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Home My WebLink About97-02184 I ~ I ! I 7- ~ E d Q( . .tJ 7 ~ / I I I ! I ! E '- ~ J " ::r- OO - ((J I r- 0-, I .1 D' zl I I . <<<. .:c- .;.:. .:c. .:<<. .:e:. <<<. .;c. '.:<<. :<<. '.*. .:<<. <~. .:.;. .:.:. .:.:. .:<<. .:.;. -:c. .:.:. :. .~. .:c. ~..:. .:<<- .:<<. <.~. .:<<- ... .;c. .;. ~, '.. ~. .'... . '~,' v ~' ~' ~) ~ . r ~: ~' "j X ,) ~I , J , J ~I xl ~! ~) IN THE COURT OF COMMON PLEAS OF CUMBERLAND STATE OF ~~! COUNTY PENNA, GEORGE P. RAMSEY, Plaint iff l\ I I, "" 2184 .' CIVIL II) 97 \'t.''....ILi ~ ,;, 0:; DEBRA K. RAMSEY, Defendant '" ~ ~I' ~ ' ~l : ! ~' , ) . ... ~ ~ 8 ~ $ 8 ~ ,;, " ~ ~ ~ ~ ~ ~ ~ ~ ~ _ ______, 'v. ~~. ... -:<<. .>>:. .~:. . DECREE IN DIVORCE AND NOW, . '~W4 . .1. ) 19Ci').. ;, ;, o,d.,.d ond decreed that,. ,(b.0V\v~ . f. .{.WrrYl~" , " plaintiff. and.", ,~1JJ.:tM-,,~ v.~v.~'1"""""'.\', defendant. are divorced from the bonds of matrimony, The court retains jurisdiction of the following claims which have been raise0 ?f record in this action for which a final order has not yet been entered; NONE... .. . ' , . , , , " , ........,... "......". ... ... ,., ,. ,. .... ........ ... .,.. ..."""'..,.,....""".,.....7";/"""'.,.""'" u, fr~c4(~' ~H_/ it0. AII~.t~uN#lU ,,7' t. ~ e.....zf_~ J, ?)Ja r~:&,. {)~ Prothonotary 8 ~ . ~ J, !1iI I~ I~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ,~ ~ 8 ~ " !~ i' I~ J. ( : liti l~ J~ , , . /;1 i~ I~ I~ ,~ ,i".' f.', i'l / : ;~ , . ~ , i~ , ' t... )~ , . .~ " ~ ~ ~ ., - - ~ ~~.~~*,~**~**.~*~..~..~.~..~~~~"~.~,~. ~ . ::.397 tV. ~/~;'~./~ a#~ ~:3 ,;) /,l'L;~ /Hi~ ~ crK . f . !f , \. . PROPERTY SETT~EMENT AGREEMENT ,f) , t, THIS AGREEMENT, made this 2,3 day of April, 1997. by and between George P. Ramsey (hereinafter referred to as "HUSBAND'). of Cumberland County. Pennsylvania. and Debra K, Ramsey (hereinafter referred to as "WIFE'), of Cumberland County, Pennsylvania. WHEREAS, the parties were married on September 3. 1977; and WHEREAS, there were two children born of the marriage, namely, Nathan W, Ramsey, date of birth June 3, 1980 and Lauren D, Ramsey, date of birth April 4, 1983. WHEREAS, diverse unhappy differences, disputes and difficulties have arisen between the parties and it is the intention of Wife and Husband to live separate and apart for the rest of their natural lives, The parties hereto are desirous of settling fully and flJlally their respective fmancial and property rights and obligations as to each other including, without limitation by specification: the settling of all matters between them relating to the ownership and equitable distribution of real and personal property; the settling of all matters between them relating to the past and present support, alimony and/or maintenance of Wife by Husband or of Husband by Wife; the settling of all matters between them relating to the past and present support and/or maintenance of the children; the implementation of custody/visitation arrangements for the minor children of the parties; and, in general, the settling of any and all claims and possible claims by or against the other or against their respective estates, which claims may have arisen pursuant to the Divorce Code of 1980, as amended. NOW. THEREFORE, with the foregoing recitals being hereinafter incorporalCd by reference herein and deemed as an ellSential pan hertof, and intending to be legally bound hereby, and for other good and sufficient considention, the receipt of which is hereby acknowledged, the panics mutually agree as follows: I, EXECUTION DATE, The date of the Agreement shall be construed to be the dale on which the last pany signs this document, 2, SEPARATION. It shall be lawful for each pany at all times hereafter to live sepanle and apan from the other party al such place or places as he or she may, from lime 10 lime, choose or deem fie. 3. NO INTERFERENCE. Each party shall be free from inlerference. authority and control. direcl or indirect, by the other as fully as jf he or she were single and unmarried. Neither shall molest the other. nor compel. nor endeavor to compel the other to cohabit or dwell with him or her. .. :2 - 6, REAL ESTATE. MARITAL RESIDENCE. The parties own as tenan~s by the entireties an improved property known as 18 Sherwood Circle, Enola, Cumberland County, PelUlSylvania, The unpaid balance on the mortgage for the aforementioned improved real estate, held with Chase Bank, is approximately One Hundred Four Thousand Dollan ($104,000,00). HlUband and Wife agree to list and sell the aforementioned real estate with a realtor at a price agreeable to both, Husband and Wife further agree that the balance due on the mortgage with Chase Bank, and all appropriate settlement expenses as per a settlement sheet liS agreed upon by the parties, will be paid in full, and thereafter Husband and Wife shall receive and divide, equally between them, all of the remaining net proceeds from the sale, both ta1cing Fifty Percent (50%) thereof. a. PaYment of expc'n..... DendlDlI sale. This provision regarding the sale of the marital residence (hereinafter "Residence"), and the distribution of the proceeds from such sale, is made in contemplation of Husband and Wife continuing to reside in the Residence until the Residence is sold. During sucb time as both panies continue to reside in the Residence, both Husband and Wife shall share equally all expenses related to the care and maintenance of the Residence, including but not limited to, mortgage payments, property taxes, homeowners' insurance payments, utility payments, water payments, and trash collection fees. - 4 - f. InCOI:ooratlon but not merier of real estate . marital residence Dro"lsloOl. Both panies acknowledge that there are questions regarding the effect of incorporation and merger of an agreement into an order of court, Notwithstanding the present uncertainty of the law or any changes to the law that may occur in the future, it is the express and irrevocable intention of the parties that the tenns regarding payment for the care and maintenance of the Residence and the sale and distribution of proceeds of the Residence are non- modifiable by the Pennsylvania courts. or any other court of competent jurisdiction of any other country in this world. Although this order shall be incorporated into an order of court for enforcement purposes only, the parties expressly intend that this shall not be deemed to be a merger. Both panics expressly Slate that Husband's and Wife's obligation to pay the Residence expenses as set forth in this Agreement are contractual in nahlre. Both panics specifically acknowledge the existence of Section 3502(a) of the Divorce Code and acknowledge their specific intention, request and directive that such section neither govern nor be applied to the tenus of this Agreement. .6- 7. EOUlTABLE DISTRIBUTION. GENERAL CONSIDERATIONS. The parties have attempted to distribute their marital property in a manner which conforms to the criteria set forth in 23 Pa. C.S,A. 13302(a), as amended, of the Pennsylvania Divorce Code, and taking into account the following considerations: the length of the marriage; the fact that it is the fllSt marriage for Husband and the first marriage for Wife; the age, health, station, amount and sources of income of 'he parties; contribution of each party to the education, training or increased earning power of the other party; the opportunity of each party for future acquisitions of capital assets and income; the sources of income of both parties, including but not limited to medical, retirement, insurance or other benefits; the contribution or dissipation of each party, including the contribution of each spouse as a homemaker; the value of the property set apart to each party; the standard of living of the parties established during the marriage; and the economic circumstances of each party at the time the division of property is to become effective. Both parties acknowledge that there are questions regarding the effect of incorporation and merger of an agreement into an order of court, Notwithstanding the present uncertainty of the law or any changes to the law that may occur in the future, it is the express and irrevocable intention of the parties that the terms regarding the distribution of their marital property are non- modifiable by the Pennsylvania courts, or any other court of competent jurisdiction of any other country in this world. - 7 - Although this order shall be incorporated into an order of court for enforcement purposes only, the parties expressly intend that this shall not be deemed to be a merger, Both parties expressly state that Husband's and Wife's rights to receipt of marital property as set forth in this Agreement are contractual in nature, Both parties specifically acknowledge the existence of Section 3S02(a) of the Divorce Code and acknowledge their specific intention, request and directive that such section neither govern nor be applied to the terms of this Agreement, 8. WAIVER OF PENNSYLVANIA DIVORCE CODE RIGHTS. All property set apart herein either now or in the future as the separate property of either Husband or Wife and all property now owned by or titled to Husband or Wife individually or property acquired by Husband or Wife individually at any time after the execution of this Agreement shall remain the separate property of Husband or Wife and shall under no circumstances be considered as, or deemed to be or construed to be "marital property" as that term is used in the Pennsylvania Divorce Code, and such property shall expressly not be subject to equitable distribution nor shall any appreciation in value of such property be subject to equitable distribution. This Agreement shall be deemed to be and construed to be a valid agreement for the purpose of waiving the provisions concerning equitable distribution as tha: tena is used in the Pennsylvania Divorce Code of 1980, as amended. - 8 - 9. RELEASE OF INTEREST IN SEPARATE ASSETS. The panies hereto agree to waive any and all right to claim any interest or share in the sepante assets retained by the other spouse. 10. WAIVER OF PENSION AND OTHER EMPLOYEE BENEFITS. The parties hereby waive any and all right to claim any interest or share in each other's pension, profit-sharing plans and other employee benefits, if any. from their respective employers. The parties acknowledge that Wife is employed by United Concordia Companies, Inc. and Husband is employed by Synenech Health Systems Solutions, Inc, Both acknowledge that they have received information regarding the existence or non-existence of such employment benefits (including but not limited to profit sharing. ESOP plans. pension contributions and plans and 40lk plans) and are satisfied with the information so provided. Both parties agree to sign any and all documents necessary to cause the transfer of his or her interest in any pension/employment benefit, upon request by the other spouse. Further. both parties acknowledge that they understand they must notify their employer and/or appropriate plan administrator of the removal and/or change of any such beneficiary designation. - 9 - 13. INTENDED TAX EFFECT OF DIVISION OF PROPERTY. By Ihis Agreement, the panies have intended to effectuale an equal division of Iheir marital propeny. The panies have delennined that such equal division confonns to a right and just standard with regard to the rights of both panies, The division of existing marital propeny is not, except as may be otherwise expressly provided herein, inlended by the panies 10 conslitute in any way a sale or exchange of assets and the division is being effected without the introduction of outside funds or other propeny not constituting a pan of the marital estate. As a part of the equal division of the marital propenies and the marital seltlement herein contained, the parties agree 10 save and hold each other hannless from all income taxes assessed against the other resulting from the division of the propeny as herein provided. 14. PARTIES' DEBTS. The parties hereby agree to assume sole and exclusive responsibility for the debts as provided below. The responsible party agrees 10 indemnify and hold hannless the other spouse from any and all claims or demands made against the other spouse by reason of the debts of the responsible party. 15. AUTOMOBILE PA VMENTS AND TITLE. Wife agrees to assume the sole obligation for ma1cing monthly payments to Cornerstone Federal Credit Union for the loan secured by a 1993 Dodge Caravan titled in the names of both Husband and Wife. As soon as Wife has made final payment to Cornerstone Federal Credit Union, Husband agrees to transfer his interest in the vehicle to Wife, - 11 - 16. CREDIT CARDS. Each pany hereby agrees 10 return any and all credil , i , I I I:! i ' I 1 ." I cards or charge plales which he or she may have in his or her possession 10 the pany who Is the owner of the account and agrees thaI any debts incurred on any credit cards or charge plales nOI returned to the other pany shall be the sole and exclusive responsibility of the pany who charged the debl, Each agrees 10 save the other hannless from any obligalions or inslitulions of suil commenced due to any charges made on the other pany's card afler the dale of this Agreement. ,., , I Any debts incurred on the credil cards or charge plates after the dale of execulion of this Agreement shall be the sole and exclusive responsibility of the charging pany, who shall save hannless the other spouse from any obligalion or institulion of suit. 17, ALIMONY. Husband shall pay to Wife, for her separale suppon and .~ , \ mainlenance, the sum of Fifty Dollars ($50.00) per month, conunencing on the Saturday following the execution of this Agreement and on a monthly basis thereafter so long as Husband is required 10 pay child suppon for either Nathan W. Ramsey or Lauren D. Ramsey pursuant 10 paragraph 18 of this Agreement. Husband's obligation 10 pay ma1ce alimony payments 10 Wife shall end at the time Husband's obligalion 10 ma1ce child suppon payments for both children ends. - 12 - a. Alimony . Waiver or r1vht to modlncatlon, The alimony provisions herein have been negotiated to take into account the panies' overall economic circumstances, including the equitable distribution of propeny provided for herein, and were agreed to by both parties with the specific understanding that neither the amount nor the duration thereof shall be subject to modification for any reasons, including material changes in financial circumstances, employment status or marital status, cohabitation or death of either pany. The understanding was an inducement and condition precedent to the execution of the overall Agreement. The parties agree that neither will seek a modification hereof in any coun, Further, the parties specifically acknowledge that Section 3105 of the Divorce Code of 1980, as amended, is applicable as it relates to the modification of thls subparagraph and the balance of the Agreement. b. Tax conseauences. It is the understanding of the parties that the periodic payments paid by the Husband to the Wife for her support and maintenance, as set forth hereunder, will be fully deductible by the Husband for income tax purposes and includable in Wife's income. - 13 . ! c. IncorporatIon and merller or allmonv orovlslons. Both parties acknowledge that there are questions regarding the effect of incorporation and merger of an agreement into an order of court. Notwithstanding the present uncertainty of the law or any changes to the law that may occur in the future, it is the express and irrevocable intention of the parties that the payments of alimony set forth herein, both in amount and duration are non- modifiable by the Pennsylvania courts, or any other court of competent jurisdiction or any other country in this world, and the payment obligation shalltenninate only after Husband's obligation to malce child support payments for both Nathan W. Ramsey and Lauren D, Ramsey ends, punuant to paragrapb 18 of this Agreement. ~ Althougb this order shall be incorporaled into an order of coun for enforcement purposes only, the parties expressly inlend that this shall not be deemed 10 be a merger. Both parties expressly state that Husband's obligation 10 pay the sum set forth In this Agreement and Wife's rigbt to receive these sums are contractual In nature. Both parties specifically acknowledge the existence of Section 3701(e) of the Divorce Code and acknowledge their specific Inlention, request and directive that such section neither govern nor be applied to the lenns of this Agreement. - 14 - 18. CUSTODY. Wife shall have majority custody of the panies' minor children, Nathan W, Ramsey and Lauren D. Ramsey. Husband shall have minority custody of the panies' minor children at such times as the panies mutually agree. The panics acknowledge that they are capable of arriving at a workable schedule that is in the best interests of the children and will work to effectuate that intent. 19. CHILD SUPPORT. Commencing the week ending the fIrSt Saturday after the execution of this Agreement, Husband shall pay Wife as child suppon the sum of 1l1rcc Hundred Fifty Dollars ($3S0.00) per month for Nathan W. Ramsey and the sum of Three Hundred Fifty Dollars ($3S0,OO) per month for Lauren D. Ramsey, H\:Sband shall continue to pay such sums on a monthly basis only as long as the child in question continues to live with Wife, and Husband's obligation shall cease when said child graduates from high school or reaches the age of eighteen (18) years, whichever occurs last, or upon the child's ceasing to live with Wife, if earlier than the child's graduation or eighteenth (18th) birthday. At the time Husband's obligation to pay child suppon for either child ends, Husband shall pay Wife as child suppon the sum of Four Hundred Twenty Dollars ($420.00) per month for the child who continues to live with Wife, as long as said child graduates from high school or reaches the age of eighteen (18) ycan, whichever occurs last, or upon the child's ceasing to live with Wife, if earlier than the child's graduation or eighteenth (18th) birthday. - 15 - t r a. Medical Insurance. Husband and Wife agree that Wife shall be responsible for maintaining medical Insurance coverage, dental insurance coverage, and vision insurance coverage for Nathan W. Ramsey and for Lauren D. Ramsey at its current levels. .... Wife's responsibility for providing medical insurance for each child shall cease when said child reaches age eightccn (18) or graduates from high school, whichever occurs last. In addition Husband and Wife funher agree that Husband shall be responsible for maintaining dental ., iru.'Urance coverage, for orthodonlUre only, for Nathan W. Ramsey and for Lauren D. Ramsey at its current levels, Husband's responsibility for providing dental insurance, for orthodonlUre, for each child shall cease when said child reaches age eighteen (18) or graduates from high school. whichever occurs last. - \. b. Non-covered medical expenses. Husband and Wife agree to be equally responsible for any non-covercd medical or dental expenses for the children. Husband agrees that he shall pay his one-half of any such non-covercd expenses within ten (10) days of receipt of the invoice indicating the amount which is due. - 16 - 20. REPRESENTATION BY COUNSEL. The provisions of this Agreement and their legal effect have been fully explained to the panies by their respective counsel. The Wife has employed and had the benefit of counsel of Slephen K. Ponko, Esquire as her attorney. The Husband has employed and had the benefit of counsel of Rhoads & Sinon LLP, Todd J. Shill, Esquire and M, Catherine Nolan, Esquire as his attorneys. Both panies acknowledge that he or she has received independent legal advice from counsel of his or her selcclion and/or has been advised of his or her right to independent legal counsel; that each fully understands the facts and has been fully infonned as to his or her legal rights and obligations; that each party acknowledges and accepts that this Agreement is, under the circumstances, fair and equitable, and that it is being entered into freely and voluntarily after having received such advice and with such knowledge; 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. In addition, each party hereto acknowledges that he or she has been fully advised by his or her respective attorney of the impact of the Divorce Code of 1980, as amended. " '. 21. FILING OF DIVORCE WITH AFFIDA V1T OF CONSENT. Husband and Wife agree that their marriage is irretrievably broken and that it shall be dissolved pursuant 10 Section 3301(c) of the Divorce Code of 1980, as amended. The panies, therefore, agree to the following: - 17 - a. On or before the 1st day of May, 1997, Husband shall have filed a Complaint in Divorce in the Cumberland County Court of Common Pleas. , b. On or before the 15th day of August, 1997, both Husband and Wife shall have executed an Affidavit consenting to the entry of a final Decree in divorce, c. Husband shall cause the Affidavits to be filed of record and the divorce fmalized. d. Unless either party shall have requested counseling prior to the filing of the Affidavits of Consent, the right to so request shall be deemed waived. 22. AGRF.F.MF.NT TO BE INCORPORATED INTO DIVORCE OF-rARF-. The parties agree that the terms of this Agreement, shall be incorporated Into, but not merged with, any Divorce Decree which may be entered with respect to them. The parties further agree that the Court of Common Pleas which may enter such Divorce Decree shall retain continuing jurisdiction over the parties and the subject matter of this Agreement for the purpose of enforcement of any of the provisions thereof, - 18 - 24. ENFORCEMENT OF AGREEMENT. It is expressly understood and I I , i i I i ! ~ ! i , ! i , 23. SWEOUENT RECONCILIATION. The parties agree that the terms of this Agreement shall not be affected by their subsequent cohabitation or resumption of marital relations unless the parties otherwise specifically agree in writing, agreed by and between the parties hereto that this Agreement may be specifically enforced by either Husband or Wife in Equity, and the parties agree that if an action to enforce this Agreement is brought in Equity neither party will make an objection on the alleged ground of lack of jurisdiction of the court because there is an adequate remedy at law, 'The parties do /lOt intend or purport to improperly confer jurisdiction on a court in Equity by this Agreement, but they agree as provided herein for the fonun of equity in mutual recognition of the general jurisdiction of couns in Equity over agreements such as this one. Notwithstanding anything to the contrary herein, Husband and Wife may also proceed with an action at law for redress of his or her righlS under the terms of this Agreement, and in such event, it is specifically understood and agreed that for and in specific consideration of the other provisions and covenants of this Agreement, each shall waive any right to a jury trial so as to expedite the hearing and disposition of such case and so as to avoid delay. - 19 - . . Each pany hereby agrees 10 pay all attorney's fees and COSls of lillallion lhallhe o!her spouse may sustain or incur in any way whatsoever as a consequence of InY default or breach by the other spouse of any of !he terms or provisions of this Agreement; provided lhal the party who seelu 10 recover such attorney's fees, and coSU of liligalion musl firsl be successful in whole or in part, before such liabilily may be Imposed. It is Ihe sped fie agreement and intenl of the parties thaI a breaching or wrongdoing party shall bear the burden snd obllgalion of any and all cosU and expenses and counsel fees Incurred by himself or herselt II well as the other party In endeavoring 10 protecl and enforce Ilia or her righls under Ihls Agreement. For enforcemenl purposes of any terms of this Aareemenl, the panil1s specifically acknowledge "'UII Section 310', as amended, of the Divorce Code ot 1980 spplllla 10 this Agreement. 2'. VOLUNTARY EXECUTION. The provlsiolll of thl. ^Ircomenl and their legal effect have been fully explained 10 the panic. by counsel IInd each party acknowledges that this Agreemenl is fair .nd equitable, thallt i. bcllll entered InlO voluntarily, and thaI il is nol the result of any duress or undue inftuence, 26. ENTIRE AGREEMENt. This A,rccment cOnlailll the enti" understandings of the parties and there arc no representalions, warranllea, COVIIllntl or undertakings other than !hose expressly sel forth herein, - 20 - ~ . -- 21, MODIFICATION AND WAIVER. A modification or waiver of any llf I' -j\ :i the provisions of this Agreement shall be effective only if made in writing and executed with the same fonnalily as this Agreement. The failure of either pany to insist upon strict performance of any of the provisions of this Agreement shall not be constrUed as a waiver of any subsequent default of the same or similar nature, ., 28. SITUS, This Agreement shall be constrUed and governed in accordance with the laws of the Commonwealth of Penn~ylvania, 29. PARTIAL INVALIDITY. If any provisions of this Agreement are held to be invalid or unenforceable, all other provisions shall nevertheless continue in full force and r effect. 30, BINDING EFFECT. Except as otherwise stated herein, all provisions of this Agreement shall be binding upon the respective heirs. next of kin. executors, administrators of the parties. 31. TRIPLICATE COPIES. The parties hereto agree that the within Agreement shall be executed by them in triplicate originals and the fully executed document shall be held by their respective counsel. - 21 - 32. BANKRUPI'CY. The panies hereto agI'CC that the provlllolll of the insllnt Agreement shall not be dischargeable in bankruptcy and exprtSlly aglft to rearnnn any and all obligations conrained herein. IN WITNESS WHEREOF, the panlel hereto, after full dlsclolure made, have signed, sealed and acknowledged this Agreement In lllplltate (3) counterparu, each of which shall constitute an original. SIGNED. SEALED AND DEUVERED IN THE PRESENCE OF: '-:J:!j" ~~1.4 /47 / ,a.-,r ylj;/?7 Date }/)/).~ Witness ~blC\. .1\.. 01.1~O ~ ,~~ 'I '7 Date Illl.. . :1:1 . Todd j, Shill, Esquire Attorney 1.0, No, 6922S M, Catherine Nolan, Esquire Attorney I,D. No, 77332 RHOADS & SINON LLP One South Market Square, 12th Floor P,O, Box 1146 Harrisburg, Pennsylvania 17108-1146 Attorneys for Plaintiff vs, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY. PENNSYLVANIA CIVIL ACTION - DIVORCE NO. 97-2184-Civil GEORGE P. RAMSEY plaintiff, DEBRA K. RAMSEY Defendant .. .. .. .. .. ., .. .. ., .. PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the court for entry of a Decree in Divorce: 1. Ground for divorce: irretrievable breakdown under Section 3301 (c) of the Divorce Code. 2. The Complaint in Divorce was filed with the Cumberland County Prothonotary on April 25, 1997 and was served via ordinary mail. 3. Date of execution of affidavit required by Section 3301 (c) of the Divorce Code: by Plaintiff George P. Ramsey on August 12, 1997; by Defendant Debra K. Ramsey on August 8, 1997. 4, Related claims pending: None. 5. Plaintiff and Defendant have resolved issues of child custody, child support, spousal support, alimony and equitable distribution of all marital property by a "Property Settlement Agreement." a copy of which is attached, executed by Plaintiff George P. Ramsey. on the 23rd day of April, 1997 and executed by Defendant Debra K. Ramsey on the 23rd day of April, 1997. RHOADS & SINON LLP By\ "-yfJ, (jtti'LL~'r--L r~ Todd J. Shill M. Catherine Nolan One South Market Square P.O. Box 1146 Harrisburg, PA 17108-1146 (717) 233-5731 Attorneys for Plaintiff Dated: 9/v.~ jv1 vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE NO. 17- d I S4 ,li.ukL GEORGE P. RAMSEY Plaintiff, DEBRA K. RAMSEY Defendant .. .. .. .. .. NOTICE TO DEFEND AND CLAIM RI~ 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. 'lou 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 YOll, including cURtody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counsel ing. A list of marriage counselors is avai lable at the Office of the Prothonotary, Cumberland County Courthouse, One Courthouse Square, Carlisle, PA 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMON'l, DIVISION OF PROPERTY, LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, '{au MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. '{au SHOULD ~AKE THIS PAPER TO ,{OUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. COURT ADMINISTRATOR CUMBERLAND CO COURTHOUSE 4th FLOOR 1 COURTHOUSE SQUARE CARLISLE PA 17013 3387 e7l7) 240 6200 - 1 - vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNS'lLVANIA CIVIL ACTION - DIVORCE NO. GEORGE p, RAMSEY Plaint if f , DEBRA K. RAMSEY Defendant .. .. .. .. ., .. " .. .. A V ISO USTED HA SIDE DEMANDADO/A EN CORTE. si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas, debe tomar accion dentro de los proximos veinte (20) dias despues de la notificacion de esta Demanda y Aviso radicando personalmente 0 por medio de un abogado una comparecencia escrita y radicando en la Corte por escrito sus defensas de, y objecciones a, las demandas presentadas aqui en contra suya. Se le advierte de que si usted falla de tomar accion como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda 0 cualquier otra reclamacion 0 remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Usted puede perder dinero 0 propiedad u otros derechos import antes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGAnO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGAOO 0 NO PUEDE PAGARLE A UNO, LLAME 0 VAYA A LA SIGUIENTE OFICINA PARA AVERIGUAR DONDE PUEDE ENCONTRAR ASISTENCIA LEGAL. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE Court Administrator Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 'I Todd). Shill, Esquire Attorney I,D, No, 69225 M, Catherine Nolan, Esquire Attorney 1.0, No. 77332 RHOADS & SINON LlP One South Markel Square, 12th Floor P,O, Box 1146 Harrisburg, Pennsylvania 17108-1146 Altorneys for Plaintiff vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY. PENNSYLVANIA CIVIL ACTION - DIVORCE NO. GEORGE P. RAMSE'l Plaintiff, DEBRA K. RAMSEY Defendant .. .. .. .. .. .. .. .. COMPLAINT UNDER SECTION 33011cl OF THE DIVORCE CODe 1. plaintiff is George P. Ramsey, who currently resides at 18 Sherwood Circle, Enola, Cumberland County, Pennsylvania, and has done so since 1989. 2. Defendant is Debra K. Ramsey, who currently resides at 18 Sherwood Circle, Enola, Cumberland County, Pennsylvania, and has done so since 1989. 3. Both Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least six months immediately prior to the filing of this Complaint. 4. plaintiff and Defendant were married on September 3, 1977 in Cumberland, Allegheny County, Maryland. 5. There have been no prior actions of divorce or for .", annulment between the parties. 6 . The marriage is b:retrievably broken. , 7. 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. ~ \ 8. Plaintiff and Defenda:lt have two children, Nathan W. Ramsey, born June 3, 1980, and Lauran D. Ramsey, born April 7, 1983. 9. plaintiff requests the Court to enter a Decree of Divorce. - 2 - WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter a Decree of Divorce. RHOADS & SINON LLP By~.(JQ.,lILLu.;~~ Todd J. Shill M. Catherine Nolan One South Market Square P.O. Box 1146 Harrisburg, PA 17108-1146 (717) 233-5731 Attorneys for Plaintiff 11?611 " " - 3 - I " . VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are Date: rllrl91 ,~ /~ ')/' /oe ge P. Ramse1, Plaintiff made subject to the penalties of 18 Pa.C.S. S 4904, relating to unsworn falsification to authorities. ~ERTIFICATE OF SERVICE I hereby certify that on i.f - .:t t.J , 1997 I a true and correct copy of the foregoing "Complaint under Section 3301(c) Of the Divorce Code" was served by United States Certified mail, upon the following: Debra K. Ramsey 18 Sherwood Circle Enola, PA 17025 Date: 4 - ;) 9- q 7 ~ JJ W~ /I '. ,"1::.: ",--- " ~ !, i"> .;:) , ~(,) \r) ,.- lJ" c' .- j' ('~ ; -~ lll' (~: . - (.). ',-:", ,...... I..-.::" p~. \ :.-: '::: '-... ............. (J; 'L, ,:j , , , (.)' 1:-, t, '" .'-) ., '.~ ~ ll_' &: :: I f,_ ;(Ij -i. ~~ .' t.) I- ) 0' U C\~ --- "() f"'I") ~~ "" r,..., 1'<-, ~ ~~ ;J0:iJ' ~ ~ L 1\ . t, . .1'1( ,J r ., . vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE NO. 97-2184-Civil ! ' I' GEORGE P. RAMSEY Plaintiff, DEBRA K. RAMSEY, Defendant .. .. .. .. ., .. .. .. .. AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on April 25, 1997. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final Decree in Divorce after service of notice of intention to request entry of the Decree. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn falsification to authorities. Date: J t2./CVJ . '~r:: &~ . vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE NO. 97-2184-Civil ! , i GEORGE P. RAMSEY Plaintiff, DEBRA K. RAMSEY Defendant ., .. ., .. .. .. AFFIDAVIT OF CONSENT : ~ 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on April 25, 1997. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days 'have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final Decree in Divorce after service of notice of intention to request entry of the Decree. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn falsification to authorities. Date: R.8.Ql D2b1Q. K. i&an~ Debra K: Ra sey . . ~ vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE NO. 97-2184-Civil GEORGE P. RAMSEY plaintiff , DEBRA K. RAMSEY Defendant .. .. .. .. .. .. .. .. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER 033011c) 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 Decree in Divorce 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. !i4904 relating to unsworn falsification to authorities. Date: R .5 Cti OA.n'^- 1<. Debra K. Ra/'HDCd Ramsey