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IN THE COURT OF COMMON PLEAS
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OF CUMBERLAND COUNTY
STATE OF
PENNA,
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N o. .uuuuQ.Q:::~J.70.uG;!:y.n TERM
PLAINTIFF
Versus
ST:E.\TI!:.liI K, uI<l'lA.{J]:lL
DEFENDANT
AND NOW,
DEe R EEl N -A- C, t:J /)J A
I V 0 R C E ~ :)" ~ rlV\
. . . . . . . . ,( ~ . , .. .2000.. it is ordered and
decreed that.... . OLGA .B.. .KNAUB............................., plaintiff,
and.............. .s.'r::EY~.N..I5~. .K.~~V!3........................., 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;
.......................................................................... .
....................................................... .
UHHUHU~.U J.
Prothonotary
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MARRIAGE SETTLEMENT AGREEMENT
THIS AGREEMENT made this !It. day of ~ ' 2000, by and between
OLGA H. KNAUB, (hereinafter referred to as "WIFE") and STEVEN K. KNAUB,
(hereinafter referred to as "HUSBAND").
WITNESSETH:
WHEREAS, HUSBAND and WIFE were lawfully married on May 14, 1977; and
WHEREAS, diverse, unhappy differences, disputes and difficulties have arisen between
the parties and it is the intention of HUSBAND and WIFE to live separate and apart for the rest
of their natural lives, and the parties hereto are desirous of settling fully and fmally their
respective financial and property rights and obligations as between each other, including, but not
limited to the settling of all matters between them relating to the ownership and equitable
distribution of real and personal property, the settling of all claims and possible claims by one
against the other or against their respective estates, and the equitable distribution of property and
alimony for each party.
The parties hereto agree and covenant as follows:
1.
The parties intend to maintain separate and pennanent domiciles and to live apart from
each other. It is the intent and purpose of this Agreement to set forth the respective rights and
duties of the parties while they continue to live apart from each other.
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2.
The parties have attempted to divide their matrimonial property in a manner which
conforms to a just and right standard, with due regard to the rights of each party. It is the intent
of the parties that such division shall be final and shall forever determine their respective rights.
The division of existing marital property is not intended by the parties to constitute in any way a
sale or exchange of assets.
3.
Further, the parties agree to continue living separately and apart from the other at any
place or places that he or she may select as they have heretofore been doing. Neither party shall
molest, harass, annoy, injure, threaten or interfere with the other party in any matter whatsoever.
Each party may carry on and engage in any employment; profession, business or other activity as
he or she may deem advisable for his or her sole use and benefit. Neither party shall interfere
with the uses, ownership, enjoyment or disposition of any property now owned and not specified
herein or property hereafter acquired by the other.
4.
The consideration for this contract and agreement is the mutual benefit to be obtained by
both of the parties hereto and 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.
Each party to the Agreement acknowledges and declares that he or she,
respectively:
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(I) Is represented by counsel of his or her own choosing, or if not represented by
counsel, understands that he or she has the right to counsel: HUSBAND is
represented by Douglas G. Miller, Esquire of Irwin, McKnight & Hughes; WIFE
is represented by Jane M. Alexander, Esquire;
(2) Is fully and completely informed of the facts relating to the subject matter of
this Agreement and of the rights and liabilities of the parties;
(3) Is entering into this Agreement voluntarily after receiving the advice of
counselor after choosing not to consult an. attorney;
(4) Has given careful and mature thought to the making of this Agreement;
(5) Has carefully read each provision of this Agreement; and
(6) Fully and completely understands each provision of this Agreement, both as
to the subject matter and legal effect of each provision.
This Agreement shall become effective immediately as of the date of execution.
5.
It is the purpose and intent of this Agreement to settle forever and completely the interest
and obligations of the parties in all property that they own separately, and all property that would
qualify as marital property under the Pennsylvania Divorce Code, Title 23, Section 401(e), and
that is referred to in this Agreement as "Marital Property", as between themselves, their heirs and
assigns. The parties have attempted to divide their Marital Property in a manner that conforms to
a just and fair standard, with due regard to the rights of each party. The division of existing
Marital Property is not intended by the parties to constitute in any way a sale or exchange of
assets, and the division is being effected without the introduction of outside funds or other
property not constituting a part of the marital estate.
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It is the further purpose of this Agreement to settle forever and completely any obligation
under the Pennsylvania Divorce Code relating to spousal support or alimony.
6.
Each party represents and warrants that he or she has made a full and fair disclosure to the
other of all of his or her property interests of any nature, including any mortgage, pledge, lien,
charge, security interest, encumbrance, or restriction to which any property is subject. Each
party further represents that he or she has made a full and fair disclosure of all debts and
obligations of any nature for which he or she is currently liable or may become liable. Each
further represents and warrants that he or she has not made any gifts or transfers for inadequate
consideration of Marital Property without the prior consent of the other.
Each Party acknowledges that, to the extent desired, he or she has had access to all joint
and separate State and Federal Tax Returns filed by or on behalf of either or both Parties during
marriage.
7.
REAL ESTATE: WIFE hereby agrees to transfer all right, title and interest which she
may have in the real estate situate at 507 Cascade Road, Mechanicsburg, Cumberland County,
Pennsylvania to HUSBAND and releases all claims which she may have regarding said real
estate in accordance with this paragraph. WIFE agrees to execute a Deed within ten (10) days
from the date of the execution of this Agreement transferring said property into HUSBAND's
name individually, which Deed shall remain in escrow with her legal counsel's office until
WIFE'S name has been removed from the mortgage and any other encumbrance on the property.
HUSBAND agrees to assume all liability for and indemnifY WIFE against the mortgages
currently against said residence, and agrees to be solely responsible for the payments associated
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with said mortgages. The removal of WIFE's name from the mortgages shall occur either by
refmancing or assumption of the current mortgages by HUSBAND.
8.
SUP}>ORT: It is the mutual desire of the parties that HUSBAND will not be required to
pay support to WIFE and that WIFE will not provide any fmancial support to HUSBAND. The
parties also waive any right they have to receive alimony or alimony pendente lite payments
from the other following the entry of the Divorce Decree in this marter.
9.
PERSONAL PROPERTY: The parties agree that the personal property has been
divided to the parties' mutual satisfaction. WIFE hereby waives all right, title and interest which
she may have in any personal property of the HUSBAND. HUSBAND likewise waives any
right, title and interest which he has in the personal property of WIFE. Henceforth, each of the
parties shall own, have and enjoy independently of any claim or right of the other party, all items
of personal property of every kind, nature and description and wherever situated, which are then
owned or held by or which may hereafter belong to HUSBAND or WIFE with full power to
HUSBAND or WIFE to dispose of the same as fully and effectually, in all respects and for all
purposes as ifhe or she were unmarried.
10.
AUTOMOBILES: WIFE hereby waives all right, title and interest in any vehicle that
HUSBAND currently owns or may own in the future. HUSBAND shall hold WIFE harmless
for any and all liability associated with the use and purchase of any vehicle he may own, and
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shall be solely responsible for all insurance and other financial responsibility associated with said
vehicle. HUSBAND hereby waives all right, title and interest in any vehicle that WIFE
currently owns or may own in the future. WIFE shall hold HUSBAND harmless for any and all
liability associated with the use and purchase of any vehicle she may own, and shall be solely
responsible for all insurance and other fmancial responsibility associated with said vehicle.
11.
MARITAL DEBTS: WIFE shall assume all liability for and pay for and indemnify and
hold harmless HUSBAND against the following credit cards and loans:
1. Mellon / CBSD Master Card;
2. Penn State Alumni Association MBNA Master Card; and
3. Unsecured Line of Credit through Mellon Bank.
In addition, the parties hereby agree to cooperate in closing or removing the other party's name
from any and all joint accounts, specifically a Sears charge account, within fifteen (15) days of
the execution of this Agreement.
Furthermore, it is mutually agreed by and between the parties that WIFE shall assume all
liability for and pay and indemnify the HUSBAND against all debts incurred by WIFE after the
date of separation. WIFE represents and warrants to HUSBAND that since the parties' marital
separation she has not contracted or incurred any debt or liability for which HUSBAND or his
estate might be responsible and WIFE further represents and warrants to HUSBAND that she
will not contract or incur any debt or liability after the execution of this Agreement, for which
HUSBAND or his estate might be responsible. WIFE shall indemnify and hold HUSBAND
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hannless from any and all claims or demands made against him by reason of debts or obligations
incurred by her.
HUSBAND shall assume all liability for and pay and indemnify WIFE against all debts
incurred by HUSBAND after the date of separation. HUSBAND represents and warrants to
WIFE that since the parties' marital separation he has not contracted or incurred any debt or
liability for which WIFE or her estate might be responsible and HUSBAND further represents
and warrants to WIFE that he will not contract or incur any debt or liability after the execution
of this Agreement, for which WIFE or her estate might be responsible. HUSBAND shall
indemnify and hold WIFE harmless from any and all claims or demands made against her by
reason of debts or obligations incurred by him.
12.
INSURANCE AND EMPLOYEE BENEFITS: The parties agree that any life
insurance policies on the life of HUSBAND or WIFE or any other employee benefits, including
but not limited to retirement, profit sharing or medical benefits of either party, shall be their own.
WIFE waives all right, title and claim to HUSBAND's employee benefits, and HUSBAND
waives all right, title, and claim to any of WIFE's employee benefits.
13.
BENEFITS AND BANK ACCOUNTS: WIFE agrees to waive all right, title and
interest which she may have in the savings or checking or any other bank accounts of the
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HUSBAND and likewise HUSBAND agrees to waive all right, title and interest which he may
have in the savings or checking or any other bank accounts of WIFE.
14.
DIVORCE: The parties both agree to cooperate with each other in obtaining a final
divorce of the marriage. It is agreed that the parties will execute and file the consents necessary
to obtain the divorce. Any party who fails to cooperate with obtaining the Divorce shall pay all
the costs and legal fees of the party who is seeking the divorce.
15.
BREACH: If either party breaches any provisions 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 legal fees and costs incurred by the other in enforcing their rights
under this Agreement.
16.
ADDITIONAL INSTRUMENTS: 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 that may be reasonably required to give full force and effect to the provisions of this
Agreement.
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VOLUNTARY EXECUTION: The provisions of this Agreement and their legal effect
have been fully explained to the parties by their respective counsel, are fully understood by both
parties, and each party acknowledges that the Agreement is fair and equitable, that it is being
entered into voluntarily, and that it is not the result of any duress or undue influence. It is the
parties' intent that this Agreement does not merge with the Divorce Decree, but rather shall
continue to have independent contractual significance. Each party maintains his or her
contractual remedies or any other remedies provided by law or statute. Those remedies shall
include, but not be limited to, damages resulting from breach of this Agreement, specific
enforcement of this Agreement and remedies pertaining to failure to comply with an order of
court or agreement pertaining to equitable distribution, alimony, alimony pendente lite, counsel
fees and costs as set forth in the Pennsylvania Divorce Code or other similar statutes now in
effect and as amended or hereafter enacted.
18.
ENTIRE AGREEMENT: This Agreement contains the entire understanding of the
parties and there are no representations, warranties, covenants or undertakings other than those
expressly set forth herein.
19.
APPLICABLE LAW: This Agreement shall be construed under the Laws of the
Commonwealth of Pennsylvania
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20.
PRIOR AGREEMENTS: It is understood and agreed that any and all property
settlement agreements which mayor have been executed prior to the date and time of this
Agreement are null and void and of no effect.
21.
PAYMENT OF COSTS: Each party shall be responsible for their own attorneys fees
and costs incurred in the settlement of the divorce and economic issues surrounding this divorce.
22.
WAIVER OF CLAIMS AGAINST ESTATES: Except as herein othelWise provided,
each party may dispose of his or her property in any way, and each party hereby waives and
relinquishes any and all rights he or she may now have or hereafter acquire, under the present or
future laws of any jurisdiction, to share in the property or the estate of the other as a result of the
marital relationship, including without limitation, dower, curtesy, statutory allowance, widow's
allowance, right to take in intestacy, right to take against the Will of the other, and right to act as
administrator or executor of the other's estate, and each will, at the request of the other, execute,
acknowledge and deliver any and all instruments which may be necessary or advisable to carry
into effect this mutual waiver and relinquishment of all such interests, rights and claims.
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IN WITNESS WHEREOF, the parties hereunto have set their hands and seals the day
and year first above written.
WITNESSES:
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OLGA AUB
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STEVEN K. KNAUB
(SEAL)
COMMONWEALTH OF PENNSYLVANIA
SS:
COUNTY OF CUMBERLAND
PERSONALLY APPEARED BEFORE ME, this lltk day of ~
2000, a Notary Public, in and for the Commonwealth of Pennsylvania and County of
Cumberland, OLGA H. KNAUB, known to me (or satisfactorily proven) to be the person whose
name is subscribed to the within Marriage Settlement Agreement, and acknowledges that she
executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and official seal.
Notarial Seai
Halvard E. Alexander Notary Pubiic
Dills~urg Bora, York County
My CommIssion Expires April 23, 2001
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COMMONWEALTH OF PENNSYLVANIA
SS:
COUNTY OF CUMBERLAND
PERSONALLY APPEARED BEFORE ME, this 1~ day of ~,
2000, a Notary Public, in and for the Commonwealth of Pennsylvania and County of
Cumberland, STEVEN K. KNAUB, known to me (or satisfactorily proven) to be the person
whose name is subscribed to the within Marriage Settlement Agreement, and acknowledges that
he executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and official seal.
Notarial Seal .
Betzl A Morrison, Notary Public
Carlisle Bora, cumberl8nd couni600
My CommissiOn Expires Dee, 15,
M0mbfl:' ~l"!t'S\;;;;~ Association of :: lo\arte6
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OLGA H. KNAUB,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: OF CUMBERLAND COUNTY, PENNA.
:
VS.
: NO. 00-2370 CIVIL TERM
:
STEVEN K. KNAUB,
: CIVIL ACTION - LAW
Defendant
.
.
PRAECIPE TO TRANSMIT RECORD
~o 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)) ~~~~X~ of the Divorce Code. (Strike out
inapplicable section.)
2. Date and manner of service of the complaint: Sent certified mail,
restricted delivery April 19, 2000 and was delivered to the Defendant
April 21, 2000.
3. (Complete either paragraph (a) or (b).)
(a) Date of
required by Section
December 11, 2000
December 7, 2000
execution of the affidavit of consent
3301(c) of the Divorce Code: by plaintiff
; by defendant
(b) (1) Date of execution of the plaintiff's 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: all claims are settled and
satisfied bv Marriaqe Settlement Aqreement dated December 7,
2000. siqned by both parties.
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)(1)(i) of the
Divorce Code.
6. Date
file praecipe
the decree is
Code
of Notice of Intent
December 7. 2000.
1 'ntiff - December 13'
and manner of service of the notice of intention to
to transmit record, a copy of which is attached, if
to be entered under section 3301(c) of the Divorce
, or, date of execution of waiver
Plaintiff - December 11,2000, Defendant -
and date of filing of waiver
2000 Def ndant - December 13, 2000
er
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OLGA H. KNAUB,
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PA.
NO. Co-':J.3?o G~L( ~
CIVIL ACTION - LAW
IN DIVORCE
Plaintiff
vs.
STEVEN K. KNAUB,
Defendant
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 Court House, One Courthouse
Square, Carlisle, Pennsylvania 17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS
GRANTED YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE
THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL
HELP.
Court Administrator
Cumberland County Court House
Fourth Floor
Carlisle, PA 17013
(717) 240-6222
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OLGA H. KNAUB,
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PA.
Plaintiff
vs.
NO.
STEVEN K. KNAUB,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
NOTICIA
USTED HA SIDO DEMANDADO EN LA CORTE. Si desea defenderse de las
quejas expuestas en las paginas siguientes, debe tomar accion con prontitud. Se Ie avisa que
si no se defiende, el caso puede proceder sin usted y decreto de divorcio 0 anulamiento puede
ser emitido en su contra por la Corte. Una decision puede tambien ser emitida en su contra
por cualquier otra queja 0 compensacion reclamados por el demandant. Usted puede perder
dinero, 0 propiedades u otros derechos importantes para usted.
Cuando la base para el divorcio es indignidades 0 rompimiento irreparable del
matrimonio, usted puede solicitar consejo matrimonial. Una lista de consejeros
matrimoniales esta disponible en la oficina del Prothonotry, en la Cumberland County
Courthouse, One Courthouse Square, Carlisle, Pennsylvania.
SI USTED NO RECLAMA PENSION ALIMENTICIA, PROPIEDAD MARITAL
HONORARIOS DE ABOGADO U OTROS GASTOS ANTES DE QUE EL DECRETO
FINAL DE DlVORCIO 0 ANULAMIENTO SEA EMITIDO, USTED PUEDE PERDER
EL DERECHO A RECLAMAR CUALQUlERA DE ELLOS.
USTED DEBE LLEVAR ESTE PAPEL A UN ABOGADO DE INMEDlATO. SI
NO TIENE 0 NO PUEDE PAGAR UN ABOGADO, VAYA 0 LLAME A LA OFICINA
INDlCADA ABAJO PARA A VERIGUAR DONDE PUEDE OBTENER ASISTENCIA
LEGAL.
Court Administrator
Cumberland County Court House
Fourth Floor
Carlisle, PA 17013
(717) 240-6222
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OLGA H. KNAUB,
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PA.
NO. trO ~ .237() ~ I ~
Plaintiff
vs.
STEVEN K. KNAUB,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
COMPI.AINT UNDER SECTION 3301 (C) OF THE DIVORCE CODE
COUNT I
AND NOW, this IQ~ day of
~
, 2000, comes
the Plaintiff, Olga H. Knaub, by her attorney, Jane M. Alexander, Esquire, and files this
Complaint upon a cause of action of which the following is a statement.
1. Plaintiff is Olga H. Knaub, 45 years of age, who currently resides at 202 North
Arch Street, Mechanicsburg, Pennsylvania, Borough of Mechanicsburg, Cumberland
County, Commonwealth of Pennsylvania 17055.
2. Defendant is Steven K. Knaub, 47 years of age, who currently resides at
507 Cascade Road, Mechanicsburg, Upper Allen Township, Cumberland County,
Commonwealth of Pennsylvania 17055.
3. Plaintiff and Defendant have both resided in the Commonwealth of Pennsylvania
for at least six (6) months prior to the filing of the Complaint in Divorce.
4. The Plaintiff and Defendant were married on May 14, 1977 in Trenton, New
Jersey by a Reverend.
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5. There were two (2) children born to the parties during this marriage, Michael S.
Knaub, age 21 years, born June 9, 1978, and Jennifer S. Knaub, age 19 years, born
December 31, 1980.
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6. There were no prior actions in divorce or annulment commenced by the parties.
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7. The parties have not entered into a written agreement as to alimony, counsel fees,
cost and property division.
8. The Plaintiff has been advised of the availability of counseling and that the
Plaintiff may have the right to request that the Court require the parties to participate in
counseling.
9. While the parties were domiciled within the Commonwealth of Pennsylvania, and
through no fault of Plaintiff, the innocent and injured spouse, the Defendant, in violation of
the marriage vows and the laws of the Commonwealth, has offered such indignities to the
person of the Plaintiff as to render her condition intolerable and life burdensome.
WHEREFORE, the Plaintiff prays your Honorable Court to enter a Decree of
Divorce from the bonds of matrimony.
COUNT II
10. The allegations of Paragraph one (1) through nine (9) are incorporated herein by
reference and made a part hereof.
11. The marriage is irretrievably broken.
WHEREFORE, the Plaintiff prays your Honorable Court to enter a Decree of
Divorce from the bonds of matrimony.
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II
COUNT III
12. The allegations of Paragraph one (1) through nine (9) and Paragraphs ten (10)
and eleven (11) are incorporated herein by reference and made a part hereof.
13. Plaintiff and Defendant have acquired property, both real and personal during
their marriage.
14. Plaintiff and Defendant have been unable to agree as to an equitable division of
said property.
WHEREFORE, Plaintiff requests your Honorable Court to equitably divide all
marital property of whatsoever kind and wheresoever situate and for such further relief as the
Court may deem equitable and just.
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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 Pa. C.S. Section 4904
relating to unsworn falsification to authorities.
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~01
OlgaH. aub . ~
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COMMONWEALTH OF PENNSYLVANIA
S.S
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COUNTY OF YORK
Before me, the undersigned officer, a Notary Public, in and for the said
C01llIl10nwealth and County, Personally appeared Olga H. Knaub who, being affirmed
according to law, deposes and says that the facts and matters set forth in the foregoing
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Olga H. aub .
Sworn to and subscribed before
me is 102 P7I- day of
/2A L- , 2000.
Notarial Seal
Halvard E. Alexander, Notary Public
Dillsburg Bora, York County
My Commission Expires April 23, 2001
Member, Pennsylvania Association of Notaries
II
. ---.
OLGA H. KNAUB,
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PA
VS.
NO. 00-2370 CIVIL TERM
STEVEN K. KNAUB,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
AFFIDA VIT OF SERVICE
AND NOW, this -#day of
appeared Jane M. Alexander, Esquire who swears
, 2000 personally
o law, that a true and correct
copy of a COMPLAINT IN DIVORCE was caused to be served by certified mail with return
receipt requested upon the said,
Steven K. Knaub
507 Cascade Road
Mechanicsburg, PA 17055
on April 21,2000 by leaving the same at the Dillsburg Post Office with postage pre-paid
thereon as evidenced by the mailing receipt and return receipt hereto attahced and made a
part hereof.
Sworn and subscribed before
me this ,-(9 day of
,2000.
Notary Public
Notarial Seal
HalVard E. Alexaoder. Notary Public
DlI/sburg Bore, York County
My Commission Expires April 23. 2001
Member. Pennsylvania Association of Notaries
.
OLGA H. KNAUB,
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PA
VS.
NO. 00-2370 CIVIL TERM
STEVEN K. KNAUB,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
II
PROOF OF SERVICE
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. Complete items 1 and/or 2 for additional services.
. Complete Items 3, 4a, and 4b.
. Print your name and addfess on 'the reverse of this form so that we can return Ihls
card to you. '
. Attach this form to the front of the mailpiece, or on the back if space does not
permit.
. Write. "Return Receipt Requested" on the mail piece below the article number.
. The Return Receipt will show 10 whom the article was delivered and the date
deli"llared.
3. ArtiCle Addressed to:
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LGA H. KNAUB, : IN THE COURT OF COMMON PLEAS
Plaintiff : OF CUMBERLAND COUNTY, PENNA.
VS. : NO. 00-2370 CIVIL TERM
TEVEN K. KNAUB, : CIVIL ACTION - LAW
Defendant : IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301 (c) of the
ivorce Code was filed on April 14, 2000.
2. The marriage of Plaintiff and Defendant is irretrievably
roken and ninety (90) days have elapsed from date of filing and
ervice of the Complaint.
3. I consent to the entry of a final decree of divorce
after service of notice of intention to request entry of the
decree.
I verify that the statements made in this Affidavit are true
and correct. I understand that false statements herein are made
subject to the penalties of 18 Pa. C.S. S4904 relating to unsworn
falsification to authorities.
DATE:
!;(-jf-OQ
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Olga . Knaub
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LGA H. KNAUB, : IN THE COURT OF COMMON PLEAS
Plaintiff : OF CUMBERLAND COUNTY, PENNA.
..
.
VS. : NO. 00-2370 CIVIL TERM
:
TEVEN K. KNAUB, : CIVIL ACTION - LAW
Defendant : IN DIVORCE
WAIVER OF NOTICE OF INTENTION
TO REQUEST ENTRY OF A DIVORCE DECREE
UNDER CODE S3301(c) OF THE DIVORCE CODE
1. I consent to the entry of a final decree of divorce
ithout notice.
2. I understand that I may lose rights concerning alimony,
ivision of property, lawyer's fees or expenses if I do not claim
hem before a divorce is granted.
3. I understand that I will not be divorced until a divorce
ecree is entered by the Court and that a copy of the decree will
e sent to me immediately after it is filed with the
rothonotary.
I verify that the statements made in this affidavit, are
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and correct. I understand that false statements herein are
subject to the penalties of 18 Pa.C.S. 54904 relating to
nsworn falsification to authorities.
Date:
1~_11_<S0
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OLGA H. KNAUB, IN THE COURT OF COMMON PLEAS
Pl.aintiff : OF CUMBERLAND COUNTY, PENNA.
:
VS. : NO. 00-2310 CIVIL TERM
:
STEVEN K. KNAUB, : CIVIL ACTION - LAW
Defendant : IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301 (c) of the
Divorce Code was filed on April 14, 2000.
2. The marriage of Plaintiff and Defendant is irretrievably
broken and ninety (90) days have elapsed from date of filing and
service of the Complaint.
3. I consent to the entry of a final decree of divorce
after service of notice of intention to request entry of the
decree.
I verify that the statements made in this Affidavit are true
and correct. I understand that false statements herein are made
subject to the penalties of 18 Pa. C.S. ~4904 relating to unsworn
falsification to authorities.
DATE:
/;),-?-OO
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Steven K. Knaub
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OLGA H. KNAUB, : IN THJ1: COURT OF COMMON PLEAS
Plaintiff : OF CUMBERLAND COUNTY, PENMA.
:
VS. NO. 00-2370 CIVIL TERM
:
STEVEN K. KNAUB, : CIVIL ACTION - LAW
Defendant : IN DIVORCE
WAIVER OF NOTICE OF INTENTION
TO REQUEST ENTRY OF A DIVORCE DECREE
UNDER CODE S3301(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. S4904 relating to
unsworn falsification to authorities.
Date: /:<.1-00
~_JcY~
Steven K. Knaub
e, _ ~ ___._
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OLGA H. KNAUB,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
00-2370 CIVIL TERM
STEVEN K. KNAUB,
Defendant
IN DIVORCE
PRAECIPE TO ENTER APPEARANCE
To Curtis R. Long, Prothonotary:
Please enter my appearance on behalf of the defendant, Steven K. Knaub, in the above
captioned case.
Respectfully submitted,
IRWIN, McKNIGHT & HUGHES
By:
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Douglas . Mill~r, Esquire
Attorney for Defendant, Martha E. Harry
West Pomfret Professional Building
60 West Pomfret Street
Carlisle, Pennsylvania 17013-3222
(717) 249-2353
Supreme Court I.D. No. 83776
Date: June 28th, 2000
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SOCIAL SECURITY INFORMATION SHEET
PURSUANT TO 23 Pa.C.S.A. SECTION 4304.1 (a) (3) ALL DIVORCES MUST
INCLUDE THE PARTIES SOCIAL SECURITY NUMBER
PLEASE FILL IN THE APPROPRlA TE INFORMATION AND RETURN TO TI-IE
PROTHONOTARY'S OFFICE
DATE:
December 13, 2000
DOCKET NUMBER: 00-2370 CIVIL TERM
PLAINTIFF/PETITIONER SS# 135-50-5484
NAME: Olga H. Knaub
DEFENDANT/RESPONDENT SS # 193 46 4253
NAME: steven K. Knaub
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