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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
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STATE OF 1~ PENNA.
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MARILYN}. CANTALUPI,
Plaintiff
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JOHN D. CANTALUPi.
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DECREE IN ~ 8
ANDNOW.Xl~'tf,:.,E<<!:;'~~'~~d ~ :
Defendant
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decreed that ,',',""'" MARILYN, J.., ,CANTALUPI. " , , , , " " , " plaintiff,
and,.."""..,..""", ,-!9!"1.~ ,I?:..GtWrAI.,l!"'~,..,..,......... defendant,
are diyorced 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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MARILYN J. CANTALUPI,
plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 97 - 374 civil
vs.
JOHN D. CANTALUPI,
Defendant
IN DIVORCE
AND NOW,
ORDER OF ~
this ~~ day
Of~
1998, the economic claims raised in the proceedings having been
resolved in accordance with a property settlement agreement
dated september 2, 1998, the appointment of the Master is
vacated and counsel can file a praecipe transmitting the record
to the court requesting a final decree in divorce.
BY THE COURT,
cc:
Wayne F. Shade
Attorney for plaintiff
Hubert X. Gilroy
Attorney for Defendant
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PROPERlY SEmEMENT AGREEMENT
TInS IS AN Agreement made this J....J day of September, 1998, by and between, John D.
Cantalup~ (hereinafter referred to as Husband) and Marilyn 1. Cantalup~ (hereinafter referred to as
Wife),
WHEREAS, Husband and Wife were married on ]u1y 8, 1978; and
WHEREAS, various differences have arisen between Husband and Wife, whereby they have been
living separate and apart; and
WHEREAS, the Wife has commenced a diyorce action against Husband docketed at No.97 - 374 in
Cumberland County, Pennsylvania; and
WHEREAS, the parties desire to enter into an amicable settlement to provide for all of the property
rights of the parties and to dispose of the rights and obligations of each to the other in respect to
support, maintenance, alimony, counsel fees, equitable distribution, and all other rights and obligations
under the Diyorce Code of 1980, as amended, and it is the intention and agreement of the parties that
this Agreement be a fuU, complete and final settlement of all of those rights and obligations under said
Diyorce Code; and
NOW, THEREFORE, for and in exchange of mutual considerations, and intending to be bound by the
provisions hereof, the parties agree that their recitals fonn a part of this Agreement and waive any right
to counseling under the Diyorce Code of 1980, as amended, and right to counsel fees, costs, alimony,
support, maintenance, and any other rights under the said Diyorce Code not provided for herein and
agree as foUows:
1
The parties agree that it shall be lawful for each party, at all times hereafter, to live separate and apart
from the other, at such place or places as he or she may, from time to time, choose or deem fit. Each .
party sha1I be free from intenerence, authority or contact by the other, as fully as if he or she were
single and unmarried, except as may be necessary to carTY out the provisions of this Agreement.
Neither party sha1I molest the other or attempt to endeayor 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
peacefu1 existence, separate and apart, from the other.
hi
10
The parties will enter into a separate Stipulation for purposes of presentation to the Court for
entry of an order on custody. The Stipulation shall recite that the parties shall share legal custody
of the their three minor children, SteyeR, Brian and Susan. Physical custody shall be handled such
that Steyen will reside primarily with Wife, Brian willliye primarily with Husband. and Susan will
alternate between the two parents on a weekly basis. The Stipulation will further set forth that
~d~~~~~.M~~~d~~~~~
with Father.
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The parties will enter into a Stipulation Agreement relating to support whereby Husband sha1I pay to
Wife support in an amount pursuant to DRO guidelines, This Support Agrcel1lCfIt may be modified as
cifQ1lllStlUlCCS change, these circumstances to include the custody of the children. the earnings of the
parties and other related matters,
12
The parties agree that Husband will be able to claim the dependency deduction for Federal
Income Tax purposes for Brian and Susan in 1998, Mother shall be able to claim Stephen.
Assuming the support obligation as set forth in Paragraph II aboye continues in 1999, Husband
shall also be able to claim dependency deduction for Brian and Susan for that year. The parties
will renegotiate this issue for the year 2000 and thereafter.
13
Each party hereby represents they have disclosed all of the marital assets to the other party in the
negotiations for the consumption of this Agreement. '
14
Both parties shall incur their own legal expenses with respect to this diyorce litigation,
IS
The parties agree that they will not contraet or incur any debt or liability for which the other party
might be responsible and sha1I indemnify and save the other party hann1ess from any and all claims or
demands made against that party by reason of such debts or obligations incurred by the other party.
16
Should a decree, judgment or order of separation or diyorce 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 modi6cation and revision thereof shall
alter, amend or vary any tenn of this Agreement, whether or not either or both of the parties shall
remarry, it being understood by and between the parities hereto that this Agreement shall surviye and
shall not be merged into any decree, judgment, or order of divorce or separation. It is specifically
agreed, however, that a copy of this Agreement or the substance of the provisions thereo~ may be
incorporated by reference into any diyoree, judgment or its decree. This incorporation, however, shall
not be regarded as a merger, it being the specific intent of the parties to pennit this Agreement to
swvive any judgment and to be forever binding and conclusive upon the parties,
17
Husband and Wife do hereby mutually remise, release. quit claim or forever discharge the other and the
estate of such other, for all time to come, and I' Of all purposes whatsoever, from any and all rights, title
and interest, or c1aims in or against the estate of such other, of whatever nature and wherever situate,
which he or she now has or at anytime hereafter may haye against such other, the estate of such other
or any part thereo~ whether arising out of any fonner acts, contracts, engagements or liabilities of such
other or by way of dower or courtesy of claims in the nature of dower or curtsey, or widow's or
widowCl'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
or other rights of the surviving spouse to participate in a deceased spouse's estate, whether arising
under the laws of Pennsylvania, any state, commonwealth or tenitory of the United States, or any other
country or any right which either party may now haye or at anytime hereafter haye for past, present or
future support or maintenance, alimony, alimony pendente lite, counsel fees, 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 provision 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 righl~ and agreements and obligations of whatsoever nature arising
or which may arise under this Agreeinent or for the breach of any provision thereof. -
18
Each of the parties shall, from time to tim~ at the request of the other, execute, acknowledge and .
deliver to the other party any and all further instruments or documents that may be reasonably required
to giye full force and effect to the provisions of this Agreement.
19
A modification or waiyer of any of the provisions of this Agreement shall be effective only if made in
writing and executed with the same fonnality as this Agreement. The fiIiIure of either party to insist
upon the strict perfonnance of any of the provisions of this Agreement shall not be c:onstrued as a
waiver of any subsequent default of the same or similar nature.
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COMMONWEAL 111 OF PENNSYL V ANlA
COUNTY OF CUMBERLAND
: ss
On this, the 2nd day of September, 1998, btfore me a Notary Public, the undersigned officer,
personally appeared John D. Cantalupi, known to me (or satisfactorily proyen) to be the person
whose name is subscribed to the within instrument, and acknowledged that he executed the same
for toe purpose therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and notarial seal,
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NoIItIII Seat
Bt\daII Am ColcOI8n. =
CailIsl4I Boro, CmlbIItand
MV Comr1UIIon ExpIres June 10. 2
COMMONWEAL 111 OF PENNSYLVANIA
: ss
COUNTY OF CUMBERLAND
On this, the /'Tr/, day of ~ L.... ,1998, before me a Notary Public, the
undersigned officer, personally app ed Marilyn J. Cantalupi, known to me (or satisfactorily
proyen) to be the persons whose names are subscribed to the within instrument, and acknowledged
that they executed the same for the purpose therein contained,
IN WITNESS WHEREOF, I have hereunto set my hand and notarial seal,
c.:,...~~~
Notary lic
Notarial Seal
Connie J. Trill, Nolary Public
Carlisle, Cumberland County
; My Commission ExpllllS Oct, 6.2000
WAYNE F. SHADB
A.....,. ..lAw
53 Well Pam(", SIred
Carliole, I'moIyIvIDia
17013
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MARILYN J. CANTALUPI,
plaintiff
IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
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v.
NO. 97- 3 7~
CIVIL TERM
JOHN D. CANTALUPI,
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 the divorce is indignities or
irretrievable breakdown of the marriage, you may request marriage
counseling. A list of marriage counselors is available in the
Office of the prothonotary at
CUMBERLAND COUNTY COURTHOUSE, CARLISLE. PENNSYLVANIA 17013
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF
PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT
IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Court Administrator
Fourth Floor
Cumberland County Courthouse
Carlisle, Pennsylvania 17013
Telephone: (717) 240-6200
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Wayn F. Sha e
Attorney for Plaintiff
5.
The parties have been living separate and apart since
January 15, 1997.
6.
Plaintiff avers as the grounds on which this action is based
that the marriage of the parties is irretrievably broken.
7.
There have been no prior actions for divorce or annulment of
this marriage in Pennsylvania or in any other jurisdiction.
8.
Both parties to this Action in Divorce are legally capable
of managing their own concerns.
9.
Defendant herein is not a member of the armed forces of the
United states of America.
10.
There were three children born to the parties, namely,
steven John Cantalupi, born July 6, 1980, Brian Albert Cantalupi,
born October 1, 1983, and Susan Elizabeth Cantalupi, born
December 15, 1985.
11.
WAYNI! F. SHADE
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53 Weal. Pomfm Strtd
Carlisle, Pcm.ylv....
17013
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.
WHEREFORE, Plaintiff demands judgment dissolving the
marriage between the parties.
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I verify that the statements made in this pleading 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.
Date: January ~(>, 1997
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CARU8L.C. PENNSYLVANIA 17013
t717J "'.04e74 7....'..0
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MARILYN J. CANTALUPI,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
v.
.
.
: NO. 97 - 374
CIVIL TERM
JOHN D. CANTALUPI,
Defendant,
.
.
.
.
: IN DIVORCE
PRAECIPE
TO THE PROTHONOTARY:
Please enter my appearance as counsel of record for the above
captioned Defendant.
Dated: February 7, 1997
ert X. G' roy, Esquire
BroUjos, G' roy & Houston, P.C.
4 North H over Street
Carlisle PA 17013
(717) 24 -4574
cc: Wayne F. Shade, Esquire
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MARILYN J. CANTALUPI,
Plaintiff
:IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
:CIVIL ACTION - LAW
v.
JOHN D, CANTALUPI,
Defendant
:NO. 97-374 CIVIL TERM
:IN DIVORCE
NOTICE TO PLEAD
TO: Marilyn J. Cantalupi C/O ATTORNEY Wayne F. Shade, 53 West Pomfret Street, Carlisle,
PA 17013
You are hereby notified to file wrillen response to the enclosed Counterclaim within twenty (20)
days from service hereof or judgment may be entercd against you.
Hubert X. Oil , Allomey for Plaintiff
Broujos & . roy
Allomey at Law
4 N. Hanover Street
Carlisle, P A 17013
(717) 243-4574
MARILYN J, CANTALUPI,
Plaintiff
:IN THE COURT or COMMON PLEAS or
:CUMBERLAND COUNTY, PENNSYLVANIA
:C1VIL ACTION - LAW
v.
:NO. 97-374 CIVIL TERM
JOHN D. CAI'IT ALUPI,
Defendant
:IN DIVORCE
ANSWER TO COMPLAINT AND COUNTERCLAIM
Defendant, John D. Cantalupi, by his allomeys, Broujos & Gilroy, P,C" sets forth the following
in response to the Plaintill's Complaint:
Admitted.
2
Admitted.
3
Admitted.
4
Admitted.
5
Admilled.
6
Admitted.
7
Admilled.
8
Admitted.
9
Admitted.
10
Admitted.
II
Admitted.
WHEREFORE, Defendant joins in Plaintitl's request that a judgment of divorce be issued
between the parties.
COUNT II
12
Admitted.
13
Admitted.
WHEREFORE, Defendant joints in Plaintitl's request that the Court equitably divide the marital
property of the parties.
COUNTERCLAIM IN DIVORCE
14
The allegations set forth in paragraphs I through 13 above are incorporated herein by reference
thereto.
IS
The Plaintiff, Marilyn J. Cantalupi, has offered such indignities to the Defendant, John D.
Cantalupi, her innocent and injured spouse, as to render his condition intolemble and life
burdensome.
16
Plaintiff, Marilyn J. Cantalupi, has committed adultery.
17
Defendant, John D. Cantalupi, is an innocent and injured spouse.
WHEREFORE, Defendant, John D. Cantalupi, requests that the Court issue a judgment diyoreing
him from Marilyn J. Canlalupi.
Respectfully submitted,
VERIFICATION
I yeri fy that the statements made in the foregoing documents are true and correct. I
understand that false statements herein are made subjeet to the penalties of 18 Pa,C.S. Section
4904, relating to unsworn falsification to authorities.
WITNESS
2:~CA~LUPI
.
OFFICE OF DIVORCE MASTER
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
9 North Hanover Street
Carlisle, PA 17013
(717) 240.6535
E. Robert Elicker, II
Divorce Masler
Tracl .10 Col~er
Office Maneger/Repoller
West Shore
697,0371 Ext, 6535
June 16, 1998
Hubert X. Gilroy, Esquire
BROUJOS & GILROY
4 North Hanover street
Carlisle, PA 17013
RE: Marilyn J. Cantalupi vs. John D. Cantalupi
No. 97 - 374 civil
In Divorce
Wayne F. Shade, Esquire
53 West Pomfret Street
Carlisle, PA 17013
Dear Mr. Shade and Mr. Gilroy:
By order of Court of President Judge George E. Hoffer
dated June 9, 1998, the full-time Master has been appointed in
the above referenced divorce proceedings.
A divorce complaint was filed on January 22, 1997,
raising grounds for divorce of irretrievable breakdown of the
marriage and the economic claim of equitable distribution. On
June 8, 1998, the Defendant filed an answer and counterclaim.
The counterclaim raised the grounds for divorce of indignities
and adultery.
The only economic claim pending before the Master is
equitable distribution. I am unable to tell from the pleadings
whether or not counsel need to proceed on grounds other than
no-fault grounds; however, I am going to proceed on the basis
that grounds for divorce are not an issue and direct that each
counsel file a pre-trial statement in accordance with P.R.C.P.
1920.33(b) on or before Friday, July 17, 1998. If grounds for
divorce are an issue and we need to schedule a hearing on the
grounds of indignities and/or adultery, please advise
immediately. Otherwise, upon receipt of the pre-trial
statements I will immediately schedule a pre-hearing conference
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FNC1243-6221
JOHN 11, BROUJOS
HUBERT X, GILROY
BROUJOS 8 GILROY. p,c.
ATrORNEYS AT U\W
.S NOR.TIlIf^IJOVER. SnUtT
CARLISLE, PENNSYLVANIA 1/013
111-243-4514
NON-TOLL FOR HARRI.\8URG AR[^:
711-166-Il:mO
August 6, 1998
E, Robert Elicker, II, Esquire
Office of the Divorce Master
9 North Hanover Street
Carlisle, PA 17013
Re: Cantalupi v Cantalupl
Dear Bob:
I am leaving on vacation on August 7<11 and I will not be back In the office until August
17<11. Can we get another week or ten days on the pre-trial memos due In tills case?
Unless I hear from you to the contrary, I will assume there is no problem.
Yours Sincerely,
dch
cc: Wayne F. Shade, Esquire
John Cantalupi
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WAYNE F. SHADE
Ar/lJRNEY AT I.A W
l,\ WI.ST 1~)~trRET STREET
l'ARI.ISIJ,I'FNNSYl.VANIA 170U
( 7171 24)-l)2Z0
181HI) 24.1-l)220
"A" (717)249.0017
June 19, 1998
E. Robert Elicker. II, Esquire
Office of the Di;1oree Master
9 North Hanover Street
Carlisle, Pennsylyania 17013
Re: Canlalupi Y. Cantalupi
No. 97-374 Ciyil
Dear Mr. Elicker:
You may recall your letter of June 16, 1998, with respect to the above and which
established a deadline of July 17, 1998, for the tiling of pre-trial statements.
Although it seems as though I am always trayeling, the fact is that I haye not had a
real yacation in more than two years. I will be on yaeation from June 22 through July 17.
Of course, when I return from yacation, 1 will haye the usual sole practitioner
inundation with correspondence and telephone messages.
It will take some significant ellort to properly prepare a pre-trial statement in this
case. If we could have an extension to tile our pre-trial statement until August 14, 1998,
it would be very much appreciated.
We do not belieye that Attorney Gilroy will object to this request. However, in an
effort to ayoid problems with his client lor his agreeing, we are proYiding him with a
copy of this letter with the request that his client agree to this request.
Very truly yours,
?G/~
Wayne F. Shade
WFS/cjt
cc: Hubert X. Gilroy, Esquire