The URL can be used to link to this page

Home My WebLink About00-02134 '""'. -'1 i.if'.;~~:>:C~;:;,'x+;~;:: ):c~t::!>>;(>::.X)::+:::.r:::!::c~::::~.f;)'~~:~~;;;)<~~)>>;~;;::,:!:C~;;::::~:CK,;~>>;(:::!:+::<J!::+::.~':::!:C~~::~!>>;!::;,*rt~::+:::~=-tK+):')~!::+~~r,:~::+~:!:+;~;3!:+:);:'i;:!=-G:!:+..~t ~ ~ ~ S ...', ~~~ ~ i t:~ ls ~ ~*~ , I ~.~ ~ ~~ ~ ~~ ;..~ ~ ~-.~ ~ IN THE COURT OF COMMON PLEAS ~.S ~ k~ ~ OF CUMBERLAND COUNTY ~'S J PENNA. -'-./ ~ ~.~ STATE OF -'-,l W ~." ~ ~.~ ~ ~ ~.~ I ...... ...~AE;m~J.!';...!';,...'r.'(>'F.J~.mE... ....... ..._..... .._._._. ..._ N o. .........Q.Q:::?1..H...q.Y.r.~>> ~ ~.~ , ~ ~ ~... Versus ........ ..LoE_S'rJ<;R.. 'rARNER ~ t4 't~ ~ ~.~ ~ ~.~ * I ~~~ , ''''. DECREE IN ,-.- D I V 0 R C E c.::11: 38' jJ.tfl AND NOW, . . .~. . .~~ . . . ., b9c. .2000, it is ordered and decreed that.. . . . . .~~RJ:QF.;r:E. .J;:,. :r'AEI\ll':R . ... . . . . .. . . .. . . . . . " plaintiff, and.......... LESTER .TARNER..............................., 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; None . . . . . . . . . . . ~ . . .:<,' . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , ;..; ~ ~'";~ ~ ... 8 ~..; ~'~ ~ Attest: m...CJ~~ ---. Prothonotary ~.'~ ~ $"". '., ~ i i ~ ~4E('::.~>, .~<+}.:: ":<c.;, ':*::';:. '::4E.;:: ":.:+::';:. ::~.::.;:: ':-.::co::: )':C.,::':;.>>;.::: :':.::C~,: ~..~~;_: :::.:+:>,: ':'.:+::!;:. ::,~::+::~;_::':.:+::.;:: "'.:+::'':: ";:+::< ::":+:"" ~ :;.:+x):+x ::~:.::"..>::.::.:::X.::":::~.::+::":' :,.'::.::...: ::.::.:<>:.;"': :::~::.::~:: 1 - - -,~ [._r_'_' , ""'--'-'",-.' _ " r ~"'1 ~ ~~~ ~ ;..,~ ~ i ~ i ~.~ ~.~ ~ ~ ~ ~.~ i ~.~ ~ ~ ~ ~ ~.~ ;:,~ ~ ~.~ ~ ~}. ~ ~." M< ;-s ~ ~':: i ~.~ ;.~ ~ "t''- ~ ~." J. ~ ~.~ ~ '.' ~.~ ~ w. ~.~ h ~, ~ ;;.~ ~ ~ ~.~ ~ ~.~ ~.~ * .L_ ~, ~~ ~ ~ ~ c27'(~0 ~/V P ~ ~te/ ~ -,P9 (X)-<-(!?,1 ~,...,._,.~ !C.t.; , . B!IJ!I ,,~ n~ - - - ~~ 'I',"_,Wl_~mj;l, ",,=-~- - ~I_.~""'~! MARJORIE E. TARNER v. :: IN THE COURT OF COMMON PLEAS OF :: CUMBERLAND COUNTY, PENNSYLVANIA :: NO. 00-2134 CIVIL TERM LESTER T ARNER IN DIVORCE PRAECIPE 1'0 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 Section (3301(c) ) (JJ01(d)) 6fth~ Divorce Code. (Strike out inapplicable section.) 2. Date and manner of service of the complaint: Certified Mail April 8, 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 f ~;2 '3 ~ .)rr-.r-J. by defendant Y-.5If-O 0 (b) (I) Date of execution of the plaintiff s affidavit required by Section 330 I (d) ofthe Divorce Code: ; (2) Date of service of the plaintiffs affidavit upon the defendant: 4. Related claims pending: Non", 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) of the Divorce Code: ~tl/J/{J~ rances H. Del Duca, EsqUire .-'-1 "=N,,> , .~~ ,....,..,." ~ ""~ .~ "'",".-, - . ,~ g z "'005 mrn z.::v zr;; ~?~, t<O ?ZR :P~ z ~ c:::> c:::> rft r<" -0 N c:::> r> v -r~ --0 ::~ t;-? '--'1 4",..-" !~)~ 1.,::),;(-:, -:::-?-=-\i, ';i'~ (- . =:\ ~ :..<; - ....! ..._""m"'<f!l!~"l~P~!\9l'!lIf!!illl . _1!RIllIM~~ -~I v. :: IN THE COURT OF COMMON PLEAS OF :: CUMBERLAND COUNTY, PENNSYLVANIA :: NO. Do-;}.IJ"! CIVIL TERM MARJORIEE. TARNER LESTER TARNER 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 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. PENNSYL V ANLA. 17013 IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DNISION 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 COUNTY BAR AS SOCIA TION 2 LIBERTY AVENUE CARLISLE, P A 17013 717-249-3166 ~I!U~ Frances H. Del Duca 10 West High St. Carlisle, P A 17013 I,",.. "-II v. .. IN THE COURT OF COMMON PLEAS OF :: CUMBERLAND COUNTY, PENNSYLV ANLA :: NO. tH;. ;213'1 CIVIL TERM MARJORIE E. TARNER LESTER TARNER IN DIVORCE COMPLAINT UNDER SECTION 3301(C) AND 3301(0) OF THE DIVORCE CODE COUNT I - DIVORCE 1. Plaintiff is Mmjorie E. Tamer, who resides at 463 West Main Street, Walnut Bottom, Cumberland County, Pennsylvania, 17266. 2. Defendant is Lester Tamer, who resides at 425 Steelstown Road, Newville, Cumberland County, Pennsylvania, 17241. 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 February 3, 1972, in Newville, P A. 5. The parties separated August 22, 1986, and have continued to live separate and apart for a period of at least two years. 6. There was an action in divorce filed to No. 3660, 1986, and dismissed pursuant to PA R.J.A.1901 on October 31,1989 to No. 3892, 1989. 7. Plaintiff avers that the grounds on which the action is based is that the marriage is irretrievably broken. 8. Plaintiff has been advised that counseling is available and that plaintiff may have the right to request that the court require the parties to participate in counseling. COUNT II - EOUITABLE DISTRIBUTION 9. Plaintiff and defendant are the joint owners as tenants by the entireties ofreal estate located at 425 Steelstown Road, Newville, Cumberland County, Pennsylvania. .1 10. Plaintiff and defendant have other marital assets which are subject to distribution. WHEREFORE, plaintiff respectfully requests the Court: I) To equitably distribute marital property; and 2) To enter a decree in divorce. ~J~xa<7~d~~/__ rances H. Del Duca Attorney for Plaintiff April 1. 2000 " ,. ...,.-, . . , ~ . 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: '1'7/ fl} */~/ ~ ---' , ~ /.? , 4?-' ......_ I J ~I I . . . ' Ii I~:~ .. ,JI!lIl!!!llllmr;;.. . 70 g ~ '(=- ~ 2 "-{) ~ c< B ~ , r ~~ J-~ ~ '-~ ~& o ' c () I h 8 , r ~ - ...j- ,fr) ~ o ;2 -~. lJ'", fl-j r~'\ ~<~~, -.<::'. .':~ ~c; '?itl] PC: -/ ~\ -<. c~ o :D" -..'V ;::0 I -' () en -c1 (.\~~~ ~.:; :-::'1 ,- "'x) :..< --v ~ ~ \;1 "_....~l~~ ~"~~ 1,~_~__~,,"~,_ ._''''" ,_01[1i1f~~~"'''''fj!"!'f-~::''''-'''~'''~I'''Ji("''1!mw'!ffi<!'l!j>1'!>;~~~i\i;m'l~1I~~~'1I!8lI "f"!"'""""!"I'__ MARJORIE E. TARNER .. IN THE COURT OF COMMON PLEAS OF .. CUMBERLAND COUNTY, PENNSYL V ANJA .. NO. 00-2134 CIVIL TERM v. LESTER T ARNER IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed April 7, 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: f:{flvV ~ ;:~ -a r:Y' (..-' ?~/)- M~ne E. Tamer . ~ ".' ~ _."_lc__ I ;~ . -, .~ , _10"" C) ~= gJ[~': 2~C- (j).:;- -<~, 0~-' ~~...: >-, j>s~; .?::, -< o c.-::i ;,.-') ''1 -CJ ::....:., c::> ~"'"W:'!_?;'''F;~'''!~''ll!fflI~~~I!fo!1l1!1m!f~~t v. :: IN THE COURT OF COMMON PLEAS OF :: CUMBERLAND COUNTY, PENNSYLVANIA :: NO. 00-2134 CNIL TERM MARJORIEE. TARNER LESTER T ARNER IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 330H c ) OF THE DIVORCE CODE I. I consent to the entry of a final decree without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI 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 arc 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: f bl. f/ tJ7) ~ ~ ...."e~ . rie E. Tamer '~O-l' c ' "- ,- c.-?' '-'-.-' , -. l -""C' ,,' _' "r..,."",' .. ,-"~,~~. , " \]1""'-- nl( , Z::- -;-"'r-- ()5 ,~ -< fC i~ ~~~ H' ""." o ~;. C> c-..., en i"Ti '-0 s -< :::> c=' " ,!~~Jr~~f1>!!!t1mlW,'ffl~~~~'jm~!ifl)':~'F'_i!!i!~~~~ v. :: IN THE COURT OF COMMON PLEAS OF :: CUMBERLAND COUNTY, PENNSYLVANIA :: NO. 00-2134 CIVIL TERM MARJORIEE. TARNER LESTER TARNER IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed April 7, 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 fmal 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 in 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. /"'J _ ..:-:-::.. '?r f ()' - p Dated~ h / r- 1JJ!;:~~ Lester Tamer I' ,-, ,- _ 0, ~, 1'- ~ 1 , ,~ C) c:: <' '-"Off,'-' ~~~ E~2-' ,::;:r.. ~.\.. -~ "';~~. ~ -< C:J (I) C'., -':i .'._, ....:,.. :--, t,O ~,~" - ce,,',,_ _ ,~__, .', ;,'1'~_l,' ~. ,_, ,,~ 0_',_ ^f ~llifjflW'WI-~ll'R'!~ffl'~~_~wm~~~~~~ifiIl!!IQ~ v. :: IN THE COURT OF COMMON PLEAS OF :: CUMBERLAND COUNTY, PENNSYL V ANLA :: NO. 00-2134 CIVIL TERM MARJORIE E. TARNER LESTER T ARNER IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 330H c ) OF THE DIVORCE CODE I. 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 ifl 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 IS Pa.C.S. Sec. 4904 relating to unsworn falsification to authorities. Dated:~o/~CJ>O c5 ~-J;:; E, ~ Lester Tamer ~ '-I .....l~- Ij 1~, ". ''''~'' .'"",~-' " .,,~" " C) ~ ~~r:: ---,.-:....: L.- __'. t5::,:~. -< :; ~~, ,-. ?~ . ~ ~.,~,.lIfrn'W~lo:~ ~~ ~/) "Tj -<;' ~.'-~ l_r".' ~ ~~IIf1'1'~"'''''''' ..,_If""" , ( v. :: IN THE COURT OF COMMON PLEAS OF :: CUMBERLAND COUNTY, PENNSYLVANIA :: NO. 00-2134 CIVIL TERM MARJORIE E. TARNER LESTER TARNER IN CUSTODY AFFlDA VlT OF SERVICE STATE OF PENNSYLVANIA SS COUNTY OF CUMBERLAND .. FRANCES H. DEL DUCA, attorney for plaintiff, being duly sworn according to law, deposes and says that she is an attorney having her office at Ten West High Street, Carlisle, Pennsylvania, and that she is admitted to practice in the courts of Cumberland County; that she served a copy of Complaint in Divorce in the above matter by mailing same Certified Mail, on April 7, 2000, and that said document was received by the defendant, Lester Tamer on April 8, 2000, as evidenced by return receipt card No. Z013333951 attached hereto. ~ r!/iJvI/2/_~ - Prances H. Del Duca, Esquire SUBSCRIBED and sworn to before me this / (}ii day of April, 2000. ~~tc~P)a4'u otary Public SIIlRLEY P. c'.':..~ SEAL CallIeIo~~ARYPllilUc I4.v CammIeiIoii Expire.,...." ~ "".~-I "- is. . '.. '. llllllIUIMliIll__ _ .. .. __ - ii,f8tllffor2'forad'dlUohllhJ8rv1ce8. following seM'c= (lor an . . co~ items 3, 4a.. and 4b. ...0;0 I 'I .=,:ur~andaddressonthereverseofth1sfonnSDthatwecanretumthiB extra fee): !II . Attadl J,1'. lonn to the front 01 themallpleco.oronthebackWspacedo..n0l1. 0 Addressee's Address I P8lTllll - . Write -Relum Rsoe/pt Requested"on the matlpiece ~DWth8 ~cle numbBl'. 2. D Restricted Delivery I. .TheF.letum,Reqeipt.w1llahowtowhornthearlfcleVias(teIIviiJ1ijl-andthedate Consult - sf 10 I 'Ii deirlY8red. ~ ,. - PQ<;I!~lIIa er ,r 88. II 3. Article Addressed to: "", Article Number )20/5 &8390/ 'Ii. 4b. Service Type fi D Registered o Express MeII D Return Receipt for Merchandise 1. Date 01 Delivery . - - 11 8. . dresses's AQdress (Only If requested ~4' and fee Is paid) i ~ -- ... -.~''''-'''''''-''Or!"-'-''- I .. PSF :, Z 013 333 951 Certified Fee Special Delivery Fee ~=--r'-' '. , 'T '-,", , , ra-t::8'rIified D Insured DeOD 111 '~---I , ~I 11 a' 1 II: j !!' 11 " ,s: " D. ... I: ''Jt ~I~ r .-. ~-'" ".,,~ ,~, . _W . ,_C'. _1/.<_,", -_j"'. ',- ,-~;~,;"r>T~"'~ - .'_-L__;,"''-''c"%' ,.,. '7>"'" ,~ 0 (-:) ~ ~; 0 ~,. - "1: E i ~ ~.J I' n-'r-I :=0 z'" Z[~- C) (' (j) ,.,,: -<L, ~O C) ~ >'0 ~ , Zo l::- ( )>~ :m~d.tII1lM~~ "...."'"'lilII " \ ;,. .-~ ~'C~~~ 1\ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA MARJORIE E. TARNER, Plaintiff, CIVIL ACTION - LAW v. NO. 2000-2134 LESTER E. TARNER, Defendant IN DIVORCE PRAECIPE FOR ENTRY OF APPEARANCE OF COUNSEL To the Prothonotary: Please enter my appearance on behalf of the Defendant, Lester E. Tamer. Dated: /. t I?. J 00 a~a.~ David P. Perkins, Esquire Attorney for Defendant Attorney l.D. #34342 126 East King Street Shippensburg, P A 17257 (717)532-7388 WE~GLE, PERKINS & ASSOCIATES - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 1'-, ~Iif L, 11Im, -~-_I!I ~ .. ~ ". .~-- ___J ~,., M'--' '-", ~ _ _ , 0 (::J ,-', c '""' '.-.' < ~Ii: -- -- :-z.:c" (j) .'. .,- ~<:-::: r:::r.::', _l-.~' i>c' _i_~+ ~r") Pc lJ) ;.?; :YI =< U' __!l. ~ ._~, --"""",.,_",""[>.,,.,,"l'!j~l!mfii~ij.'f'Wjl.~"'''f'';O;;'''iq:l!l'''''y.'i~~_~~~lIi~~~~I''~M ". II I: I: Ii " I' I.j I, Ii Ii i' I' h ii i:1 I ! I'! I' :' j,: I:, I,! ii I ~ i i" Iii i,. i'i !H 1_,1 1'1 I'; I:: Ii Ii I i; I Ii !,I Ii i ,-",~ MARJORIE E. TARNER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA: NO. 00 - 2134 CIVIL vs. LESTER TARNER, Defendant IN DIVORCE ORDER OF COURT AND NOW, this /9(tt- day of ~ 2000, the economic claims raised in the proceedings having been resolved in accordance with a marital settlement agreement dated August 28, 2000, the appointment of the Master is vacated and counsel can file a praecipe transmitting the record to the Court requesting a final decree in divorce. BY THE COURT, cc: Frances H. Del Duca Attorney for Plaintiff ~ f' . ("{ 00 l ~q'\~ David P. Perkins Attorney for Defendant -,-- "." ~ , ',' 'Il >- <"> ~ ~ '"" 0 "::J ~.s;;: b:::!'; tE~. ::r.:: (.)~ <C ~;;! :g f=~ 0'\ S0 _2 W(L -~-2 u:~V 0.... UJUJ ~ w co a.: t- (/0 :::E u.. 0 a J. 0 0 \ .p. -'" ~~ . ~ ~~~~- ."'- "1f1"~ . ,n." ~.- " , ."', CR.,<"")'~,,,___,,~:3'_:._' oP"" ~1lI'~~"''''''iliO'''!!i'l!w.''',~fllJ~~~ - ..."cy.... , ., . ~-" '-~~ j , <'.~ -I. It FRANCES H. DEL DUCA ATTORNEY AT LAW TEN WEST WGH ~TRE~T CARLISLE, PENNSYLVANIA 17013 MAIUIAL SJ<..l TL!J.iVlliN 1 A""Gtu;1!;MJ<..l~ 1 THIS AGREEMENT, made this ~ ~ day of August, 2000, by and between MARJORIE E. TARNER, hereinafter called Wife, and LESTER TARNER, hereinafter called Husband, WITNESSTH: WHEREAS, the parties hereto are husband and wife, who were married on February 3, 1972 in Newville, Pennsylvania, and who separated on or about August 22, 1986; WHEREAS, the parties desire to settle fully and finally their respective financial and property rights and obligations as between each other, including without limitation by specification: settling of all matters between them relating to the ownership and equitable distribution of real and personal property and related economic claims; and in general the settling of any and all claims or possible claims of one against the other or against their respective estates. WHEREAS, each party is fully familiar with the marital property and both parties now desire to settle and determine her and his property rights and claims under the Divorce Code, including all claims regarding equitable distribution of marital property, alimony, spousal support and related economic claims. NOW, THEREFORE, the parties h~reto, intending to be legally bound hereby, do covenant and agree as follows: I. The parties have divided between them to their mutual satisfaction their personal effects, household furniture and furnishings, 'automobiles and all other articles of tangible personal property which have heretofore been used by them in common and neither party will make a claim to any such items which are now in the possession or under the control of the other. . .-: I I - .,i "'~~.~ ,. 2. The parties are joint owners of real estate located at 432 Stee1stown Road, Newville, PA. Wife agrees to convey her interest in said real estate to Husband. Husband agrees to pay to Wife $55,000 for her interest and Wife agrees to accept $55,000 for her interest in the property 3. Except as herein otherwise provided, each party represents that she and he have not heretofore incurred or contracted any debt or liability or obligation for which the other may be held responsible or liable. Each party agrees to indemnity and save and hold h~less the other from and against all such debts, liabilities or obligations of every kind which may have heretofore been incurred between them, except the obligations arising out of this Agreement. 4. Both parties agree that the hereinabove set forth Agreement constitutes an equitable distribution of their marital property and equitable resolution of all other economic claims pursuant to the provisions of the Divorce Code and each party irrevocably waives, releases, and remises any claim to ownership of or interest in any property designated as the property of the other by virtue of the provisions of this Agreement except as may otherwise be provided pursuant to the provisions of this Agreement. 5. This Agreement constitutes the entire understanding of the parties. Tbere are no covenants, conditions, representations or agreements, written or oral, of any nature whatsoever, other than those herein contained. 6. This Agreement shall bind and inure to the benefit of the parties hereto and their respective heirs, executors, administrators, successors and assigns. . .- /. , .. IN \NUTNESS WHlER.E:(}F" nh,e iP:.urI.ic:s !hc:nel<<' IhIllV<C 1!IC~ u:hm lIlamells amlil ilIelI1:s 1thte day and year first above written. I '1t'~ r r /~- ./ ~ L- ~ f.7-~ '--;) jJ.. C. G>>\ L<<to<T='" . WITNESS: " ,.,-',,' "-" (SEAL) (SEAL) 'H~ .. .,. "r ~ '~""'f'T _I . . " MARJORIEE. TARNER :: IN THE COURT OF COMMON PLEAS OF :: CUMBERLAND COUNTY, PENNSYLVANIA :: NO. 00-2134 CIVIL TERM v. LESTER TARNER IN DIVORCE INVENTORY Plaintiff files the following inventory of all property owned or possessed by either party at the time this action was commenced and all property transferred within the preceding three years. ASSETS OF PARTIES Plaintiff lists below the item applicable to the case at bar: Real property located at 425 Steelstown Road, Newville, Cumberland County, Peunsylvania. MARITAL PROPERTY Plaintiff lists below marital property in which either or both spouses have a legal or equitable interest individually or with any other person as of the date this action was commenced: Real property located at 425 Steelstown Road, Newville, Cumberland County, Pennsylvania. '"'"'I .) ) . ... , ., 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: ~ !$?/ ~ ~ !Y~~ f? ~9~O-t~ , , II -, ~,<', "'"""""'"'_'''''".J1I!!. ~ ~~~,~~< Co C) ~~~ C (.:::) tJff5 , ~ P11'-:--; r= Z=:C! :z::C en.I> en -?":=-,- !i~ D> ~'... Z r.- :<! r'0 .. .... , h~ ~J~.~"!J~~_~"~~M=!ilIlI,,"~~ ,,!:-a~~iI~tpm1Illllll!fliJ__l!{UI~1 - ,~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VS. NO. OD --'21!)~ CIVIL IN DIVORCE 19 MARGORIE E. T ARNER, Plaintiff LESTER T ARNER, Defendant STATUS SHEET ACTIVITIES: I, 1"".' _ I ' - ~ ,." -. 1 . - ~. - ",'-"' ~ Ie ,_.~, . r MARGORIE E. TARNER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 00 - 2134 CIVIL LESTER TARNER, Defendant IN DIVORCE TO: Frances H. Del Duca Attorney for Plaintiff Lester Tarner Defendant DATE: Monday, June 26, 2000 CERTIFICATION I certify that discovery is complete as to the claims for which the Master has been appointed. OR IF DISCOVERY IS NOT COMPLETE: (a) Outline what information is required that is not complete in order to prepare the case for trial and indicate whether there are any outstanding interrogatories or discovery motions. :,;0-, -r'-- , ~ II _~~ "1tII!U~ J'ln~ "" " ., "' '~,_C-"T'r~> _0,",:,-"" p.'"~ ""_=",~_,I1'~"f".,,.[I_~W:~f__~I!ii/ii~"JIlIll!!Jlq~~'~~1 , ~ . (b) Provide approximate date when discovery will be complete and indicate what action is being taken to complete discovery. DATE COUNSEL FOR PLAINTIFF COUNSEL FOR DEFENDANT NOTE: PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE AT THE MASTER'S DISCRETION. AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY COUNSEL, INDICATING THAT DISCOVERY IS NOT COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL STATEMENTS WILL BE ISSUED AT THE MASTER'S DISCRETION. HOWEVER, IF BOTH COUNSEL, OR A PARTY NOT REPRESENTED, CERTIFY THAT DISCOVERY IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL STATEMENTS WILL BE ISSUED IMMEDIATELY. THE CERTIFICATION DOCUMENT SHOULD BE RETURNED TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF THE DATE SHOWN ON THE DOCUMENT. ~, ~ IN mE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MARJORIE E. TARNER Plaintiff vs. LESTER TARNER 00-2134 19 NO. MonON FOR APPOINTMENT OF MASTER Marjorie E. Tarner (Plaintiff) (J;'d.....Aa..t) , moves the court to appoint a master with respect to the following claims: (x) Divorce ( ) Annulmen t ( ) Alimony ( ) Alimony Pendente Lite 00 ( ) ( ) ( ) Distribution of Property Support Counsel Fees Costs and Expenses and in support of the motion states: (1) Discovery is comp.lete as to the c1<\ims (5) for wnich the appointment of a master is requested. (2) The defendant (has) (has not) appeared in (by his attorney, (3) The staturory ground(s) for divorce (is) <jP'c'771! N 33<" I ((')/J;/l'() " '<(( I 0 (4) Delete the inapplicable paragraph(s): (a) ~ction is not contested. (b) ~eement has been reached with respect to the the action (personally) ,Esquire). (are) following claims: (c) The action is contested with respect to the following ,E~<fult"t/l:A(~ (JIS'/~I d3rJr/~JI"\,.I (5) The action (ia~olv~~)~does not involve) complex issues of law claims: or fact. (6) The hearing is expected to take e1/V c... (hours) ~). (7) Additional information, if any. relevant to the motiOn: / ORDER APPOINTING MASTER Ij ,J:'f~. ~ ~ er with respect to the following claims: ~ Hhc-{ e4 ,lJ jJj tf2~- . ttorney for (Plaintiff) (~efe"::iant) Date: is ~ &:.U Esquire, ~ ~~~ ~ ~D~ , "~~ ~ -, --;;.J~~_.,,- -.- -.- .- - - J ~~~-~ '-'~""'ir II ., ", ~ "".,."".,~ .~_ ___i'!IIlI'I'~ .. ~ o ~. ~~ -orf) n"1rT- Z-r: z: t:~ ~'t=~! J3;n Z;c ;p>e:: .~ ViNVill)8NN:;d A.lNnC)~) nr r',/"'iHJ:'liNn:) ,,",. Ij'J :lli!V .? ,\,1.;",'1>'<' nt, .. . '.oJ f,U/I:' <.-:> C) .~-- c: Z ~~ ., 11 C?I ___--\1 (]1 ,",'q '.:::;:: ~, ~ ~... 1~1 .-' -H ~,~~ f\~ ~~ .'\:;;> J';': ::<; - ~ Iv e~ .,_ . "' ~~lf~MIW'''''''l:!I1''''1-1!!~~~~mrJl!filllll~,,,,'";""_. .,~" I FRANCES H. DEL DUCA ATTORNEY AT LAW TEN WEST HIGH STREET CARLISLE, PENNSYLVANIA 17013-2922 AREA CODE 717 249-1323 September 7, 2000 E. Robert Elicker, II, Esq. Master in Divorce 9 No. Hanover St. Carlisle, P A 17013 Re: Tamer Divorce Dear Mr. Elicker: Enclosed is a copy of Marital Settlement Agreement for the parties in the above divorce action. The property has been transferred to the Husband and Mrs. Tamer has received $55,000. You may withdraw your appointment as Master. Thank you. Sincerely, ~ ~ Frances H. Del Duca FHD/s Encl. ... ~ WEIGLE, PERKINS & ASSOCIATES Attorneys-at-Law 126 EAST KING STREET SHlPPENSBURG, PENNSYLVANIA 17257-1397 JERRY A. WEIGLE DAVID P. PERIONS Associate JOSEPH P. RUANE TELEPHONE (717) 532-7388 or (717) 776-4295 FAX (717) 532-6552 July 12,2000 Mr. E. Robert Elicker Divorce Master 9 North Hanover Street Carlisle, P A 17013 Re: Mmjorie E. Tamer vs. Lester Tamer Case No. 00-2134 Dear Mr. Elicker: Please be advised that I have been retained by Mr. Lester Tamer with regard to the divorce action pending .before you. Enclosed is a copy of a Praecipe entering my appearance. I have attenlpted to contact Frances Del Duca but she is out of the office until the end of July. I believe that the parties will be able to reach a negotiated settlement and that a master's hearing will not be necessary. Unfortunately, I will not be able to confirm this until August. Very truly yours, WEIGLE, PERKINS & ASSOCIATES Q~c7~ David P. Perkins, Esquire Enclosure DPP/plt cc: Lester Tamer . . Frances Del DlJca . . I-~ _"fl_, 0<, - <' ~< .-'1" ~II II :! IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA i il II MARJORIE E. TARNER, : Plaintiff, Ii i CIVIL ACTION - LAW NO. 2000-2134 v. LESTER E. T ARNER, Defendant IN DIVORCE PRAECIPE FOR ENTRY OF APPEARANCE OF COUNSEL To the Prothonotary: Please enter my appearance on behalf of the Defendant, Lester E. Tamer. Dated: /. II?. f 00 CJ~ a.c~ David P. Perkins, Esquire Attorney for Defendant Attorney I.D. #34342 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 . . 1 ,_~_ , . ',. '-', -y , < -