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Home My WebLink About96-03226 {Mo ... '. 111:. '.. ':>Ie- 'lit- ':lK- @ 'lOC' 'lie' ':.:- ':.:. -:.;, .*. ':.:' ':...' ':.:. .:.e. ':.:' ~ .:...' ,:tto:.:.-.- ':.... ':.... ':...' ':41} <41>~,'~ ~. .._-~------..._~~-,-..._-~----~ ~ ,. . 8 IN THE COURT OF COMMON PLEAS ~ 8 ~ ~ OF CUMBERLAND COUNTY $ ~ ~ 8 ~ -~ ~ ~ STATE OF I~~~ PENNA. ~ 8 S 8 8 ~ DAVID D. DOERR ~ PLAINT! FF i\ C 1.,0322.6,.,1996, : 8 . Vl'I':HIS ~ $ VICKI L. DOERR ~ ~ DEFENDANT ~ N, < ~ ~ ~ ., ~ ~ DECREE IN ~ ~ DIVORCE 8 ~l 3 ! AND NOW".. ,.Jo..,~., ,'~.I"", 19 ,~\". it is ordered and 8 8 ~ ~ decreed that ..,,'........, JJA,V.IJJ. JJ,., DOERR. .. . .. .., , .... .. , , . ", plaintiff, $ ~ and. .....,.. , .. ....... .. .. Y~c~~~:, ~?~~~. ........ ........." defendant, @ . are divorced from the bonds of matrimony, " 8 ;. ~ The court retains jurisdiction of the following claims which have ; 8 been raised of record in this action for which a final order has not yet ~ ~ been entered; ~"'-R... ~ . ,~ ...................................................... ',/' ..-................. '," 8 ~ $ .. .. , , , .. , .. , .. , , .. , .. , , , .. . .. ' .. .. , .. .. , .. .. , .. .. . .. .. . ~ : n, Th"'~j1wA .: ~ AtI.'I~,.h"',,~<, f< ?~ d~...;6:J; I: ~ ~~~"'i .K' ~4 4;r I':' ~ :I '/,,7 Prothonotary ! ~ ~!____.._~____..__._...__".. , '._.... ..,.1: ~-~~~-~~~~~~*~-***~**~*~.**~*~~ -,.... '- Cr; N . '., l",-~ 1-. a, UJr.;- .- ; fE' .- 1<." ~ ~ :::; ~r~ - , ;:, ~ ". ~ " en ';/) fi!;; -"';J" I 1.-.- '."":''' - i:,~a . ..: 'I :JIJ... ;;: -; ~.:: U, ,.... o:J 0 en ':-' \n.orc DAVID D. DOERR, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA rj ~, J;l:J" Cl..:J..R r:,.......... NO. VICRI L. DOERR, Defendant DIVORCE COMPLAINT UHDBR 8BCTIOH 3301(01 OR 3301(41 OF THB DIVORCB CODK 1. Plaintiff is David D. Doerr, who currently resides at __ L I I~A I?fclt/tkJl "tV[j m("rJO l.u e ~ lJi,Nt "T-~' , Camp Hill, Cumberland County, Pennsylvania, since OC-I 199/ 2. Defendant is Vicki L. Doerr, 5t~}yt/~f'AwT,lJv(" .jk /1-f'/.,l1 tJ since JUoU R - f'('1'f . who currently ~, 7j/dJ resides at __ 7 ta3J. , Texas, 3. Plaintiff has been a bona fide redisent in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The plaintiff and defendant were married on ~r~ at Harrisburg, Dauphin County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the court require the parties to participate in counseling. 8. Plaintiff requests the court to enter a decree of divorce. J ~ ~ '1 ;:J " , .... '" :n :::J I'" c..- - 1- .. ~ -J ~ --~ 6: "'4... C""') 0.;, C'-I ~c -. n: tJ !:? ~,..., ~ rL ;;:JC' "- tt:~.. ' r.:: :>- ~. ;;~ o ' ~ - '. .# " ,~ ...., " . -?) r. ,. , ') .-r; I.:'~" ) ::~ ,:~;>1 -.j .~] J- :JJ Ii,.." d;.;' ~~ ........ ,-J <.J j , ) DAVID D. DOERR, IN THE COURT OF COMMON PLEAS Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . . . Q.~ I..v-- v. . NO. l}l.. .~.J.2.(" . . . VICKI L. DOERR, . . Defendant . DIVORCE . COtlNTER-AJ'J'IDAVIT UNDER S~~!ION 3301fdl OF THE DIVORCE ~Q~E 1. Check eith9r (~) or (b): ~ I do not oppose the entry of a divorce decree. (b) I opose the entry of a divorce decree because (check (i), (ii) or both) : (i) The parties to this action have not lived separate and apart for a period of at least two years. 2. (ii) The marriage is not irretrievably broken. either (a) or (b): Check e I do not wish to make any claims for economic relief. 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. (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I verify that the statements made in this counteraffidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.c.s. S4904 relating to un.wo,. '.'."'cat'on to autbo"t'''~ .~~ ~'L' boe", De'endant Dated: >- C") i'= 0; N I~ .~J;:: S! ;-?~ ,1_. ~ :r.:: ,'j:j: 0C1: :-:l:.;j c- -;"'- C. ,... ,-t'U~ U. I ..J:.c. '10- ... ~: :r. ,'dm "'" ~ r.!la.. :~: 15 \0 ::l e,-l U DAVID D. DOERR, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA . . (~ v. . NO. %. _:U.:J~ 'I...L- . . . VICKI L. DOERR, Defendant DIVORCE NOTICIl OJ' IN'rBN'rION TO REOUBST IlN'rRY OJ' DIVORCIl DECRBB TO: vicki L. Doerr Defendant You have been sued in an action for divorce. You have failed to answer the complaint or file a counteraffidavit to the plaintiff's affidavit. Therefore, on or after 1994, .tile plaintiff can request the court to enter a final decree in divoroe. If you do not file with prothonotary of the court an answer Witil uyour signature notarized or verified or a counteraffidavit by tile above date, the court can enter a final decree in divorce. Unless' you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. A COUNTERAFFIDAVIT WHICH YOU MAY FILE WITH THE PROTHONOTARY OF THE COURT IS ATTACHED TO THIS NOTICE. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOR AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. ff C") "- N I.. ~ ~ ~ ~:?~ g~ .~ .J "-:-I ;;: ""; --l;:1 ~C, ,... :...:.~ ; , )~ IS~ S ,'~ t:) [Q~ & -. .., ::J 0'1 U . -rz. ..,~. _~.:J.:z<.. ~ r.....- AGRBIlXBJrT THIS AGREEMENT made this _:?lJ day of 5e..fJ/ 1994, by and between VICKI L. DOERR, hereinafter referred to as "Wife" and DAVID D. DOERR, hereinafter referred to as "Husband". WITNESSETH: WHEREAS, the parties were married on May 24, 19RC; , at Harrisburq, Pennsylvania, and separated on or about -::J/JA/ 1994/ and WHF.REAS, the partiu~ have no children; and WHEREAS, diverse unhappy differences have arisen between the parties and it is the intention of Wife and Husband to live separate and apart for the rest of their natural lives, and the parties hereto are desirous of sett1inq fully and finally their respective financial and property riqhts and obliqations as between each other includinq without limitation by specification the ownership and equitable distribution of real and personal property and, in general, the sett1inq of all claims and possible claims by one against the other or against their respective estates; and WHEP~AS, the parties have represented to each other that to their knowledge there are no assets nor outstanding marital debts except as provided for in this Agreement; and WHEREAS, the parties hereto after being advised by their respective counsel, have come to the following Agreement: NOW THEREFORE, in consideration of the above recitals, the parties hereto, intending to be legally bound, promise and agree as follows: 1 1 1. Secarate and Acart. The parties shall not molest or intertere with each other nor in any way harass or malign the other, or in any way interfere with the peacetul existence, .eparate and apart trom the other. 2. Personal Pronertv. (a) Wife hereby assigns, conveys and transter. allot her right, title, and interest which she may have in and to Husband's Retirement and savings Plans. (b) Husband hereby assigns, conveys, and transfers allot his right, title and interest which he may have in wife's Retirement and savings Plans and Wite's Management Bonus Program (AlP). (c) The parties agree that they have divided or shall divide informally the remaining marital personal property which is now in the possession of the Wite. (d) The parties agree that all property not referred to in Item 2 above nor in the above provisions of Item 3 are items of non-marital property, that each party share of said property, is presently in the sole possession or sole title of the party entitled to said non-marital property. 3. Eauitable Distribution. (a) It is specifically understood that this Agreement constitutes an equitable distribution of property both real and personal, which was legally and beneficially acquired by Husband, Wife, or either of them during the marriage, as contemplated by the Act of April 2, 1980, known as "The Divorce Code" 23 P.S. Section 101, et sea, of the commonwealth of pennsylvania. 2 (b) The equitable division provision above has been negotiated to take into account the parties' overall economic circumstances including Wife's present employment, Wife's retirement and savings plans, and Husband's present employment and retirement plan. 4. Debts. (a) Each of the parties hereto covenants and agrees that he and she will not at any time in the future incur or contract any debto, charge or liability wh~tsoever for which the other of them, their legal representatives, or their property or estate may become liable. (b) Except as provided, each party further covenants at all times to keep the other free, harmless, and indemnified of and from all debts, charges, and liabilities hereafter or heretofore contracted by each of them. 5. Scousal Succort. (a) Husband does hereby waive, release and give up any rights he may have against Wife for alimony, support, or maintenance. (b) Wife does hereby wive, release and give up any rights she may have against Husband for alimony, support or maintenance. 6. Attornev's Fees. with the exception of right given below in Item 12, the parties shall be responsible for their own attorney's fees. 7. Waiver of Claims. Each party hereby releases and relinquishes any and all rights that he or she may now havo or may hereafter acquire as spouse under the present or future laws of any 3 jurisdiction; (a) to share in the estate of the other party upon the latter's death; and (b) to act as executor or administrator of the other party's estate, This provision is intended to constitute a mutual waiver by the partios to take action against each other's laet Will under the present or future laws of any jurisdiction whataoever. 8. Divorce Documents. (a) The parties ehall sign Affidavits of Consent to divorce under Section 201(c) of the Divorce Code contemporaneously with the signing of this Agreement and the parties direct their respective counsel to file these documents immediately with the Court and request the Court to enter a Decree in Divorce from the bonds of matrimony. (b) It is further agreed, covenanted and stipulated that this Agreement shall be incorporated in any Decree of Divorce obtained by Husband or Wife. 9. Mutual CooDeration. Except as otherwise herein expressly provided, the parties covenant and agree that they will forthwith and within fourteen (14) days after demand therefore, execute any and all documents and/or writings as may be necessary or desirable for the proper effectuation of this Agreement. 10. Breach. (a) In addition to other remedies given above or below, it is expressly stipulated that if either party fails in the due performance of any of his or her material obligations under this Agreement, the other party shall have the right, at his or her 4 election, to sue tor damages tor breach thereof, to sue tor &p~citic performance, to rescind this Agreement, to seek a moditication ot this Agreement, or to seek any other legal remedies as may be available, and the defaulting party shall pay the reasonable legal feea and costs tor any services rendered by the non-detaulting party'. attorney in any action or proceeding to compel pertormance hereunder. (b) All remedies provided by law and all remedies provided tor in thin Agreament tor entor.cement of the Agreement shall be deemed to be cumulative and the exercise of one remedy shall not bar or prevent the pursuit ot any other remedy and either party may elect to pursue such remedies simultaneously and the exercise ot a remedy on or more times shall not exhaust its use or prevent further pursuit ot such remedy. (c) The parties agree that they shall not pursue any such remedies until fom:'teen (14) days after they have given each other notice to cure any default in any obligation. 11. Construction of Aareement. (a) This Agreement shall be construed in accordance with the laws of the Commonwealth of pennsylvania. (b) This Agreement constitutes the entire understanding of the parties and supercedes any and all prior agreements or negotiations between them; there are no representations or warranties other than those expressly set forth herein. 5 . (c) No moditication or waiver ot any ot the terms herein shall be valid unless in writing and signed by both tile parties. (d) No waiver ott any breach hereot ot detault hereunder shall be deemed a waiver ot any subsequent breach or detault ot the same or similar nature. (e) Any headings preceding the text ot the several paragraphs and subparagraphs hereot are inserted solely tor the convenience of reterence and shall not constitute a part ot this Agreement, nor shall they attect its being, construction, or ettect. (t) It any 'term, condition, clause or provision ot tl',is Agreement shall be determined to be void or invalid at law, or tor any other reason, than only that term, condition, clause or provision shall be stricken from this Agreement as is held to be void or invalid, and in all other respects, this Agreement shall remain in full force and effect. 12. Aareement Bindina on Heirs. This Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective heirs, executors, administrators, successors and assigns. IN WITNESS WHEREOF, the parties, having been fully informed regarding their legal rights and obligations by their respective counsel and having read and understood the above provisions, set their hands and seals the day and year first above written. This 6 ~ M '>- '" ,.. ;:.-: B 8 ~)..-,; ~~; "';":: ~'. ~ J ~i'; ::.: i~~' :i;:' Co r- ,~ H. . l., f~_] I ;,01'5 ~;!:1 -- "'irE =:.; ~q -, ...-: U. '0 :J 0 en u . '-- h; " i'.' 6; IlIC' c;:!; , I .. f,." .-.-., }~ .., ~t cr. '':'} " U. I, I H _I- ~7h , .. iiJ1 u.. .';" ::.:' I~' -, l,_ r-- -~ ) u C" u ---. ,. ~ I I , I! " (.....; . , 1-,:: ,-, , , .' I , , t' , ,-- I '-' ',. h~ N i~. 6\ lo"! ,. .~... , (" :.;;: , ;"'J .'-.J ~- , ~: (7, " J.i' I ..~J I ' ~ ",j l.i; )...1_ r:. , " .... (.) l;) ".., i:-; C\., '. I " ~L( l.,.il " f" .f." ...~ !..., '"._J 6; l::-' : ~ll:, . u< .. oj ,. Il .... i '--' 01 (.1 p/e/1S €- r2otZ&.ecl TAe f}dd~ess FOA. tVJy ~ WLF) IN The. DIvoRce. hLed 6-7-90.-, f{eLI~r.:/J- 39rot3. OAvld D. Doe~R K,'/ed 143 fTlf\)SI Uc'~k,' t. Doe~R.. C145e # I 'l91o - 0 3 ;;t:;L(, . A /oJ Y tv Tf...., (J.. Q \) e <;, fr rJ IU .s I p Je(+5~ Cflrt t11e.. IlT 737-5/'/ d., ThItNK-you CjJ;.~ fJ,~ 7/9/9~ / ,/ / .~ / . "" \)QJJ\ ~"'_"--"''''' " oS- "'~ '?....-.s:o \ s\C\\..O ~ "I \ \.. ~0' . :\:,C'...0-' ~~' dY~ 00// \ q) / C .\ /n . tl,.\jJOO' ~ ::? \ '1' \1M-- '\-o~ ~ \!, ~p , ofJ.Jl'\:""' . L''V'>'"'' ~ ~~&r\ ~('