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IN THE COURT OF COMMON
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OF CUMBERLAND COUNTY
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STATE OF ~~ PENNA.
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TODD A. LYONS
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C;Iyg'..J)lRM
Plaintiff
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TERESA D . LYONS.
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Defendant
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DECREE IN
DIVORCE
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AND NOW. ' . . . . . . . .1~ . . . ..z. 9". . . . .. 19. r~ . ., it Is ordered and
decreed that ..."... .To.d.d. .~'. .~y.o,n.s. . . , . . . . . , . . , , . . . , . . . , . , . . . " plaintiff.
and.. .. . .. .. .. . . .. ... T,:,:,:,~....~: ,L:(,:,,:,~, . . . . . .. . . , .. . .. .. . .. .. ., defendant,
are divorced from the bonds of matrimony.
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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Provisions of Property Settlement Agreement. dsted May 6, 1998
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, T.I.phona (117) 761.4540
., T.ll<opl.. (711) 761.)01'
THIS AGREEMENT made this Jt!: day of rn~ ' 1998, by and batween
TERESA D. LYONS, residing at 220 Evergreen Road, New Cum erland, York County, Pennsylvania 17070,
hereinafter referred to as "WIFE; and TODD A. LYONS, residing at 211 9'" Street, Apartment B, New
Cumberland, Cumberland County, Pennsylvania 17070, hereinafter referred to as "HUSBAND."
WI TNE SS E TH:
WHEREAS, the parties were married on the 11th day of September, 1993 In New Cumberland,
Cumberland County, Pennsylvania; and
WHEREAS, In consequence of disputes and unhappy difficulties, the parties have agreed to live
separate and apart durlng their natural lives; and
WHEREAS, the parties are desirous of settling their existing property rights Including an amicable
equitable distribution, assignment and division of their property, which property Is considered to be "marital
property" as defined In the Divorce Code known as Act 26 of 1980, and amendments thereto enacted Into
law on February 12, 1988; and
WHEREAS, the parties are desirous of settling the Issues of alimony and/or spousal support; and
NOW THEREFORE, in consideration of the promises and the mutual undertaking herein contained
and for other good and valuable consideration, the parties agree as follows:
1.
Interfer~nce,
unmarried.
Ssosratlon. The parties shall hereinafter live separate and apart. Each shall be free from
authority, and control, direct and Indirect, by the other as If he or she were single and
2. Control of Agreement. The provisions of this Property Settlement Agreement shall govern
all claims for alimony, support, counsel fees and costs, alimony pendente lIle, equitable distribution, or other
property rights, and all other claims which the WIFE or HUSBAND has or might have against the other and
for the complete and absolute satisfaction of any claim or right the WIFE against the HUSBAND or the
HUSBAND against WIFE for support, alimony, counsel fees and costs, alimony pendente lIle, equitable
distribution, or other property rights, except as set forth hereinafter.
3. Divorce. A Complaint In Divorce was filed by HUSBAND on October 27, 1997, alleging the
irretrievable breakdown of the marriage and seeking a divorce under Section 3301(c) of the Pennsylvania
Divorce Code. The Complaint is docketed to No. 97-5928 Civil Term. On February 25, 1998, HUSBAND
flied an Amended Complaint alleging indignities pursuant to Section 3301(a) of the Pennsylvania Divorce
Code, and seeking equitable distribution of the marital estate.
Simultaneously with the execution of this property Settlement Agreement, the parties will 51gn any
and all documents necessary to obtain a Divorce Decree under Section 3301(c) of the Divorce Code,
Including but not limited to, Affidavits of Consent, Affidavits Waiving Marriage Counseling, and Waivers of
Notice of Intent to seek divorce under Section 3301 (c) of the Divorce Code.
4. Real PrODerty. The parties acknowledge that they are not the owners of any Jointly tltied or
individually tltied real property.
5. Personal PrQperty. The parties have acquired certain personal property during the course of
their marriage and hereby acknowledge and represent that such personal property has been divided to their
mutual satisfaction with the exception of the following items that shall be turned over to WIFE within seven
(7) days of the date of this Agreement: microwave; Ironing board ana Iron; two (2) Iron skillets; computer
with all programs in existence during the marriage Intact; computer desk; all personal belongings of Amber
Dietz and Russel Dietz, Including but not limited to clothing, toys, games, furniture, athletic equipment and
academic materials; and all personal belongings of WIFE Including but not limited to clothing, tolleb1es.
Jewelry and housewares.
It Is agreed that each party shall retain all items of tangible personal property currenUy In their
possession as if It were their sole and separate property. With the exception of the above described Items.
neither party shall make any claim to any such Items of marital property, or of the separate personal property
of either party which are now In the possession or under the control of the other. Furthermore, eadl party
agrees to waive allY right, title andlor Interest they may have to the property In the possession of the other.
Should It become necessary, the parties each agree to sign upon request, any titles or documents
necessary to give effect to this paragraph.
6. A 11m OilY. HUSBAND agrees to pay to WIFE the sum of $500.00 per month In alimony for a
period of two years/24 months from the date of this Agreement. For the first eighteen (18) months,
HUSBAND shall pay directly to WIFE, the sum of $240.00 on the first day of every month, commencing on
the first day of the month following the date of this Agreement. The remaining $260.00 shall be paid by
HUSBAND directly to the lender of the lJartles' Jointly titled Plymouth Voyager van more fully described in
paragraph 7. HUSBAND represents and acknowledges that the van will be paid In full and will be free and
clear of any liens and encumbrances no later than eighteen (18) months from the date of this Agreement.
Commencing on the first day of the 19th month following the date of this Agreement (or when the van
Is paid In full) whichever event occurs first, HUSBAND shall pay the entire $500.00 per month amount
directly to WIFE until the expiration of the two year allmon~' award. If for whatever reason, the van Is paid In
full prior to the expiration of the eighteen (18) month period, HUSBAND shall pay the entire $500.00 per
month amount dlrectiy to WIFE until the expiration of the two (2) year alimony award.
It Is agreed that as alimony, all payments shall be tax deductible to HUSBAND and shall be
considered taxable Income to WIFE. This alimony provision shall not be affected by WIFE's cohabitation
with a member of the opposite sex and Is non-modifiable.
7. Automobiles. There Is a 1991 Plymouth Voyager Van which Is titled In Joint name, arid
which shall become the sole and separate property of WIFE, free from any right, tltie, or interest that
HUSBAND may have In such property once the van Is paid In full. The parties agree that the van shall
remain jolntiy tltied until It Is paid In full, at which time WIFE shall become the soie and exclusive owner.
During the period of time when the van remains jointly titled, the parties agree that It shall remain In the sole
and exclusive possession of WIFE and HUSBAND shall not make any possessory or other claim to the
vehicle.
In accordance with paragraph 6 of this Agreement, HUSBAND agrees to make all monthly payments
on the van untIl It Is paid In full and free from any liens and encumbrances. HUSBAND shall be solely
responsible for making such payments and represents that the van will be paid In full no later than eighteen
(18) months from the date of this Agreement.
Furthermore, HUSBAND agrees to execute whatever documents necessary to effectuate transfer of
the title Into WIFE's name alone Immediately following the dale of the final payment. HUSBAND also agrees
to Immediately tum over to WIFE any and all documentation regarding the van (except as necessary to
make tha monthly payments), If he has not done so already,
WIFE has already taken steps to transfer the car Insurance payments with respect to the van In to
her own name, and she shall conllnue to be solely responsible for any and all such automobile Insurance
payments.
Upon WIFE's request, HUSBAND shall provide WIFE with written documentation that the monthly
van payments are being made.
There Is a 1988 S-10 Chevrolet truck which Is 1I1Ied In HUSBAND's and Randl Lyon's name, which
shall remain the sole and separate property of HUSBAND, subject to any liens and encumbrances. WIFE
agrees to waive any right, IIlIe or Interest she may have In the truck.
8. Bank Accounts. Any and all bank accounts In the parties' names which existed 'a1
separallon have been previously divided to both parties' mutual sallsfactlon. The parties acknowledge that
there are no Joint accounts remaining In existence. Furthermore, each party agrees to waive any right, tlUe
or Interest he or she may have In the bank account of the other.
9. Pension and Retirement Benefits. The parties acknowledge that there are no defined
bene nt, 401 (k), pension or prof1t sharing, stock, savings or other plan through his or her place of
employment, or otherwise, whether lIested or non-vested.
10. Health Insurance. The parties acknowledge that COBRA heallhlmedlcaUdentallnsurence
coverage Is available to WIFE through HUSBAND's former employer, Sheladla Associates, for a maximum
period of eighteen (18) months. Sheladla Associates carries Fortis Insurance. Should WIFE elect to receive
this COBRA coverage, she shall be solely responsible for making the monthly premium payments, and
HUSBAND agrees to cooperate and take whatever steps necessary to assist WIFE In securing this
Insurance coverage.
11. Life Insurance Policies. HUSBAND and WIFE each hereby specifically releases and
waives any and all rights, title, claim or Interest that he or she may have In and to any and all policies of life
Insurance owned by or Insuring the life of the other, Including the cash surrender value, If any, and also
specifically to Include a waiver of any beneficiary designation thereunder.
12. Credit Card Debt. The parties acknowledge and represent that there are no joint credit
cards or joint credit card debt In existence. Any such debt that may have existed at separation has been
divided to the parties' mutual satisfaction. Any credit card debt Incurred subsequent to separation on
October 15, 1997 shall be the sole and separate responsibility of the party who Incurred that debt.
13. Miscellaneous Debt. There Is a Dauphin Deposit Loan, Account #1326260-8001-001 In
HUSBAND's name, which approximated $1,349.00 at separation. HUSBAND shall be solely responsible for
this debt and agrees to Indemnify and hold harmless WIFE with respect to this obligation.
There Is a New Cumberland Federal Credit Union Loan, Account #71606 In HUSBAND's name,
which approximated $7,764.00 at separation. HUSBAND shall be solely responsible for this debt and agrees
to Indemnify and hold harmless WIFE with respsct to this obligation.
Any debts not specifically listed In this Agreement shall be the sole and separate responsibility of the
party who Incurred them.
14. Cemetery Plots. The parties are joint owners of two (2) Tri-County Memorla: Gard~ns
cemetery plots. HUSBAND represents and acknowledges that there Is a remaining balance of $1,250.00
due, and monthly payments are $46.73. It Is agreed that the plots shall become the sole and separate
property of WIFE, free and clear of any right, title or Interest of HUSBAND. HUSBAND agrees to cooperate
and sign any necessary docl'mentatlon to effectuate transfer of this asset to WIFE. WIFE shall then become
solely responsible for any outstanding debt, and agrees to Indemnify and hold harmless HUSBAND In
connection with the payments and obligations on the plots.
15. Agreement Executed Voluntarllv and Clearly Understood. Each party to this Agreement
acknowledges and declares that he or she respectively:
A. If fully and completely Informed as to the facts relating to the subject matter of this
Agreement, and as to the rlghts and liabilities of both parties;
B. Enters Into this Agreement voluntarily, free from fraud, undue Influence, coercion or
duress of any kind;
C. Has given careful and mature thought to the making of this Agreement;
D. Has carefully read each provision of this Agreement;
E. Acknowledges that thgre has been a full and fair financial disclosure by both parties,
and fully and completely understands each provision of this Agreement.
16. Release of All Claims. Each party releases the other from all claims, liabilities, debts,
obligations, actions and causes of action of every kind that have been or will be Incurred. Moreover, neither
party Is relieved or discharged from any obligation under this Agreement or any Instrument or document
executed pursuant to this Agreement.
17. Holding Other Party Free and Hannless. HUSBAND hereby warrants to WIFE that he has
not Incurred and he hereby agrees that he will not hereafter Incur any liability or obligation on which she Is of
may be liable. If any claim or action Is brought attempting to hold WIFE liable for any such liability or
obligation, HUSBAND shall, at his sole expense, defend WIFE against any such claim or action whether or
not founded, and he shall hold her free and hannless therefrom. WIFE hereby warrants to HUSBAND that
she has not Incurred and she hereby agrees that she will not hereafter Incur any liability or obligation Qn
which he Is or may be liable. If any claim or action Is brought attempting to hold HUSBAND liable for any
such liability or obligation, WIFE shall, at her sole expense, defend HUSBAND against any such claim or
action whether or not founded, and she shall hold him free and harmless therefrom.
16. Additional Instruments. The parties shall, on demand, execute and deliver to the other, any
document, and do or cause to be done, any other act or thing that may be necessary or desirable to
effectuate the provisions and purposes of this Agreement. If either party falls, on demand, to comply with
this provision, that party shall pay to the other, all attomey's fees, costs and other expenses reasonably
Incurred as a result of such failure.
19. Full Disclosure. The respective parties do hereby warrant, represent, and declare, and do
acknowledge and agree that each Is and has been fully and C(1mpletely Infonned of, and Is familiar with and
cognizant of the wealth, Income, real and/or personal property, whether jointly or Individually titled. estate
and assets of the other, and that each has made a full and complete disclosure to the other of his and her
entire assets and liabilities, and any further enumeration or statement thereof In this Agreement Is hereby
specifically waived. The parties do not wish to make or append hereto any further enumeration or
statement. Each of the parties hereto further covenants and agrees for himself or herself that his or her
heirs, personal representatives and assigns, that he or she will never at any time hereafter sue the other or
his or her heirs, personal representatives or assigns, In any action or contention, direct or Indirect, that there
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was any absence or lack of full and proper disclosure. Further, both parties waive their right to have the
Inventory or financial disclosure statement of the other attached hereto. , I
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20. Reoresen's'/on of 'he Parties. WIFE Is represented by Johnson, Duffie, Stewart &
Weidner, in connection with the negotiation and preparation of this Agreement. HUSBAND Is represented
by Christopher Houston, Esquire. Each party acknowledges that he or she has received Independent legal
advice from counsel of his or her own selection, and that each fully understands the facts and has been fully
Informed as to his or her legal rights and obligations, and each party acknowledges and accepts that this
Agreement Is, In the circumstances, fair and equitable, and that It Is being entered Into freely and voluntarily,
after having received such advice and with such knowledge, and that the execution of this Agreement Is not
the result of any duress or undue Influence, and that It Is not the result of any 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 Pennsylvania Divorce Code, whereby the Court has the right and
duty to determine all marital rights of the parties Including divorce, alimony, alimony pendente lite, equitable
distribution of all marital property or property owned or possessed Individually by the other, counsel fees and
costs of litigation, and fully knowing the same and being fully advised of his or her rights thereunder, each
party hereto stili desires to execute this Agreement, acknowledging that the terms and conditions set forth
herein are fair, Just and equitable to each of the parties, and waives his and her respective right to have the
Court of Common Pleas of Cumberland County, or any other Court of competent Jurisdiction, make any
determination other than what may have already occurred or order effecting the respective party's rights to
alimony, alimony pendente lite, support and maintenance, equitable distribution, counsel fees and costs of
IIIlgatlon. Each party has carefully read this Agreement and Is completely aware of not only Its contents but
also of lis legal effect.
21. Waiver of Rich's to Other Party's Estate. Except as provided for herein, HUSBAND and
WIFE each waive any and all right:
A. To Inherit any part of the estate of the other at his or her death, except as provided
herein;
B. To receive property from the estate of the other by bequest or devise except under a
Will or Codicil dated subsequently to the effective date of this Agreement;
C. To act as personal representative of the estate of the other on intestacy unless
nominated by another party legally entitled to so act;
D. To act as the personal representative under the Will of the other unless so nominated
by a Will or Codicil dated subsequently to the effective dele of this Agreement;
E. To claim a family allowance In the estate of the other.
22. Containment of Entire Agreement Herein. this Agreement supersedes any and all other
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Agreements, either oral or in writing, between the parties reiatlng to the rights and liabilities arising out of .
their marriage. this Agreement contains the entire agreement of the parties.
23. Partial Invalidity. If any portion of this Agreement Is held by a Court of competent
Jurisdiction to be Invalid, void, or unenforceable, the remaining provisions shall, nevertheless, continue In full
force and effect without being Impaired or Invalidated In any way.
24. Breach. If either party hereto breaches any proviSion hereof, the other party shall have the
right to sue for damages for such breach, or seek such other remedies or relief as may be available to him or
her. The non'breachlng party shall be entitled to recover from the breaching party all costs, expenses and
legal fees actually Incurred In the enforcement of the rights of tho non-breaching party.
25. Effect of Reconciliation. Cohabitation or Divorce Decree. The terms of this Agreement
shall be Incorporated Into any Divorce Decree which may be entered with respect to the parties. this
Agreement shall survive any such flnal Judgment or Decree of Divorce. Both parties shall have all rights and
enforcement under applicable law including the Pennsylvania Divorce Code. this Agreement shall also
remain In full forC!" and effect even If the parties effect a reconciliation, cohabllate as Husband and Wife, or
attempt to effect a reconciliation.
26. ModlflcatiJul. This Agreement shall not be subject to modification except as In accordance I
with Pennsylvania law and with a writing between both parties evidencing their Intent to modify the
Agreement.
27. No Waiver tJf Default. This Agreement shall remain In 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 not be construed as a waiver of any
subsequent default of the same or similar nature.
28. Attormws Fees and Expenses. Each party shall be responsible for their own attomey's
fees and expenses.
29. Mutual Cooperation. Each of the parties shall, on demand, execute and deliver to the other,
any deeds, bills of sale, quit claims, assignments, consents, tax retums, and other documents and do or
cause to be done any other acts or things as may be necessary or desirable to effectuate the provisions and
purposes of this Agreement. If either party falls on demand to comply with this provision, that party shall pay
to the other all attomey's fees, costs and other expenses reasonably incurred as a result of such failure.
30. Sankruotc;y. Each of the parties acknowledges and agrees that with respect to the liabilities
each is required to assume and pay under the provisions of this Agreement, each has the ability to fulfill his
or her respective obligations from income or property not reasonably necessary to be expended for such
party's maintenance and support or for the maintenance and support of such party's dependents. Should
either party file a Petition under Tltle XI of the United States Code, or should a petition be filed against either
involuntarily, each party acknowledges and agrees that the discharge of the debtor party's obligations under
this Agreement will not result in a benefit to the debtor party that outweighs the detrimental consequence to
the non-debtor party or the non-debtor party's child or children.
31. Incol'poratlon. This Agreement may be incorporated Into a decree of divorce, but shall not
be merged. The parties shall have the right to enforce this Agreement under the Divorce Code of 1980. as
amended, and in addition, shall retain any remedies in law or In equity under this Agreement as an
independent contract. Such remedies In law or equity are specifically not waived or released.
32. Law of Pennsylvania Aoollcab/e. This Agreement shall be construed In accordance with
the laws of the Commonwealth of Pennsylvania.
33. Date of Agreement. The effective date of this Agreement shall be the date on which the last
party executes the Agreement If the parties do not execute the Agreement on the same date. Otherwise, the
effective date will be the dale that both parties execute the Agreement If they execute on the same date.
34. Successors and Assigns. This Agreement, except as otherwise expressly provided herein.
shall be binding on and shall inure to the benefit of the respective legatees. devisees. heirs, executors,
administrators, assigns and successors and Interest of the parties.
IN WITNESS WHEREOF. the partJes hereby have hereunto set their hands and seals the date and
year flrst above written.
WITNESS:
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Teresa D. Lyons
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Todd A. Lyons
:108735
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plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COmJTY, PENNSYLVANIA
TODD A. LYONS,
v
97-5928 CIVIL TERM
TERESA D. L'..'ONS,
Defendant
CIVIL ACTION - LAW
PRABCIP. TO TRANSMIT R.CORD
TO THE PROTHONOTARY:
Transmit the record. together with the following information, to the Court
for entry of a divorce decree:
1. Ground for Divorce: Irretrievable breakdown under S330I(c)
3301 (d) (1) of the Divorce Code. (Strike out inapplicable section).
2. Date and manner of service of the Complsint:
certified mail. return receiot reauested
October 28. 1997. bv
3. Complete either paragraph (a) or (b).
(a) Date of execution of the affidavit of consent required by
S330I(c) of the Divorce Code: by plaintiff Mav 1. 199B by defendant
Mav 6. 199B
(b) (I)-Date of execution of the affidavit required by S330I(d) of the
Divorce Code: (2) Date of filing and service of the
plaintiff's affidavit upon the respondent:
4. Related claims pending I
Aareement. dated Mav 6. 1998
provisions of Prooertv SfI!ttle;o.:t!nt
5. Complete either (a) or (b).
(a) Date and manner of .ervic6 of the notice of intention to file
praecipe to transmit record, a copy of which is attached:
(b) Date plaintiff's Waiver of Notice in S3301(c) Divorce was filed
with the Prothonotary: Mav 7. 199B
Date defendant's Waiver in S3301(c) Divorce was filed
with the Prothonotary:
. Hounton, Esquire
Attorney for Plaintiff
52 West Pomfret Street
Carlisle, PA 17013
717-241-5970
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TODD A. LYONS, I IN THE COURT OF COMMON PLEAS OF
Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA
I
v I CIVIL ACTION - LAW
I 5'128
TERESA D. LYONS I 97- CIVIL TERM
Defendant I
I IN DIVORCE
HOTICB TO DBFEND 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 grounds for divorce is indignities or irretrievable
breakdown of the marriage, you may request marriage counseling. A
list of marriage counselors is available in the Prothonotary's
Office at the Cumberland County Courthouse, Carlisle, Pennsylvania.
IF YOU DO HOT FILE A CLAIM FOR ALIMONY, DIVISIOH OF PROPBRTY,
LAWYBR'S FBES OR EXPBNSBS, BEFORE A DIVORCB OR AHHULMBHT IS
ORAHTBD, YOU MAY LOSB THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCB. IF YOU DO
HOT HAVE A LAWYBR OR CAHHOT AJl'FORD OHB. GO TO OR TBLEPHOHB TBB
OFFICB SBT FORTH BELOW TO FIHD OUT WHERE YOU CAN GET LEGAL
HBLP.
COURT ADMINISTRATOR
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PENNSYLVANIA 17013
TELEPHONE I 717 - 240-6200
TODD A. LYONS, I IN THE COURT OF COMMON PLEAS OF
Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA
I
v I CIVIL DIVISION - LAW
I ,rq).8
TERESA D. LYONS, I 97- CIVIL TERM
Defendant I
I IN DIVORCE
COMPLAINT
Plaintiff, Todd A. Lyons, by his attorney, Christopher C. Houston,
Esquire, sets forth the following I
1
Plaintiff, Todd A. Lyons, is an adult individual residing at 2118
Ninth Street, New Cumberland, Cumberland County, Pennsylvania.
2
Defendant. Teresa D. Lyons, is an adult individual residing at c/o
Jimmy Dietz, 220 Evergreen Road, New Cumberland, Cumberland County,
Pennsylvania.
3
The parties were married on September 11, 1993, in New Cumberland,
Cumberland County, Pennsylvania.
4
Plaintiff and Defendant have lived continuously in the Commonwealth
of Pennsylvania for at least six months prior to the commencement
of this action.
5
This action is not collusive.
6
There have been no prior actions for divorce or annulment in this
or any other jurisdiction within the knowledg~ of the Plaintiff.
7
In accordance with Section 3301(c) of the Divorce Code, the
marriage between the parties is irretrievably broken.
8
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, the Plaintiff requests your nonorable Court to decree
that the Plaintiff be divorced from the Defendant.
r stopher C. Houston, Esqu re
Attorney for Plaintiff
52 Weet Pomfret Street
Carlisle, PA 17013
717-24l-5970
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
TODD A. LYONS,
v
CIVIL ACTION - LAW
TERESA D. LYONS,
Defendant
97-5928
CIVIL TERM
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 grounds for divorce is indignities or irretrievable
breakdown of the marriage, you may request marriage counseling. A
list of marriage counselors is available in the Prothonotary's
Office at the Cumberland County Courthouse, Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY. DIVISION OF PROPBRTY.
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 loAWYER 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
TWO LIBERTY AVENUE
CARLISLE, PENNSYLVANIA 17013
TELEPHONE: 717-249-3166
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
TODD A. LYONS,
v
CIVIL DIVISION - LAW
TERESA D. LYONS,
: 97-5928
CIVIL TERM
Defendant
IN DIVORCE
AMBNDBD COMPLAINT
Plaintiff, Todd A. Lyons, by his attorney, Christopher C. Houston,
Esquire, sets forth the following:
1
Plaintiff, Todd A. Lyons, is an adult individual residing at 211B
Ninth Street, New Cumberland, Cumberland County, Pennsylvania.
2
Defendant, Teresa D. Lyons, is an adult individual residing at c/o
Jimmy Dietz, 220 Evergreen Road, New Cumberland, Cumberland County,
Pennsylvania.
3
The parties were married on September 11, 1993, in New Cumberland,
cumberland County, Pennsylvania.
4
Plaintiff and Defendant have lived continuously in the Commonwealth
of Pennsylvania for at least six months prior to the commencement
of this action.
5
This action is not collusive.
6
There have been no prior actions for divorce or annulment in this
or any other jurisdiction within the knowledge of the Plaintiff.
7
In accordance with Section 3301 (c) of the Divorce Code, the
marriage between the parties is irretrievably broken.
8
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, the Plaintiff requests your Honorable Court to decree
that the Plaintiff be divorced from the Defendant.
COUNT II - DIVORCE PURSUANT TO 3301(a) (6)
9
Paragraphs 1 through 6 of the Complaint are incorporated herein by
reference as though set forth in full.
10
The Defendant has offered such indignities to the Plaintiff, the
injured and innocent spouse, as to render his condition intolerable
and life burdensome.
WHEREFORE, the plaintiff requests your Honorable Court to decree
that the Plaintiff be divorced from the Defendant.
COUNT III - BQUITABLB DISTRIBUrION
11
Plaintiff and Defendant have acquired property, both real and
personal during their marriage from September 11, 1993 until
October 15, 1997, the date of their separation.
12
Plaintiff and Defendant have been unable to agree as to an
equitable division of said property.
WHEREFORE, Plaintiff requests your Honorable Court to equitably
divide all marital property.
Christopher Houston, Esquire
Attorney for Plaintiff
52 West Pomfret Street
Carlisl~, PA 17013
717 - 241-5970
I verify that the statements in the foregoing pleading are true and
correct.
I understand that false statements herein are made
subject to the penalties of 18 PaCS 4904 relating to unsworn
falsification to authorities.
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By: Kcirsten L. Walsh
1.0, No, 78243
301 Market Street
p, 0, Box 109
Lel11oyne. Pennsylvania 17043-0109
(717) 761-4540
Attorneys for Defendant
TODD A. LYONS.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO, 97-5928 CIVIL TERM
CIVIL ACTION - LAW
Plaintiff
v,
TERESA D, LYONS,
IN DIVORCE
Dsfendant
AFRDA VlT OF CONSENT
1. A Complaint In divorce under Section 3301(c) of the Divorce Code was filed on October 27,
1997,
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed
from the date of filinllths 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.
4, I have been advised of the availability of marriage counseling, understand that the Court
maintains a list of marriags counselors and that I may request the Court require my spouse and Ita participate
in counseling and, being so advised, I do not request that the Court require that my spouse and I participate In
counseling prior to the divorce becoming final.
I verify that ths 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. ~904 relating to unsworn falsification to
authorities,
Date: ~ (,." '118
~ Vl-UlA D ~~
Teresa D. Lyons, Defen nt
,
Johnson, Duffie, Stewart & Weidner
By: Keirslen L. Walsh
1.0, No, 78243
30 I Market Street
p, 0, Box 109
Lernoyne, Pennsylvania 17043-0109
(717) 761-4540
Attorneys for Defendant
TODD A. LYONS,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO, 97-5928 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
Plaintiff
v,
TERESA 0, LYONS.
Defendant
WAIVER OF NOTICE OF INTENTION TO
REQUEST ENTRY OF A DIVORCE DECREE
UNDER SECTION 3301(,,1 OF THE DIVORCE CODE
1, I consent to ths entry of a final decree in divorce without notice,
2. I understand that I may lose rights concerning alimony, division of properly, lawyer's fees or
expenses If I do not claim thsm before a divorce Is granted,
3, I understand that I will not be divorced until a divorce dscree Is entered by the Court and that a
copy of ths decres will be sent to ms immediately after It is filed with the Prothonotary.
I verify that ths statsments mads In this Affidavit ars true and correct. I understand thst false
statements herein are made subject to the penalties of 18 Pa.C,S. ~904 relating 10 unsworn falsification to
authorities,
Date: Y1l(j fr., J l.:l..i8
r;;A4/U> 1) ~l~r.>-
Teresa D. Lyons, Defe ant
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Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 97-5928 CIVIL TERM
TODD A. LYONS,
v,
CIVIL ACTION - LAW
IN DIVORCE
TERESA D. LYONS,
Defendant
AFFIDAVIT OF CONSENT
1. A Complaint In divorce under Ssctlon 3301(c) of the Divorce Cods was filed on October 27,
1997. An Amended Complaint was filed on February 25,1998.
2. The marriage of Plaintiff and Defsndant is irretrievably broken and ninety days have elapsed
from the date of filing the Complaint.
3. I consent to ths entry of a final decree In divorce after seNlce of notice of Intention to request
entry of ths decree.
4. I have been advised of the availability of marriage counseling, undsrstand that the Court
maintains a list of marriags counselors and that I may request the Court require my spouse and Ito partlclpate
in counseling and, being so advised, I do not request thatths Court require that my spouse and I participate In
counseling prior to ths divorce becoming final,
I verify Ihat the statemenls mads In this Affidavit are lrue and correct. I understand that false
statements herein are made subject to Ihe penalties of 18 Pa.C,S, ~904 relating to unsworn falsification to
authorities.
Date:
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Todd A, Lyons, Plaintiff
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 97-5928 CIVIL TERM
CIVIL ACTION - LAW
TODD A. LYONS,
v,
TERESA D. LYONS,
IN DIVORCE
Defendant
WAIVER OF NOTICE OF INTENTION TO
REQUEST ENTRY OF A DIVORCE DECREE
UNDER SECTION 330ftl;} OF THE DIVORCE CODE
1. I consent to the entry of a final dscree In divorce without notice.
2. I understand that I may lose rights concemlng 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 bs divorced unlil a divorce decree Is entsred by the Court and that s
copy of the decree will be sent to me Immediately after It Is filed with ths 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 penallles of 18 Pa,C,S. ~904 relating to unswom falsificallon to
authorilles,
Date:
Mo.'t I, I'}')i',
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Todd A. Lyons, Plaintiff
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Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
TERESA D. LYONS.
Defendant
CIVIL ACTION - LAW
NO. 97 - 5928 CIVIL
19
IN DIVORCE
STATUS SHEET
DATE I
ACTIVITIESI
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OFFICE OF DIVORCE MASTER
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
9 North Hanover Slreel
Carlisle. PA 17013
(717) 240.6535
I. Robert Ellck.r, II
Divorce Maste,
Tracl .10 Col~.r
Office ManagerlReporte,
w... Shore
697-0371 Ex', 6535
March 3, 1998
Christopher C. Houston, Esquire
52 West Pomfret street
Carlisle, PA 17013
Teresa D. Lyons
clo Jimmy Dietz
220 Evergreen Road
New Cumberland, PA 17070
RE: Todd A. Lyons vs. Teresa D. Lyons
No. 97 - 5928 civil
In Divorce
Dear Mr. Houston and Mr. Lyons:
By order of Court of President Judge George E. Hoffer
dated February 26, 199B, the full-time Master has been appointed
in the above referenced divorce proceedings.
A divorcB complaint was filed on October 27, 1998,
raising grounds for divorce of irretrievable breakdown of the
marriage. On February 25, 1998, an amended complaint was filed
adding grounds for divorce of indignities and the economic claim
of equitable distribution.
If the parties are not willing to sign affidavits of
consent, I direct that they advise me within the next two weeks;
I will then immediately schedule a hearing on the alternative
grounds of indignities.
Assuming that grounds for divorce are not an issue and
that both parties will sign affidavits of consent, I am
directing Mr. Houston, attorney for Mr. Lyons and Ms. Lyons, who
apparently is representing herself, to each file a pre-trial
statement in accordance with P.R.C.P. 1920.33(b) on or before
Monday, March 3D, 199B. upon receipt of the pre-trial
statements, I will immediately schedule a pre-hearing conference
with counsel for husband and with Ms. Lyons, if she remains
Hr. Houston, Attorney at Law, and Ms. Lyons, Defendant
3 March 1998
Paqe 2
unrepre.ented, to discuss the issues and, if necessary, schedule
a hearinq.
Very truly yours,
E. Robert Elicker, II
Divorce Master
NOTE: Sanctions for failure to file the pre-trial statem~nts
are set forth in subdivision (c) and (d) of Rule 1920.33.
THE ORIGINAL PRE-TRIAL STATEMENT SHOULD BE FILED IN THE
MASTER'S OFFICE AND A COPY SENT DIRECTLY TO OPPOSING
COUNSEL.
Christopher C, Houston
Anorney at Law
52 We.' Pomrrel Slreet
Carli.le. Penn.ylvania 17013
717-2-11-5970 Fac.imile: 717-2'\1-6970
June 1, 1998
E. Robert Elicker, II, Esquire
Divorce Master
Office of the Divorce Master
Cumberland County Court of
Common Pleas
9 North Hanover Street
Carlisle, PA 17013
RBI Lyon. v Lyon./97-5928
Dear Bob:
Enclosed please find two copies of the fully-executed Property
Settlement Agreement on the above matter. We would need to have
your appointment vacated so as to proceed and finalize the divorce.
kb
Enclosures
cc: Keirsten L. Walsh, Esquire
Todd A. Lyons
-, .
Johnson, Duffie, 5:tewart & Weidner
By: Keirsten L. Walsh
('D. No, 78243
301 Market Street
P. 0, Box 109
Lemoyne, Pennsylvania 17043-0109
(717) 761-4540
Attorneys for Petitioner
TODD A. LYONS.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY. PENNSYLVANIA
NO. 97.5928 CIVIL TERM
CIVIL ACTION -IN SUPPORT
PlaintifflRespondent
v,
TERESA D. LYONS,
DefendanVPstltloner
PETITION FOR ALIMONY PENDENTE LITE
1. Petitioner is Teresa D. Lyons.
2. Respondent is Todd A. Lyons,
3. Petitioner resides at 220 Evergreen Road. New Cumberland, York County, Pennsylvania
17070. Petitioner's Social Security Number is 166-60-1421, and dats of birth Is February 6,1963,
4. Respondent rssides at 211 9"' Street, Apt. B, New Cumberland, Cumberland County.
Pennsylvania 17070, Respondent's Social Security Numbsr is 179-56-6326, and date of birth is April 10.
1966,
5, Petitioner and Respondent wers married on September 11. 1993, In New Cumberland.
Cumberland County, Pennsylvania.
Petitioner and Respondent were separated on or about October 15, 1997.
6, Petitioner seeks APL for the following psrsons: hersslf.
WHEREFORE, Petitioner requests that an order be entered against Respondent and in favor of the
Petitioner for reasonable APL and health and medical coverage.
JOHNSON. DUFFIE. STEWART & WEIDNER
BY:~ V] 'dllll.~l
Kelrsten L, Walsh
:107418
I verify that the Itatementl made In thll Petition are true and correct. I understand that false
statements herein are made lubjectto the penaltlel of 18 Pa,C.S. ~904, relating to unsworn falsification to
authorltlel,
~M_]'J ~"
Teresa D. Lyon
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CERTIFICA TE OF SERVICE
AND NOW. this 12'" day of March. 1998, the undersigned does hereby certify that she did this date
servs a copy of the foregoing Petillon for Alimony Pendents Lite upon the other parties of record by causing
same to be deposited in the United States Mail, first class postage prepaid, at Lsmoyne, Pennsylvania,
addressed as follows:
Christopher C. Houston, Esquire
52 West Pomfret Street
Carllsls, PA 17013
JOHNSON. DUFFIE, STEWART & WEIDNER
BY:~~~
Kelrsten L. Walsh
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RICHARD W HEWART
C ROY WEIDNER. IlL
EDMUND G MYEIU
DAVID W DELUCE
RALPH H WRIGHT, IlL
DAVID J L~NZA
IOSEPH L, HITCHINGS
MARK C. DUffiE
KEIIl5TEN L. WAUH
lAW Olfln~
JOHNSON, DUFFIE, STEWART & WEIDNER
A Profelllonal Corporarlon
lOI MARKET STREET
P. 0, BOX 109
LEMOYNE, PENNSYLVANIA 17043-0109
HORACE ^- IOHNSON
0, COUNUL
TiLll'HONI717,761.4540
FACSIMILI717-761-]OU
I.MAIL 1Il.IIGJdtw.com
March 30,1998
FAX AND REGULAR MAIL
E. Robert Elicker, II
Divorce Master
Cumberland County
Court of Common Pleas
9 North Hanover Street
Carlisle, PA 17013
Re: Lyons v, Lyons
Dsar Attorney Elicker:
Pursuant to my tslephone message with your recsptlonlst on Friday, March 27, 1998,
please be advised that Todd and Teresa Lyons have reached an agreement with respect to
their divorce. Therefore, neither party will be submitting pretrial statements, and It appears as
though a prehearing confsrence/master's conference will be unnecessary.
I am confirming the above by copy of this letter to Attorney Christopher Houston.
If you have any questions, please do not hesitate to contact me,
Very truly yours,
JOHNSON,~UFFIE~ ~Tr=WART & WEIDNER
LY-t~,}.n., 'oA Cc 'j. )
Keirsten L. Walsh
KLW:kkm:108551
cc: Christopher C. Houston, Esquire
Teresa D, Lyons
In the Court uf Common P1ellS of CUMBERLAND County. Pennsylvania
DOMESTIC RELATIONS SECTION
TERBSA D. LYONS ) Oll\:kCI Numher 97-59a
Plaimiff )
'IS. ) PACSES Case: Numher 730100071
TODD A. LYONS )
Ocfclldllnl ) Othcr Sllll. ID Numher DR. ,174:).7
CONSENT ORDER
AND NOW, to wit on this
27TH DAY OF MAY, 1998
IT IS HEREBY
ORDERED that the D Complaint for Support or 0 Petition to Modify or I[] Other
Petition for AliJoony Pendente Lite filed on March 19, 1998
in the above captioned
mailer is dismissed without prejudice due to:
Parties' r~achlllg a settlement agreement.
o The Complaint or Petition may be reinstated upon wriuen application of the plaintiff
petitioner. if filed within one year from date hereof.
Consented:
Date
Plaintiff Signature
Date
Defendant Signature
BY THE COURT:
DROI
CCI
CCI
CCI
Form OE-SOS
Wllrk.r ID 21201
R.J. Shadday '----""
plaintiff and defendant ) L I
. J;a'~o.,.LJt..(c
Keusten L. Walsh, Esq. i)f'.llIJ
Christopher C. Houston, Esq ,."
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