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Home My WebLink About97-03035 ~ ~ ~ - '.. .~ .. '" C'C) ~ t..:. ~ '-, ',,- '........... \ *~~*~~**~*~*****~~**):~:'~:~'*.;*--~~~~. ~ - -~--~-- - 8 ,;, ~ w ~. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY ~ STATE OF ~~ PENNA. .~ ~ ~ s ;;, ~ ~ ~.' .~ :, $ 'I N (). ..........3035... ........,........ 19 97 ~ '.' ~ WILLIAM R.. TEE.'I'S. ~ ',' \'t'I.~HS ~ '.' ~ MELISSA TEETS ~ ',' " ~ ~ DECREE IN DIVORCE AND NOW, ""'~,~,.~'i.,',. 19.98.~~.;~~~.::~ and decreed that", ,~~~~~~ ,~: ,~~~~'" "., """,.', ",., ,....", plaintiff. and. ., , , " ., ,_. ,~f~~r., :rF!>:I'~, ., , , , , .,. , , , , . , . .. . , . _ " , , , , , " defendant, are divorced from the bonds of matrimony. ~ ~l .. ~ ..~ * w ~.' ~ ~ '.' s 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; 8 ~ ~ ~. ~ ., :r!1!l, !'l~F.i~~,l, ~!l,t,t,l,~,n,t, ,lI.9.r,~~1'\'<', ,c!a,'<~ ,t-!'1'!~~r: ,Ii, ,~<:1<:1~! ,;11,.."""." , . ~!l~FP.'F~,t!l?, ):l~,re,ip", ,b,u,t, ,n,qt, ,~t:g~" ,i,1'\'<'1 .,<l)~ ,~cr n ,1?;Y9r;~!, ~1:1;91:1, , ,;.. :, s w ro' agreement is attached hereto. .'. ~ .', i!- Alle.t: i'J.....d:, ,0. ~,t1: ~-~ ti~~ K >>~. J:# ~ ' Prothonotary ~ ~ ~ ? ~...;-:l.; -::.:' ~ .', * ~ ~ ... ~ s .', ~ .'~ ~ ,'. ~ ~ '.' ~ '.' w ~, s ~ '.' ~ ',' I, ~ '.' i ',' s w ~. ", ~ ~ '.. ~ ',' ~ $ $ s l~ ~~ i~ '" I, '~ ~ J. ~ I'" !~ ('0' I, I~ t"- J~ I",' i ,:(;. ;v 1'41 - - ._*-*----~******-~. J~ '.. '.' ... '.- . " " " '..., .. .. .. ..;.,... , ."1 r.. NOW 'rHEREt'ORE, in consideration 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. PERSONAL PROPERTY: Except as otherwise stated hereto, Husband and Wife have agreed that their personal property, including any and all bank accounts, has been divided to the parties' mutual satisfaction and neither party will make any claims to said property possessed by the other. 2. MOTOR VEHICLES: Husband and Wife agree that the 1996 Dodge Neon shall become the sole and separate property of wife, upon the removal of Husband's name from the loan for said vehicle, as Wife hereby agrees to refinance or otherwise remove Husband's name from said vehicle loan, within six (6) months from the date of execution of this Agreement. J. MARITAL DEBTS: Except as otherwise stated hereto, Husband and Wife agree that Husband shall be fully responsible to pay the current line of credit debt, and Wife shall be tully responsible to pay any and all other marital debts, including but not limited to, the VISA credit card account, Structure account and the loan on the furniture, purchased by the parties during the marriage. Each 2 .'"'\ ,-.., party shall indemnify and hold the other harmless as to the aforesaid payment obligations upon any default. 4. AFTER ACOUIRED PROPERTY: Except as otherwise stated hereto, as of April 28, 1997, the date of final separation, each of the parties shall own and enjoy, independentlY of any claims or right of the other, all items of personal property, tangible or intangible, and/or real property, acquired by him or her, with full power in him or her to dispose of the same as fully and effectively, in all respect and for all purposes, as though he or she were unmarried. 5. WIFE'S DEBTS: Except as otherwise stated hereto, Wife represents and warrants to Husband that since the date of final separation, April 28, 1997, she has not contracted or incurred any debt or liability for which Husband or his estate might be responsible; and Wife further represents and warrants to Husband that she will not contract or incur any debt or liability after the execution of this Agreement for which Husband or his estate might be responsible. Wife shall indemnify and hold Husband harmless from any and all claims or demands made against Husband by reson of debts or obligations incurred by Wife. 6. HUSBAND'S DEBTS: Except as otherwise stated hereto, Husband represents and warrants to Wife that since the date of final separation, April 28, 1997, he has not incurred any debt or liability for which Wife or her estate might be responsible and Husband further J .'" o , represents and warrants to Wife tha he will not contract or incur any debt or liability after the execution of this Agreement for which Wife or her estate might be responsible. Husband shall indennify and hold Wife harmless from any and all claims or demands against Wife by reason of debts or obligations incurred by Husband. 7 . WAIVER: The parties hereto fully understand their rights under and pursuant to the Divorce Code, Act of 1980, No. 1980-26, as Amended February 12, 1988, particularly the provisions for alimony, alimony pendente lite, spousal support, equitable distribution of marital property, attorney fees and expenses. Both parties agree that this Agreement shall conclusively provide for the distribution of property under the said law and the parties hereby waive, release and forever relinquish any further rights they may respectively have against the other for alimony, alimony pendente lite, spousal support, equitable distribution of marital property, attorney fees and expenses. 8. MUTUAL RELEASE: Husband and Wife each do hereby mutually remise, release, quitclaim and forever discharge the other, and the estate of each other, for all time to come, and for all purposes whatsoever, of and from any and all legal or equitable rights, title and interests, or claims in or against, the real or personal property, tangible or intangible property (inclUding income and gain from property hereafter accruing) of the other, or against 4 ~ - (:: , .' ,. l~ .. ")..=: u If ~ ~O . . '. ~-_. I. " , " fU' '.', I- .~:.: " , , ' . (J' , .:7.; ; , (':1 ., co! " ll". t~ J -'I' -. u:: ;- . ~U_ , .~ .. ll. (fi ..' U O' 'U .' ~ WILLIAM R. TEETS Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 97 - 3035 MELISSA TEETS Defendant CIVIL ACTION - LAW 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: 1. Grounds for divorce: irretrievable breakdown under Section Ixl 33011cl I I 33011dl of the Divorce Code. 2. Date and manner of service of the Complaint: on June 16, 1997: see attached Acceptance of Service. 3. Complete Paragraph (a) or (b): (a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff on 11/6/98. filed 11/20/98: and by Defendant on 9/29/98. filed 10/29/98. (b) (1) Date of execution of the Plaintiff's Affidavit required by Section 3301(d) of the Divorce Code: N/A (2) date of service of the plaintiff's Affidavit upon the Defendant: N/A 4. Related claims pending: None pursuant to Marital Settlement Agreement. 5. Date and manner of service of the Notice of Intention to File Praecipe to Transmit Record, a copy of which is attached if the decree is to be entered under section 3301(d)(i) of the Divorce Code: N/A . 6. Date and manner of service of Notice of Intention to file Praecipe To Transmit Record, a copy of which is attached, if the decree is to be entered under section 3301(c) of the Divorce Code N/A : OR, date of execution of Waiver of Notice of Intention 9/29/98 : date of filing Waiver 10/29/98. ~~~ James W. Abraham, Esq. Attorney for Plaintiff ~ .' ,:; " ;';1:; -", " ,',: r.~ \ ' I :':" ,., '. ~ -, . " !' }'.if-'. d,: III." i~"\ j .> . t." . (' .- .. 'i.;,' '.! -;. I.; " '" : ~ I. i ::'Y ; -~. ';,' .(; .,' l ;,t.,:,: .' " '!.' ....;-.. ,,' " .-~ ~ ~- " ! .' . , ",',I' .... , . ~ .i "; '-.-,' ,! " i "'. ~ If) >- , -- ;;;: i i!J ::!-<. , " u " ": :?'. ( ',~ j'..... <--,j~. ,J:"_" 1 .-... !:... ".; ::J (~j ; . .;-:-, " , '.'; .' L...; C.1 ~.',. ., -. ~:It ::-~ " ',AtLl , . " " L.'. C' , a. , (.1 :::). t.... ';0' r;) ! ",' .,;~H' '..j..(f,t,H{I\ot:"".n.'c4;~},: ~.\t.yr " "~i. '. .".' " '..-. ii " ~t'.' f,q n(l.r(':,',~,,, i~~:.' 't't;. .- ( )', " "., '. ;. ~ l ' '{ . " I' " 1,:' .. -':,f ,u:, ~ " f ii' \' ,{ ~.- t. \. .1.. ". '.':' ~ J ' " , ~ . t -'~,-;;, (01',---:; " ~' I:'!' , .' ',,' ~ ..),,\ :'.T~: I' ;i(.< 1 f~>,; j. ~. r ! ';,1;:: t" " "::'r',,_ ','r ,,' " J. .'; '.~ r i ~j .', t. ". ,-;1: ',: ,.;' WILLIAM R. TEETS Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. NO. 4 7 - .1 01 ,t)' ctr.:.t -r b-, : CIVIL ACTION - LAW IN DIVORCE MELISSA TEETS Defendant COMPLAINT AND NOW, comes Plaintiff, William R. Teets, by and through his attorney, James W. Abraham, Esquire, Abraham Law Offices, Harrisburg, Pennsylvania, and files the following: COUNT I DIVORCE PURSUANT TO SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff, William R. Teets, is an adult individual whose residence is located at 606 Allenview Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. Defendant, Melissa Teets, is an adult invididual whose residence is located at 665 A, State Street, Lemoyne, Cumberland County, Pennsylvania, 17043. 3. Plaintiff and/or Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on October 5, 1996, in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties hereto. 6. The marriage is irretrievably broken. ~ ...:I' >- 1-. ,,,: .- I-' .. 5~ I~Q. - C.J::Z'~ ( ..-. :e ,,)~:. -f~ p..., <C .....I~.:'j ~t~ .->. .::- ;'-C') I ~: N ;:e~-.: ~,." t!; U.hlJ u:11: U:o... .' ~ I,' -, ~-,;. U_ r- ~5 0 c' 0 r [;: - f.; - i.:-~ - .' ,.... 8; !.'-),,-( 11-" I _{:.( n' re:' . .., 0.. . ,', " -:'-..: '1>:; C.J -~, . c..~, ~. " '-.~ <" \) , ltij -, l:~. , (, ~ . :a. , ... . > \:- ~~ -, ~> <.i' t:) -, ..;. ~ C") ?:; :;z C'l ." '6 .. -)5 - u.lz - Ot,;, ~6 :r.: ':J~ ~~' oa ''"')~ 0' Z~ c. _7~~ ,.. l;'J ._.1...- ~u: t; e;re ti:i!: fn 1- 0 ~. ~: \5 CO a 0' "'.- '- ot; $~ ~~L ,~... 'ff.' (") ~ 4 (') 0 .' -- - :..)".. 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