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Home My WebLink About98-02184 ~ ~.. ~I " &: ~ ~ ~ ~ ~ " ~ " ,i ~ ~ -:- .. .':) '- <::J ~ ~ - ti . 0.- ~ ~ ..:+:.--,..- .~<<. .~:. ':+:'_ .~.:. .~+:. .:.:.- ,:<<.- .:+;. .:+:. <.:.- .:+~. .:+} .:.:. .:+~. <.:. _<+:. .:+;. -:+;. :._---.:+:.:-._:+:.:,:.~.~._ ':.;'- .:.:.' .:.:. _.:<<.--.:c-: -.:.i(_'~ li!'-"'^-"-"^~'~'" >"-_.. '~-'-^^-'-- ,..",...,... ..,,,, ...,- -..........,., ..... .,..., -""-"-^-''^~^' " , 8 t 8 ~ 8 ~ IN THE COURT OF COMMON PLEAS ~ ~ ':' ~ .:! P.l ~ ~ .:! P.l " ~ ,'. * .', ~ " P.l ~ ~ ,,' ~ " !' " ~ .:, ~ OF CUMBERLAND COUNTY STATE OF ;,~..,1:. .~ PENNA. ~~,l ~.. ,\'. . ",,/, ~ " P.l .'. ~ ~ .', * ~ ,,, ~ DeAise Jo McCardell Plaintiff N (),..~~::~J8.4..",...._.. I () ~ Vl'I','';W; ... ~ steven M. McCardell .', * ~ 'i ~ " Defendant :1 ,'. ~ DECREE IN DIVORCE ;'~ * ~ 'i AND NOW" _" _t:),:to~(l:", _, -l,.",,' 19 ",i, , it is ordered and decreed that, , , , , , , .l?fi'fl,i,~~, iIp .M9{::,a,z:cj~~,l, , , , , , , , , , , , , , , , , , " plaintiff, and ' , . , , , , , , . , , , , , , , S,teven ,M. , McCardell, , , , , , , , , , , , , , , , " 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; The Property Settlement and Separation Agreement dated ....'..........,'......., . ",.."........"..,..,....,..",......,........ , , , 9/,9/98, ,i,~ ,~~,reby, ,i!,!cor()orat,ec;l bu.t ,n?,t ,mer,g,~d ~, , , , , , , , , , , , , , , , , , , /J y Tho. el'/" " I : /J /J d. w~ Kr..a t)e~r ^th.~t' _~ /1 '."Ii ?_- ., <H14 / . X~~ ,~"~?t.td< ~t');t< k .J:jh^ .. .' r . ~ 8 ~ ~;.w.:<<<:- ,:.:::;;:,^ 'It:' '..:' ,:.;,:.i: ::.:' - ':.::::+:' .. ':.:: ::+~ ':+;, ':+;, ,i+:, -:+~ ':+;, ':+;. ~ " ~ ~ .. ~ ~ ~ " ~ ~ ,< ~ " ~ ',l ~ ~ .. f~f ~ ~ ~ " ~ ~ ... *. ~.~ ~ " a ~.~ ~ \,1 ~ ... ~ ... ~ l~ ',' ~ ',' w ... ~ ',' ~ '.. ~ '.. .J, * ',' ~ '.' ~ ',' * .:+;. -:.:- .:+:' ,~~;. .~.;. -:.;. -:+:- 0:.;' ,:.;. .:+:.' ~ ',' SAlOIS, SHUFF & MAS LAND AmlIMtYIIATtLAW 16 W, HIaJ> Str..t eorUII.. p^ hereby releases the other from any and all claims, or demands up to the date of execution hereof. (3) The parties are the owners of a certain real estate with improvements thereon erected known as 1934 Carlisle Road, Camp Hill, PA 17011, Wife agrees within thirty (30) days of the signing of this Agreement to convey said real estat.e to Husband by special warranty deed, Husband shall assume full responsibility for all household expenses including but not limited to the mortgage to Fleet Mortgage, liens of record, utility bills, insurance and real estate taxes in connection with said property, With regard to all such expenses, Husband agrees to hold Wlfe harmless and indemnify her from any loss thereon, In exchange for her equity in the property, Husband agrees to pay to the Wifa the sum of $18,000,00, to be payable within 120 days of the signing of this Agreement, (4) In the event that either party contracted or incurred any debts since the date of sepat'at ion on November 6, 1997, the party who incurred said debt shall be responsible for the payment ther'eof regardless of the name in which the debt may have been incurred, Husband and Wife acknowledge and agree that they have no other outstanding joint debts and obligations of the Husband and Wife incurred prior to the signing of this Agreement, (5) Each party relinquishes any right, title and interest he or she may have to any and all motor vehicles currently in possession of the other party, Each party shall execute any SAlOIS. SHUFF & MASLAND ATDNIYltATtlAW J6 W, "Ish II.... CollI..., PA documento necessary to have said vehicles properly registered in the other party's name with the Pennsylvania Department of Transportation, Each party shall assume full responsibility of any encumbrance on the motor vehicle received by said party, and shall hold harmless and indemnify the other party from any loss thereon, (6) The parties hereto mutually agree that they have effected a satisfactory division of the furniture, household furnishings, appliances, tools and other household personal property between them, and they mutually agree that each party shall from and after the date hereof be the sole and separate owner of all such property presently in his or her POSSession whether said property was heretofore owned jointly or individually by the parties hereto, Husband specifically reserves a list of items of personalty which is attached hereto and made a part hereof and marked as Exhibit nAn, This agreement shall have the effect of an assignment or bill of sale from each party to the other for such property as may be in the individual possession of each of the parties hereto, (7) Each party hereby relinquishes any right, title or interest he or she may have in or to any intangible personal property currently titled in the name of or in the possession of the other party, including, but not limited to, Wife's pension and 401K with Penn National Insurance Company I and Husband's 403B, and his pension with the Naval Reserve, as well as stocks, bonds, insurance, bank accounts and retirement accounts, (8) Except as otherwise provided herein, Husband shall not pay to Wife nor Wife to Husband any sum whatsoever as alimony, alimony pendente lite, or for his or her support or maintenance, (9) Wife does not seek Husband to provide post - secondary financial assistance for their children, Tina Lu McCardell and Jason Craig McCardell as a result of the result of thls Agreement. This does not preclude, however, the rights that said children may have as a result of the status of the law at the tlme attendance of post-secondary education. (10) Each party is now represented by counsel of his and her own choice, and each shall pay his or her own attorney for all legal services rendered or to be rendered on his or her behalf, (11) Neither party shall contract or incur any debt or liability for which the other party or his or her property or estate might be responsible and shall indemnify and save the other party harmless from any and all claims or demands made against him or her by reason of debts or obligations incurred by the other party, (12) Each of the parties shall from time to time, at the request of the other, execute, acknowledge and deliver to the SAlOIS. SHUFF & MASLAND A~AT'LAW 16 W, "11h 8l1H' COIII.le, p~ other party any and all further instruments that may be reasonably required to give full force and effect to the provision of this Agreen,ent, (13) The parties do hereby warrant, represent. acknowledge and agree that each is fully and completely informed of, and is (21) This Agreement shall bind the parties h~reto, their respective heirs, executors and assigns, IN WITNESS WHEREOF, the parties hereto intending to be legally bound have hereunto set their hands and seals the day .nd _~O__'~"'" iJ.'.'l_ .bovO WitI s I Cl;oo ~W'::::..-_ Witness :J)t~~tllc In~C~h,ilI1f) Denise J cCardell .... . " - _.1 ,~'_,.. _II., '1/' , .. .....(.....' ~_St....:L''"''_L? /,;/ J:.a.uJ.llJ..., Steven M, McCer ell SAlOIS. SHUFF & MASLAND ~ 16 W, HI'" 81,eel ~,\III.,P^ ;It DENISE JO MCCARDELL, ,IN THE COURT OF COHMON I'I.EIIS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Plaintiff VS. STEVEN M. MCCARDEI,L, NO. 98-2184 CIVIL TERM Defendant 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. Ground for divorce: irretrievable breakdown under S3301(c) ,1l1X~)<OQX) of the Dfvorce Code. (Strike out inapplicable section). 2. Date and manner of service of the complaint: April 25, 1998, c~rtified mail (see attached) 3. Complete eitner paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by 53301(c) of f;he Divorce Code: by plaintiff 9/22/98 by defendant 9/22/98 (bl(l) Date of execution of the S3J01(d) and of the Divorce service of the affidavit required by : (2) Date of filing affidavit upon the r.:!spondent: Code: plainUff's 4. Related claims pending: none 5. Complete either (a) or (bl. (a) Date and manner of service 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 53301(c) Divorce was filed with the Prothonctary: Date defendant's Waiver of Notice in 53301(c) Divorce was filed wi th the Prothonotary: Att:o """ ...:l' ~ 'C.1.; '" .c ;?; I," .. ~',;1.,'(, ~.I(;; - - :,'>:1~ )J,. ~c ;1: ,,) ~.J. 0:1" ..< ',),!~ (11\:- ;If (,'"1 \-j',\('-' N dll' L\_ ",I~O ~~ .-\ I""' \J\ 1.. I,' Vi "<i!: lJ. 0',' ~') 0 cn 0 ....., DENISE JO MoCARDELL, f IN THE COURT OF COMMON PLEAS OF plaintiff I CUMBERLAND coUNTy, PENNSYLVANIA I C-lud, Tl<-.....- v. I NO. 98- j I j'L( I STEVEN M. MoCARDlCLL, I Defendant I IN DIVORCE COMPLAINT UNDER SECTION 3~Ol(C) OR 3301(d) OF THE DlVORCE ~ODE 1. plaintiff is Denise Jo McCardell, who currently resides at P.O. Box 1351/ Camp Hill, Cumberland County, Pennsylvania. 2. Defendant is Steven M. McCardell who currently resides at 1934 Carlisle Road, Camp Hill, PA 17001. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previoua to the filing of thi,s Complaint, 4, The plaintiff and Defendant were married on November 19, 1988 in Mechanicsburg, Cumberland County, Pennsylvania. 5. There have been no prioI' actions of divorce or for annulment between the parties, 6. 'rhe plaintiff has been advised of the availability of marriage counseling and the plaintiff may have the right to request that the Court require the parties to participate in counseling. Having been so advised plaintiff does not desire SAlOIS. SHUFF & MASLAND ATMIN!YltAT_UW 16 W. H1lh 51...1 Cull,I.. PA the Court to order counseling. 7. The marriage is irretrievably broken. ~ DENISE JO MCCARDELL, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUN'l'Y I PENNSYLVANIA NO. Y I. J II '( C,;,U ?;,'" v. STEVEN M. MCCARDELL Defendant IN DIVORCE AE'FIDAVU I, Deniss Jo McCardell being d~ly sworn according to law, depose and say: (1) I have been advised of the availability of marriage counselling and 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, Date: ~ ~?'m~ Denise Jo McCardel1 Plaintiff /~ 19tJfI . ...' t .-<6" ~ o ~ ,'" (t 9 c<' .-' rf\ ~ tl' ~ ~ ~ ~~. .\ \. '..'" i'-., ',' ..... 1.'<' l'\ \ ,. .. \\..\ + -5. J , , (~~ \" . V ~,\. , ' \' \\. ." ...-,. '.'. ~) .) I,' \ (~ 1..,) DENISE JO MCCARDELL, Plaintiff i v. I IN THE COURT OP' COMMON PI,EAS OF CUMBERLAND COUNTY, PENNSYLVAN1A NO. 98.2184 STEVEN M. MCCARDELL, Defendant IN DIVORCE PLAINTIFF'S l\!':.E.J,DAVIT OLCONSEN'I' lINfL WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVOR~E DECREE UNDER SECTION 33Qi(c) OF THE DIVORCE CQllE 1, A Complaint in divorce under Section 3301 (c) of the Divorce Code was filed on April 20/ 199B, 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint, 3, I consent to the entry of a final decree of divorce without notice. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not clai them before a divorce is granted. 5. I understand that I will not be divorced until a divorce decree 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. Section 4904 relating to unsworn falsification to authorities. " ' DATED I .1/ d-o,/0 'J' :::D.t.t..1~~~ )n~t~h.dL1.L . Denise J McCardell, Plaintiff ......'. 63 N ...... C\.! E-: "C :J~J" ,.,. .. t:,q - .- C)t:rJ )-, cJ';i: f"'c, ~,~ 1"-1 .<t.; i);~~! r"i r, co d?i:1) 61" (f'J -lJI,,< ('\.I ,;~J (~~ ..j" frj \ dtll (l~ ,L Un, , Vi ;1~ Lt.. r" ,.l 0 01 0 '",..) SAlOIS, SHUFF & MAS LAND AT1'faJMYleATtLAW 16 W, HI.h 81.ee, CoIII.I.. PA Dl':NISE ,)0 MCCARDEl,L, Plaintiff IN THE: COURT OV' COMMON PLEAS OF I CUMBI\RLAND COUNTY, PENNSYlNANIA v. NO, 98-2184 STEVEN M MCCARDELL, Defendant IN DIVORCE DI\PENDAl::lJ~12 AEE,lDAVIT OF CONSEN'L ACC.!WIMJ;]; OF SERVICE lilil2 W/lIVER _9..f NO'l'le!}; OF IN'rEN'l'lON-.1QjlliQJl!'t!IT !lli.IR.:LPF A DI.Y9RQlLQE.CREE UNDEIL SECTION 3301 (c) OF .THE DIVORCE; \'..Qill; 1. A Complaint in divorce under Section 3301 (c) of the Divorce Code was filed on April 20, 1998, 2. Defendant ilcknowledges and accepts service of the Complaint on Apri.l 25, 199B, 3, The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 4. I consent to the entry of a final decree of divorce without notice, 5. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expellses if I do not claim them before a divorce is g~anted. 6. I understand that I will not be divorced until a divorce decree 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. 7, I have been advised of the availability of marriage counselling and understand that I may request that the court require counselling. I do not request that the court require counselling. 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 IB Pa, C.S, Section 4904 relating to unsworn falsification to authorities. DATED: __,_2//.:., )/-5..'5.___ .' ;.' .' , '.;' s'rft:~7'r~ ,. /~~6:::;~r~ 't~<___ Defendant ", ,~ C\J ',.. , ~F 1'\1 1::; ,.. .. ..-,;.. ("1 ,::::l.~ ~J;' '- '- ():;' rt,\ ~jI:~ L) ~'f' ~I-~:' .,"< (li: r~~.:J c"1 (, ..)('1 ,...) ;0," 1;5 ~ll' N ',i?~:; U:I.;< o. ;,'.lrti j, : ~,' UJ, U) jJ" t!" (,l"') ::5 (,.) 0' C..>