HomeMy WebLinkAbout00-01147
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
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PENNA.
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STATE OF
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Christina M. Short,
No. 2000-1147
Civil
Plaintiff,
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VERSUS
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Christopher L. Short,
Defendant.
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DECREE IN
DIVORCE
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AND NOW, A"O" 50-\ ~ 2000 , IT IS ORDERED AND
DECREED THAT Christina M. Short
, PLAINTIFF,
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AND Christopher L. Short
, DEFENDANT,
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ARE DIVORCED FROM THE BONDS OF MATRIMONY.
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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;
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The attached Marital Agreement between the parties dated June 27, 2000, shall be:
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THONOTARY ,
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incorporated into this Decree in Divorce pursuant to the said Marital Agreement.
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By THE
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MARITAL AGREEMENT
TillS AGREEMENT, made this ~-day of 2000, by and between
Christopher L. Short, hereinafter-referred-to as Husb of 105 Wolf Street, Highspire, Dauphin
County, Pennsylvania, 17034, and Christina M. Short, heremafter-referred-to as Wife, of 35 Rolo Court,
Mechanicsburg, Cumberland County, Pennsylvania, 17055.
WITNESSETH:
WHEREAS, the parties hereto are Husband and Wife, having been married on January 28,1995,
in Linglestown, Dauphin County, Pennsylvania, and
WHEREAS, diverse unhappy differences, disputes and difficulties have arisen between the
parties and it is the intention of Wife and Husband to live separate and apart, and the parties hereto are
desirous of settling some of their respective fmancial and property rights and obligations as between
each other including, without limitation by specification: the equitable division of marital property; and
the settling of all matters between them relating to the past, present and future support, alimony and lor
maintenance of Wife by Husband or of Husband by Wife.
NOW, THEREFORE, in consideration of the premises and of the mutual promises, covenants
and under takings hereinafter set forth which are hereby acknowledged by each of the parties hereto,
Wife and Husband, each intending to be legally bound hereby, covenant and agree as follows:
AGREEMENT NOT A BAR TO DIVORCE PROCEEDINGS
This Agreement shall not be considered to affect or bar the right of Wife or Husband to a limited
or absolute divorce on lawful grounds, if such grounds exist or shall hereafter exist or to such defense as
may be available to either party. This Agreement is not intended to condone and shall not be deemed to
be a condonation, on the part of either party hereto, of any act or acts on the part of the other party which
have occasioned the disputes or unhappy differences which have occurred prior to or which may occur
subsequent to the date hereof. The parties intend to secure a mutual consent, no-fault divorce pursuant
to the terms of Section 3:301(c) of the Pennsylvania Divorce Code of 1980, as amended.
EFFECT OF DIVORCE DECREE
The parties agree that unless otherwise specifically provided herein, this Agreement shall
continue in full force and effect after such time as a final decree in divorce may be entered with respect
to the parties.
AGREEMENT TO BE INCORPORATED IN DIVORCE DECREE
The parties agree that the terms of this Agreement may be incorporated into any divorce decree,
which may be entered with respect to them.
WEIGLE, PERKINS & ASSOCIATES - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397
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DATE OF EXECUTION
The "date of execution" or "execution date" of the Agreement shall be defIDed 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.
ADVICE OF COUNSEL
The provisions of this Agreement and their legal effect have been fully explained to Christina M.
Short, by Jerry A. Weigle, Esquire, who is attorney for Plaintiff and who prepared this marital
agreement. Christopher L. Short acknowledges that he has been advised of his right to seek independent
legal counsel and he has decided not to do so. Both parties acknowledge that they fully understand the
facts and have been fully informed as to their legal rights and obligations and understand the same. The
parties hereto further acknowledge and accept that this Agreement is, in the circumstances, fair and
equitable and that it is being entered into freely and voluntarily after having received such advice and
with such knowledge, and that execution of this Agreement is not the result of any duress or undue
influence and that it is not the result of any collusion or improper or illegal agreement or agreements.
PERSONAL RIGHTS
Wife and Husband may and shall, at all times hereafter, live separate and apart. They shall be
free from any control, restraint, interference or authority, direct or indirect, by the other in all respects as
fully as if they were unmarried. They may reside at such place as they may select. Each may, for his or
her separate use or benefit, conduct, carry on and engage in any business, occupation, profession or
employment, which to him or her may seem advisable. Wife and Husband shall not molest, harass,
disturb or malign each other or the respective families of each other nor compel or attempt to compel the
other to cohabit or dwell by any means or in any manner whatsoever with him or her.
SEPARATION DATE
The parties do hereby acknowledge that they separated on October 22, 1999. It is hereby agreed
that October 22, 1999, shall be the separation date for purposes of equitable distribution under the
Pennsylvania Divorce Code unless altered by subsequent agreement of the parties in writing and signed
by each of the parties. No attempt at reconciliation shall be considered to alter the separation date unless
evidenced by written agreement.
MOTOR VEHICLES
A. The parties agree that Wife shall become the sole and exclusive owner of the parties'
1997 Chevrolet Cavalier motor vehicle. Wife shall be solely responsible for all payments on the
automobile loan for the Chevrolet Cavalier through PNC Bank (account number 40028006564728) and
shall indemnify and hold Wife harmless for the same. Husband shall execute any and all documents
necessary to convey said vehicle solely into the name of Wife.
WEIGLE, PERKINS & ASSOCIATES - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397
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B. The parties agree that Husband shall become the sole and exclusive owner of the parties'
Toyota Tacoma motor vehicle. Wife agrees to execute any and all documents necessary to convey said
vehicle over to Husband or to affect its' sale or trade-in by Husband to a 3rd party. Upon any sale or
trade-in of said vehicle, Husband shall cause the automobile loan through Core States Bank, now First
Union Bank (account #0000100002002591234) to be paid in full.
PERSONAL PROPERTY
Husband and Wife do hereby acknowledge that they have previously divided their tangible
personal property, including but not limited to jewelry, clothes, furniture, furnishings, rugs, carpets,
household equipment and appliances, vehicles, pictures, books, works of art and other personal property
and hereafter Wife agrees that all of the property in the possession of Husband shall be the sole and
separate property of Husband and Husband agrees that all of the property in the possession of Wife shall
be the sole and separate property of Wife. The parties do hereby specifically waive, release, renounce
and forever abandon whatever claims, if any, he or she may have with respect to the above items, which
shall become the sole and separate property of the other.
AFTER-ACOUIRED PERSONAL PROPERTY
Each of the parties shall hereafter own and enjoy, independently of any claim or right of the
other, all items of personal property, tangible or intangible, hereafter acquired by him or her, with full
power in him or her to dispose of the same as fully and effectively, in all respects and for all purposes,
as though he or she were not married.
REAL ESTATE
The parties hereto acknowledge and agree that they are owners of a home residence known as
105 Wolf Street, Highspire, Dauphin County, Pennsylvania. For and in consideration of the mutual
covenants and agreements herein contained in the body of this instrument, Husband and Wife further
stipulate and agree that said real estate shall be retained by Husband. In consideration of the mutual
covenants and agreements herein contained in the body of this instrument, Husband shall cause the
parties' mortgage at Columbia National Mortgage Company (account number 2109128) to be refinanced
so as to remove Wife's name from any liability therefore. Until said refinancing can occur, Husband
agrees to indemnify and/or hold Wife harmless from and against any and all liability for the same. In
the event that Husband has not caused said mortgage obligation to be refInanced or paid in full so as to
remove Wife from any liability therefore on or before five (5) years from the date hereof, the parties
agree that the marital residence will be sold at the earliest possible time thereafter and that the net
proceeds after payment of the said mortgage loan obligation and consolidation loan noted below
therefrom shall be divided equally between Husband and Wife. In the event of a default by Husband
during the above referenced five (5) year period or in the event that he fails to comply with any other
term or condition of the mortgage documents, or fails to pay the property taxes or homeowner's
insurance thereon, the marital real estate shall be sold and the net proceeds of the sale shall be
distributed as outlined above.
WEIGLE, PERKINS & ASSOCIATES - ATTORNEYS AT LAW - 126 EAST KlNG STREET - SHIPPENSBURG, PA 17257-1397
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CONSOLIDATION LOAN
Parties hereto agree that Husband shall assume sole responsibility for a joint loan consolidation
loan in the approximate amount of Nine Thousand Three Hundred Thirty-nine Dollars and Five Cents
($9,339.05) through the First Union Bank (account number 00001002869335) in consideration of the
mutual covenants and agreements herein contained in the body of this instrument, Husband shall
refmance the above referenced obligation so as to remove Wife's name from any liability therefore.
Until said refinancing can occur, Husband agrees to indemnify and/or hold Wife harmless from and
against any and all liability for the same. In the event that Husband has not caused said joint loan
consolidation loan to be refmanced or paid on full so as to remove Wife from any liability therefore on
or before five (5) years from the date hereof, the parties agree that the marital real estate known as 105
Wolf Street, Highspire, Dauphin County, Pennsylvania, will be sold at the earliest possible time
thereafter and that the net proceeds therefrom shall be used to pay in full said consolidation loan and
mortgage obligation noted above and that the net proceeds therefrom shall be divided equally between
Husband and Wife. In the event of a default by Husband during the above referenced five (5) year
period or in the event that he fails to pay property taxes, or insurance on the marital residence or fails to
fulfill any other loan obligation required by the Consolidation Loan Agreement, the marital real estate
shall be sold and the net proceeds of sale distributed as outlined above.
WARRANTY AS TO EXISTING OBLIGATIONS
Each party represents that he or she has not heretofore incurred or contracted for any debt or
liability or obligation for which the estate of the other party may be responsible or liable except as may
be provided for in this Agreement. Each party agrees to indemnify and hold the other party harmless
from and against any and all such debts, liabilities or obligations of every kind which may have
heretofore been incurred by them, including those for necessities, except for the obligations arising out
of this Agreement.
WARRANTY AS TO FUTURE OBLIGATIONS
Wife and Husband each covenant, warrant, represent and agree that each will now and at all
times hereafter save harmless and keep the other indemnified from all debts, charges and liabilities
incurred by the other after the execution date of this Agreement, except as may be otherwise specifically
provided for by the terms of this Agreement and that neither of them shall hereafter incur a liability
whatsoever for which the estate of the other may be liable.
LEGAL FEES
Wife shall pay the cost of legal fees incurred in preparation of this marital agreement and all
legal fees and court costs in connection with obtaining a 330l(c) No-Fault Divorce. Husband agrees to
cooperate by executing the necessary consents and other documents required to effectuate said divorce,
as requested by Wife's attorney.
INCOME TAX RETURNS
The parties agree to file separate federal and state income tax returns.
WEIGLE, PERKINS & ASSOCIATES - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397
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MUTUAL RELEASES
Husband and Wife each do hereby mutually remise, release, quitclaim and forever discharge the
other and the estate of each other, for all time to come, and for all purposes whatsoever, of and from any
and all rights, title and interest, or claims in or against the property (including income and gain from
property hereafter accruing) of the other or against the estate of such other, of whatsoever nature and
wheresoever situate, which he or she now has or at any time hereafter may have against such other, the
estate of such other or any part thereof, whether arising out of any former acts, contracts, engagements
or liabilities of such other or by way of dower, courtesy, or claims in the nature of dower or courtesy or
widow's or widower's rights, family exemption or similar allowance, 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 (a) Pennsylvania, (b) any State, Commonwealth or territory of the
United States, or (c) any other country, except, and only except, all rights and agreements and
obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of
any provision thereof. It is the intention of Husband and Wife to give to each other by the execution of
this Agreement a full, complete and general release with respect to any and all property of any kind or
nature, real, personal or mixed, which the other now owns or may hereafter acquire, except and only
except all rights and agreements and obligations of whatsoever nature arising or which may arise under
this Agreement or for the breach of any provision thereof.
WAIVER OR MODIFICATION TO BE IN WRITING
No modification or waiver of any of the terms hereofs}lall be valid unless in writing and signed
by both parties and no waiver of any breach hereof or default hereunder shall be deemed a waiver of any
subsequent default of the same or similar nature.
DIVORCE
The parties hereto agree to enter into a mutual consent divorce under Section 3301(c) of the
Pennsylvania Divorce Code of 1980, as amended. Christina M. Shart agrees to pursue the present
divorce action filed to No. 2000-1147 Civil, 2000 in the Court of Common Pleas of Cumberland
County, Pennsylvania, and to be the Plaintiff therein. Christopher L. Short agrees to sign the necessary
documents, including the Affidavit of Consent, at such time after the ninety (90) days of filing of the
Complaint and further instruments that may be reasonably required to give full force and effect to the
provisions of this Agreement.
MUTUAL COOPERATION
Each party shall, at any time and from time to time hereafter, take any and all steps and execute,
acknowledge and deliver to the other party any and all future instruments and/or documents that the
other party may reasonably require for the purpose of giving full force and effect to the provisions of
this Agreement.
LAW OF PENNSYL VANIA APPLICABLE
This Agreement shall be construed in accordance with the laws of the Commonwealth of
Pennsylvania.
WEIGLE, PERKINS & ASSOCIATES - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397
AGREEMENT BINDING ON HEIRS
This Agreement shall be binding and shall insure to the benefit of the parties hereto and their
respective heirs, executors, administrators, successors and assigns.
BREACH
If either party breaches any provision of this Agreement, the other party shall have the right, at
his or her election, to sue for damages for such breach or seek su,:h other remedies or relief as may be
available to him or her, and the party breaching this contract shall be responsible for payment of legal
fees and costs incurred by the other in enforcing their rights under this Agreement.
WAIVER OF ALIMONY AND OTHER RIGHTS
The parties hereto have been informed of their rights or have been advised ta seek counsel to
inform them of their rights under and pursuant to the Divorce Code, Action of April 2, 1980, Number
1980-26, as amended, particularly the provisions for alimony, alimony pendente lite, equitable
distribution of marital property, counsel fees or expenses. Both parties agree that this Agreement shall
conclusively provide for the distribution of property under the said law and except as specifically
provided for in this agreement, hereby waive, release and relinquish any further rights they may
respectively have against the other for alimony, alimony pendente lite, equitable distribution of marital
property, counsel fees or expenses. From the date hereof, each party may acquire either personal or real
property in their own name. Any property so acquired shall be owned solely by the individual and shall
not be subject to any claim whatsoever by the other party. '
FINANCIAL DISCLOSURE
The parties confirm that they have relied on the substantial accuracy of the financial disclosure
of the other as an inducement to the execution of this Agreement.
ENTIRE AGREEMENT
This Agreement constitutes the entire understanding of the parties and supersedes any and all
prior agreements and negotiations between them. There are no representations or warranties other than
those expressly set forth herein.
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 ofthe provisions of this Agreement shall in no way affect the right of such party hereafter to enforce
the same, nor shall the waiver of any breach of any provision hereof be construed as a waiver of any
subsequent default of the same or similar nature, nor shall it be construed as a waiver of strict
performance of any other obligations herein.
WEIGLE, PERKINS & ASSOCIATES - ATTORNEYS AT LAW- - 126 EAST KING STREET - SHIPPENSBURG, PA 17257~1397
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SEVERABILITY
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 provisions shall be
stricken from this Agreement and in all other respects this Agreement shall be valid and continue in full
force, effect and operation. Likewise, the failure of any party to meet her or his obligations under any
one or more of the paragraphs herein, with the exception of the satisfaction of the conditions precedent,
shall in no way void or alter the remaining obligations of the parties.
HEADfflGSNOT PART OF AGREEMENT
Any headings preceding the text of the several paragraphs and subparagraphs hereof are inserted
solely for convenience of reference and shall not constitute a part of this Agreement nor shall they affect
its meaning, construction or effect.
VOLUNTARY EXECUTION
The provisions of this Agreement and their legal effect have been fully explained to the parties
by their respective counsel, and each party acknowledges that the Agreement is fair and equitable, that it
is being entered into voluntarily, and that it is not the result of any duress or undue influence.
IN WITNESS WHEREOF, the parties hereto have set their hands and seals the day and year
first above written.
WITNESS:
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Christopher L. S ort
WEIGLE, PERKINS & ASSOCIATES ~ ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257~1397
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COMMONWEALTH OF PENNSYL VANIA
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COUNTY OF CUMBERLAND
On this, the c-Ol'tb day of ~~ C , 2000, before me a Notary Public,
the undersigned officer, personally appeared Christina M. Short, known to me to be the person whose
name is subscribed to the within Agreement and acknowledged that she executed the same for the
purposes therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and seal.
(SEAL)
COMMONWEALTH OF PENNSYLVANIA
NOTARIAL SEA
Jerry A Weigle, Notary ublie
Shippensburg, PA Cumberland County
M Commission Ex ires October 07 2002
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COUNTY OF CUMBERLAND
On this, the ,-Ql'\:b.. day of 2\~ , 2000, before me a Notary Public,
the undersigned officer, personally appeared Christopher L. Short, known to me to be the person whose
name is subscribed to the within Agreement and acknowledged that he executed the same for the
purposes therein contained.
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(SEAL)
IN WITNESS WHEREOF, I have hereunto set my hand and seal.
NOTARIAL SEAL
Jerry A Weigle, Notary bile
Shlppensburg, PA Cumberland County
M Commission Ex ires October 07 2002
WEIGLE. PERKINS & ASSOCIATES - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG. PA 17257~1397
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYL VANIA
CHRISTINA M. SHORT,
Plaintiff,
CIVIL ACTION- LAW
vs.
NO. 2000-1147 CIVIL
CHRISTOPHER L. SHORT,
Defendant.
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. Grounds for divorce: irretrievable breakdown under ~ 3301(c) of the Divorce
Code.
2. Date and manner of service of the complaint: March 6, 2000, by mailing postage
paid, certified mail, addressee only, and return receipt requested at Shippensburg, Pennsylvania.
3. Date of execution of the affidavit of consent required by ~ 3301(c) of the Divorce
Code: by Plaintiff June 27, 2000, by Defendant June 27, 2000.
4. Related claims pending: None: The attached Marital Settlement Agreement
between the parties dated June 27, 2000, shall be incorporated into this Decree in Divorce
pursuant to said Agreement.
5. (a) Date Plaintiffs Waiver in ~ 3301(c) Divorce was filed with the prothonotary:
July 19,2000;
Date Defendant's Waiver of Notice in ~ 330l(c) Divorce was filed with the
prothonotary: July 19, 2000.
WEIGLE, PERKINS AND ASSOCIATES
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erry . Weigle, Esquire - Attorney ill # 01624
Jo h P. Ruane, Esquire - Attorney ill # 71577
ttorneys for Plaintiff
126 East King Street
Shippensburg, P A 17257
717-532-7388
WEIGLE, PERKINS & ASSOCIATES ~ ATTORNEYS
AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
PENNSYL VANIA
NOTICE TO DEFEND AND CLAIM RIGHTS
CHRISTINA M. SHORT,
Plaintiff,
CIVIL ACTION -- LAW
VS.
NO. ;;2q;o~ /JC/? -tWJ
CHRISTOPHER L. SHORT,
Defendant.
IN DIVORCE
You have been sued in court. If you wish to defend agl\inst the claims set forth in
the following pages, you must take prompt action. You are warned that if you filiI 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 judgement may also be entered l\gainst 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 visitl\tion of your children.
When grounds for the divorce is indignities or irretrievable breakdown of the
marriage, you may request marriage counseling. A list of marriage counselors is
aVl\iIable in the office of the Prothonotary at Cumberland County Courthouse, Carlisle,
PA 17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DMSION 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 TIllS 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, Pa 17013
717-249-3166
MARK, WEIGLE AND PERKINS - ATTORNEYS AT LAW - 126 EAST KING STREET _ SHIPPENSBURG, PA 17257-1397
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
PENNSYLVANIA
CHRISTINA M. SHORT,
Plaintiff,
CIVIL ACTION - LAW
vs.
NO. 02,&'00 - / I <r'1 C;;J f..v-
CHRISTOPHER L. SHORT,
Defendant.
IN DIVORCE
COMPLAINT IN DIVORCE
COUNT I-nrnffiTRffiVABLE BREAKDOWN
AND NOW, comes the above named Plaintiff, Christina M. Short, by and through
her attorneys, Weigle, Perkins and Associates, and Jerry A. Weigle, Esquire, and seeks
to obtain a Decree in Divorce from the above-named Defendant, upon the grounds
hereinafter more fully set forth:
1. Plaintift Christina M. Short, is an adult individual presently residing at 35
Rolo Court, Mechanicsburg, Cumberland County, Pennsylvania, since
October, 1999.
2. Defendant, Christopher L. Short, is an adult individual presently residing
at, 105 Wolf Street, Highspire, Dauphin County, Pennsylvania, since
January, 1995.
3. The Plaintiff and Defendant are nationals and citizens of the United States
of America, and both have been bona fide residents of the Commonwealth
of Pennsylvania for at least six (6) months immediately previous to the
fJling of the Complaint in Divorce.
4. The Plaintiff and Defendant were married on January 28, 1995, in
Linglestown Church of God, Linglestown, Dauphin County, Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the
parties or in any other jurisdiction.
6. Plaintiff has been advised that counseling is available and the Plaintiff
may have the right to request that the court require the parties to
participate in counseling.
7. The'marriage is irretrievably broken.
8. The parties have lived separate and apart since October 22,1999.
9. The Plaintiff requests the court to enter a decree of divorce.
MARK, WEIGLE AND PERKINS - ATTORNEYS AT LAW - 126 EAST KING STREET _ SHIPPENSBURG, PA 17257-1397
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COUNT n - INDIGNITIES GROUNDS FOR DIVORCE
10. Paragraphs I through 9 of this Complaint are incorporated herein by
reference as though set forth in full.
11. Defendant has offered to the person of the Plaintiff, Plaintiff being the
innocent and injured spouse, such indignities as to render Plaintiff's
condition intolerable and Plaintiff's life burdensome.
COUNT ill - EQUITABLE DISTRIBUTION
12. Paragraphs 1 through 9 of this Complaint are incorporated herein by
reference as though set forth in full.
13. Plaintiff and Defendant have legally and beneficially acquired property,
both real and persona~ during their marriage from January 28, 1995 until
October 22, 1999, the date 'of separation, all of which property is "marital
property".
14. Plaintiff andlor Defendant have acquired, prior to the marriage or
subsequent thereto, "non-marital property" which has increased in value
since the date of the marriage and or subsequent to its acquisition during
the marriage, which increase in value as marital property.
l5. Plaintiff and Defendant have been able to agree as to an equitable division
of said property to the date of the filing of this Complaint.
16. Plaintiff requests the Court to equitably divide all marital property.
WHEREFORE, the Plaintiff prays your Honorable Court to enter a Decree in
Divorce from the bonds of matrimony and for such other and further relief to which
Plaintiff shall be entitled.
By:
OLE, PERKINS AND ASSOCIAT S
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VERIFICATION
I verify that the statements made in the foregoing Complaint in Divorw are true
and correct. I understand that mise statements herein are made subject to the penalties of
18 Pa C.S. ~ 4904, relating to unsworn falsification to authorities.
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. ina M. Short, Plaintiff
Dated:
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MARK, WEIGl-E AND PERKINS - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG. PA 17257-1397
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CHRISTINA M. SHORT,
Plaintiff,
CIVIL ACTION - LAW
VS.
NO. 2000-1147 CIVIL
CHRISTOPHER L. SHORT,
Defendant.
.
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A complaint in divorce under g 3301(c) of the Divorce Code was filed on
February 29, 2000.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days
have elapsed from the date of 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. g 4904 relating to
unsworn falsification to authorities.
Dated:
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stina M. Short, Plaintiff .
WEIGLE, PERKINS & ASSOCIATES - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CHRISTINA M. SHORT,
Plaintiff,
CIVIL ACTION - LAW
vs.
NO. 2000-1147 CIVIL
CHRISTOPHER L. SHORT,
Defendant.
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A
DIVORCE DECREE UNDER !l3301(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 I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by the
Court and that a copy of the decree will be sent to me immediately after it is fIled with the
prothonotary.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa. C.S. ~ 4904 relating to
unsworn falsification to authorities.
Dated:
L:./1l17/0lJ
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Zch1istina M. Short, Plaintiff
WEIGLE, PERKINS & ASSOCIATES - ATTORNEVS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257~1397
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYL VANIA
CHRISTINA M. SHORT,
Plaintiff,
CIVIL ACTION - LAW
vs.
NO. 2000-1147 CIVIL
CHRISTOPHER L. SHORT,
Defendant.
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A complaint in divorce under ~ 3301(c) of the Divorce Code was filed on
February 29, 2000.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days
have elapsed from the date of filing and service ofthe 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. ~ 4904 relating to
unsworn falsification to authorities.
Dated: /P,'/ 7 - () ()
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Christopher L. Short, Defendant
WEIGLE, PERKINS & ASSOCIATES - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257~1397
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CHRISTINA M. SHORT,
Plaintiff,
CIVIL ACTION - LAW
vs.
NO. 2000-1147 CIVIL
CHRISTOPHER L. SHORT,
Defendant.
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A
DIVORCE DECREE UNDER !l3301(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! do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by the
Court and that a copy of the decree will be sent to me immediately after it is filed with the
prothonotary.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa. C.S. ~ 4904 relating to
unsworn falsification to authorities.
Dated: &. o? 7 - aD
h '.r/~
Christopher L. Sh~ndant -
WEIGLE, PERKINS & ASSOCIATES ~ ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257~1397
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
PENNSYL VANIA
CHRISTINA M. SHORT,
Plaintiff,
CIVIL ACTION - LAW
vs.
NO. 2000-1147 CIVIL
CHRISTOPHER L. SHORT,
Defendant.
IN DIVORCE
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA
~
COUNTY OF CUMBERLAND
Rhonda Wolford, being duly sworn according to law, deposes and says that on
March 6, 2000, she served true and attested copies ofa Divorce Complaint upon the
Defendant, Christopher L. Short, by mailing the same postage paid, certified mail,
addressee only, and return receipt requested, at Shippensburg, Pennsylvania, addressed as
follows:
Christopher L. Short
105 Wolf Street
Highspire, P A 17034
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Rhonda Wolford
Sworn to and subscribed before
me this 20th day of March, 2000.
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Notary Public
Notarial Seal
David P. Perkins, Notary Public
Shippensburg Bcro, Cumberland County
My Commission Expires Oct. 28, 2001
Member, Pennsylvania Association of Notaries
MARK, WEIGLE AND PERKINS - ATTORNEYS AT LAW _ 126 EAST KING STREET _ SHIPPENSBURG, PA 17257-1397
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
PENNSYLVANIA
CHRISTINA M. SHORT,
Plaintiff,
VS.
CHRISTOPHER L. SHORT,
Defendant.
CIVIL ACTION - LAW
NO.
200-1147 CIVIL
IN DIVORCE
PROOF OF SERVICE
Is your RI;1;URN ADDRESS completed on the reverse side?
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