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HomeMy WebLinkAbout02-4930Johnson, Dnffie, Stewart & Weidner By: David W. DeLuce I.D. No. 41687 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff STEPHANIE J. SECHRIST, Plaintiff ERIC L. SECHRIST, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.O2,.,/-/¢0~O CIVIL TERM CIVIL ACTION - LAW IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHT,~ 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 of divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these pages 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 the Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE THE 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, Pennsylvania 17013 Telephone: (717) 249-3166 Johnson, Duffle, Stewart & Weidner By: David W. DeLuce I.D. No. 41687 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff STEPHANIE J. SECHRIST, Plaintiff V. ERIC L. SECHRIST, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.(:2~ -.,~c~,.~(~ CIVIL TERM CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORC. F UNDER SECTIONS 3301(c) OR 3301(d) OF THE DIVORCE CODI? AND NOW, comes the Plaintiff, Stephanie J. Sechrist, by and through herattorneys, Johnson, Duffle Stewart & Weidner, and files the following Divorce Complaint against the Defendant, Eric L. Sechrist: 1. The Plaintiff is Stephanie J. Sechrist, an adult individual, residing at 810 Dada Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. Plaintiff's Social Security Number is 188-62- 6402. 2. The Defendant is Eric L. Sechrist, an adult individual, residing at 810 DaHa Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. Defendant's Social Security Number is 167-38- 4387. 3. The Plaintiff and Defendant were married on October 24, 1992, in Shiremanstown, Cumberland County, Pennsylvania. 4. The Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania at least six months immediately prior to the filing of this Complaint. 5. There has been no prior action for divorce or annulment between the parties in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. The Plaintiff has been advised of the availability of marriage counseling and she may have the right to request that the Court require the parties to participate in counseling. WNEREFORE, the Plaintiff respectfully requests that your Honorable Court enter a decree of divorce. COUNT II - EQUITABLE DISTRIBUTION 8. Plaintiff incorporates herein by reference, the allegations set forth in Paragraphs 1 through 7 inclusive, of the Complaint as if the same were set forth herein at length. marriage. Plaintiff and Defendant have ~egally and beneficially acquired certain property during their WHEREFORE, the Plaintiff respectfully requests that your Honorable Court equitably divide all marital property. COUNT~-CUSTODY 10. Plaintiff incorporates herein by reference, the allegations set forth in Paragraphs 1 through 9 inclusive, of the Complaint as if the same were set forth herein at length. 11. The Plaintiff is Stephanie J. Sechrist, who resides at 810 Dada Road, Mechanicsburg, Cumberland County, Mechanicsburg, Pennsylvania 17055. 12. The Defendant is Eric L. Sechrist, who resides at 810 Dada Road, Mechanicsburg, Cumberland County, Mechanicsburg, Pennsylvania 17055. 13. Plaintiff seeks primary physical custody of the following children: JENNA L. SECHRIST, age 7, whose date of birth is March 5, 1995; and HARRISON E. SECHRIST, age 4, whose date of birth is October 28, 1997. 14. The children were not born out of wedlock. 15. The children are presently in the custody of Plaintiff and Defendant. 16. During the past five (5) years, the children have resided with the following persons at the following addresses: Name Plaintiff and Defendant Plaintiff and Defendant Address 810 Dada Road Mechanicsburg, PA 17055 701 Jenna Court Mechanicsburg, PA 17055 Date 2000 to present birth to 2000 17. The mother of the children is Plaintiff, who resides at 810 Dada Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. She is married. 18. The father of the children is Defendant, who resides at 810 Dada Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. He is married. 19. The relationship of Plaintiff to the children is that of natural mother. The Plaintiff currently resides with the following persons: Defendant and the minor children. 20. The relationship of Defendant to the children is that of natural father. The Defendant currently resides with the following persons: Plaintiff and the minor children. 21. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. 22. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. 23. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 24. The best interest and permanent welfare of the children will be served by granting the relief requested because: A. Plaintiff has been t ' ' · he children s pr mary careg~ver since birth; B. Plaintiff is able to provide a stable and loving environment for the children; and C. The children have developed a close emotional relationship with Plaintiff. 25. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. WHERE,CORE, Plaintiff requests the Court to grant her primary physical custody of the minor children, JENNA L. SECHRIST and HARRISON E. SECHRIST, subject to liberal periods of partial custody with the Defendant. :163267 VERIFICATION I, Stephanie J. Sechrist, verify that the statements made in this Complaint in Divorce are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are made subject to the penalties of 18 Pa. C.S.A §4904, relating to unsworn falsification to authorities. Date: / , / Stephanie J. ~ecl~ris{ Johnson, Duffle, Stewart & Weidner By: David W. DeLuce I.D. No. 41687 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff STEPHANII= J. SI=CHRIST, Plaintiff ERIC L. SECHRIST, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL TI=RM CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT STEPHANIE J. S£CHRIST, 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 by the court. 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 falsification to authorities. Date: / IStephanie J. ~s[ Johnson, Duffle, Stewart & Weidner By: David W. DeLuce I.D. No. 41687 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attomeys for Plaintiff STEPHANIE J. SECHRIST, Plaintiff V, ERIC L. SECHRIST, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-4930 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE ACCEPTANCE OF SERVICE on behalf of the firm of Snelbaker, Brenneman & Spare, P. C., I, Richard C. Snelbaker, Esquire,/attorneysfor Defendant, Eric h. Sechrist, hereby accept service and acknowledge receipt of the Complaint in Divorce Under Sections 3301(c) or 3301(d) of the Divorce Code filed on October 9, 2002 in the above-captioned divorce action. I certify that I am authorized to accept service on behalf of Defendant. Date: f)r, tnhpr 1 7: , 2002 S NEL BA,~~,~AN & SPARE Attorney I.D. # 44 West Main Street Mechanicsburg, PA 17055 (717) 697-8528 Attorneys for Defendant :163267 STEPHANIE J. SECHRIST PLAINTIFF ERIC L. SECHRIST DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : 02-4930 CIVIL ACTION LAW : : IN CUSTODY ORDER OF COURT AND NOW, Wednesday, October 23, 2002 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Dawn S. Sunday, Esq. _, the conciliator, at39 West Main Street, Mechanicsburg, PA 17055 on Wednesday, November 06, 2002 at 11:30 AM 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 THE COURT, By: /s/ Dawn S. Sunday. Esq. 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 faclht~es and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY 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, Pennsylvania 17013 Telephone (717) 249-3166 Johnson, Duffle, Stewart & Weidner By: David W. DeLuce I.D. No. 41687 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff STEPHANIE J. SECHRIST, Plaintiff V. ERIC L. SECHRIST, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.~.~, ,. X/~'.~ CIVIL TERM CIVIL ACTION - LAW IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHT,~ 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 of divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these pages 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 the Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE THE 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, Pennsylvania 17013 Telephone: (717) 249-3166 Johnson, Duffle, Stewart & Weidner By: David W. DcLuc¢ I.D. No. 41687 301 Market Street P. O. Box 109 Lcmoyn¢, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff STEPHANIE J. SECHRIST, Plaintiff V. ERIC L. SECHRIST, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. (~:~, --,,~,~(~ CIVIL TERM CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTIONS 3301(c) OR 3301(d,) OF THE DIVORCE CODF AND NOW, comes the Plaintiff, Stephanie J. Sechrist, by and through herattorneys, Johnson, Duffie, Stewart & Weidner, and files the following Divorce Complaint against the Defendant, Eric L. Sechrist: 1. The Plaintiff is Stephanie J. Sechrist, an adult individual, residing at 810 Dada Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. Plaintiff's Social Security Number is 188-62- 6402. 2. The Defendant is Eric L. Sechrist, an adult individual, residing at 810 Dada Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. Defendant's Social Security Number is 167-38- 4387. 3. The Plaintiff and Defendant were married on October 24, 1992, in Shiremanstown, Cumberland County, Pennsylvania. 4. The Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania at least six months immediately prior to the filing of this Complaint. 5. There has been no prior action for divorce or annulment between the parties in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. The Plaintiff has been advised of the availability of marriage counseling and she may have the right to request that the Court require the parties to participate in counseling. WHEREFORE, the Plaintiff respectfully requests that your Honorable Court enter a decree of divorce. COUNT II - EQUITABLE DISTRIBUTION 8. Plaintiff incorporates herein by reference, the allegations set forth in Paragraphs I through 7 inclusive, of the Complaint as if the same were set forth herein at length. marriage. Plaintiff and Defendant have legally and beneficially acquired certain property during their WHEREFORE, the Plaintiff respectfully requests that your Honorable Court equitably divide all marital property. COUNT III - CUSTODY 10. Plaintiff incorporates herein by reference, the allegations set forth in Paragraphs 1 through 9 inclusive, of the Complaint as if the same were set forth herein at length. 11. The Plaintiff is Stephanie J. Sechrist, who resides at 810 Dada Road, Mechanicsburg, Cumberland County, Mechanicsburg, Pennsylvania 17055. 12. The Defendant is Eric L. Sechdst, who resides at 810 Dada Road, Mechanicsburg, Cumberland County, Mechanicsburg, Pennsylvania 17055. 13. Plaintiff seeks primary physical custody of the following children: JENNA L. SECHRIST, age 7, whose date of birth is March 5, 1995; and HARRISON E. SECHRIST, age 4, whose date of birth is October 28, 1997. 14. The children were not born out of wedlock. 15. The children are presently in the custody of Plaintiff and Defendant. 16. During the past five (5) years, the children have resided with the following persons at the following addresses: Name Plaintiff and Defendant Plaintiff and Defendant Address 810 Darla Road Mechanicsburg, PA 17055 701 Jenna Court Mechanicsburg, PA 17055 Date 2000 to present birth to 2000 17. The mother of the children is Plaintiff, who resides at 810 Darla Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. She is married. 18. The father of the children is Defendant, who resides at 810 Dada Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. He is married. 19. The relationship of Plaintiff to the children is that of natural mother. The Plaintiff currently resides with the following persons: Defendant and the minor children. 20. The relationship of Defendant to the children is that of natural father. The Defendant currently resides with the following persons: Plaintiff and the minor children. 21. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. 22. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. 23. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 24. The best interest and permanent welfare of the children will be served by granting the relief requested because: Plaintiff has been the children's primary caregiver since birth; Plaintiff is able to provide a stable and loving environment for the children; and The children have developed a close emotional relationship with Plaintiff. 25. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. WN~ZREFORE, Plaintiff requests the Court to grant her primary physical custody of the minor children, JENNA L. SECHRIST and HARRISON E. SECHRIST, subject to liberal periods of partial custody with the Defendant. :163267 VERIFICATION I, Stephanie J. Sechrist, verify that the statements made in this Complaint in Divorce are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are made subject to the penalties of 18 Pa. C.S.A §4904, relating to unsworn falsification to authorities. Date: / phanie J. ~ech'ris~- Johnson, Duffle, Stewart & Weidner By: David W. DeLuce I.D. No. 41687 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff STEPHANIE J. SECHRIST, Plaintiff V. ERIC L. SECHRIST, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL TERM · CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT STEPHANIE J. SECHRIST, 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 by the court. 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 falsification to authorities. Date: JERRY R. DUFFIE RICHARD V~ STEWART C. ROY WEIDNER, JR. EDMUND G. MYERS DAVID W. DELUCE RALPH H. WRIGHT, JP~ DAVID J. LANZA MARK C. DUFFLE MELISSA PEEL GREEVY MICHAEL J. CASSIDY ROBERT M. WALKER LAW OFFICES JOHNSON, DUFFIE, STEWART WEIDNER A Professional Corporation 301 MARKET STREET P. O. BOX 109 LEMOYNE, PENNSYLVANIA 17043-0109 lgtEBSITE: ~vuma.jdsw. com TELEPHONE 717-761-4540 FACSIMILE 717-761-3015 E-MAIL mailOjdsw.com HORACE A. JOHNSON COUNSEL TO THE FIRM KEIRSTEN WALSH DAVIDSON OF COUNSEL WRITER'S EXT. NO. 15 E-MAIL dwd@jdsw.com October 16, 2002 Attn: Irene Prothonotary's Office Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013-3387 Re: Stephanie J. Sechrist v. Eric L. Sechrist No. 02-4930 Civil Term In Divorce/Custody Dear Irene: Pursuant to your telephone conversation with my secretary today, enclosed are the appropriate Orders and envelopes for the Court Administrator to assign a Conciliator as well as an additional copy of the Complaint. It is expected that the parties will separate on or about November 7, 2002. We would appreciate a conference on or before that date as that will be in the best interest of the children. Thank you for your prompt attention to this matter. If you have any questions, please do not hesitate to contact us. Very truly yours, DWD:kkm:162962v2 Enclosures Johnson, Duffle, Stewart & Weidner By: David W. DcLuc¢ I.D. No. 41687 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff STEPHANIE J. SECHRIST, Plaintiff V. ERIC L. SECHRIST, Defendant IN 'THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-4930 CIVIL TERM CIVIL ACTION - LAW iN DIVORCE / CUSTODY CUSTODY STIPULA ]'/ON 1. Legal Custody. The parties, Stephanie J. Sechrist ("Mother") and Eric L. Sechrist ("Farther"), shall have shared legal custody of the minor children: Jenna L. Sechrist, born March 5, 1995, and Harrison E. Sechrist, born October 28, 1997. 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 23 Pa. C. S. §5309, 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. Mother shall have primary physical custody. Father shall have rights of partial physical custody as follows: A. To commence December 6, 2002, on alternating weekends from Friday at 3:00 p.m. until Sunday at 7:00 p.m. During the school year, Father's periods of partial custody shall begin on Friday at the time school is dismissed; B. Every Wednesday from 3:00 p.m. until 8:00 p.m.; and C. At such other times that the parties agree. 3. Summer Vacation. Each party shall have the right to exclusive custody of the minor children for two (2) weeks during their summer recess from school. The parties agree to cooperate with each other by setting a vacation schedule on or before May 1st of each ,.fear which shall include revisions of the weekday and weekend arrangements. The vacation arrangements may be for two (2) consecutive weeks or for two (2) one week periods separated by at least one week during the summer recess from school. 4. Holidays. Unless otherwise agreed by the parties, holidays shall be shared as follows: A. Thanksgiving. Thanksgiving shall be divided into two (2) segments, Segment A and Segment B. Segment A shall be from the Wednesday before Thanksgiving at school dismissal until the Friday following Thanksgiving at 7:00 p.m. Segment B shall be from the Friday following Thanksgiving at 7:00 p.m. until Monday at 7:00 p.m. In even numbered years, Mother shall have Segment A and Father shall have Segment B. In odd numbered years, Father shall have Segment A and Mother shall havE; Segment B. B. Christmas. Christmas shall be divided into, two (2) segments, Segment A and Segment B. Segment A shall be from December 24th at noon to December 25th at noon. Segment B shall be from December 25~h at noon until December 26th at noon. In even numbered years, Father shall have Segment A and Mother shall have Segment B. In odd numbered years, Mother shall have Segment A and Father shall have Segment B. The remainder of the Christmas holiday school recess shall be. divided into two equal pads, one of which shall be with Mother and the other with Father, said order to alternate annually unless otherwise agreed by the parties. C. Easter. Easter shall be divided into two (2) segments, Segment A and Segment B. Segment A shall be from the Saturday before Easter at 4:00 p.m. until Easter Day at 4:00 p.m. Segment B shall be from Easter Day at 4:00 p.m. until the Monday following Easter at 4:00 p.m. in odd numbered years, Mother shall have Segment A and Father shall have Segment B. In even numbered years, Father shall have Segment A and Mother shall have Segment B. D. Memorial Day, Independence Day and Labor Day. The parties shall share these holidays they have traditionally observed as family times, either on a half day or annual alternating basis as they shall agree. If the parties are Lmable to agree, these holidays shall alternate on an annual basis with Mother having Memorial Day in 2003. ' a' The children shall be with Mother on Mother's E. M~ot~; period of custody shall be from 9:00 a.m. to 7:00 Day and with Father on ' p.m. F. Holidays shall take precedence over the regular schedule. 5. ~o~. Mother or her designee shall be responsible for transporting the minor children to and from school and/or daycare,, and Father or his designee shall be responsible for transporting the children from school and/or daycare on Wednesdays and for his periods of partial custody. Father shall also be responsible for returning the children to Mother's residence at the completion of his scheduled period of partial physical custody. 6. The parties intend that this Stipulation shall be made into an Order of Court. Eric L. Sechrist :164819 OEC STEPHANIE J. SECHRIST, ' Plaintiff ' V. ERIC L. SECHRIST, Defendant ' IN '['HE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-4930 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE / CUSTODY AND NOW, this the attached Custody Stipulation is hereby made into an Order of Court. ORDER OF COURT I ~' "~ day of ~ ,,, 2002, upon the agreement of the parties, STEPHANIEJ. SECHRIST, VS. ERIC L. SECHRIST, Plaintiff · Defendant · IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-4930 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY ORDER OF COURT AND NOW, this 5th day of December, 2002, the Conciliator, being advised by Plaintiff's counsel that all custody issues have been resolved by agreement of the parties, hereby relinquishes jurisdiction. The Custody Conciliation Conference scheduled for today, December 5, 2002 is canceled. FOR THE COURT, Dawn S. Sunday, Esquire Custody Conciliator POST-NUPTIAL AGREEMENT ,o19 THIS AGREEMENT made and entered into this ~ day of ~---'-~, 2003 by and between: ERIC L. SECHRIST, of 804 Darla Road, Borough of Mechanicsburg, Cumberland County, Pennsylvania, party of the first part, hereinafter called "Husband", AND STEPHANIE J. SECHRIST, 2491 Glime Drive, Mechanicsburg, Cumberland County, Pennsylvania, party of the second part, hereinafter called "Wife"; WITNESSETH: WHEREAS, Husband and Wife were married to each other on October 24, 1992, in Cumberland County, Pennsylvania and last resided together at 810 Darla Road in the Borough of Mechanicsburg, Cumberland County, Pennsylvania; and WHEREAS, the parties are the parents of two minor children, namely, Jenna Lynn Sechrist, bom on March 5, 1995 ("Jenna") and Harrison Emmanuel Sechrist, bom on October 28, 1997 ("Harrison"), collectively called "Minor Children"; and WHEREAS, certain differences have arisen between the parties, as a consequence of which the parties now live separate and apart from each other; and WHEREAS, during their marriage the parties accumulated various assets and property which they intend to divide and distribute by their agreemem; and WHEREAS, Husband is represented by Philip H. Spare, Esquire of the firm of Snelbaker, Breuneman & Spare, P. C. and Wife is represemed by David W. DeLuce, Esquire, of the firm of Johnson, Duffle, Stewart & Weidner; and WHEREAS, the parties having a full opportunity to be advised of their respective rights, duties and obligations arising out of the marriage and each having a full opportunity to investigate and evaluate the assets, liabilities and all other aspects of each other's property and their jointly owned assets and liabilities, have come to an agreement for the fmal settlement of their property and affairs; NOW THEREFORE, in consideration of these .presents and the mutual covenants, promises, terms and conditions hereinafter set forth and to be kept and performed by each party hereto, and intending to be legally bound hereby, the parties mutually agree as follows: 1. INCORPORATION OF PREAMBI ~1~. The foregoing preamble and paragraphs are incorporated by reference herein in their entirety. 2. SEPARATION. Wife and Husband may and shall, at all times hereafter, live separate and apart. Each shall be free from any direct or indirect control, restraint, interference or authority, by the other and shall be treated in all respects as if they were married. Except as otherwise provided for in this Agreement, each may reside at such place or places and with such other persons as he or she may select. Each may, for his or her separate use or benefit, conduct, carry on and engage in any business, occupation, profession or employment and at such locations which to him or her may seem advisable. Wife and Husband shall not molest, harass, disturb or malign each other or the respective families, friends, colleagues, employers or employees of each other nor compel or attempt to compel by any means the other to cohabit or dwell in any manner whatsoever with him or her. The parties are free to make mutually and voluntarily any efforts at reconciliation as he, she or they may deem advisable. The foregoing provisions shall not be taken to be an admission on the part of either Wife or Husband of the 2 lawfulness or unlawfulness of the causes leading to their living apart. This Agreement is not intended to condone and shall not be deemed to be a condonation on the part of either party hereto of any act on the part of the other party which has occasioned the disputes or unhappy differences which have occurred prior to or which may occur subsequent to the date of execution of this Agreement. 3. DISPOSITION OF MARITAL RESIDENCE. The parties are former owners as tenants by the entireties of a house and lot known as 810 Darla Road in the Borough of Mechanicsburg, Cumberland County, Pennsylvania, ("Marital Residence") which they sold on November 8, 2002 and used the proceesds to pay the following debts (collectively hereinafter called "Marital Debts"): a. Mortgage loan from Northwest Savings Bank, Account # 001695028108. b. Home equity line of credit from/with Waypoint Bank, Account # 1807007166. c. Consumer loan from PNC Bank, N.A., Account # 4003041859002783. Upon the final settlement of any sale of said property, the net proceeds were divided one-half to Wife and one-half to Husband after Waypoint Bank retained $16,868.00 of the proceeds as collateral for an Irrevocable Standby Letter of Credit (No. 100251) dated January 15, 2002 issued in favor of the Borough of Mechanicsburg (hereinafter "Letter of Credit"). The Letter of Credit was for certain site work to be performed at Heritage Acres Subdivision. Wife's one-half of the proceeds were placed in escrow with her attorney in the names of both parties. Husband's one-half of the proceeds were held in escrow by Waypoint Bank in his name as collateral for certain commercial loans. Wife shall retain her one-half of the proceeds currently held in escrow in joint names by her attorney. Husband shall retain his one-half of the proceeds currently held in escrow by Waypoint Bank in his name. The $16,868.00 collateral o~n/the Le~er of,Credit has been released by_ Waypoint Bank · , ?tM all aEC. taxi. c( into an account in Husband s name. The $16,868.0~shall be shared equally ~etween t~he parties upon execution of this Agreement by both parties. 4. HUSBAND'S MONETARY OBLIGATION TO WIFE. As the final adjustment in equitable distribution of the parties' marital property, Husband covenants and agrees to pay to Wife the sum of Twenty Thousand ($20,000.00) Dollars, said sum to be paid without interest in five (5) equal annual installments of Four Thousand ($4,000.00) Dollars each on November 15 of each year, the first installment to be due and payable on November 15, 2003, and the final installment due and payable on November 15, 2007. 5. HOUSEHOLD GOODS· Upon execution of this Agreement, Wife and Husband shall each become the sole and separate owner of all the household goods, furniture, furnishings, dishes, glassware and other household items currently in his or her possession. 6. MEDICAL INSURANCE. Until the parties are divomed and as long as Wife's employer provides medical insurance, Husband shall continue to be covered by the medical insurance as provided by Wife's employer and he shall be entitled to an insurance card or other documentation proving such coverage· Any copayment required by Wife's employer to provide coverage for Husband shall be paid by Husband to Wife. Wife shall promptly inform her employer upon the issuance of the divorce decree and shall cooperate with Husband's efforts to obtain medical insurance from her employer under any COBRA rights he may have. 7. CUSTODY OF MINOR CIq-II,DREN. Custody of the minor children is currently set forth and controlled by Order of Court dated December 16, 2002. 8. MINOR CHILDREN'S SUPPORT. Support for the children is currently set forth and controlled by an Agreement For Child Support effective February 23, 2003, executed by Wife on May 9, 2003 and executed by Husband on April 25, 2003. 9. DEPENDENT'S INCOME TAX EXEMPTIONS. The claiming or taking of the minor children as dependency exemptions for federal, state and local income tax purposes shall be determined according to applicable law. 10. PNC INVESTMENT ACCOUNT. Contemporaneously herewith Wife assigns, transfers and sets over unto Husband all her fight, title and interest in a certain investment account at PNC Investments, bearing Account Number 72500137, to be Husband's sole and separate property. I 1. DECLARATION AS TO ASSETS AND WAIVER OF EVALUATION. The parties acknowledge that during their marriage they acquired assets (some individually and some jointly) which might be the subject of equitable distribution if submitted to a court for division under the provisions of the Pennsylvania Divorce Code. The parties hereby waive the inventory and evaluation of marital assets, although each party declares that she/he has had full opportunity obtain such information. 12. INDIVIDUAL PROPERTY. Each party shall ret~n all property, real, personal and otherwise, which is presently titled in his or her name and ownership, whether or not said property is or would be deemed to be marital property under the Pennsylvania Divorce Code and each party hereby expressly releases the other of and from any and all right of equitable distribution in and to said individually owned property of such other party. 13. AFTER-ACQUIRED PROPERTY. Each of the parties shall hereafter own and enjoy independently of any claim or right of the other, all items of property, be they real, personal or mixed, tangible or intangible, which are hereafter acquired by him or her, with full power in him or her to dispose of the same as fully and effectively, in all respects and for all purposes as though he or she were unmarried. 14. MARITAL DEBTS. The parties acknowledge and agree that except for the obligations identified in paragraph 3 hereinabove and in paragraph 16 hereinbelow, there are no marital debts. Moreover, each party agrees to pay and discharge any and all debts, which he or she has individually incurred or will incur in the future without contribution from the other party. 15. COMMERCIAL DEBTS. The parties were obligors on two (2) loans with Waypoint Bank ("Bank") in which Sechrist Development Corp. is the principal borrower ("Commercial Debts"). Bank has removed Wife from liability associated with the Commercial Debts. Husband covenants and agrees to timely pay all said obligations if Sechrist Development Corporation should default on said loans, and further agrees to indemnify, defend and hold Wife harmless of and fi:om any and all liability arising in any way from said Commercial Debts. 16. INDEMNIFICATION. Each party represents and warrants to the other that he or she has not incurred any debt, obligation, or other liability, other than described in this Agreement, on which the other party is or may be liable. Each party covenants and agrees that if any claim, action or proceeding is hereinafter initiated seeking to hold the other party liable for any other debts, obligations, liability, act or omission of such party, such party will at his or her sole expense, defend the other against any such claim or demand, whether or not well- founded, and that he or she will indemnify and hold harmless the other party in respect of all damages as resulting therefrom. Damages as used herein shall include any claim, action, demand, loss, cost, expense, penalty, and other damage, including without limitation, counsel fees and other costs and expenses reasonably incurred in investigating or attempting to avoid same or in opposing the imposition thereof or enforcing this indemnity, resulting to Husband or Wife from any inaccurate representation made by or on behalf of either Husband or Wife to the other in this Agreement, any breach of any of the warranties made by Husband or Wife in this Agreement, or breach or default in performance by Husband or Wife of any of the obligations to be performed by such party hereunder. The Husband or Wife agrees to give the other prompt written notice of any litigation threatened or instituted against either party which might constitute the basis for a claim for indemnity pursuant to the terms of this Agreement. 17. LIFE INSURANCE. Each party shall be and continue to be the owner of any life insurance policies heretofore acquired by either of them, with each party naming the parties' minor children as the beneficiaries of such policies. 18. FUTURE OBLIGATIONS. From and after the date hereof, each party agrees that he/she will not incur or attempt to incur any obligations for or on behalf of the other party and will indemnify and hold harmless the other party of and from any and all liability arising from any such future obligations. 19. MUTUAL CONSENT DIVORCE. It is the intention of the parties, and the parties agree, that by this Agreement they have resolved all ancillary economic issues related to the dissolution of their marriage and that either party shall have the right to commence a no-fault divorce which shall be granted by mutual consent of the parties in the Divorce Action. 20. COUNSEL FEES, COSTS AND EXPENSES. Each party shall be responsible for his or her own legal fees, costs and expenses, if any, incurred in connection with their separation and/or the dissolution of their marriage. This paragraph does not prevent counsel fees, costs and expenses from being awarded in the event of breach of this Agreement as set forth elsewhere in this Agreement. 21. RELEASE OF RIGHTS UNDER DIVORCE CODE Except only as specifically provided to the contrary hereinabove in this Agreement, each party hereby waives and forever releases the other party of and from any and all claims which either may have against the other by reason of and pursuant to the Pennsylvania Divorce Code (and the divorce law of any other jurisdiction) including, but not limited to, spousal support, alimony, alimony pendente lite, equitable distribution of marital property, counsel fees, costs and expenses, except that the performance of any obligations created by this Post-Nuptial Agreement may be enforced by any remedies under the Pennsylvania Divorce Code. 22. GENERAL RELEASE. Husband relinquishes his inchoate intestate right in the estate of Wife, and Wife relinquishes her inchoate intestate right in the estate of Husband, and each of the parties hereto by these presents, for himself or herself, his or her heirs, executors, administrators or assigns, does hereby remise, release, quit-claim and forever discharge the other party hereto, his or her heirs, executors, administrators or assigns, or any of them, of any and all claims, demands, damages, actions, causes of action or suits at law or in equity of whatsoever kind or nature, for or because of any matter or thing done, omitted or suffered to be done by such other party prior to the date hereof, except that this release shall in no way exonerate or discharge either party from the obligations and promises made or imposed by reason of this Agreement. This Agreement shall not be construed to affect or bar the right of either party to an action for the enforcement or performance of this Agreement which may be instituted pursuant to the remedies available under the Pennsylvania Divorce Code. 23. SURVIVAL OF AGREEMENT. It is the intention of the parties that this Post- Nuptial Agreement shall survive any action in divorce which may be instituted or prosecuted by either party, and no order, judgment or decree of divorce, temporary, interlocutory, final or permanent, shall affect or modify the terms of this Agreement, but said Agreement may be enforced by any remedy at law or in equity, including enforcement proceedings under the Pennsylvania Divorce Code. The parties agree to incorporate this Agreement into a separate order of court to be entered in the Divorce Action, but this Agreement shall not be merged into said order or decree in divorce. 24. VOLUNTARY EXECUTION. Each party, acknowledges that this Post-Nuptial Agreement is fair and equitable, that it is being entered into voluntarily. The parties acknowledge that they have been furnished with all information relating to the financial affairs of the other to the extent same has been requested by each of them. 25. ENTIRE AGREEMENT. This Post-Nuptial Agreement contains the entire understanding of the parties and there are no representations, warranties, covenants or undertakings other than those expressly set forth herein. The parties acknowledge and agree that the provisions of this Agreement with respect to the distribution and division of marital and separate property are fair, equitable and satisfactory to them based on the length of their marriage and other relevant factors which have been taken into consideration by the parties. Both parties hereby accept the provisions of this Agreement with respect to the division of property in lieu of and in full and fmal settlement and satisfaction of all claims and demands that they may now have or hereafter have against the other for equitable distribution of their property by any court of competent jurisdiction pursuant to the Pennsylvania Divorce Code or any amendments thereto. Each party voluntarily and intelligently waives and relinquishes any right to seek a court ordered determination and distribution of marital property, but nothing herein contained shall constitute a waiver by either party of any rights to seek the relief of any court for the purpose of enforcing the provisions of this Agreement. 26. EFFECT OF RECONCILIATION OR RECONCILIATION ATTEMPT. This Agreement will remain in full force and effect even if the parties affect a reconciliation, cohabit as Husband and Wife or attempt to effect a reconciliation. This Agreement shall continue in full force and effect and there shall be no modification or waiver of any of the terms hereof unless the parties in writing, signed by both parties, execute a statement declaring th/s Agreement or any term of this Agreement null and void. The purpose of this paragraph is to discourage either party from reconciling with the other party so as to obtain monetary benefits. Further, the parties hereto acknowledge that they have been fully informed and are fully acquainted with the legal effect of a reconciliation and that they have given due consideration to such matters and questions, and that each party enters into this Agreement, and the terms of this paragraph freely, voluntarily and with full knowledge and understanding. 27. WAIVER. The waiver of any term, condition, clause or provision of this Agreement shall in no way be deemed or considered a waiver of any other term, condition, clause or provision of this Agreement. 28. APPLICABLE LAW. This Agreement shall be construed, interpreted and enforced according to the laws of the Commonwealth of Pennsylvania. 29. HEADINGS. The headings or titles of the numbered paragraphs of this Agreement have been used only for the purpose of convenience and shall not be resorted to for the purposes of interpretation or construction of the text of this Agreement. 30. BREACH. 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 election, to sue for damages for breach thereof, to sue for specific performance or to seek any other legal remedies as may be available, and the defaulting party shall pay the reasonable legal fees for any services rendered by the non-defaulting party's attorney in any action or proceeding to compel performance hereunder. 31. MODIFICATION. No modification, rescission or amendment to this Agreement shall be effective unless in writing signed by each of the parties hereto. 32. SEVERABILITY. If any provision of this Agreement is held by a Court of competent jurisdiction to be void, invalid or unenfomeable, the remaining provisions hereof shall nevertheless survive and continue in full force and effect without being impaired or invalidated in any way. 33. COOPERATION. The parties agree to cooperate with each other and to make, execute, acknowledge and deliver such inslruments and take further action as may hereafter be determined to be requisite and necessary to effect the purposes and intention of this Post- Nuptial Agreement. IN WITNESS WHEREOF, the parties have hereunto set their respective hands and seals the day and year first above written intending to legally bind themselves and their respective heirs, personal representatives and assigns. WITNESSED BY: Eric L. Sechrist / Ste~hanie J. Sech~'ist / (SEAL) (SEAL) 3_2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS. On this, the o2 7 -hk day of ~_,,~O ~/__~C., 2003, before me, a Notary Public in and for the Commonwealth and County aforesaid, the undersigned officer, personally appeared ERIC L. SECHRIST, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrumem, and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. COMMONWEALTH OF PENNSYLVANIA ) : SS. COUNTY OF CUMBERLAND ) Onthis, the ~dayof ff~f&~_~ ,2003, beforeme, a Notary Public in and for the Commonwealth and County aforesaid, the undersigned officer, personally appeared STEPHANIE J. SECHRIST, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. 13 Notary Publicf Notarial Seal Kristee K. Myers, Notary Public Lernoyne Bom, Cumberland Courtly My Commission ExpOs D~. 2, 2006 Member, Pennsylvania ~ Of No~ies Johnson, Duffle, Stewart & Weidner By: David W. DeLuce I.D. No. 41687 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff STEPHANIE J. SECHRIST, Plaintiff V. : ERIC L. SECHRIST, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-4930 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE AFFIDAVlT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on or about October 9, 2002. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service the Complaint. 3. I consent to the entry of a final Decree in Divorce after service of notice of intention to request entry of the Decree. 4. I have been advised of the availability of marriage counseling, understand that the Court maintains a list of marriage counselors and that I may request the Court require my spouse and I to participate in counseling and, being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to the divorce becoming final. 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 falsification to authorities. Date: /~)/ :219850 /~.e~~f~'~ ~''~'/~~b[ephanie J i Sf~c_~rist, Plaintiffz · ..,,.4. ,~.. Johnson, Duffle, Stewart & Weidner By: David W. DeLuce I.D. No. 41687 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff STEPHANIE J. SECHRIST, Plaintiff V. ERIC L. SECHRIST, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-4930 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECRFF UNDER SECTION 3301(c) OF THE DIVORCE CODF 1. I consent to the entry of a final Decree in Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of properly, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a Divorce Decree is entered by the Court and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary. 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 falsification to authorities. Date: /~/~/tg' ~tephanie J. cl~'ist, Plaintiff - :219850-2 Johnson, Duffle, Stewart & Weidner By: David W. DeLuce I.D. No. 41687 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff STEPHANIE J. SECHRIST, Plaintiff V. ERIC L. SECHRIST, Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-4930 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on or about October 9, 2002. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service the Complaint. 3. I consent to the entry of a final Decree in Divorce after service of notice of intention to request entry of the Decree. 4. I have been advised of the availability of marriage counseling, understand that the Court maintains a list of marriage counselors and that I may request the Court require my spouse and I to participate in counseling and, being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to the divorce becoming final. 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 falsification to authorities. Date: Eric L. Sechrist, Defendant :219850-3 Johnson, Duffle, Stewart & Weidner By: David W. DeLuce I.D. No. 41687 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff STEPHANIE J. SECHRIST, Plaintiff ERIC L. SECHRIST, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-4930 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECRFF UNDER SECTION 330f(c) OF THE DIVORCE CODF 1. I consent to the entry of a final 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 not claim them before a divorce is granted. 3. I understand that I will not be divorced until a Divorce Decree is entered by the Court and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary. 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 falsification to authorities. Eric L. Sechrist, Defendant :219850-4 STEPHANIE J. SECHRIST, Plaintiff IN THE CCURT OF CC~MCXN PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NOl 02-4930 CIVIL TERM vs. ERIC L. SECHRIST, Defendant PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following inform~tion~ to the court for entry of a divorce decree: 1. Grounds for divorce: irretrievable breakdown under Section 3301 (c) ~ of the Divorce Code. (Strike out inapplicable section) 2. Date and manner of service of the cc~plaint: Acceptance of Service signed by' Defendant's counsel and filed with this Court on October 22, 2002. 3. Complete either Paragraph A. or B. A. Date of execution of the affidavit of consent required by Section 3301 (c) of the Divorce Code: by the plaintiff 10/22/03 by the defendant 10/27/03 B. (1) Date of execution of the plaintiff's affidavit requJ-red by Section 3301 (d) of the Divorce Code: · (2) Date of service of the plaintiff's affidavit ul~on the defendant: 4. Related claims pending: None. The Pos~-Nuptial A~3reement dated October 22, 2003 shall be incorporated, but not merged, into the Decree in Divorce. 5. Indicate date and manner of service of the notice of intentioh to file praecipe to transmit record, and attach a copy of said notice under Section 3301 (d)(1)(i) of the Divorce Code Waiver of Notice signed by Plaintiff on 10/22/03 and filed concurrently herewith; Waiver of Notice signed by Defendant on 10/27/03 an~ filed concurrently herewith. A~ to~ne~ f~r ~i~t if f/De fendan--i David W. DeLuce Atty ID # 41687 IN THE COURT Of COMMON PLEAS STEPHANIE J. SECHRIST, Plaintiff VERSUS ERIC L. SECHRIST, Defendant OF CUMBERLAND COUNTY STATE OF ~~,%, PENNA. 02-4930 CIVIL TERM NO. AND NOW, DECREED THAT DECREE IN DIVORCE STEPHANIE J. SECHRIST 2003 , {T IS ORDERED AND , PLAINTIFF, AND ERIC L. SECHRIST , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; None. The Post-Nuptial Agreement dated October 22, 2003 shall be incorporated, but not merged, into this Decree in Divorce. ATTEST: PROTHONOTARY .£z ff