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IN THE COURT OF COMMON PLEAS
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OF CUMBERLAND COUNTY
SHERI A. PECHART,
PENNA,
STATE OF
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Plaintiff
N 2000-3879
o.
Civil Term
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VERSUS
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JEFFREY K. PECHART.
Defendant
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DECREE IN
DIVORCE
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AND NOW,
/1, I~ " ., .-- 2000
L<'c~~ ........ , IT IS ORDERED AND
DECREED THAT
SHERI A. PECHART , PLAINTIFF,
AND
JEFFREY K. PECHART
, 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;
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The attached Property Settlement Agreement, dated October 12,
is hereby incorporated, but not merged, into the Divorce Decree.
OTHONOTARY
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PROPERTY SETTLEMENT AGREEMENT
THIS AGREEMENT, made this
I ~ ~day of ~ooo
by and
between SHERI A. PECHART of Cumberland County, Pennsylvania
(hereinafter referred to as WIFE), and J:EFFREY K. PECHART of
Cumberland County, Pennsylvania (hereinafter referred to as
HUSBAND) ,
WHEREAS, HUSBAND and WIFE were lawfully married on May 27,
1982 in Cumberland County, Pennsylvania; and
WHEREAS, one (2) children were born of this marriage, namely:
AMANDA C. PECHART, born August 18, 1982; and SPENSER C. PECHART,
born June 26, 1990; and
WHEREAS,
diverse,
unhappy
differences,
disputes
and
difficulties have arisen between the parties and it is the
intention of HUSBAND and WIFE to live separate and apart for the
rest of their natural lives, and the parties hereto are desirous of
settling fully and finally their respective financial and property
rights and obligations as between each other, including without
limitation by specification: the settling of all matters between
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them relating to the ownership and equitable distribution of real
and personal property; the settling of all matters between them
relating to past, present and future support and alimony; and in
general, the settling of any and all claims by one against the
other or against their respective estates,
NOW, THEREFORE, in consideration of the premises and of the
mutual promises, covenants and undertakings hereinafter set forth
and for other good and valuable consideration, receipt of which is
hereby acknowledged by each of the parties hereto, HUSBAND and
WIFE, each intending to be legally bound, hereby covenant and agree
as follows:
1.
Separation:
It shall be lawful for each party at all
times hereafter to live separate and apart from the other party at
such place as he or she may from time to time choose or deem fit.
The foregoing provision shall not be taken as an admission on the
part of either party of the lawfulness or unlawfulness of the
causes leading to their living apart.
2,
Interference: Each
party
shall
be
free
from
interference, authority, and contact by the other, as fully as if
he or she were single and unmarried, except as may be necessary to
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carry out the provisions of this Agreement, Neither party shall
molest the other or attempt to endeavor to molest the other, nor
compel the other to cohabit with the other, or in any way harass or
malign the other, nor in any way interfere with the peaceful
existence of the other, while living separate and apart,
3,
Subsequent Divorce:
The parties acknowledge that WIFE
has filed a Complaint in Divorce in Cumberland County,
Pennsylvania, to docket number 2000-3879 civil Term, claiming that
the marriage is irretrievably broken under the no-fault mutual
consent provision of Section 3301(c) of the Pennsylvania Divorce
Code. HUSBAND hereby expresses his agreement that the marriage is
irretrievably broken and expresses his intent to execute any and
all affidavits or other documents necessary for the parties to
obtain an absolute divorce pursuant to Section 3301 (c) of the
Divorce Code. The parties hereby waive all rights to request Court-
ordered counseling under the Divorce Code, It is specifically
understood and agreed by the parties that the provisions of this
Agreement as to equitable distribution of property of the parties
are accepted by each party as a final settlement for all purposes
whatsoever, as contemplated by the Pennsylvania Divorce Code,
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Should a decree, judgment or order of separation or divorce be
obtained by either of the parties in this or any other state,
country or jurisdiction, each of the parties 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 modification
or revision thereof shall alter, amend or vary any term of this
Agreement, whether or not either or both of the parties shall
remarry, It is specifically agreed, that a copy of this Agreement
or the substance of the provisions thereof, may be incorporated by
reference, but not merged, into any divorce, judgment or decree, It
is the specific intent of the parties to permit this Agreement to
survive any judgment and to be forever binding and conclusive upon
the parties.
4,
Date of Execution:
The
"date
of execution" or
"execution date" of this Agreement shall be defined as the day upon
which it is executed by the parties if they have each executed the
agreement on the same date, Otherwise, the "date of execution" or
"execution date" of this Agreement shall be defined as the date of
execution by the party last executing this Agreement,
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5.
Distribution Date:
The transfer of property, funds
and/or documents provided for herein, shall only take place on the
"distribution date" which shall be defined as specified herein.
6, Mutual Release: 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 interests, 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 the 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 widower's rights, family exemption
or similar allowance, or under the intestate laws, or the right to
take against the spouse's will; or the right to treat a lifetime
conveyance by the other as testamentary, or all other rights of a
survi ving spouse to participate in a deceased spouse's estate,
whether arising under the laws of (a) Pennsylvania, (b) any State,
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Commonwealth or territory of the United States, or (c) any country,
or any rights which either party may have or at any time hereafter
shall have for past, present or future support or maintenance,
alimony, alimony pendente lite, counsel fees, property division,
costs or expenses, whether arising as a result of the marital
relations or otherwise, except, all rights and obligation of
whatsoever nature arising or which may arise under this Agreement
or for the breach of any provisions 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 right and agreements and
obligations of whatsoever nature arising or which may arise under
this Agreement or for the breach of any provision thereof.
It is further agreed that this Agreement shall be and
constitute a full and final resolution of any and all claims which
each of the parties may have against the other for equitable
division of property, alimony, counsel fees and expenses, alimony
pendente lite or any other claims pursuant to the Pennsylvania
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Divorce Code or the divorce laws of any other jurisdiction,
Advice of Counsel:
The provisions of this Agreement and
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their legal effect have been fully explained to WIFE by MARYANN
MURPHY, ESQUIRE, counsel for WIFE, HUSBAND has knowingly, willingly
and voluntarily waived his right to counsel. HUSBAND understands
that he has the right to have an attorney of his choice review this
Agreement before it is executed,
HUSBAND and WIFE acknowledge and accept that this Agreement
is, in the circumstances, fair and equitable and that it is being
entered into freely and voluntarily and that execution of this
Agreement is not the result of any duress or undue influence and
that it is not the result of any collusion or improper or illegal
agreement or agreements,
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Warranty as to Existincr Oblicrations:
Each party
represents that he or she has 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 and hold the
other party harmless for and against any and all such debts,
liabilities or obligations of every kind which may have heretofore
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been incurred by them, including those for necessities, except for
the obligation arising out of this Agreement.
9, EXISTING DEBTS: HUSBAND agrees to be solely and
exclusively responsible for any and all debts in his individual
name, and for any monies owed for the parties' Toyota which was
repossessed, HUSBAND further agrees to indemnify WIFE and hold her
harmless from any and all liability for same,
WIFE agrees to be solely and exclusively responsible for any
and all debts in her individual name, WIFE further agrees to
indemnify HUSBAND and hold him harmless from any and all liability
for same.
10, Warrantvas to Future Oblicrations: HUSBAND and WIFE each
covenant, warrant, represent and agree that, with the exception of
obligations set forth in this Agreement, neither of them shall
hereafter incur any liability whatsoever for which the estate of
the other may be liable,
Each party shall indemnify and hold
harmless the other party for and against any and all debts, charges
and liabilities incurred by the other after the execution date of
this Agreement, except as may be otherwise specifically provided
for by the terms of this Agreement.
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11. Personal Property: The parties acknowledge that they
have already divided their personal property between themselves;
HUSBAND shall become the sole and exclusive owner of all personal
property currently in his possession, and WIFE shall become the
sole and exclusive owner of all personal property currently in her
possession,
HUSBAND and WIFE agree that the above division of property is
mutually acceptable to them. Neither party shall make any claim to
any such item of marital property, or of the separate personal
property of either party, except as provided for in this Agreement,
which will be in the possession and/or under the control of the
other at the time of the execution of this Agreement, 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 execution of this Agreement; and in
the case of intangible personal property, if any physical or
written evidence of ownership, such as passbook, checkbook, policy
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or certificate of insurance or other similar writing is in the
possession or control of the party at the time of the execution of
this Agreement,
12, Motor Vebicles:
The parties agree that HUSBAND shall
be solely and exclusively responsible for any and all monies owed
for the parties' Toyota which was repossessed, HUSBAND agrees to
indemnify WIFE and hold her harmless from any and all liability for
same,
The parties acknowledge that the 1992 Chevrolet Cavalier,
currently titled in WIFE's name and driven by the parties'
daughter, Amanda, was purchased after the date of separation and
shall remain the sole and exclusive property of WIFE.
13, Pension/Retirement Benefits: HUSBAND
and WIFE
acknowledge that HUSBAND shall become the sole and exclusive owner
of any and all pension/retirement benefits he has accrued during
the course of the marriage. WIFE agrees to execute, upon request,
any and all documents necessary to effectuate the terms of this
agreement,
The parties acknowledge that WIFE has not accrued any
pension/retirement benefits during the course of the marriage.
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14, Health Insurance: HUSBAND agrees to provide medical
insurance coverage for the parties' children: AMANDA and SPENSER
for so long as it is available to him through his employer, HUSBAND
further agrees to provide medical insurance coverage for WIFE until
the Decree in Divorce has been issued by the Court.
HUSBAND agrees to provide to WIFE, in a timely manner, all
information regarding COBRA for WIFE's continued medical insurance
coverage through HUSBAND's employer,
15, Life Insurance: The parties agree that HUSBAND shall
name the parties' children, AMANDA and SPENSER, as beneficiaries of
his life insurance policy through his employer, HUSBAND agrees to
maintain said policy with these named beneficiaries until SPENSER
reaches the age of eighteen (18) years or graduates from high
school, whichever shall last occur,
16. After Acauired Personal Property: Each of the parties
shall hereafter own and enjoy, independently of any claims or right
of the other, all items of personal property, tangible or
intangible, hereafter acquired by him or her, with full power in
him or her to dispose of the same as fully and effectively, in all
respects and for all purposes, as though he or she were unmarried.
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17. Applicability of Tax Law to Property Transfers: The
parties hereby agree and express their intent that any transfers of
property pursuant to this Agreement shall be within the scope and
applicability of the Deficit Reduction Act of 1984 (herein the
"Act"), specifically, the provisions of said Act pertaining to
transfers of property between spouses or former spouses, The
parties agree to sign and cause to be filed any elections or other
documents required by the Internal Revenue Service to render the
Act applicable to the transfers set forth in this Agreement,
without recognition of gain on such transfer and subject to the
carry-over basis provisions of said Act,
18. Alimony: HUSBAND agrees that he shall pay to WIFE the
sum of fifty ($50,00) dollars per week in alimony beginning the
first Monday after the Decree in Divorce is entered and ending only
upon WIFE's remarriage, or the death of HUSBAND or WIFE.
The parties agree that alimony payments, and enforcement if
necessary, shall be through the Domestic Relations Office of
Cumberland County, Pennsylvania,
19. Waiver of Alimony Pendente Lite, and Counsel Fees:
Each party hereby waives any right to alimony pendente lite.
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WIFE agrees to file a petition to terminate spousal support within
ten (10) days of the execution of this Agreement, with the
effective date of termination being the date of the execution of
this Agreement, WIFE further agrees to provide a copy of this
Agreement to the Domestic Relations Office of Cumberland County,
Pennsylvania regarding alimony payments as per paragraph number 18
herein,
The parties agree to be responsible for their own attorney's
fees,
20, Full Disclosure:
HUSBAND and WIFE each represent and
warrant to the other that he or she has made a full and complete
disclosure to the other of all assets of any nature whatsoever and
of every type whatsoever in which such party has an interest, and
of all other facts relating to the subject matter of this
Agreement.
21, Disclosure and Waiver of Procedural Riqhts: Each party
understands that he or she has the right to obtain from the other
party a complete inventory or list of all. of the property that
either or both parties own at this time or owned as of the date of
separation, and that each party has the right to have all such
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property valued by means of appraisals or otherwise. Both parties
understand that they have the right to have the Court hold hearings
and make decisions on the matters covered by this Agreement, Both
parties understand that a Court decision concerning the parties'
respective rights and obligations might be different from the
provisions of this Agreement,
Both parties waive the following procedural rights:
a, The right to obtain an Inventory and Appraisement of
all marital and separate property as defined by the Pennsylvania
Divorce Code;
b, The right to obtain an Income and Expense Statement
of the other party as provided by the Pennsylvania Divorce Code;
c, The right to have the Court determine which property
is marital and which is non-marital and equitably distribute
between the parties that property which the Court determines to be
marital;
d, The right to have the Court decide any other rights,
remedies, privileges, or obligations covered by this Agreement,
including but not limited to, possible claims for divorce, spousal
support, alimony, alimony pendente lite, counsel fees, costs and
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expenses,
22, Waiver of Modification to be in WritinQ': 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.
23, 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,
24, Applicable Law:
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,
25, AQ'reement BindinQ' on Heirs:
This Agreement shall be
binding and shall inure to the benefits of the parties hereto and
their respective heirs, executors, administrators, successors and
assigns.
26, InteQ'ration:
This Agreement constitutes the entire
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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,
27, Other Documentation: HUSBAND and WIFE covenant and agree
that they will forthwith execute any and all written instruments,
assignments, releases, satisfactions, deeds, notes or such other
writings as may be necessary or desirable for the proper
effectuation of this Agreement,
This Agreement shall remain in
28 . No Wai ver on Defaul t:
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 default
or breach of any provisions hereof be construed as a waiver of any
subsequent default or breach of the same or similar nature, nor
shall it be construed as a waiver of strict performance of any
other obligations herein,
29, Severability:
If any term, condition, clause or
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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, effect and operation, Likewise, the
failure of any party to meet his or her obligation 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,
30. Breach: If either party breaches any provision of this
Agreement, the other party shall have the right, at his or her
election, to sue for damages for such breach or seek such other
remedies or relief as may be available to him or her, The party
breaching this contract shall be responsible for payment of
reasonable legal fees and costs incurred by the other in enforcing
their rights under this agreement,
31, Headinqs Not Part of Aqreement: Any heading 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
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meaning, construction or effect.
IN WITNESS WHEREOF, the parties hereto have set their
hands and seals this day and year first above written,
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SHERI '. PECHARTL,
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
,
CIVIL ACTION - LAW
SHERI A. PECHART,
Plaintiff
: No. 2000-3879 Civil Term
v.
JEFFREY K. PECHART,
Defendant
: IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
To The Prothonotary:
Transmit the record, together with the following information, to the Court for entry of a
divorce decree:
L Ground for divorce: Irretrievable breakdown under Section 3301(c) of the Divorce
Code,
2, Date and Manner of service of the Complaint: Sent to Defendant on June 23. 2000 by
U,S, first class mail. oostage ore-oaid. certified/restricted deliverv, Received bv Defendant on Julv
3.2000,
3, Complete either paragraph (a) or (b),
(a) Date of execution of the Affidavit of Consent required by Section 330l(c) of the
Divorce Code: by Plaintiff, October 13. 2000; by Defendant, October 13. 2000,
(b)(1) Date of execution of the Plaintiff's Affidavit required by Section 3301 (d) of the Divorce
Code: N/A
(2) Date of filing and service of the Plaintiff's Affidavit upon Defendant: N/A,
4, Related claims pending: All claims have been resolved bv the Prooertv Settlement
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Agreement dated October 12.2000,
5, Complete either paragraph (a) or (b),
(a) Date and manner of service of the notice of intention to file Praecipe to Transmit
Record, a copy of which is attached: N/A
(b) Date Plaintiff's Waiver of Notice in Section 3301(c) Divorce was filed with the
Prothonotary: October 23. 2000,
(c) Date Defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the
Prothonotary: October 23. 2000,
Plaintiff's Social Security Number: 177-60-4085
Defendant's Social Security Number: 184-50-3367
~~Wre
LEGAL SERVICES, INe.
8 Irvine Row
Carlisle, PAl 70 13
(717) 243-9400
LD, # 61900
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA
CIVIL ACTION - LAW
SHERI A. PECHART,
Plaintiff
.
; No..(CX)o-3?19
Civil Term
v.
JEFFREY K. PECHART,
Defendant
: IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth
in the following pages, you must take prompt action,
You are warned that if you fail to do so, the case may proceed without you and a decree of
divorce or annulment may be entered against you by the Court, A judgment may also be entered
against you for any other claim or relief requested in these papers by the Plaintiff, You may lose
money or property or other rights important to you, including custody or visitation of your children.
When the ground for 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, Cumberland County Courthouse, I Courthouse Square, Carlisle, Pennsylvania,
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 TmS 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, PA 17013
(717) 249-3166
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Le han demandado a usted a la corte, Si usted quiere defenderse en contra estas demandas
expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la
demanda y la notificacion, Usted debe presentar una apariencia escrita 0 en persona 0 por abogado
y archivar en la corte en forma escrita sus defensas 0 sus objeciones a las demandas en contra suya,
Se has avisado que si usted no se defienda, la corte tomara me9idas y puede entrar una orden
contra usted sin previo aviso 0 notificacion y por cualquier que ja 0 alivio que es pedido en la
peticion do demanda, USTED PUEDE PERDER DINERO 0 PROPIENDADES 0 OTROS
DERECHOS IMPORTANTES PARA USTED,
LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI USTED NO
TIENE 0 CONOCES UN ABOGADO, VA Y A EN PERSONA 0 LLAME POR TELEFONO A LA
OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR
DONDE SE PUEDE CONSEGUlR ASISTENCIA LEGAL,
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with the
Americans with Disabilities Act of I 990, For information about accessible facilities and reasonable
accommodations available to disabled individuals having business before the Court, please contact
our office, All arrangements must be made at least 72 hours prior to any hearing or business before
the Court, You must attend the scheduled Conference or Hearing,
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PAl 70 13
(717) 249-3166
,
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
SHERI A. PECHART,
Plaintiff
: No.
()-(J.3f7Q Cw.ze f~
v.
JEFFREY K. PECHART,
Defendant
: IN DIVORCE
COUNT I
COMPLAINT UNDER SECTION 330Hc) and 330Hd)
OF THE DIVORCE CODE
AND NOW comes SHERI A. PECHART, by and through her attorney,
Maryann Murphy, Esquire of Legal Services, Inc., who respectfully
avers as follows:
1. Plaintiff is SHERI A. PECHART whose current address is
4183 Cove Court, Mechanicsburg, Cumberland County, Pennsylvania.
2, Defendant is JEFFREY K. PECHART whose current address is
1133 Laurel Avenue, Camp Hill, Cumberland County, Pennsylvania.
3, Plaintiff and Defendant have been bona fide residents in
the Commonwealth for at least six months immediately previous to
the filing of this Complaint,
4. Plaintiff and Defendant were married on May 27, 1982 in
Cumberland County, Pennsylvania,
5, There have been no prior actions for divorce or for
annulment between the parties.
,> ,-
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6 . Defendant is not a member of the Armed Forces of the
United States of America or any of its Allies.
7. The marriage is irretrievably broken.
8. Plaintiff has been advised of the availability of
marriage counseling and that she may have the right to request the
Court to require the parties to participate in such counseling,
Being so advised, Plaintiff does not request that the Court require
the parties to participate in counseling prior to a Divorce Decree
being handed down by the Court.
9. Plaintiff requests this Court to enter a Decree in
Divorce from the bonds of matrimony.
COUNT II
CLAIM FOR EQUITABLE DISTRIBUTION OF MARITAL PROPERTY
UNDER SECTION 3502 OF THE DIVORCE CODE
10, plaintiff hereby incorporates by reference all of the
averments contained in Count I of this Complaint.
11. Plaintiff and Defendant are the owners of motor
vehicles, retirement benefits, etc. acquired during the marriage
which is subject to equitable distribution by this Court.
12, Plaintiff and Defendant have been unable to agree as to
an equitable division of said property as of the date of the filing
of this Complaint.
',,:---
Ii".""",,
13, Plaintiff requests this Court to equitably distribute the
parties' marital property,
COUNT III
CLAIM FOR ALIMONY
ONDER SECTION 3701 OF THE DIVORCE CODE
14, Plaintiff hereby incorporates by reference all of the
averments contained in Counts I and II of this Complaint,
15. Plaintiff does not have a sufficient source of income or
earning capacity at the present time to maintain the standard of
living enjoyed by the parties during their marriage,
16. Defendant does have a sufficient source of income and
earning capacity to aid Plaintiff in maintaining the standard of
living enjoyed by the parties during their marriage,
17, Plaintiff requests this Court to grant her alimony to
enable her to maintain the standard of living enjoyed by the
parties during their marriage.
WHEREFORE, Plaintiff requests this Honorable Court to
enter a Decree:
a. dissolving the marriage between the Plaintiff and
Defendant; and
b. equitably distributing all property owned by the
parties hereto; and
I'-~
c,
d,
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granting alimony to Plaintiff;
for such further relief as the
to be equitable and just,
and
Court may determine
Respectfully submitted,
Maryann Murphy, Esquire
LEGAL SERVICES, INC.
a Irvine Row
Carlisle, PA 17013
(717) 243-9400
LD, # 61900
Attorney for Plaintiff
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I, SHERI A. PECHART, verify that the statements made in the
foregoing Complaint in Divorce are true and correct. I understand
that false statements herein are made subject to the penalties of
18 Pa. c. S, Section 4904, relating to unsworn falsification to
authorities,
(rr l-:droo
~'~A-
SBER~. PEbHART
Date
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
SHERI A. PECHART,
Plaintiff
: No.
v.
JEFFREY K. PECHART,
Defendant
: IN DIVORCE
NOTICE TO DEFENDANT
If you wish to deny any of the allegations set forth in this affidavit, you must me a
counterclaim within twenty (20) days after this affidavit has been served on you or the
allegations will be admitted.
AFFIDAVIT OF PLAINTIFF UNDER
SECTION 3301 (d) OF THE DIVORCE CODE
I, The parties to this action separated in October of I 997 and have continued to live separate
and apart for a period of at least two years,
2, The marriage is irretrievably broken,
3, I understand that I may lose rights concerning alimony, division of marital property,
attorney's fees or expenses if! do not claim them before a divorce is granted,
I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT
ARE TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE, INFORMATION AND
BELIEF. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT
TO THE PENALTIES OF 18 Pa.C.S. SECTION 4904 RELATING TO UNSWORN
FALSIFICATION TO AUTHORITIES.
iJ- - 7- dJ::cD
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Date
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
SHERI A. PECHART,
Plaintiff
: No.
v.
JEFFREY K. PECHART,
Defendant
: IN DIVORCE
CERTIFICATE OF SERVICE
I, Maryann Murphy, Esquire, do hereby certify that a true and
correct copy of the within Divorce Complaint and Affidavit of
Plaintiff under Section 3301(d) of the Divorce Code was mailed to
the Defendant, JEFFREY K. PECHART, by first class U.S. mail, postage
pre-paid, certified/restricted delivery, addressed as follows:
Jeffrey K, pechart
1133 Laurel Avenue
Camp Hill, PA 17011
Respectfully submitted,
MUrphy,
LEGAL SERVICES,
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
LD, # 61900
Attorney for Plaintiff
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA
CIVIL ACTION - LAW
SHERI A, PECHART,
Plaintiff
; NO, ;;000 - 38'79
Civil Term
v,
PRAECIPE TO PROCEED IN FORMA PAUPERIS
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: IN DIVORCE
JEFFREY K. PECHART,
Defendant
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To the Prothonotary:
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Kindly allow, SHERI A. PECHART, Plaintiff, to proceed in forma pauperis,
I, Maryann Murphy, Esquire, of Legal Services, Inc" attorney for the party proceeding
in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing
free legal services to the party, The party's affidavit showing inability to pay the costs of
litigation is attached hereto,
Vru ~!At.l
Maryann M rphy, Esquire
Legal Services, Inc,
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
LD, # 61900
Attorney for Plaintiff
"
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
SHERI A, PECHART,
Plaintiff
: NO. ll'O' 3 S 7'1
Civil Term
v,
: IN DIVORCE
JEFFREY K. PECHART,
Defendant
AFFIDAVIT IN SUPPORT OF PETITION
FOR LEAVE TO PROCEED IN FORMA PAUPERIS
1, I am SHERI A. PECHART, the Plaintiff in the above matter and because of my
financial condition am unable to pay the fees and costs of prosecuting, defending, or appealing
the action or proceeding,
2, I am unable to obtain funds from anyone, including my family and associates, to pay
the costs of litigation,
3, I represent that the information below relating to my ability to pay the fees and costs
is true and correct.
(a) Name: SHERI A, PECHART
Address: 4183 Cove Court. Mechanicsburg. PA 17055
(b) Social Security Number: 177-60-4085
If you are presently employed, state N / A
Employer:
N/A
Address:
N/A
Salary or wages per month: N/A
Type of work:
N/A
, ~""";'
If you are presently unemployed, state
Date of last employment:
12/99
Salary or wages per month:
$8,50 per hour
Type of work:
Receptionist
(c) Other income within the past twelve months
Business or profession: -0-
Other self-employment: -0-
Interest: -0-
Dividends: -0-
Pension and annuities: -0-
Social Security benefits: -0-
Support payments: $866,00
Disability payments: -0-
Unemployment compensation and
supplemental benefits: -0-
Workman's compensation: -0-
Public Assistance: -0-
Other: -0-
(d) Other contributions to household support N/A
If your (husband) (wife) is employed, state
(Husband)(wife) Name: N/A
Employer: N/A
~ . " ," - ,- ,--
~~
Salary or wages per month:
Type of work:
Contributions from children:
N/A
N/A
-0-
(e) Property owned
Cash:
Checking Account:
Savings Account:
Certificates of Deposit:
Real Estate (including home):
-0-
-0-
$8,00
-O-
N/A
Motor vehicle: Make Chevrolet
Year
1986
Cost $3.500,00
Amount owed
-0-
Stocks; bonds:
Other:
-0-
-0-
(t) Debts and obligations
Mortgage: N/A
Rent: $635,00
Loans: -0-
Monthly Expenses: $1.200,00
(g) Persons dependent upon you for support
(Wife) (Husband) Name: N/A
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Children, if any:
Name: Amanda
Age: 17
Age: 9
Name: SDencer
4, I understand that I have a continuing obligation to inform the court of improvement in
my fInancial circumstances which would permit me to pay the costs incurred herein,
5, I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa, C,S, 4904, relating to unsworn
falsifIcation to authorities,
Date: IJ.. - r Jed)
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
SHERI A. PECHART,
Plaintiff
: No. 2000-3879 Civil Term
v.
JEFFREY K. PECHART,
Defendant
: IN DIVORCE
AFFIDAVIT OF CONSENT
L A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on June
22, 2000,
2, The marriage of Plaintiff and Defendant is irretrievably broken, and ninety (90) days have
elapsed from the date of filing and service ofthe Complaint
3. I consent to the entry of a final decree of divorce after service of notice of intention to
request entry of the decree,
I verifY that the statements made in this affidavit are true and correct I understand that false
statements herein are made subject to the penalties of 18 Pa,C.S, Section 4904 relating to unsworn
falsification to authorities,
\0- \~-;;).oo()
Date
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SHE A. PECHART
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
SHERI A. PECHART,
Plaintiff
: No. 2000-3879 Civil Term
v.
JEFFREY K. PECHART,
Defendant
: IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301(c) OF THE DIVORCE CODE
I, 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 in 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, Section 4904 relating to unsworn
falsification to authorities,
\0- \~-~OZl
Date
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SHE A. PECHART
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
SHERI A. PECHART,
Plaintiff
: No. 2000-3879 Civil Term
v.
JEFFREY K. PECHART,
Defendant
: IN DIVORCE
AFFIDAVIT OF CONSENT
L A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on June
22, 2000,
2, The marriage of Plaintiff and Defendant is irretrievably broken, and ninety (90) days have
elapsed from the date of filing and service ofthe Complaint
3, I consent to the entry of a final decree of divorce after service of notice of intention to
request entry of the decree,
I verify that the statements made in this affidavit are true and correct I understand that false
statements herein are made subject to the penalties of 18 Pa,C.S, Section 4904 relating to unsworn
falsification to authorities,
/t1-/3 -(jf)
Date
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
SHERI A. PECHART,
Plaintiff
: No. 2000-3879 Civil Term
v.
JEFFREY K. PECHART,
Defendant
: IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301(c) OF THE DIVORCE CODE
I, 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! 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, Section 4904 relating to unsworn
falsification to authorities,
/1) -/:1 -CTZI
Date
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
SHERI A. PECHART,
Plaintiff
: No. 2000-3879 Civil Term
v.
JEFFREY K. PECHART,
Defendant
: IN DIVORCE
AFFIDAVIT OF SERVICE
I, Maryann Murphy, Esquire, depose and say:
1, That I am an adult individual residing in Cumberland County, Pennsylvania,
2, That on June 23, 2000, I sent by U,S, first class mail, postage pre-paid,
.
certified/restricted delivery, number 7099 3400 0004 52 I 67429, a 3301( c) Complaint in Divorce to
the Defendant, JEFFREY K. PECHART, at the following address:
Jeffrey K, Pechart
1133 Laurel Avenue
Camp Hill, PAl 70 11
3, That on July 3,2000, the Defendant was served with the Complaint in Divorce
as evidenced by his signature on the green card, number 7099 3400 0004 5216 7429, which is
attached hereto,
~"ire
LEGAL SERVICES, INe.
8 Irvine Row
Carlisle, P A 17013
(717) 243-9400
LD, # 61900
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA
CIVIL ACTION - LAW
SHERI A. PECHART,
Plaintiff
: No. 2000-3879 Civil Term
v.
JEFFREY K. PECHART,
Defendant
: IN DIVORCE
NOTICE TO RESUME PRIOR SURNAME
Notice is hereby given that the Plaintiff in the above matter, having been granted a Final
Decree in Divorce on the 25th day of October, 2000, hereby elects to resume the prior sumame of
Sheri A, McClain, and gives this written notice pursuant to the provisions of 54 P,S, Section 704,
Date: I/-:;J,. _e..
~~ ~ 9. .\e.<:i--
SHE ANN PECHART
~~. \-:~~
SHE~NN McCL~ .
COMMONWEALTH OF PENNSYLVANIA:
: ss:
COUNTY OF CUMBERLAND
On the k..I day of I1l /7J~ ,~.(. , 2000, before me, a Notary Public, personally
appeared the above affiant known to me to be the person whose name is subscribed to the within
document and acknowledged that she executed the foregoing for the purpose therein contained,
In Witness Whereof, I have hereunto set my hand and official seaL
~~~-:~AJA~
Notary Public
. NOT ARIAt. SEAL
PATRICIA A SHATTO. Notary Public
Carlisle BOlO, Cumber/and County
My Commlslion Expir.i December 17. 2001
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