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Home My WebLink About00-01077 .' ,. >n;,.' - d_y' -:,>,~"" ~ ,". .~ . ',",c,_o',__''~~~,! ! l~!::C!;::::{CC:!::.::(,:~!>>::~;;;i>~~!::.i~::_{(:!~!::C!;g!WAJ~!~:<~!::.~;:;:i::!rci-:X~!::.E:~it ----- ~~~ ~ ~.~ ~ ~.~ . ~ i ".~ ~.S ~ ',., ~ :.::C( ):.}(':~::c.;" :.3>;0:,:)>>::;< X+::( )::+::0::: :::.::.::.::. ::"::+::":: :~::.::< :'.:'+::" ::~::.::<)::.::.~::::.::.::.-:. >::.::.~: :::~::.::<:::'.:::':, ::"::.::"" ,:.::.::'( :'.:.::;, :::.::.::~:: -"'< " ",-,~" , j ~~:c(}.);:,,)~;:,:C'!::.::(':::!::.::~;;:::'!>>X:::!:+::{:XC<:;!"~:::!::~,<:::!_;g:!::.X':~!::.::~~:':~:!::<<(}{C~t:~!"::~; ~ ~ ~.." ~ "~,,, W ~.~ IN THE COURT OF COMMON PLEAS "-.,,, ~ ~.~ OF CUMBERLAND COUNTY "d ;"S ~ ~ ~ ~i ~ ;'.S ~ STATE OF PENNA. JEFFREY CLEMENTS ~~~ ~ N o. ,..,l.~!L(),F.,..zOO()..'..m....... v ~ 'v' ~ ~.~ Versus ~ ~ ~ ~ ~ ~.~ RUTH E. CLEMENTS t "."1 DECREE IN DIVORCE AND NOW, ..~. ...~l...... .,'lOPf.., it is ordered and decreed that,.,. .JEffEEY.CLEMENrS............................, plaintiff, and. . . . . .. . , .. . . . .~U!.~ .E... .c,~~~~s. . . . .. . .. . . . . . . . . . . . . . . . . . ., defendant, are divorced from the bonds of matrimony. ...,.' ~ ~.~ ~.; ~ :<,-; ,f~ , I ",+", ~ ".'. k~ I t ~, a ~.~ ~ t - ,'''- 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; ~ a "'.~ ~.~ ~ k~ ~ l:.; e ~~~~~~.~~~~~~~~~F.~g~~~~~PF.~~. ~P~?~P?,~~~~. P?~. P?~.~~,g~~ ~~~A~A~~ A~~r~e Prothonotary ~.~ ~ "". ~.; ~ t". ;:; ~ ~ ".~ ~,' I $'0,; t; I :i/ i J..:,,;: ,....".,. ,....... -..,."......"..... .,.."..., ,., . ,. .... ,........,..... By Attest: .d >..,< W !l'.~ ~ ~l ~.~ ~ ~.~ a ~.'i#, ~ ~ s ~ i ~.~ ~ !l'.'# ~~ a ~.~ ~.~ ~ ! ~ ,"" s ".;: i ~.~ ~ ~ !l'.'i#, ~ ~ ~.~ * '",,' ~ .... ~ ~.'i#, ~ ~ ~.~ J. ~ ~.~ ~ ~.~ ~.~ ~ ~ '.. ~ y ~ ~.~ ;', ~ 73/-tJ/ 73f.tJl 'I ~,~'~ ,~ , :', u~ ~~4ct~ ~ 'Y1fl'~-o ~- . . , r ,~ f. ~"'f"-'IilI!IllI, 0" .="W, 'I" ' .' ~', ~' I,' ~',", ~..~":-""" ' < " -.i1~ , , NUUUTALSETTLEMENTAGREEMENT THIS AGREEMENT, made this !(;~ of between Ruth Clements (hereinafter "WIFE") and , 2001, by and lements, (hereinafter "HUSBAND"); W I TN E SSE T H: WHEREAS, the parties hereto were rnarried on October 4, 1997, i~ Dauphin County; and WHEREAS, the parties have no children of this marriage; and WHEREAS, difficulties have arisen between the parties and it is therefore their intention to live separate and apart for the rest of their lives and the parties are desirous of settling completely the economic and other rights and obligations between each other, including, but not limited to: the equitable distribution of the marital property; past, present and future support; alimony, alimony pendente lite; and, in general, any and all other claims and possible claims by one against the other or against their respective estates; and NOW THEREFORE, in consideration of the covenants and promises hereinafter to be kept and performed by each party and intending to be legally bound hereby, the parties do hereby agree as follows: 1. ADVICE OF COUNSEL. The provisions of this Agreement and their legal effect have been fully explained to the parties by their respective counsel. WIFE is represented by Jacqueline Verney, Esquire. HUSBAND is represented by Debra Denison Cantor, Esquire of Reager & Adler, PC. The parties further declare that each is executing the Agreement freely and voluntarily having either obtained sufficient knowledge and disclosure of their respective legal rights and 1", ~" '" .,' '., ",. obligations, or if counsel has not been consulted, expressly waiving the right to obtain such knowledge, The parties each acknowledge that this Agreement is fair and equitable and is not the result of any fraud, coercion, duress, undue influence or collusion. 2. DIVORCE ACTION. The parties acknowledge that their marriage is irretrievably broken and that they shall secure a mutual consent no fault divorce pursuant to ~ 3301(c) of the Divorce Code. A divorce action was filed by Plaintiff with the Court of Cornmon Pleas of Cumberland County, Pennsylvania at Civil Action N. 2000-1077 on 2/25/00. The parties agree to execute Affidavits of Consent for divorce and Waivers ofN otice of Intention to Request Entry of a Divorce Decree concurrently with the execution of this Agreement. This Agreement shall remain in full force and effect after such time as a final decree in divorce may be entered with respect to the parties. The parties agree that the terms of this Agreement shall be incorporated into any Divorce Decree which may be entered with respect to them and specifically referenced in the Divorce Decree. This Agreement shall not merge with the divorce decree, but shall continue to have independent contractual significance. 3. DATE OF EXECUTION. The "date of execution" and "execution date" of this Agreernent shall be defined as the date upon which it is executed by the parties if they have each executed the Agreement on the same date. Otherwise, the "date of execution" or "execution date" of this Agreement shall be defined as the date of execution by the party last executing this Agreement. 4, MUTUAL RELEASES. Each party absolutely and unconditionally release the other and the estate of the other from any and all rights and obligations which either may have for past, present, or future obligations, arising out of the marital relationship or otherwise, including all rights and benefits under the Pennsylvania Divorce Code of 1980, and amendments except as described herein. Page 2 of 9 - ,d;;.",j Each party absolutely and unconditionally releases the other and his or her heirs, executors, and estate from any claims arising by virtue of the marital relationship of the parties, The above release shall be effective whether such claims arise by way of widow's or widower's rights, family exemption, or under the intestate laws, or the right to take against the spouse's will, or the right to treat a lifetime conveyance by the other as testamentary or all other rights of a surviving spouse to participate in a deceased spouse's estate, whether arising under the laws of Pennsylvania, any state, Commonwealth, or territory of the United States, or any other country. Except for any cause of action for divorce which either party may have or claim to have, each party gives to the other by the execution of this Agreement an absolute and unconditional release form all claims whatsoever, in law or in equity which either party now has against the other. 5. FINANCIAL AND PROCEDURAL DISCLOSURE. The parties confirm that each has relied on the accuracy of the financial disclosure of the other as an inducement to the execution of this Agreement. Each party understands that he/ she had the right to obtain from the other party a complete inventory or list of all property that either or both parties owned at the time of separation or currently and that each party had the right to have all such property valued by means of appraisals or otherwise. Both parties understand that they have right to have a court hold hearings and make decisions on the matters covered by this Agreement. Both parties hereby acknowledge that this Agreement is fair and equitable, and that the terms adequately provide for his or her interests, and that this Agreement is not a result of fraud, duress or undue influence exercised by either party upon the other or by any person or persons upon either party. 6. SEPARATION/NON-INTERFERENCE. WIFE and HUSBAND may and shall, at all times hereafter, live separate and apart. They shall be free from any interference, direct or indirect, by the other in all respects as fully as if they were unmarried. Each rnay, for his or her separate use or benefit, conduct, carry on and engage in any business, occupation, profession or ernployment which to him or her rnay Page 3 of 9 ~ '-" "' . ,I dli/fi;I;lf>' seem advisable. WIFE and HUSBAND shall not harass, disturb, or rnalign each other or the respective families of each other. 7. REAL PROPERTY. Husband is the owner of real property located at 1328 Sugar Maple Court, New Cumberland, Pennsylvania. Husband owned this property prior to marriage and Wife hereby waives any right, title and interest she may have in said real property as a result of the parties' rnarnage. HUSBAND made payments in support of the household and the above-mentioned real property while WIFE exercised exclusive possession of the home. WIFE hereby acknowledges. receipt of said funds as part of the equitable distribution in this matter. 8. INVESTMENTS. The parties own joint money market and joint mutual fund accounts with Schwab at account number 2374-2668. Pursuant to a Petition for Immediate Relief and subsequent Stipulation, WIFEreceived the amount of $9,812.82 from the parties' joint Schwab money market account. WIFE is hereby credited with receipt of said funds for the purposes of equitable distribution. Thereafter, WIFE waives any right, title and interest that she may have in said Schwab accounts, and HUSBAND shall maintain ownership of the balance of said accounts. WIFE agrees to cooperate in executing any documentation necessary to transfer her interest in said account to HUSBAND. 9. CASH. The parties' 1999 income tax refund has been placed into a jointly held escrow account at PNC Bank account number 50-0203-7109. The current balance on the account is $3952.59. HUSBAND hereby waives any right, title and interest he may have in said funds. The balance of this account is to be released to WIFE concurrently with the execution of this Agreement. Page 4 of 9 - ~ ..;;-, 10. FAMILY OWNED BUSINESS. HUSBAND is a minority shareholder in a family owned business, Johnson Imaging Systems, Inc. WIFE hereby waives any right, title and interest she may have to HUSBAND's ownership of said business. 12. COUNTRY CLUB MEMBERSHIP. If permitted by Country Club rules and regulations, WIFE shall retain the parties' family Country Club membership. HUSBAND will pay an additional $700.00 to the Country Club to initiate his own membership. 13. TAXES. In 1997, 1998 and 1999, the parties filed joint federal and state tax returns. In the event that the parties are subject to a review or tax audit that results in the imposition of interest and penalties, the party to whom the under-reporting or error can be credited to shall bear sole responsibility for the payment of the interest and penalty and shall indemnify and hold the other harmless from such responsibility. All property transfers in this Agreement are intended to be tax free transfers pursuant to the Internal Revenue Code. 14. DEBTS. The parties represent that there are no joint debts. HUSBAND represents and warrants to WIFE that since the separation 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 he shall indemnify and save WIFE harmless from any and all claims or demands made against her by reason of such debts or obligations incurred by him since the date of said separation, except as otherwise set forth herein. WIFE represents and warrants to HUSBAND that since the separation she has not, and in the future she will not, contract or incur any debt or liability for which HUSBAND or his estate might be responsible, and he shall indemnify and save HUSBAND harmless from any Page 5 of 9 ~ .- "",:.:,-1., ,," lB."' and all claims or demands made against him by reason of such debts or obligations incurred by her since the date of said separation, except as otherwise set forth herein. 15. PERSONAL PROPERTY. Except as set forth here below, the parties hereto mutually agree that they have divided all furniture, household furnishings and personal property between them in a manner agreeable to both parties. The parties mutually agree that each party shall from and after the date of this Agreement be the sole and separate owner of all tangible personal property in his or her possesslon. 16. VEmCLES. WIFE is the owner of a 1997 Honda. HUSBAND waives all right, title and interest he may have to said vehicle. HUSBAND is the owner of a 2000 Honda. WIFE waives all right, title and interest she may have to said vehicle. 17. ALIMONY, SUPPORT, AND ALIMONY PENDENTE LITE. Effective June 30, 2001, WIFE hereby waives any right, title or any interest she may have in the receipt of spousal support and alimony pendente lite. Beginning on July 1, 2001, HUSBAND shall pay to WIFE alimony or alimony pendente lite in the amount of$500.00 per month for a period of six (6) months. Said amount shall be taxable to WIFE as income and deductible to HUSBAND. Said payments shall be terminable upon the death, remarriage or cohabitation of WIFE or the death of HUSBAND. Said payments shall be non-modifiable in amount and term and shall be rnade directly between the parties. WIFE hereby waives any future right to receipt of alimony, support or maintenance of any type from HUSBAND. 18. ATTORNEY FEES, COURT COSTS. Each party hereby agrees to be solely responsible for his or her own counsel fees, costs and expenses. Neither shall seek any contribution thereto from the other except as otherwise expressly provided herein. Page 6 of 9 ~~ - '~ ' ,-- '.," ,'0.' " ' I, --, '< ~:< 19. ATTORNEYS'FEESFORENFORCEMENT. In the event that either party breaches any provision of this Agreement and the other party retains counsel to assist in enforcing the terms thereof, the breaching party will pay all reasonable attorneys' fees, court costs and expenses (including interest and travel costs, if applicable) which are incurred by the other party in enforcing the Agreement, whether enforcement is ultimately achieved by litigation or by amicable resolution. It is the specific Agreement and intent of the parties that a breaching or wrongdoing party shall bear the obligation of any and all costs, expenses and reasonable counsel fees incurred by the nonbreaching party in protecting and enforcing his or her rights under this Agreement. 20. WAIVER OF RIGHTS. Both parties hereby waive the following procedural rights: (a.) The right to obtain an inventory and the appraisement of all rnarital and non-rnarital property; (b.) The right to obtain an income and expense statement of either party; (c.) The right to have all property identified and appraised; (d.) The right to discovery as provided by the Pennsylvania Rules of Civil Procedure; and (e.) The right to have the court make all determinations regarding marital and non-marital property, equitable distribution, spousal support, alimony pendente lite, alirnony, counsel fees and costs and expenses. 21. MUTUAL COOPERATION. WIFE and HUSBAND shall rnutually cooperate with each other in order to carry through the terms of this Agreement, including but not limited to, the signing of docurnents. 22. VOID CLAUSES. If any term, condition, clause or provision of this Agreement shall be determined or declared to be void or invalid in law or otherwise, then only that term, condition, clause or Page 7 of 9 -, I I provision shall be stricken from this Agreement, and in all other respects this Agreement shall be valid and continue in full force, effect and operation. 23. APPLICABLE LAW. This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania. 24. ENTIRE AGREEMENT. This Agreement contains the entire understanding of the parties, and there are no representations, warranties, covenants or undertakings other than those expressly set forth herein. 25. CONTRACT INTERPRETATION. For purposes of contract interpretation and for the purpose in resolving any ambiguity herein, the parties agree that this Agreement was prepared jointly by the parties. IN WITNESS WHEREOF, the parties hereto have set their hands and seals of the day first above written. This Agreement is executed in duplicate, and in counterparts. WIFE and HUSBAND acknowledge the receipt of a duly executed copy hereof. s o Page 8 of 9 I:.."';""'''';, ....." COMMONWEALTH OF PENNSYLVANIA : SS. COUNTY OF CUMBERLAND 0+~ - On the _l day of J u I~ ,2001, before me, aNotary Public in and for the Commonwealth 0 Pennsylvama, the undesigned officer, personally appeared Jeffrey Clements, known to me (or satisfactory proven) to be one of the parties executing the foregoing instrument, and she acknowledges the foregoing instrument to be her free act and deed. IN WITNESS WHEREOF, I have hereunto set rny hand and notarial seal the day and year first above written. ot ublic My Commission Expires: Notarial Seal J Jennffer S. Kuhns, Notary Public Ca!nP HIli Bom, Cumberland Coo My COmmiSSion, Expires Sept. 11, ~4 Member, PennsylvamaAssociatlonofNotartes COMMONWEALTH OF : SS. COUNTY OF : On the 10 Ji..- day of C1~ ,2001, before me, a Notary Public in and for the Commonwealth ~f Pe ylvania, the undesigned officer, personally appeared Ruth Clements, known to me (or satisfactory proven) to be on of the parties executing the foregoing instrurnent, and she acknowledges the foregoing instrument to be her free act and deed. IN WITNESS WHEREOF, I have hereunto set my hand and notarial seal the day and year first above written. ~ My Commission Expires: NOTARIAL SEAL KATHLEEN K SHAULIS, Notary Public CartisleBoro. Cumberland County My Commission expires Dec. 22.m Page 9 of 9 - , ~,,'.. ., I....... . r-. JEFF CLEMENTS Plaintiff v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2000-1077 CIVIL TERM RUTH E. CLEMENTS Defendant CIVIL ACTION - LAW IN DIVORCE 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. Ground for divorce: Irretrievable breakdown under ~3301(c) of the Divorce Code. 2. Date and manner of service of the Cornplaint: Service was accepted by the Defendant on the 2nd day of March, 2000, by certified rnail, return receipt requested, receipt number 2902- 067-572. 3. Date of execution of the Affidavit of Consent required by ~3301(c) of the Divorce Code: by Plaintiff, on July 24,2001; by Defendant, on July 23,2001. 4. Related claims pending: Settled by Agreernent dated July 16, 2001. 5. (Complete either (a) or (b).) (a) Date and manner of service of the Notice ofIntention to File Praecipe to Transmit record, a copy of which is attached: (b) Date Plaintiffs Waiver of Notice in ~3301(c) Divorce was filed with the Prothonotary: July 26,2001. - .,'" ~' , ,~:, -..;".. ~, Date Defendant's Waiver of Notice in ~3301(c) Divorce was fIled with the Prothonotary: July 23,2001. Respectfully submitted, REAGER & ADLER, PC Date: (f%/D/ By: e s ID # 78 2331 Market Street Camp Hill, PA 17011 717-763-1383 Attorneys for Plaintiff ~.....~ ~ii~~~--~ i__~~' " '~ ' ..",'" o ~ v:,';' rn ~:-: ::~~ ;:::. (/) .' / ~;:. J>. ~~-; ~'C-:: L""1 -< . '~bO,'. - .'..... ,.--'- '- ,",) C :;1 . -- .. >~, -,'I , ,IINtsblfamily lawlClient DirectoryIClemenfs-Jlpleaaingsldivdrce.cmp.wpd February 25, 2000 .. , " ; I Ii '~ REAGER, ADLER & COGNETTI, PC BY: DEBRA DENISON CANTOR, ESQUIRE Attorney LD, No. 66378 2331 Market Street Camp Hill, PA 17011-4642 Telephone: (717) 763-1383 Attorneys for Plaintiff Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLV AN1A NO. d07!v - Jb 7'1 ~ I.b-- CNIL ACTION - LAW IN DNORCE "1 , :,1 '1 :1 :j :j '; :i , JEFF CLEMENTS v. ',1 :1 . Defendant ,I i i , 'I ;1 RUTH E. CLEMENTS, 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 wamed that if you fail to do so, the case may proceed without you and a decree of divorce or annuhnent 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, Room 101, Cumberland County Courthouse, Once Courthouse Square, Carlisle, Pennsylvania, 17013. 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 WHEIU: YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, P A 17013 (717) 249-3166 ....!ij ~ , <, I' ',~: J_",,! , .INtsblfarnily lawlClient DirectorylClements-Jlpleadingsldivdrce,cmp, wpd February 25, 2000 . REAGER, ADLER & COGNETTI, PC BY: DEBRA DENISON CANTOR, ESQUIRE Attorney LD. No. 66378 2331 Market Street Camp Hill, PA 17011-4642 Telephone: (717) 763-1383 Attorneys for Plaintiff JEFF CLEMENTS Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Defendant NO. CIVIL ACTION - LAW IN DIVORCE v. RUTH E. CLEMENTS, A VISO PARA DEFENDER Y RECLAIMAR DERECHOS USTED HA DISO DEMANDANDO EN LA CORTE. Is desea defenderse de las quejas expuestas en las paginas siguientes, debar tomar accion con prontitud. Se la avisa que is no se diefiende, el caso purde proceder sin usted y decreto de divorcio 0 anulamiento puede ser emitado en su contra por la Corte. Una decision puede tambien ser emitida en su contra por caulquier otra queja 0 compensaction reclamados por el demandante. Usted puede perder dinero, 0 sus propiedades 0 otros derechos importantes para usted. Cuando la base para el divorcio es indignadades 0 rompimiento irreparable del matrimonio, usted puede solicitar consejo matrimonial. Una lista de consejeros matrimoniales esta disponible en la oficina del Prothonotary, en la Room 101, Cumberland County Courthouse, Once Courthouse Square, Carlisle, Pennsylvania, 17013. SI USTED NO RECLAMAPENSION ALIMENTACIA, PROPIEDAD MARITAL, HONORARIOS DE ABOGADO U OTROS GASTOS ANTES DE QUE EI_ DECRETO FINAL DE DIVORCIO 0 ANULAMIENTO SEAEMITIDO, USTEIl PUEIlE PERDER EL IlERECHO A RECLAMAR CUALQUlERA IlE ELLOS" USTED DEBE LLEVAR ESTE PAPEL A UN ABOGADO IlE INMEDIATO. SI NO TIENE 0 NO PUEIlO PAGAR UN ABOGADO, V AYA 0 LLAME A LA OFICINA INDICADA ABAJO PARA AVERIGUAR 1l0NIlE SE PUEIlE OBTENER ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 < < ~-:l-, ,~ ~; . \~Ntsb\fal]liIY law\Cltent Directory\Clements-J\pJeadings\divCirce.cmp.wpd February 25, 2000 REAGER, ADLER & COGNETTI, PC BY: DEBRA DENISON CANTOR, ESQUIRE Attorney I.D. No. 66378 2331 Market Street Camp Hill, PA 17011-4642 Telephone: (717) 763-1383 Attorneys for Plaintiff ;', I ~ : JEFF CLEMENTS : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA i I' I: I:' i I',: I! .' I:',: I:,:, ! j: ! Plaintiff Defendant NO.~-lb'7'r ~-u....... CNIL ACTION - LAW IN DNORCE v. RUTH E. CLEMENTS, COMPLAINT IN DIVORCE UNDER SECTION 330HC) OR CD) OF THE DIVORCE CODE 1. Plaintiffis Jeff Clements, an adult individual, who currently resides at 1328 Sugar Maple Court, New Cumberland, Cumberland County, Pennsylvania, 17070. 2. Defendant is Ruth E. Clements, an adult individual, who currently resides at 1328 Sugar ii Maple Court, New Cumberland, Cumberland County, Pennsylvania, 17070. :"! 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately prior to the filing of this Complaint. [i ':1 iii 11 i) 1;1 " 4. The Plaintiff and Defendant were married on October 4, 1997 at Dauphin County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. . ,IINtsblfa/llily lawlClient DirectorylClements-Jlpleadingsldivorce,cmp, wpd February 25, 2000 ~'i' I', I' " !::; '~ 6. Neither Plaintiffnor Defendant is in the military ornaval service of the United States or its allies within the provisions of the Soldiers' & Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 7. The marriage is irretrievably broken. 8. Plaintiff has been advised that counseling is available and that Defendant may have the :~ right to request that the court require the parties to participate in counseling. Plaintiff declines counseling. I ~: i~i 9. Afterninety (90) days have elapsed from the date ofthe filing ofthis Complaint, Plaintiff intends to file an Affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an affidavit. 10. In the alternative, Plaintiff will file an Affidavit of Consent and provide the appropriate notices two (2) years from the date of separation. WHEREFORE, Plaintiff respectfully requests the Court to enter a decree of divorce pursuant to Section 3301(c) or (d) of the Divorce Code. COUNT I EOUITABLE DISTRIBUTION 11. Paragraphs one (1) through ten (10) of this Complaint are incorporated herein by reference. 2 I,' ~~ "" .',- , , ,,'~_ I, "'.-,i," , . ,\\Ntsb\farjlily law\Client Directory\Clements-J\pleaelings\divorce,cmp,wpd February 25, 2000 12, Plaintiff and Defendant have acquired property, both real and personal, during their marnage. 13, The parties have acquired marital debt during the course of their marriage. 14. In the event the parties are unable to resolve the property issues in this matter, Plaintiff requests this Honorable Court equitably divide all marital property and debt. WHEREFORE, Plaintiff respectfully requests this Honorable Court to eqnitably divide all marital property and debt. Respectfully Submitted: REAGER, ADLER & COGNETTI, PC Date: February 25, 2000 BY: 2331 Market Street Camp Hill, PA 17011-4642 Telephone: (717) 763-1383 Attorneys for Plaintiff 3 ,n', . , :I." ~, ,\\Ntsb\falJliIY law\Client Directory\Clements-J\pleadings\div@rce.cmp.wpd February 21. 2000 . VERIFICATION I, JEFF CLEMENTS, 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 herein are made subject to the penalties of 18 Pa,C.S, Section 4904, relating to unsworn falsification to authorities. Date: 2-/ z4- 10D 4 /' " L..... ''''~'' \ . ~ ... . ~ - c::) C> c::~~ ~' j -, ~1 .---, rr, .; - ) ~< ..' .- t..,) t,j . '-' . i ... --::J ~... .- ;t.; :',) ~;j H) _-'--J .~o:... .~ () '" "0 '{l " REAGER, ADLER & COGNETTI, P,C, ATTORNEYS AT LAW 2331 MARKET STREET CAMP Hill, PA 17011-4642 (717) 763.1383 ~ ~ 1 ..D - .. v-, "" "" ?\ 0 "I~ v e '" " ,'0 d c: e ~ ~ t ... r f l- l_iO:,; I IINtsbltamily lawlFormslmiscellaneouslAFFIDAVI.SVE , '. ~ REAGER, ADLER & COGNETTI, PC BY: DEBRA DENISON CANTOR, ESQUIRE Attorney 1.0. No. 66378 2331 Market Street Camp Hill, PA 17011 Telephone: (717) 763-1383 Attorneys for Plaintiff JEFF CLEMENTS : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff Defendant NO. 2000-1077 CIVIL ACTION - LAW IN DIVORCE V. RUTH E. CLEMENTS, AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Before me, the undersigned Notary Public, this day, personally appeared Debra Denison Cantor, Esquire, attorney for the Plaintiff, to me known, who being duly sworn according to law, deposes the following: I, Debra Denison Cantor, Esquire, being duly sworn according to law, depose and state that service of the Complaint in Divorce in the above-captioned matter was served by Certified Mail, Return Receipt Requested, on Defendant, Ruth E. Clements, 1328 Sugar Maple Court, New Cumberland, Pennsylvania, 17070 on March 2, 2000. The Certified Receipt is attached hereto as "Exhibit A." REAGER, ADLER & COGNETTI, P,C. ,~~....>--' TOR, ESQUIRE By: Subscribad and sworru,o"before me this Jr. day of /lI(,dC h ,2000. ~o.~ Notary Public Notariat Seal I.ori A, Richard, Notary Pubt", Camp Hill Bora. Cumb<\rland county My CommisSiOn ExpiresOct. 1, 2001 I\IJemOOr, Pennsylvania ASSOCiation at No"''"' - ~ ~'S_r:RE: I >>'~~A ~!iI~, F4Ii1T<lIi, I REAGER & ADLER', 'P.C I 2331 MARKET STREET I ' CAMP HILL, PA 17011 I 15, 7. Date of DeHvary ...z.- I I i f , , I , I I I i' , J i i , I I ~ f IWIR:. '4a. "Aliti~~ jq " ber ~\ '" . Z 902 0~7 572, 2, 0 ~"'. . ..... .'. ,4b" S. e. rvice Type RESl',RICTEO DELIVERY ." ce~FIED I ~11111~111~1I~1~11I~1I~'IIII~IIIIIII~II~.~lmlllllll!I~III'~,1111 Z 902 067 572 3. Article-Addressed to: RUTH E. CLEMENTS 1328 SUGAR MAPLE COURT NEW CUMBERLAND PA 17070 .f /, , ~-'--<- -~ ,." -,;;"~'",;:i,,r',", "'~, Ii." . ,.",..,c.;""., '" '_~',~J~"_. - ~ "c,,",'"" > ~ """. ^ ~~',l~, .. "". .... , ," .....,.. " .., ','..,.,' .\n .~' (") c d ~ Cl -n :::11: ~::! -ot'tr hI> it1iT; ',~..... i-:t.;f!? ~? ~ - -',-'ffi ~d.i' 0 ~7~' C> --;---L'-r, ~8 =:.: S:;~le5 - Om ~ ~--I <n 2> w -0 -< ~ -, i i JEFF CLEMENTS Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2000-1077 CIVIL TERM RUTH E. CLEMENTS 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 February 25, 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 a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the staternents 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 Date: 1/2..W unsworn falsification to authorities. liilitililJW-"'''''';' .' "Jwe;.' =' ...[;~';;:.;.. ,'~' L.",~,"." 'I&'j ~~tr';r4\~ """"." .,,- . . '.. ~ ~~ (~~~: j>C~:: ~..- ---.; -" -:;::' .... '. I I ~ I c.~, ;"';J C', . 1- , -J; I . IJ , JEFF CLEMENTS Plaintiff v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2000-1077 CIVIL TERM RUTH E. CLEMENTS Defendant CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER ~ 3301(c) OF THE DIVORCE CODE I. 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 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 f:tled 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:'1-2JjrOI ~ ;ijlfiili ~ ec.',"C "lIVeL" ,'0 (,:,,--. . " ,^',~ , "Mme" 'e S:J C_ <:" [~F C/. s~ ~~;c-,; )> ~:.::, C/ :::'J, ,CO;, " c.'> >) C', i:--, ~,'1 . " '~.!loI~' i: ,i i , " . . .J . JEFF CLEMENTS Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO, 2000-1077 CIVIL TERM RUTH E, CLEMENTS Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT L A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on February 25, 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 a final decree of divorce after service of notice of intention to request entry of the decree. 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 authorities, Date: 7/;;).3 Ie) I Ut-~ Ruth Clements _1'" ""--'" ~';. ,,,.' ~"l! ...', <.i <, "T~'i 'iP"I~"'~~ ,- ..1"" ,""," ",'., ,. .. < , .-..< . " oj ~ (~~ r :..":= .~,~,:C', 1''7::(-) ';"'C -,7 ::-=i -< , , '-,.' r'<,~) c.-: .._;-) :",J '..J '~ ~' . . . . . i) . JEFF CLEMENTS Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA : NO. 2000-1077 CIVIL TERM RUTH E. CLEMENTS Defendant : CIVIL ACTION - LAW : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER ~ 3301(c) OF THE DIVORCE CODE L 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 in 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, S 4904 relating to unsworn falsification to authorities. Date: 7 f:J..3/61 ~~ Ruth Clernents .', , .. " _I"" , -~ ....... ~, ", '~ U!1'Ii'ii;lii!:!; , . ~ . ,.;-. . ~,; " , "','- ~,I' ". . "" iIlt:-:, JEFF CLEMENTS Plaintiff v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2000-1077 CIVIL TERM RUTH E. CLEMENTS Defendant : CIVIL ACTION - LAW : IN DIVORCE PRAECIPE TO THE PROTHONOTARY: The Social Security nurnbers of the parties hereto are as follows: Plaintiff, Jeffrey Clements: 166-46-3772 Defendant, Ruth Clements: 365-56-6866 Respectfully submitted, REAGER & ADLER, PC Date: -1 [?--~1l21 I By~r. Dea n tor, Esquire ID #66378 2331 Market Street Camp Hill, P A 17011 717-763-1383 Attorneys for Plaintiff d"""^" ~~-""";,_'iMI~~~iIll .0 "'mT'i' d "~: to - .. C) ~: -,...~ . [T;: ~" '" ~, . -~J , ,. , ~ ,1. ;ili;; JEFF CLEMENTS Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY,PENNSYLVANIA V. : NO. 2000-1077 CIVIL TERM RUTH E. CLEMENTS Defendant : CIVIL ACTION - LAW : IN DIVORCE ORDER OF COURT AND NOW, this Ol,jM day of {]pJ , 2000, upon consideration of the attached Petition for Immediate Relief, a hearing shall be held on the S6f day Of~ ,2000 at 9:/5 o'clock C( . m. in court Room No. ~ Fourth floor of the Cumberland County Courthouse, Carlisle, Pennsylvania. ~/ BY THE c1f\, ".. ;.j / . . ... / J. I cc: Jacqueline M. Verney, Esquire c..;ur ~ .f;, 0:Jij , Debra Denison Cantor, Esquire ,~~ / . I _.' , ,-, '(I';' '. 'J~lctiY DD IQFi"~ ,) , ,', ,j P{':1 ?: 0Q "" .1,.., GUJ\/ii/~~;"iL./., ();! l\r"' I':-,\I{' ":'VL' u, I,' !. .vIi I Y - '\""l V,I'<\!!/, ~~ '.;' ,~~" I', ~ !1l7~~~~~~~~~1 l.:mi""",~.~,,~,Nlt! ~ _00. ~". -~ ~, I ~"", JEFF CLEMENTS Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLV ANIA V. NO. 2000-1077 CIVIL TERM RUTH E. CLEMENTS Defendant CIVIL ACTION - LAW IN DIVORCE PETITION FOR IMMEDIATE RELIEF AND NOW, comes Ruth E. Clements, Defendant, by and through her attorney, Jacqueline M. Verney, Esquire, and hereby petitions this Honorable Court as follows: I. On or about February 25, 2000, a divorce complaint was initiated by Jeff Clements at the above term and number. 2. The parties were married on October 4, 1997. 3. The Plaintiff owned, prior to the marriage, real estate located at 1328 Sugar Maple Court, New Cumberland, Cumberland County, Pennsylvania, 17070. Said location became the parties' marital residence. 4. The parties separated on or about March 1,2000. Defendant continues to reside in the marital residence. 5. Plaintiff has requested Defendant to vacate the marital residence, which defendant is willing to do. 6. Defendant signed a sales agreement to purchase a home and applied for a mortgage on or about March 28, 2000. Settlement to purchase the home is scheduled for May 25, 2000. 7. Defendant requires approximately $9,800.00 to pay for the purchase of the home and closing costs. - ,,. . - ~ ~ <' "~""\;j:b!'i 8. Prior to the marriage, Defendant owned individually $5,027.82 in an account at Mellon Bank, NA. A copy of the statement is attached hereto as Exhibit "A". Said amount was commingled into a joint account upon marriage. Defendant claims this amount is a premarital asset. 9. The parties maintain a joint money market account at Schwab Institutional identified as account number 2374-2668. The present value of that account is $9,812.82. A copy of the recent statement is attached as Exhibit "B". 1 O. The parties also maintain a joint mutual fund account at Schwab Institutional identified as account number 2374-2668. The present value of that account is $15,098.01. See Exhibit "B". 11. Defendant has requested the release of $9,812.82 from the joint Schwab money market account, consisting of $5,027.82 of premarital assets and $4,785.00 being marital assets, in order to close on the purchase of the new home which has been necessitated by Plaintiffs demand that Defendant vacate the marital residence. 12. The marital portion of said withdrawal would be credited against Defendant's ultimate equitable distribution of marital assets. 13. Plaintiff has refused to agree to the withdrawal of said $9,812.82. 14. Defendant's mortgage company has requested assurances on or before May 15,2000 that the $9,812.82 is available to Defendant. 15. Closing on the real estate purchase will not occur unless said amount is released. 16. The parties received various wedding gifts and jointly purchased other household furnishings that Defendant wishes to remove from the marital residence to set ''-1,J,~''-' .- ,1..: ~ """',-: up housekeeping in her new residence. A list of items she wishes to remove is attached hereto as Exhibit "C". 17. Plaintiff has refused to permit Defendant to remove the items listed on Exhibit "C". 18. Plaintiff visits the marital residence daily and has had ample opportunity to inventory and appraise these items. 19. The parties filed joint 1999 federal and state income tax returns. A refund in the amount of $3,600.00 is expected. Defendant seeks to divide the refund equally. 20. Plaintiff has refused to agree to divide the federal and state income refunds. WHEREFORE, Defendant respectfully requests the following: a. This Court order that $9,812.82 be withdrawn from the Schwab money market account for the use of Defendant to close on the purchase of alternate housing. b. This Court order that Defendant may remove the items listed on Exhibit "C". c. This Court order that the parties' 1999 income tax refunds be divided equally among the parties. Respectfully submitted, 'i ! ~SiOD %,f{ c eline M. Verney, Esquire # 167 44 S. Hanover Street Carlisle, P A 17013 (717) 243-9190 Attorney for Defendant ~. J.,ImJ J.U... .ti1'J.f.,bYUld IH~_ 211~ Q~R-2~-2aBm eB~IB RM J"VERNEV ,.,~,~, ~ 717 243 3:I!!!Ue VERD'ICA. TION I vori~ that 1he statements made in the within PetitlDII are tru. lIlld oorl'eQt to the best of my knowle4se and beliof. I understand that fAlse statements herein are made subject to the penalties of 18 Pa. C. S.A. f 4904 relating to UllliWOl'n falslfir:ati.an to authorities. Dated: L)) ~J ao ~JA. e t~~, RI1th E. Clements , ,'" L,. , . ,~.- ~005 J!".e7 1IlIIil.!i.illc" -'o..oJ> PERSONAL BANKING STATEMENT DIRECT INQUIRIES TO. MELLON BANK NA 0 COMMONWEALTH REGION MECMANICSBURG 2 W MAIN ST MECHANICS8URG PA 17055-6231 717-766-'1743 1",111...111,.....111..1.1.1..1",111....11.,1,1..1.1",,11.1 RUTH I! STOVI!R 1341 MOUNTAIN' RD DAUPHIN fA 17018-9706 00336 O'lU 144-000-2911 PAGI! 1 OF 4 STATEMENT FROM 07/04/97 THRU 08/05/97 ;. ,.- - -- ---'---'1'111& ANENDS ',YOUR.-AlileQumO-IlIJ'L.55 ,MI~LAfJ.0N8. \<OlIR .s:r.Af&.MBN~wz.L!.--. BE HAILED JI TO THE LAST ADDRESS THAT YOU PROVIDED TO US. OR 21 TO THE LAST ADDIlESS THAT YOU PROVIDED TO OUR CHiCf( vI!tfDOR, OR.JI TO THE FORWARDING ADDRESS THAT YOU PROVIDED TO THE U.S. POSTAL SERVICE. RELATIONSHIP SUMMARY .; E ACCDlINTS PE_AL CHeCKING NIlS --.. TOTAL PERSONAL CHECKING ACCOUNT 144-000--2911 ~..9.:!\:tjl~..,. ...~!::':~:I'lilr' ',: '. .' fl."'.", .'j. I ,. .I "'. . " OI'ENIMl 8A~ AS OF 071_'7 TOTAL DEPOSXTS AND O11lE~ ADPln_ INCLUPINS INTlRIST CRlDITlD THIS PEUDD TftTAl CHI;CKS, AND OTHER WlTHDRAWD.L!t tNtLUDINS ~IES ANO CHARGES TtttS PEJg:DD CLlISING IlALANCE AS QF 08lC5I'7 . " ., - . . . ..' 071091'7 07109 MILLON ATH IIJ:THDAAHAL "02122 LINSLESTONN _ PA . . . a.n,'. n +1.,,3M.46 ...1,.lm'.76 2,IlM.41 2,&&4.21 C""CKs _ DTllER DAILY Ift:THDRAWAI It I!I.lLj,MtE 2,'99.7$ r "..- ~.7D 1,8$0.0$ 100.00 2..130.u3 nO.'lI 18O.OD 2,4039.08 100.00 2..3;9.oa SD,OO z.za,.aa I 1 ,.. ": ,r , :' " .. . , , ..' ~'. DATI! POSTED DESCR!I!ITJ:aN ,071041"7 IlI'llra:NG IlALANCI '7.'.""'; .nEe<.' It!l'. : CHECK. , 12S1l. . . . C17/1fV97 CIfECk.. 12.!i7 . CHECK. , US9 . 07/15197 CHICK' 1261 07116/" CHECK' 1255 r~ '11+" -~ " 04/25/00 10:17 FAX 717 975 3018 Charles Schwab - Account Overview HIGHllARK 2B L2 " ",1- Ii!I006 Page 1 on ~J_lild _ ISitaMop.I~O'!'1 ~ Account I Trade I Quotes & Research I Alerts I Planrli'1g I Service Overview I Balances I Positions I E'erformal)<;!!1 ~nltorl History I MO'Je Monev Urgent Notification ~-tl~";B\ Margin trading maintenance requirements and """ , ,... ...11I buying power oaloulation for certain volatile 8Iocke Customl~ ~...Help ... Account Information Securities Market Value T olal Cash Total Account Value Delan. $15.098.01 $9,812.82 $24,810.B3 IndlOf!$ (Del.yed) Schwab 1000 Q9W Inrjustriel NASDAO .... .. NYSE Adv/Q~J:; Dotall< Lasr Change 4,009_39 +72.85 10,934.:3:3 +28,23 3,633,10 +150,62 Advance Oaclll\Cl. +1,451 -l'l41 NYSE: Volume 105,800,500 share. "" of 09:5\1:65 Ef, 04I2512OtlO _unIlIW!.~ IllIoltu&FI!!!oa"'" IAI""-I PIa".".I~ 11l"~pJ [R.\lIUmloToD] P.J!O!!O~I !l..~ I ~!1Si~ I Perfo,man"'l M.nllo'IHisYI~Ypnoy 02ll!lllCha~.. Soh"'ob &Co..lno. An rlghl"'_. M_ SIPCINYSe, Unauthorized aCC0&S ~ ptohibiWi. Usage wiU be monrrored. A........nbll ~Pqll!'X Account Number 2374-2668 v"""... .r, April 25. 2t1OQ 09:59AM ET https:llinvesting_schweb.com...I?Refresh=Yes&NeedCASelValue=Y &menu=l&submenu= 04125/2000 [)( I' 8'/ IlIIl . ~ ~~ , . "~'~""'~t~,',: ITEMS TO BE REMVOED BY DEFENDANT: I. Leather couch 2. Leather chair 3. Leather altim 4. Book case 5. Chest 6. Coffee table 7. Console table 8. Glass end table 9. VCR 10. Small TV 11. Coffee pot 12. Toaster 13. Pfaltzgraff-plates, bowls, cups, dessert dishes, baking bowls, meat platter 14. Glasses 15. Blender 16. Lettuce tosser 17. Crystal cake dish 18. Wine glasses 19. Pots and pans 20. Plastic ware 21. Corell dishes 22. Mikasa picture frame 23. Towels-yellow, dark green 24. Kitchen towels and place mats 25. Table cloth 26. Spice rack 27. Cutting board 28. Silverware 29. Baking dishes 30. Golfpictures 31. Golf statues 32. Artificial tree 33. Paper towel holder EXHIBIT "C" --lid < 1~ '~lMlMil5. CERTIFICATE OF SERVICE I hereby certify that a copy of the within Petition for Immediate Relief in the foregoing matter was served on the person named below by placing same in first class US mail, postage prepaid. Debra Denison Cantor, Esquire 2331 Market Street Camp Hill, PA 17011 Date: ~ - 2- ~-~oV fi;,i cq line M. Verney, Esquire #231 ~ 44 South Hanover Street Carlisle, P A 17013 (717) 243-9190 Attorney for Defendant I,; c5 :.::-' ~...J . C') <, i: ~5 [\..l ~. L.L ,. '; ,-, 'r; .~:,:.j C',~; , :)',~~~ ~.j~li :~') C) Jacqueline M. Verney LAW OFFICE OF 44 S. HANOVER ST. . CARLISLE, PA 17013 . (717) 24H190 . FAX (717) 243-3518 -. ~~..- l' , JEFF CLEMENTS Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY,PENNSYLV ANIA V. NO. 2000-1077 CIVIL TERM RUTH E. CLEMENTS Defendant CIVIL ACTION - LAW IN DIVORCE ORDER OF COURT AND NOW, this .:>~ day of V\.Acl,t+-, 2000, upon consideration of the attached Petition for Immediate Relief and response thereto, it is hereby ordered: A. $9,812.82 shall be withdrawn from the parties' Schwab money market account for use by Defendant for the purchase of alternate housing only. B. The $9,812.82 is fully marital and shall be credited to Defendant as an advance on equitable distribution. C. Any and all tax consequences or capital gains incurred as a result of the withdrawal shall be attributed to Defendant alone. D. Defendant is entitled to remove all items listed on Exhibit "C", except that item 30 shall be revised to "Pinehurst poster." E. The parties 1999 income tax refund shall be placed in a jointly held escrow account pending final equitable distribution or further order of the court. F. The parties agree that the distribution of personal property pursuant to this order is the final division of personal property. The parties reserve the right to assess value on said items at a later date. '-'JtWM.llrw ,- - {~ - -~,~~ '--. ~ - ~ ~ " . cc: Jacqueline M. Verney, Esquire Debra Denison Cantor, Esquire ~' W" ... , .- ~\ 0/~ BY Ttffi COUl~l/:/ , ,'J ,I I '/ ~ I 7 Edgar B. Bay ey, J ~ 5 -..5-00 p,K3 F\\.E\}-()~r\CE OF 1\-\C v:.fi\\-\O~\O\f\R'{ \lU~~1-S M" 9: 54 CUNiOtR\J'ND COUl{\{ ?ENNS'il'J{o!,\!\/\ l I :~ '. " 1 ~ . ~\ ~,,'~1, ,~ ""..,.".... ,~~ IT ~ ""lil!1'~tM , ---=,~ v-rr "","V""O,",_ '- -"1"",... -- t1~ ~ pJ~~ po, ~ ~~ ~~[L ~ ~~ , "'1--, " ",' .,', "iiit'" -- ~ '..,- '<" ",~ " ,'" I:, iIlUi JEFF CLEMENTS Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA : v. NO. 2000-1077 CIVIL TERM RUTH E. CLEMENTS Defendant CIVIL ACTION - LAW IN DIVORCE ORDER AND NOW, this _ day of ,2000, upon consideration of the attached Petition for Immediate Relief and response thereto, it is hereby ordered: A. $9,812.82 shall be withdrawn from the parties joint Schwab money account for use by Defendant ofthe purchase of alternate housing only, B. The $9,812.82 is fully marital and shall be credited to Defendant as an advance on equitable distribution. C. Any and all tax consequences or capital gains results incurred as a result of the withdrawal shall be attributed to Defendant alone. D. Defendant may be entitled to remove all items listed on Exhibit "C", except the coffee table, console table and glass end table. Defendant is only entitled to remove the Pine Hurst poster and no other golf pictures. E. The parties 1999 income tax refund shall be placed in a jointly held escrow account pending final equitable distribution or further order of the court. BY THE COURT, Edgar B. Bayley, Judge - ,C,',., ... .l;"" 1- "" JEFF CLEMENTS Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000-1077 CIVIL TERM RUTH E. CLEMENTS Defendant CIVIL ACTION - LAW IN DIVORCE ANSWER TO DEFENDANT'S PETITION FOR IMMEDIATE RELIEF AND NOW, comes Plaintiff, Jeff Clements, by and through his counsel, Reager, Adler and Cognetti, P.C. and Debra Denison Cantor, Esquire, hereby answers Defendant's Petition for Immediate Relief as follows: 1. Admitted. 2. Admitted. 3. Admitted. By way of further answer, Defendant has maintained exclusive possession of said residence since the parties separation. 4. Admitted. 5. Admitted. By way of further answer, Plaintiff has not resided in his pre-marital home since the date of separation and has been solely responsible for all payments thereon. 6. Denied. After reasonable investigation, Plaintiff is without sufficient knowledge to form a belief as to the truth of this averment and strict proof thereof is required. 7. Denied. After reasonable investigation, Plaintiff is without sufficient knowledge to form a belief as to the truth of this averment and strict proof thereof is required. - . . ~ . ',"' - , " I -~. 8. Admitted in part, Denied in part. It is admitted that Defendant owned individually $5,027.82 in an account at Mellon Banle It is further admitted that said amount was commingled into joint marital assets. It is specifically denied that this amount is a pre-marital asset. Pursuant to Pennsylvania case law, separate assets which are commingled into joint marital assets are deemed a gift of the marriage and are no longer pre-maritaL Defendant is improperly seeking a pre-marital credit on a marital asset. By way of further answer, Plaintiff contributed $15,000.00 of separate pre-marital money to the joint marital assets. 9. Admitted. 10. Admitted. 11. Admitted in part. Denied in part. It is admitted that Defendant has requested the release of$9,812.82, consisting of both pre-marital and marital assets. Please see Plaintiffs Answer to Paragraph 8 indicating that the pre-marital contribution is now a marital asset. Therefore, Defendant is requesting the release of$9,812.82 of marital assets. It is further denied that the purchase of the new home is necessitated by Plaintiffs demand that Defendant vacate the marital residence. At no time has Plaintiff pressured Defendant to move from the marital residence, and has in fact assumed sole responsibility for all payments associated with said residence. 12. Denied. The marital portion of this request is $9,812.82. 13. Admitted. It is admitted that Plaintiff has refused to agree to the withdrawal of $9,812.82, based on the requested division of pre-marital versus marital assets. Plaintiff would agree to the withdrawal, if said withdrawal is deemed entirely marital and will be viewed as an advance on equitable distribution in its full amount. - ,-. ..--, ,-~ ' . _1 14. Denied. After reasonable investigation, Plaintiff is without sufficient knowledge to form a belief as to the truth of this averment and strict proof thereof is required. 15. Denied. After reasonable investigation. Plaintiff is without sufficient knowledge to form a belief as to the truth of this averment and strict proof thereof is required. 16. Admitted. It is admitted that the parties received various wedding gifts and jointly purchased household furnishings and that the Defendant wishes to remove from the marital residence. In essence, Defendant is removing all of the jointly purchased marital property and wedding gifts to which Plaintiff has the following objections. Plaintiff would like to retain the coffee table, console table and glass end table. In addition, Plaintiff would consent to Defendant removing the Pine Hurst poster from the marital home. The remaining golf pictures were Plaintiffs pre-maritally and should therefore remain with Plaintiff. 17. Admitted. Please see the above answer. 18. Admitted. By way of further answer. Plaintiff seeks an agreement that upon this removal of personal property there will be no additional issues regarding personal property, no request for the appraisal of personal property, and the parties will agree that the division of the personal property is fair and equitable. 19. Admitted. It is admitted that the parties filed a joint 1999 federal and state income tax return with a refund amount of $3,600.00 expected. This amount is a marital asset which should be preserved until the final distribution of the assets. The parties assets are largely tied up in the increase in value in the home, an alleged value to Plaintiff s business interest, and in the Schwab accounts. Distribution of the Schwab accounts will involve taxable consequences. Therefore, the tax refund represents the only non-taxable liquid asset to be divided. Plaintiff ~-- l.~~ - ~ W:- requests to reserve that asset for the ultimate distribution. 20. Admitted. Please see above. WHEREFORE, Plaintiff respectfully requests the following: a. The Court order that the $9,812.82 be withdrawn from the Schwab money account for use of Defendant to close on the purchase of alternate housing only; b. The Court deem that the $9,812.82 is fully marital and shall be credited to Defendant as an advance on equitable distribution; c. The Court order that any tax consequences or capital gains incurred as a result of that withdrawal be attributed to Defendant alone; d. The Court order that Defendant may remove all items listed on Exhibit "C", except the coffee table, console table, glass end table, and to limit the golf pictures to be removed to the Pine Hurst poster, and; e. The Court order that the parties 1999 income tax refund be placed into ajointly held escrow account pending fmal equitable distribution or further order of court. RESPECTFULLY SUBMITTED, REAGER, ADLER & COGNETTI, P.C. By: CANTOR, ESQUIRE Id catio 0 6378 2331 Market Street Camp Hill, PA 17011 (717) 763-1383 Dated: May 3, 2000 Attorney for Plaintiff - '. I :, lliililltiilllii, CERTIFICATE OF SERVICE AND NOW, this 3'd day of May, 2000, I hereby verify that I have caused a true and correct copy of the foregoing document, Answer to Defendant's Petition For Immediate Relief, to be placed in the U.S. mail, first class, postage prepaid and addressed as follows: Jacqueline M. Verney, Esquire 44 S. Hanover Street Carlisle, PA 17013 REAGER, ADLER & COGNETTI, P.C. By: , ESQUIRE D'~6};'i Attorney for Plaintiff .~. ~v~ ::i - AUW , . -'\'- <,') c-- :s ,i?a; ;?:: f7 J ;<Jf Ujc,,~ ;::S;l~ liii"J -'0 ~0 >:;:: -<" :::f REAGER, ADLER & COGNETTI, P.C. ATTORNEYS AT LAW 2331 MARKET STREET CAMP HILL, PA 17011-4642 (717) 763-1383 \" ~ c::. <::) "'-:to "'" -.; I 0./:."", 'if ;:p C<) '. .~ a:. :::;:1 "';'1;!:; r- .:Qf!j :-$;: :2~ ~t;) -:ti ,S/J $ -~i ~ ? . JEFF CLEMENTS Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. NO, 2000-1077 CIVIL TERM RUTH E. CLEMENTS Defendant CIVIL ACTION - LAW IN DIVORCE ORDER AND NOW, this ~ day of , 2000, upon consideration of the attached Petitio]) for Immediate Relief and response thereto, it is hereby ordered: A. $9,812.82 shall be withdrawn from the parties joint Schwab money account for use by Defendant of the purchase of alternate housing only, B. The $9,812,82 is fully marital and shall be credited to Defendant as an advance on equitable distribution. C. Any and all tax consequences or capital gains results incurred as a result ofthe withdrawal shall be attributed to Defendant alone. D, Defendant may be entitled to remove all items listed on Exhibit "C", except the coffee table, console table and glass end table. Defendant is only entitled to remove the Pine Hurst poster and no other golf pictures. E. The parties 1999 income tax refund shall be placed in a jointly held escrow account pending final equitable distribution or further order of the court, BY THE COURT, Edgar B. Bayley, Judge '''''''ili~! , . JEFF CLEMENTS Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. NO. 2000-1077 CIVIL TERM RUTH E. CLEMENTS Defendant CIVIL ACTION - LAW IN DIVORCE ANSWER TO DEFENDANT'S PETITION FOR IMMEDIATE RELIEF AND NOW, comes Plaintiff, Jeff Clements, by and through his counsel, Reager, Adler and Cognetti, P.C. and Debra Denison Cantor, Esquire, hereby answers Defendant's Petition for Immediate Relief as follows: I. Admitted. 2. Admitted. 3. Admitted. By way of further answer, Defendant has maintained exclusive possession of said residence since the parties separation. 4. Admitted. 5. Admitted. By way offurther answer, Plaintiff has not resided in his pre-marital home since the date of separation and has been solely responsible for all payments thereon. 6. Denied. After reasonable investigation, Plaintiff is without sufficient knowledge to form a belief as to the truth of this averment and strict proof thereof is required. 7. Denied. After reasonable investigation, Plaintiff is without sufficient knowledge to form a belief as to the truth of this averment and strict proof thereof is required. . .~~, ," <,- I ^', , 8. Admitted in part, Denied in part. It is admitted that Defendant owned individually $5,027.82 in an account at Mellon Bank. It is further admitted that said amount was commingled into joint marital assets. It is specifically denied that this amount is a pre-marital asset. Pursuant to Pennsylvania case law, separate assets which are commingled into joint marital assets are deemed a gift of the marriage and are no longer pre-marital. Defendant is improperly seeking a pre-marital credit on a marital asset. By way of further answer, Plaintiff contributed $15,000.00 of separate pre-marital money to the joint marital assets. 9. Admitted. 10. Admitted. II. Admitted in part. Denied in part. It is admitted that Defendant has requested the release of $9,812.82, consisting of both pre-marital and marital assets. Please see Plaintiffs Answer to Paragraph 8 indicating that the pre-marital contribution is now a marital asset. Therefore, Defendant is requesting the release of$9,8l2.82 of marital assets. It is further denied that the purchase ofthe new home is necessitated by Plaintiffs demand that Defendant vacate the marital residence. At no time has Plaintiff pressured Defendant to move from the marital residence, and has in fact assumed sole responsibility for all payments associated with said residence. 12. Denied. The marital portion ofthis request is $9,812.82. 13. Admitted. It is admitted that Plaintiff has refused to agree to the withdrawal of $9,812.82, based on the requested division of pre-marital versus marital assets. Plaintiff would agree to the withdrawal, if said withdrawal is deemed entirely marital and will be viewed as an advance on equitable distribution in its full amount. ~ I,~ ~, 14. Denied. After reasonable investigation, Plaintiff is without sufficient knowledge to form a belief as to the truth of this averment and strict proof thereof is required. 15. Denied. Afterreasonable investigation. Plaintiff is without sufficient knowledge to form a belief as to the truth of this averment and strict proof thereof is required, 16. Admitted. It is admitted that the parties received various wedding gifts and jointly purchased household furnishings and that the Defendant wishes to remove from the marital residence. In essence, Defendant is removing all of the jointly purchased marital property and wedding gifts to which Plaintiff has the following objections. Plaintiff would like to retain the coffee table, console table and glass end table, In addition, Plaintiff would consent to Defendant removing the Pine Hurst poster from the marital home. The remaining golf pictures were Plaintiffs pre-maritally and should therefore remain with Plaintiff. 17. Admitted. Please see the above answer. 18. Admitted. By way of further answer. Plaintiff seeks an agreement that upon this removal of personal property there will be no additional issues regarding personal property, no request for the appraisal of personal property, and the parties will agree that the division of the personal property is fair and equitable. 19. Admitted. It is admitted that the parties filed ajoint 1999 federal and state income tax return with a refund amount of$3,600.00 expected. This amount is a marital asset which should be preserved until the final distribution of the assets. The parties assets are largely tied up in the increase in value in the home, an alleged value to Plaintiff s business interest, and in the Schwab accounts. Distribution of the Schwab accounts will involve taxable consequences. Therefore, the tax refund represents the only non-taxable liquid 'asset to be divided. Plaintiff ~ 1lI1., requests to reserve that asset for the ultimate distribution. 20. Admitted. Please see above, WHEREFORE, Plaintiff respectfully requests .the following: a. The Court order that the $9,812.82 be withdrawn from the Schwab money account for use of Defendant to close on the purchase of alternate housing only; b. The Court deem that the $9,812.82 is fully marital and shall be credited to Defendant as an advance on equitable distribution; c. The Court order that any tax consequences or capital gains incurred as a result of that withdrawal be attributed to Defendant alone; d. The Court order that Defendant may remove all items listed on Exhibit "C", except the coffee table, console table, glass end table, and to limit the golf pictures to be removed to the Pine Hurst poster, and; e. The Court order that the parties 1999 income tax refund be placed into ajointly held escrow account pending final equitable distribution or further order of court. RESPECTFULLY SUBMITTED, REAGER, ADLER & COGNETTI, P.c. By: CANTOR, ESQUIRE Id lcatio 0 6378 2331 Market Street Camp Hill, P A 17011 (717) 763-1383 Dated: May 3, 2000 Attorney for Plaintiff I CERTIFICATE OF SERVICE AND NOW, this 3'd day of May, 2000, I hereby verify that I have caused a true and correct copy of the foregoing document, Answer to Defendant's Petition For Immediate Relief, to be placed in the U.S. mail, first class, postage prepaid and addressed as follows: Jacqueline M. Verney, Esquire 44 S. Hanover Street Carlisle, PA 17013 REAGER, ADLER & COGNETTI, P.C. By: D'loo s}j. ~ Attorney for Plaintiff ,. " .. .. JEFF CLEMENTS Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000-1077 CIVIL TERM RUTH E. CLEMENTS Defendant CIVIL ACTION - LAW IN DIVORCE ORDER AND NOW, this ~ day of ,2000, upon consideration of the attached Petitio]) for Immediate Relief and response thereto, it is hereby ordered: A. $9,812.82 shall be withdrawn from the parties joint Schwab money account for use by Defendant of the purchase of alternate housing only. B. The $9,812.82 is fully marital and shall be credited to Defendant as an advance on equitable distribution. C. Any and all tax consequences or capital gains results incurred as a result of the withdrawal shall be attributed to Defendant alone. D. Defendant may be entitled to remove all items listed on Exhibit "C", except the coffee table, console table and glass end table. Defendant is only entitled to remove the Pine Hurst poster and no other golf pictures. E. The parties 1999 income tax refund shall be placed in a jointly held escrow account pending final equitable distribution or further order of the court. BY THE COURT, Edgar B. Bayley, Judge ".~ ~ Jl.--jilf( . JEFF CLEMENTS Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. NO. 2000-1077 CIVIL TERM RUTH E. CLEMENTS Defendant CIVIL ACTION - LAW IN DIVORCE ANSWER TO DEFENDANT'S PETITION FOR IMMEDIATE RELIEF AND NOW, comes Plaintiff, Jeff Clements, by and through his counsel, Reager, Adler and Cognetti, P.c. and Debra Denison Cantor, Esquire, hereby answers Defendant's Petition for Immediate Relief as follows: 1. Admitted. 2. Admitted. 3. Admitted. By way of further answer, Defendant has maintained exclusive possession of said residence since the parties separation. 4. Admitted. 5. Admitted. By way of further answer, Plaintiff has not resided in his pre-marital home since the date of separation and has been solely responsible for all payments thereon. 6. Denied. After reasonable investigation, Plaintiff is without sufficient knowledge to form a belief as to the truth of this averment and strict proof thereof is required. 7. Denied. After reasonable investigation, Plaintiff is without sufficient knowledge to form a belief as to the truth of this averment and strict proof thereof is required. ~ . ~~ 8. Admitted in part, Denied in part. It is admitted that Defendant owned individually $5,027.82 in an account at Mellon Bank. It is further admitted that said amount was commingled into joint marital assets, It is specifically denied that this amount is a pre-marital asset. Pursuant to Pennsylvania case law, separate assets which are commingled into joint marital assets are deemed a gift ofthe marriage and are no longer pre-marital. Defendant is improperly seeking a pre-marital credit on a marital asset. By way of further answer, Plaintiff contributed $15,000.00 of separate pre-marital money to the joint marital assets. '9. Admitted. 10. Admitted. II. Admitted in part. Denied in part. It is admitted that Defendant has requested the release of$9,812.82, consisting of both pre-marital and marital assets. Please see Plaintiffs Answer to Paragraph 8 indicating that the pre-marital contribution is now a marital asset. Therefore, Defendant is requesting the release of$9,812.82 of marital assets. It is further denied that the purchase of the new home is necessitated by Plaintiffs demand that Defendant vacate the marital residence. At no time has Plaintiff pressured Defendant to move from the marital residence, and has in fact assumed sole responsibility for all payments associated with said residence. 12. Denied. The marital portion of this request is $9,812.82. 13. Admitted. It is admitted that Plaintiff has refused to agree to the withdrawal of $9,812.82, based on the requested division of pre-marital versus marital assets. Plaintiff would agree to the withdrawal, if said withdrawal is deemed entirely marital and will be viewed as an advance on equitable distribution in its full amount. ....t- 14. Denied. After reasonable investigation, Plaintiff is without sufficient knowledge to form a belief as to the truth of this averment and strict proof thereof is required. 15. Denied. After reasonable investigation. Plaintiff is without sufficient knowledge to form a belief as to the truth of this averment and strict proof thereof is required. 16. Admitted. It is admitted that the parties received various wedding gifts and jointly purchased household furnishings and that the Defendant wishes to remove from the marital residence. In essence, Defendant is removing all of the jointly purchased marital property and wedding gifts to which Plaintiff has the following objections. Plaintiff would like to retain the coffee table, console table and glass end table. In addition, Plaintiff would consent to Defendant removing the Pine Hurst poster from the marital home. The remaining golf pictures were Plaintiffs pre-maritally and should therefore remain with Plaintiff. 17. Admitted. Please see the above answer. 18. Admitted. By way of further answer. Plaintiff seeks an agreement that upon this removal of personal property there will be no additional issues regarding personal property, no request for the appraisal of personal property, and the parties will agree that the division of the personal property is fair and equitable. 19. Admitted. It is admitted that the parties filed ajoint 1999 federal and state income tax return with a refund amount of$3,600.00 expected. This amount is a marital asset which should be preserved until the final distribution of the assets. The parties assets are largely tied up in the increase in value in the home, an alleged value to Plaintiffs business interest, and in the Schwab accounts. Distribution of the Schwab accounts will involve taxable consequences. Therefore, the tax refund represents the only non-taxable liquid asset to be divided. Plaintiff ..~ - ,.,1 ,. llml requests to reserve that asset for the ultimate distribution, 20. Admitted. Please see above. WHEREFORE, Plaintiff respectfully requests the following: a. The Court order that the $9,812.82 be withdrawn from the Schwab money account for use of Defendant to close on the purchase of alternate housing only; b. The Court deem that the $9,812.82 is fully marital and shall be credited to Defendant as an advance on equitable distribution; c. The Court order that any tax consequences or capital gains incurred as a result of that withdrawal be attributed to Defendant alone; d. The Court order that Defendant may remove all items listed on Exhibit "C", except the coffee table, console table, glass end table, and to limit the golf pictures to be removed to the Pine Hurst poster, and; e. The Court order that the parties 1999 income tax refund be placed into a jointly held escrow account pending final equitable distribution or further order of court. RESPECTFULLY SUBMITTED, REAGER, ADLER & COGNETTI, P.C. By: CANTOR, ESQUIRE Id lcatio 0 6378 2331 Market Street Camp Hill, PA l70ll (717) 763-1383 Dated: May 3, 2000 Attorney for Plaintiff ~-W'".."', CERTIFICATE OF SERVICE AND NOW, this 3'd day of May, 2000, I hereby verify that I have caused a true and correct copy of the foregoing document, Answer to Defendant's Petition For Immediate Relief, to be placed in the U.S. mail, first class, postage prepaid and addressed as follows: Jacqueline M. Verney, Esquire 44 S. Hanover Street Carlisle, PA 17013 REAGER, ADLER & COGNETTI, P.C. By: 0"00 s};' 0 Attorney for Plaintiff ~ ,-.- "~" - Q_~"~~" I ,~ j ~ ~~ - ~ .. "~ . L , "=~~"-' JEFFREY CLEMENTS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY,PENNSYL VANIA V. : CIVIL ACTION - LAW : NO, 2000-1077 CIVIL TERM RUTH E. CLEMENTS, Defendant : IN DIVORCE NOTICE OF INTENTION TO RESUME PRIOR NAME Notice is hereby given that the Plaintiff in the above matter, having been granted a final decree in divorce on the 31 st day of July, 2001, hereby intends to resume and hereafter use the previous name of Ruth E, Stover and gives this written notice avowing her intention in accordance with applicable law. U1A- E- ~ Ruth E. Clements To be known as: ~'E-5kA;J Ruth E. Stover COMMONWEALTH OF PENNSYLVANIA ss COUNTY OF CUMBERLAND On the I (};J::Io..day of ~, 2001, before me, a notary public, personally appeared Ruth E. Stover (formerly' own as Ruth E, Clements), known to me to be the person whose name is subscribed to the within document and acknowledged that she executed the foregoing for the purpose therein contained, IN WITNESS WHEREOF, I have hereunto set my hand and seal. NOTARIAL SEAl KATHLEEN K. 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