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HomeMy WebLinkAbout00-05107 "0 ,"I,,, . ,c L \ ~ . . . . . .. "''''''' "'''';t:; '" '" ;t:; "''''''' "';Ii .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. Susan Louanne Ingram No. 00-5107 VERSUS Paul Martin Ingram DECREE IN DIVORCE o:t" f(: 33A.p1. ~ , IT IS ORDERED AND AND NOW, tJ~ ;)~ Susan Louanne Ingram , PLAINTIFF, DECREED THAT Paul Martin Ingram , DEFENDANT, AND 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; ~ By ATTEST: (l~ J 1 PROTHONOTARY .. . . . . . . . .. . - ''.; ;Ii ;Ii;+;;+; . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. , '~~'-'"' .-i ,,-'. ~~.; ., :'~-' ~ -.-" IiI1liiil. h ~ ~~ <:1-- .~ ~ ,..:"'-~.- i2li!!:tiiiJ81 . " ---"~ . ~ :2' ~ ~ eV-/7.C'! ~ ;; '? ~ ~ n oC'h-e/ t, .', ~ ,t'-',- m""_.". ,....'- _ _,.~. -p__'_ ~~" ",~,~""~'''','''''',,", ,~", ~7"O,"' ,~=~, ~ ,,~ ~ ~i Ii' ,-- . - SEPARATION AND PROPERTY SETTLEMENT AGREEMENT THIS AGREEMENT, made this .:2,01' day of <;epf"EfII/ 8E~ , 2000, by and between SuSlUl L. Ingram, hereinafter referred to as "Wife", and Paul M. Ingram, hereinafter referred to as "Husband." WITNESSTH: WHEREAS, Husband and Wife were lawfully married on November 4, 1995; and WHEREAS, certain differences have arisen between the parties as a result of which they have separated and now live separate and apart from one another, and are desirous, therefore, of entering into an Agreement which will provide for support, distribution their marital property, and will provide for their mutual responsibilities and rights growing out of the marriage relationship. NOW, THEREFORE, in consideration of the above recitals and the following covenants and- promises mutually made and mutually to be kept, the parties hereto, intending to be legally bound and to legally bind their heirs, successors and assigns thereby, covenant, promise agree as follows: 1. SEPARATION It shall be lawful for each party at all times hereafter to live separate and apart from each other at such place or places as he or she may be from time to time choose or deem fit. 2. INTEREFERENCE Each party shall be free from interference, authority and contract by the other, as fully as if he or she were single and unmarried, except as may be necessary to carry out the provisions of this Agreement. Neither party shall molest the other nor attempt to endeavor to molest the other, nor compel the other to cohabit with the other, nor in any way harass or malign -.the other, nor in any way interfere with the peaceful existence, separate and apart from the other in all respects as if he or she were single and unmarried. 3. WIFE'S DEBTS Wife represents and warrants to Husband that since their separation on June 30, 2000, she has not, and in the future she will not, contract or incur any debt or liability for which the Husband or his estate might be responsible, except as otherwise specifically provided for .in this Agreement, and Wife shall indemnify and save Husband harmless from any and all lIS! claims or demands made against him by reason of debts or obligations incurred by her except as otherwise provided for in this Agreement. 4. HUSBAND'S DEBTS Husband represents and warrants to Wife that since their separation on June 30, 2000 he has not, and in the future he will not, contract or incur any debt or liability for which the Wife or her estate might be responsible, except as otherwise specifically provided for in this Agreement, and Husband 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 except as otherwise provided for in this Agreement. 5. MUTUAL RELEASE Subject to the provisions of this Agreement, each party has released and discharged, and by this Agreement does for himself or herself, and his or her heirs, legal representatives, executors, administrators and assigns, release and discharge the other of and from all causes of actions. Claims, rights or demands whatsoever in law or equity, which either of the parties ever had or now has against the other, except in any or all causes of action for breach of any provisions of this Agreement. Subject to the provisions of this Agreement each party waives his or her right to alimony and eqnitable distribution of property notwithstanding the Pennsylvania "Divorce Code", Act No. 206 of 1990, 19 P.L. 1240. Each party also waives his/her right to request marital counseling pursuant to Section 3302 ofthe Divorce Code. 6. DISCLOSURE OF PROPERTY Husband and Wife acknowledge and agree that they have made a full and complete disclosure to the other of all information pertaining to the parties' separate and marital property owned, possessed and! or controlled by the other at the time of the separation of the parties. Further, Husband and Wife voluntarily and intelligently agree to waive any rights which they may have to revive an inventory and appraisements of all property owned or possessed by them either jointly or individually, at the time ofthe delivery of this Agreement or of the commencement of any action in divorce. 7. EOUlTABLE DISTRIBUTION OF MARITAL PROPERTY The parties have attempted to distribute their marital property in a manner which conforms to the criteria set forth in Section 3502 of the Pennsylvania Divorce Code, and taking into account the following considerations: the length of the marriage; the age, health, station, amount and sources of income vocational skills, employability, estate, liabilities and needs earning power of the other party, the opportunity of each party to the education, training or increased earning power of the other party; the opportunity of each party for future acquisitions of capital assists and income; the sources of income of both parties, including but not limited to medical, retirement, insurance or other benefits; the contribution or dissipation of each party in the acquisition, preservation, depreciation or appreciation of the marital property, including the contribution of each __spouse as a homemal>er; the value of the property set apart to each other; the standard of living of the parties established during the marriage; and the economic circumstances of each party at the time of the division of the property is to become effective. The division of the existing marital property is not intending by the parties to constitute in any way a sale or exchange of assets, and the division is being effected without the introduction of outside funds or other property not constituting marital property. The division of property under this Agreement shall be in full satisfaction of all marital rights of the parties. A. DISTRIBUTION OF REAL ESTATE The parties are joint owners of real estate situated at 11 Greenway Drive, Mechanicsburg, Pennsylvania. The parties have placed the property on the market for sale. The parties will make a good faith effort to sell the subject premises. In the event of the sale, the first twenty-five thousands of -the proceeds of the property will be transferred to Wife's counsel in value of the initial twenty-five thousand she coutributed toward down payment. The remaining proceeds will also be transferred to the Wife for the purposes of the equitable distributiou of marital property agreed upon by the parties. Additionally, in event of the sale occnrring after a divorce decree is entered, then both parties shall cooperate fully to execute a sale of the residence that is in accordance to the appraisal value. B. DISTRIBUTION OF PERSONAL PROPERTY Husband shall agree to deliver the following items of tangible personal property that is pre-marital property of Wife: dining room set, two dressers and desk! cabinet in bedroom, two end tables, dry sink, miniature tables, antique rocking chairs, antique glasses and pottery, all the Christmas -gold ornaments. Husband hereby covenants and agrees to set over, transfer and assign and by these presents does hereby set over, transfer and assign absolutely to Wife, all of his rights, title and interest in and to the Plymouth Voyager currently registered in the name of Husband. Wife hereby agrees that she shall be solely liable to make payments due on the load secured by the Van and does agree to indemnify and Husband harmless from any future liability with regard thereto. Wife hereby covenants and agrees to set over, transfer and assign and by these presents does hereby set over, transfer and assign absolutely to -'-",I:<, Husband, all of his rights, title and interest iu and to the Plymouth Neon currently registered in the name of Wife. Husband hereby agrees that he shall be solely liable to make payments due on the load secured by the Neon and does agree to indemnify and Wife harmless from any future liability with regard thereto. Except as provided for herein, the parties hereto have divided between themselves, to their mutual satisfaction, all items of tangible and intangible marital property. Except as otherwise provided herein, neither party shall make any claim to any such items of marital property, or the separate personal property of either property of either party, which items are now in the possession and/or under the control 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. Property shall be deemed to be in the possession or under control of either party if, in the case of tangible personal property, the item is physically in the possession or control of the party at the time of the signing of the Agreement, and in the case of intangible personal property, if any physical or written evidence of ownership, such as passbook, checkbook, policy or certificate of insurance or other similar writing is in the possession or control of the party. Husband and Wife shall each be deemed to be in possession and control of his or her own individual pension or other employee benefit plans or retirement benefits of any nature with the exception of Social Security benefits to which either party may have a vested or contingent right or interest at the time of the signing of this Agreement, and neither will make any claim against the other for any interest in such benefits. 8. PENSION. PROFIT SHARING AND THRIFT PLANS Wife hereby specifically waives her claim to any employee benefit provided to Husband by Husband's employee including Husband's contributory and non-contributory interest in his pension plan and 401 (k) account which plan and account shall hereafter be the sole and separate property of Husband. Husband hereby specifically waives his claim to any employee benefit provided to Wife by Wife's employee including Wife's contributory and non-contributory interest in his pension plan and 401 (k) account which plan and account shall hereafter be the sole and separate property of Wife. 9. ALIMONY. Al..IMONY PENDENTE LITE. COUNSEL FEES. AND EXPENSES Both parties acknowledge and agree that the proVIsIOns of this Agreement providing for equitable distribution of marital property are fair, adequate and satisfactory to them and are accepted by them in lieu of and in -full and final settlement and satisfaction of any claims. or demands that either may now or hereafter have against the other for support, maintenance or alimony. Husband and Wife further, voluntarily and intelligently waive and relinquish any right to seek from the other any payment for support, alimony, ., alimony pendete lite, counsel fees or expenses or any other provisions for their support or mainteuance, before, during, and after the commencement of any proceeding for divorce or annulment between parties. 10. WAIVERS OF CLAIMS AGAINST ESTATES: Except as hereiu 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 uow 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, courtesy, 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 executor of the other's estate. Each will, at the request ofthe 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 iuterests, rights and claims. 11. MUTUAL CONSENT DIVORCE The parties agree and acknowledge that their marriage is irretrievably broken, that they do not desire marital counseling, and that they both consent to the entry of a decree iu divorce pursuant to 23 Pa.C.S.A. Section 3301(c). Accordingly, both parties agree to forthwith execute such consents, affidavits, or other documents and to direct Wife's attorney to forthwith file such cousents, affidavits, or other documents as may be necessary to promptly proceed to obtain a divorce pursuant to said 23 Pa.C.S.A. Section 3301(c). Upon request, to the extent permitted by law and the applicable Rules of Civil Procedure, the named defendant in such divorce action shall execute any waivers of uotice or other waivers necessary to expedite such divorce. It is the intention of the parties that the Agreement shall survive any action for divorce, which may be instituted or prosecuted by either party, and no order, judgment or decree of divorce, temporary, fiual or permanent, shall affect or modify the financial terms of this Agreement. This Agreement shall be incorporated in but shall not merge into any such judgment or decree of _final divorce, but shall be incorporated for the purposes of enforcemeut only. 12. EFFECT OF RECONCILIATION OR COHABITATION This Agreement shall remain in full force and effect and shall not be abrogated even if the parties effect reconciliation, cohabit as husband and wife or attempt to effect reconciliation. 13. BREACH AND ENFORCEMENT 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, or seek such other remedies or relief as may be available to him or her, and the party breaching this Agreement shall be responsible for payment of legal fees and costs incurred by the other in enforcing his or her rights under this Agreement. It is expressly understood and agreed by and between the parties hereto that this Agreement may be specifically enforced by either Husband or Wife in Equity, and the parties hereto agree that if an action to enforce this Agreement is brought in Equity by either party, the other party will make no objection on the alleged ground of lack of jurisdiction of said Court on the ground that there is an adequate remedy at law. The parties do not intend or purport hereby to improperly confer jurisdiction on a Court in Equity by this Agreement, but they agree as provided herein for the forum of equity in _mutual recognition of the present state of the law, and in recognition of the general jurisdiction of Courts in Equity over agreements such as this one. Notwithstanding anything to the contrary herein, Husband and Wife may also proceed with an action at law for redress of his or her rights under the terms of this Agreement, and in such event it is specifically understood and agreed that for and in specific consideration of the other provisions and covenants of this Agreement, each shall waive any right to a jury trial so as to expedite the hearing and disposition of such case and so as to avoid delay. Each party further hereby agrees to pay and to save and hold harmless the other .party from any and all attorney's fees and costs of litigation that either may sustain, or incur or become liable for, in any way whatsoever, or shall pay upon, or in consequence of any default or breach by the other of any of the terms or provisions of this Agreement by reason of which either party shall be obliged to retain or engage counsel to initiate or maintain or defend proceedings against the other at law or equity or both in any way whatsoever; provided that the party who seeks to recover such attorney's fees, and costs of litigation must first be successful in whole or in part, before there would be any liability for attorney's fees and costs of litigation. It is the specific agreement and intent of the parties that a breaching or wrongdoing party shall bear the burden and obligation of any and all costs and expenses and counsel fees incurred by himself or herself as well as the other party in endeavoring to protect and enforce his or her rights under this Agreement. 14. TIDRD PARTY BENEFICIARIES Husband and Wife agree that it is not their intention in this Agreement that any other individuals, including their minor children, be third party beneficiaries of this Agreement at this time or at any time in the future. 15. ADDITIONAL INSTRUMENTS Each ofthe parties shall from time to time, at the request of the other, execute, acknowledge and deliver to the other party any and all further instruments that may be reasonably required to give full force and effect to the provisions of this Agreement. 1~1i........1..J.l...i.~,~i , ,,~ 16. TAX ADVICE Both parties hereto hereby acknowledge and agree that they have had the opportunity to retain their own accountants, certified public accountants, tax advisor, or tax attorney with reference to the tax implications of this Agreement. Further, neither party has been given any tax advice whatsoever by Wife's attorney. Further Wife hereby acknowledge that she has been advised by her attorney to seek her own independent tax advice by retaining an accountant, certified public accountant, tax attorney, or tax advisor with reference to the tax implications involved in this Agreement. Further, the parties acknowledge and agree that their signatures to this Agreement serve as their acknowledgment that they have read this particular paragraph and have had the opportunity to seek independent tax advice. 17. VOLUNTARY EXECUTION The Husband acknowledges that Gail G. Souders, attorney, has acted liS legal counsel to Wife in connection with the negotiation and preparation of this Property Settlement Agreement. The Husband acknowledges that, by copy of this Agreement, he has been advised of his right to seek the advice of counsel of his own choice in connection with any matter pertaining to this Agreement or the divorce action filed by Wife. Upon that provision, Husband and Wife acknowledge and represent that the provisions of this are fully understood by both parties and each party acknowledges that the Agreement is in all respects fair and equitable, that it is being entered into voluntarily and knowingly and that it is not the result of any duress or undue influence; Husband further acknowledges that he had the opportunity to seek the advice of legal counsel for the purpose of having the legal effect of the provisions herein fully explained to him, and that if he chose not to seek such legal counsel, such action was taken by him voluntarily of his own free will. 18. 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. Husband and Wife acknowledge and agree that the provisions of this Agreement with respect to the distribution and division of marital and separate property are fair, equitable and satisfactory to them based on the length of their marriage and other relevant factors, which have been taken into consideration by the parties. Both parties hereby accept the provisions of this Agreement with respect to the division of property in lieu of and in full and final settlement and satisfaction of all claims and demands that they may now have or hereafter have against the other for equitable distribution of their property by any court of competent jurisdiction pursuant to 23 Pa.C.S.A. Section 3501 et. sea. or any other laws. Husband and Wife each voluntarily and intelligently waive and relinquish any right to seek a court ordered determination and distribution of marital property, but nothing herein contained shall constitute a waiver by either party of any ~" , I, - iiik' rights to seek the relief of any court for the purpose of enforcing the provisions of this Agreement. 19. DISCLOSURE Husband and Wife each represent and warrant to the other that he or shtl has made a full and complete disclosure to the other of all assets of any nature whatsoever in which such party has an interest, the sources and amount of the income of such party or every type whatsoever and of all other facts relating to the subject matter of this Agreement. -20. MODIFICATIONS AND WAIVER A modification or waiver of any of the provisions of this Agreement shall be effective only if made in writing and executed with the same formality as this Agreemeut. 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. 21. 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 aud void and of no effect. 22. DESCRIPTIVE HEADINGS The descriptive headiugs used herein are for convenience only. They -shall have no effect whatsoever in determining the rights or obligations of the parties. 23. INDEPENDENT SEPARATE COVENANTS It is specifically understood aud agreed by and between the parties hereto that each paragraph hereof shall be deemed to be a separate and independent covenant and agreement. 24. APPLICABLE LAW This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania. 25. 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 shall be stricken from this Agreement and in all other respects this Agreement shall be valid and continue in full force, effect and operation. =- " ~ ,', - <. . . 26. AGREEMENT BINDING ON HEIRS This Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective heirs, executors, administrators, successors, and assigns. IN WITNESS WHEREOF, the parties hereto set their hands and seals on the dates of their acknowledgments. cfh~-JU~ Witness M/fi~< Witness r?J~ ~~ -~ 1- ~': STATE OF PENNSYLVANIA COUNTY OF DAUPHIN On , / Z t / (1<J , before me, a Notary Public, for the State of . Pennsylvania, residing in the city of Harrisburg, personally appeared Susan L. Ingram, known to me or satisfactorily proven to be the person whose name subscribed to the within instrument, and acknowledged that lIe executed the same for the purposes therein contained. WITNESS my hand and notarial seal the day and year aforesaid. /'-1[.~ Notary Public My Commission expires on: Notarial Seal Richard E. &lida. Notary PubUa Hanisburg, Dauphin COUnty . My Commission Expires March 2~, 2001 Member, Pennsylvania Association of Notari... -- ,~ , . '~r'=---'"L!Ii1'~' ," STATE OF PENNSYLVANIA COUNTY OF DAUPHIN --On ~/lI~p.:z" ; 2<lIID , before me, a Notary Public, for the State of Pennsylvania, residing in the city of Harrisburg, personally appeared Paul M. Ingram, known to me or satisfactorily proven to be the person whose name subscribed to the within instrument, and acknowledged that he executed the same . for the purposes therein contained. WITNESS my hand and notarial seal the day and year aforesaid. ~ ;;/t;ij ()~ ~ary Public My Commission expires on: SWbA.AJ .f StJ&s\~/8/1) -ro .&:n'<'hI /fJ8 -Ids OJo-m.PAj "r ..sa'hem&;:.f.~,2c)Oi) Notarfal Seal ~~,!:.henibo, N~ Pub/lc .... Com:~_':""!"V' Pa!IPh/n COu!llY on, mIIaIoii Ellpll88 June 28, 2004 MomIlii",.....~A88cciiiionOlNoterfee l~ i . ~ ,",,". ',' SUSAN LOUANNE INGRAM PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS CIVIL ACTION - DIVORCE PAUL MARTIN INGRAM DEFENDANT NO. 00-5107 PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the fonowing information, to tbe court for entry of a divorce decree: 1. Ground for Divorce: irretrievable breakdown under Section 3301 t!:> of the Divorce Code. 2. Date and manner of service of the Complaint: Certified mail, restricted delivery served on July 29,2000. 3. (a) Date of execution ofthe Affidavit of Consent required by Section 3301 (c) of the Divorce code: by the plaintiff October 31, 2000; by defendant October 31, 2000. 4. Related claims pending: No other claim pending. 5. Date and service of the notice of intention to file praecipe to transmit record, a copy of which is attached, if the decree is to be entered under section 330l (dO (1) (i) of the Divorce Code. 6. Date of Plaintiff's Waiver of Notice in Section 3301 t!:> Divorce Code was filed with the Prothonotary: November 6, 2000 7. Date of Defendant's Waiver of Notice in Section 3301 t!:> Divorce Code was filed ......,-_. N_~-A # , ~/ff ~mnti :Y:is;;""- fj , ",",'~_'''"" ,",",,~~~ 'A~",~;_'''''~''''''__" '",,,,, ~1IAbiUJiI[1 "",,,,-,~-- ,- ~'m't-- .' Jit.'~:'>' "'-- ,'.' - <~-"'-' -'-, ,"",'"""",,..., '~:,'~" ,', -" "",-,;,"'''''' ,'", _.~ - 'n .!idlll\tLiiiiWt11h:11 ':'~ o ~ ~g} ~r:; ~~~~:. :PC z: --I -< " -" , -, .,,, o (-) ':::r-1 ---I , , ~ ::.::'. r~" -v ::r,: '-:--j~'~)1 g~~ --I -t.'" ,~ -'~ .-< :11 -I"" ~ ;" - '~;" , ~ SUSAN LOUANNE INGRAM PLAINTIFF vs IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE PAUL MARTIN INGRAM DEFENDANT NO. 00 - KI()1 Ci0~L'-r~ NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do $0 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 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 the Prothonotary's at: Office of the Prothonotary's Cumberland County Courthouse Carlisle, Peunsylvania 17013 IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DMSION 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 OmCE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. :~---, O~~n...E 8F"fB:E E6UIt'J A:>>ll'.LI.nl;'IKAIUK C()UK.lUUVi)J!.., 4:"1lI'LVUK GAftLISI.E, p.o. 17913 (71 ~ 249 6299 Ct....~b~c.L C1u...Jty k {ksacJ'<d.t00 ;(. J.,;.wJ.'i /)~~ C.aA..L./'S Lr., '(c) fJ... I 70 t3 7/7- :J.'19 - ~/(.. (" ~,. c- '- , ,1, ' ,~", '''""",, .'.", , '~y , , SUSAN LOUANNE INGRAM PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS PAUL MARTIN INGRAM DEFENDANT CIVIL ACTION - DIVORCE Q-t) - ..s'lo? Ciw. -r ~ NO. COMPLAINT IN DIVORCE AND NOW, comes the Plaintiff, Susan Louanne Ingram, by her attorney, Gail Guida Souders, Esquire, and avers as follows: COUNT I DIVORCE PURSUANT TO SECTION 3301 (C) OR 3301 (D) OF THE DIVORCE CODE 1, The Plaintiff, Susan Louanne Ingram, is an adult individual residing at 11 Greenway Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. The Defendant, Paul Martin Ingram, is an adult individual residing at 11 Greenway Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on November 4, 1995 in Penbrook, Pennsylvania. 5. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties to participate in counseling and does not request the same. 6. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. 7. The Plaintiff and Defendant are both citizens of the Uuited States of America. 8. Neither of the partied in this action is presently a member of the Armed Forces. a ~ , -:.:~ " """', ~- -~' ,-;,':i, , 9. The Plaintiff and Defendant do not have children together. 10. The cause of action and Section of Divorce Code under which Plaintiff is proceeding is the marriage is irretrievably broken. WHEREFORE, The plaintiff requests this Honorable Court to enter a Decree of Divorce. COUNT n Divorce Dunuant to section 3301 (a) (6) 11. Plaintiff repeats and re-aIleges the averments contained in paragraphs 1 through 10 as if more fully set out at length herein. 12. Plaintiff avers that she is the innocent and injured spouse and that the Defendant has offered such indignities to her as to render her condition intolerable and life burdensome. 13. Plaintiff has been advised of the availability of counseling and that she may have the right to request that the court require the parties to participate. WHEREFORE, Plaintiff prays this Court to enter a Decree in Divorce pursuant to Section 3301 (a) 6 ofthe Divorce Code. - , JalU :,",,_~c-, ~,'",',""i' -"~ .' rt,~'~;1 , COUNT ill - EOUITABLE DISTRIBUTION 14. Paragraphs 1 through 10 are incorporated herein by reference as if set forth at length. 15. Both parties are owners of property requiring equitable distribution. WHEREFORE, Plaintiff respectfully requests this Honorable Court to equitably divide the marital property of the parties in accordance with the Divorce Code. COUNT IV - ALIMONY 16. Paragraphs 1 through 10 are incorporated herein by reference as if set forth at length. 17. Plaintiff lacks sufficient property to provide for her reasonable means. 18. Plaintiff requires reasonable support to adequately maintain herself in accordance with the standard of living established in the marriage. WHEREFORE, Plaintiff requests Your Honorable Court to enter an award of alimony in her favor. PIIIJ/s Gail Guida Souders Attorney for Plaintiff Guida Law Offices 503 North Front Street Harrisburg, PA 17101 Supreme Court ID # 68740 ~ .' _ ",._,,_,_ L..dLl i-'~:"_,,,_""'jh,''_ " . . ~ , I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. f 4904, relating to unsworn falsificaf n to DATE/~ /~~ -, ^ - -'" - ,-,',,- '-:;.;"",- , ... ... SUSAN LOUANNE INGRAM PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS CIVIL ACTION - DIVORCE PAUL MARTIN INGRAM DEFENDANT NO. 00-5/0'/ C-,:";\-(t.c-,..r"\ CERTIFICATE OF SERVICE I hereby certify that I am this day serving the foregoing document upon the persons and in the manner indicated below, which service satisfies the requirements of Pennsylvania Rule of Civil Procedure. 403: Service by certified mail to: Paul Martin Ingram 11 Greenway Drive Mechauicsburg, P A 17055 ail F. Guida Guida Law Offices 503 North Front Street Harrisburg, P A 17101 717-236-6440 Dated: 7/2. , /00 , ... , , ,;-,11.' , . CU11IpIVIl., IlI'111:'; \, ,Ill\! ,; I\b\l ~lJ;il\til'Il' item 4 iI F,estricted Delivery IS delilred . Print your name and address on the reverse so that we can return the card to you. . Attach this card to the back of the mailpiece, or on the front jf space permits. 1. Article Addressed 10' r".,.J (v{ (,... I.-.-: o Agen1 o Addressf: I from item 1? 0 Yes o No 00'\ 'i~ ,.-f' ~'JV \, (11'1(" ~ ",/\.1 I u" ,'i~ 0flGVtl )(~trwl C ' I r 11 () ) 70':::; j , 3, Service Type iK~ified M o Registered o Insured Mail o C,O,D. 4, Restricted OeUvery-? (Extra F&e) o Ye$ 2, Article Number (Copy from service label) 70 9Cf ;iJt;OD 0007 Y9CJB c9-/S-~ , PS Form 3811, July 1999 Domestic Return Receipt 102595.9Q.M-l n '-" '-" ,-1 ru en '" 0- '" f':iS'~gc' C;i:rtd,,,aFeel I"'- '" '" '" Ht'1\.JfI1 nOC(,II;)1 ,'ee ItnJor5elT\&r'-~ ?e",I,If;!d) ~- R.;s!I'ClbOUb''-'''"r''i;';' ~ IFI1(J[JriBIlWI',j f\",q~'~"d; '::__ TO\:t1 PO~l<19" & F'-iC~ '!~~,_,__3'2-- 0 '" '" "'" IT1 .'~-;--;;;(I~--;-~'~-- --;-/:;~,7-i;'r:ouCi0PICflJrj b'l mader} ~ l ~ ~ >.W1",,~, ... I $rreel,AQI N0"IJ'P08of(No "., ~ i.c""",.jki!ttf.l.w1r;-ai'te...."... I"'- fYl{~~'[d~.RA ')O.s,-!{ k~";j"'IIl'''!:!':I. t _ \.,.,......' . "" 'l ",j i ..f.l\rllkljlmj~ $t'!cBO;:l,'crs "",,,,'-- "'" '" ,- =-"',,-- -> SUSAN LOUANNE INGRAM PLA:llIITlFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS CIVIL ACTION - DIVORCE PAUL MARTIN INGRAM DEFENDANT NO. 00-5107 AFFlDA VIT OF CONSENT 1. A complaint in divorce under Section 3301 ( c) of the Divorce Code was filed on July 20,2000. 2, The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date offi1ing 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 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. ~ 4904 relating to unsworn falsification to authorities. DATE ;<1 ~~~~illi:,o.l!",~lli~~Iil:I;...~..w...~'~~;'~"'""""'~~lif!liiU,:!il-...t'"" -"'"',< a ~ - ~"""~" .~' . "'---"-....:"., ~ , ""w ~ ; -~' ~, ", ", I 0 0 () c a -'\"1 <' Z -Om C) :=;:1 nlrr; "'" ':':;1;11 Z::o -:7'-'" I -.-1 iT! Ci5 It-, en :i~'jO -<:2" ~~j ~c; ""Q )> -;,' z.C) -0 Pc 1'..) orn Z ,; =< r=- :'b m -< :w. " ," '-~ -,.,_," _,tF'" SUSAN LOUANNE INGRAM IN THE COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY , PENNSYLVANIA VS CIVIL ACTION - DIVORCE PAUL MARTIN INGRAM DEFENDANT NO. 00-5107 WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF DIVORCE DECREE UNDER SECTION 336HC) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in 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 veritY 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. ~ 4904 relating to unsworu falsification to authorities. DATE ~i!i!;.,li';~,I#.'-""""'llT1!!"'''fu-i;i<ig~jiI_IIilii.'Ul!iliWlil;RiHlti.i~!\~N'~~~tl!:W~. ,'<C ""-" __~ ,~." ~ ~ "~~,, ",,- ~ "'b~~ ~ '............ H'~'; I ! , 0 0 C 0 0 ?" -n uCG ~ ,"'- m["C C") :z: " ,"'= -" 2'~! I F----= (I)'" :;1~ ::<,""7' CO r::b ~, -U zO ~"'p' ~~~Q j!.:O c 1"\J l."sn~1 :z: ~-j :< &:- e 0"\ :n -< I> ~"" . ;'-' '" ,,'S - .' .~: . SUSAN LOUANNE INGRAM PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS CIVIL ACTION - DIVORCE PAUL MARTIN INGRAM DEFENDANT NO. 00-5107 AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301 (c) of the Divorce Code was filed on July 20, 2000. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service ofthe 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 veritY 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. i 4904 relating to unsworu falsification to anthorities. ~~+ , ~'~~~"L%~::-;;o~obf~:~~__Il!"I$h'1'ii_~~~L "~" '-'="~""- '~IllIIlIliiaI--'lilj1U " '" .. () 0 t.-.:) C <:::1 <"' -n ""D no z ~:;~lp) mr.....' C) z:.L: ,,'.- Zc' , ~~~~i ::J (/) T,: C) --< ~,. (;~~ (~) ~b v Pc", -~~ ;~--r-; zc5 ?~~~ );.c: I,,>? ~ -, .&:- )> 0\ ::0 -< ..1 .-;'-' ,..', . _ '",_ ->- h'. -', ~' . c SUSAN LOUANNE INGRAM PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA !-' VS CIVIL ACTION - DIVORCE PAUL MARTIN INGRAM DEFENDANT NO. 00-5107 W AlVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF DIVORCE DECREE UNDER SECTION 3301(0 OF THE DIVORCE CODE 1. I consent to the entry of a final decree in 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's. I verity 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. ~ 4904 relating to unsworn falsification to authorities. DATE ~//Jh~ (Defendant) y ~~4ffi~""~~""~b",.;'''-A:'~l5~_I~~r ,;,',-,!"-"" ,; ""," -~- ,- ~ <~" ,'" ",' <,~ ,,,-,",", >y, ,-"",-, .' '~ ....WMi. <,. ,.<'-""--' ,~" ~ '-""""~"""j,.-' 11_ ~~ .'"",,,,-,= '--'"- ". ,~-- - (") 0 C) C- O -'1"1 '?: ;~ v 0::; 0 rnrr; Z~"' .';:::;: ~-- zr-- I -"'" (f) "10> <::0 ,>(~ --< ~~ C) ,1, ~Cj '0 ~~--r~ )>C :J;-: c5J] z "'~ 5>0 ~ ~?l~ C ~--' z: o;-l ~ r:- ",' m ::0 -< ll'!