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IN THE COURT OF COMMON PLEAS
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OF CUMBERLAND COUNTY
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PENNA.
STATE OF
PATRrcrA A. BEEKLER,
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No. #3503 CrVrL TERM
2000
PLArNTrFF
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VERSUS
RAYMOND R. BEEKLER,
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DEFENDANT
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DECREE IN
DIVORCE
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AND NOW,
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In'a, IT is ORDERED AND
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PATRrcrA A. BEEKLER
DECREED THAT
, PLAiNTIFF,
.
RAYMOND R. BEEKLER
AND
, DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
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THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED;
A PROPERTY SETTLEMENT AGREEMENT rs ATTACHED AND MADE A PART HEREOF FOR
.
PURPOSES OF ENFORCEMENT.
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PROPERTY SETTLEMENT AGREEMENT
between Raymond R. Beekler,
residing at 718 T
, 2000, by and
THIS AGREEMENT, dated
the j 4*' day of
Hummeltown, Dauphin
County, Pennsylvania, 17036, Social Security Number 174-58-0379, hereinafter
called the "Husband", and Patricia A. Beekler formerly Lavia, residing at 105 S.
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17th Street, Camp Hill, Cumberland County, Pennsylvania, 17011, Sociar=Se~ityl
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Number 182-62-3926, hereinafter called the "Wife", who agree as fo~: _-0:: '"''''
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WHEREAS, the parties are Husband and wife, having been marriE',,~goc~erbrn
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28, 1995, in Camp Hill, Cumberland County, Pennsylvania. The parties ~par]fed~
June 2, 2000.
WHEREAS, there have been issue of the marriage, to wit: Madison Marie
Beekler, born April 3, 1997, and Samantha JoAnne Beekler, born October 17, 1999
hereinafter referred to as the Children.
WHEREAS, diverse unhappy, and irreconcilable 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 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; the settling of all matters between them relating to the past, present
and future support and or maintenance of the Children, the implementation of
custody/visitation arrangements for the minor Children of the parties; and in
general, the settling of any and all claims and possible claims by one against
the other or against their respective estates.
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
.
.
.
PENNA.
.
STATE OF
PATRICIA A. BEEKLER,
.
No. #3503
CIVIL TERM
2000
PLAINTIFF
VERSUS
RAYMOND R. BEEKLER,
.
DEFENDANT
.
.
.
.
.
.
DECREE IN
DIVORCE
.
AND NOW,
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~ , IT IS ORDERED AND
PATRICIA A. BEEKLER
.
.
DECREED THAT
, PLAINTIFF,
RAYMOND R. BEEKLER
.
.
.
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;
A PROPERTY SETTLEMENT AGREEMENT IS ATTACHED AND MADE A PART HEREOF FOR
.
.
PURPOSES OF ENFORCEMENT.
.
.
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ATTEST:
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NOW THEREFORE, in consideration of the promises 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. AGREEMENT NOT A BAR TO DIVORCE PROCEEDINGS
This Agreement shall not be considered to affect or bar the right of Wife
or Husband to a limited or absolute divorce on lawful grounds if such grounds
now exist or shall hereafter exist or to such defense as may be available to
ei ther party. This Agreement is not intended to condone and shall not be deemed
to be a condonation on the part of either party hereto of any act or acts on the
part of the other party which have occasioned the disputes or unhappy differences
which have occurred prior to or which may occur subsequent to the date hereof.
The parties intend to secure a mutual consent, no-fault divorce pursuant to the
terms of Section 3301@ of the Divorce Code of 1980 as amended by Act No. 1990,
206 effective 3-19-91.
2. EFFECT OF DECREE, NO MERGER
Other than upon a showing of substantially changed circumstances, neither
party to any such action shall ask alimony or support contrary to the provisions
of this Agreement. It is further specifically understood and agreed that the
provisions of this Agreement relating to the equitable distribution of property
of the parties are accepted by each party as a final settlement for all purposes
whatsoever. Should either of the parties obtain a decree, judgment, or order of
separation or divorce in any other state, country, or jurisdiction, each of the
parties to this Agreement hereby consents and agrees that this Agreement and all
of its covenants shall not be affected in any way by any such separation or
divorce; and that nothing in any such decree, judgment, order, or further
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modification or revision thereof shall alter, amend or vary any term of this
Agreement, whether or not either or both of the parties should remarry, it being
understood by and between the parties that this Agreement shall survive and shall
not be merged into any decree, judgment, or order of divorce or separation.
It is further understood that Pennsylvania law provides that "a provision
of an Agreement regarding child support, visitation or custody shall be subject
to modification by the Court upon a showing of changed circumstances".
It is specifically agreed, however, that a copy of this Agreement may be
incorporated, by reference, into divorce judgment or decree. This incorporation,
however, shall not be regarded as a merger, it being the intent of the parties
to permit this Agreement to survive any such judgment, unless otherwise
specifically provided herein, and for this Agreement to continue in full force
and effect after such time as a final decree in divorce may be entered with
respect to the parties. The parties agree that the terms of this Agreement may
be incoJ'porated into any divorce decree which may be entered with respect to them
for purposes of enforcement only of any provisions therein, but shall survive
such decree.
That is, this agreement and all warranties and representations contained
herein shall survive the Divorce Decree and shall continue to be enforceable in
accordance with its terms, Except with regard to child support and child
custody, no court may change the terms of this agreement, and it shall be binding
and conclusive upon the parties, In the event of a reconciliation, attempted
reconciliation, or other cohabitation of the parties hereto after the date of
this agreement, this agreement shall remain in full force and effect in the
absence of a written agreement signed by both parties expressly stating that this
agreement has been revoked or modified.
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3, DISTRIBUTION DATE
The transfer of property, funds and/or documents provided for herein shall
take place simultaneously with the execution of this Agreement,
4, ADVICE OF COUNSEL
This Agreement has been prepared by Ruby D. Weeks, Esquire, the attorney
for Wife. Said attorney at the commencement of, and at all stages during the
negotiation of this Agreement, informed Husband that she has acted solely as
counsel for Wife and has not advised or represented Husband in any manner
whatsoever.
Husband, at the commencement of, and all stages during the
negotiation of this Agreement, has been informed by Ruby D. Weeksl Esquire, that
he has a right to be represented by his own counsel and has encouraged him to
seek the advice of counsel. Husband has read this Agreement carefully and
thoroughly, fully understanding each of its provisions, and therefore signs it
freely and voluntarily.
5. FINANCIAL DISCLOSURE
The parties confirm that each has relied on the substantial accuracy of the
financial disclosure of the other as an inducement to the execution of this
Agreement, and that Wife does not wish to exercise her right to have appraisals
by experts as to the value of the various interests of Husband. She understands
that such appraisals would be necessary to fix the fair market value of these
interests for purposes of equitable distribution.
6. WARRANTY OF DISCLOSURE
The parties warrant and represent that they have made a full disclosure of
all assets and their valuation prior to the execution of this Agreement. This
disclosure was in the form of an information exchange of information by the
parties' attorneys and this Agreement between the parties is based upon this
disclosure.
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7. OBTAINING INFORMATION ON FINANCES
Each party acknowledges that they have been informed they may have the
right, as provided by statute and Pennsylvania Rules of Civil Procedure, to
obtain information regarding the parties' finances. Such information would
include, without limitation, their present and past incomei and the identity and
value of assets both presently owned and transferred previously, Such
information may be obtained by one or more of several methods including
depositions upon oral examination, written interrogatories, production of
documents or entry upon property for inspection. The parties agree to waive any
further discovery.
8. FILING INVENTORIES AND APPRAISEMENT
The parties further acknowledge their understanding that they each have the
right to file Inventories and Appraisement with the Court and to require the
other party to do so. Such Inventories and Appraisement require a party to
indicate, under oath, information regarding all marital property in which either
party has an interest as of the date the action was commenced. Fully knowing the
same, each party nonetheless waives their respective rights to request additional
discovery be conducted, to file Inventories and Appraisement with the Court, or
to require the other party to do so.
9. PERSONAL RIGHTS
Wife and Husband may and shall, at all times hereafter, live separate and
apart. They shall be free from any control, restraint, interference or
authority, direct or indirect, by the other in all respects as fully as if they
were unmarried, They may reside at such place or places as they may select,
Each may, for his or her separate use or benefit, conduct, carryon and engage
in any business, occupation, profession or employment which to him or her may
seem advisable. However, each party shall make best efforts to maintain
employment with comparable benefits and salary as they now hold or for which they
are in training.
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10. MUTUAL RELEASES
Husband and Wife each do hereby mutually remise, release, quitclaim 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, title and
interest, or claims in or against the property (including income and gain from
property hereafter accruing) of the other or against the estate of such other,
of whatever nature and wheresoever situate, which he or she now has or at any
time hereafter may have against such other, the estate of such other or any part
thereof, whether arising out of any former acts, contracts, engagements or
liabilities of such other or by way of dower or curtesy, or claims in the nature
of dower or curtesy or widow's or widower1s rights, family exemption or similar
allowance, or under the intestate laws, or the right to take against the spouse 1 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 spouse1s
estate, whether arising under the laws of (a) Pennsylvania, (b) any State,
Commonwealth or territory of the United States, or @ any other country, or any
rights which either party may have or at any time hereafter have for past,
present or future support or maintenance, alimony, alimony pendente lite, counsel
fees, equitable distribution, 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 Husband
and Wife to give to each other by the execution of this Agreement a full,
complete and general release with respect to any and all property of any kind or
nature, real, personal or mixed, which the other now owns or may hereafter
acquire, except and only except all rights and agreements and obligations of
whatsoever nature arising or which may arise under this Agreement or for the
breach of any thereof.
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11. DISTRIBUTION OF PERSONAL PROPERTY:
The parties hereto mutually agree that they have effected a satisfactory
division of the furniture, household furnishings, appliances, and other household
personal property between them as per Appendix "A" attached hereto and made a
part hereof, and they mutually agree that each party shall from and after the
date hereof be the sole and separate owner of all such tangible personal property
presently in his or her possession, and this Agreement shall have the effect of
an assignment Or bill of sale from each party to the other for such property as
may be in the individual possession of each of the parties hereto.
The parties hereto have divided between thernsel ves I to their mutual
satisfaction, all items of tangible and intangible marital property. Neither
party shall make any claim to any such items of marital property, or of the
separate personal property of either party, which are now in the possession
and/or under the control of the other. Should it become necessary, the parties
each agree to sign, upon request, any titles or documents necessary to give
effect to this paragraph. Property shall be deemed to be in the possession or
under the control of either party if, in the case of tangible personal property,
the item is physically in the possession or control of the party at the time of
the signing of this Agreement and, in the case of intangible personal property,
if any physical or written certificate of insurance or other similar writing is
in the possession or control of the party. Husband and Wife shall each be deemed
to, be in the possession and control of his or her own individual pension or other
employee benefit plans or retirement benefits of any nature with the exception
of social security benefits to which either party may have a vested or contingent
right or interest at the time of the signing of this Agreement, and neither will
make any claim against the other for any interest in such benefits.
From and after the date of the signing of this Agreement both parties shall
have complete freedom of disposition as to their separate property and any
property which is in their possession or control pursuant to this Agreement, and
may mortgage, sell, grant, convey I or otherwise encumber or dispose of such
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property, whether real or personal, whether such property was acquired before,
during or after marriage, and neither Husband nor Wife need join in, consent to,
or acknowledge any deed, mortgage, or other instrument of the other pertaining
to such disposition of property.
12. GENERAL:
(1) Husband hereby waives all interest in Wife's property including
but not limited to all accounts, certificates of deposit and securities.
(2) Wife hereby waives all interest in Husband's property
including but not limited to all accounts, certificates of deposit, and
securities.
(3) Husband and Wife agree that Husband shall pay all costs,
including attorney fees, of transferring any property necessary to be
titled from joint ownership to that of either party.
13. MOTOR VEHICLES:
With respect to the motor vehicles owned by one or both of the parties,
they agree as follows:
(a) The 1999 Jeep titled jointly, shall become and remain the sole
and exclusive property of the Husband. It is security for a loan at All
First Bank, loan number 20-0000-0005-9868, and Husband agrees to indemnify
and hold harmless the Wife from any and all liability for this debt.
(b) The 1996 Dodge Stratus, titled jointly, shall become and remain
the sole and exclusive property of the Wife. It is security for a lease
at Allfirst Bank, lease number 231-98-13567, and Wife agrees to indemnify
and hold harmless the Husband from any and all liability for this debt.
14. DOCUMENTS TO BE FURNISHED:
Both Husband and Wife agrees to provide each other with information as to
policy numbers, company names and addresses, and proof of beneficiary
designations of any and all life insurance policies mentioned in this Agreement.
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Additionally, ,Husband agrees to provide wife with copies of any and all joint tax
returns filed by the parties.
15. AFTER-ACQUIRED PERSONAL PROPERTY
Each of the parties shall hereafter own and enjoy, independently of any
claim or right of the other, all items of personal property, tangible and
intangible, subsequently acquired by the other party.
16. PAYMENT OF SP~CIFIED OBLIGATIONS.
A. During the course of the marriage, Wife and Husband have incurred
certain bills and obligations and have amassed a variety of debts, and it
is hereby agr~ed, without the necessity of ascertaining for what purpose
and to whose Use each of the bills were incurred, that Husband shall be
solely responsible for all bills, obligations and debts as set forth
below:
1. Loan for old jeep, Ford Credit Company, Loan number JJA275D42Y,
approximate balance $2,953.00
2. Capital One, credit card number 4121-7414-2368-2249, approximate
balance $4,937.53
The Wife shall be solely responsible for all bills, obligations and debts
as set forth below:
1. Loan at First National Bank of Maryland, loan number 68279698001001,
approximate balance $1,650.00
2. Visa th:tough BankCord Services, credit card number 4336009010877882,
approximate balance $1,434.00.
3. Sears credit card, credit card number 0362090868708, approximate
balance $1,918.71
B. Each party agrees to hold the other harmless from any and all
liability which may arise from the aforesaid bills and which,
pursuant to the terms herein, are not the responsibility of the
other party.
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17. SUBSEQUENT PERSONAL DEBTS:
Husband and Wife agree from time of the signing of this Agreement that each
party shall be responsible for their own debts and hold each other harmless from
same.
18, FUTURE DEBTS:
Husband and Wife hereby mutually agree that subsequent to the execution of
this Agreement neither party shall incur any debts which will obligate the other
to make payment for same. Husband and Wife hereby acknowledge that there are no
outstanding bills or other indebtedness which have been incurred by either for
the liability of the other, and both parties hereby covenant and agree that
neither shall have any financial obligation to pay any financial obligations
which are solely the financial obligation of the other and which have been
contracted by either party solely for their own benefit and without the knowledge
or consent of the other party. Husband and Wife further agree that they will
indemnify the other from any and all claims or demands made against the other by
reason of any debts or obligations contracted in violation of this Agreement.
19, WARRANTY AS TO EXISTING OBLIGATIONS:
Each party represents that they have not heretofore incurred or contracted
for any debt or liability or obligation for which the estate of the other party
may be responsible or liable except as may be provided for in this Agreement,
Each party agrees to indemnify or hold the other party harmless from and against
any and all such debts, liabilities or obligations of every kind which may have
heretofore been incurred by them, including those for necessities, except for
the obligations arising out of this Agreement.
20. WARRANTY AS TO FUTURE OBLIGATIONS:
Wife and Husband each covenant, warrant, represent and agree that each will
now and at all times hereafter save harmless and keep the other indemnified from
all debts, charges and liabilities incurred by the other after the execution
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date of' this Agreement, except as may be otherwise specifically provided for by
the terms of this Agreement and that neither of them shall hereafter incur any
liability whatsoeve~ for which the estate of the other may be liable.
21. 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.
22. HIGHER EDUCATION, POST HIGH SCHOOL VOCATIONAL EXPENSES OF THE CHILD
Husband agrees to be responsible for the reasonable cost of undergraduate
college education Or post high school vocational training for the Children
including but not limited to the following: tuition, room I board, books,
supplies, fees, transportation, and clothing based on the same ratio as his
income bears to wife's. The tuition to be apportioned between the parties shall
not exceed the tuition amount for a state school. Husband's obligation pursuant
to this Paragraph is conditioned upon his being consulted with respect to the
choice of educational institutions and his approval thereof obtained, provided,
however, that Husband's approval shall not be unreasonably withheld, providing
that the Children have made a reasonable effort to obtain scholarship and other
financial aid which shall first be deducted from the total cost of undergraduate
college education. Husband does agree that the obligations imposed herein shall
take precedence over any college expenses and costs for any future adopted or
step-children of Husband.
23. RETIREMENT FUNDS
A. The Wife, who has been employed by Clarity Vision, 100 Senate Avenue,
Senate Plaza, Camp Hill, pennsylvania, has accumulated benefits in her
retirement account, It is agreed by the parties that the Husband shall
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waive any interest he may have in any of the benefits, including
retirement, which the Husband may have as a result of his employment.
B. The Husband, who is employed at Allegheny Valley School, 1291
Middletown Road, Hummelstown, Pennsylvania, also has retirement and other
employee benefits. It is agreed by the parties that the wife shall waive
any interest she may have in any of the benefits, including retirement,
which the Husband may have as a result of her employment.
24. LIFE INSURANCE
Both parties shall continue to maintain all current life insurance
policies on their lives even in the event their employment changes, naming the
Children solely as irrevocable beneficiaries of such policies until such time as
each Child reaches the age of twenty-one (21). They shall each provide a written
list to the other setting forth the insurance company(s), policy number(s), and
principal amount(s) of such insurance as provided above with proof of
beneficiary.
They also agree not to borrow against or assign said policies
without prior written consent of the other party. Both Parties agree to make
payment of premiums on the policies on their individual lives so as to continue
said coverage as long as each Child is owed a duty of support.
25 . DIVORCE
Husband and Wife agree that Wife shall file a Complaint in divorce seeking
a divorce on the basis of mutual consent. Husband and Wife both agree that
ninety (90) days following the filing of a Divorce Complaint by Wife that both
parties will execute the required Affidavits of Consent to be filed with the
Court to allow the Court to grant a divorce on the basis of mutual consent.
Husband agrees to pay all counsel fees, costs, and expenses incident to
obtaining the aforesaid divorce.
26. ALIMONY
The amount and/or duration of alimony shall not be modified upward or
downward for any reason and the parties release any rights they may have to seek
modification with respect to the provisions of this paragraph. Husband agrees
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to pay the wife Alimony in the amount of $75.00 per month for 36 months
commencing date of divorce decree. Husband agrees to pay Wife's attorney fees
and cost of divorce, preparing and filing custody stipulation and property
settlement agreement.
27. WILLS
The parties hereby contract and agree to include in their will a provision
whereby each will name the parties! minor children as heirs to at least one-half
of the testator's estate and that such interest shall be held in trust for a
child who is under the age of twenty-five (25), and naming the other parent as
Trustee of such inheritance.
28. BREACH OF AGREEMENT
If either party fails in the due performance of obligations under this
Agreement at their election, the non-breaching party shall have the right to sue
for damages for breach of this Agreement or to rescind same and seek such legal
remedies as may be available to them. The breaching party will be responsible
for actual legal fees and costs incurred by the non-breaching party necessary to
the enforcement of this Agreement.
29. LAW OF PENNSYLVANIA APPLICABLE
This Agreement shall be construed in accordance with the laws of the
Commonwealth of Pennsylvania which are in effect as of the date of execution of
this Agreement.
30. AGREEMENT BINDING ON HEIRS
This Agreement shall be binding and shall inure to the benefit of the
parties hereto and their respective heirs, executors, administrators, successors
and assigns.
31. SEVERABILITY
If any term, condition, clause or provision of this Agreement shall be
determined or declared to be void or invalid in law or otherwise, then only that
term, condition, clause or provision shall be stricken from this Agreement and
in all other respects this Agreement shall be valid and continue in full force,
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effect and operation. Likewise, the failure of any party to meet her or his
obligations under anyone or more of the paragraphs herein, with the exception
of the satisfaction of the conditions precedent, shall in no way avoid or alter
the remaining obligations of the parties.
32. INTEGRATION
This Agreement constitutes the entire understanding of the parties and
supersedes any and all prior agreements and negotiations between them. There are
no representations or warranties other than those expressly set forth herein.
33. NO WAIVER OF DEFAULT
This Agreement shall remain in full force and effect unless and until
terminated under and pursuant to the terms of this Agreement. The failure of
either party to insist upon strict performance of any of the provisions of this
Agreement shall in no way affect the right of such party hereafter to enforce
the same, nor shall the waiver of any breach of any provision hereof be
construed as a waiver of any subsequent default of the same or similar nature,
nor shall it be construed as a waiver of any subsequent default of the same or
similar nature, nor shall it be construed as a waiver of strict performance of
any other obligations herein.
34. WAIVER OR MODIFICATION TO BE IN WRITING
No modification or waiver of any of the terms hereof 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.
35. SUBSEOUENT DIVORCE
It is contemplated that Wife will proceed with a Complaint in Divorce
against Husband in the near future. Husband and Wife each agree to sign an
Affidavit of Consent and an Affidavit waiving counseling to be filed in said
divorce action. In the event such divorce action is concluded, Husband shall be
entitled to receive a copy of the Decree in Divorce for the normal fee charged
by the Prothonotary and shall not be assessed any costs of the proceeding, except
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as previously agreed to herein in Paragraph twenty five (25) regarding attorney
fees and costs. In the event such divorce action is concluded, the parties shall
be bound by all the terms of this Agreement, which shall not be incorporated by
reference into the Divorce Decree, and this Agreement shall not be merged in such
Decree, but shall in all respects survive the same and be forever binding and
conclusive upon the parties.
36. MUTUAL COOPERATION
Each party shall, at any time and from time to time hereafter, take any and
all steps and execute, acknowledge and deliver to the other party any and all
further instruments and/or documents that the other party may reasonably require
for the purpose of giving full force and effect to the provisions of this
Agreement.
37. AGREEMENT BINDING ON HEIRS
This Agreement shall be binding and shall inure to the benefit of the
parties hereto and their respective heirs, executors, administrators, successors
and assigns.
38. HEADINGS NOT PART OF AGREEMENT
Any headings preceding the text of the several paragraphs and subparagraphs
hereof are inserted solely for convenience of reference and shall not constitute
a part of this Agreement nor shall they affect its meaning, construction or
effect.
39. BANKRUPTCY
In the event that either party becomes a debtor in any bankruptcy or
financial reorganization proceedings of any kind while any obligations remain to
be performed by that party for the benefit of the other party pursuant to the
provisions of this Agreement, the debtor spouse hereby waives, releases and
relinquishes any right to claim any exemption (whether granted under state or
federal law) to any property remaining in the debtor as a defense to any claim
made pursuant hereto by the creditor-spouse, and the debtor-spouse hereby
assigns, transfers, and conveys to the creditor-spouse an interest in all of the
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debtor's exempt property sufficient to meet all obligations to the creditor-
spouse as set forth herein, including all attorneys' fees and costs incurred in
the enforcement of this Paragraph or any other provision of this Agreement.
No obligation created by this Agreement shall be discharged or
dischargeable, regardless of federal or state law to the contrary, and each party
waives any and all right to assert that any obligation hereunder is discharged
or dischargeable.
IN WITNESS WHEREOF, the parties hereto have set their hands and seals the
day and year first above written.
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Raymo R. Beekler
P~AA, A ~d,j~;)
Patricia A. Beekler
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COMMONWEALTH OF PENNSYLVANIA
ss
COUNTY OF CUMBERLAND
On this, the t('$-day of9p~/ , 2000, before me, a Notary
Public, the undersigned officer, personally appeared, Raymond R. Beekler, known
to me to be the person whose name is subscribed to the within Property Settlement
Agreement, and acknowledged that he executed the same for the purposes therein
contained.
-.-
NOt~~/1 ~~
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
D Sue A. Kohr, Notary Public
My C erry,Twp" Dauphin C0untv
ommlssJOn expires May f." 20134
Member,PennSYlyani;;1AsSoclaticfl ;Nctar;es
ss
COUNTY OF CUMBERLAND
On this, the .l~ day
of
~ <;) . ~ ,2000, before me, a Notary
personally appeared, Patricia A. Beekler, known
Public, the undersigned officer,
to me to be the person whose name is subscribed to the within Property Settlement
Agreement, and acknowledged that she executed the same for the purposes therein
contained.
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PATRICIA A. BEEKLER,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
IN DIVORCE
#3503 CIVIL TERM 2000
RAYMOND R. BEEKLER,
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 Section 3301(c) (Consent)
2. Date and manner of service of the complaint: Served on June 22. 2000 certified mail
restricted delivery No. 7099 3400 0004 5215 2883. service was accented on June 24. 2000
3. Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce
Code: by the plaintiff October 13. 2000 ; by the defendant October 12. 2000
4.
Related claims pending:
None
5. Date plaintiffs Waiver of Notice in S 3301(c) Divorce was filed with the prothonotary:
October 19. 2000.
Date defendant's Waiver ofN otice in S 330 I (c) Divorce was filed with the prothonotary:
October 16. 2000
Date: October 31, 2000
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Ruby D. eks, Esquire
Attorney for the Plaintiff
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PATRICIA A. BEEKLER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
IN DIVORCE
RAYMOND R. BEEKLER,
Defendant
# fro. 3 )0.] CIVIL TERM
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 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, 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.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
717-249-3166
,
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PATRICIA A. BEEKLER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
IN DIVORCE
RAYMOND R. BEEKLER,
Defendant
II 00 - 3 S' /i.:3 CIVIL TERM
AFFIDAVIT OF MARRIAGE COUNSELING
I, Patricia A. Beekler, being duly sworn according to law, depose and say:
1. I have been advised of the availability of marriage counseling and
understand that I may request that the Court require that my spouse and I
particip~te in counseling.
2. I understand that the Court maintains a list of marriage counselors in the
Prothonotary's Office, which list is available to me upon request.
3. Being so advised, I do not request that the Court require that my spouse
and I participate in counseling prior to a divorce decree being handed
down by the Court.
I understand that false statements herein are made subject to the penalties
of 18 Pa. C.S. ~4904 relating to unsworn falsification to authorities.
Dated: (p. j- 00
~>v A &1du..J
patricia A. Beekler, Plaintiff
Sworn and SubsC~ to
bef~ me this ,...
of .J I q'\ I
(j~~ ~cuJ
Notary Public
day
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NOrAlllAL 8IW
eAIlOl A. MOIIIIDW, IoIrIIaIr .......
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My eo......... &pi.... June 28, 2003
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PATRICIA A. BEEKLER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
IN DIVORCE
RAYMOND R. BEEKLER,
Defendant
# Uv- -2,5'03CIVIL TERM
COMPLAINT IN DIVORCE
TO THE HONORABLE, THE JUDGES OF SAID COURT:
AND NOW COMES, patricia A. Beekler, Plaintiff, by her attorney, Ruby D.
Weeks, Esquire, who avers as follows:
1. Plaintiff, an adult sui juris, is patricia A. Beekler, a U. S. citizen,
who currently resides at 105 S. 17th Street, Camp Hill, Cumberland
County, Pennsylvania 17011, since June 2, 2000.
2. Defendant, an adult sui juris, is Raymond R. Beekler, a U. S. citizen,
who currently resides at 718 Trail Road, Hummelstown, Dauphin County,
Pennsylvania 17036, since July, 1995.
3. Plaintiff and Defendant have been a bona fide resident(s) in the
Commonwealth of Pennsylvania for at least six months immediately
previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on October 28, 1995, at Camp
Hill, Cumberland County, Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the
parties in this or any other jurisdiction.
6. Neither party is a member of the Armed Forces of the United States.
7. The marriage is irretrievably broken.
8. Plaintiff and Defendant have lived separate and apart since June 2,
2000.
9. 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.
10. Plaintiff requests the Court to enter a decree of divorce.
COUNT I (A)- INDIGNITIES
3301 (a) (6) of the Divorce Code
11. Paragraphs 1 through 10 are hereby incorporated by reference and made a
part hereof.
12. The averments under this Count are not collusive.
13. Defendant has offered such indignities to Plaintiff, the innocent and
injured spouse, as to render her condition intolerable and life
burdensome.
COUNT II - IRRETRIEVABLE BREAKDOWN
3301 (c) of the Divorce Code
14. Paragraphs 1 through 13 are hereby incorporated by reference and made a
part hereof.
15. The marriage is irretrievably broken.
a. Plaintiff and Defendant have lived separate and apart since June 2,
2000.
16. Plaintiff has been advised as to the availability of counseling and that
she may have the right to request that the Court require the parties to
participate in counseling.
17. Plaintiff requests the Court to enter a decree of divorce.
COUNT III - REOUEST FOR DIVISION OF PROPERTY
UNDER SECTION 53502 OF THE DIVORCE CODE
18. Paragraphs 1 through 17 are hereby incorporated by reference and made a
part hereof.
19. The parties purchased or otherwise obtained during the course of their
marriage property which is considered "marital property".
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20.
Upon entry of a divorce decree, such property should be divided equitably
as is just and proper.
COUNT IV - CHILD CUSTODY
21. Paragraphs 1 through 20 are hereby incorporated by reference and made a
part hereof.
22. There were children born of the marriage:
a. Madison Marie Beekler, born April 3, 1997.
b. Samantha JoAnne Beekler, born October 17, 1999.
Said children were not born out of wedlock.
23. Said children are presently in the custody of their mother, Patricia A.
Beekler herein, who resides at 105 S. 17th Street, Camp Hill, Cumberland
County, Pennsylvania.
24. During the past five years, the children have resided with the following
persons and at the following addresses:
a. From birth to June 2, 2000 with Raymond and patricia A. Beckler at
718 Trail Road, Hummelstown, Dauphin County, Pennsylvania.
25. Plaintiff has not participated as a party or witness, or in another
capacity, in other litigation concerning the custody of the children in
this or another Court.
26. Plaintiff has no information of a custody proceeding concerning the
children pending in a Court of this Commonwealth or in any other Court in
any other jurisdiction.
27. Plaintiff does not know of a person not a party to the proceedings who has
physical custody of the children or claims to have custody or visitation
rights with respect to the children.
28. Each parent whose parental rights to the children have not been terminated
and the persons who have physical custody of the children have been named
as parties to this action. There are no other persons who are known to
~,
have or claim a right to custody or visitation of the children, to
intervene.
29. The best interests and permanent welfare of the children and their
physical, spiritual, emotional and moral well-being will be served by
granting the relief requested.
30. Plaintiff requests joint, shared legal custody of the children, with
physical custody of the children to be with the mother. Liberal
visitation of the children with the father shall be as the Court deems in
the best interests of the children.
COUNT V - CHILD SUPPORT
31. Paragraphs 1 through 30 are hereby incorporated by reference and made a
part hereof.
32. Plaintiff lacks sufficient means of support at present to fully provide
for the reasonable needs of their children, despite the fact she is
employed. Plaintiff requests an award of child support for the following
children of the parties: Madison Marie Beekler, born April 3, 1997 and
Samantha JoAnne Beekler, born October 17, 1999. The children currently
resides with the Plaintiff.
33. Plaintiff requires reasonable support to adequately maintain herself and
the children in accordance with the standard of living established during
the marriage.
34. Defendant is financially able to provide for the reasonable needs of
Plaintiff and the children.
COUNT VI - ALIMONY AND ALIMONY PENDENTE LITE
35. Paragraphs 1 through 34 are hereby incorporated by reference and made a
part hereof.
36. Plaintiff lacks sufficient means of support at present to fully provide
for her reasonable needs, despite the fact she is employed. Plaintiff
requests an award of alimony pendente lite.
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37. Plaintiff requires reasonable support to adequately maintain herself in
accordance with the standard of living established during the marriage.
38. Defendant is financially able to provide for the reasonable needs of
Plaintiff.
COUNT VII. COUNSEL FEES, COSTS, EXPENSES
39. Plaintiff, patricia A. Beekler, has retained the services of Ruby D.
Weeks,
Esquire,
and the counsel fees,
costs,
and expenses for
representation in this action will be substantial and continuing.
40. Plaintiff is without sufficient funds, income, or assets to pay such
counsel fees, costs, and expenses.
41. Plaintiff will need to retain the services of an appraiser and other
experts with regard to this action.
42. Defendant is financially able to provide for these expenses of Plaintiff.
WHEREFORE, plaintiff prays that a decree in divorce be entered divorcing
plaintiff from the bonds of matrimony between the said plaintiff and defendant.
1.
a.
As to Count I, that a decree in divorce be entered divorcing
Plaintiff from the bonds of matrimony between the said Plaintiff and
Defendant.
b. As to Count II, in the alternative, should Defendant execute an
Affidavit consenting to a divorce because the marriage is
irretrievably broken, that a decree in divorce be entered divorcing
Plaintiff from the bonds of matrimony between the said Plaintiff and
Defendant.
b. As to Count III, that this Court determine marital property and
order an equitable distribution thereof.
1-.,...."
.
,
c. As to Count IV,that joint, shared legal custody of the minor
children, Madison Marie Beekler, born April 3, 1997, and Samantha
JoAnne Beekler, born October 17, 1999 be awarded with physical
custody of the children to be with the mother, and liberal
visitation of the children with the father shall be as the Court
deems in the best interests of the children.
d. As to Count V, that Plaintiff be awarded child support for the
parties' children.
e. As to Court VI, that Plaintiff be awarded alimony pendente lite
until final hearing and permanent alimony thereafter.
f. As to Count VII, that this Court enter an award for preliminary and
interim counsel fees, costs and expenses and to enter a final award
of counsel fees, costs, and expenses.
g. Such other additional relief as the Court deems necessary and
appropriate.
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. ~4904, relating to unsworn falsification to authorities.
Date: (b-J-OO
A~~ A&~
Patricia A. Beekler
R~k~
Attorney for Plaintiff
10 West High Street
Carlisle, PA 17013
(717) 243-1294
.'
COMMONWEALTH OF PENNSYLVANIA
ss
COUNTY OF CUMBERLAND
The above named, patricia A. Beekler, being duly sworn according to law,
deposes and says that the facts contained in the foregoing Complaint are true
and correct, and the Complaint is not made out of levity or by collusion
between her and the said Defendant for the mere purpose of being freed and
separated from each other, but that it is brought in sincerity and in truth
for the cause mentioned in the said Complaint.
4awaJ vi &MJ
Patricia A. Beekler, Plaintiff
Sworn and subscribed to
before me this ~ day
of ~\ .-,,,,0. , 2OCSD.
C'Q..A.rJ}~, ~~
Notary Public
NOrAIIAL SEAl.
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PATRICIA A. BEEKLER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
IN DIVORCE
?,1:JOO
#~"2000 CIVIL TERM
RAYMOND R. BEEKLER,
Defendant
AFFIDAVIT OF SERVICE BY MAIL
PURSUANT TO PA R.C.P. 1920.4 (al (ll (iil
COMMONWEALTH OF PENNSYLVANIA
ss
COUNTY OF CUMBERLAND
I, RUBY D. WEEKS, ESQUIRE, Attorney for Patricia A. Beek1er, being duly
sworn according to law, depose and say that a true and correct copy of the
Divorce Complaint, was served on Raymond R. Beekler, at 718 Trail Road,
Hummelstown, Dauphin County, Pennsylvania, 17036, by mailing the same to him
by, postage prepaid, certified mail, restricted delivery, No. 7099 3400 0004
5215 2883, on June 22, 2000. Service was accepted on June 24, 2000.
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Ruby D. W~s, Esquire
Sworn and subscriq~ to
befo~ this ~ day.
of J) , 20QJl..
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PATRICIA A. BEEKLER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
IN DIVORCE
RAYMOND R. BEEKLER,
Defendant
#3503 CIVIL TERM 2000
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed
on June 30, 2000.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety
(90) days have elapsed from the date of filing and service of the
Complaint.
3. I consent to the entry of a final decree of divorce after service of
notice of intention to request entry of the decree.
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 falsification to authorities.
Dated: lO- 13- 0 0
~uA~A&iCJ
patricia A. Beekler, Plaintiff
SiFi and" s, Ub,S, c, ;3jkd to
b .qme~s I day
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PATRICIA A. BEEKLER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
IN DIVORCE
RAYMOND R. BEEKLER,
Defendant
#3503 CIVIL TERM 2000
WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY
OF DIVORCE DECREE UNDER S 3301 (e) 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. 5 4904 relating to unsworn falsification to authorities.
Date:
/ (J-/...3-(){)
v2 v? ~
air.lA'J~J :4 15#12111.
patricia A. Beekler, Plaintiff
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PATRICIA A. BEEKLER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
IN DIVORCE
RAYMOND R. BEEKLER,
Defendant
#3503 CIVIL TERM 2000
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed
on June 30, 2000.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety
(90) days have elapsed from the date of filing and service of the
Complaint.
3. I consent to the entry of a final decree of divorce after service of
notice of intention to request entry of the decree.
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. 54904 relating to unsworn falsification to authorities.
Dated: /b -I'z,-OU
Q.~J>.go~Q.po. ,
Raym d R. Beekler, Defendant --
Sworn and subscribed to
befor~e this.42J;& day
of!)A' r;i./4 , , 20~
-~p /(~
Notary Public
Notarial Seal
Sue A Kohr, Notary Public
Oerry.1wp., Dauphin Counly
My Commission Expires May 1, 2004
Member, Pennsylvania Association otNotarjes
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PATRICIA A. BEEKLER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
IN DIVORCE
RAYMOND R. BEEKLER,
Defendant
#3503 CIVIL TERM 2000
WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY
OF DIVORCE DECREE UNDER S 3301 eel 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. S 4904 relating to unsworn falsification to authorities.
Date:
IO"(Z~OO
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Raymo R. Beekler, Defendant
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P~TRICI~ A. BEEKLER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
IN DIVORCE
RAYMOND R. BEEKLER,
Defendant
#3503 CIVIL TERM 2000
PRAECIPE TO WITHDRAW COUNTS IN DIVORCE
TO THE OFFICE OF THE PROTHONOTARY:
Please withdraw the previous requests for Request for Division of Property,
Child Custody, Child Support, Alimony and Alimony Pendente Lite, Counsel Fees,
Costs, Expenses in the above captioned divorce action since these matters have
been satisfactorily resolved between the parties through a Property Settlement
Agreement entered into July 14, 2000.
Dated: 10-.31- OD ~
ce: Ruby D. Weeks, Esquire
Raymond R. Beekler, Pro Se
E. Robert Elicker, Esquire, Master in Divorce
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PATRICIA A. BEEKLER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
IN CUSTODY
RAYMOND R. BEEKLER,
Defendant
#3603-~ooo CIVIL TERM
ORDER OF COURT
AND NOW,
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this (}O day of
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I 2~ I upon agreement of the
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parties, the attached Custody Stipulation and Agreement is made an Order of
Court.
Ruby D. Weeks, Esquire For Plaintiff
Raymond R. Beekler, Pro Se
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PATRICIA A. BEEKLER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
IN CUSTODY
RAYMOND R. BEEKLER,
Defendant
#
CIVIL TERM
CUSTODY STIPULATION AND AGREEMENT
This Agreement and Stipulation entered into the day and year hereinafter
set forth, is by and between patricia A. Beekler, natural mother, by her
attorney, Ruby D. Weeks, Esquire, and Raymond R. Beekler, natural father, who
aver as follows:
I. Plaintiff is patricia A. Beekler natural mother and an adult sui juris,
who resides at 105 S. 17th Street, Camp Hill, cumberland County,
Pennsylvania, 17011.
II. Defendant is Raymond R. Beekler natural father and an adult sui juris, who
resides at 718 Trail Road, Hummelstown, Dauphin County, Pennsylvania,
17036
III. Mother and father are the parents of two children, Madison Marie Beekler,
born April 3, 1997 and Samantha JoAnne Beekler, born October 17, 1999.
IV. The parties, Patricia A. Beekler and Raymond R. Beekler, agree to the
following custody terms regarding custody of Madison Marie Beekler and
Samantha JoAnne Beekler, and request the terms be entered as an Order of
Court:
A. The parties shall have joint, shared, legal custody of the children.
B. The mother shall have actual physical custody of the children, with
partial custody awarded to the father as follows:
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1. A. Father shall have the children every Wednesday, father shall pick
the children up from daycare in the afternoon and return them to
daycare the following morning.
B. The father shall have the children every other weekend, from
Friday afternoon, beginning the weekend following the signing of the
this agreement by both parties, when the father shall pick the
children up from daycare and return them to daycare the following
Monday morning.
C. Once Madison starts school, the above shall be modified so that
the father shall return the children to the mother at 8:00 p.m. on
Wednesday and at 8:00 p.m. on Sunday every other weekend.
D. The father shall have partial custody for two weeks each summer,
not consecutively, and shall provide notice of the dates to the
mother by May 30 of each year. For the 2000, the father is able to
have only one week during the summer.
E. 1. Commencing with July 4th, 2000, when the father shall have
partial custody, the parties agree to alternate the following
holidays: New Years, Easter Sunday, Memorial Day, July 4th,
Labor Day, Thanksgiving and Christmas, with the father having
partial custody on his holidays from 9:00 a.m. to 8:00 p.m.
2. Once the children are in school, the parents agree to
divide between them, in addition to the above holidays, the
balance of school Christmas and Thanksgiving break periods.
F. Father shall have the children on Father's Day from 9:00 a.m.
to 8:00 p.. and the mother shall have the children on Mother's
Day.
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G. The parties shall each have a reasonable period of time with
the children on their birthdays and on the children's
birthday to celebrate these events.
H. The parties agree that the children shall accompany each
parent to the parent's family reunions or work related family
events as may from time to time be scheduled, provided that at
least one weeks advance notice is given the other parent.
I. The father shall provide all transportation to and from his
periods of partial custody.
2. The father may have partial custody of the children during such
additional periods as the parties shall from time to time agree,
without the need to modify the Order of Court entered as a result of
this Stipulation.
3. The husband agrees to call before appearing for a visit and to
prearrange periods of partial custody at least twenty four hours in
advance. The wife agrees not to unreasonably withhold consent for
visitation or periods of partial custody by the father.
4. The parties shall notify each other in a timely fashion if it is
necessary due to an emergency or unforeseen circumstance for him or
her to be delayed at any of the times set out herein. It is
intended, however, that time be of the essence, and that the parties
as strictly as possible comply with the times set forth herein.
5. Notice of Child's Location
(A) The parties agree that they will each notify the other parent
when a child is away from the child's primary residence for
more than two consecutive nights and will provide an address
and phone number where the child can be reached.
(B) Both parents shall be kept informed as to the whereabouts of
the children at all times.
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6. The parties will notify and consult with the other party immediately
in cases of medical emergencies that occur while the children are in
their custody.
7. The father agrees to assure the children attend activities scheduled
for the children during his periods of partial custody, such as but
not limited to school events, activities and outings, swimming and
other such lessons, birthday and other parties to which the children
are invited by their friends. The parties agree to keep each other
timely advised as to these events and activities.
8. Neither parent shall do anything which may estrange the children
from the other parent or injure the opinion of the children as to
the other parent, or which may hamper the free and natural
development of the children's love or affection for the other
parent.
9. Husband and wife acknowledge that it is in the best interests of the
children to have reasonable and liberal contact with both parents so
as to maintain a normal parent-child relationship with both parents.
10. The parties agree that in making this Agreement, there has been no
fraud, concealment, overreaching, coercion, or other unfair dealing
on the part of the other.
11. Any modification or waiver of any of the provisions of this
Agreement shall be effective only if made in writing and only if
executed with the same formality as this Agreement.
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IN WITNESS WHEREOF, the parties hereto intending to be legally bound by the
hereof, set forth their hands and seals this I~~day of ~,
20 CP .
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Attorney for Plaintiff
10 West High Street
Carlisle, PA 17013
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Patricia A. Beekler,
Plaintiff - mother
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Raymo R. Beekler -
Defendant - father
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COMMONWEALTH OF PENNSYLVANIA
ss
COUNTY OF CUMBERLAND
of J}~,
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Public, the undersigned officer, personally appeared patricia A. Beekler, known
On this, the ~y
, 20111) before me, a Notary
to me to be the person whose name is subscribed to the within Custody Stipulation
and Agreement, and acknowledged that she executed the same for the purposes
therein contained.
NOr... aAI.
C1AI!Illt A. AIClIl'IlIow, NelaIr........
C'.aollIfe ~ 0............ c:ou..e,
Mt>j c.'OJ, . ' r J """""" June 28. 2003
r~O-Qi\. dVlwwJ
Notary Public
COMMONWEALTH OF PENNSYLVANIA
ss
COUNTY OF CUMBERLAND
On this, the t-1i day of n ' 20C;C'; before me, a Notary
Public, the undersigned officer, personally appeared Raymond R, Beekler,
known to me to be the person whose name is subscribed to the within Custody
Stipulation and Agreement, and acknowledged that he executed the same for the
purposes therein contained,
No,Ao f ~
Notarial Seal
Sue A. Kohr, Notary Public
Derry. Twp" Dauphin County
My Commission Expires May 1, 2004
MemI1er,Pi1!niylvaniaAmei~UQn91NglBl!95
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