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IN THE COURT OF COMMON PLEAS
OF
CUMBERLAND
COUNTY
STATE OF
PENNA.
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Plaintiff
No. uuo.o.::-,1.7.9..1uu,
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DIANNE E. REESE,
Versus
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Defendant
DECREE IN
D I V 0 R C E 'n A,~.
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. . . . , . , . , . . . . . , . . . . . . . , . . . . , ,~!~. . , " it is ordered and
AND NOW,
decreed that... .. .. ~~. -:':, ~~~.. .. .. . ..... .. .. .. .. .. .. .. ", plaintiff,
DIANNE E. REESE
and. . , . , . , , , , . . . . , . . . . . . . . . , . . . . . , . . , . . , , . . . . . . . . . . . . . . , . , . " defendant,
are divorced from the bonds of matrimony.
The court retains jurisdiction of the following claims which have
been raised of record in this action for which a final order has not yet
been entered;
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CHRIS A. REESE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO . 00 - 1791
DIANNE E. REESE,
Defendant
CIVIL ACTION - IN DIVORCE
o R D E R
AND NOW, this
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, 2000, upon
consideration of the foregoing motion, the Custody Agreement for Minor
Children between the parties dated October 24, 2000, and attached
hereto is hereby incorporated into the above captioned action and made
an Order of Court.
BY THE
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CHRIS A. REESE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO . 00 - 1791
DIANNE E. REESE,
Defendant
CIVIL ACTION
IN DIVORCE
MOTION TO MAKE CUSTODY AGREEMENT
AN ORDER OF COURT
CHRIS A. REESE, plaintiff in the above action, by and through his
attorneys, STONE LaFAVER & SHEKLETSKI, moves that your Honorable Court
make the attached Custody Agreement for Minor Children dated October
24, 2000, in the above captioned action as an Order of Court.
STONE LaFAVER & SHEKLETSKI
By
Attar
for Plaintiff
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CUSTODY AGREEMENT FOR MINOR CHILDREN
THIS AGREEMENT, made this ~1f1.., day of
8clrIber
, 2000,
by and between DIANNE E. REESE, of Cumberland County, Pennsylvania,
(hereinafter referred to as "Mother") and CHRIS A. REESE, of
Cumberland County, Pennsylvania, (hereinafter referred to as
"Father") .
WIT N E SSE T H:
WHEREAS, Mother and Father have two children, AMANDA R. REESE,
born September 6, 1987, and HEATHER L. REESE, born August 6, 1991; and
WHEREAS, Mother and Father are parties to a divorce proceeding
filed in the Court of Common Pleas of Cumberland County Pennsylvania
to Docket No. 2000 - 1791 Civil Term; and
WHEREAS, the parties hereto have mutually agreed to enter into an
agreement for the custody and visitation of AMANDA R. REESE and
HEATHER L. REESE, and the parties now wish to have that agreement
reduced to writing.
NOW, THEREFORE, the parties hereto, in consideration of the
mutually made and to be kept promises set forth herein and for other
good and valuable consideration, intending to be legally bound and to
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legally bind their heirs, successors, assigns, and personal represen-
tatives, hereby covenant, promise, and agree as follows:
1. CUSTODY. The parties shall share legal custody of AMANDA R.
REESE and HEATHER L. REESE. They shall consult with each other
relative to all important decisions concerning the minor children,
including but not limited to such matters as health, education,
activities, and religion. The parties further agree that each shall
have equal access to information concerning the children. Except as
provided herein, Mother shall have primary physical custody of AMANDA
R. REESE and HEATHER L. REESE subject to Father's right to partial
physical custody of AMANDA R. REESE and HEATHER L. REESE as follows:
A. WEEKENDS. Father shall have partial physical custody of
the children on alternating weekends from after school on Friday to
7:00 P.M. on Sunday.
B. WEEKDAYS. Father shall have partial physical custody of
the children every Thursday from 5:00 P.M. to 8:00 P.M.
C. SUMMER. During the summer months of every year, Father
shall have partial physical custody of the minor children for two 2-
week intervals from Friday at 6:00 P.M. to Sunday at 6:00 P.M., which
shall be in addition to the periods of partial physical custody
otherwise set forth herein. Father shall give Mother notice of the two
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each year.
D. HOLIDAYS. Father shall have partial physical custody of
the minor children for the Thanksgiving holiday, from 9:00 A.M. to
7:00 P.M. on Thanksgiving Day in the year 2000 and in every even
numbered year thereafter. Father shall have partial physical custody
of the children for the Christmas holiday from December 24th at 5:00
P.M. to December 25th at 12 Noon commencing in 2001, and in every odd
numbered year thereafter. Father shall have partial physical custody
of the children for the Christmas holiday from December 25th at 12
Noon to December 26th at 12 Noon commencing in 2000, and in every even
numbered year thereafter. Father shall have partial physical custody
of the children on Easter Sunday and the 4th of July from 9:00 A.M. to
8:00 P.M. commencing in 2001, and in every odd numbered year there-
after. Father shall have partial physical custody of the children on
Memorial Day and Labor Day from 9:00 A.M. to 8:00 P.M. commencing in
2002, and in every even numbered year thereafter.
E. TRANSPORTATION. Mother and Father shall share
transportation responsibilities under this agreement with the parent
who is receiving custody picking up the children.
If Father cannot,
for any reason, exercise his right of visitation he shall notify
Mother at least 24 hours in advance of the scheduled visitation.
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2. MISCELLANEOUS.
A. No waiver or modification of any of the terms of this
agreement shall 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. This agreement may be modified by court order.
B. This agreement shall be construed in accordance with the
laws of the Commonwealth of Pennsylvania which are in effect as of the
date of the execution of this agreement. Moreover, the parties hereby
agree that the provisions of this agreement shall be entered as a
custody order in the Court of Common Pleas of Cumberland County,
Pennsylvania, or in such other appropriate court.
C. This agreement constitutes the entire understanding of
the parties regarding custody and supersedes any and all prior agree-
ments and negotiations between them. There are no representations or
warranties regarding custody other than those expressly set forth
herein.
D. If any term, condition, clause, section, or provision of
this agreement shall be determined or declared to be void or invalid
in law by a court of competent jurisdiction, only that term,
condition, clause, section, or provision shall be stricken from this
agreement, and in all other respects, this agreement shall be valid
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and continue in full force, effect, and operation. Likewise, the
failure of any party to meet his or her obligations under anyone or
more of the articles and sections herein shall in no way void or alter
the remaining obligations of the parties.
E. In the event there is a conflict between the weekend and
holiday schedules, the holiday schedule shall take precedence and be
the binding schedule.
F. Both Mother and Father shall refrain from making
derogatory comments about the other party in the presence of the minor
children. Neither Mother nor Father shall use drugs while the minor
children are with them. Both Father and Mother shall abstain from
excessive use of alcohol while the minor children are with them.
G. This agreement shall forever be binding upon the
parties; and any independent action may be brought, either at law or
in equity, to enforce the terms of this agreement by either Father or
Mother until it shall have been fully satisfied and performed. The
consideration for this agreement is the mutual benefits to be obtain
by both of the parties hereto in the covenants and agreements of each
of the parties to the other. The adequacy of the consideration for
all agreements herein contained is stipulated, confessed, and admitted
by the parties and the parties intend to be legally bound hereby.
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IN WITNESS WHEREOF, Mother and Father have set their hands and
seals the day and year first above written.
1) 1lAI\J; t:.R 2 ~ M<.,
DIAN~E. REESE, Mother
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CHRIS A. REESE, Father
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CHRIS A. REESE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO . 00 - 1791
DIANNE E. REESE,
Defendant
CIVIL ACTION
IN DIVORCE
MOTION TO INCORPORATE AGREEMENT
INTO DECREE IN DIVORCE
CHRIS A. REESE, plaintiff in the above action, by his attorneys,
STONE LaFAVER & SHEKLETSKI, moves that your Honorable Court incorpo-
rate the attached agreement dated October 24, 2000, into the Decree in
Divorce.
STONE LaFAVER & SHEKLETSKI
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CHRIS A. REESE,
Plaintiff
v.
DIANNE E. REESE,
Defendant
AND NOW, this
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Y day of
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00 - 1791
CIVIL ACTION - DIVORCE
o R D E R
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, 2000, the
property settlement agreement between the parties dated October 24,
2000, and attached hereto is hereby incorporated into the Decree in
Divorce.
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CUfviBERLA,>jJ COUNTY
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AGREEMENT
THIS AGREEMENT, made this ;l<-//A. day of oc/f; ~
, 2000,
by and between DIANNE E. REESE, of Cumberland County, Pennsylvania,
(hereinafter referred to as "Wife"), and CHRIS A. REESE, of Cumberland
County, Pennsylvania, (hereinafter referred to as "Husband");
WIT N E SSE T H:
WHEREAS, Husband and Wife were lawfully married on June 28, 1986,
and
WHEREAS, two (2) children have been born of this marriage, AMANDA
R. REESE, born on September 6, 1987, and HEATHER L. REESE, born on
August 6, 1991; 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 for the rest of their natural
lives, and the parties hereto are desirous of settling fully and
finally their respective financial and property rights and obligations
as between each other including, without limitation by specification:
the settling of all matters between them relating to the ownership and
equitable distribution of real and personal property; the settling of
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all matters between them relating to the past, present and future
support, alimony and/or maintenance of Wife by Husband or of Husband
by Wife; and in general, the settling of any and all claims and
possible claims by one against the other or against their respective
estates.
NOW THEREFORE, in consideration of the premises and of the mutual
promises, covenants and undertakings hereinafter set forth and for
other good and valuable consideration, receipt of which is hereby
acknowledged by each of the parties hereto, Wife and Husband, each
intending to be legally bound hereby, covenant and agree as follows:
1. Disclosure of Assets. Each party asserts that he or she has
made a full and fair disclosure of all of the real and personal
property of any nature whatsoever belonging in any way to each of them
of all debts and encumbrances incurred in any manner whatsoever by
each of them, of all sources and amounts of income received or receiv-
able by each party, and of every other fact relating in any way to the
subject matter of this agreement. These disclosures are part of the
consideration made by each party for entering into this agreement.
2. Advice of Counsel. Each party has been represented by an
independent attorney, who was selected by the party whom he or she
represents, in the negotiation and preparation of this agreement.
Gerald J. Shekletski, Esquire, represented the Husband and Jane M.
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Alexander, Attorney at Law, represented the Wife. This agreement has
been fully explained to each party by that party's attorney. Each
party has carefully read this agreement and is completely aware, not
only of its contents, but also of its legal effect.
3. Lawfulness of Separation. It shall be lawful for each party
at all times hereafter to live separate and apart from the other party
at such place as he or she may from time to time choose or deem fit.
The foregoing provisions shall not be taken as an admission on the
part of either party of the lawfulness or unlawfulness of the causes
leading to their living apart.
4. Freedom from Interference. Each party shall be free from
interference, authority, and contact by the other, as fully as if he
or she were single and unmarried except as may be necessary to carry
out the provisions of this agreement. Neither party shall molest the
other or attempt to endeavor to molest the other, nor compel the other
to cohabit with the other, or in any way harass or malign the other,
nor in any way interfere with the peaceful existence, separate and
apart from the other.
5. Release of Claims. Wife and Husband each do hereby mutually
remise, release, quit-claim and forever discharge the other and the
estate of such other, for all time to come, and for all purposes
whatsoever, of and from any and all rights, titles and interests, or
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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 whatever nature and wheresoever situate, which she or
he 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 or curtesy, or claims in the nature of dower or curtesy
of 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, or any rights which Wife may have or
at any time hereafter have for past, present or future support or
maintenance, alimony, alimony pendente lite, counsel fees, costs or
expenses, whether arising as a result of the marital relation or
otherwise, 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 thereof.
It is the intention of
Wife and Husband to give to each other by the execution of this
agreement a full, complete and general release with respect to any and
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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 thereof,
subject, however, to the implementation and satisfaction of the
conditions precedent as set forth herein above.
6. Warranty as to Future Obliqations. Each party represents
that they have not contracted any debt or liability for the other for
which the estate of the other party may be responsible or liable, and
that except only for the rights arising out of this agreement, neither
party will hereafter incur any liability whatsoever for which the
other party or the estate of the other party, will be liable. Each
party agrees to indemnify or hold the other party harmless from and
against all future obligations of every kind incurred by them, includ-
ing those for necessities.
7. Assumption of Liabilities. This provision sets forth the
method for the payment and assumption of the debts and liabilities of
the parties. Since the assumption is not binding on the creditor, the
party assuming the debt agrees to indemnify the other party in the
event the creditor seeks to hold such other party liable. Should the
parties wish to bind the creditor and relieve the original debts from
all liability, a novation should be executed.
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a. Husband assumes and agrees to pay and hold the Wife
harmless against the following debts and obligations: Citibank Account
No. 4271382200373799.
If any claim, action or proceeding is hereafter
brought seeking to hold the Wife liable on account of such debts or
obligations, the Husband will, at his sole expense, defend the Wife
against any such claim, action or proceeding, whether or not well
founded, and Husband will indemnify and hold Wife harmless from and
against such claim, action or proceeding.
b. Wife assumes and agrees to pay and hold the Husband
harmless against the following debts and obligations: Discover Card
Account No.
and Master Card Account No.
The
aforesaid Master Card account has been paid in full and closed. If
any claim, action or proceeding is hereafter brought seeking to hold
the Husband liable on account of such debts or obligations, the Wife
will, at her sole expense, defend the Husband against any such claim,
action or proceeding, whether or not well founded, and Wife will
indemnify and hold Husband harmless from and against such claim,
action or proceeding.
8. Warranty as to Future Obliqations. Each party represents
that they have not contracted any debt or liability for the other for
which the estate of the other party may be responsible or liable, and
that except only for the rights arising out of this agreement, neither
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party will hereafter incur any liability whatsoever for which the
other party or the estate of the other party, will be liable. Each
party agrees to indemnify or hold the other party harmless from and
against all future obligations of every kind incurred by them,
including those for necessities.
9. Personal Property. Husband and Wife shall receive the
personal property listed under their respective names on Exhibit A
which is attached hereto and incorporated by reference herein. Wife
and Husband do hereby acknowledge that they have otherwise heretofore
divided the marital personal property including, but without
limitation, jewelry, clothes, furniture and other personalty 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 property in the possession of Wife shall be
the sole and separate property of Wife. Each of the parties does
hereby specifically waive, release, renounce and forever abandon
whatever claims, if any, she or he may have with respect to any of the
above items which are the sole and separate property of the other.
10. Cash. All cash presently in the possession of either party
shall be and remain their separate property, free and clear of any
claim whatsoever on the part of the other.
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11. Cash Payment by Husband. The Wife shall receive and the
Husband shall deliver or cause to be delivered to the Wife the sum of
Twenty Thousand and NO/l00 ($20,000.00) Dollars at such time as Wife
delivers to Husband a deed for the property known as 407 Market
Street, New Cumberland, Cumberland County, Pennsylvania, as provided
in paragraph 16 below.
12. Automobile to Husband. The Husband shall be the sole owner,
free and clear from any claim on the part of the Wife, of the 1999
Chevrolet Silverado pick-up truck.
13. Automobile to Wife. The Wife shall be the sole owner, free
and clear from any claim on the part of the Husband, of the 1991
Chevrolet Lumina. Husband shall deliver executed certificate of
title, sales and use tax form and any other documents necessary to
convey title within ten days of the execution of this agreement.
14. Pension/Retirement. Husband and Wife do hereby waive any
and all right, title and interest which they may have in the any and
all pension and/or retirement accounts of the other party.
15. Property Not Provided For. The parties hereto agree that
they have, by the terms of this agreement, settled, to their mutual
satisfaction, all rights that either may have in their property,
whether owned by them jointly or separately, real and personal, and
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wheresoever situated. Any property not specifically provided for in
this agreement, which the Husband or Wife owns or has the right to
control or possess, shall be and remain his or her property, free and
clear from any claim on the part of the other.
16. Real Estate. Wife hereby agrees to transfer and grant to
Husband all of her right, title and interest in the real estate
situate and located at 407 Market Street, New Cumberland, Cumberland
County, Pennsylvania, upon receipt from Husband of: 1) the Twenty
Thousand ($20,000.00) Dollar payment required under paragraph 11
above, and 2) evidence of Wife's full and complete release of all
liability under the mortgage loan currently affecting the property.
17. Payment of Attorney Fees. Each party of this agreement
hereby agrees that each of them will be solely responsible for the
full payment of all attorney's fees and other costs heretofore and
hereafter incurred, respectively, by each of them in connection with
the negotiation, preparation, and execution of this agreement, and in
connection with any action commenced by either party with respect to
the divorce of the parties. Each party further agrees hereby to
indemnify and hold the other party harmless from any demand, claim,
loss, cost and expense (including additional attorney's fees) arising
from a failure to pay all of the aforesaid attorney's fees and other
costs.
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18. Informed and Voluntary Execution. Each party to this
agreement acknowledges and declares that he or she, respectively:
A. Is fully and completely informed as to the facts
relating to the subject matter of this agreement and as to the rights
and liabilities of both parties.
B. Enters into this agreement voluntarily after receiving
the advice of independent counsel, free from fraud, undue influence,
coercion or duress of any kind.
c. Has given careful and mature thought to the making of
this agreement.
D. Has carefully read each provision of this agreement.
E. Fully and completely understands each provision of this
agreement.
19. Mutual Cooperation. The Husband and the Wife shall each
concurrently herewith, or at any time hereafter on the demand of the
other, execute any other documents or instruments, and do or cause to
be done any other acts and things as may be necessary or convenient to
carry out the intents and purposes of this agreement.
20. Severability. If any provision in this agreement is held by
a court of competent jurisdiction to be invalid, void, or
unenforceable, the remaining provisions shall nevertheless continue in
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full force and effect without being impaired in invalidated in any
way.
21. Reconciliation. If there should be a reconciliation of the
parties after the date of execution of this agreement, this agreement
shall nevertheless continue in full force until it is modified or
abrogated by another written instrument to that effect signed by each
of the parties hereto.
22. Future Earninqs. All income, earnings or other property
received or acquired by either party to this agreement on or after the
date of execution of this agreement shall be the sole and separate
property of the receiving or acquiring party. Each party, as of the
effective date of this agreement, does hereby and forever waive,
release and relinquish all right, title and interest in all such
income, earnings or other property so received or acquired by the
other.
23. Waiver of Riqhts. Each of the parties hereby irrevocably
waive all rights which he or she may have to request any court to
equitably distribute the marital property of the parties or to have
alimony, alimony pendente lite or counsel fees awarded to either
party, it being the express intention of the parties hereto to fully
settle all claims which they have with respect to each other in this
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agreement. Each of the parties further agree to consent to the entry
of a Decree in Divorce.
24. Waiver of Breach. The waiver of any term, condition, clause
or provision of this agreement shall in no way be deemed or considered
a waiver of any other term, condition, clause or provision of this
agreement.
25. Survival of Aqreement. If any term, condition, clause or
provision of this agreement shall, by its reasonable interpretation,
be intended to survive and extend beyond the termination of the
marriage relationship presently existing between the parties hereto,
said term or terms, condition or conditions, clause or clauses,
provision or provisions, shall be so construed, being the express
intention of both parties hereto to have this agreement govern their
relationship now or hereafter, irrespective of their marital status.
26. Jurisdiction. This agreement shall be construed under the
laws of the Commonwealth of Pennsylvania, and both parties consent and
agree to the jurisdiction of the Court of Common Pleas of Cumberland
County, pennsylvania, on account of any suit or action brought with
respect to this agreement or any provisions or matters referred to in
any provisions thereof.
27. Aqreement Bindinq on Parties and Heirs. This agreement
shall be binding in all its terms, conditions, clauses and provisions
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of the parties hereto and their respective heirs, administrators,
executors and assigns.
28. Divorce. Husband and Wife agree to execute, at such time as
they sign this agreement, all Affidavits of Consent and other
documentation necessary to have a divorce decree entered pursuant to
Section 3301(c) of the Divorce Code of Pennsylvania on the ground that
the marriage is irretrievably broken.
29. Headinas. The headings or captions preceding the paragraphs
in this agreement are inserted for convenience of reference only and
shall not be construed in interpreting this agreement.
IN WITNESS WHEREOF, the parties have hereunto set their hands and
seals the day and year above first written.
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DIANNE E. REESE
(SEAL)
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CHRIS A. REESE
(SEAL)
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DIANNE E. REESE
Refrigerator
Toaster oven
Crockpot
Silverware
Coffee maker/grinder
Corning ware
Microwave
Washer/dryer
Post/Pans
Computer/table
Avon dishes
Germany steins
VCR
Playstation
Televisions (2)
2 single beds or bunks
3 dressers
Pictures/albums/frames
Lighthouse stuff
Couch/loveseat
Cedar chest
Holiday decorations
Dining room table and chairs
Small appliances
Children's personal property
Dog
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EXHIBIT A
CHRIS A. REESE
Stove
Dishes
Freezer
Hutch
Entertainment center
Stereo/speakers
Hess trucks
Television (1)
Patio furniture
Grill
Master bedroom stuff
Cat
Recliner
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Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CHRIS A. REESE,
v.
NO. 00-1791
DIANNE E. REESE,
ACTION IN DIVORCE
Defendant
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the following information, to the court
for entry of a divorce decree:
1. Ground for divorce: irretrievable breakdown under S (330l(c))
~ of the Divorce Code. (Strike out inapplicable section).
2. Date and manner of service of the complaint: Hand delivered April 3, 2000,
Acceptance of Service filed April 5, 2000.
3. Complete either paragraph (a) or (b).
(a) Date of execution of the affidavit of consent required by
S 3301(c) of the Divorce Code: by Plaintiff October 24, 2000 by
Defendant October 24, 2000
(b) (1) Date of execution of the affidavit required by S 3301(d) of the
Divorce Code:
(2) A. Date of filing of Plaintiff's affidavit upon respondent:
B. Date of service of Plaintiff's affidavit upon respondent:
4. Related claims pending:
NO CLAIMS RAISED
5. Complete either (a) or (b):
(a) Date and manner of service of the notice of intention to file praecipe
to transmit record, a copy of which is attached:
(b) Date Plaintiff's Waiver of Notice in s 3301(c) Divorce was filed with
the Prothonotary: (I. ,- 0..,
Date Defendant's Waiver of Notice in S 330l(c) Divorce was filed with
the Prothonotary: 11.\,...."
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Attorney for (PLAINTIFF)~)
Supreme Court No. 40486
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CHRIS A. REESE,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
v.
NO. O-V. I7q I
CIVIL TERM
DIANNE E. REESE,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in court. If you wish to defend against the claims
set forth in the following pages, you must take prompt action. You are
warned that if you fail to do so, the case may proceed without you and a
Decree of Divorce or annulment may be entered against you by the Court. A
judgment may also be entered against you for any other claim or relief
requested in these papers by the plaintiff. You may lose money or property
or other rights important to you, including custody or visitation of your
children.
When the ground for the divorce is indignities or irretrievable
breakdown of the marriage, you may request marriage counseling. A list of
marriage counselors is available in the Office of the Prothonotary at the
Cumberland County Courthouse, Carlisle, PA 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 WHERE YOU CAN GET
LEGAL HELP.
Cumberland Count v Bar Association
2 Libertv Avenue
Carlisle. PA 17013
Telephone: (717) 249-3166
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CHRIS A. REESE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. U-O-I7'if ~T.......-
DIANNE E. REESE,
Defendant
CIVIL ACTION LAW
IN DIVORCE
COMPLAINT
1. The plaintiff in this action is CHRIS A. REESE, an adult
individual, who currently resides at 407 Market Street, New Cumber-
land, Cumberland County, Pennsylvania 17070.
2. The Defendant in this action is DIANNE E. REESE, an adult
individual, who currently resides at 407 Market Street, New Cumber-
land, Cumberland County, pennsylvania 17070.
3. Both the Plaintiff and the Defendant have been bona fide
residents of the Commonwealth of Pennsylvania for at least six (6)
months immediately previous to the filing of this complaint.
4. The plaintiff and Defendant were lawfully joined in marriage
on July 28, 1986, in Barstow, California.
5. There have been no prior actions of divorce or for annulment
between the parties hereto in this or any other jurisdiction.
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6. The Plaintiff avers as the grounds upon which this action is
based is that the marriage between the parties hereto is
irretrievably broken.
7. The Plaintiff avers that two children have been born of this
marriage.
8. The Plaintiff has been advised that counseling is available
and that the Plaintiff may have the right to request that the court
require the parties to participate in counseling.
9. The Plaintiff requests the court to enter a decree of di-
vorce.
I verify that the statements made in this complaint are true and
correct. I understand that false statements herein are made subject
to the penalties of 18 P.C.S. 34904, relating to unsworn falsification
to authorities.
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Date:
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CHRIS A. REESE
STONE LaFAVER & SHEKLETSKI
B~~~
GERALD . SHEKLETSKI, ESQUIRE
Supreme Court ID # 40486
414 Bridge Street, P.O. Box E
New Cumberland, PA 17070
Telephone 717-774-7435
Attorneys for Plaintiff
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CHRIS A. REESE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 00-1791
DIANNE E. REESE,
Defendant
CIVIL ACTION - IN DIVORCE
AFFIDAVIT OF CONSENT
1. A complaint in divorce under ~ 3301(c) of the Divorce Code
was filed on March 23, 2000.
2. The marriage of plaintiff and defendant is irretrievably
broken and ninety (90) days have elapsed from the date of filing the
complaint 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.
4. 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 18 Pa. C.S. ~ 4904 relating to unsworn falsifica-
tion to authorities.
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CHRIS A. REESE, Plaintiff
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CHRIS A. REESE,
plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 00-1791
DIANNE E. REESE,
Defendant
CIVIL ACTION LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF DIVORCE DECREE UNDER ~ 3301(c) OF THE DIVORCE CODE
1. I consent to the entry of a final decree of divorce without
notice.
2. I understand that I may lose rights concerning alimony,
division of property, lawyer's fees or expenses if 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 falsifica-
tion to authorities.
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CHRIS A. REESE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 00-1791
DIANNE E. REESE,
Defendant
CIVIL ACTION - IN DIVORCE
AFFIDAVIT OF CONSENT
1. A complaint in divorce under S 3301(c) of the Divorce Code
was filed on March 23, 2000.
2. The marriage of plaintiff and defendant is irretrievably
broken and ninety (90) days have elapsed from the date of filing the
complaint 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.
4. 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 18 Pa. C.S. s 4904 relating to unsworn falsifica-
tion to authorities.
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DIANNE E. REESE, Defendant
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CHRIS A. REESE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 00 -1791
DIANNE E. REESE,
Defendant
CIVIL ACTION LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF DIVORCE DECREE UNDER ~ 3301(c) OF THE DIVORCE CODE
1. I consent to the entry of a final decree of divorce without
notice.
2. I understand that I may lose rights concerning alimony,
division of property, lawyer's fees or expenses if 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 falsifica-
tion to authorities.
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DIANNE E. REESE, Defendant
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CHRIS A. REESE
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 00-1791
DIANNE E. REESE
Defendant
CIVIL ACTION LAW
IN DIVORCE
ACCEPTANCE OF SERVICE
I, DIANNE E. REESE, defendant in the above captioned matter,
accept service of a certified copy of the Complaint in Divorce
filed March 23, 2000, to the above term and number.
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DIANNE E. REESE, Defendant
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Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PA
CHRIS A. REESE,
VS.
NO. 00-1791 Civil Term
Defendant
CIVIL ACTION - LAW
IN DIVORCE
DIANNE E. REESE,
DEFENDANT'S ANSWER TO PLAINTIFF'S COMPLAINT
IN DIVORCE WITH COUNTERCLAIM
TO THE HONORABLE, THE JUDGES OF SAID COURT:
AND NOW, TO WIT, this \Qif. day of
~
2000, comes the Defendant, Dianne E. Reese, by her Attorney, Jane M. Alexander, Esquire,
and files the following Answer to Plaintiff's Complaint in Divorce:
COUNT I
1. Admitted,
2. Admitted,
3, Admitted.
4. Admitted.
5. Admitted.
6. Admitted.
7, Admitted.
8. Denied. Defendant has no knowledge as to what advice Plaintiff received,
9. Admitted,
WHEREFORE, Defendant prays that a Decree be entered divorcing the said
Defendant, Dianne Reese, and the Plaintiff, Chris A. Reese, from the bounds of matrimony.
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COUNTER CLAIM
COUNT A
EQUTT ABLE DISTRIBUTION
10. The averments in paragraph one (1) through nine (9), inclusive, of the Complaint
and of the Answer are incorporated herein by reference.
11, Through out the duration of this marriage, Defendant contributed considerable
time effort and resources to the acquisition and maintenance of marital property which the
parties now possess.
WHEREFORE, Defendant respectfully requests the Court to equitably divide,
distribute, or assign the marital property between the parties in such proportion as the Court
deems equitable and just.
COUNT B
SUPPORT, ALIMONY PENDENTE LITE, COUNSEL FEES,
COSTS AND EXPENSES
12. Paragraph one (1) through eleven (11) of the Complaint and of the Answer are
incorporated herein by reference as though set forth in full,
13. Defendant, whose job experience is limited; requires reasonable support to
adequately sustain herself in the standard of living established during the marriage.
14. Defendant has employed counsel, but is unable to pay the necessary and
reasonable attorney's fees for said counsel.
WHEREFORE, Defendant, Dianne E. Reese, prays this Honorable Court to enter an
order awarding the Defendant support alimony, and alimony pendente lite, counsel fees costs
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and expenses, and equitably distributing the marital property and awarding such other relief
as the Court deems just and reasonable.
Date
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Respectfully submitted,
u
J e . Alexan r, Esquire
ttorney for D endant
148 South Baltimore Street
Dillsburg, PA 17019
Attorney 1. D. #07355
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I verify that the statements made in this Petition 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: 4-h~co
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Dianne E, Reese
COMMONWEALTH OF PENNSYLVANIA
S.S.
COUNTY OF YORK
Before me, the undersigned officer, a Notary Public, in and for the said
Commonwealth and County, Personally appeared Dianne E. Reese who, being affirmed
according to law, deposes and says that the facts and matters set forth in the foregoing
Complaint are true and correct to the best of her knowledge, information and belief.
~~OAO_
Dianne E, Reese
Notarial Seal
Halvard E, Alexander, Notary Public
Diiisbur~ Boro, York County
My Commission Expires April 23, 2001
Member, Pennsylvania Association at Notaries
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