 29, 1996, which divorce action is still pel1ding, a copy of which Complaint
is hereto and incorporated herein by reference as Exhibit "A."
2. Despite ongoing, repeated. al1d extel1sive negotiations with the Defendant and
his counsel of record, a resolution of the economic aspects of this case have not
been reached,
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COUNTl
EQUITABLE DISTRIBUTION
-I
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3. Paragraphs I through 2 are incorporated herein by reference as if set forth in
their flllltext.
4. The partics are the joint owncrs of rcal estate located at 308 East North Street,
Carlisle, Cumberland County, Pennsylvania, which is marital property and
available for distribution,
5, The parties have marital personal property, both tangible and intanalblc.
available for distribution,
6, The parties bave incurred ccrtain debts during their marrilSo wlUch arc
appropriate for apportionment by the court.
"
CRYSTAL C. ELEDGE,
PlaintHf
IN THE COURT OF COMMON PLEAS or
: ctJKBERLAND COUNTY, P!NNS'lLVANIA
.
.
v.
.
.
CIVIL ACTION - LAW
96-.:J~'75' CIVIL TERM
IN DIVORCE
.
.
CHARLES ELEDGE,
Defendant
.
.
.
.
NOTICE TO DEFEND AND CLAIM RIGHTS
'lou have t1..n sued in court. If you wish to detend _liainst
the claiDul .et forth in the follovinq paqes, you lluat talc. proapt
action. You a.re warned that it you tail to do so, the ca.. vill
procH<l without you and ill decree ot divorc:e or annulaent _, be
entered aqainat you by the court. A judc;ment ..y al.o be antezed
aqainst you tor any other c:laim or relief requested in t!le..
papers by the Plaintitt. 'lou _y lo.e 1I0ney or property or other
rights important to you, inc:ludinq c:ustody or visitat:ion of your
children .
When the qround tor tha divClrc:e is indiliniti.. or
irretriavable braakdovn of th. urriaqe, you uy raque.t ..ni_li.
c:oun..linq. A list of urriaqe c:ounselors is availal:lle in the
OUic. of the Prothonotary at CUlG.rland county Courtboll.e,
earlisla, CUllQerlan4 County, pennsylvania, 17013.
Ill' YOU DO HOT FIIZ A CLADe FOR ALIXOIfY, OIVISION or ICAIlITAL
PROPER'l'Y, LAWYER'S FEES OR !:XPENSES BzrOU A OIVORCI OR AKN'CJUCDIT
IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY or THEIl.
YOU SHOULD TAD THIS PAPER TO 'lOUR LAW'lJ:R AT ONCI. IF YOO
00 NO'l' HAVE A LAWYER OR CANNOT AFl'ORD OHl:, ao TO OK TlLlPBOtfl '1'R:I
OFFICE SET FORTH BELOW '~O rIND OUT WHDJ: YOU CAN GET LltlAL BILl.
~': '_J
owaberland county Co~ A~ini.trator
4th rloor
cumberland county Courthou..
earlisl., Pennsylvania 17013
(717) 240-6200
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EXHIBIT uAu
CR~STAL C. ELEDGE, , IN THE COURT OF COMKON PLEAS OF
,
Plaintift. : CUHBERLANO COC'N'l'Y, PENNS~LVANtA
.
.
v. . CIVIL ACTION - LAW
.
: 96- j..l. rs
CHARLES ELEDGE, . CIVI:L TERM
.
Defendant , IN DIVORCE
.
COMPLAINT IN DIVORCE
COUNT I
1, Plaintitt is Crystal C. !lede;e, an adult individual
currently residine; at 308 East North street, carlisle, CUIII:lerlUld
County, Pennaylvania. Ma, Elede;e I:lu lived at this r_ic1uce
tor tour years.
2. Oefenclant is Charles !lec1ge, an ac1ult indivicltlal
currently resicUnc; at 308 hst North Street, carlisle, O""hotrlUld
County, Pennsylvania.
Mr, ! lec1ge has 1 i vec1 a t this for
four years.
3, Plaintiff is a 1:Iona fide resident of the Co-.onwe<h
of Pennsylvania
and has been so tor at least six months
immediately previous to the tiline; of this complaint.
", Plaintitt and Defendant ....ere lRarrild in Auqust 1983 in
Reno, Nevada.
5. There have been no prior action. tor divorc:e or
annulment bet....een the parties,
6. The Defendant is not a meml:ler of the Armed Forces ot the
United States of AIIIerica or its Allie..
7. Plaintitf has 1:Ieen advised of the availability of
c:ounseline; and the riqht to request that the court require the
partie. to participate in counseline;. Jtnowine; this, Plaintiff
doe. not d..ire that the Court require the partie. to participate
in coun.el ine; .
8, Plaintitt and C41rendllnt are citizen. ot the United
State. ot Aaerica.
9. The partie.' III&rria9a i. irretrievably broken.
10. Plaintitt d..ire. . divorce and it i. believael that
C41tanc!ant will atter ninety (90) day. tro. tha date ot the UliDg
ot thi. Ccmplaint conaent to this divorce,
pPD'UOU, Plai.ntitt raque.t.a your Honorable COUrt to enter
a Decree in Divorce ,WIder section 3301(c) ot the DOlIe.tic
ltaJ.atJ.oaa COcIa.
cot7II'r II
rKDrmnnu
..11. Paracp:apha 1 throU9h 10 are incorporatael haraiD by
reterence a. it .at torth in their tull text.
12. Detendant: h.. coui ttad auch ind,iqni tie. upon the
parson ot the Plaintitt, the innoc:ent injurael .pou.e, a. to lIAlca
her condition intolerabla and lite burd~Q.e.
WBl:RErOU, Plaintitt reque.e. your Honorable Court to
enter a divorce pur.uant eo 23 P,S. Section 3301(a) (6).
GRIllI! , ASSOC:IATIS
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Anne M. Shepa , Z. re
Attorney tor Plaintift
200 North Hanover Street
Carli.la, PA 17013
(717) 243-"51
1-CIOO) 347-!5!5!12
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CRYSTAL C. ELEDGE,
l'luintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
v.
CIIARLES ELEDGE,
Defcndnnt
NO, l)6 .2295 CIVIL TERM
IN DIVORCE
MOTION FO~ APPOINTMENT OF MASTER
AND NOW come Plaintiff, Crystal C. Elcdge. by and through her allomey of record,
Brudley L, Griffie, Esquire, nnd moves the court to appoint u Master with respect to the
following claims:
(x)
Divorce
(x)
Distribution of Property
( )
Al1nulment
( )
Support
(x)
(x)
Alimony
(x)
(x)
Alimony Pendente Lite
Counsel Fees
Costs and Expcnses
and in support of her Motion states:
I, Discovery is complete as to the duims for which the appointment of a Master
is requested.
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2.
The Defendant has appeared in this action by his allomey, Mallhew J,
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Eshelman, Esquire,
3. The Statutory grounds for divorce are 23 Pa.C.S,A. 3301(c) and/or 3301(d).
4. This action is contested with respect to the claims of Alimony, Costs and
Expenses, Distribution of Property. Counsel Fees, and Alimony Pendente Lite,
5, The action docs not involve complex issues of law or fact,
6. The hearing is expected to takc two days.
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CRYSTAL C, ELEDGE,
Plaintiff
t IN THE: COURT Of COMMON PLEAS Of'
t CUMBERLAND COUNTY, PENNSYLVANIA
t
VB.
NO. 96 - 2295 CIVIL
CHARLES ELEDGE,
Defendant
IN DIVORCE:
ORDER OF:peUR'f
AND NOW, this -l11!---- day
1999, the economic claims raised in the proceedings having
of jJtJJ
been resolved in accordance with a separation and property
settlement agreement dated November 5, 1999, 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,
CCt Bradley L. Griffie
Attorney for Plaintiff
P.J.
Matthew J, Eshelman
Attorney for Defendant
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SEPARATION AND PROPERTY 5ETTI.[:\[[:,/1' AGREEMENT
THIS AGREE~lENT made this Sill day of JJc~~ tJt:/
, 1999, by and
between CRYST,-\L C. ELEDGE. of 880 Eppley Road, Mechanicsburg, Cumberland County.
Pennsylvania (hereinafter referred to as "Wife"), BlId CHARLES ELEDGE, 308 East North.
Street, CB1'lisIe, Cumberland County, PeMsylvania (hereinafter referred to as "Husband").
WITNESSETH:
WHEREAS, Husband :md Wife were lawfully married on August !6, !983 in Reno,
Nevada.
WHEREAS, differences have arisen between HusbBlld and Wife in consequence of
which they have chosen to live separate and apart from each other; :md
WHEREAS, the parties acknowledge that they have had the opportunity to review the
provisions of this Agreement BlId further have had the opportunity to secure legal counsel and
advice relative to the legal effect of this Agreement. Tbe parties acknowledge that they have
either received independent legal advice from counsel of their own selection or that they have
relative to this Agreement. They further acknowledge that they fully understand the facts that
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specitically chosen with full knowledge and on their own volition, to not seek legal advice
are the basis of this Agreement. Tbey acknowledge md :lccept that it is being ~ntered into freely
and voluntarily, after having the opportunity to receive legal :ldvice :lnd WIth the knowledge that
execution of this Agreement is not the result of any duress or ur.Jue II1tluence, ,1Ild further that it
is not the result of the collusion or improper or ille':)al agreement or :lgreements.
~OW, THEREFORE, the parties hereto intenJing to be legally bound hereby do
covenant and agree:
l. S~[}aration' [t shall be lawrJI for each at all times hereafter to live separate and apart
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from the other party at such pl:lce as he or she may from time to time ~hoose or deem tit. The
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foregoing provision shall not be lllken as Illl admission on the part of either pany of the
lawfulness or unlawfulness of the C3uses le3ding to their living 3pnrt.
2, Interference: E3ch party sh311 be free t'rom interteren.;e, authority, and con!;1ct by the
other. as fully :IS if he or she were single or unrmmied except as may be necessary to carry out
the provisions of this Agreement.
3, W(fe '! Debts: Wife represents Illld Wl1lT3llts to Husband that she will not contract or
incur any debts or liabilities for which Husband or his est.'lte might be responsible and shall
indemnify and save hunnless Husband from any and all cl3ims or demands m3de 3gainst him by
reason of debts or obligations incurred by her other than those debts incurred pursuant to any
sections of this Agreement.
4, Husband'! DeblS' Husband represents 3lld warrants to Wife that he will not contract
or incur 3ny debt or liability for which Wite or her estate might be responsible and shall
indemnify 3nd save hunnless Wife from any and all claims or dem311ds made against her by
re3Son of debts or obligations incurred by him other than those debts incurred pursuant to any
section of this Agreement.
5, Owslandinv Joint Debl~ The parties acknowledge that they have no outstanding
joint debts other th3n the <:ncwnbrance on the re31 estate jointly owned by them located at 308
East :-iorth Street. Carlisle, Cumberland County, Pennsylvania, Should it be detennined that
there Jre any outstanding joint debts following the execution of this Agreement and the
tinJlizJtion or the divorce proceedings between the parties, the party who has est3blished any
such debt throu~h the authonzJtion of any credit card, charge card, line of credit, personal loan.
or any other debt, shall be solely and exclUSively responsible for the repayment of that debt and
shall indemnify and hold the other party hannless from and against any and all demands for
payment or collection activity of any nature whatsoever,
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6, J{ucua/ R~/~ase' Subj~ct to the provisions'ofthis Agreement, each pwty hIlS relellScd
and dischll/'ged, and by this Agreement does for himself or hmelf, and his or her heirs, legal
representatives, executors, administrators, and assigns, release and discharge the other of and
from all causes of action, claims. rights or d~mands, whatsoever in law or equity, which either of
the parties ever had or now hIlS against the othel, except any or all cause or cause$ of action lor
7. Alimoflv ~Um{)nv P€!ndentl! Lite. Spousal SUlJDor! clnd J,{aintenancE!' The parties
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divorce or any action to enforce this Agreement.
specifically are aware of, acknowl~dge and understand their right to demand alimony, alimony
pendente lite and support and hereby waive their right to these claims against the other puny
now and in the future. Both panies agree not to make a claim for alimony, alimony pendente lite
or support now, during any future divorce proceeding between the parties, or at anytime
thereafter.
8. Division Q,( Perrona/ ProCJerry' Th~ parties have divided their personal property to
their mutual satisfaction including personal effects, household furniture, furnishings, appliances.
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and all other articles of personal property. including automobiles, which have hereto tore been
used in common and neither will make any claim to any such items that are in the possession of
or under the control of the other party, In the event it IS necessary to execute any documents to
waive, relinquish or transfer ownership of any such items of personal property to the party In
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possession, the other party shall do so within tltieen 115) days or'be:ng ~equested to do so,
,
9, Divirion Q/ Real P"()o~ro-' The parties ,m )01nt o\\ners ,Jr' ~eal e:itate located Jt 308
East North Street, Carlisle. Cumberland County. Pennsylvania, Within SIXty 16')' da:.s of
I,
execution of this Agreement by both parties, Husband shall rerinance the mortgage due and
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owing on the aforesaid real estate to Chemical Bank. \Vife shall execute J. ipecla[ "'.lITanty. fee
simple Deed conveying all of her right. title and Interest ill the aroresald real estate :0 Husband
and said Deed shall be retamed in escrow by ,ounsel tor Wlte:. Counsel tor Wite: shal! ~x,hange
-
the aforesaid Deed with counsel for Husbanu for copies of executeu doeuments relative to the
retinancing of the mortgage indica,ting and referencing the fact that Wife is no longer an obligee
in the aforesaid mortgage.
For and in consideration of Wife's interest in the aforesaid real estate as well as :lilY other
mat1tul assets to which Wife waives here interest herein, Husband shall compensate Wife to the
amount of TWO THOUSAND FIVE HUNDRED ,-t;VD XX/lOO (51,500.00) DOLLARS. This
paymenl af S2,500,OO shall occur no later than ninety (90) days from the date af execution of
this Agreement by Husband, Wife shall not be obligated to deliver the aforesaid Deed until such
time as Husband has delivered the $2,500.00 payment as required herein.
10. Insurance. Retirement and Orher Benl{.tlts' The panies agree that neither party shall
make any claim of any nature whatsoever concerning any insurance benetits, retirement benefits,
protit sharing accounts or other similar accounts ar bene tits that are available to or accruing to
either party,
II, Wazver 01' Claims ~ rainst EsraM~' 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 have or hereafter acquire under the present ar future laws of any
jurisdiction, to share in the property or the est:lte of the other as a result of the maritul
relationship, including without limitatlon. dower. curtesy. statutOry allowance, widow's
allowance, nght to take in intestacy, right to take a~ainst the will ot" the other. and right to act as
administrator or e:{ecutor 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 md relinquishment of all such Interests, rights, and claims. This
paragraph shall not at'fect either party's nght or power to expressly Include the other party in any
will or ,nher document, whether "'ntten in the past or to rhe tUture.
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12. Breach' If either party brea..:hes any provision of this Agreement, the other pany
shall have the right, at his or her election, to sue for damages for such breach, or seek such other
remedies or relief lIS may be avadable to him or her.
13. Counsel Fees' The parties agree that ,hould a divorce a..:tion be maintained by
either of the parties to dissolve their marriage, neither party shall mllke a claim for counsel fees
from the other puny. Both parties have been fully informed of an acknowledge their right to
make a claim for reasonable counsel fees in the presently pending divorce proceedings, but
hereby mllke a full, complete and voluntary waiver of that right.
14, Enforcement: The parties agree that this Agreement may be made a part of my final
divorce order or decree entered in this case. This Agreement may be incorporated in but shall
not be merged with any such order or decree, In the event either party fails to comply with the
terms of this Agreement, tbe other pany may enforce this Agreement by filing a Petition for
Contempt if a party breaches this Agreement the other party, in pursuing enforcement of the
Agreement. shall be entitled to Attorney's fees form the breaching party.
[N WIT.'J'ESS WHEREOF, the parties hereunto set their hands md ,eals the day and year
tim mentioned above.
WI'f:\iESS:
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Date CRYSl~L C, ELEDGE ~
Ij l c' /(1/'./ r~-
te,/ MRlts p:EDGE
CRYSTAL C. ELEDGB, I IN THE COURT OF COMMON PLEAS OF
Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA
I
VS. I No. 96 - 2295 CIVIL TERM
I
CHARLES ELEDGE, I CIVIL ACTION - AT LAW
Defendant I IN DIVORCE
DEFENDANT'S PRE-TRIAL STATBMBNT PER Pa. R.C.P. RULE 1920.331bl
( 1 ) (i) Mad tal As sets I See the Inventory submitted by the
Defendant per Pa.R.C.P. Rule 1920.33(a) and filed as of record for
a list of the marital assets, their value, the date of the
valuation, whether any portion of the value is non-marital, and any
liens or encumbrances thereon.
(l)(ii) Non-Marital Assetsl See the Inventory submitted by the
Defendant per Pa.R.C.P. Rule 1920.33(a) and filed as of record for
a list of the marital assets, their value, the date of the
valuation, whether any portion of the value is non-marital, and any
liens or encumbrances thereon.
(2) Expert Testimony: All documents which Defendant
currently intends to offer into evidence have been exchanged with
opposing counsel, with th.e following exceptions: appraisal of
current fair market value of marital residence, statement of
current outstanding balance of mortgage secured by martial
residence. Defendant intends to call no expert witnesses at trial
unless demand for the witness' presence is made within seven (7)
days of the receipt of any document prepared by such an individual
or of this pre-trial statement.
(3) Witnesses: Defendant intends to call Charles Eledge, 308
East North Street, Carlisle, Pennsylvania 17013 to testify
regarding the factors set forth in section 3502 (a) (relating to
equi.table distribution) of the Divorce Code. Defendant reserves
the right to call various witnesses regarding the factors set forth
in section 3701(b)(relating to alimony, A.P.L., etc.). A list of
reserved witnssses shall be presented at the prehearing conference.
(4) IDmi.Rlli: Defendant reserves the right to enter the
following exhibits:
(A) Comparative Market Analysis of marital residence
(8) Real Estate Appraisal marital residence
(C) Agreement of Sale for marital residence
(0) Settlement Sheet from refinancing of marital residence
(E) Chase mortgage monthly billing statements, DOS and Current
(F) Statement of repairs Defendant made to marital residence
_A' I
(G) Statements of value of retirement plans of the parti..
(H) Statements of account, PSECU, DOS and current
(I) Statements of account, FTC, DOS and current
(J) Shtements of account, Franklin Templeton, DOS and current
(K) Statements of account, Pa. TAP, DOS and current
(L) Statements of account, Pa. OFO, DOS and current
( 5)
Statement
income.
Defendant's Income I See Defendant's Income and Expense
filed as of record for a statement of Defendant's current
( 6)
Statement
expenses.
Defendant' s Excensea I See Defendant' e Income and Expense
filed as of record for a statement of Defendant's current
(7) Pension and Retirement Benefitsl Defendant commenced a
retirement savings package during the marriage and contributed to
the plan over its course. The total value of the marital portion
of the Defendant's SERS account is believed to be $15,005.00. The
parties likewise accumulated over the course of the marriage
savings bonds ($200), checking ($12001, FTC savings ($0), and
Franklin Templeton account ($1000)
(8) Attornev'e Feesl Each party has sufficient resources to
maintain their own attorney's fees or cost..
(9) TanQible Personaltv Valuation: See the
submitted by the Defendant per Pa.R.C.P. Rule 1920.33(a)
as of record for a list of all household furnishings
personalty where distribution of such items is disputed.
(10) Marital Debts: During the marriage, the parties incurred
a $63,750 mortgage secured by the martial residence in the amount
of some $61,650.00 as of January 1996, the current balance of which
is approximately $59,000,00. The purchase price of the property
was $63,000 in October 1991. The marital r..idence h.. not
appreciated in value since its date of purchase, and coata of a.le
would exceed even the current mortgage balance. Refinancin9 is not
a practical option to provide a payout to Plaintiff of anr aaount
to which she may be entitled as a result of equitable dhtr bution.
Defendant stands ready to transfer the reBidonce, and correapondinv
mortgage liability, to Plaintiff for a credit equal to whatever
amount Plaintiff sets forth in her Pre-Trial Statement or Inventory .
and Appraisement.
Inventory
and filed
or other
(11) Summary of Special Iuu.. of Interest I The Defendant
respectfully submits the following special haues to tbe attentiOA
of the Court:
Defendant holds a strong, moral conviction in opposition to
the concept of divorce and passively objeots to its institution.
Defendant has not, and will not, actively obstruct its punuit,
however, recognizing the authority and jurisdiction of the Court.
(121 ProDosed Resolution of the Economic Issues I Defendant
suggests an overall division of the marital assets where Plaintiff
retains 50\ of the marital property and, by transferring to
Plaintiff the marital residence, and incorporating the balance of
any necessary transfer into a Qualified Domestic Relations Order.
Any future capital gains tax iSBues of the remaining aBsets are to
pass along with the corresponding asset, Plaintiff to refinance
the Chase mortgage, thereby removing Defendant'B name.
Reell drr ~~tt__
Data, ?/;q/if
Matthew J, shelman, Esquire
Law Offices of Patrick F. Lauer, Jr.
2108 Market Street, Aztec Building
Camp Hill, Pennsylvania 17011-4706
lOt 72655 Tel. (717) 763-1800
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III TBB COURT OP COMMON PLBAS OP CUMBBRLAND COUNTY, PBHIISYLVAIIIA
OPPICB OP DIVORCB MASTBR
Crystal C. Eledae
address unknown
No. 96 - 2295 civil Term
Action in Divorce
vs.
CharllBs Eledae
308 East North Street
Carlisle. PA 17013
PLAINTIFF'S ATTORNEYI
DEFENDANT'S ATTORNEY I
Bradlev L. Griffie. Esa.
200 North Hanover St.
Carlisle. PA 17013
1717 \ 243-5551
Matthew J. Eshelman. Esa.
2108 Market Street
Came Hill. PA 17011
1717 \ 249-6971
INVENTORY OF DBFENDANT CHARLES BLEDGE
( ) Plaintiff (X) Defendant files the following Inventory and
Appraisement of all property owned or possessed by either party at the
time this action was commenced and all property transferred within the
preceding three years.
( ) Plaintiff (X) Defendant verifies that the statements made in
thi. Inventory and Appraisement are true and correct.
( ) Plaintiff (X) Defendant understands that false statements
herein are made subject to the penalties of 18 Pa.C.S. Section 4904
relating to unsworn falsification to authorities,
.....11 "
MSITS or TBB PARTIBS PAGB
( ) Plaintiff (X) Defendant marks on the list below those items
applioable to the case at bar and itemizea the assets on the following
pages.
(X) 1-
( ) 2.
(X) 3.
( ) 4.
(X) 5.
(X) 6.
) 7.
) 8.
) 9.
) 10.
) 11.
) 12.
) 13.
) 14.
) 15.
) 16.
) 17,
) 18.
(X) 19.
( ) 20.
( ) 21-
( ) 22.
( ) 23.
( ) 24.
( ) 25.
(X) 26.
Real property
Motor vehicles
Stocks, bonds, securities, and options
Cerificates of deposit (CD's)
Checking accounts, oash
Savings accounts, money markets, and savings
certificates
Contents of safe deposit boxes
Trusts
Life Insurance policies (indicate face value, cash
surrender value, and beneficiaries)
Annuities
Gifts
Inheritances
Patents, copyrights, inventions, and royalties
Personal property outside the home
Business (list all owners, including percentage of
ownership, and officer/director positions held by a
party with the company)
Employment termination benefits - severance pay,
workman's compensation claims/awards
Profit sharing plans
Pension plans (indicate employee contributions and the
date on which plan vests)
Retirement plans, Indi.vidual Retirement Accounts
Disability payments
Litigation claims (matured and unmatured)
Military/VA benefits
Education benefits
Debts due, including loans, mortgages held
Household furnishings and personalty (include as a total
category and attach itemized lists if distribution of
suoh assets is in dispute)
Other - Mortgage secured by marital residence
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CRYSTAL C. ELEDGE, I IN THE COURT OF COMMON PLEAS OF
Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA
I
vs. I No. 96 - 2295 CIVIL TERM
I
CHARLES ELEDGE, I CIVIL ACTION - AT LAW
Def"ndant I IN DIVORCE
CBRTIFICATB OF SBRVICB
I hereby certify that I am this day serving a copy of the
foregoing PRE-TRIAL STATEMENT upon the person, and in the manner,
indicated below, which service satisfies the requirements of the
Pennsylvania Rules of Civil Procedure, by depositing a copy of the
lIame with the United States Post Office at Camp Hill, Pennsylvania,
through first class mail, prepaid and addressed as follows:
Bradley L. Griffie
(Plaintiff's Attorney)
200 North Hanover St.
Carlisle, PA 17013
E. Robert Elicker, II
Divorce Master
9 North Hanover St.
Carlisle, PA 17013
Il,Ubm t ted,
+7hl
Date I 0 t. .
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,
helman, Esquire
Law Offices f Patrick F. Lauer, Jr.
2108 Market Street, Aztec Building
Camp Hill, Pennsylvania 17011-4706
IDi 72655 Tel. (717) 763-1800
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Mr. Griffie and Hr. Eledge
27 July 1999
Paa. 2
unrepresented, to each file a pretrial statement on or before
Monday, August 30 ,1999. Upon receipt ot the pretrial
statements, I will immediately schedule a prehearing conference
with counsel and with Mr, Eledge, it he remains unrepresented,
to discuss the issues and, if necessary, schedule a hearing.
Very truly yours,
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E, Robert Elicker, II
Divorce Master
NOTE: Sanctions for failure to file the pretrial statements
are set forth in subdivision (c) and (d) of Rule 1920.33.
THE ORIGINAL PRETRIAL STATEMENT SHOULD BE FILED IN THE
MASTER'S OFFICE AND A COPY SENT DIRECTLY TO OPPOSING
COUNSEL.
"
* FAILURE TO FILE PRETRIAL STATEMENTS AS DIRECTED BY THE
MASTER HAY RESULT IN THE MASTER'S APPOINTMENT BEING
VACATED.
cc: ' Matthew J. Eshelman, Esquire
,- ......
- '
CRYSTAL C. ELEDGE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 96 - 2295
vs.
CIVIL ACTION - LAW
CHARLES ELEDGE,
Defendant
IN DIVORCE
ORDER AND NOTICE SETTING HEARING
'1'0: Crystal C. Eledge Plaintiff
,
Br!ldley L. Griffie Counsel for Pl!lintiff
,
Ch!lrles Eledge Defendant
,
, Counsel for Defendant
You are directed to !lppear for a hearing to take
testimony on the outstanding issueH in the above captioned
divorce proceedings at the Officc of the Divorce Mast~r, 9 North
Hanover Street, Carllsle, Pennsy Ivan ia on the ,_,______ ,_,____. day
of III _____.__________ a,m., ,lt which
place and lime you will be given the opportunity to prcsent
witncsueo and exhibits in support of your cas~,
ort
,go ,. Q,.
rro!!sident Judge
Date of Order and
Notice:
By:
Divorce Master
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 BArl ASSOCIATION
2 LrBERTY AVENUE
CARL[SLE, PA 1701]
T E [. E PilON E ('j I -'I 24 'J - 1166
CRYSTAL C. BLBDGB, I IN THE COURT OF COMMON PLBAS OF
Plaintiff I CUMBERLAND COUNTY, PBNNSYLVANIA
I
VI. I No. 96 - 2295 CIVIL TBRM
I
CHARLBS ELEDGE, I CIVIL ACTION - AT LN/I
Defendant I IN DIVORCE
ACCBPTANCE OF SERVICE
I accept BBrvice of the COMPLAINT IN DIVORCE pursuant to
penn.ylvania Rule of Civi 1 ".
that I am aut
1930.4(d). I cBrtify
half of the Defendant,
,
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Datel .
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Char lee Eledg
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helman, BBquire
the Defendant)
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CRYSTAL C. ELBDGB, I IN THE COURT OF COMMON PLEAS OF
Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA
I
VB. I No. 96 ~ 2295 CIVIL TERM
I
CHARLBS BLEDGE, I CIVIL ACTION - AT LAW
Defendant I IN DIVORCE
ACCEPTANCB OF SERVICE
I aocept service of the COMPLAINT IN DIVORCE purBuant to
penn.ylvania Rule of Civil Procedure, Rule 1930.4(d). I certify
that I am authorized to accept service on behalf of the Defendant,
Charles Bledge.
l!rL~( ~ C
Matthew J. Eshelman, Esquire
(Attorney or the Defendant)
Date I
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vs.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION. LA W
CRYSTAL C. ELEDGE,
Plaintiff
CHARLES ELEDGE,
Defendant
: NO, 91l.2295 CIVIL TERM
: IN DIVORCE
"
A......IDA VIT OF CONSENT
1. A Complaint in Divorce under Section 3~OI ~~.(the Divorce Code was filed on
/d....\{ N 1'19(, :/,'--
April 29, 1996 and served 011 [~ber 28, 191)6:,," ~
2. The marriage of Plaintifl' and Defendant is irretricvably broken and ninety (90)
days since the Complaint was filed and served.
3. I consent to the entry of a linal Decree of Divorce at\er service of notice of
intention to request cntry of the decrees.
I VERIFY TUAT THE STATEMENTS MADE IN TIlE FOREGOING AFFIDAVIT
ARE TRUE AND CORRECT, I UNDERSTAND THAT FALSE STATEMENTS
HEREIN ARE MADE SUBJECT TO TilE PENALTIES OF 18 Pa. C.S. 4904
RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES,
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DATE: je 1';1 /9'1
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CHARLES EL E;f6 ndant
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