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HomeMy WebLinkAbout00-00448 "',, . . . .. . . . .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY . PENNA. . STATE OF . YVONNE L. RENDE, . Plaintiff No. 2000-448 CIVIL TERM . VERSUS . ;F. RALPH A. RENDE, . . Defendant . . . DECREE IN DIVORCE it L( ~ ~~ A 2003 ,IT IS ORDERED AND . . . . . . . AND NOW, . YVONNE L. RENDE , PLAINTIFF, DECREED THAT . RALPH A. RENDE , DEFENDANT, AND . . . 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 Property Settlement Agreement dated March 3, 2003 shall be incorporated, but not merged, into this Decree in Divorce. . . . . . . . . . . i,,'I'-' ,'-' I, ;.0 , ~ ", " .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J. . . . . . 3/:<'0 &/-~~:'-t;''4~ J/d;tJ3 7f~.. ~ ~~ ~" ,~-~ ~~ ~ - -~ ~,,___~ r"~'."""I.,,~','lI'\f!II!lIiIP''''"",L",,''' ~ ~lIII!'!l!l!lll!rr , ,+llI!!l'II~ , . I-~,;) . ' . ' PROPERTY SETTLEMENT AGREEMENT THIS AGREEMENT, made this ~ day ~vfL , 2003, by and between YVONNE L. RENDE, residing at 35 Meadowbrook Court, New Cumberland, Cumberland County, Pennsylvania, hereinafter referred to as "WIFE," and RALPH A. RENDE, residing at 2 York Road, New Cumberland, York County, Pennsylvania, hereinafter referred to as "HUSBAND." WI TNESSETH: WHEREAS, the parties were lawfully married on September 23, 1989, in New Cumberland, York County, Pennsylvania; and WHEREAS, in consequence of disputes and unhappy difficulties, the parties have agreed to live separate and apart during their natural lives; and WHEREAS, the parties are desirous of settling their existing property rights including an amicable equitable distribution, assignment and division of their property, which property is considered to be "marital property" as defined in the Divorce Code known as Act 26 of 1980, and amendments thereto enacted into law on February 12,1988; and NOW THEREFORE, in consideration of the promises and the mutual undertaking herein contained and for other good and valuable consideration, the parties, intending to be legally bound, agree as follows: 1. Separation. The parties shall hereinafter live separate and apart. Each shall be free from interference, authority, and control, direct and indirect, by the other as if he or she were single and unmarried, 2, Control of Agreement. The provisions of this Property Settlement Agreement shall govern all past, present, and/or future claims for alimony, support, counsel fees and costs, alimony pendente lite, 1 "......~, . ' equitable distribution, or other property rights, and all other claims which the WIFE or HUSBAND has or might have against the other except as set forth hereinafter. 3. Divorce. A Complaint in Divorce was filed in Cumberland County by WIFE on or about January 24. 2000, which Complaint is docketed to No. 2000-448. The Complaint was served upon HUSBAND via Certified Mail, Restricted Delivery on or about February 1, 2000. Hl.!SBAND accepted service of such Complaint on February 2, 2000. Simultaneously with the execution of this Agreement, the parties agree to sign and cooperate with the immediate filing of any and all documents necessary to obtain a Divorce Decree under Section 3301 (c) or 3301 (d) of the Divorce Code, including but not limited to, Affidavits of Consent, Affidavits Waiving Marriage Counseling, and Waivers of Notice of Intent to Seek Divorce under Section 3301 (c) of the Divorce Code. The parties intend that this Agreement shall be incorporated into any forthcoming Decree in Divorce. 4. Real Property. The parties acknowledge that they are the owners of real property, which property HUSBAND purchased prior to the parties marriage located at 2 York Road, New Cumberland, York County. Pennsylvania. HUSBAND represents that there are no encumbrances on the home whatsoever. and that the Mortgage and Note on the home which were in his name individually, have been satisfied in full. HUSBAND paid approximately Thirty Two Thousand ($32,000.00) Dollars for the home from his individual funds, and the parties estimate the home's fair market value currently to be approximately Sixty Two Thousand ($62,000.00) Dollars. HUSBAND and WIFE moved into the home together immediately after its purchase, however married several years later. The parties agree that there is an approximate Thirty Thousand ($30,000.00) Dollar increase in value which is marital property subject to equitable distribution. The parties agree that HUSBAND shall retain the marital home, subject to any and all encumbrances thereupon, as his sole and separate property. HUSBAND shall be solely responsible for payment of all bills in connection with the marital home, including but not limited to the mortgage, taxes, insurance, utilities, repairs, and general maintenance, and HUSBAND shall indemnify WIFE and hold her harmless with respect to any past, present or future liability in connection with the marital home and/or with respect to his non- payment or non-performance of the above obligations. Simultaneously with the execution of this agreement, WIFE shall convey all of her right, title, and interest in and to the marital home to HUSBAND, and WIFE agrees to cooperate with the signing of any deeds, documents or other papers necessary to effectuate this provision of the Agreement. The parties contemplate that HUSBAND shall assume full and sole financial responsibility for each and every debt of . ~. ",--I lilIiiiiiillli,. j , ' any kind whatsoever in connection with the home and lot identified in Paragraph 5 below, and in exchange for this, WIFE shall waive any right she may have to the home or to the increase in value of the home and the lot. 5. Building Lot. The parties jointly own a commercial building lot which is adjacent to the marital home and which has an estimated fair market value of approximately Twenty Five Thousand ($25,000.00) Dollars. HUSBAND represents this lot is free from all encumbrances of any kind whatsoever. The parties agree that HUSBAND shall retain this lot, subject to any encumbrance thereupon, as his sole and separate property. HUSBAND shall be solely responsible for payment of all bills in connection with this lot, including but not limited to the mortgage, taxes, insurance, utilities, repairs. and general maintenance. and HUSBAND shall indemnify WIFE and hold her harmless with respect to any past, present or future liability in connection with this lot and/or with respect to his non-payment or non-performance of the above obligations. HUSBAND and WIFE agree to cooperate with the prompt execution of whatever documents necessary to effectuate the provisions of this paragraph. 6. Huntingdon Cabin. The parties own, together with WIFE'S family John D. and Delores M. Shimmel, a cabin in Huntingdon, Pennsylvania. The parties own as tenants by the entireties, an undivided one-half interest in this property, and the Shimmel's own as tenants by the entireties, an undivided one-half interest in the property. The one-half interests are held as tenants in common. There are no encumbrances upon this cabin. The parties agree that the cabin shall remain titled in all four (4) parties names, and both HUSBAND and WIFE shall be entitled to use and enjoy it, upon reasonable advance notice to the other party. HUSBAND and WIFE shall retain their respective interest in the property and in the event that one of the parties no longer desires to retain the cabin, the other party shall be given the right of first refusal to purchase the other's interest. In the event the cabin is sold, HUSBAND and WIFE shall each be entitled to 1/4 of any net proceeds, after payment of all normal settlement charges including but not limited to realtor commissions, transfer taxes, attorney's fees, and any other tax, cost, expense or fee generated in connection with the sale. 7. Employee. I'ension and Retirement Benefits. The parties acknowledge that WIFE is the owner of a Hertzler-Ammerman Associates Profit Sharing Plan which Plan had a value as of December 31, 1998 of Seventeen Thousand, Six Hundred and Seventeen ($17,617.26) Dollars and Twenty Six Cents. WIFE is also the owner of a Hertzler-Ammerman Associates Pension Plan which Plan had a value as of December 31, 1998 of Fourteen Thousand, Eight Hundred and Nineteen ($14,819.24) Dollars and Twenty '~~d-..~,~ . ' Four Cents. HUSBAND acknowledges that he has no retirement or investment plan that can be considered marital property as that term is defined in the Pennsylvania Divorce Code. WIFE shall retain as her sole and separate property, the retirement accounts referenced above. Furthermore, WIFE shall retain as her sole and separate property, any individual retirement account, and/or retirement benefit plan (including but not limited to pension or profit sharing plans, deferred compensation plans, defined benefit plans, 401 (k) plans, employee savings and thrift plans, IRA's, or other similar benefits), whether vested or non-vested. The above shall specifically include a waiver of any spousal annuity benefits and/or beneficiary designations thereunder. Furthermore, each party shall be and remain the sole owner of any other asset in his or her control not specifically covered by other provisions of this Agreement. Should it become necessary, each party agrees to sign any other title or documents necessary to give effect to this section upon request of the other party. 8. Personal Property. The parties have acquired certain personal property during the course of their marriage and hereby acknowledge and represent that such personal property, including household furnishings and other similar property, has been divided to their mutual satisfaction. It is agreed that each party shall retain all items of tangible personal property currently in their possession as if it were their sole and separate property. Neither party shall make any claim to any such items of marital property, or of the separate personal property of either party which are now in the possession or under the control of the other. Furthermore, each party agrees to waive any right, title, and/or interest they may have to the property in the possession of the other. Should it become necessary, the parties each agree to sign upon request, any titles or documents necessary to give effect to this paragraph. 9. Automobiles. There are no jointly titled automobiles in existence. The parties shall each retain their respective vehicles as their sole and separate property, subject to any liens and encumbrances. The parties agree to indemnify and hold the other harmless with respect to any encumbrance on their respective vehicles, for which they shall be solely responsible. Each party agrees to waive any right, title or interest he or she may have in the vehicle of the other, and promptly sign any and all documents necessary to effectuate the provisions of this paragraph. 10. Bank Accounts. Any and all bank accounts in the parties' names which existed at separation have been previously divided to both parties' mutual satisfaction. Furthermore, each party agrees to waive any right, title or interest he or she may have in the bank account of the other. ._-, ,,-...- ;..f"~ 11. Alimony. Spousal Support. Alimony Pendente Lite. Counsel Fees. Costs and Expenses. Each party specifically waives any past, present and/or future claims against the other party for alimony, spousal support, APL, counsel fees, and costs and expenses. 12. Credit Card Debt. There are no joint credit cards in existence and all marital credit card debt has been satisfied in full. Any other credit card debt in existence shall be the sole and separate responsibility of the person who incurred such debt, and that person shall indemnify and hold the other harmless with respect to any and all liability in connection with the same. 13. Miscellaneous Debt. Any debt not specifically listed in this Agreement and/or incurred after the date of separation (March 25, 1999) shall be the sole and separate responsibility of the party who incurred it. 14. Agreement Executed Voluntarily and Clearly Understood. Each party to this Agreement acknowledges and declares that he or she respectively: A. If fully and completely informed as to the facts relating to the subject matter of this Agreement, and as to the rights and liabilities of both parties; B. Enters into this Agreement voluntarily, free from fraud, undue influence, coercion or duress of any kind; C. Has given careful and mature thought to the making of this Agreement; D. Has carefully read each provision of this Agreement; E. Acknowledges that there has been a full and fair financial disclosure by both parties, and fully and completely understands each provision of this Agreement. 15. Release of All Claims. Each party releases the other from all claims, Iiabiiities, debts, obligations, actions and causes of action of every kind that have been or will be incurred. Moreover, neither party is relieved or discharged from any obiigation under this Agreement or any instrument or document executed pursuant to this Agreement. "' ~ 16. Holding Other Party Free and Harmless. HUSBAND hereby warrants to WIFE that he has not incurred and he hereby agrees that he will not hereafter incur any liability or obligation on which she is or may be liable. If any claim or action is brought attempting to hold WIFE liable for any such liability or obligation, HUSBAND shall, at his sole expense, defend WIFE against any such claim or action whether or not founded, and he shall hold her free and harmless therefrom. WIFE hereby warrants to HUSBAND that she has not incurred and she hereby agrees that she will not hereafter incur any liability or obligation on which he is or may be liable. If any claim or action is brought attempting to hold HUSBAND liable for any such liability or obligation, WIFE shall, at her sole expense, defend HUSBAND against any such claim or action whether or not founded, and she shall hold him free and harmless therefrom. 17. Additional Instruments. The parties shall, on demand, execute and deliver to the other, any document, and do or cause to be done, any other act or thing that may be necessary or desirable to effectuate the provisions and purposes of this Agreement. If either party fails, on demand, to comply with this provision, that party shall pay to the other, all attorney's fees, costs and other expenses reasonably incurred as a result of such failure. 18. Full Disclosure. The respective parties do hereby warrant, represent, and declare, and do acknowledge and agree that each is and has been fully and completely informed of, and is familiar with and cognizant of the wealth, income, real and/or personal property, whether jointly or individually titled, estate and assets of the other, and that each has made a full and complete disclosure to the other of his and her entire assets and liabilities, and any further enumeration or statement thereof in this Agreement is hereby specifically waived. Although within their right to request, the parties specifically waive their right to engage in formal discovery and are satisfied with the disclosures made by the other. The parties do not wish to make or append hereto any further enumeration or statement. Each of the parties hereto further covenants and agrees for himself or herself that his or her heirs, personal representatives and assigns, that he or she will never at any time hereafter sue the other or his or her heirs, personal representatives or assigns, in any action or contention, direct or indirect, that there was any absence or lack of full and proper disclosure. Further, both parties waive their right to have the inventory or financial disclosure statement of the other attached hereto. 19. Representation of the Parties. WIFE is represented by Johnson, Duffie, Stewart & Weidner, in connection with the negotiation and preparation of this Agreement. HUSBAND is represented by Robert P. Kline in connection with the negotiation and preparation of this Agreement. Each party has carefully read this Agreement and is completely aware not only of its contents but also of its legal effect. . WIFE acknowledges that her counsel has specifically advised her that in the event this matter proceeded to a Divorce Master, in her opinion WIFE would be entitled to a larger portion of the marital estate than is contemplated in this Agreement, either in equitable distribution or in alimony. Despite this, WIFE desires to enter into this Agreement knowingly and voluntarily. Each party acknowledges and accepts that this Agreement, in the circumstances, is fair and equitable, and that it is being entered into freely and voluntarily, and that the execution of this Agreement is not the result of any duress or undue influence, and that it is not the result of any improper or illegal Agreement and/or Agreements. 20. Waiver of Rights to Other Party's Estate. Except as provided for herein, HUSBAND and WIFE each waive any and all right: A. To inherit any part of the estate of the other at his or her death, except as provided herein; B. To receive property from the estate of the other by bequest or devise except under a Will or Codicil dated subsequently to the effective date of this Agreement; C. To act as personal representative of the estate of the other on intestacy unless nominated by another party legally entitled to so act; D. To act as the personal representative under the Will of the other unless so nominated by a Will or Codicil dated subsequently to the effective date of this Agreement; E. To claim a family allowance in the estate of the other. 21. Containment of Entire Agreement Herein. This Agreement supersedes any and all other Agreements, either oral or in writing, between the parties relating to the rights and liabilities arising out of their marriage. This Agreement contains the entire agreement of the parties. 22. Partial Invalidity. If any portion of this Agreement is held by a Court of competent jurisdiction to be invalid, void, or unenforceable, the remaining provisions shall, nevertheless, continue in full force and effect without being impaired or invalidated in any way. )-, ~ ' ' . . 23. Effect of Reconciliation. Cohabitation or Divorce Decree. The terms of this Agreement shall be incorporated into any Divorce Decree which may be entered with respect to the parties. This Agreement shall survive any such final judgment or Decree of Divorce. Both parties shall have all rights and enforcement under applicable law including the Pennsylvania Divorce Code. This Agreement shall also remain in full force and effect even if the parties effect a reconciliation, cohabitate as Husband and Wife, or attempt to effect a reconciliation. 24. Modification. This Agreement shall not be subject to modification except as in accordance with Pennsylvania law and with a writing between both parties evidencing their intent to modify the Agreement. 25. No Waiver of Default. This Agreement shall remain in full force and effect unless and until terminated under and pursuant to the terms of this Agreement. 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. " 26. Attorneys Fees and Expenses. Each party shall be responsible for their own attorneys fees and expenses. 27. Mutual Cooperation. Each of the parties shall, on demand, execute and deliver to the other, any deeds, bills of sale, quit claims, assignments, consents, tax returns, and other documents and do or cause to be done any other acts or things as may be necessary or desirable to effectuate the provisions and purposes of this Agreement. If either party fails on demand to comply with this provision, that party shall pay to the other all attorney's fees, costs and other expenses reasonably incurred as a result of such failure. 28. Bankruptcy. Each of the parties acknowledges and agrees that with respect to the liabilities each is required to assume and pay under the provisions of this Agreement, each has the ability to fulfill his or her respective obligations from income or property not reasonably necessary to be expended for such party's maintenance and support or for the maintenance and support of such party's dependents. Should either party file a Petition under Title XI of the United States Code, or should a petition be filed against either involuntarily, each party acknowledges and agrees that the discharge of the debtor party's obligations under this Agreement will not result in a benefit to the debtor party that outweighs the detrimental consequence to the non-debtor party or the non-debtor party's child or children. ~--, '--,-", ~-. - '~ 29. Law of Pennsylvania Applicable. This Agreement shall be construed in accordance with the laws of the Commonwealth of Pennsylvania. 30. Date of Agreement. The effective date of this Agreement shall be the date on which the last party executes the Agreement if the parties do not execute the Agreement on the same date. Otherwise, the effective date will be the date that both parties execute the Agreement if they execute on the same date. 31. Successors and Assigns. This Agreement, except as otherwise expressly provided herein, shall be binding on and shall inure to the benefit of the respective legatees, devisees, heirs, executors, administrators, assigns and successors and interest of the parties. IN WITNESS WHEREOF, the parties hereby have hereunto set their hands and seals the date and year first above written. WITNESS: vt0/hj Date ~~d Qo~ ONNE L. RENDE '2A-?~ 2/;;'5103 Date' .2~o- R~ RALPH f':\.. RENDE :131760 " iili_ "......""~~" -~~ -' .. -~ ~~ -"","~-'" (') C z gr~~\ ZC ",1" v~ >.__ --<..~ C;::C! '"1> -, 2':(,.) ,:;U c: -S =< " c?- ~: i J:I -:;-'f" !-~-, " - , i'.' ("" " ..::.:;-c; ~___ " (~~ ~" jO -< -0 ::1i~ fSi "" ...J "~~ U~ ",,~ ~~ ,L__",_ . IN THE COURT OF CCMMON PLEAS OF OJMBERLAND COUNI'Y, PENNSYLVANIA YVONNE L. RENDE, Plaintiff NO. 2000-448 CIVIL TERM vs. RALPH A. RENDE, Defendant PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information~ 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 complaint: February I, 2000 via certified mail, rest"icted delivery, and received by Defendant on February 2, 2000. 3. Complete either Paragraph A. or B. A. Date of execution of the affidavit of consent 3301 (c) of the Divorce Code: by the plaintiff March 3, required by Section 2003 by the defendant February 25, 2003 B. (1) Date of execution of the plaintiff's affidavit required by Section 3301 (d) of the Divorce Code: (2) Date of service of the plaintiff's affidavit upon the defendant: 4 . Related claims pending: None. . All economic claims have been resolved by the Property Settlement Agreement dated March 3, 2003 which shall be incorporated, but not merged, into the Decree in Divorce. 5. Indicate date and manner of service of the notice of intention to file praecipe to transmit record, and attach a copy of said notice under Section 3301 (d)(l)(i) of the Divorce Code Waiver of Notice signed by Plaintiff on March 3, 2003 and filed concu=ently herewith. and filed concurrently herewith. Waiver of Notice signed by Defendant on February 25, 2003 ~ Attorney for. Plaintiff/~ Melissa Peel Greevy ~Wt"""'--"llIIiIl:lol~lM_bfli~ii1~~...",~~",,,,,,,~,."'-'JiJlhill'I,,-j, ,',"" _iilli1i_!lI:t'~ '- ~ 0 C':r 0 c: L~ --1'1 S. :1r ." ;:HOC' :Z::;:<r ::GZJ g;JrTl :'::-0' ;:r -:q8 ZL~' , (.fJ .J~T en .:c~~~ /.:.,. --</ _.-I'...J !<c '"0 l:-" " -n ~c :2.: =-::;c) :z: C' ~ :5m J;>c -1 ~ r:- ]:.'" :0 . -< -- . .1. ~ , " "... , ,., , " ",' e ~'" ,k " '''''''"4.-1' .,_'! Johnson, Duffie, Stewart & Weidner By: Keirsten W. Davidson J.D. No. 78243 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff YVONNE L. RENDE, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 2000- '-ILlP CIVIL TERM v. CIVIL ACTION - LAW RALPH A. RENDE, IN DIVORCE Defendant NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree 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. I; I " I,i , 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 ..~~- ~ " ~ ' , , '^'. ~ ~ "i _t Johnson, Duffie, Stewart & Weidner By: Keirsten W. Davidson LD. No. 78243 301 Market Street P. O. Box 109 Lemoyne, Pelillsy1vania 17043-0109 (717) 761-4540 Attorneys for Plaintiff YVONNE L. RENDE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000- '1'1 P" CIVIL TERM v. CIVIL ACTION - LAW RALPH A. RENDE, IN DIVORCE Defendant COMPLAINT IN DIVORCE UNDER SECTIONS 3301(cl OR 3301(dl OF THE DIVORCE CODE AND NOW, comes the Plaintiff, Yvonne L. Rende, by and through her attorneys, Johnson, Duffie, Stewart & Weidner, and files the following Divorce Complaint against the Defendant, Ralph a. Rende: 1. The Plaintiff is Yvonne L. Rende, an adult individual, residing at 143 15th Street, Apartment 7, New Cumberland, Cumberland County, Pennsylvania. 2. The Defendant is Ralph A. Rende, an adult individual, residing at 2 York Road, New Cumberland, Cumberland County, Pennsylvania. 3. The Plaintiff and Defendant were married on September 23, 1983 in Harrisburg, 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 of marriage between the parties in this or any other jurisdiction. - ^ ~' _,J ~.h'''-<'~''''''-_'I '~ 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 under Section 3301 (c) of the Divorce Code. COUNT 11- 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. 9. Plaintiff and Defendant have legally and beneficially acquired certain real and personal property during their marriage. WHEREFORE, the Plaintiff respectfully requests that your Honorable Court equitably divide all marital property. JOHNSON, DUFFIE, STEWART & WEIDNER BY:~UCth Keirsten W. Davidson :130314 VERIFICA TlON I verify that the statements made in this Divorce Complaint 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 !l4904, relating to unsworn falsification to authorities. Date: 1 -I.;) -DO ~~d~ Yvonne L. Rende Johnson, Duffie, Stewart & Weidner By: Keirsten W. Davidson LD. No. 78243 301 Market Street p, 0, Box 109 Lernoyne, Pennsylvania 17043-0109 (717)761-4540 Attorneys for Plaintiff YVONNE L. RENDE, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 2000- CIVIL TERM v. CIVIL ACTION - LAW RALPH A. RENDE, IN DIVORCE Defendant AFFIDA VIT YVONNE L. RENDE, 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. 94904, relating to unsworn falsification to authorities. Date: 1- Id.-OO ~~.R~e~ ",' ~-~'"" '.......-~, ~,~..c" ., .IiiiIIiiiii ~'IIII""" . .~~..f ' ~~~ cP ~ ~ ~ \' ~ ...t ~-......f. -...c~~ ( ~. ~ f"" ~ , "'"?- ~ ~ FJ ~ -...... ~ ~\). ~ ~ (") g 0 C -n ;z- "- -off, ".-, 1-"" ..~ ';I!f11 Z --~i i~ :IJ ~~ N "::,~lE .;::- --- "...;, ;~) \ !<:O -"'l,J. ~~~~ ~C] 3: 5>~ :20 :f? l~rn ~ -., W ~ W '" ~ f ., -~ " 0-" -", -0)' . ~ " ,,,J . . -- Johnson, Duffie, Stewart & Weidner By: Keirsten W. Davidson I.D. No. 78243 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717)761-4540 Attorneys for Plaintiff YVONNE L. RENDE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000-448 CIVIL TERM v. CIVIL ACTION - LAW RALPH A. RENDE, IN DIVORCE Defendant CERTlFICA TE OF SERVICE I hereby certify that on the 1st day of February, 2000, I served a true and correct copy of the foregoing Complaint in Divorce upon the Defendant, Ralph A. Rende, by certified mail, restricted delivery, to his mailing address at 2 York Road, New Cumberland, Pennsylvania 17070, return receipt requested, attached hereto and made a part hereof. Respectfully submitted, JOHNSON, DUFFIE, STEWART & WEIDNER BY:.!L~ W~~ Keirsten W.'Davidson :130314-6 } .- Z 200 lIH, 429 , Postage Certified Fee Spada! DaJivery Fee '- Restricted DeliveryFee "' m Return Receipt ShP!Mg to :-0. ',; ..... Whom_& Date ~Delilfllred _ ~ _ , '[ RelUm RecoipiShowin!ito <: Date, & Mdressee'sAddress o ., .... o TOTAL postage & Fees 00. . ~ postma~d: .~A: /119/ ~ / If f' flUr ~ 4/100 (1.;- " I l' l!! " 5. .. " I 3'~1t:Z~ t~€JJJE 8M A/( ;') { ill c2 /0 fL {\ill . I )/01 Ca rn-bt.:}j dLtL~ PA 17 nO ... --~,--" I al$iJ Wi$b.to lie.$aive the follow- ing servfc.. (fer an extra fee): ~~I'i!~, i~~s t,_~iillor 2 ~r alildilio[laJ-servlces. -_Comple1e items',3, 4a, and 4b. [J-Pririt your name, and address on the ljverse of this fonT! so that we can return this ..am:ltoypu, -- oAUach this form to the front of the mailplece, or on the back If space does not permi., ' ", ' C Writj;jmtum'ReCeipt Requested" on the mallpiece below the article numbClr. [!J The Ffmu[Jl Receipt will show to whom the article was delivered and the date deliv~" '(" " ,. --, 4a. Article Number L ,,}.uo lib 1(';''1 4b. Service Type o Registered o Express Mail o Return Receipt for Merchandise !; g, .!!l ; ~ n ili ".~___ _~___----.i 1. 0 Addressee's Address 2. jR[ Restricted Delivery ~ertified o Insured DCOD 7. Date of Del~ry _'at,.} ~ ~ ~ . -VV 8. Addressee's Address (Only if requested and fee is paid) it :J i ! 1; "~I' """'" ~ Return Receipt ai .. ; In il. ~ 'it .. " 0: .. ~ ~ . 'il 0: '" .. 'ijj ~ .2 ~ g, ... ii ~ ~~ ,..'iIIolio.....-""-..'....~Wlll1lllllllfi~.:<lIllil1.lll!i!i!l;;l_liI!.UtMlll C) <;; ~~,~ -ot1' [nil ~f~:: ~~-~';:: r::~c. -- -"," ,-.., d:~,-.' "':-':'::(J >(':: ~ " .^ o CJ - ., ril ~:';~J r _. \ . .., -,1"1 ., t.}~ ~'. ,"11"--;"';; ....r:-\ .';c? , ~ ~~:~ ~~ ')Sl 0'" ~ 51 -<; -0 ::-x:. ~ ? ,;:) .~ [ill -,- " , , ~' ". " ,-, ~.-"', --~_., ,'---"~,~., ,,,,~,,,,--" ~"~"-,,,,<' """"'~"'-"'~' - """,'~"-'''-'-'' Johnson, Duffie, Stewart & Weidner By: Keirsten W. Davidson J.D. No. 78243 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff YVONNE L. RENDE, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 2000-448 CIVIL TERM v. CIVIL ACTION - LAW RALPH A. RENDE, IN DIVORCE Defendant AFFIDA VIT OF CONSENT 1. A Complaint in divorce under Section 3301 (c) of the Divorce Code was filed on January 24, 2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing 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 advi15ed, 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: ..J /3/ () '3 ft(~ 01 ~J- Yvonne L. Rende, Plamliff :136320 . ,~ . ~, ~. ~-.~ ' we.-. ~l I '~'. .'. ", "" 0 C:} " .~ C (.,:' -,1 S. :;;: -:..-:;~ -;D-~ 'J';<''' mr; .. Z~-" _e'~' -- -ZC cr. ~~{ '2C ~.,:) '-:::(~l:, -q ">:"0 ~;;::". ;'0 ;;So 1)2 ;-3m :v-c '. . ~ .-, c- ';? ~ ....1 :.<: ~ ,- - ."~ "" ^= "-~<- -" -,--. - ,- ". ~--'--"'-' --~,-";~-'.~'. ." <.;,.. ",~- ~.," - ";-~h'~-';-_' -~~':-" ~" "',,. ,-, ,_I . "0 ""..- Johnson, Duffie, Stewart & Weidner By: Keirsten W. Davidson J.D. No. 78243 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff YVONNE L. RENDE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000-448 CIVIL TERM v. CIVIL ACTION - LAW RALPH A, RENDE, IN DIVORCE Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(cl OF THE DIVORCE CODE 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 Waiver are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. !l4904 relating to unsworn falsification to authorities. Date:3!0lb> , ~~d~ Yvonne L. Rende, Plaintiff :136320-2 ,-~, ,.;....... '-, ~, ~ - '"..:~ - ,., _ J~ ,-", ~. '" ~~ {") 0 0 C 1:0 -" s: ~ +--, ""OCc 1.;:<;> ~!-i 'J) rn~ :';0 2--.--- 2:5:" , :":?ts (Ij " m ~ ;~ ~~:~ r:f-.:: ~'--..--' -0 ~(-. :r.: (~~"';FJ Zb Pc: ty Q m 2: :----1 l:"" "" --j ::0 -< -..J -< '" YVONNE 1. RENDE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2000-448 CIVIL TERM RALPH A. RENDE, Defendant : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on January 24, 2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of the fmal Decree of Divorce after service of notice of intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 PA. C.S. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. ;;</;(s/{)'<, # .J Date ~~~-({~ SSN: " " ~ ",",,,-,,,,,:,,iiJ. ". ~o;.... ~ L' '.~ .~-'.~ , -).dl:llll~ "--~MI,ij;'""~'-- .L "'" ',,,, ~.^ ~. ,"- -,.,- - 0 C C) !;; w --q " - -off .;~ ~'::::i rn ,,~ ~i';:", ,,-:; ~.:J) ~\:] , 21~- --., no C/)~_ a'. ;.;::-!t]? :-< " r---'r~' :::_1&,) K'~ "0 'k_'" _~~ "'0 "",:." ')~ 2, <.() "-0 fS5 >c .-,,, n '-' ~ -. ~ -. "~ ,. :n >-.1 -:;,: m ~, < ' . ,'-- ~I, 'I, ,- it YVONNE L. RENDE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2000-448 CIVIL TERM RALPH A. RENDE, Defendant : CIVIL ACTION - LAW : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2, I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! 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. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORlTIES. 2/:25/(Y3 Date 2~d/J.R~ RALPH A. NDE , """'''''"''''J' ~'~""~wlOiallii!idiiulfl. '~ '_.-.......'~~,WlOliMillllNilllO;~' T , ", H" '__".. -~ ;..,", -~ 0 C" ~ t"_, c: (..:,1 -l<j ;;;:: -:r.:: --, -r,.llJJ :L-" n'\[t', :7.] Z ,-r ~~.. 1 ":'-) ,'" V .~l~ <- ""C: ~n ::L b i'v- )>C '=-, ~ ~ :p" :JJ .-.1 -< .