HomeMy WebLinkAbout96-04645
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MARITAL SETTLEMENT AGREEMENT
THIS AGREEMENT made this ,.;1..1 "'iT day of OCTZ>f?t:'R
1998 by and between PATTI S. HARTW'.N Ihen2inafter referred to as
"Viife") and GREGORY R. HARTMAN (hereinafter referred to as
"Husband") .
WIT N E SSE T H
WHEREAS, Husband and Viife were lawfully married on Februa~y
1, 1975 in Mechanicsburg, Cumberland County, Pennsylvania; and
WHEREAS, three children have been conceived of this
marriage; namely, Amy M. Hartman, born on April 11, 1976, Kelly
L. Hartman, bDrn on February 28, 1979 and Megan E. Hartman born
Dn October 10, 1990; and
WHEREAS, diverse differences and difficulties have arisen
between the parties respecting their interests, rights and title
in and to certain property, real and/or personal, owned by or in
pDssession of the said parties to either Df them; and
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1. DIVORCE: The parties agre" that their marriage is
irretrievably broken and that they mutually consent to a
divorce and agree and have executed all necessary Affidavits
required by the courc for the entry of a mutual consent
divorce. Both Husband and Wife have directed their
respective counsel to :mmediately file with the Court said
Affidavits and file t~e appropriate documents to request a
Decree in Divorce fro~ the bonds of matrimony under Section
3301 (c) of the Divorc~ Code.
2. FULL FORCE AND EFFECT: This ;'.greement shall continue in full
force and effect until such time of final Decree in Divorce
is entered.
3. INTERFERENCE: Each party shall be free from interference,
authority, and contac: by the other, as fully as if he or
she were single and unmarried except as may be necessary to
carry out the provisions of this Agreement. Neither party
shall molest the other or attempt to endeavor to molest the
other, nor compel the other to cohabit with the other, or in
any way harass or malign the other, nor in any way interfere
with the peaceful existence, separate and apart from the
other.
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4. WIFE'S DEBTS: Wife represents and warr~nts to Husband that
since t}lC date tile divorce was filed, to Wil, August 22,
1996, she has not and in the futur'.::" ~:!-l~ w: 1.1 Eat, contract
Ol.~ .:r:::ur any debt or li3.bility [OL" ',.;::.i.:::h Ii'.lsband or his
esta::e might. be responsible arid shall indemnify and save
harmless }!usband from any and alJ clairns or demands made
against him by reason of debts or obligations incurred by
her.
5. HUSBJI.ND'S DEBTS: Husband represents and \'la'Tants to Wife
that since the divorce was filed, to wit, August 22, 1996,
he has not and in the future 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.
6. MUTUAL RELEASES: Subject to the provisions of this
Agreement, each party has released and discharged, and by
this Agreement does for himself or herself 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 demands, whatsoever in
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law or equity, vJhich eittlC'r of: the- parties ever had or now
has agilinst the- o:::.h,,=:1', except any or all causes of action
[or termination of the In~rriag~: by divorce or anllullnent and
except ~rjY or all causes of ~ctjon for breactl of any
provisions of this Agreement. Husband a.nd vlife specificall~'
release and 'tJaive any and all ris;hts he or siv~ rnig:'lt have to
raise claims under the Divorce Cocie of 1980, as amended in
1988 including, but not limited to claims for equitable
distributio:1 of marital property, suppor:::., alimony, alimony
pendente lite, counsel fees or expenses.
The fact that a
party b~.-ings an actio:1 to enforce this Agreement as
incorporated in the divorce decree, under the Divorce Code
of 1980, as amended in 1988, does not give either party the
right to raise other claims under the Divorce Code,
specifically waived and released by this paragraph and all
rights and obligations of the parties arising out of the
marriage shall be determined by this Agreement.
7. RELEASE OF TESTAMENTARY CLAIMS: Except as provided for in
this Agreement, each of the parties hereto shall have the
right to dispose of his or her property by Last Will and
Testament or otherwise and each of them agree that the
estate of the other, whether real, personal or mixed, shall
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be and belong to the person or persons who would become
entitled thereto as if the decedent had been the last to
die. This provision is int011ded to constitute a mutual
waiver by the parties of any rights to take against each
other's Last Viills under the present or future laws of any
jurisdiction whatsoever and is intended to confer third-
party beneficiary right.s upon the otli.::r heirs and
beneficiaries of each.
8. AGREEMENT BINDING ON HEIRS: The parties acknowledge that
except as provided for in this Agreement, each of the
parties shall have the right to dispose of their respective
property by Last Will and Testament, and that each party
waives the right to take under the Will of the other. This
Agreement shall be binding on the respective heirs,
executors, administrators and assigns of the parties
thereto.
9. ENTIRE AGREEMENT: This l'.greement represents the entire
agreement between the parties and supersedes any and all
prior agreements or negotiations between them. There are ~o
representations, promises, agreements/ conditions, or
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warranties between the parties ottler tllan those set forth
h..=:rein.
10. LEGAL ADVICE/VOLUNTARY EXECUTION: The provisions of this
AgrBemBnt and their legal effect have been fully explained
:0 the parties by ttleir respect:ve counsel.
The Wife has
employed and has had the benBfit of counsel of Philip Spare,
Esquire, as her attorney. The Husband has employed and has
~ad the benefit of counsel of Cacherine A. Boyle, Esquire,
as his attorney. Each party acknowledges that they have
received independent legal advice from counsel and that each
party fully understands the facts and have been fully
informed of their legal rights and obligations, and each
party acknowledges and accepts that this Agreement is, under
the circumstances, fair and equitable, and that it is being
entered into freely and voluntarily after having received
such advice and with such knowledge, and that execution of
chis Agreement is not the result of any duress or undue
influence and that it is not the result of any collusion or
improper or illegal agreement or agreements. Also, each
party hereto acknowledges that he or she has been fully
advised by his or her respective attorney of the current
Pennsylvania Divorce Law, and his or her rights thereunder,
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each party hereto still desires to exeCU:2 this Agreement
acknowledging that the terms and conditi=~s set forth herein
are fair, just, and equitable to each of :he parties and
waives their respective right to have th~ Court make any
determination or order affecting the res~ective parties'
right to a divorce, alimony, alimony pcnc=nte lite,
equitable distribution of all marital prc?erty, counsel fees
and costs and expenses.
Each party hereto acknowledges that ~e or she had an
opportunity to consult a professional re~arding the fair
market value of the marital assets. Eac~ party hereto also
acknowledges that the within Marital Set:lement Agreement
and/or any transfer pursuant thereto may ~ave tax
consequences to him or her and that each ~as been advised of
same and had the opportunity to consult ;lith an accountant
of his or her choice.
11. DIVISION OF PERSONAL PROPERTY: The parties have divided
between them, to their mutual satisfaction, the personal
effects, household furniture and furnishings, and all other
articles of personal property which have heretofore been
used by them in common, except as otherwise provided herein.
Should it become necessary, the parties each agree to sign
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any titles or documents necessilry to give effect to this
paragraph.
""life shall retiJin as her ~~ule and exclusi ve property
the Little Tykes playhouse, her great grandmother's kitchen
set, the tvlO cabinets from I'Jr. Hampton, a copy of the
vid~otape of Megan's J)irtll an8 Iler p0rsollal items such as
her school yearbooks. HusbaIlc.~ sha2.1 reLain as his sole a:1d
exclusive property all other ~urniture and furnishings
currently located at the marital residellce, 2115 Foxfire
Drive, Mechanicsburg, Cumbr;:;rland County, Pennsylvania.
12. DISPOSITION OF REAL PROPERTY: Viife does hereby set over,
transfer and assign to Husband all of her right, title and
interest in t}le nlarital residence located at 2115 Foxfire
Drive, Mechanicsburg, Cumberland County, Pennsylvania. The
marital residence shall be the sole property of the Husband
and Wife agrees to execute a deed and any other necessary
documents or instruments transferring the property into the
Husband's name alone.
Husband agrees that he alone shall be responsible for
the mortgage on said residence held at Fulton Bank (loan
#220-1157171), and Husband shall indemnify and save harmless
Wife from any and all claims or demands made against said
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mortgage. Husband has obtained a release of the Fulton Bank
mortgage from the parties names to his name alone pursuant
to Exhibit IIAtt.
13. EOUITABLE DISTRIBUTION:
a. Husband shall keep as his sole and exclusive property
the following assets:
(1) Members 1st Fed~ral Credit Union account
#150711-11
(2) Members 1st Federal Credit Union account
#47423-11
(3) Fulton Bank account #221886353
(4) Members 1st Federal Credit Union account
#150711-00
(5) Members 1st Federal Credit Union account
#47423-00
(6) Life Insurance policies:
(a) prudential #19-567-686
(b) prudential #22-052-122
(c) prudential #42-015-507
(d) prudential 1173-909-740
(e) Prudential #D42-695-685
(7) Loan receivable from Amy Hartman
(8 ) 1985 Volvo automobile
(9 ) 1986 Saab automobile
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e. Husband shall pay to Viife $24,441.60 in cash. Husband
can choose to make said payment in full at such time
t~is Martial Settlement Agreement is executed. Husband
may also elect to make said payment in two
installments. If Husband so elects, he shall make
payments to Wife totalling $25,401.60. The first
installment of $12,441.60 shall be paid at such time
this Martial Settlement Agreement is executed. The
second installment of $12,960.00, shall be paid one
YEar after the first paymen:.
f. The parties acknowledge that they shall execute any
r~levant documents necessary to accomplish the purposes
of this paragraph.
g. Husband and Wife each hereby indemnify the other and
guarantee to hold each other harmless for any and all
payments, charges or penalties due on account of any
liability which is the sole responsibility of the other
pa~ty.
14, BUSINESS INTERESTS: Husband shall keep as his sole and
exclusive property his business interests and any benefits
and/or liabilities derived therefrom. Specifically, these
business interests are any interests which Husband may have
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in DGS Enterprises, Hartman Enterprises and Hartman &
Scheuchenzuber.
15. ALIMONY: The Court entered an Order dated October 14, 1997,
in relation to alimony pendence lite. Upon entry of a
Decree in Divorce, said Order shall terminate.
Consequently, Husband and Wife shall be solely responsible
for their own medical insurance and medical expe~ses. Wife
shall execute all appropriate documents, file appropriate
documents and otherwise cooperate with Husband so that said
Alimony Pendente Lice Order terminates properly.
Thereupon, an Order for alimony shall be entered
requiring Husband to pay to vlife alimony of $750.00 per
month for a term of seven years. Said alimony payments
shall be due upon the 15th of each month to commence the
month after the issuance of the Divorce Decree and shall be
paid by Husband directly to wife. The parties agree that
said payments shall be taxable to Viife and deductible to
Husband for income tax purposes. The parties also agree
that said payments shall be non-modifJ.able and shall
terminate upon wife's death, remarriage or cohabitation.
16. EXEMPTION: Wife may utilize Megan for purposes of
qualifying as head of household. Husband may claim Megan as
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a dependent for purposes of an exemption deduction. Once
Kelly can no longer be utilized by Husband for purposes of
Husband qualifying as lIe ad of household, then Husband shall
be entitled to use Megan fer purposes of both qualifying as
head of household and as a dependent for the exemption
deduction. Wife shall execute any appropriate documents at
the time of the signing of this agreement for Husband to use
in the future to utilize Megan for purposes of both
qualifying as head of housellold and as a dependent for the
exemption deduction. Husband ag~ees not to file said
document/documents until the time that Kelly can no longer
be utilized by Husband for purposes of qualifying as head of
household.
17. DISCLOSURE: The parties acknowledge that there has been
full and fair disclosure to the other of his or her
respective income, assets and liabilities, whether they are
held jointly or in the name of one party alone. Any and all
other accounts, investments, property rights, contract
rights, business interest, retirement accounts and other
retirement vehicles and insurances, not specifically
mentioned herein, and of whatsoever nature of either of the
parties in their individual names shall be and shall remain
the sole and separate property of the individual in whose
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name it presently exists and rleitller party 811all 11ave any'
claims whatsoever tllereto.
18. WAIVER OF RIGHT TO COUNSEL FEES, COSTS AND EXPENSES: The
parties hereby acknowledge that they each waive their right
to request counsel fees! costs and expenses from the other.
Each party shall be responsible [or payment of his or her
own counsel fees! costs and expenses.
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19. INDEMNIFICATION:
Each party covenants and agrees that if
any claim! action or proceeding is hereinafter initiated
seeking to hold the other party liable for any 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 110t well-
founded, and that he or she will indemnify and hold harmless
the other party with respect to 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 r
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 Viife to th~ oth~r in this Agreement,
any breach of any of the vlarrant ie',] made by Husband or \'life
of any of the obligations to be performed by such party
hereunder. The Husband or Viife agrees to give the other
prompt written notice of any litigation threatened or
instituted against either party which might constitute that
basis for a claim for indemnity pursuan~ to the terms of
this Agreement.
20. BREACH:
If either party breaches any provision of this
Agreement, the other party shall have the righc, at his or
her election, to sue for damages for such breach or seek
such other remedies or relief as may be available to him or
her, and the party breaching this contract shall be
responsible for payment of legal fees and costs incurred by
the other in enforcing their rights under this Agreement.
21. AGREEMENT TO CONTINUE IN EVENT OF DIVORCE: The failure of
either party to insist upon strict performance of any of the
provisions of this Agreement shall not be construed as a
waiver of any subsequent default of the same or similar
nature. In the event that the marriage of the parties hereto
is terminated by divorce, this Agreement shall nevertheless
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whatsoe'/er in d(:l('nninin~J the riCJ!lt~:; o!' obligations of the
parties_
26. VOID CLAUSES: If arlY term, condition, c)allse or provisiol1
of this Agreement shall be determined or declared to be void
or invalid in la-..; or oth~~rwis~, then o:11y that term,
condition, clause or provision shall be stricken from this
Agreeme~.: and in all other respects, this Agreement shall be
valid a~d continue in full force, effect, and operation.
27. EXECUTION DATE: The execution dClte shall be defined as the
date both parties have signed this ?greement. In the event
that the parties do not sign this Agreement at the same
time, the execut,on date shall be the date the last party
has signed.
28. LAW: This Agreement shall be construed pursuant to the laws
of the Commonwealth of Pennsylvania.
IN WITNESS WHEREOF, the parties have hereunto set their
hands and seals the day and year first above-written.
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G~R/J}il~
"
/Idn
Pl,TTI S.
.:5 /-hk/w;r; a
HARTMAN
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NOT ARIM SEAL
CHRISTINA l. WALKER. NC'l!Ory Public
Horrj~burg. Dauphin County. PA
My Commiuion Expire~ Moy 1, 2000
COMr10NI'IEALTH OF PEN,.:;;n,VAN [f, )
( ,r::;;
COUNTY OF I
/)jJ" /C..!t. /
On !:hiD, the.) dilY U; __~_~(:{':L I , 1998
before me the unders iqn(:d r;f f ice r, p(~'rr;tJllCt_-J.J. 'I clppeared GREGORY R.
HARTMAN know to me (or satis[uctorily pr';vf:'n) to be the person
whose name is subscribed to the within Milrital Property
Settlement Agreement and acknovilr:;dq'ed tllat he: executed the same
for the purposes therein contairl~d.
IN WITNESS THEREOF, I have hereunto set my hand and official
seal.
_L~~d"u- /(IJd!Jz,(j
Notary Pur'l ic
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:0-0'3-t~98 22:3:.?PI'l FRO.'- H)rtr(I-)/', ':. :(I',~.'cl,'!r,;:'.'~:'':''
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FUlton Bank
Peorle ded,catec to your success..
r .:) f<' _1-:_,:;.; . i_.;'.'IC..\~,-[~. r>:' ~ 7;-,
Sept.ember 25, 1998
GREGORY R HARTMPJ,
2: 15 FOXE'IRE DRIVE
ME:HJlJlICSBURG PI'. :7055
Dear Mr. Hartman:
You have notifiec Fd ton BanK that YO'J i:1ts:oj t8 convey, by deed
from Gregory R. Eartman a:od PattI S. HartDan :0 Gregory R. Har:man,
U:e rea: property located a': 2:15 FOKfira Dri'Je, Mecha:oicscurg, PI'.
~7055 (the 1JReal Estate'I). The Real Estate ~s subjec: to a ce=tain
Mcrtgtige dated Jur.e 8, 1993 and gr:i:lted by Gregory R. Har::man and
?att:. S. Eartman to E'Ultcn Ba:)}: {the IrHQ::tgage"). The l1or-tga;e has
bee~ recorded in the Office of. the Recorde:: c: Deejs fo:: the :c~nty
of Cwrberla~d, Pen~sy~va~ia in Book 11~21 Page 0378.
This letter shall serve as the "r.~tten cc::eer.t of Fulton Bank,
given pursuant tc' Paragrapr. 17 of tr.a Eongage, tc. t~e
afo:-ementioned conveyance of the Real S.stat€. Such conveyar.ce a:1d
this COrlsem: shall in :10 ...Iay dischar.,e any of the ir.debtedr:ess
se::ured by the Hor-tgage or impair tr.e p:-io:-i.ty or effect c.: the
Mortgage.
~lagner
Vice sident
Residential Mortgage l1anager
JJW/cac
EXHIBIT
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TOTRL P.03
__ 2~"':~
TI:I
t' n~'
FPCi'" Hl'r'Tri,"':',: =o::f'<:"_I,:I,,;,r'':I.lf:'~'.
.'
IELEAse:
KNOW All JEIC BY THl!SE PRESEIfiS that Fulton s.nlc. fnUndlng
to be l'9'al1y bound. h....by relusls PATTI S. HARTMAN
personal l1abflfty under (1) IIIOrtgage date<f JUNE 8
19..ll. (recorde<f at CUnBERLAND COU,\TY COURTHOUSE ;
fMlID
.
i1Id (2) the
IIlQrtgage noU!. secure<! by such IlIOrtgage; reservfng, however, all lu
rfghts and reme<fles thereunder. against GREGORY R. HliRTMA/;
and agafnst the real .,taU! covered by said mortgage and other coHateral
securfng such lDO~age note, if any.
IN IIITftESS WHEREOF these presents are duly executed eM s
?8th day of SEPTEMBER
, 19.2Q...
FULTON
AND
oIDENT!AL MORTGAGES
19'1'6', I.
HOW.
GREGORY R. HARTMArI
hereby consent to and approve the above
release and agree that such release sha 11 not affect my liability under
the aforesaid mortgage or 1IICrtgage note and that I shall rell1ilin 1'u17y
and solely lfable un<fer the aforesaid mortgage and mortgage note despite
such release.
~l~~
"GREG RY " HARHIAN
(To Be Executed In Triplicat~
(r/-;"~-:':(lt) c_ :l.\~i"'\ FF'I:..' ~i!tl r,,~,. ': '-.-1 ,":"J':I.... -,~"
, ....~.U:.i' F' ,fJ.::
Fulton Bank
?~Jple dedlc,;:ed 10 YCt;r 51!CWS..
0\-
i );J.-. . h\Rr.:I;:';l!PC. P:\ 171.,',~
July 21. 1998
lvIr. Gregory R.-l-!nnmaJl'
Hartman & Scheuehenzuber
4823 E. Trindle Road
Mcchanicsburg, PA 17055
Dear Greg:
Upon satisfa..:torj review orthe l\1aritul Sep~ration Agreemt:nt between Gregory R. and
Patti S. Eartman, Fulton Bank hereby agrees to relen,e ?2tti S.l-lal1mon from ell
guarantees aJ~d financial obligations for ;he deb: aS$ociat~d with DGS Enterprises and
Hartman &. Seheueh"nwbc....
The appr')priale documents "ill be executed within 30 days of the final settkment. If you
h~ve any queslions, please reel free to call me at 255.7669.
sit~CerellC ~
James G. Tamall
Vice President
EXHIBIT
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GREGORY R. HARTMAN,
plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
I
II
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PATTI S. HARTMAN,
Defendant
vs.
NO.
4645 1996
CIVIL ACTION
DIVORCE AND CUSTODY
'1
II
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PRAECIPE TO TRANSMIT RECORD
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II TO THE PROTHONOTARY:
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Transmit the record, together with the following
information, to the court for entry of a divorce decree:
1. Ground for Divorce: irretrievable breakdown under
I Section (3301(c) of the Divorce Code.
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II
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2. Date and manner of service of the Complaint:Michael
Barrick, Sheriff or Deputv Sheriff of Cumberland Countv,
pennsvlvania served the Complaint in Divorce upon Patti S.
Hartman on AUGust 26, 1996 and the Sheriff's return was filed
AUGust 27, 1996.
on
3.
(Complete either paragraph (a) or (b).)
I (a) Date of execution of the Affidavit of Consent
' required by Section 3301(c) of the Divorce Code: by the plaint if
II October 21, 1998; by the defendant October 21. 1998.
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(bl III Date of execution of the plaintiff's affidavi
required by Section 3301(d) of the Divorce Code:
(2) Date of filing and service of the plaintiff'
affidavit upon the defendant:
4.
Related claims pending: Nnnp
I
5. Date and manner of service of the notice of intention I
to file praecipe to transmit record, a copy of which is attached]
if the decree is to be entered under section 3301 (d) (1) (i) of thJ
Divorce Code.
I; (Complete either (a) or (b).)
(a) Date and manner of service of the notice of intention
to file praecipe to transmit record, a copy of which is attached1
1
MEYERS, DES FOR & SALTZGIVEn
,11OtJOIITHSECQND Sl11EET . PO nox 1Of.2 . HAfmIS[1lJl1G, PA 1/11111
(111) ?:Il;-!j.12H . FAX {Ill) 23h;!1l17
,
(b) Date Plaintiff's Waiver of Notice in 5 3301(c) Divorc
was filed with the prothonotary: October 22, 1998.
Date Divorce
was filed with
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MEYERS, OESFOR & SALTZG1VER
.\10 NORTH SECOND STREET . P.o. OOX 1062 . HARRISOURG. PA 17108
(717) 236.9428 . FAX (717) 236-2817
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LI\W OffIces
SNELlJAKER,
BRENNEMAN
Be SPARE
DR#
GREGORY R. HARTMAN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 96-4645 CIVIL TERM
PATTI S. HARTMAN,
Defendant
IN DIVORCE
ORDER OF COURT
AND NOW, this
day of
, 1997, upon
consideration of the attached Petition for Alimony Pendente Lite,
Counsel Fees and Expenses, it is hereby directed that the parties
and their respective counsel appear before
on
at
o'clock
.M. for a
conference, after which the conference officer may recommend that
an order for Alimony Pendente Lite be entered.
You are further ordered to bring to the conference:
(1) a true copy of your most recent Federal Income Tax
Return, including W-2s as filed;
(2) your pay stubs for the preceding six (6) months;
(3) the Income and Expense statement attached to this
order, completed as required by Rule 1910.11(c);
(4) verification of child care expenses; and
(5) proof of medical coverage which you may have, or may
be available to you.
If you fail to appear for the conference or bring the
LAW OFFICE:G
SNELBAKER.
BRENNEMAN
Be SPARE
to Petitioner, to be paid by Respondent.
Respectfully Submitted,
SNELBAKER, BRENNEMAN & SPARE, P. C.
By: p~~1~~-:e Esquire
44 W. Main street
Mechanicsburg, PA 17055
(717) 697-8528
Attorneys for Petitioner-
Defendant Patti S. Hartman
Date: February 10, 1997
-2-
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PATTI S. HARTMAN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 96 -4645
GREGORY R. HARTMAN,
Defendant
CIVIL ACTION
IN DIVORCE
ORDER OF COURT
The parties have hereby agreed that the amount of
Alimony Pendent Lite to be paid by the Defendant to the
Plaintiff shall increase to $556.00 per month effective June
12, 1997.
Defendant shall receive a credit toward arrears of
$388.00 including Defendant's credit, the total amount of
arrears to be paid is $823.00. Upon the entry of this
order, Defendant shall pay $250.00 to Plaintiff against
arrears. Starting the month immediately following
Defendant's $250.00 payment, he shall pay $SO.OO/month
against arrears until said arrears are paid in full.
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BY THE COURT,
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MEVERS 8. DESFOR
410NORTHSr.CONDSTREET . PO 80X1062 . HARRISBURG, PA 17108
(7171236-9428 . FAX (717)236.2817
\
In light of the foregoing, the Parties have reached the
following agreement:
1. The parties' daughter, Kelly L. Hartman (Date of Birth
February 29, 1979), has graduated from high school and
other than set forth below, Husband shall not pay child
support for Kelly, effective June 12, 1997.
2. Also effective June 12, 1997, Husband shall pay $508.00
per month to Wife for the support of the parties'
daughter, Megan E. Hartman (Date of Birth October 10,
1990) .
3. Also effective June 12, 1997, Husband shall pay $556.00
per month to Wife as alimony pendente lite.
4. Arrears:
a. The child support arrears are $857.00. Alimony
pendente lite arrears are $1,211.00.
b. Husband is entitled to $1,594.00 credit towards
child support and alimony pendente lite arrears.
c. The child support arrears have been paid in full
and Husband owes $474.00 in alimony pendente lite
arrears.
d. Upon entry of this Agreement as a Court Order,
Husband will pay a "down payment" of $250.00
toward the alimony pendente lite arrears. Each
month thereafter, Husband shall pay the arrears at
a rate of $50.00 per month until such time the
2
..
GREGORY R. HARTMAN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 96-4645
PATTI S. HARTMAN,
Defendant
CIVIL ACTION
DIVORCE AND CUSTODY
AMENDED ORDER OF COURT
The parties have hereby agreed that the amount of
Alimony Pendent Lite to be paid by the Defendant to the
Plaintiff shall increase to $556.00 per month effective June
12, 1997.
Defendant shall receive a credit toward arrears of
$388.00 including Defendant's credit, the total amount of
arrears to be paid is $474.00. Upon the entry of this
order, Defendant shall pay $250.00 to Plaintiff against
arrears. Starting the month immediately following
Defendant's $250.00 payment, he shall pay $50.00/month
Ii
against arrears until said arrears are paid in full.
The prior Order dated October 6, 1997, is hereby
rescinded.
BY THE COURT,
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MEYERS &: llESFOR
<l10rWATHSrCOfJDSTR[ET . PO [lOX 1067 . HARRISBURG. PA 1110B
17171;>36.9<1]B . FAX (717)236.2817
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PATTI S. HARTMAN,
Plai.ntiff
IN THE COURT or COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VB.
NO. 96-4645
GREGORY I'. HAHTMAN,
Defendant
CIVIL ACTION
IN DIVORCE
II
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I Alimony Pendent D.i te to be paid by the Defendant to the
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ORDER OF COURT
The parties have hereby agreed that the amount of
Plaintiff shall increase to $556.00 per month effective June
12,
1997.
Defendant shall receive a credit toward arrears of
$388,00 includincJ Defendant's credit, the total amount of
arrears
to be paid is $823.00.
Upon the entry of this
order, Defendant shall pay $250.00 to Plaintiff against
arrears.
Starting the month immediately following
Defendant's $250.00 payment,
he shall pay $50.00/month
against arrears until said arrears ara paid in full.
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MEYERS & DESFOR
410 NORTH SECOND STREET . P. o. BOX 10fil' . HARHISI3URG, PA. 17100
(717)23(;,,9428 . rAX (717)236.2917
1.n 1i911:': 01 tlF' rnrcCJoill'-', Lh.-! Pdt; 1'-':~ hav,~_' r'."~ac!1(:d t:he
Eol10vli.llSl a~p--ec:mcnL:
1, The part".icf-3' dauSJhtl..'r, K,~l.iy 1.J. I-!i.H.t:n,Hl (DaL(: at nirl:l1
F'ebl-uC:l1:y' ~9, 1.,)'/9), har; 'J)"adu("lt,--,rj !!.:_);n hiq:l ~.:chool and
othElr t.han set fort.h bi-:luvl, itll:..:;h.~lll'J ~:;il(lll !lot pay child
suppo::t Eor Kelly, c;ffective ,Juncl/., 1997.
2. Also ef::cctiv(! ~Tune 12, :!997, l!u~:>\:'dnd ~jha] 1 pay $508.00
per mQn~h to Wife fOl- l11(~ SUPP01:t of tile 11drties'
daughter, ivj':~gan E. Ha-:-:tman (Date of 0irth Oclcber 10,
1990) .
3. Also e::f:ecl.:..ive LJune 1.2, 1997{ Hlj~;ban() shall pay ~;55C.OD
per 1;~(jr:.L.h to \'!:i.fe .:.'1..'3 C11imony pendente J.itc.
4. . l\l'T'ears:
a.
T~:e child support arrears al~e ~857.00.
Alimony
pendente littJ ~irrears are $l,21J_.00.
b. Husband is entitled to $1,591.00 credit towards
Cililcl r;upport and alimony pendentc lite arrears.
c. ~'he clli.ld support ar)~ears have been paid in full
and lWsband owes $474.00 in alimony pendente lite
arrears.
d. Upon entry of tili.,; Agreement as a Court Order,
HUf;band will pay a "down payment" of $250.00
LOVli1rrJ the alimony pcnden te Ii te arrears, Each
month thcreaft"r, Husband shall pay the arrears at
ij raUl oj :;;';0.00 per month until such time the
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GREGORY R. HARTMAN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERT~ND COUNTY, PENNSYLVANIA
v.
NO. 96-
CIVIL TERM
PATTI s. HARTMAN,
Defendant
IN DIVORCE AND CUSTODY
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in court. If you wish to defend
against the claims set forth in the following pages, you must take
prompt action. You are warned that if you fail to do so, the case
may proceed without you and a decree 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 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 the Cumberland County Courthouse,
First Floor, Carlisle, pennsylvania 17013, Telephone: (717)-240-
6195.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF
PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT
IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF
YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE
THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL
HELP.
COURT ADMINISTRATOR
4TH FLOOR
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013
(717) 240-6200
Court require the parties to participate in counselling.
8. The marriage of the parties is irretrievably broken.
WHEREFORE, plaintiff respectfully requests that the Court
enter a Decree in Divorce pursuant to ~3301 of the Divorce Code.
COUNT II
REQUEST FOR EQUITABLE DISTRIBUTION OF MARITAL PROPERTY
9. The prior paragraphs in this Complaint are incorporated
herein by reference thereto.
10. Plaintiff requests the Court to equitably divide,
distribute or assign the marital property between the parties in
such proportion as the Court deems just after consideration of all
relevant factors.
WHEREFORE, plaintiff respectfully requests the Court to enter
an Order of equitable distribution of marital property pursuant to
~3302(a) of the Divorce Code.
COUNT III
REQUEST FOR CUSTODY
11. The prior paragraphs of this Complaint are incorporated
herein by reference thereto.
12. The parties are the parents of the following
unemancipated minor children who currently reside at 2115 Foxfire
Drive, Mechanicsburg, Pennsylvania:
Name
Kelly Lynn Hartman
Megan Elizabeth Hartman
Age
17
5
Sex
Female
Female
Date of Birth
2/28/79
10/10/90
13. During the past five years, the children have resided
with the
parties
2115 Foxfire
Drive,
Mechanicsburg,
at
pennsylvania.
Also, residing with the parties was their first
child, Amy Michelle Hartman, born April 11, 1976.
14. Plaintiff has not participated in any other litigation
concerning the children in this or any other state.
15. There are no other proceedings pending involving custody
of the children in this or any other state.
J.6. Plaintiff knows of no person not a party to these
proceedings who has physical custody of the children or who claims
to have custody, partial custody or visitation rights with respect
to the children.
17. The best interest of the children will be served if
primary custody of them is given to plaintiff.
WHEREFORE, plaintiff respectfully requests that, pursuant to
~3304(a) (ii) and ~3323(b) of the Divorce Code, the Court enter an
Order awarding primary custody of the children to plaintiff.
Respectfully submitted,
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R. Mark Thomas, Esquire
Attorney for Plaintiff
54 E. Main street
Mechanicsburg, PA 17055
(717) 697-4650
I.D.# 41301
VERIFICA'l'ION
I verify that the statements made in the foregoing Complaint
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.
A.~~~ ~ ~~6, ",.-1
Gi'egory R. artman
Date:
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SNELDAKER
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BRENNEMAN
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Ii at this time because the parties have not separated and the
,
marriage has not been dissolved.
4,
The issue of custody is not properly before this Court
5. Plaintiff's Complaint is legally insufficient as it
!fails to state a cause of action in custody upon which relief can
II be granted.
II
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I WHEREFORE, Defendant, Patti S. Hartman respectfully requests
your Honorable Court to dismiss Count III of Plaintiff's
I Complaint
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involving custody of Minor Children.
Respectfully Submitted,
SNELBAKER & BRENNEMAN, P. C.
By:
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Ptulip 'H. S re, Esquire
44 W. Main street
Mechanicsburg, PA 17055
(717) 697-8528
Attorneys for Defendant
Patti S. Hartman
Date: September 11, 1996
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LAW OF'FICE6
SNEI.DAKER
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CERTIFICATE OF SERVICE
I, PHILIP H. SPARE, ESQUIRE, hereby certify that I have,
on the below date, caused a true and correct copy of the
foregoing Preliminary Objection to be served upon the person and
in the manner indicated below:
FIRST CLASS MAIL. POSTAGE PREPAID. ADDRESSED AS FOLLOWS:
R. Mark Thomas, Esquire
54 E. Main Street
Mechanicsburg, PA 17055
v;
ilip . S
SNELBAKER & BRENNEMAN, C.
44 West Main Street
P. O. Box 318
Mechanicsburg, PA 17055
(717) 697-8528
Attorneys for Defendant
Patti S. Hartman
Date: September II, 1996
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GREGORY R. HARTMAN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 96-4645 CIVIL TERM
PATTI S. HARTMAN,
Defendant
IN CUSTODY
ORDER OF COURT
AND NOW, this 1. I day of T '^ ^ v . I 'f , 1997,
,
upon consideration of the attached Petition, it is hereby directed
that the parties and their respective counsel appear before
_D ,,~ A ~ C, ,.j,,, , ~" 0 , the conciliator, at
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~. ); .,.." h,', '" 4l.( tJ ~,~ ,-. .. ( l.. " "', ( '~ ~ (... { ,~ on the l r .. "-
day of J::,b,"^",' , 1997, at 1.'.<;0 F.M., 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. Either party may bring
the child who is the subject of this custody action to the
conference, but the child/children's attendance is not mandatory.
Failure to appear at the Conference may provide grounds for entry
of a temporary or permanent order.
FOR THE COURT:
By:
[)cuu--rJ-J -<"il'~L?'1 ~ ~
Custody Conciliator '
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.
Office of the Court Administrator
Cumberland County Courthouse
Fourth Floor
Carlisle, PA 17013
(717) 240-6200
GREGORY R. HARTMAN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 96-4645 CIVIL TERM
v.
PATTI S. HARTMAN,
Defendant
IN CUSTODY
PETITION FOR CONCILIATION CONFERENCE
AND NOW, comes the petitioner, Gregory R. Hartman, by and
through his attorney, R. Mark Thomas, Esquire, and petitions this
Court to schedule a Custody Conciliation Conference in the above-
captioned matter.
1. On or about August 22, 1996, your petitioner filed a
Complaint seeking custody of his minor child indexed at the above
term and number.
2. Dawn sunday, Esquire was appointed as the Custody
Conciliator and a Conciliation Conference was scheduled for
september 12, 1996.
3.
By Order dated September 23,
the custody
1996,
Conciliator relinquished jurisdiction in this case since the
parties were continuing to reside in the same residence where the
minor child was also living.
4. Respondent has advised petitioner that she is moving out
of the marital residence on or about February 8, 1997, and your
petitioner desires that a Custody Conciliation Conference be
scheduled to address the issues raised in the Complaint.
Respectfully submitted,
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R. Mark Thomas, Esquire
Attorney for Petitioner
54 E. Main street
Mechanicsburg, PA 17055
(717)697-4650
1.D.# 41301
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Plaintiff
IN THE COURT OF ~U1ON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
vs.
NO. 96-4645
CIVIL TERM
PATTI S. HARTMAN,
Defendant
IN CUSTODY
ORDER OF COURT
AND ~,this 111'" day of
upon consideration of the attached Custody
ordered and directed as follows:
Flo~H" V ""I. , 1997,
Conciliation 'Report, it is
1. The Father, Gregory R. Hartman, and the Mother, Patti S.
Hartman, shall have shared legal and physical custody of Megan Elizabeth
Hartman, born October la, 1990.
2. The parties shall share physical custody of the Child on a
rotating biweekly schedule as follows:
A. Week One:
1. The Mother shall
Monday after daycare
daycare.
have custody of the Child from
until \vednesday morning before
2. The Father shall have custody of the Child from
Wednesday after daycare until Saturday morning at 9:00
a.m.
3. The Mother shall have custody of the Child from
Saturday morning at 9:00 a.m. until the following Monday
before daycare.
B. Week Two:
1. The Fa ther shall
Monday after daycare
daycare.
have custody of the Child from
until Wednesday morning before
2. The Mother shall have custody of the Child from
Wednesday after daycare until Saturday morning at 9:00
a.m.
3. The Father shall have custody of the Child from
Saturday morning at 9:00 a.m. until the following Monday
before daycare.
C. This rotating custody schedule shall begin with the
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GREGORY R. HARTMAN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 96-4645
CIVIL TERM
PATTI S. HARTMAN,
Defendant
IN CUSTODY
CUSl'ODY COOCILIATIOO SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND CXXJNTY RULE OF CIVIL PROCEDURE
1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Child who is the subject
of this litigation is as follows:
NAME
DATE OF BIRTH
aJRRENl'LY IN aJSTODY OF
Megan Elizabeth Hartman
October la, 1990
Plaintiff/Defendant
2. A Conciliation Conference was held in this matter on February 6,
1997, with the following individuals in attendance: The Father, Gregory R.
Hartman, with his counsel, R. Mark Thomas, Esquire, and the Mother, Patti
S. Hartman, with her counsel Philip H. Spare, Esquire.
3. The Mother is moving to a separate residence on Saturday, February
8, 1997. To their credit, the parties were able to cooperate in making
custody arrangements for their six year old daughter during the six week
transition period. After that time, either the parties will be able to
establish ongoing custody arrangements between themselves by agreement or
will attend the second Conciliation Conference scheduled for March 27, 1997
if necessary.
4. The parties agree to entry
fe.b rua.r/J
Date
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.
of an Order in the form as
~_JL_",-dW'
Dawn S. Sunday, Esquir
Custody Conciliator
attached.
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GREGORY R. HARTMAN,
plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: NO. 96-4645
CIVIL TERM
PATTI S. HARTMAN,
Defendant
: CIVIL ACTION - LAW
: IN CUSTODY
OlUlER OF COURT
AND N(lol, this 3rd day of July,
1997, the Conciliator
relinquishes jurisdiction in this case based on the fact that counsel for
the parties had canceled the second Conference scheduled for March 27, 1997
and no current request is pending by the parties for an additional
Conference.
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Dawn S. Sunday, Esquire [I
Custody Conciliator
In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
PATTI S. HAR'!'MAN ) Dlldt:1 Numhl.'r 96-4645
Plaillliff )
VS. ) PACSES Case Numher 014000022
GREGORY R, HARTMAN )
Dcft:mJam ) Other Sial" ID Numh"r ,x;(;;f5() 1
Order
AND NOW to wit, this
NOVEMBER 9, 1998
it is hereby Ordered
that:
THE ABOVE ALIMONY PENDENTE LITE ORDER IS TERMINATED, EFFECTIVE OCTOBER 29,
1998 PURSUANT TO THE FINAL DIVORCE DECREE OF OCTOBER 29, 1998. THE
REMAINING OVERPAYMENT OF $999,55 WILL BE DIRECTED AS A CREDIT ON THE CHILD
SUPPORT CASE AS WILL THE $26.23 SERVICE FEE CREDIT WILL BE APPLIED ON THE
SERVICE FEE ON THE CHILD SUPPORT ACCOUNT.
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BY THE COURT:
DRO: R..1. Shadday
cc: Patti. S. HaY'tman, pIalntl.ff
Service rli~iJ.Y.{y R. Hartman, dcfend'lIlL
P'(11.1 Lp H. Sptirc, EsqJl.re
Catherine A. B0Y]C, EsqJI.re
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I~dgar B. 11a,lCY,
.JUDGE
Form OE-OO I
Worker ID 21005
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SNELBAKER
BRENNEMAN
8: SPARE
VERIFlCATI()N
I vcrily thatthc statcmcnts madc inthc lill'cgoing Pctition Illr Modilication arc truc and
corrcct. lundcrstand that falsc statcmcnts hcrein arc madc subjcct to thc penaltics of 18 Pa, c.s,
S 4904 rclating to unsworn falsification to authoritics,
/d& d,4u.LL
. Patti S, Powell
Date: March it).. , 2002
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GREGORY R. HARTMAN,
Plaintiff
IN THE COURT OF CCX1MON PLEAS OF
CU11BERLAND COUNTY, PENNSYLVANIA
vs.
NO. 96-4645
CIVIL TERM
PATTI S. HARTMAN,
Defendant
IN CUSTODY
ORDER OF CCURT
AND 10/, this 1/ ii day of 3'-eL~ ,1997,
upon consideration of the attached Custody Co:Ciliation f(~port, it is
ordered and directed as follows:
1. The Father, Gregory R. Hartman, and the Mother, Patti S.
Hartman, shall have shared legal and physical custody of Megan Elizabeth
Hartman, born october la, 1990.
2. The parties shall share physical custody of the Child on a
rotating biweekly schedule as follows:
A. Week One:
1. The Mother shall have custody of the Child from
Monday after daycare until Wednesday morning before
daycare.
2. The Father shall have custody of the Child from
Wednesday after daycare until Saturday morning at 9:00
a.m..
3. The Mother shall have custody of the Child from
saturday morning at 9:00 a.m. until the following Monday
before daycare.
B. Week Two:
1. The Father shall have custody of the Child from
Monday after daycare until Wednesday morning before
daycare.
2. The r10ther shall have custody of the Child from
Wednesday after daycare until Saturday morning at 9:00
a.m.
3. The Father shall have custody of the Child from
Saturday morning at 9:00 a.m. until the following Monday
before daycare.
C. This rotating custody schedule shall begin with the
EXHIBiT ^
l'. I of 2
LAW OFFICES
SNEL8AKER.
BRENNEMAN
&: SPARE
~'I'RTIFIC^,IT OF SER VICE
I, PHILIP II. SPARE. ESQUIRE. h~r~by ~~rlify lhall haw on lh~ below dat~.
~aus~d a lru~ and corr~ct copy of lh~ Illr~going P~lition Il)r Modili~ation to b~ s~rv~d upon th~
p~rson and in th~ mann~r indicat~d b~low:
FIRST CLASS MAli.. POSTAGE PREPAID. ADDRI'SSED AS FOLLOWS:
Daled: March 13 .2002
('atherin~ A, Boyl~. Esquir~
Mey~rs. Desfor. Saltzgiv~r & Boyle
410 Nurth Second Streel
1',0, Box 1062
Harrisburg. I' A 17108
Qfl/;!~-0
Philip II, Spare, Esquire
Snelbak~r. Brenneman & Spar~. I',c.
44 WeSI Main Street
1',0, Box 318
Mechanicsburg. I' A 17055-0318
(717) 697-8528
Attorneys for Defendant Patti S, Powell
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5, Th~ Fath~r shall hav~ partial phYSical cuslody "I' th~ ('llIld "n alt~rnating \\c~k~nds rrom
Friday at 5:30 p,m, through Sunday at 8:00 p,m,
6, Th~ parties shall shar~ or alt~rnal~ having custody orth~ Child on holidays as r"II,,\\s:
A, CHRISTMAS: The Christmas holiday shall b~ divid~d int" S~gm~nt A, which
shall run rrom Christmas Ev~ at 12:00 noon through Christmas Day at 12:0(J noon. and
Segment B, which shall run Irom Christmas Day at 12:00 noon through D~c~mb~r 26 at
12:00 noon, In even numbered years, th~ Moth~r shall hav~ custody or th~ Child during
Segment A and the Father shall have cuslody during Seglll~nl 13, in odd nUJJ1ber~d
years, the Fath~r shall have custody orth~ Child during S~glll~nl A allll th~ Moth~r shall
have custody during Segmenl B,
B. ALTERNATING HOLIDAYS: The parti~s shall alt~rnat~ having custody or the
Child on Thanksgiving, Easler, M~morial Day, July 41h and l.abor Day rrom 9:00 a,m.
until 9:00p.m, In even numbered years, the Mother shall have custody or the Child on
Labor Day and Memorial Day, and the Father shall have custody on Easter, July 41h and
Thanksgiving, (n odd numbered years, the Father shall have custody or the Child on
Memorial Day and Labor Day and the Mother shall have custody on Easter, July 41h and
Thanksgiving,
C, MOTHER'S DA Y/FATHER'S DAY: In every year, the Mother shall have
custody or the Child on Mother's Day and the Fathcr shall have custody on Father's
Day rrom 9:00 a,m, until 9:00 p,m,
D. The holiday custody schedule shall supersede and take precedence over the regular
custody schedule,
7, Each party shall be entitled to have custody or the Child 1'01' 2 non-eonsceutive weeks during
the summer school break each year upon providing at least 30 days advance notice to the other party,
8, Neither party shall do or say anything which may estrange the Child rrom the other parent,
injure the opinion orthe Child as to the other parent, or hamper the rree and natural development or the
Child's love and respect 1'01' the other parent. Both parties shall cnsure that third parties having contact
with the Child comply with this provision,
9 Either party, through counsel, may contact the Conciliator to request the scheduling or an
additional Conciliation Conrerence, ir necessary, after making a reasonably diligent errort to complete
the counseling as provided in this Order,
exacerbated by reducing contact between the Child and the Father. As the parties were not able to
reach an agreement on this issue. the Conciliator recommends continuing the .dtemating weekend
periods of partial custody in accordance with the parties' agreement in April. rccognizing that the
agreement resulted in a substantial reduction from the previously shared arrangement.
Date
(J-"e''&'f ,\' },'c)
J
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...............~' ..{..
Dawn S. Sunday, Esquir
Custody Conciliator
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