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Home My WebLink About98-06559 \.. ~ ~ "'I ~ \ '4 \,~ -. ~ ~~ ..... . , ." ~ ~ ~' . ' 'C) : \c)1 ~f i I f l..>aj ~I ,I ~ ~--**'~*'~*~'~*'~'~~'*"~'~'*"~'*'>'~*'~*'~***~'~ ...."..., """" ,. ,-, .... ''",._..'.....~ .....-,._,.~-.,........----.,!' ~ *- ~.# ~ ;(. ~ ~ ~ ~ -~-,- ,..:.-:..:.-:.:. .:.:. .:+:. .~"'~ I~ !* ~ i~ )~ ), i. /'.' '';; r'.' , . ,'~ ( , I~ )", ,~ .:+;. -:+:- .:+;. -:~;. -:+;. -:+;. .:<t;. <~;. .:+;. .:+i.' ~. ,', "-.,1 f.' : I ~i IN THE COURT OF COMMON PLEAS ~:' " ~:i ~I ',', ,',1 ~! ~. '.'i ~I -"i ~I :1 ~, ,J ~ OF CUMBERLAND COUNTY t;\' STATE OF ;~~~! PENNA. JUNE LIANNE HUNT, \: (), 98-6559 CIVIL Plaintiff II} \'('1"'11< JEFFREY CHARLES HUNT, ~ Defendant ~ ~I' .. ~! :::1 ~ DECREE IN DIVORCE V\\cwJ1'Z. AN D NOW, . . . . . .. . . .. , . .. . . . . . . . . . it is ordered and ~ y .. $ 199.9. ~ ~.' decreed that .JUNE, .L~AN.~E. HUN~. and . ~F;FFR,EY. ClIARLE.S ,HUN.'f. . .. . . .,. ore divorced from the bonds of matrimony, I ' fff ............" porn I . . . . . . . . . . " defendant, ?- ~ ~ '.' ~ The court retains jurisdiction of the following claims which have been raised of r.ttc~rd in this action for which a final order has not yet been entered; ~ ~ ~ ~.~ ~ The Marriage Settlement Agreement dated December 3, 1998 is .... ...... ...... ... ......., '" ........ """"" ...... ......... .... ......., s ,hE7r~.b~ ,~~,~'?:r:P?.ra~~?. ,i~. .1;0 . J;~i,!, !)~c~~~. .~J:l. piyo~.~~, . , , , . . . . . . . . . , . ./ ,'. ~ ~ " ~ :-~ / / ?( A /'..4. 'v.: ' ttcst:G-kt:UJ ;1(-. ~,-1'~': .~~7/,_"7~ .~- y ~ ~ 7,,~ -"i: /" ~{l ') y ,~ rothonotary /J y ; T(h ' *- v J, $ ~ " ~ ~ ~ v ~ v ~ ~ ',' ~ ',' ~ ',' ~ ~ ',I s ,,~ ~ ~ " .' ~ s ~ v t~ i~ .. i(.'~ ~ ; ~ $ ~ ~ ~ ',' ~ .Jj,/~7' t ;,/, dyy~: t',;;;' ~ d;f .d;,',;:/ .]0"'/;7""~ /i:' ~ r,J..-> 7'C / ...' ........' ";/ " -.'/' " I~ <<,' ~{t:(_, {, L. .', ~ . ;,1... .. ':7"<< ( LAW OFFICE OF THOMAS D. GOULD A"ORNEVS A' LAW 2 EAS! MAIN STREET' SHIREMANS10WN, PA 17011 117,731,1461 u 'M ~c.,_._._.._.___,__u_._.._.._.- MARRIAGE SETTLEMENT AGREEMENT I ~ deC/~ THIS AGREEMENT made this day of , 1998, by and between Jeffrey C, Hunt, (hereinafter referred to as "Husband,") and June L, Hunt, (hereinafter referred to as "Wife"), WITNESSETH: WHEREAS, the Husband and Wife were lawfully married on July 9, 1990; and WHEREAS, differences have arisen between Husband and Wife in consequence of which they intend to live apart from each other; and WHEREAS, there were no children born of this marriage; and WHEREAS, Husband and Wife desire to settle and determine their rights and obligations; and NOW, THEREFORE, the parties intending to be legally bound hereby do covenant and agree as follows; 1 , SEPARATION It shall be lawful for each party at all times hereafter to live separate and apart from the other party at such place or places as he or she may from time to time choose or deem fit, The foregoing provisions shall not be taken as an admission on the part of either party as to the lawfulness or unlawfulness of the causes leading to their living apart. 2 , INTERFERENCE Each party shall be free from interference, authority, and contact by the other as fully as if he or she were single and unmarried except as maybe necessary to carry out the provisions of the agreement, Neither party shall molest the other or attempt to endeavor to molest the other, nor compel the other to cohabit with the other, or in any way harass or malign the other, nor in any way interfere with the peaceful existence, separate and apart from the other, 1 3, DIVISION OF PERSONAL PROPERTY The parties have equitably divided between them to their mutual satisfaction the personal affects, household furniture and furnishings and all other articles of personal property which heretofore have been used by them in common, Neither party will make any claim to any such items which are now in the possession or under the control of the other. 4, AUTOMOBILES The Husband is the owner of a 1982 Ford Bronco and Wife is the owner of a 1997 Chevrolet Cavalier. Husband shall have all right and title to his vehicle, He shall maintain insurance on his vehicle and be responsible for any and all maintenance and other payments related thereto. Husband shall indemnify and hold Wife harmless for all matters related to his vehicle, Wife shall have all right and title to her vehicle and shall maintain insurar.ce on her vehicle and be responsible for any and all maintenance and other payments related thereto. Wife shall indemnify and hold Husband harmless for all matters related to her vehicle, 5, DIVISION OF REAL PROPERTY The real estate owned by the parties as tenants by the entireties situated at 349 Sporting Hill Road, Mechanicsburg, Cumberland County, Pennsylvania shall be conveyed in fee simple to Husband. Husband shall assume full responsibility for the payment of the existing mortgages, notes, liens and taxes. Husband shall indemnify and hold Wife harmless from any liability on the marital home's mortgages, notes, liens and taxes, Husband shall make every reasonable attempt to refinance the existing mortgages/notes on the marital home, If Husband is not successful in his first attempt to refinance the marital home, he will make a new application, at least every l2 months, from time to time. Wife agrees to cooperate with Husband and provide all required information and sign any documents necessary to assist Husband in refinancing the mortgage and note solely into his name, Upon execution of this Agreement Wife relinquishes any and all rights or interest in property, specifically including the marital home, provided in this Agreement, releases and any marital except as 2 6, MARITAL DEBTS Husband shall be responsible for all marital debts solely in his name and the mortgages, notes, liens and other costs, taxes, utilities & expenses related to the marital home, Wife shall be responsible for all marital debts solely in her name. Wife shall not be liable for any debts related the marital home. Each party agrees to indemnify and hold the other harmless for any debt that they are responsible for pursuant to this Agreement. It is understood that it may be in either or both parties best interest to seek protection from creditors under the Bankruptcy Code. Either party may file bankruptcy and thereby relieve him/herself of the liability for joint and individual debts, 7. PENSION AND RETIREMENT ACCOUNTS Husband and Wife shall maintain their separate pension and/or retirement accounts. Husband relinquishes any and all rights he may have in Wife's pension or retirement accounts and Wife relinquishes any and all rights she may have in Husband's pension or retirement accounts, 8, SUPPORT/ALIMONY/ALIMONY PENDENTE LITE The parties hereby waive, release, discharge and give up any rights either may have against the other to receive spousal support, alimony pendente lite or alimony. 9 . FILING OF IRS RETURN Husband and Wife agree to file a joint tax return for tax year 1998 and separate returns in all subsequent years, lO, DIVORCE Wife filed a Complaint in Divorce on November 18, 1998 in Cumberland County, The parties agree to cooperate with each other in obtaining a final divorce of the marriage, It is agreed that at the expiration of the mandatory 90 day waiting period each party shall execute and allow to be filed the documents necessary to obtain a divorce. Each party shall be responsible for their respective attorney fees and costs, ll, INCORPORATION This agreement is to be incorporated into any subsequent Degree in Divorce, 3 .... 12, CONTINUED COOPERATION The parties agree that Lhey will within fifteen days after the execution of this agreement execute any and all written instruments assignments, releases, deeds or notes or other such writings as may be necessary or desirable for the proper effectuation of this agreement, 13, BREACH If either party breaches any provision of this agreement, the other party shall have the right, at his or her election, to sue for damages for such breach, and the party breaching this contract shall be responsible for the payment of legal fees and costs incurred by the other in enforcing their rights under this agreement or for seeking such other remedies or relief as may be available to him or her, l4 , VOLUNTARY AGREEMENT The provisions of this agreement are fully understood by both parties and each party acknowledges that the agreement is fair and equitable, that it is being entered into voluntarily, and that it is not the result of any duress or undue influence, l5, WAIVER OF CLAIMS AGAINST ESTATES Except as herein otherwise provided, each party may dispose of his or her property in any way, and each party hereby waives and relinquishes any and all rights he or she may now have or hereafter acquire under the present or future laws of any jurisdiction to share in the property or the estate of the other as a result of the marital relationship, including without limitation, dower, curtesy, statutory allowance, widows allowance, right to take in intestacy, right to take against the will of the other and the right to act as administrator or executor of the other's estate, l6, BINDING AFFECT This agreement shall be binding upon the parties' heirs, successors and assigns, 4 17, MODIFICATION AND WAIVER Any modification or waiver of any of the provlslons of this agreement shall be effective only if made in writing and executed with the ~dme formalities as 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, 18 , PRIOR AGREEMENTS It is understood and agreed that any and all prior agreements which may have been made or executed or verbally discussed prior to the date and time of this agreement are null and void and of no affect, 1 9 . ENTIRE AGREEMENT This agreement contains the entire understanding of the parties and there are no representations, warranties, covenants or undertakings other than those expressly set forth herein, 20. DESCRIPTIVE HEADINGS The descriptive headings used herein are for convenience only, They shall not have any binding affect whatsoever in determining the rights or obligations of the parties, 21 , APPLICABLE LAW This agreement shall be construed under the laws of the Commonwealth of Pennsylvania, IN WITNESS WHEREOF, the parties set their hands and seals L~/f4d ~ness :L-~-9<{ Date ~4-.?2>. ~ Witness (2(9178- Date ~u-l..k June L, Hunt 5 Commonwealth of Pennsylvania: ,~ ss County of Cumberland PERSONALLY APPEARED BEFORE ME, this J-iy of this ~~'7" 1998, a notary public, in and for the Commonwealth of Pennsylvania, Jeffrey C, Hunt, known to me (or satisfactorily proven to be) the person whose name is subscribed to the wi thin agreement and acknowledged that he executed the same for the purposes herein contained, I;:' '" , IN WITNESS WHEREOF, I have hereunto set my hand and official seal. NOTARIAL SEAL ATTORNEY JAMES M. BACH, Nolary Public Cumberland County MyCommlS6lOnExpirllSMay13,l999 ~~~?/l ~ NO~ Public Commonwealth of Pennsylvania: County of tUY't'\ber\ Cll"Id ss " PERSONALLY APPEARED BEFORE ME, this q~ay of thiS~~ , 1998, a notary public, in and for the Commonwealth of Pennsylvania, June L, Hunt, known to me (or satisfactorily proven to be) the person whose name is subscribed to the within agreement and acknowledged that she executed the same for the purposes herein contained, -I ~> \~ ,;..,. '-1: :(; .c' ,.,'~ t' ,:;:, ;1 } 1R~~ Y1J, kJJ Notary Public Notarial Seal Leola M, Gould, Notary publlo Shlramanstown Bora. cumberl~nd county My Commission Expires April B, 2000 em nr, ennsylvanla AssociatIon of NotarIes 6 ~ C'I. ;~. tr: -( .. ,', 0' lJJ\ C. - '. ~ !....: Cj;- c,: I I.'-il f~~1 r I.. -,- LI... e:-, .-' (.J u. U ,- CD - ,.c. If'. . -'. > O"~ L'. ~ , ; " ( h.~ ....c. ~:. , ' .'~' C':;', I , ( '. , c: , C>..: , .. , 1.'_ G' 0 0 ,,-' ~ JUNE LIANNE HUNT, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v, NO. 98 -l,'~// r' CIVIL TERM JEFFREY CHARLES HUNT, DEFENDANT 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 ground for is indignities or irretrievable breakdown of the marriage, you may request marriage counseling, A list of marriage counselors is available in the Court Administrator's Office, Fourth floor, Cumberland County Courthouse, Hanover and High Streets, 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 THIS 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, Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA l7013 (717) 249-3l66 l-BOC-990-9l08 '.\1; JUNE LIANNE HUNT, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v, NO, 98 -~,.;crl CIVIL TERM JEFFREY CHARLES HUNT, DEFENDANT IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE IN DIVORCE 1, The Plaintiff is June Lianne Hunt who currently resides at l26 Hill Lane, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2, The Defendant is Jeffrey Charles Hunt who resides at 349 Sporting Hill Road, Mechanicsburg, Cumberland County, Pennsylvania 17055, 3, The Plaintiff and 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. The Plaintiff and Defendant were married on July 9, 1990 in Cumberland County, Pennsylvania, 5, There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. 6, The marriage is irretrievably broken, 7, The Defendant is not a member of the Armed Services of the United States or any of its Allies, .~ JUNE LIANNE HUNT, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 98 - 6559 CIVIL TERM JEFFREY CHARLES HUNT, DEFENDANT IN DIVORCE AFFIDAVIT OF SERVICE I, Thomas D, Gould, attorney for Plaintiff, in the above captioned action for divorce, hereby certify that a conformed and certified copy of the Complaint in Divorce was served upon the Defendant by depositing the same in the United States mail, certified, restricted delivery, on November 19, 1998 pursuant to I , Rule 1920,4 of the Amendments to the Pennsylvania Rules of Civil Procedure relating to the Divorce Code, As indicated by the postal return receipt attached hereto, the Complaint was received by the Defendant on November 20, 1998, ;l ~_o,~ Thomas D, Gould ID # 36508 Attorney At Law 2 East Main Street Shiremanstown, PA 1701l (717) 73l-l46l I:' ! ~; . , I I <;; SENDER: :!:! . Complete ilems I and/or 2 lor mJdll'oMI sn'V,c/)s, I en . CornplOlO items 3, 411, and 4b. II) . Prllll VOUI name and address on Tho reVl$rSf:! of ThiS lorm so lhal wo can IlIlum lhis !! Cllfdloyou. I ~ . Allach nus lorm 10 the Irani ollho mallpieCe, or Orllht! back " SPilOO does nOI lI) permit. I .. . W,lle oRflIurn Receipt Rt/ques/ed" onlhe rTlwlplcce b~'ow Itte nrllclf. number ~ . TIlt! Rolum AccOlplwiH show to whom tho milch- '>'Ias delivOfod imrJ tho dill& - delivered j S 3. Article Addressed 10: / ~ --:JeNrey' {! he< t Ie.:; lime 1 ~ :3<-/9 S'jJN f/{1(( d II;?",,,'; I 0 , J?/1 j u IrJechtlnlCSbtl':,J ~/7 /7&sS- I also wish to receive the following services (for an eXmtRI&tEq 2'Jinrfcftl~ Jl Cons~~w.~a.l Q. 0; u ~ a: . ~ ;; a: 0> . '. . , .s . o '" '" . . .t: ... 4a. Article Number Z. 075 08.5 4// 4b. Service Type o Roglslered o Express Mail Receipt for Merchandise ji:l Certified o Insured o COO ,Oal?(6~ ~{r 5. Received By: (Print Name) 8. Addressee's Address (Only if requested and toe is paid) ~ 6'~lurr: orAr'9 tV/! /fJ o ~X ~_ 1--_ ;; PS Form 381 , ecembor 1994 1025%'98"B~'" Domestic Return Receipt (-. ..D ,"") "..') , 1 "'1: , .. ,. 'I:"D :J 11"1 <J ", ::;~~ .~, ).-. .C) '.0 jrn ':1 . :.r1 - . ::-':1 -, m ~ JUNE LIANNE HUNT, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v, NO, 98 - 6559 CIVIL TERM JEFFREY CHARLES HUNT, DEFENDANT IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 330l (c) of the Divorce Code was filed on November 19, 1998, 2, The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing and service of the Complaint. 3, I consent to the entry of a Final Decree of Divorce after service of notice of intention to request entry of the decree, I acknowledge that pursuant to Rule 1920, 42 (e) I have waived the requirement that I receive notice of intention to request entry of the decree, 4, 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, I verify that the statements made in this Affidavit are true and correct, I understand that false statements herein are subject to the penalties of 18 Pa, C.S. Section 4904 relating to unsworn falsification to authorities, DATED: d 1:;1.'f /q'1 I I ',.Q... l Lianne Hunt lCe v ~ 0' r L..C .'- , l-~. a.. r"' t ! J.~ . n' "'~ ( ~ ;- : '- " (~)r ':-.1 I l.~ . " ~l C. '-'- - ,. ;. 1 ~ ~ ..:') , ~..) '..-' C) , t .. r >c 0' (. to, cr. ..;, , 1-.: ... " I.'.J ~ C.J' .- .( . ~:'". - .. '~:t f]: I b:! c :t..: I'.. en (J e.- Ll'! JUNE LIANNE HUNT, PLAINTIFF IN THE COURT OF COMMON pLEAS CUMBERLAND COUNTY, PENNSYLVANIA v, NO, 98 - 6559 CIVIL TERM JEFFREY CHARLES HUNT, DEFENDANT IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on November 19, 1998, 2, The marriage of plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing and service of the Complaint, 3, I consent to the entry of a Final Decree of Divorce after service of notice of intention to request entry of the decree, I acknowledge that pursuant to Rule 1920,42(e) I have waived the requirement that I receive notice of intention to request entry of the decree, 4, 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, I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa, C,S, section 4904 relating to unsworn falsification to authorities. DATED: e7p~jqq / ' '- o. c.~ U., ," J:> ,-. U", !.'.l.c', ( )". ! ~.- I 1-<-.... . , S)f: .. (:;~ , =.. I Li: C~ ,; ."-' 1,1 ,::', (;) c' L) JUNE LIANNE HUNT, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v, NO, 98 - 6559 CIVIL TERM JEFFREY CHARLES HUNT, DEFENDANT IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301/01 OF THE DIVORCE CODE 1, I consent to the entry of a final decree 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 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 stat.ements herein are subject to the penalties of lB Pa, C,S, Section 4904 relating to unsworn falsification to authorities. DATED: ~/.:2--Y /11 I I --- ,- w c:r: lr. t::': (-: <p u 1_ <- )- --.:..( L.l-';:' '1_... ';);:.. Co); , I U_ =--"l! C- LI__" I. .-- lL Gl U c', '.J