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~ and. . .. . .KATHLEEN. .J.. EISEMANN. . . . .. . . . . . . . ., . . . . .... . . . " defendant, ~
~ are divorced from the bonds of matrimony. ~
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~ The court retains jurisdiction of the following claims which have ~
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ANDREW R. EISEMANN
.. IN THE COURT OF COMMON PLEAS OF
.. CUMBERLAND COUNTY, PENNSYLVANIA
.. NO. 00-1743 CIVIL TERM
v.
KATHLEEN J. EISEMANN
IN DIVORCE
OUALIFIED DOMESTIC RELATIONS ORDER
WHEREAS, Kathleen J. Eisemann, (hereinafter referred to as "Spouse"), and
Andrew R. Eisemann, (hereinafter referred to as "Participant"), have entered into a
comprehensive Stipulation and Agreement ("Agreement") dated the lOth day of August,
2000; and
WHEREAS, as part of the settlement agreement Participant agrees that the
Spouse shall receive a portion of his United States Army Pension that was earned during
the parties' marriage; and
WHEREAS, counsel for Participant and counsel for Spouse have acknowledged
that this Qualified Domestic Relations Order is being made pursuant to the Domestic
Relations Code of the Commonwealth of Pennsylvania and the Pennsylvania Rules of
Civil Procedure as they relate to the provisions being made by the Spouse relating to her
marital property rights; and
WHEREAS, it is intended that this Order will qualify as a Qualified Domestic
Relations Order, as defined in Section 414(P)(1) of the Internal Revenue Code of 1986
and the provisions hereof shall be administered and interpreted in conformity with the
Code.
Pursuant to Section 414(P)(2) of the Code, the following facts are hereby
specified:
1. The Act to which this Order applies is the Uniform Services Former Spouse
Protection Act of September 8, 1982.
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2. The name of the Service member (Participant) is Andrew R. Eisemann, whose
eurrent mailing address is 305 West Willow Street, Apt. 101, Carlisle, Cumberland
County, Pennsylvania, 17013, and whose social security nwnber is 061-62-7085.
3. The name and address of the alternate payee (Spouse) is Kathleen J. Eisemann,
whose current mailing address is 323 South Pitt Street, Carlisle, Cwnberland County,
Pennsylvania, 17013, and whose social security nwnber is 00<;<- -71J - '77$/0.
4. Military RetiredlRetainer Pay. Spouse shall be awarded 50% of Participant's
military base pay retirement as of September 1,2000 payable on Participant attaining 60
years of age. Said award shall be in accordance with and construed by the Uniform
Services Former Spouse Protection Act of September 8, 1982 (Public Law 97-252) and
10 U.S.C. Section 1401 et seq. Spouse's monthly amount shall be 50% of Participant's
military base pay retirement as of September I, 2000 and shall be paid from Disposable
Military RetiredlRetainer Pay when Participant attains the age of 60 years.
Disposable Military RetiredlRetainer pay as used herein means Retiree's gross
Military RetiredlRetainerpay less only those amounts deducted for the Survivor Benefit
Plan premium, if any for Spouse, or in lieu of Retiree's Military Retirement benefits, or
VA Waiver benefits. Spouse shall receive a pro-rata share of any costs of living
increases or similar increases that. occur. The sharing of Disposable Military
RetiredlRetainer pay shall commence upon Participant attaining 60 years of age on
September 29, 2022, with dishursement made by the Defense Finance and Accounting
Service following receipt of a certified copy of this Order, executed by the parties and the
Court of appropriate jurisdiction.
Under the terms of the Uniform Services Former Spouse Protection Act, the
United States Army, as the paying authority, is required to directly pay Spouse her
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monthly share of Participant's monthly disposable Military Retired/Retainer pay because
of the following: In the parties' marriage, Participant formed at least ten years of credible
service for determining his eligibility for RetiredlRetainer pay. The parties were married
on October 9, 1984, and were separated on February 27, 2000. The parties' divorce is
pending and shall be concluded contemporaneously with the processing of the Qualified
Domestic Relations Order.
Each party shall be responsible for any and all tax consequences resulting from
their receipt of benefits pursuant to this Order
Neither Participant nor Spouse will do or cause to be done any act which will
cause this provision to become null and void, and each party agrees that this will be the
final Order pertaining to the division of the Participant's Disposable Military
RetiredlRetainer pay.
Participant and Spouse agree that the Participant's Military RetiredlRetainer pay
was accrued as a result of his service, both active and reserve, in the United States Army
and that the Military RetiredlRetainer pay is marital property subject to equitable
distribution by the Court of Common Pleas of Cumberland County,. Commonwealth of
PelIDsylvania. Participant and Spouse further agree that the Court of Common Pleas of
Cumberland County, Commonwealth of Pennsylvania, is competent to divide the parties'
marital property incident to their divorce pursuant to Section 3:301 (c) of the Domestic
Relations Code. Participant and Spouse, finally, agree that the Court of Common Pleas
of Cumberland County, Commonwealth of Pennsylvania, has jurisdiction over the
Participant for the purpose of dividing his disposable Military RetiredlRetainer pay
because Participant specifically consents to the Court's jurisdiction to divide his
disposable Military Retired/Retainer pay.
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Participant acknowledges and agrees that he has been afforded his rights under the
Soldiers and Sailors Civil Relief Act of 1940 (50 U.S.S. appencIix 501-591).
The Court shaIl retain jurisdiction over Retiree's Military RetiredlRetainer pay for
as long as the parties both shaIl live. The Court shall also have the authority to make
every just and equitable Order not inconsistent with the other provisions hereof.
The Court shaIl also have continuing jurisdiction to make every Order reasonably
necessary to implement and accomplish the direct payment to the Spouse by the United
States Army of her share of Retiree's disposable Military RetfredlRetainer pay, including
the right to advise the United States Army of the precise amount of Retiree's disposable
military Retired/Retainer pay to be payable to the Spouse.
Dated: r:lvct OJ).. ~q) -wtD
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The parties hereby acknowledge their receipt, review and approval of the within
Qualified Domestic Relations Order and, further, request the Court of Common Pleas of
Cumberland County enter this Order upon receipt and
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Kath een J. Ei~mann
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MARRIAGE SETTLEMENT AGREEMENT
THIS AGREEMENT made this /t'fl day of t2ug., 2000, by and between
ANDREW R. EISEMANN (hereinafter referred to as "Husband") and KATHLEEN J.
EISEMANN (hereinafter referred to as "Wife").
WITNESSETH:
WHEREAS, the parties hereto are Husband and Wife, having been married
October 9, 1984, in Oklahoma; and
WHEREAS, there has been one child born of this marriage, to wit: Alyssa K.
Eisemann; and
WHEREAS, diverse, unhappy differences, disputes, misunderstandings and
difficulties have arisen between the parties as a result of which they intend to live
separate and apart; and
WHEREAS, the parties desire to confirm their separation and make arrangements
in connection therewith, including the settling of their property rights and other rights
and obligations growing out of their marriage; and
WHEREAS, it is the desire of the parties to effect a complete and full settlement
with respect to any and all claims, obligations, rights, duties and responsibilities of the
parties with respect to the marriage, including but not limited to financial and property
rights and obligations between each other, in accordance with the provisions of the
Divorce Code.
NOW THEREFORE, corisidering the above conditions and circumstances, and in
consideration of the covenants and promises hereinafter to be mutually kept and
performed by each party, as well as for other good and valuable consideration, and
intending to be legally bound hereby, it is agreed as follows:
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1.
It shall be lawful for each party at all times hereafter to live separate and apart
from the other party at such place or places as he or she from time to time may choose
or deem fit.
2.
Each party shall be free from interference, authority and control, direct or
indirect, by the other as fully as if he or she were single and unmarried. Neither shall
molest the other or compel or endeavor to compel the other to cohabitate or dwell with
him or her.
3.
The parties have divided between them to their mutual satisfaction the personal
effects, household furniture and furnishings, and all other articles of personal property
which have heretofore been used by them in common.
4.
The parties have agreed to disposition of financial assets as follows;
A. To Wife;
1998 Saturn lease
50% of military base pay retirement, as of date of divorce, payable
to wife at Husband's reachi~ng 60 years of age
IRA Vanguard Morgan Growth Fund in the amount of $31 ,000
T. Rowe Price Account in the amount of $10,000 ~
US Savings Bonds in the amount 0[$30,000
Berger Growth Fund in the amount of$12,000
CGM Mutual Fund in the amount of $6,000
Kaufman Fund in the amount of$6,500
Vanguard Money Market account in the amount of $1,400
Algiers Money Market account in the amount of$I,OOO
1999 Income tax refund in the amount of$I,OOO
Daughter's Trust at Legg Mason, Wife custodian, in the amount of
$17,000
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B. To Husband:
2000_Plymouth lease - value of $16,200
IRA Janus Twenty Fund in the amount of $43,000
Franklin Mutual Series in the amount of$12,000
C. Wife will pay the current credit card debt of $1,000
D. Husband will pay moving expenses
E. Husband will name their daughter Alyssa as beneficiary of 50% on his
SGLI Serviceman Group Life Insurance policy at least until she is 18 years of age
F. The parties shall have joint legal custody of Alyssa. The parties shall
have joint physical custody of Alyssa. Alyssa will live with her mother. Father and
Mother will agree to a schedule so that father has frequent and substantial time with
Alyssa to include after school, soccer practice and games, alternate weekends, sharing
holidays and school vacations as the parents work schedule permits.
G. FathershaU pay support in the amount of $300 a month which shaU be
made by direct deposit into ~othcr's checking account During summer months Father
will also pay Alyssa's summer camp expenses. The amount of support will increase to
$500 as agreed upon when Father has graduated from Law School and passed the Bar
Examination.
5.
Wife relinquishes her inchoate intestate right in the estate of Husband, and
Husband relinquishes his inchoate intestate right in the estate of Wife, and each of the
parties hereto, by these presents for himself or herself, his or her heirs, executors,
administrators or assigns, does remise, release, quit-claim and forever discharge the other
party hereto, his or her heirs, .executors, administrators or assigns, or any of them, of any
and aU claims, demands, damages, actions, cause of action, or suite at law or in equity of
whatsoever kind of nature, for or because ofa matter or thing done, omitted or suffered
to be done by said party prior to and including the date hereof, except that this release
shaU in no way affect any cause of action in any absolute divorce which either party may
have against the other of whatever nature, arising or which may arise, under this
Agreement or for the breach of any provision thereof.
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6.
Nothing contained in this Agreement shall be deemed to prevent either of the
parties from maintaining a suit for absolute divorce against each other in any jurisdiction
based upon any of the grounds for divorce specified in 23 Pa. C.S.A. #3301 of the
Pennsylvania Divorce Code. In the event any such action is pursued or initiated, the
parties shall be bound by all the terms of this Agreement.
7.
The parties have attempted to distribute their marital property in a manner which
conforms to the criteria set forth in 23 Pa C.S.A. 3502 Pa. C.S.A. 3502 of the
Pennsylvania Divorce Code, and have taken into account all considerations set forth
therein. The division of property under this Agreement shall be in full satisfaction of all
marital rights and any other rights of the parties.
8.
Both parties relinquish and waive all right, title, claim or interest either may have
in the employee benefits of the other, including but not limited to stock options,
retirement plans and IRA's except as set forth in Pargaraph 4.
9.
Each of parties shall hereafter own and enjoy, independently of any claims or
rights of the other, all real property and all items of personal property, tangible or
intangible, acquired after the date of separation of the parties or hereafter acquired by
him or her, with full power in him or her to dispose of the same as fully and effectively,
in all respects and for all purposes, as though he or she were unmarried.
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10.
Except as specifically provided for herein, both parties specifically waive any and
all rights they may have at present or hereafter may have for spousal support and further
waive any and all rights they may have at present or hereafter may have, for alimony,
alimony pendente lite, or separate maintenance and support as provided in Section 501 of
the Divorce Code.
I!.
Each party shall be individually responsible for the payment of his or her own
respective attorney's fecs and costs, both for the negotiation and preparation of this
Agreement and also for any divorce action which may be filed.
12.
Except for any debt or obligation of either party to the other under this
Agreement, each party hereby agrees to save and hold the other harmless from all
personal debts and obligations incurred by him or her from the date hereof.
13.
Each party represents and warrants to the other that he or she has not incurred any
debt, obligation or other liability other than described in this Agreement on which the
other party is or may be liable. Each party covenants and agrees that if any claim, action
or proceeding is hereinafter instituted seeking to hold the other party liable for any other
debts, obligations, liability, act or omission of such party, such party will, at his or her
sole expense, defend the other against any such claim or demand, whether or not well-
founded, and that he or she will indemnify and hold harmless the other party in respect to
all damages resulting therefrom. Each party hereby releases the other from all claims,
liabilities, debts, obligations, actions and causes of action of every kind that have been or
will be incurred relating to or arising from the marriage between the parties. However,
neither party is relieved or discharged from any obligations under this Agreement, or
under any instrument or document executed pursuant to this Agreement.
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14.
Neither party shall contract any debt or liability for which the other party or his or
her property or estate might be responsible, and shall indemnify and save the other
harmless from any and all claims and demands made against him or her by reason of the
debts or obligations incurred by the other party.
15.
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 such
other remedies or relief as may be available to him or her, and the party breaching this
contract shall be responsible for payment of reasonable fees and costs incurred by the
other in enforcing his or her rights under this Agreement.
16.
Each party acknowledges that hc or she has received independent legal advice
from counsel of his or her selection, and each fully understands the facts and has been
fully informed as to his or her legal rights and obligations, and each party acknowledges
and accepts that this Agreement is, under the circumstances, fair and equitable, and that it
is being entered into freely and voluntarily having received sU9h advice and with such
knowledge, and that the execution of this Agreement is not the result of any duress or
undue influence, and that it is not the result of any collusion or improper or illegal
agreements.
17.
Each of the parties shall, from time to time, at the request of the other, execute,
acknowledge and deliver to the other party any and all further instruments which may be
reasonably required to give full force and effect to the provisions of this Agreement.
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18.
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. Husband and Wife acknowledge and agree that the provisions of this
Agreement with respect to the distribution and division of marital and separate property
are fair, equitable and satisfactory to them based on the length of their marriage and other
relevant factors which have been taken into consideration by the parties. Both parties
hereby accept the provisions of this Agreement with respect to the division of property in
lieu of and in full and final settlement and satisfaction of all claims and demands that
they may now have or hereafter may have against the other for equitable distribution of
their property by any court of competent jurisdiction pursuant to Section 330l(d) of the
Divorce Code or any other laws. Husband and Wife each voluntarily and intelligently
waive and relinquish any right to seek a court-ordered determination and distribution of
marital property, but nothing herein contained shall constitute a waiver by either party of
any rights to seek relief of any court for the purpose of enforcing the provisions of this
Agreement.
19.
It is understood and agreed by the parties hereto that Husband has filed an action
in divorce in the Court of Common Pleas of Cumberland County in which he has alleged
or will allege that the marriage is irretrievably broken under Section 330l(c) of the
Divorce Code. Both parties further understand and agree that said divorce on said
grounds shall be pursued and that both parties will file the necessary Affidavits of
Consent and all other petitions and documents necessary to effectuate the divorce.
20.
A moditication or waiver of any of the provisions of this Agreement shall be
effective only if made in writing and executed with the same formality as this
Agreement. The failure of either party to insist upon the strict performance of any of the
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provisions of this Agreement shall not be construed~ as a waiver of any subsequent default
of the same or similar nature.
21.
This Agreement shalr be construed under the laws of the Commonwealth of
Pennsylvania.
22.
If any term, condition or 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 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.
This Agreement shall be binding and shall inure to the benefit of the parties
hereto and to their respective heirs, executors, administrators, successors and assigns.
IN WITNESS WHEREOF, the parties hereto, intending to be legally bound
hereby, have hereunto set their hands and seals the day and year first above written.
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Kathleen J. Eise a
WITNESS:
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ANDREW R. EISEMANN
v.
.. IN THE COURT OF COMMON PLEAS OF
.. CUMBERLAND COUNTY, PENNSYLVANIA
.. NO. 00-1743 CIVIL TERM
KATHLEEN J. EISEMANN
IN DIVORCE
PRAECIPE TO TRANSMIT RECOJID
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 Section (3301(c) )
(3301(d)) of the Divorce Code. (Strike out inapplicable section.)
2. Date and manner of service of the complaint:
Personal servIce on June 23, 2000
3. (Complete either paragraph (a) or (b).)
(a) Date of execution of the affidavit of consent required by Section
3301(c) of the Divorce Code: by plaintiff 8/10/00 : by defendant
8/3/00
(b) (1) Date of execution of the plaintiffs affidavit required by Section
3301(d) of the Divorce Code: ; (2) Date of service of the
plaintiff's affidavit upon the defendant:
4. Related claims pending:
None
5. Date and manner of service of the notice of intention to file praecipe to
transmit record, a copy of which is attached, if the decree is to be entered under Section
3301(d) ofthe Divorce Code:
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Frances H. Del Duca, Esquire
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ANDREW R. EISEMANN
.. IN THE COURT OF COMMON PLEAS OF
:: CUMBERLAND COUNTY, PENNSYLVANIA
:: NO. t:f:).I7l{J CIVIL TERM
v.
KATHLEEN J. EISEMANN
IN DIVORCE
NOTICE TO DEFpNQa~D <;::J,.AIM RIGHTS
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims
set forth in the following pages, you must take prompt action. You are warned that if you
fail to do so, the case may proceed without you and a decree of divorce or annulment
may be entered against you 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 ofthe Prothonotary at the
CUMBERLAND COUNTY COURTHOUSE. 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 HA VB 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 A VENUE
CARLISLE, P A 17013
717-249-3166
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Frances H. Del Duca
10 West High S1.
Carlisle, PA 17013
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ANDREW R. EISEMANN
.. IN THE COURT OF COMMON PLEAS OF
.. CUMBERLAND COUNTY, PENNSYLVANIA
.. NO. frIJ -17'13 CIVIL TERM
v.
KATHLEEN J. EISEMANN
IN DIVORCE
COMPLAINT UND~R,SECTION 330HC) OF THE DIVORCE CODE
I. Plaintiff is Andrew R. Eisemann, who resides at 305 West Willow Street, Apt.
101, Carlisle, Cumberland County, Pennsylvania, 17013.
2. Defendant is Kathleen J. Eisemann, who resides at 323 South Pitt Street,
Carlisle, Cumberland County, Pennsylvania, 17013.
3. Plaintiff and defendant have been bona fide residents in the Commonwealth of
Pennsylvania for at least six (6) months immediately previous to the filing of this
complaint.
4. The plaintiff and defendant were married October 9, 1984, in Oklahoma.
5. There have been no prior actions of divorce or for annulment between the
parties.
6. Plaintiff avers that the grounds on which the action is based is that the
marriage is irretrievably broken.
WHEREFORE, the plaintiff requests the Court to enter a decree in divorce.
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rances H. Del't>uca, Esq.
Attorney for Plaintiff
March 21,2000
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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 10 Pa.C.S.
Sec. 4904 relating to unsworn falsification to authorities.
Dated: 6/.5</ / dJ
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ANDREW R EISEMANN
v.
.. IN THE COURT OF COMMON PLEAS OF
.. CUMBERLAND COUNTY, PENNSYLVANIA
.. NO. 00-1743 CIVIL TERM
KATHLEEN J. EISEMANN
'IN DIVORCE
AFFIDAVIT OF CONSENT
1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed March
22,2000.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have
elapsed from the date of filing the complaint.
3. I consent to the entry of a final decree of divorce.
4. I have been advised of the availability of marriage counseling, that I may request that
the Court require that my spouse and I participate in counseling, and that the Court maintains a
list Of marriage counselors in the Prothonotary's Office, which list is available to me upon
request. Being so advised, I decline to request that the Court require that my spouse and I
participate in counseling.
5. I understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses if! do not ciaim them before a divorce is granted.
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 19 Pa.C.S. Sec. 4904 relating to
unsworn falsification to authorities.
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:: IN THE COURT OF COMMON PLEAS OF
:: CUMBERLAND COUNTY, PENNSYL VANIA
:: NO. 00-1743 CIVIL TERM
ANDREW R. EISEMANN
-KATHLEEN J. EISEMANN
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed March
22, 2000.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have
elapsed from the date of filing the complaint.
3. I consent to the. entry of a final decree of divorce.
4. I have been advised of the availability of marriage counseling, that I may request that
the Court require that my spouse and I participate in counseling, and that the Court maintains a
list Of marriage counselors in the Prothonotary's .Office, which list is available to me upon
request. Being so advised, I decline to request that the Court require that my spouse and I
participate in counseling.
5. 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.
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 19 Pa.C.S. Sec. 4904 relating to
unsworn falsification to authorities.
Dated: 8'/3Jcr::,
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Kathlelrl'J. Eisemann
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ANDREW R. EISEMANN
v.
.. IN THE COURT OF COMMON PLEAS OF
.. CUMBERLAND COUNTY, PENNSYLVANIA
.. NO. 00-1743 CIVIL TERM
KATHLEEN J. EISEMANN
IN DIVORCE
WAIVER OF-NOTICE OF INTENTION TO REOUEST
ENTRY OF A DIVORCE DECREE UNDlj:R .
SECTlOj.'l ~;301( c ) OF THE DIVORCE CODE
1. I consent to the entry of a final decree without notice.
2. 1 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 subjectto the penalties of 18 Pa.C.S.
Sec. 4904 relating to unsworn falsification to authorities.
Dated: 1/10/ tf[)
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:: IN THE COURT OF COMMON PLEAS OF
:: CUMBERLAND COUNTY, PENNSYLVANIA
:: NO. 00-1743 CIVIL TERM
ANDREW R. EISEMANN
KATHLEEN J. EISEMANN
IN DIVORCE
WAIVER OF NOTICE OF INTeNTION TO REOUEST
ENTRY OF A DIVORCEJ)ECREE UNDER
SECTION 33j}1( c) OF THE DlVORCECODE
1. I consent to the entry of a fmal decree 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.
Sec. 4904 relating to unsworn falsification to authorities.
Dated: ~/3/00
7f'l ~o _ tl3.~ >
Kathleen UEisemann
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ANDREW R. EISEMANN
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;; IN THE COURT OF COMMON PLEAS OF
;; CUMBERLAND COUNTY, PENNSYLVANIA
;; NO. 00-17</.3 CIVIL TERM
KATHLEEN J. EISEMANN
IN DIVORCE
ACCEPTANCE OF SERVICE
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AND NOW, this ~"-lIay of~-eh; 2000, I hereby acknowledge receiving_a
copy of the Complaint in Divorce filed to the above term and number.
.-;rCttf. 0,... ~ ~(J ~'-- ~
Kathleen J. El mann ~.
SUBSCRIBED and sworn to ~
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me this 013 day of , 2000.
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NOTARIAL SEAL
JUDITH ANN VALENTINE, Notary PublIc
Carlisle, Cumberllllld County
My CommiSSion ExpIres Nov. 12, 200;
....J
JUDITH AN:~8EAl
^ CartIslII ~~PItlIi:
My Commlsiton ElqJ/ras N~ 2002
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ANDREW R. EISEMANN
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:: IN THE COURT OF COMMON PLEAS OF
:: COMB ERLAND COUNTY, PENNSYLVANIA
:: NO. 00-1743 CIVIL TERM
KATHLEEN J. EISEMANN
IN DIVORCE
EOUITABLE DISTRIBUTION OF MARITAL PROPERTY
COUNT II
7. Paragraphs 1 through 6 ofthe complaint filed March 22, 2000 are incorporated
by reference herein.
8. Plaintiff and defendant are the owners of various items of personal property
including a U. S. Army Pension, U.S. Savings Bonds, Mutual Funds, and Money Market
Accounts acquired during the marriage which are subject to equitable distribution by this
Court.
WHEREFORE, plaintiff requests the court to enter a decree equitably distributing
all property owned by the parties.
Respectfully submitted,
d~A'-/~ &:~~
ance H. Del Duca, sq.
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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 10 Pa.C.S.
Sec. 4904 relating to unsworn falsification to authorities.
Dated: g~:v-- ~
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isemann
I hereby consent to the addition of Count II for Equitable Distribution of Marital
Property in the divorce action filed to 00-1743 in which I am the named defendant.
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Yn.l....kOIL C\~
Kathleen lsemann
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