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HomeMy WebLinkAbout98-06642 ~ .... I~ llt' ~ .t ~ \it , " ~I I - . .. .':) ... ~ ril ';j..i ~I ~ ~ J ~l '1 ~ I . -****.~.~*,~~.~..~'~':~,~~~.:~-'~.~~ , .:.:. .;.:. .:.:. -:.:. .:.:. .:!~. .:.:. .:.:. .;.:. '\4 q ...~ l~ /"- ~~ }" I~ i~ /',- i. .~ 8 ~ -_8....."O--.~"....,.~ ...-,-..",.._,', ~ , (1,( ~I '.'( .' ~) '.') . ' W( '.'( ~~ .." .) ~l :1 v/ 8 IN THE COURT OF COMMON PLEAS COUNTY OF CUMBERLAND ~. ;>~~~ ~\.. ~~'~r1 PENNA. STATE OF 8 LAURIE A. EPPLEY, ~ PlaintIff :'\ (). 98 - 6642 CIVIL TERI1(} ~. \", r.~ \1" ~ RONALD E. EPPLEY, JR., ~ Defendant ~ .' ~ I~ DEe R EEl N -I+- 1"(07 f) 1/1 D I va R ~~ax:/ f/y \ I: ('8.. " 19......, it is ordered ond 1* Lauric A. Eppley laintiff decreed that ......... ........................................ p , and........... .R~~ald .E~ .~ppley~ .Jr:........................, defendant, ~ ~ ~ ~ ..; ~ ~ ~.' AND NOW, . . . . . ~ ~ S ~ are divorced from the bonds of matrimony. The court retains jurisdiction of the following claims which hove been raised of record in this action for which a final order has not yet been entered; None ~ ~ ~ ~ '.' ;'. ~ ~ .'~ The attached Property Settlement Agreement is hereby incorporated, . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , . . . . . . . . , . . . . , . . . . . . , . . . . . . . . . , ~~~.~9~.~~,g~~,.;~t9.~~~~.~~9r~~.~~.~iY9rc~,.............................. . Prothonotary ,', ~ ~ p. i. ~ ~ ;;. ~I ~ :::..:. .4t;., .:.:. .:+:. .:.... .;.:. -:.:- .:+:. ~ I: '.~.:. '.:+::'-::.:-: ~;:~:: '{~::'.::;:~ --~~:.' .:+:: --::t-::~':.; ,- -:~~ ~ ',' ~ '.' $ ~ ~ ~ .. ~ s ~ ~ I.. ~ ~ ~ ~.' ~ ~ ~ ~ ~ s \~ IS ~ ~ !~ ;':' I~ I~ ~ PROPERTY SETTLEMENT AGREEMENT THIS AGREEMENT, made this .f/~kfi.dayor 'jj €Tf ,1999, by and betwcen RONALD E. EPPLEY,lR., hercinafter callcd "Husband " and LAURIE A. EPPLEY, hereinafter called "Wife". WITNESSETH: WHEREAS, Husband and Wife wcrc legally married on July 14, 1990; WHEREAS, differences havc arisen between Husband and Wife in consequence of which they desire to live separate and apart from each other; and WHEREAS, Husband and Wife desire to settle and determine their rights and obligations. NOW THEREFORE, in considemtion of the premises and covenants contained herein. it is agreed by and between the parties hereto that: 1. SEPARATION. It shall be lawful for each party at all times hereafter to live separate and apart from each other at such place as he or she from time to time shall choose or deem lit. The foregoing provision shall not be taken as an admission on the part of either party of the lawfulncss or unlawfulness of the causes leading to their living apart. 2. INTERFERENCES. Each party shall be free from interference, authority and control by the other, as fully as ifhe or she were single and unmarried, except as may be necessary to carry out the provisions of this Agreement. Neither party shall molest or attempt to endeavor to molest the other, or in any way harass or malign the other, nor in any other way interfere with the peaceful existence, separate and apart from the other. .... 4. DIVISION OF PERf.ONAI. PROPERTY, Thc parties havc dividcd bctween lhcm to thcir mutual satisfaction, personal effects, household goods and furnishings and all other articlcs of personal propcrty which have hcretofore becn used in common by thcm, and neither party will make any claim to any such itcms which arc now in thc possession or under the control oflhc other. Should it become necessary, cach party agrces 10 sign any titlc or documcnts necessary to givc cffcct to this paragraph, upon rcqucst. S. PENSIONSIRETlREMENT. Each party shall retain as their sole and separate property, any pcnsion and/or retiremcnt vehicle in thcir individual name. 6, MOTOR VEHICI.ES, Husband shall retain as his solc and sepamtc propcrty, thc 199 I Chcvy Pick Up titled in his namc individually. Wife shall rctain as her sole and scparate propcrty, the 1995 Isuzu Rodco titled in hcr name individually. 7, TAX ON PROPERTY DM~J!lli. Husband hcrcby agrecs to pay all income taxcs asscssed against him, if any, as a rcsult of the division ofthc property ofthc parties hercundcr. Wife hcrcby agrees to pay all income taxes assessed against her, ifany, as a result oflhe division of the property of the parties hereunder. 8. ASSUMPTION OF DEBTS. Husband agrees to pay the Members l~ Visa, account no. 4121-4499-9856-5654, with an approximate balance of $1,195.94 and further agrees to indemnify and hold Wife harmless on said debt. Wife agrees to pay the Crestar Bank loan, account no. 05200000001145085, with an approximate balance of$5,264.64 and further agrees to indemnify and hold Husband harmless on said debt. All other debts incurred by the parties shall be their individual responsibility. 9, BREACH. If either party breaches any provision oflhis Agreement, the other party shall have the right, 2 at his or her election. to sue for damages for such breach. The party breaching this contract shall be responsible for the payment of legal fees and costs incurred by the other in enforcing his or her rigbts under this Agreement, or seeking such other remedy or relief as may be available to him or her. 10, FULL DISCLOSURE. Husband and Wife each represent and warrant to the other that he or she has made a full and complete disclosure to the other of all assets of any nature whatsoever in which such party of every type whatsoever and all other facts relating to the subject matter of this Agreement. 11. ADDITIONAL INSTRUMENT. Each of the parties shall on demand execute and deliver to the other any deeds, bills of sale, assignment, consents to change of beneficiary on insurance policies, tax returns and other documents and do or caused to be done any other act or thing that may be necessary or desirable to the provisions and purposes of this Agreement. If either party fails on demand to comply with this provision, that party shall pay to the other all attorneys' fees, costs and other expenses reasonable incurred as a result of such failure. 12, WIFE'S DEBTS. Wife represents and warrants to Husband that since the parties' separation she has not and in the future she will not contract or incur any debt or liability for which Husband or his estate might be responsible and shall indemnify and save Husband harmless from any and all claims or demands made against him by reason of debts or obligations incurred by her. 13. HUSBAND'S DEBTS. Husband represents and warrants to Wife that since the parties' separation he has not and in the future he will not contract or incur any debt or liability for which Wife or her estate might be responsible and shall indemnify and save Wife harmless from any and all claims or demands made against her by reason of debts or obligations incurred by him. 3 .. \" ) "\ , .. 14. WAIVERS OFCI.AIMS AGAINST ESTATES, Except as herein otberwise 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, curtsy, statutory allowance, widow's allowance, right to take in intcstacy, right to take against the Will of the other, and right to act as administrator or cxecutor of the other's estate, and cach will, to the request of the other. execute, acknowledge, and deliver any and ail instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interests, rights and claims. 15. REPRESENTATION. It is recognized by the parties hereto that Laurie A. Eppley is represented by John J. Connelly, Jr., Esquire, and Ronald E. Eppley, Jr., is represcnted by Rob A. Krug, Esquire. It is fully understood and agreed that by the signing of this Agreement, each party understands the legal impact of this Agreement and further acknowledges that the Agreement is fair and reasonable and each party intends to be legally bound by the terms hereof. 16. VOLUNTARY EXECUTION. The provisions of this Agrecment are fully undcrstood by both parties and each party acknowledges that this Agreement is fair and cquitable, that it is being entered into voluntarily and that it is not the result of any duress or undue influence. 17. 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. 18, PRIOR AGREEMENT. It is understood and agreed that any and all property settlement agreements which mayor have been executed prior to the date and time of this Agreement are null and void and of no effect. 4 19. MODIFICATION AND WMVER. Any modification or waiver of any provision of this Agreement shall be effective only if made in writing and executed with the same fonnality as this Agreement. The failure of either party to insist upon strict perfonnance 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. 20, GOVERNING I.A W. This Agreement shall be governed by and shall be construed in accordance with the laws of the Commonwealth of Pennsylvania. 21. INDEPENDENT SEPARATE COVENANTS. It is specifically understood and agreed by and between the parties bereto that each paragraph hereof shall be deemed to be a separate and independent covenant and agreement. 22. VOID CLAUSES. If any term, condition, clause, or provision of this Agreement shall be determined or declared to be void or invalid in law or otherwise, then only that tenn, condition, clause or provision shall be stricken from this Agreement and in all other respects this Agreement shall be valid and continue in full force, effect and operation. 23. ENTRY AS PART OF DECREE. It is the intention of the parties that this Agreement shall survive any action for divorce which may be instituted or prosecuted by either party and no order, judgement or decree of divoree, temporary, final or pennanent, shall affect or modifY the financial tenns of this Agreement. This Agreement shall be made a part of, but shall not merge with, any such judgment or decree of final divorce. 24. DIVORCE ACTION. The parties shall, at the time of the execution of the Agreement, execute documents 5 necessary to finalize the divorce action including, but nOllimited 10, th.: withdrJwal of any claims pending under said action, indexed to number 98-6642, in the Coun of Common Pleas, Cumberland County, Pennsylvania, as well as Affidavits of Consent and Waivers of Counseling and Waivers of Notice of Intention to Request Entry ofa Divorce Decree. 25. DOMESTIC RELATIONS CODE OFTH!': COMMONWEALTH OF PENNSYLVANIA. Except as specifically provided in this Agreement. each pany waives any claim they may have against the other under the Domestic Relalions Code of the Commonwealth of Pennsylvania including, but not limited to, alimony, alimony pendente lite, counsel fees, costs and equitable distribution of marital property. IN WITNESS WHEREOF, the parties hereto, intending to be legally bound hereby, have hereunto set their hands and seals the day and year first above written. . I ~lUtJ_ (l fnlt~ Laune A. Eppley ;2~1 (: (~~.. Ronald E. Eppley, Jr. I -' ~ , " r;i'!,,,"" i1~ ;'1:; ~~ I'':'' , . '~"' 6 ......:;, . I.:~ >'.'.; ,~.:. .~+} .~f'}' 1t ',~ l~ I I~ I.' I. l~ I~ ".' I.;, II< I.:. l~ I~ t~ l~ !'" I~ i~ I~ i~ l~ I~ Ii; (~ ( . !~ ('.' ~~ I... ,~ i'o' I~ 1':' .~ li~ ~.' ~ i~ '.' ~~~~*.~*~~~.~~,~:.:~:~:~. :.: :.;. :.:- ,. :..: .:.;, <.:. <.;. .:.~. .~:. ~ I ,--,---.,.,~ ... 0",. ~) -.'( ~; ~; "'1 ~' . " ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY ~i "'1 ~: ':'i ~, '.'1 ~I " ~l ~i "1 ~. : I ~I .~ ~~~'.. , ~'A~~'~' -\ ...."'...~,;...,..' STATE OF PENNA. LAURIE A, EPPLI,Y. Plaintrr[ :\ t I. 9H - 6M2 CIVIl. TEM \'1'1",11, RONALD E, EPPLEY. JR.. ~ D~(endant ~ ~ ~ '.'/ ~I ':'I ~. DECREE IN DIVORCE ~ .', ~ AND NOW, . . . 19. " it is ordered and Laurie A. Eppley decreed thot .... and.. . " plaintiff, defendant, ~ Ronald E. Eppley, Jr. ~ s are divorced from the bonds of matrimony, s ~ ~.' The court retains jurisdiction of the following claims which have been raised of record in this action for which a final order hos not yet been entered; None $ ~ ~.' s . . . . . .~~~ .~~~~~~~~ .~~~~~~~~ .~~~~~~~e~~ . t~~~~:~H~I~~. ~s i~e:e~~. ~~~'?~I?'?:~~~~~. . , b.~~ .~~~ .~~~&~~ '. . ~~t~ . ~~~~ .~~'7~r:'7C; . ~ry. ~~vorce. ~ ~ ~ ~ ..' en 11 I' t : ~ I'" I~ I~ ;", I~ I'" i~ iV I~ I':' J~ ,~&:. .:+;. -:+:. .:+:. .:.:. -:+:. '.:+:.' ny The ~ '.' Attest: ~ ~.~ $ ~ ~ ~ ~ ~...;-:;.;{~:;.-:~-~:;;:-::;;<;;-: .:;;;-~i:.--~.:. '::+:: ~:+;.':~.::-.::.:- Prothonotary .:.:- -:+:. -:+:. .:+:. -:+;. .:+;. .:+;. -:+;. -:+:. ~ '.' ~ ',' ~ '.' ~ I~ I':' ~ ~ J. PROPERTY SEITI.EMENT AGREEMENT THIS AGREEMENT, made this Jf:?k d day of ~l tlf! ' 1999, by and between RONALD E. EPPLEY, JR., hereinafter called "Husband', and LAURIE A. EPPLEY, hereinafter called "Wife". WITNESSETH: WHEREAS, Husband and Wife were legally married on July 14, 1990; WHEREAS, differences have arisen between Husband and Wife in consequence of which they desire to live separate and apart from each other; and WHEREAS, Husband and Wife desire to settle and detennine their rights and obligations. NOW THEREFORE, in consideration of the premises and covenants contained herein, it is agreed by and between the parries hereto that: 1. SEPARATION. It shall be lawful for each party at all times hereafter to live separate and apart from each other at such place as he or she from time to time shall choose or deem fit. The foregoing provision shall not be taken as an admission on the part of either party of the lawfulness or unlawfulness of the causes leading to their living apart. 2. INTERFRRENCF:S. Each party shall be free from interference, authority and control by the other, as fully as ifhe or she were single and unmarried, except as may be necessary to cany out the provisions of this Agreement. Neither party shall molest or attempt to endeavor to molest the other, or in any way harass or malign the other, nor in any other way interfere with the peaceful existence, separate and apart from the other. .... 4. DIVISION OF PERSONAl. PROPERTY. The parties have dividcd betwecn them to their mutual satisfaction, personal effects, houschold goods and furnishings and all othcr articlcs of personal property which have heretofore been used in common by them, and neither party will make any claim to any sucb items which are now in the possession or under the control of the other. Should it become necessary, each party agrees to sign any title or documents necessary to give effect to this paragmph, upon request. 5, PENSIONSIRETlREMENT. Each party shall retain as their sole and separate property, any pension and/or retirement vehicle in their individual name. 6. MOTOR VEHICLES. Husband shall retain as his sole and separate property, the 1991 Chevy Pick Up titled in his name individually. Wife shall retain as her sole and separate property, the 19951suzu Rodeo titled in her name individually. 7. TAX ON PROPERTY DIVISION. Husband hereby agrees to pay all income taxes assessed against him, if any, as a result of the division of the property of the parties hereunder. Wife hereby agrees to pay all income taxes assessed against her, if any, as a result of the division of the properly of the parties hereunder. 8. ASSUMYrION OF DEBTS. Husband agrees to pay the Members 1 st Visa, account no. 4121-4499-9856-5654, with an approximate balance of $ I ,195.94 and further agrees to indemnifY and hold Wife harmless on said debt. Wife agrees to pay the Crestar Bank loan, account no. 05200000001145085, with an approximate balance of $5,264.64 and further agrees to indemnifY and hold Husband harmless on said debt. All other debts incurred by the parties shall be their individual responsibility. 9. BREACH. If either party breaches any provision of this Agreement, the other party shall have the right, 2 at his or her clcction, to sue for d:unugcs for such brcach. The pany breaching this contract shall be responsible for the paymcnt of Icgal fees and costs incurred by the other in enforcing his or her rights undcr this Agrccment, or seeking such other remedy or relief as may be available to him or her. 10, FUI.1. DISCLOSURE. Husband and Wifc cach represent and warrant to the other that he or she has made a full and complete disclosure to the othcr of all assets of any nature whatsocver in which such party of every type whatsocvcr and all othcr facts relating to the subject matter of this Agreement. I L ADDITIONAL INSTRUMENT. Each of thc panies shall on demand execute and deliver to the other any deeds. bills of sale, assignment, consents to change of beneficiary on insurance policies, taX returns and other documcnts and do or caused to be done any other act or thing that may be necessary or desirable to thc provisions and purposes of this Agreement If either party fails on demand to comply with this provision. that party shall pay to the other all artomeys' fees, costs and other expenses reasonable incurrcd as a result of such failure. 12. WIFE'S DF:BTS. Wife represents and warrants to Husband that since the parties' separation she has not and in the future she will not contract or incur any debt or liability for which Husband or his estate might bc responsiblc and shall indemnify and save Husband harmless from any and all claims or demands made against him by reason of debts or obligations incurred by her. 13. HUSBAND'S DEBTS. Husband represents and warrants to Wife that since the parties' separation he has not and in the futurc he will not contract or incur any debt or liability for which Wife or her estate might be responsible and shall indemnify and save Wife harmless from any and all claims or demands made against her by rcason of dcbts or obligations incurred by him. 3 14. W AIVRRS OF CLAIMS AGAINST EST A TES. Except as herein otherwise provided, each party may disposc of his or hcr propcrty in any way, and each party hereby waives and relinquishes any and all rights hc 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 ofthc other as a rcsult of the marital relationship, including without limitation, dower, curtsy, statutory allowance, widow's allowance, right to take in intestacy, right to take against the Will of the other, and right to act as administrator or cxecutor of the other's estate, and cach will, to the request of the other, execute, acknowledge, and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interests, rights and claims. 15, REPRESENTATION, It is recognized by the parties hereto that Laurie A. Eppley is represented by John J. Connelly, Jr., Esquire, and Ronald E. Eppley, Jr., is represented by Rob A. Krug, Esquire. It is fully understood and agreed that by the signing of this Agreement, each party understands the legal impact of this Agreement and further acknowledges that the Agreement is fair and reasonable and each party intends to be legally bound by the terms hereof. 16. VOLUNTARY EXECUTION. The provisions of this Agreement are fully understood by both parties and each party acknowledges that this 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. 17. 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. 18. PRIOR AGREEMENT. It is understood and agreed that any and all property settlement agreements which mayor have been executed prior to the date and time of this Agreement are null and void and of no effect. 4 t9. MODIFICATION AND WAIVER. Any modification orwaivcr of any provision of this Agrecment shall be effective only if made in writing and executed with the same formality as this Agreement. The failure of either party to insist upon strict pcrformance of any of thc provisions of this Agreement shall not be construed as a waivcr of any subsequent default of the same or similar nature. 20. GOVERNING LAW. This Agreement shall be governed by and shall be construed in accordance with the laws of the Commonwealth of Pennsylvania. 21. INDEPENDENT SEPARATE COVENANTS, It is specifically understood and agreed by and berween the panies hereto that each paragraph hereof shall be deemed to be a sepamte and independent covenant and agreement. 22, VOID CLAUSES. If any term, condition, clause, or provision of this Agreement shall be determined or declared to be void or invalid in law or otherwise, then only that term, condition, clause or provision shaH be stricken from this Agreement and in all other respects this Agreement shall be valid and continue in full force, effect and operation. 23. ENTRY AS PART OF DECREE. It is the intention of the parties that this Agreement shall survive any action for divorce which may be instituted or prosecuted by either party and no order, judgement or decree of divorce, temporary, final or permanent, shall affect or modify the financial tenns of this Agreement. This Agreement shall be made a part of, but shall not merge with, any such judgment or decree of final divorce. 24, DIVORCE ACTION, The parties shall, at the time of the execution of the Agreement, execute documents 5 necessary to finalize the divorcc action including. but not limited to. thc withdrawal of any claims pending under said action, indcxcd to numbcr 98-6642, in thc Coun of Common Pleas, Cumberland County, Pennsylvania. as well as Affidavits of Consent and Waivers of Counseling and Waivers of Notice of Intention to Request Entry ofa Divorce Decree. 25. DOMESTIC RELATIONS CODE OFTHE COMMONWEALTH OF PENNSYLVANIA. Except as specifieally provided in this Agrcement, each party waives any claim they may have against the other under the Domestic Relations Code of the Commonwealth of Pennsylvania including, but not limited to, alimony, alimony pcndente lite, counsel fees, costs and equitable distribution of marital property. IN WITNESS WHEREOF, thc parties hereto, intending to be legally bound hereby, have hereunto set their hands and seals the day and year first above written. ~2uvi (7 f:;zptl~ Laune A. Eppley . g:;1~eY~. (~; L 6 COMMONWEALTH OF PENNSYL VANIA COUNTY OF /ILu;JILi..'}v : ss. On this, the A1luidayof :Ju~ . 1999, before me, a Notary Public, personally appeared Laurie A. Eppley. ~own Va me to be the person whose name is subscribed to the within Property Settlement Agreement and acknowledged that she execuled the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. '~~0"~;JG / NOTARYPUB IC COMMONWEALTH OF PENNSYL VANIA ':07"AAIAL <='L 1":/'" "''''_._ wL.J'\ ,...,~.-" ..,....~'c:R.No'u"P.bf - . ;1 ':,:".:-:;,;tn" __.: iJ Ie .~:. _ c' :.,., ~:;.~_:L::...n COunt'1 --- . -.....,. .0'1.29. 1S:;:'; : ss. COUNTY OF ~01k. On this, the ~ day of C', ~c.G.v . 1999, before me, a Notary Public. <,I' II personally appeared Ronald E. Eppley, Jr., known to'me to be the person whose name is subscribed to the within Property Settlement Agreement and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. I I '. '1 I' J;., ~: /.-' \ (j If. " /, ).rl:' -- ..l j........... 100 '" __ NOTARY PUBLIC NOTARIAL SEAl ,,'eXll BODE. NOTARY PUBLIC DOVER BDRD YORK COUNTY .~v ~0'."}ISS'ON EXPIRES OCT 23, t999 TO YOU ..... HI".." "011.'10 10 ~l''''D fO 'MI.NCLO.,O W11HfN , TWrN"" ,lOt DAn Of' 'f"V!(:f "f"t~ ('t" .. DIU"'u,,' JUDGMINf M,U .. lIll11.."0 AQAINI' YOU LAw OfI'lCF. JAMES. SMITH, DURKIN & CONNELLY. LLP WI ,"I.'.'" cr."n THA' '"I WI'"IN'I I. ,aut "'NO ~O~.ICT C~Y D. 'HI .0.101""'" "'10 IN 'H'. Ac;T1Ol'f ""~. I), () nux b.~) HERSIIEY. I'HNNSYI.VANIA 11O}).Ut'l~O ."OOPtCf ., -.'-_.',...,--- .. " ~.;:.~ ;j"-" ..t\'W",,,,,,~---,"- LAURIE A. EPPLEY, l'laintiff : IN TilE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v, NO. 98 6642 CIVIL TERM RONALD E, EPPLEY, JR" Defendant CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO TRANSMIT RECORI> To the Prothonotary: Tr'dI1smit the record, togethcr with the following information, to thc Court for entry of a Divorce Dccrce: I. Ground for divorce: irretricvablc breakdown undcr Scction (XX) 3301(c) ( ) 3301(d) of the Divorce Codc. 2. Date and manncr of service of thc Complaint: Dcccmbcr 18, 1998 by the Sheriffs Office. Complete either paragraph (a) or (b). (a) Date of execution of thc Affidavit of Consent and Waiver of Counseling required by Section 3301(c) of the Divorce Codc: by Plaintiff: July 30,1999; by Defendant: July 13, 1999 (b) (I) Date of execution of the Plaintiffs Affidavit rcquired by Scction 3301(d) of the Divorce Code: (2) Date of service of the Plaintiff's Affidavit upon the Defendant: 4. Related claims pending: All claims of record havc bcen resolved and settled pursuant to a Property Settlement Agreement dated July 23, 1999. , 5. Dale and manner ofscrvice ofthc noticc of in ten lion to filc Praccipe to Transmit Rccord, a copy of which is attachcd, if lhc dccrce is to be entercd undcr Section 330I(d) ofthc Divorce Code: 6. Datc and manncr ofservicc ofNoticc oflntcntion to filc Praccipe 10 Transmit Rccord, a copy of which is attachcd, if thc dccrcc is to bc cntcred undcr Scction 3301(c) of the Divorce Codc: or, date of cxccution of Waiver of Notice of Intcntion to Rcqucst Entry of a Divorce Dccree undcr Scction 3301(c} of thc Divorce Codc: by Plaintiff: July 30, 1999; by Dcfendant: July 13, 1999. and, date of filing of thc Waivcr of Notice of Intcntion to Requcst Entry of a Divorce Decree: Both tbe Plaintiffs and Defendant's Waivcrs wcrc filcd on August 9, 1999. JAMES, SMITH, DURKIN & CO .LL Y Date: 1- f;O -q 9 , , 'I ~j :i" I',';:::, ,\1.:,' r{-:I' J,~l i , I , , i , ,i : j : 1 .\~~ ,i ," .~, ;y.",:.~l'~ I. Laurie A. Eppley, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. qp-/.,/..,t"I.z CUll ~)>} Ronald E. Eppley, Jr.,: CIVIL ACTION - LAW Defendant : IN DIVORCE NOTICE 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 Plaintiff. You may lose money, property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of Prothonotary at the Cumberland County Court House, One Courthouse Square, 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Phone: (717) 249-3166 Jaj)Ii~a~ Plaintiff (Pro Se) Laurie A. Eppley, Plaintiff vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 9P - 1ct...L(;).. C'u;{ , 1'i'V') Ronald E. Eppley, Jr.,: CIVIL ACTION - LAW Defendant IN DIVORCE COMPLAINT UNDER SECTION 3301 OF THE DIVORCE CODE 1. Plaintiff is Laurie A. Eppley, social security number 193-60-8086, who currently resides at 511 Reno Street, New Cumberland, PA 17070, Cumberland County. 2. Defendant is Ronald E. Eppley, Jr., social security number 197-58-6529, who currently resides at 120 Ramblewood Drive, Apartment 7, Etters, PA 17319, York County. 3. Plaintiff and Defendant have been a bona fide residents in the Commonwealth .\ , or at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on July 14, 1990. 5. There have been no prior actions for divorce or annulment between the parties. 6. The Plaintiff is a citizen of the United States of America. 7. The Defendant is not a member of the Armed Services of the United States of America or its Allies. 8. The marriage is irretrievably broken. 9. The Plaintiff has been advised of the availability of counseling and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling. 10. The parties to this action have been separated since October 26, 1997. 11. Plaintiff requests the Court to enter a Decree in Divorce. COUNT" CLAIM FOR EQUITABLE DISTRIBUTION OF MARITAL PROPERTY UNDER SECTION 3502 OF THE DIVORCE CODE 12. Plaintiff and Dependant are the owners of various personal property, motor vehicles, bank accounts and insurance policies acquired during their marriage which are subject to equitable distribution by this Court. WHEREFORE, the Plaintiff requests the Court to enter a Decree: a. dissolving the marriage between the Plaintiff and Defendant; b. equitably distributing all property owned by the parties hereto; and c. for such further relief as the Court may determine equitable and just. Date: 11- 30 '?/ g r!4~- () ~ Plaintiff (Pro Se) ~1 By: I"" !<':. ~..~ r I.: /. ~ ~'~'; ;:;:~' .~ , , I , -, " ~ .......... ~. - p ~ --J ,~ ~ .......... 0 ., k ~ . ) .,'.~J f:k t C' L. , ,-, 0 "-' & . ;i () fr) C- o .1::) ~ ...... (' ~ J ~ ~ l t: 0 c () .. :! & I '.) :::~ f!! , ... "-J if: ~ (I} " ~ ?... 1-- "b r- D 9- . . - .:-' -.{ . ::u ""I HIIlIIV NO''''ID TO ""'AD '0 THI IHCL.OaID WltW.. . TWl:Nn 1201 D."'. O' IIU'V'(I HIIIIO' 0.. .. DI'''UU JUDOMINT NA, II IH't:1iI.0 AGAIH" "'au . I.AwOrun JAMIlS. S1.IlTll. DURKIN & CONNEI.LY.I.I.P I' n uox Mn IWMSltI;y, I'I:SNSYI.VAN'A Hill' (}h~J . \ol.l ........ c...,''. T"'" THI WITHIN.S " "UI AHD ,.cO""le, co.., 0' THI OIl'?IHAl 'U.IO IN 'HIS ACTION .. ., .-...-----.. "".,..." "'''CMiIof, LAURIE A. EPPLEY, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLANDCOUNTY, PENNSYLVANIA v. : NO, 9B - 6642 CIVIL TERM RONALD E. EPPLEY, JR., Defendant : CIVIL ACTION - LAW : IN DIVORCE PLAINTfFF'S AFFIDAVIT OF CONSENT AND WAIVER OF COUNSELING 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on November 23,1998 and served on December 18 , 1998. 2. The marriage of the Plaintiff and Defendant is irretrievably broken, and ninety days have elapsed from the date of both 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. 4. I have been advised of the availability of marriage counseling, and understand that I may request that the Court require that my spouse and I participate in counseling. I further understand that the Court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. Being so advised, I do not request that the Court require that my Spouse and I :~u A"I HUI.' HOfl1l10 TO PUAD TO THI IHeI.O'CD WI'H'" TWINTY 1:tOt DA" 0' 'CJNICIE HI"IEO' 0" . .. ol.".,.u.' J~OVMU.n MAY DE ENTE"ED AOAINST TOU I.AI\' OnlCIl lAMES. SMITH, DURKIN & CONNELLY, LLP . \.;._--,...' I" () uo:'( n.~1 ItERSIII'.Y. f'I:NN\"I,V"NI~ nUl.' tlMU . . .,,--_....'l.,~, WI HUtC.' C'ltfln 'HAT THI WITNIN ,. . ,ltur. ...0 co..eCT co'"., 011' THI OltIQIN"1. 'ILlD IN 'HI' ACTION ., AnCll'Pt<<Y LAURIE A. EPPLEY, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLANDCOUNTY, PENNSYLVANIA v. : NO. 98 - 6642 CIVIL TERM RONALD E. EPPLEY, JR., Defendant : CIVIL ACTION - LAW : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UN[!EH3L3.3QJlcH>F lJ:!ILDI"-OJl~E_C_O.QJ; 1. I consent to the entry of a final Decree of Divorce 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. understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. Date: 1-30"~? . . " . . '. -~,---~- LAURIE A. EPPLEY, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLANDCOUNTY, PENNSYLVANIA : NO. 9B - 6642 CIVIL TERM v. RONALD E. EPPLEY, JR., Defendant : CIVIL ACTION - LAW : IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT AND WAIVER OF COUNSELING 1. A Complaint in Divorce under Section 3301 (e) of the Divorce Code was filed on November 23,1998 and served on December 18 ,1998. 2. The marriage of the Plaintiff and Defendant is irretrievably broken, and ninety days have elapsed from the date of both 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. 4. I have been advised of the availability of marriage counseling, and understand that I may request that the Court require that my spouse and I participate in counseling. I further understand that the Court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. Being so advised, I do not request that the Court require that my spouse and I ~. .. . .---.~ . LAURIE A. EPPLEY, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLANDCOUNTY, PENNSYLVANIA : NO. 9B - 6642 CIVIL TERM v, RONALD E. EPPLEY, JR., Defendant : CIVIL ACTION - LAW : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UND~~ 3301l!:LOF TH~PIVORC~'-c_QQI: 1. I consent to the entry of a final Decree of Divorce 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 statements herein are made subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. Date: J "'-'1 I" I 'i$ 7 i t r~ I I .\ ~<. .",., ),.~~"..:' .... LAURIE A. EPPLEY, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 9B - 6642 CIVIL RONALD E. EPPLEY, JR., Defendant CIVIL ACTION - LAW IN DIVORCE PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of John J. Connelly, Jr., Esquire on behalf of the Plaintiff, Laurie A. Eppley, in the above-captioned action. Date: .3 -13 -99 JAMES, SMITH, DURKIN & CONNELLY BY~-' /'u (~ C(}.. Jof:1n . Connelly, r., Esquire, ~ \ pqs.t. qffice Box 56'0 ' Hd,[s.f:1ey, PAl 1703,3 (717) 533-3280.-/ i i , r t' TO YOU ..... 101....' "O.......Q '0 ~'6.t)'~ '"' IHCI,OIIO ll'f1'"IN MINty 1101 DA'. 01' "!WK' ".....or 011' A DI''''ULT JUDOM.NT N., II ...tU'O AOAIHtT YOU I.AW OH1('li . JAMES. SMITU. DURKIN & CONNELLY. LLP ~1,:~:I~~~.~~~~:~:r :;:yW:;:I~~: -- _.# .. ,0.101"'''" '1'-'0 IN '''I' AC'IOflI If (l BOX 630 -- ., ---- ., ItIJI.~IIEY. P1'NNSYIVANIA 11IlH 116.'O ..,,~. ...,,~, JAMES, SMITH, DURKIN & CONNELLY LAURIE A, EPPLEY, Plaintiff : IN TilE COUIU OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO, 98 6642 CIVIL TERM RONALD E. EPPLEY, JR., Defendant CIVIL ACTION - LAW IN I>IVORCE PRAECIPE TO WITHDRA W CLAIM TO THE PROTHONOTARY: Please withdraw the claim for Equitable Distribution in the above-captioncd divorce action. Date: 7 - ,'0() AN k ! 1 (l q 'Ii ,I TO 'f'OU ..... "11It1.' HO''''IO TO ~U"D TO '"I IHeLMIG WIT"I" l'WIHn lJOI DA,.. D. 111tV1C1 "1"10' 0.. .. De'AuLT JUDOu....,.."" .. INtlMID AOA'"'' 'tOU L- ., .....__._.-.nu:;.;i:;'--'._-- LAw Ol'fl('!! JAMES, SMITH, DURKIN & CONNELLY, LLP ~ I~ n un'" tt..~ 1IJ:lllllliY. 1'!!NNSnV^NI^ I~I.I' ,,,jCl WI HIII.a, CaItlin THA' THI WnN'''l 'I A '.UI "NO ~O..ICT ,o~, 0' THI 911101"0\" flLID IN TH'. ACflOH 81' _.___,_ "Ol_r, ---"---'_"~ _"__..__.._n..____~ LAURIE A, EPPLEY. Plaintiff : IN TilE COURT OF COMMON PU:AS : CUMBERLAND COUNTY, PENNSYLVANIA \'. : NO, 98 - 6642 CIVIL RONALD E. EPPLEY, JR., Defendant : CIVIL ACTION - LAW : IN DIVORCE NOTICE OF ELECTION TO RETAKE FORMER NAME Notice is hereby given that the Plaintiff in the above matter having been granted a Final Decree in Divorce from the bonds of matrimony on the 1:~t)Lday of {fLlfj-l.J/' ,1999, and hereby elects to retake and hereafter use her maiden name of Lauric A, Neidert and gives this written notice avowing her intention in accordance with the provisions of the Act of May 25,1939, p, L. 192, as amended, DATED: SI_:~"3 ..{jlj TO BE KNOWN AS ;L flLIJuf. (){ 11tldJ It-t La 'rie A, Neidert Sworn to and subscribed befor~ me this ,Y&li day of {1Li~ 101- ,19~'t, J 'S1i;,/ ' . 1 (1 !).../ ~l,J( tL ,:. NOTARY P LIe IKlTARIAL SEAL JE/.:! I 1:"'.'~,i::R, Nnt~:y p!Jblic CIty" ..~; O.1(;;.'~:" C"J'J:1ry My CU ..-_..~S;~~:~.~~;' ,"), lJ~19 ..... ...\. ..... <.? ,~ ~.R ?=G' ..>t ~ ~ ~ ~~N I ~ " V\ ~ .z - '- ~ ;'J"