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4. The parties have divided between them to their mutual satisfaction all intangible
personal property c?nsisting of cash, bank accounts, annuities, securities, insurance policies, pension
and retirement rights, whether vested or contingent, and all other such types of property, The parties
hereby agree that all such intangible property presently in the possession of or titled in the name of
Husband shall be his sole and separate property, and that in the possession or titled in the name of
the Wife shall be her sole and separate property, Each party hereby expressly waives any right to
claim any pension/profit sharing/retirement rights of the other, vested or contingent, each party to
retain full ownership of such rights as his or her sole and separate property, Nevertheless, Husband
shall execute a Promissory Note payable to Wife in the sum of One Thou5and ($1,000,00) Dollars,
which note shall be paid in installments of $20,00 per week in full satisfaction of any claim Wife may
have in Husband's 401K plan and Christmas Club account.
5. Wife agrees to indemnifY and save and hold harmless the Husband for any liability
upon the obligations assumed by the Wife in accordance with the terms and conditions set lbrth in
paragraph 3 of this Agreement.
6. Husband agrees to indemnifY and save and hold harmless Wife for any liability upon
the obligations hereby assumed by Husband in accordance with the terms and conditions set forth in
paragraph 3,
7, Except as herein otherwise provided, each party represents that she and he have not
heretofore incurred or contracted any debt or liability or obligation for which the other may be held
responsible or liable, Each party agrees to indemnifY and save and. hold harmless the other from and
against all such debts, liabilities or obligations of any kind which may have heretofore been incurred
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between them, except the obligations arising out of this Agreement
8, Both parties covenant, warrant, represent and al!Tcc that each will now and at all times
hereafter save and keep each other indemnilied agllinst all debts. charges, or liabilities incurred by the
other after execution of this Agreement. except as may be otherwise specifically provided for by the
terms of this Agreement and neither of them shall hereal\er incur any liability whatsoever for which
the Estate of the other may be liable, Each party further agrees to indemnitY and save and hold
harmless the other from any and all liabilities he or she may incur upon the obligations of or assumed
by the other, which indemnilication as to all provisions of this Agreement shall include the right to
recover out of pocket expenses and reasonable allorney's fees actually incurred.
9, Both parties agree that the hereinabove set forth Agreement cor.stitutes an equitable
distribution of their marital property and equitable resnlution of all other economic claims pursuant
to the provisions of the Divorce Code and each party irrevoeably waives. releases. and remises any
claim to ownership of or interest in any property designated as the property of the other by virtue of
th~ provisions of this Agreement except as otherwise may be provided pursuant to the provisions of
this Agreement.
10, Husband does hereby release, remise. quitclaim and forever discharge Wife and the
estate of the Wife from any and all claims he has now. ever may have or can at any time have against
the Wife or her estate or any part thereof, whether arising out of formal contracts. engagements or
liabilities of the Wife. arising by way of widower's right or under the Intestate Law arising by any
right to take against the Wife's will, arising out of the Divorce Code. Act No. 26 of 1980, as
amended, including, alimony, alimony pendente lite. counsel fees and expenses. arising as a right to
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spousal support or arising by any nuture whatsoever, excepting only those rights accorded to the
Husband under this Agreement.
II. Wile does hereby release, remise, quitclaim and lorever discharge the Husband and
the Estate of the Husband trom any and all claims she hll' now, every may have or can at any time
have against the Husband or his estate or any part thereol; whether arising out of formal contracts,
engagements or liabilities of the lIusband, arising by way of the widower's right or under the Intestate
law, arising by way of any right to take lIgainstthe Husband's Will, arising under the Divorce Code,
Act No, 26 of 1980, as amended, inclucting, alimony, alimony pendente lite, counsel fees and
expenses, arising as a right to spousal support arising by any nature whatsoever, excepting only those
rights accorded to the Wile under this Agreement and the right to obtain child support shall be
determined Irom time to time by a court of competent jurisdiction
12, If either party to this Agreement resorts to a lawsuit or other legal action pursuant to
the provisions of the Divorce Code or otherwi,e shall enforce the provision of this Agreement, the
successful party shall be entitled to recover his or her reasonable attorney fees, actually incurred, from
the other as party of the judgment entered in such legal action, whether in law, in equity, pursuant
to the provisions of the Divorce Code or otherwise as the same shall be determined by the Court,
13, The parties do hereby Wllrranl, represent and declare and do acknowledge and agree
that each is and has been fully and completely inlormed of and is familiar with and is cognizant of the
wealth, real and/or personal property, estate and assets, earnings and income of the other and that
each has made a full and complete disclosure to the other of his or her entire assets and liabilities and
any further enumeration or statemenlthereof in this Agreement is specifically waived,
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II
II
I
SCHEDULE "A"
B,RENT A, GIBSON
1. All pro materials which remain at 336 North Bedford Street
by Wife prior to execution of this Agreement.
2.
3. Zenith VCR ~\Y
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PATRICIA MYERS,
Plaintiff.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 97-
CIVIL TERM
Defendant
CIVIL ACTION - LAW
IN DIVORCE
PAUL L. MYERS,
~ECIPE TO TRANSMIT REQQRQ
To the Prothonotary:
Transmit the record, together with the following information,
to the Court for entry of a divorce decree: '
1. Ground for divorce:
3301 (c) -- Section 3301 (d)
out inapplicable ser.tion.)
2. Date and manner of service of the Complaint: Certified
mail, return receipt requested attached hereto as Exhibit "A",
postage prepaid.
I rretrievable breakdown under Section
of the Divorce Code. (Strike
3. (Complete either paragraph (a) or (b):
(a) Date of execut ion of the Af f idavi t of Consent required by
Section 330l(c) of the Divorce Code:
3-7-99
By the Plaintiff:
By Defendant:
(b) (1) Date of Execution of the Plaintiff's Affidavit required
by Section 330l(d) of the Divorce Code:
3-2-99
(2) Date of service of the Plaintiff's Affidavit upon the
Defendant:
4, Related claims pending:
None.
5. Complete either (a) or (b):
(a) Date and manner of service of the notice of intention to
file Praecipe to Transmit the Record, a copy of which is attached:
(b) Date Plaintiff's Waiver of Notice in ~ 3301 (c) divorce
was filed with the Prothonotary: 31~llq~
Date Defendant's Waiver of Notice in ~ 3301 (c) di von:e
was filed with the Prothonotary: 3131Iq~
Date: 3131\~
Mar
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PATRICIA MYERS,
Plaintiff
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 97- '/'/11 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
v.
PAUl. L. MYERS,
COMPLAINT UNDER SECTION 3301L~
OR 3301(dl OF THE DIVORCE ~QQE
AND NOW COMES, Plaintiff Patricia Myers, by and through her
attorneys, Saidis, Guido, Shuff & Mas land and files this
Complaint and represents as follows:
1. plaintiff is Patricia Myers, who currently resides at
2738 Falling Spring Road, Chambersburg, Franklin County,
Pennsylvania.
2. Defendant is Paul L. Myers, who currently resides at 25
Hilltop Lane, Newville, 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. The Plaintiff and Defendant were married 011 August 25,
1973 in Carlisle, Cumberland County, Pennsylvania.
5. There have been no prior actions of divorce or for
SAlOIS, GUlOO, annulment between the parties.
SHUFF '"
MASLANO 6. The Plaintiff has been advised of the availability of
].6 W Hilb Slre.:1
C.,Ii,le,PI\ marriage counseling and the Plaintiff may have the right to
request that the Court require the parties to participate in
1
SAlOIS, GUIDO,
SHUFF "
MASLAND
26 W, HiSh S,....
CiUlillle. PA
COUNT IV
ALIMONY~D ALIMONY PENDENTE LITE
14. The allegations in paragraphs one through thirteen,
inclusive, are made a part hereof and incorpqrated herein by
reference.
15. Plaintiff lacks sufficient property to provide for her
reasonable needs and is unable to support herself through
appropriate employment.
\6. Plaintiff requires reasonable support to adequately
maintain herself in accordance with the standard of living
established during the marriage.
17. Defendant is financially able to provide for the
reasonable needs of the Plaintiff.
WHEREFORE, Plaintiff requests Your Honorable Court to enter
an award of alimony pendente lite until final hearing and
permanent alimony thereafter.
COUNT VI
COUNSEL FEES. COSTS AND EXPENSES
18. The allegations in paragraphs one through seventeen,
inclusive, are made a part hereof and incorporated herein by
reference.
19. Plaintiff has retained the services of Saidis, Guido,
Shuff & Masland and the counsel fees, costs and expenses for
representation in this action will be substantial and continuing.
20. plaintiff is without sufficient funds, income or assets
to pay such counsel fees, costs and expenses.
4
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SAlOIS, GUIDO,
SHUFF &
MASLAND
26 W. HiahStretl
CiU'lisJe, PA
PATRICIA MYERS,
Plaintiff
IN 'l'HE COURT 01-' COMMON PLEAS
CUMBERLAND COUNTY / I"I'.NNSY.LVAN IA
v.
NO. 97"!'i3) CIVIL TERM
PAUL L. MYERS /
CIVIL AC1'ION . LAW
IN DIVORC~;
Defendant
NOTICr.
You have b~en sued in cou~t. If you wish to defend against
the claims set fo~th in the following pages, you must take p~ompt
action. You a~e wa~ned that if you fail to do so, the case may
p~oceed without you and a dec~ee of divor.ce o~ annulment may be
entered against you by the Cou~t. A judgment may also be entered
against you for any othe~ claim or ~elief ~equested in these
pape~s by the Plaintiff. You may lose money o~ p~ope~ty o~ othe~
rights impo~tant to you, including custody o~ visitation of you~
children,
When the ground for the divorce is indignities or
irretrievable b~eakdown of the marriage, you may ~equest marriage
counselling. A list of marriage counselors is available in the
Office of the P~othonotary at the Cumberland County Court House,
High and Hanove~ Street, 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 THI S 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 Cou~t Administ~ator
One Courthouse Square
Carlisle, PA 17013
(717) 240-6200
TRUE COpy FROM RECORD
In Testimony wheraol, I here unto set my hand
IOd '''' ae&l of said ~,~),a~.~~f1s1e, PI.
rhll I( day 0 ,", 19 ~")
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SAlOIS, GUI~HUFF & MASLAND
By: ~ DC .,......
~cott D. Moore, Esquire
Supreme Ct. 1.0. * 55694
26 West High Street
Carlisle, pA 17013
(717) 243-6222
Atto~ney for Plaintiff
Exhibit "A"
PATRICIA MYERS,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v,
NO. 97-
CIVIL TERM
PAUL L. MYERS,
CIVIL ACTION - LAW
IN DIVORCE
Defendant
COMPLAINT UNDER SECTION 3301Cc)
QR 3301Cdl OF THE DIVORCE CODE
AND NOW COMES, Plaintiff Patricia Myers, by and through her
attorneys, Saidis, Guido, Shuff & Masland and files this
Complaint and represents as follows:
1. Plaintiff is Patricia Myers, who currently resides at
2738 Falling Spring Road, Chambersburg, Franklin County,
Pennsylvania.
2. Defendant is Paul L. Myers, who currently resides at 25
Hilltop Lane, Newville, 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. The Plaintiff and Defendant were married on August 25,
1973 in Carlisle, Cumberland County, pennsylvania.
5, There have been no prior actions of divorce or for
.IDIS, GUIOO, annulment between the parties,
SHUFF &
MASLAND 6. The Plaintiff has been advised of the availability of
6 w. Hilh Stre~t
Carli,I',PA marriage counseling and the Plaintiff may have the right to
request that the Cou~t require the parties to participate in
1
~.9Utrt_1Y
[lJJl NQ!'!X...AN.!LbJJ1:I.9liLJ'ENO!,; NT~;__!Jj'i;
14. The allegationu in Pat'l1grapha one through thirteen,
inclusive, are made a part hereof and incorporatl.ld herein by
reference.
15. Plaintiff lacks sufficient property to provide for her
reasonable needs and is unable to support herself through
appropriate employment.
16. Plaintiff requires reasonable support to adequately
maintain herself in accordance with the standard of living
established during the marriage,
17. Defendant is financially able to provide for the
reasonable needs of the Plaintiff.
WHEREFORE, Plaintiff requests Your Honorable Court to enter
an award of alimony pendente lite until final hearing and
permanent alimony thereafter.
COUN'r VI
COUNSEL FEES. COSTS AND EXPENSES
18. The allegations in paragraphs one through seventeen,
inclusive, are made a part hereof and incorporated herein by
reference,
19. Plaintiff has retained the services of Saidis, Guido,
SAlOIS, GUIDO,
SHUFF & Shuff & Masland and the counsel fees, costs and expenses for
MASLAND
26W I\iSh S"w representation in this action will be substantial and continuing.
Carlisle, fA
20. Plaintiff is without sufficient funds, income or assets
to pay such counsel fees, coets and expenses,
4
f,FFIDAVIT
I, patricia Myers, being duly sworn according to law, depose
and say:
(1) I have been advised of the availability of marriage
counselling ond understand that I may request that the court
require that my spouse and I participate 'in counselling.
(2) I understand that the court maintains a list of
marriage counselors in the Prothonotary's Office, which list is
available to me upon request.
(3) Being so advised, I do not request that the court
require that my spouse and I participate in counselling prior to
a divorce decree being handed down by the court.
I understand that false statements herein are made subject
to the penalties of 18 Pa, C,S. Section 4904 relating to unsworn
falsification to authorities.
Dated:
'1-(1-1..,
~o;I: """" --..J ,.. H J
Patrie a MY~
UDlS. GUIDO,
SHUFF &
MAS LAND
!6 w. tliih Street
Carlimle, fA
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In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
PATRICIA MYERS ) Ou.:kel Number 97-4937
Plaillllff )
'IS. ) PACSES Ca.~e Numht:r 09310000~
PAUL L. MYERS )
Defendam ) Olher Slale ID Numht:r M :2701 'I
DEMAND FOR HEARING
Date of Order: Novcrrl:lor 20. 1997
Amount:
$ 780.00
per month
For the support of: Alimony Pendent.. Lite
Reason(s): ,
, /Jr;:::,.., "J.?t'\{..., . .s<.(..;./~ori ,.-I 1/6Y1,.( oy..J Slloulc~ ~~ 8AS'C"d'o-"
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1- ~ -<~ Ot'I-"--'^-<.i Pi, ''6 O~ ~ ;Ct... ")''-''v'~_ I..A."'<:~
Party Filing Demand for Hearing: PAUL L. MYElR~ 0"",L C, OOU (,() /)o{( ,~- ~I. ~'1,\
/).;.~ A.J.4~ 't/7 ..,/L" '1'7,
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PATRICIA MYERS,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO 97-4937 CIVIL TERM
v.
PAUL L. MYERS,
Defendant
CIVIL ACTION-LAW
IN DIVORCE
PRAECIPE FOR WITHDRAWAL OF COUNSEL
AND APPEARANCE OF COUNSEL
TO THE PROTHONOTARY:
Please note my withdrawal a$ counsel for Paul L. Myers, Defendant In the above
matter.
Dated: I I & t1 g
BY:
~fl ,,) lU ~-.b-
sall:6. Winder, Esquire
701 East King Street
Shippensburg, Pennsylvania 17257
(717) 532-9476
Kindly enter our appearance on behalf of Paul L. Myers, Defendant in the above ,
matter.
Dated: ,/.: I ) 1 Y
O'BRIEN, BARIC A~CHERER
By~V~~1
David A Baric, Esquire
Pa I.D. 44853
17 West South Street
Carlisle, PA 17013
(717) 249-6873
PATRICIA MYERS.
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO 97-4CJ37 CIVIL TERM
PAUL L. MYERS.
Defendant
PACSES CASE NUMBER 093100006
DR N 27, 019
hORO~
AND NOW, this J,h,_ day of_
Stipulation and Agreement is hereby made an Order of Court.
, 1998, the attached
BY THE COURT,
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PATRICIA MYERS,
PlaintltT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO, 97-4937 CIVIL. TERM
PAUL L MYERS,
Defendant
I' ACSES (' ASE NUMBER 093100006
DR # 27,019
STIPULATION ANI> AGREEME~
AND NOW, the parties in the above-captioned matter by and through their legal counsel
hereby stipulate and agree as follows:
I, The Plaintiff, Patricia Myers, is represented in this matter by Scoll D, Moore,
Esquire,
2. The Defendant, Paul L. Myers, is represented in this mailer by David A. Baric,
Esquire,
3. On or about December 8, 1997 the Honorable George E. HotTer signed an Order
of Court as recommended by the Domestic Relations Office selling the Defendants monthly
alimony pendente lite obligation at $667,00 per month plus $26 00 per week in arrearages,
4, On or about December 24, 1997. Defendant filed an appeal from the
Recommended Order entered in this matter on December 8, 1997, requesting a hearing de novo.
5, The parties by and through their respective counsel agree as follows:
a, The Defendant will pay to the Plaintiff alimony pendente lite in the amount
of$80,OO per week;
b, The Defendant would be responsible to maintain health insurance coverap
on the PlaintitTthrough his employer at the cost of$22,OO per week; and,
In the Court or Common Pleas or CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
~ATRICIA MYBRS ) Docket Number 97-1937
Plllinliff )
vs. ) PACSES Case Number 093100006 ID27,019
PAUL L. MYBRS )
, )
Defendant Other Slale 10 Number
Order
AND NOW to wit, this
APRIL 12, 1999
it is hereby Ordered
that:
THB ABOVl CAPTIONED ORDBR POR ALIMONY PBNDBNTB LITB IS TBRMINATBO PURSUANT TO
THB PARTIBS SB'M'LBMBNT AGRBBMBNT OP MARCH 2, 1999 AND 'l'HB PINAL OICRBB OP
DIVORCB.
BY THE COURT:
DRO: RJ Shadday "
xc: plalntlff___....
defendant ~~'~
SCvn 'Iv.lre. Esq;J L r ',jet,.....
I ~T\
DavId BarLc, EsqJLre .\'''
Service Type M _.'"
...
IDENT JUDGE
Form OE-OOl
Worker ID 21005