HomeMy WebLinkAbout00-03531
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF
RICHARD E. STOUGHTON,
VERSUS
TRISHA C. STOUGHTON,
AND NOW,
DECREED THAT
AND
PENNA.
Plaintiff
No. 2000-3531 CIVIL
Defendant
DECREE IN
DIVORCE
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, 2002 , IT IS ORDERED AND
RICHARD E. STOUGHTON
, PLAINTIFF,
TRISHA C. STOUGHTON
, DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED;
None. The parties' Post-Nuptial Aqreement dated February
13, 2002 is incorporated but not merged into this Decree.
.
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PROTHONOTARY
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LAW OFFICES
SNELBAKER,
BRENNEMAN
& SPARE
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RICHARD E. , STOUGHTON,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
: NQ. 2000- 36-3{ CIVIL TERM
CIVIL ACTION - LAW
v.
,
TRlSHA C. STOUGHTON,
Defendant
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IN DIVORCE
NQTICE 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 that the court require you and your spouse to attend marriage counseling prior
to a divorce decree being handed down by the court. A list of marriage counselors is available in
the Qffice of the Prothonotary at the Cumberland County Court House, Carlisle. You are
advised that this list is kept as a convenience to you and you are not bound to choose a counselor
from the list. All necessary arrangements and the cost of counseling sessions are to be borne by
you and your spouse.
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IF YQU DO NQT FILE A CLAIM FQR ALIMDNY, DIVISION QF PROPERTY,
LAWYER'S FEES QR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED,
YOU MAY LOSE THE RIGHT TQ CLAIM ANY OF THEM.
YQU SHQULD TAKE THIS PAPER TO YQUR LAWYER AT QNCE. IF YQU DO
NOT HAVE A LAWYER QR CANNOT AFFORD ONE, GO TQ OR TELEPHQNE THE
OFFICE SET FQRTH BELOW WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
(717) 249-3166
SNELBAKER, BRENNEMAN & SPARE, P.C.
By
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Attorneys for Plaintiff
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LAW OFFICES
SNELBAKER,
BRENNEMAN
& SPARE
RICHARD E. STQUGHTON
,
Plaintiff
IN THE CQURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
: NO. 2000- 36'..31 CIVIL TERM
CIVIL ACTION - LAW
v.
TRISHA C. STOUGHTON
,
Defendant
IN DIVORCE
CQMPLAINT
1. Plaintiff RICHARD E. STOUGHTON, is an adult individual residing at 6332
Chesterfield Lane, Mechanicsburg, Cumberland County, Pennsylvania 17055.
2. Defendant TRISHA C. STQUGHTQN, is an adult individual residing at 233 Birch
Lane, Carlisle, Cumberland County, Pennsylvania 17013.
3. Both Plaintiff and Defendant have been bona fide residents of the Commonwealth of
Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were lawfully joined in marriage on April 12, 1986 in
Middlesex Township, Cumberland County, Pennsylvania.
5. There has been a prior action of divorce between the parties docketed to No. 95-712 in
the Court of Common Pleas of Cumberland County. That action was dismissed due to inactivity
of record.
6. Neither party is a member ofthe armed forces of the United States of America.
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LAW OFFICES
SNELBAKER,
BRENNEMAN
& SPARE
7. The Plaintiff avers as the grounds upon which this action is based is that the marriage
between the parties hereto is irretrievably broken.
8. The 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.
9. The Plaintiff requests this Court to enter a decree of divorce.
WHEREFQRE, RICHARD E. STQUGHTQN requests this Court to enter a Decree of
Divorce, divorcing the Plaintiff from the bonds of matrimony heretofore existing between the
Plaintiff and Defendant.
WHEREFORE, the Plaintiff requests this Court to:
(a) enter a decree of divorce, divorcing the Plaintiff from the
bonds of matrimony; and
(b) order such other relief as this Court deems just and reasonable.
SNELBAKER, BRENNEMAN & SPARE, P.C.
I/~~
Date: June 9, 2000
By:
Keith O. Brenneman, Esquire
44 West Main Street
Mechanicsburg, PA 17055-0318
(717) 697-8528
Attorneys for Plaintiff Richard E. Stoughton
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VERIFICATION
I verify that the statements made in the foregoing Complaint are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section
4909 relating to unsworn falsification to authorities.
Date: June 9, 2000
LAW OFFICES
SNELBAKER.
BRENNEMAN
& SPARE
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LAW OFFICES
SNEL8AKER,
BRENNEMAN
& SPARE
RICHARD E. STQUGHTON,
Plaintiff
IN THE CQURT QF CQMMQN PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
NO. 2000- CIVIL TERM
CIVIL ACTION - LAW
v.
TRISHA C. STQUGHTQN,
Defendant
IN DIVORCE
AFFIDAVIT
RICHARD E. STOUGHTON, being duly sworn accnrdingto law, deposes alld says:
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 participate in counseling.
2. I understand that the court maintains a list of marriage counselors in the Office of the
Prothonotary, which list is available to me upon request.
3. Being so advised, I do NQT request that the court require 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.
;;::/ /:I.~~ -
~hard E. Sto ton
(plaintiff)
Date: June 9,2000
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LAW OFFICES
SNELBAKER,
BRENNEMAN
& SPARE
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7'U;. (H). .35'.3 / e l'
POST .NUPTIAL AGREEMENT
THIS AGREEMENT, made and entered into this J3Ih day of February, 2002 by and
between:
TRISHA C. STOUGHTQN, of 1916A Fryloop Avenue,
Carlisle, Cumberland County, Pennsylvania, party
of the first part, (hereinafter "Wife")
AND
RICHARD E. STOUGHTON, of233 Birch Lane,
Carlisle, Cumberland County, Pennsylvania, party of
the second part, (hereinafter "Husband")
WITNESSETH:
WHEREAS, Husband and Wife (collectively referred to herein as the "parties") were
married to each other on April 12, 1986 and last resided with each other at 233 Birch Lane,
Carlisle, Pennsylvania; and
WHEREAS, the parties have accumulated certain assets and property during their
marriage; and
WHEREAS, the parties have had only one child of their marriage, Richard A. Stoughton,
a minor; and
WHEREAS, certain differences have arisen between the parties, as a consequence of
which they separated on May 27, 2000 and now live separate and apart from each other; and
WHEREAS, on June 9, 2000 Husband commenced an action in divorce docketed to No.
2000-3531 Civil Term in the Court of Common Pleas of Cumberland County, Pennsylvania
(hereinafter the "Divorce Action"); and
WHEREAS, the parties agree that their marriage is irretrievably broken; and
WHEREAS, the parties acknowledge that each has had the full opportunity to be advised
independently and represented by separate counsel concerning their respective rights, duties and
obligations arising out of their marital status; and
WHEREAS, the parties having a full opportunity to be so advised of their respective
rights, duties and obligations arising out of their marital status, and each having a full
opportunity to investigate and evaluate assets, liabilities and all other aspects of each other's
property and their jointly owned assets and liabilities, have come to an agreement for the final
settlement of their property and affairs.
NOW THEREFORE, in consideration ofthese presents and the mutual covenants,
promises, terms and conditions hereinafter set forth and to be kept and performed by each party
hereto, and intending to be legally bound hereby, the parties mutually agree as follows:
I. INCORPORATION OF PREAMBLE. The foregoing preamble and paragraphs are
incorporated by reference herein in their entirety.
2. DECLARATION AS TO ASSETS AND WAIVER OF EVALUATION.
The parties declare and agree that they have, prior to the execution of this Post-Nuptial
Agreement, voluntarily agreed to divide and have physically divided and distributed between
themselves all assets which they acquired during their marriage, whether or not said property is
or would be deemed to be marital property under Pennsylvania Divorce Code and subject to
equitable distribution. The parties further declare and agree that prior to the execution hereof,
they have voluntarily distributed between themselves all assets and property which each brought
LAW OFFICES
SNELBAKER.
BRENNEMAN
& SPARE
with them into their marriage.
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The parties declare and acknowledge that they are fully aware and familiar with all assets
and property that each has brought into the marriage and that has been obtained or acquired
separately or jointly by them during the course of their marriage and therefore waive any
valuation thereof. Each party expressly releases the other of and from any and all right of
equitable distribution or claims to assets and property of any kind or nature whatever possessed
by the other party and acknowledge that each party may freely dispose of any property in his or
her possession without interference from or claim by the other.
3. MARITAL RESIDENCE. Prior to the parties' separation, the parties resided in a
1998 Eagle Model Fleetwood Manufactured home located at 233 Birch Lane, Carlisle,
Pennsylvania (the "marital residence"). The parties agree that the marital residence shall be
exclusively owned, possessed and used by Husband. Husband shall be solely responsible for
paying all taxes, expenses and utilities now and in the future due and owing arising out of the
occupation or use of said residence. Husband shall further be solely responsible for paying all
lot rent on the residence.
The parties acknowledge and agree that the residence is titled in both of their names,
which title is encumbered by a lien held by FirstMerit Mortgage Corporation identified as loan
number 6251011777 for which the parties are jointly liable. Husband agrees that he will be
solely responsible for and pay the FirstMerit mortgage. Husband further agrees that he will
indemnify and hold Wife harmless of and from any and all liability, debts, claims and damages
caused by Husband's failure to pay the FirstMerit mortgage. Wife agrees, at Husband's request,
to execute any and all documents necessary to transfer to Husband, or any entity or person
LAW OFFICES
SNELBAKER.
BRENNEMAN
8: SPARE
identified by Husband, all of her right, title and interest she has in and to the marital residence.
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Such transfer shall be made without payment of any consideration to Wife, it being understood
that Husband shall be considered for purposes of this Agreement, the sole legal and equitable
owner of the residence entitled to all proceeds from any future sale of same.
4. AUTOMOBILES. The parties acknowledge and agree that Wife is the sole owner of
a 1997 Camero which is subject to a loan secured by said vehicle. The parties agree that Wife
shall retain sole possession, ownership and use of the 1997 Camero and shall be solely
responsible for and pay the loan on said vehicle. Each party agrees to hold harmless and
indemnify the other of and from any and all liability, debts, claims and damages caused by said
party's failure to pay the loans agreed to be paid by said party herein.
5. DIVISION OF DEBTS AND LIABILITIES. The parties acknowledge that prior to
the execution of this agreement they jointly filed for bankruptcy. It is expected that a majority of
debt incurred during their marriage has been or will be discharged.
To the extent not discharged in their bankruptcy, Husband agrees to hold harmless and
indemnify Wife from any and all debts, damages, costs and expenses which Wife may incur
directly as a result of Husband's failure to payor discharge any debt or obligation he agrees to
pay as set forth in the Agreement. Wife agrees to hold harmless and indemnify Husband from
any and all debts, damages, costs and expenses which Husband may incur directly as a result of
Wife's failure to payor discharge any debt or obligation she agrees to pay as set forth in this
Agreement.
6. FUTURE OBLIGATIONS. The parties agree that any and all obligations incurred
LAW OFFICES
SNELBAKER.
BRENNEMAN
& SPARE
subsequent to the date of their separation, May 27, 2000, and the date of their filing for
bankruptcy shall be the sole and separate liability and responsibility of the party incurring the
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obligation and each party agrees that he/she will not incur or attempt to incur any obligations for
or on behalf of the other party and will indemnify and hold harmless the other party of and from
any and all liability arising from such future obligation.
7. COUNSEL FEES. Each party to this Post-Nuptial Agreement shall be responsible for
paying his or her own counsel fees and related costs associated with the processing of the
Divorce Action and the negotiation, execution and consummation of the provisions of this Post-
Nuptial Agreement.
8. PENSION, 40lK RETIREMENT PLANS. BENEFITS AND
EMPLOYMENT BENEFITS.
Each party waives and forever releases the other of and from any and all claims which
either may have against the other's pension, 40lK Plan, retirement plan or any other retirement
plan benefit or employee benefit or benefits. Wife specifically acknowledges that Husband
participates in a pension retirement plan through his current employer, Strohman Bakeries.
9. RELEASE OF SUPPORT AND RIGHTS UNDER DIVORCE CODE.
Each party waives and forever releases the other party of and from any and all claims
which either may have against the other for spousal support and for all claims which either may
have against the other by reason of and pursuant to the Pennsylvania Divorce Code (and the
divorce law of any other jurisdiction) including, but not limited to, alimony, alimony pendente
lite, equitable distribution of marital property, counsel fees, costs and expenses, except that the
performance of any obligation created hereunder may be enforced by any remedies nnder the
pennsylvania Divorce Code.
10. DIVORCE. The parties agree to terminate their marriage by mutual consent without
LAW OFFICES
SNELBAKER.
BRENNEMAN
& SPARE
counseling and each agrees to execute the necessary affidavits, waivers and consents to procure a
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consensual divorce under the provisions ofthe Pennsylvania Divorce Code, such documents to
be filed in the Divorce Action.
11. CUSTODY. Husband and Wife shall have shared legal custody of the parties' minor
child, Richard A. Stoughton. The parties agree that they shall have equal shared physical
custody of their son, with each party having physical custody of their son fifty percent (50%) of
the time. It is the intention of the parties that a custody arrangement respecting Richard be
flexible and can be subject to modification in the future, taking in consideration the physical
custody preferences of their son.
12. GENERAL RELEASE. Husband relinquishes his inchoate intestate right in the
estate of Wife, and Wife relinquishes her inchoate intestate right in the estate of Husband, and
each of the parties hereto by these presents, for himself or herself, his or her heirs, executors,
administrators or assigns, does hereby remise, release, quit-claim and forever discharge the other
party hereto, his or her heirs, executors, administrators or assigns, or any of them, of any and all
claims, demands, damages, actions, causes of action or suits at law or in equity of whatsoever
kind or nature, for or because of any matter or thing done, omitted or suffered to be done by such
other party prior to the date hereof, except that this release shall in no way exonerate or discharge
either party from the obligations and promises made or imposed by reason of this Agreement.
13. SURVIVAL OF AGREEMENT. It is the intention ofthe parties that this Post-
Nuptial Agreement shall survive any action in divorce which may be instituted or prosecuted by
either party, and no order, judgment or decree of divorce, temporary, interlocutory, fmal or
permanent, shall affect or modify the terms of this Agreement, but said Agreement may be
enforced by any remedy at law or in equity, including enforcement proceedings under the
LAW OFFICES
SNELBAKER.
BRENNEMAN
& SPARE
Pennsylvania Divorce Code. The parties agree to incorporate this Agreement into a separate
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LAW OFFICES
SNELBAKER.
BRENNEMAN
& SPARE
order of court to be entered in the Divorce Action, but this Agreement shall not be merged into
said order or decree in divorce.
14. COOPERA TIQN. The parties agree to cooperate with each other and to make,
execute, acknowledge and deliver such instruments and take such further action as may hereafter
be determined to be requisite and necessary to effect the purposes and intention of this Post-
Nuptial Agreement.
15. VOLUNTARY EXECUTION. The parties declare and acknowledge that they have
had the opportunity to have the provisions of this Post-Nuptial Agreement and their legal effect
explained to them by independent counsel of their choosing and each party acknowledges that
this Post-Nuptial Agreement is fair and equitable, that it is being entered into voluntarily, with
full knowledge of the assets of both parties, and that it is not the result of any duress or undue
influence. The parties acknowledge that they have been furnished with all information
relating to the financial affairs of the other to the extent same has been requested by each of
them.
16. ENTIRE AGREEMENT. This Post-Nuptial Agreement contains the entire
understanding of the parties and there are no representations, warranties, covenants or
undertakings other than those expressly set forth herein. The parties acknowledge and agree that
the provisions of this Agreement with respect to the distribution and division of marital and
separate property are fair, equitable and satisfactory to them based on the length of their marriage
and other relevant factors which have been taken into consideration by the parties. Both parties
hereby accept the provisions of this Agreement with respect to the division of property in lieu of
and in full and final settlement and satisfaction of all claims and demands that they may now
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have or hereafter have against the other for equitable distribution oftheir property by any court
of competent jurisdiction pursuant to the Pennsylvania Divorce Code or any amendments
thereto. Each party voluntarily and intelligently waives and relinquishes any right to seek a court
ordered determination and distribution of marital property, but nothing herein contained shall
constitute a waiver by either party of any rights to seek the relief of any court for the purpose of
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enforcing the provisions of this Agreement.
17 . WAIVER/MODIFICATION. The waiver of any term, condition, clause or provision
of this Agreement shall in no way be deemed or considered a waiver of any other term,
condition, clause or provision of this Agreement. This Agreement can only be modified in
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writing executed by both parties hereto.
18. APPLICABLE LAW. This Agreement shall be construed, interpreted and enforced
according to the laws of the Commonwealth of Pennsylvania.
19. HEADINGS. The headings or titles ofthe numbered paragraphs of this Agreement
have been used only for the purpose of convenience and shall not be resorted to for the purposes
of interpretation or construction of the text of this Agreement.
20. EFFECTIVE DATE. This Agreement shall be dated and become effective on the
date when executed by the latter of the two parties.
21. BREACH; INDEMNIFICATION. If either party hereto breaches any provision
hereof, then the nonbreaching party shall have the right, at his or her election, to sue for damages
for said breach, or seek such other remedies or relief as may be available to him or her, and the
LAW OFFICES
SNELBAKER.
BRENNEMAN
& SPARE
defaulting party shall be responsible for payment of all reasonable legal fees and costs incurred
by the other party in enforcing his or her rights under this Agreement. Each party agrees and
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LAW OFFICE&
SNELBAKER.
BRENNEMAN
& SPARE
.
covenants to indemnify and hold harmless the other party from any and all liability and/or claims
and/or damages and/or expenses (including attorneys' fees and expenses of litigation) that the
indemnitee may sustain or may become liable or answerable in any way whatsoever, or shall pay
upon, or in the consequence of, the indemnitor's breach of any obligation, term or covenant of
indemnitor under this Agreement, including, but not limited to, indemnitor's obligation to make
any payment provided for herein.
IN WITNESS WHEREOF, the parties have hereunto set their respective hands and seals
intending to legally bind themselves and their respective heirs, personal representatives and
assigns.
WITNESSED BY:
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'chardE. Stoughton
Date:c2-/3 -c ~
(SEAL)
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Trisha C. Stoughton
Date: "1
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(SEAL)
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& SPARE
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RICHARD E. STOUGHTON,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 2000-3531 CIVIL TERM
TRISHA C. STOUGHTON,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
TO: Prothonotary of Cumberland County:
Please 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 330l(c) of the Divorce
Code.
2. Date and manner of service of Complaint: by certified mail, restricted delivery on
Defendant on June 13,2000 (see Affidavit of Service filed June 19,2000).
3. Date of execution ofthe Affidavit of Consent required by Section 3301(c) of the
Divorce Code: by the Plaintiff: February 13, 2002; by the Defendant: February 13,2002.
4. Date of execution of Waiver of Notice in Section 3301 (c) Divorce: by the Plaintiff:
February 13,2002; by the Defendant: February 13, 2002.
S. Related pending claims: None.
Date: February 14, 2002
SNELBAKER, BRENNEMAN & SPARE, P. C.
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By:
Attorneys for Plaintiff
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LAW OFFICES
SNEL8AKER.
BRENNEMAN
& SPARE
RICHARD E. STOUGHTON,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 2000-3531 CIVIL TERM
v.
TRISHA C. STOUGHTON,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
PLAINTIFF'S AFFIDA VII OF CONSENT
UNDER SECTION 3301(C) OF THE DNORCE CODE
1. A complaint in divorce under Section 3301(c) ofthe Divorce Code was filed on
June 9, 2000.
2. The marriage of the Plaintiff and the Defendant is irretrievably broken and ninety (90)
days have elapsed from the date of the 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 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.
Dme: February 13, 2002
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. Richard . Stoughton
(Plaintiff)
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LAW OFFICES
SNELBAKER.
BRENNEMAN
& SPARE
RICHARD E. STOUGHTON,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 2000-3531 CIVIL TERM
TRISHA C. STOUGHTON,
Defendant
CIVIL ACTION - LAW
: IN DIVORCE
DEFENDANT'S AFFIDAVIT OF CONSENT
UNDER SECTION 3301(C) OF THE DIVORCE CODE
1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on
June 9, 2000.
2. The marriage of the Plaintiff and the Defendant is irretrievably broken and ninety (90)
days have elapsed from the date of the 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 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. 9 4904, relating to
unsworn falsification to authorities.
Date:
-)nA~
<2, S=~
Trisha C. Stough
(Defendant)
February 13, 2002
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LAW OFFICES
SNELBAKER.
BRENNEMAN
& SPARE
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RICHARD E. STOUGHTON,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 2000-3531 CIVIL TERM
TRISHA C. STOUGHTON,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
PLAINTIFF'S WAIVER OF NOTICE OF INTENTION
TO REQUEST ENTRY OF A DIVORCE DECREE
UNDER SECTION 3301(c) OF THE DIVORCE CODE
1. I consent to the entry of a final decree of divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property, lawyer's
fees, or expenses ifI do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by the Court
and that a copy of the decree will be sent to me irmnediately after it is filed with the
Prothonotary.
4. 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:
February 13, 2002
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Richard E. St ghton
(Plaintiff)
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LAW OFFICES
SNEL8AKER.
BRENNEMAN
8: SPARE
RICHARD E. STOUGHTQN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 2000-3531 CIVIL TERM
TRISHA C. STOUGHTON,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
DEFENDANT'S WAIVER OF NOTICE OF INTENTION
TO REQUEST ENTRY OF A DIVORCE DECREE
UNDER SECTION 3301(c) OF THE DIVORCE CODE
1. I consent to the entry of a final decree of divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property, lawyer's
fees, or expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by the Court
and that a copy of the decree will be sent to me immediately after it is filed with the
Prothonotary.
4. 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.
D~e: February 13, 2002
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Trisha C. Sto ghton
(Defendant)
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LAW OFFICES
SNEL8AKER.
BRENNEMAN
& SPARE
RICHARD E. STOUGHTON,
Plaintiff
IN THE CQURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: NO. 200 3531 CIVIL TERM
CIVIL ACTION -LAW
TRISHA C. STOUGHTQN,
Defendant
IN DIVORCE
AFFIDAVIT QF SERVICE
COMMONWEALTH OF PENNSYLVANIA )
: SS.
COUNTY QF CUMBERLAND )
Keith O. Brenneman, Esquire, being duly sworn according to law deposes and
says: that he is a principal in the law firm of Snelbaker, Brenneman & Spare, P.C.,
being the attorneys for Richard A. Stoughton, the Plaintiff in the above captioned
action in divorce; that on June 12, 2000, he did send to Defendant Trisha C.
Stoughton by certified mail, return receipt requested, restricted delivery, a duly
certified copy of the Complaint in Divorce which was filed in the above captioned
action as evidenced by the attached cover letter of the same date and Receipt for
Certified Mail No.7099 3400000450098695; that both the Complaint and cover
etter were duly received by Trisha C. Stoughton, the Defendant herein, as
evidenced by the return receipt card for said certified mail dated June 13, 2000;
hat a copy of the aforementioned cover letter dated June 12, 2000 is attached
hereto and incorporated by reference herein as "Exhibit A" and that the original
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Receipt for Certified Mail and the Domestic Return Receipt are attached hereto and
incorporated by reference herein as "Exhibit B"; and that the foregoing facts are
true and correct to the best of his knowledge, information and belief.
J~
Keith O. Brenneman
Sworn to and subscribed before I
me this \lO+bI. day of June, 2000.
S CAv1~ (;L +< sh~
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NOlllnal Seal
Sandra K. Showers, Notary Public
, Mecll!ll1lcsbu'9 80m, Cumb.~and County
My CommissIon Expires Nov. 22, 2003
Memosr, PennsyiIJanli.) (.\~.~:,:;r:i0W:n ')i' Hc:."u'ies
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LAW OFFICES
SNELBAKER.
BRENNEMAN
& SPARE
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SNELBAKER, BRENNEMAN S SPARE
A PROFESSIONAL CORPORA nON
ATTORNEYS AT LAW
RICHARD C. SNELBAKER
KEITH O. BRENNEMAN
PHILIP H. SPARE
44 WEST MAIN STREET
MECHANICSBURG, PENNSYLVANIA 17055
717-697-8528
P. O. BOX 318
FACSIMiLE (717) 697-7681
June 12,2000
Trisha C. Stoughton
233 Birch Lane
Carlisle, PA 17013
Re: Stoughton v. Stoughton
No. 2000 - 3531, C.C.P. Cumberland County
Dear Ms. Stoughton:
Enclosed please find a certified copy of the Divorce Complaint, the original of
which was filed in the above action.
~o~ jlY,
10ft / Zf'a-~
Keith O. Brenneman
Enclosure
BY CERTIFIED MAIL, RETURN RECEIPT REQUESTED, RESTRICTED
DELIVERY, PARCEL NO. 7099 3400 0004 5009 8695
EXHIBIT A
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(Endorsement Required)
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m Name (please Print Claarly) (to be completed by mailer)
IT" .n.".~!:r.;i,..$.lH;L.C."m-S.tQllg:ht.OIl.......mmm....m....n..
0- Street, APt. No.; or PO Box No.
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~ City, State, ZIP+4
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Total Postage & Fees $
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Compiete items" 1;- 2~:"aii'd~i' Ai~~'"'to~piet~-
item.4'if Resh'ictecLDeHvery is desired.
. Print youl'! name and address on the reverse
so that we can return the card to you.
. Attach this card to the back of the mailpiece.
or on the front if space permits.
1. Article Addressed to:
Trisha C. Stoughton
2s-3 Brrch Lam=-
Carlisle PA 17013
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D. Is ceUvery address different from. m 1?
If YES, enter delivery address bow:
3. Service Type
~Certified Mail 0 Express Mail
o Registered 0 Return Receipt for Merchandise
o Insured Mall 0 C.O.D.
4. Restricted Delivery? (Extra Fee) Gl Yes
2. Article Number (Copy from service label)
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LAW OFFICES
SNELBAKER,
BRENNEMAN
& SPARE
EXHIBIT B
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