HomeMy WebLinkAbout00-05479
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF
STEVEN S. COHICK,
PENNA.
Plaintiff
No. 00-5479 CIVIL TERM
VERSUS
KAREN S. COHICK.
Defendant
AND
DECREE IN
DIVORCE
NOW'~<~-Jw. ,e
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DECREED THAT
Steven S. Cohick
AND
Karen S. Cohick
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ARE DIVORCED FROM THE BONDS OF MATRIMONY.
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~, IT IS ORDERED AND
, PLAINTIFF,
, DEFENDANT,
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED;
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The parties' Separation and Property Settlement Agreement dated
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August 14, 2000, is incorporated herein. but not merged.
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OTHONOTARY
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SEPARATION AND PROPERTY SETTLEMENT AGREEMENT
THISAGREEMENT, made this JI-lii- dayof ~ ,2000, by and
between STEVEN S. COHICK, of 625 Grahams Woods Road, Newville, Cumberland Coun!)',
Pennsylvania, party of the first part, hereinafter referred to as "Husbantl',
AND
KAREN S. COHICK, of 406 Mohawk Road, Newville, Cumberland County,
Pennsylvania, party of the second part, hereinafter referred to as "Wift!',
WITNESSETH:
WHEREAS, Husband and Wile were married on March 13, 1982, in Carlisle, Cumberland
County, Pennsylvania; and
WHEREAS, Husband and Wife are residents of the Commonwealth of Pennsylvania and
have been so for at least the past six months;
WHEREAS, certain differences have arisen between the parties hereto which has caused
Wife to be desirous of living separate and apart from one another; and
WHEREAS, Husband and Wife desire to settle and determine certain of their marital
rights and obligations, and make an equitable distribution of their marital property, determine their
rights to alimony and support and any other matters which may be considered under the Divorce
Code; and
WHEREAS, it is the intention and purpose of this Agreement to set forth the respective
rights and duties of the parties while they continue to live apart from each other and to settle all
financial and property rights between them; and
WHEREAS, the parties hereto have mutually entered into an agreement for the division of
their jointly owned assets, the provisions for the liabilities they owe, and provisions for the
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resolution of their mutual differences, after both have had full and ample opportunity to consult
with attorneys of their respective choice, the parties now wish to have that agreement reduced to
writing.
NOW, THEREFORE, the parties hereto in consideration of the mutually made and to be
kept promises set forth hereinafter and for other good and valuable consideration, and intending
to be legally bound and to legally bind their heirs, successors, assigns, and personal
representatives, do hereby covenant, promise and agree as follows:
ARTICLE I
SEPARATION
1.1
It shall be lawful for Husband and Wile at all times hereafter to live separate and apart
from each other and to reside from time to time at such place or places as they shall respectively
deem fit free from any control, restraint, or interference, direct or indirllCt, by each other. Neither
party shall molest the other or compel or endeavor to compel the other to cohabit or dwell with
him or her by any legal or other proceedings. The foregoing provisions shall not be taken to be an
admission on the part of either Husband or Wife of the lawfulness of the causes leading to them
living separate and apart.
ARTICLE II
DIVORCE
2.1
This Agreement is not predicated on divorce. It is specifically understood and agreed by
and between the parties hereto that each of the said parties does hereby warrant and represent to
the other that the execution and delivery of this Agreement is not predicated upon nor made
subject to any agreement for institution, prosecution, defense, or for the non-prosecution or non-
defense of any action for divorce; provided, however, that nothing contained in this Agreement
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shall prevent or preclude either of the parties hereto from commencing, instituting or prosecuting
any action or actions for divorce, either absolute or otherwise, upon just, legal and proper
grounqs; not to prevent either party from defending any such action which has been, may. or shall
be instituted by the other party, or from making any just or proper defense thereto. It is
warranted, covenanted, and represented by Husband and Wife, each to the other, that this
Agreement is lawful and enforceable and this warranty, covenant, and representation is made for
the specific purpose of inducing Husband and WIfe to execute the Agreement. Husband and WIfe
each knowingly and understandingly hereby waive any and all possible claims that this Agreement
is, for any reason, illegal, or for any reason whatsoever of public policy, unenforceable in whole or
in part. Husband and WIfe do each hereby warrant, covenant and agree that, in any possible
event, he and she are and shall forever be estopped from asserting any illegality or
unenforceability as to all or any part of this Agreement.
2.2
It is further specifically understood and agreed that the provision of this Agreement
relating to the equitable distribution of property of the parties are accepted by each party as a final
settlement for all purposes whatsoever. Should either of the parties obtain a decree, judgment or
order of separation or divorce in any other state, country, or jurisdiction, each of the parties to
this Agreement hereby consents and agrees that this Agreement and all its covenants shall not be
affected in any way by any such separation and divorce.
2.3
This Agreement shall survive any decree in divorce and shall be forever binding and
conclusive on the parties. It is understood by and between the parties that this Agreement shall be
incorporated into any decree, divorce or separation, but it shall not be deemed merged in such
decree.
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ARTICLE III
EOUITABLE DISTRIBUTION OF MARITAL PROPERTY
3.1
The parties have attempted to divide their marital property in a manner which conforms to
the criteria set forth in the Pennsylvania Divorce Code, and taking into account the following
considerations: the length of the marriage; the prior marriages of the parties; the age, health,
station, amount and sources of income, vocational skills, employability; estate, liabilities, and
needs for each of the parties; the contribution of one party to the education, training or increased
earning power to the other party; the opportunity of each party for future acquisition of capital
assets 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 part in the
acquisition, preservation, depreciation, or appreciation of marital property, including the
contribution of a party as a homemaker; the value of the property set apart to each party; the
standard of living of the parties established during their marriage; the economic circumstances of
each party, including federal, state and local tax ramifications, at the time of the division of the
property is to become effective; and whether the parties will be serving as the custodian of any
dependent minor children.
3.2
The division of existing marital property is not intended 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 rights of equitable distribution of the parties.
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3.3
Pt!1'8onal PrODertv. The parties acknowledge that they have divided their personal
property, tangible and intangible, to their mutual satisfaction. The parties acknowledge that they
have the cash, accounts, and other tangible or intangible property in their possession that they
wish to have and neither party will make any claim whatsoever against the other party for any
items of personal property or assets that is in the other parties' possession.
3.4
Life Insurance. At present, the only life insurance maintained by the parties is a life
insurance policy on Husband's life, which he carries through his present employment with
Computer Aide, Incorporated and a "rider" on that policy insuring Wife's life. The parties agree
that they shall maintain their children, Seldon Scott Cohick, born November 11, 1983, and Sean
Swain Cohick, born September 14, 1986, as the beneficiaries on these each of their life insurance
policies maintained through Husband's employment. Until such time as the children reach twenty-
one (21) years of age, the other party shall serve as Trustee for 'the children on the said life
insurance policies. This provision of this Agreement shall override any other beneficiary
designation on the life insurance policies themselves such that, under any circumstances, the
within named children shall be the sole beneficiaries on the aforesaid life insurance policies.
With the exception of these life insurance policies, neither party has life insurance that they
have purchased independently of their employment.
3.5
Subsequentlv Acquired ProDertv. Husband and Wife agree to waive and relinquish any
and all right that he or she may now have or hereafter acquire in any real or tangible personal
property subsequently acquired by the other party. Husband and Wife specifically agree to waive
and relinquish any right in such property that may arise as a result of the marriage relationship.
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3.6
Real Estate. The parties are the joint owners of real estate located at 625 Grahams
Woods Road, Newville, Cumberland County, Pennsylvania, which property is currently held in
the parties' names as tenants by the entireties. This property is encumbered with a mortgage due
and owing to Keystone Financial and a home equity loan or second mortgage loan due and owing
to Americhoice Federal Credit Union.
Within fifteen (15) days of execution of this Agreement, Wife shall execute a general
warranty, fee simple deed conveying all of her right, title and interest in the aforesaid real estate to
Husband. From the date of execution of this Agreement forward, she shall make no claim of any
legal or equitable interest in the aforesaid real estate. In the event it is necessary for Wife to
execute any other documents to so waive, relinquish or transfer her legal and equitable rights in
the real estate, she will do so within fifteen (15) days of being requested to do so by Husband or
his legal representation.
Husband shall be solely and exclusively responsible for repayment of the mortgage due
and owing to Keystone Financial and the home equity or second mortgage due and owing to
Americhoice Federal Credit Union from the date of execution of this Agreement forward. He
shall indemnify Wife and hold her harmless from and against any and all demands for payment or
collection activity of any nature whatsoever relative to the aforesaid mortgages and
encumbrances.
The within described real estate is the only real estate in which either party has any legal or
equitable interest.
3.7
Pension. Retirement. Profit-Sharinf!. Wife agrees to waive, relinquish or transfer any
and all of her right, title and interest she has or may have in her individual capacity or as
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Husband's WIfe in any and all pension, retirement, profit-sharing, stock options or similar
accounts with Husband's present employers or past employers or which Husband has secured
independently, including, but not limited to, any retirement that has been established through his
past employment with IBM, as well as the 401(k) account that he has established through his
present employment with Computer Aide Incorporated.
Husband agrees to waive, relinquish or transfer any and all of his right, title and interest he
has or may have in his individual capacity or as Wife's Husband in any and all pension, retirement,
profit-sharing, stock options or similar accounts with WIfe's present employers or past employers
or which WIfe has secured independently, including, but not limited to, any retirement that has
been established through her present employment with Saylors IGA and her prior employment
with the Big Spring School District.
3.8
Vehicles. The parties acknowledge that during their marriage they purchased certain
vehicles and presently have in their ownership and possession the following vehicles: 1984 Honda
Prelude; 1989 Mercury Marquis Station Wagon; 1991 Jeep Wrangler; and a 1998 Dodge
Durango.
WIfe shall retain as her sole and exclusive possession the 1984 Honda Prelude, which shall
be transferred into WIfe's sole name contemporaneously with the execution of this Agreement or,
under any circumstance, within fifteen (15) days of execution of this Agreement. From that date
forward, Husband shall make no claim of any nature whatsoever relative to any ownership interest
or rights to possession of the aforesaid vehicle.
Husband shall retain sole and exclusive ownership and possession of the 1989 Mercury
Marquis Station Wagon, the 1991 Jeep Wrangler and the 1998 Dodge Durango.
Contemporaneously with execution of this Agr!!t1ment or within fifteen (15) days of being
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requested to do so, Wife shall execute any and all necessary documents to waive, relinquish and
transfer any and all right, title and interest she has in the aforesaid vehicles.
In the event there are any encumbrances of any nature on any of the aforesaid vehicles, the
party retaining ownership and possession of the respective vehicle shall be sole and exclusively
responsible for any such debts and shall indemnifY the other party and hold them harmless from
and against any and all demands for payment or collection activity of any nature whatsoever
relative to any such debts. It is specifically recognized that there is a loan due and owing to
Americhoice Federal Credit Union on the 1991 Jeep Wrangler and a loan due and owing to
Americhoice Federal Credit Union on the 1998 Dodge Durango, both of which encumbrances
shall be Husband's sole and exclusive responsibility.
3.9
Intanl!ible Personal PrODertv. The parties acknowledge that they have previously
transferred or waived rights or otherwise transferred their ownership interest in all intangible
personal property such that all the intangible personal property that presently exists including their
various bank accounts, credit union accounts and the like have already been distributed to their
mutual satisfaction. Neither party will make any claim of any nature whatsoever against the other
relative to the fuIancial accounts or other investments or intangible personal property that have
already" been retained by that party as described herein.
3.10
Cemeterv Plots. The parties are the joint owners of cemetery plots with Cumberland
Valley Memorial Gardens, Carlisle, Pennsylvania. Within fifteen (15) days of being requested to
do so by Husband or his legal representative, Wife shall execute any and all necessary documents
to waive, relinquish and transfer any and all right, title and interest she has in the aforesaid
cemetery plots so that they shall become and remain Husband's sole and exclusive possession.
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ARTICLE W
ALIMONY. ALIMONY PENDENTE LITE.
SPOUSAL SUPPORT. CHILD SUPPORT AND MAINTENANCE
4.1
The parties acknowledge that they have each secured and maintained sufficient income
and adequate funds to provide for themselves with sufficient resources to provide for their own
comfort, maintenance and support in the station of life in which they are accustom. Husband and
Wile do hereby waive, release and give up any rights they may have, respectively, against the
other, for alimony, spousal support or maintenance except as provided in paragraph 4.2
hereinafter.
4.2
At the time of the parties' separation and prospective divorce, if it becomes necessary for
Wile to secure her own automobile insurance, independent of the insurance carried by Husband,
Husband agrees that he shall be responsible for payment of Wile's automobile insurance premiums
in a timely fashion until such time as Wile remarries. In the event Husband believes that Wile has
attempted to secure an automobile insurance policy that is excessive, he has the right to secure
insurance for Wife's vehicle comparable to the insurance that he carries on his vehicles through an
insurance carrier of his selection.
In addition, Husband agrees that he shall be solely and exclusively responsible for any and
all uninsured medical expenses that are presently due and owing to any service care provider for
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Husband, Wile or the parties' children, as of the date of the execution of this Agreement. In
addition, any uninsured medical expenses that are incurred by Wife in the future shall be
Husband's responsibility until such time as Wife is able to secure health insurance through her
present employment with Saylors IGA.
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4.3
The parties agree that neither party will request or secure child support from the other
party from the date of execution of this Agreement forward, but rather, the party who has primary
physical custody of the children shall simply remain responsible for the primary expenses
associated with raising the children and the non-custodial parent shall assist in those expenses as
that parent deems appropriate.
4.4
Husband and Wife specifically waive, release and relinquish any rights for alimony,
alimony pendente lite, and spousal support pursuant to Chapter 37 of the Domestic Relations
Code.
ARTICLE V
DEBTS OF THE PARTIES
5.1
The parties acknowledge that they have secured certain debts not previously referenced
herein during their marriage. With respect to such debts, the parties shall each assume
responsibility for repayment of certain debts and hold the other party hannIess from collection of
such debts. More specifically, Wife shall be solely and exclusively responsible for repayment of
the Bon Ton credit card or charge card account that is believed to exist in her name alone. She
shall indemnifY Husband and hold him harmless from and against any and all demand for payment
or collection activity of any nature whatsoever relative to such account.
Husband shall be solely and exclusively responsible for the Americhoice Visa account, the
Discover credit card, and the Sears credit card or charge card account, which are believed to be
primarily in Husband's name, but with Wife as a joint obligor. Husband shall indemnifY Wife and
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hold her harmless from and against any and all demand for payment or collection activity of any
nature whatsoever relative to the aforesaid debts.
In addition, the parties have secured personal loans due and owing to Citi Financial and to
Americhoice Federal Credit Union, both of which accounts are and shall remain Husband's sole
and exclusive responsibility. Husband shall indemnify Wife and hold her harmless from and
against any and all demand for payment or collection activity of any nature whatsoever relative to
said personal loans.
In addition, the parties reaffirm their responsibility for repayment of the debts hereinbefore
set forth with respect to the parties' real estate and vehicles.
5.2
Each party represents to the other that except as otherwise specifically set forth in this
Agreement, and more particularly as s~t forth in subparagraph 5.1 above, there are no major
outstanding obligations of the parties' that since the separation neither party has contracted for
any debts for which the other will be responsible, and each party indemnifies and holds harmless
the other for all obligations separately incurred or assumed under this Agreement.
ARTICLE VI
MISCELLANEOUS PROVISONS
6.1
Advice of Counsel. The parties acknowledge that they have had the opportunity to
review the provisions of this Agreement and further have had the opportunity to secure legal
counsel and advice relative to the legal effect to this Agreement. The parties acknowledge that
they have either received independent legal advice from counsel of their own selection or that they
have specifically chosen with full knowledge and on their on volition, to not seek legal advice
relative to this Agreement. They further acknowledge that they fully understand the facts that are
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the basis of this Agreement. They acknowledge and accept that this Agreement is being entered
into freely and voluntarily after having the opportunity to receive legal advice and within the
knowledge that execution of this Agreement is not the result of any duress or undue influence,
and further that it is not the result of any collusion or improper or illegal agreement or
agreements.
6.2
Counsel fees. Each party agrees to be responsible for his or her own legal fees and
expenses, and each party hereby agrees to waive any claim for alimony, alimony pendente lite,
counsel fees, expenses or costs.
6.3
Mutual Release. Husband and Wife each do hereby mutually remise, release, quitclaim,
and forever discharge the other and the estate of such other, for all times to come and for all
purposes whatsoever, of and from any and all right, title and interest, or claims in or against the
property (including income and gain from property hereafter accruing) of the other or against the
estate of such other, of whatever nature and wheresoever situate, which he or she now has or at
any time hereafter may have against such other, the estate of such other, or any part thereof:
whether arising out of any former acts, contracts, engagements, or liabilities of such other as by
way of dower or curtesy, or claims in the nature of dower or curtesy or widow's or widower's
rights, family exemption, or similar allowance, or under the intestate laws, or the right to take
against the spouse's Will; or the right to treat a lifetime conveyance by the other as testamentary,
or all other rights of a surviving spouse to participate in a deceased spouse's estate, whether
arising under the laws of (a) Pennsylvania, (b) any state, commonwealth or territory of the United
States, or ( c) any other country, or any rights which either party may have or at any time hereafter
have for past, present, or future support or maintenance, alimony, alimony pendente lite, counsel
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fees, costs or expenses, whether arising as a result of the marital relation or otherwise, except and
only except, all rights and agreements and obligations of whatsoever nature arising or which may
arise under this Agreement or for the breach of any thereof. It is the intention of Husband and
Wife to give to each other by execution of this Agreement a full, complete, and general release
with respect to any and all property of any kind or nature, real or personal, not mixed, which the
other now owns or may hereafter acquire, except and only except, all rights and agreements and
obligations of whatsoever nature arising or which may arise under this Agreement or for the
breach of any thereof.
6.4
Warranties. Each party represents that they have not heretofore incurred or contracted
for any debt or liability or obligation for which the estate of the other party may be responsible or
liable, except as may be provided for in this Agreement. Each party agrees to indemnify or hold
the other party harmless from and against any and all such debts, liabilities or obligations of every
kind, including those for necessities, except for the obligations arising out of this Agreement.
Husband and Wife each warrant, covenant, represent and agree that each will, now and at all
times hereafter, save harmless and keep the other indemnified from all debts, charges, and
liabilities incurred by the other after the execution date of this Agreement, except as is otherwise
specifically provided for by the terms of this Agreement and that neither of them hereafter incur
any liability whatsoever for which the estate of the other may be liable.
6.5
No waiver or modification of any of the terms of this Agreement shall be valid unless in
writing and signed by both parties and no waiver of any breach hereof or default hereunder shall
be deemed a waiver of any subsequent default of the same or similar nature.
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6.6
Husband and WIfe covenant and agree that they will forthwith execute any and all written
instruments, assignments, releases, satisfactions, deeds, notes or such other writings as may be
necessary or desirable for the proper implementation of this Agreement, and as their respective
counsel shall mutually agree should be so executed in order to carry fully and effectively the terms
of this Agreement.
6.7
This Agreement shall be construed in accordance with the laws of the Commonwealth of
Pennsylvania which are in effect as of the date of the execution of this Agreement.
6.8
This Agreement shall be binding and shall inure to the benefit of the parties hereto and
their respective heirs, executors, administrators, successors and assigns.
6.9
This Agreement constitutes the entire understanding of the parties and supersedes any and
all prior agreements and negotiations between them. There are no representations or warranties
other than those expressly set forth herein.
6.10
Severabilitv. If any term, condition, clause, section, 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. Likewise, the failure of
any party to meet his or her obligation under anyone or more of the articles and sections herein
shall in no way void or alter the remaining obligations of the parties.
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6.11
It is specifically understood and agreed that this Agreement constitutes an equitable
distribution of property, both real and personal, which was legally and beneficially acquired by
Husband and wife, or either ofthern, during the marriage as contemplated by the Divorce Code of
the Commonwealth of Pennsylvania.
6.12
Disclosure. The parties each warrant and represent 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 party has
an interest, of the sources, and amount of the income of such party of every type whatsoever, and
all other facts relating to the subject matter of this Agreement.
6.13
Enforceabilitv and Consideration. This Agreement shall survive any action for divorce
and decree of divorce and shall forever be binding and conclusive on the parties; and any
independent action may be brought, either at law or in equity, to enforce the terms of the
Agreement by either Husband or Wife until it shall have been fully satisfied and performed. The
consideration for this contract and agreement is the mutual benefits to be obtained by both of the
parties hereto and the covenants and agreements of each of the parties to the other. The
adequacy of the consideration for all agreements herein contained in stipulated, confessed, and
admitted by the parties, and the parties intend to be legally bound hereby. In the event either
party breaches the aforesaid Agreement and it is detemIined through appropriate legal action that
the alleged party has so breached the Agreement, the breaching party shall be responsible for any
and all attorney's fees as well as costs and expenses associated with litigation incurred by the non-
breaching party to enforce this Agreement against the breaching party. In the event of breach,
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the non-breaching party shall have the right, at his or her election, to sue for damages for such
breach or to seek such other and additional remedies as may be available to him or her including
equitable enforcement of this Agreement.
IN WITNESS WHEREOF, the parties hereto have set their hands and seals the day and
year first above written.
WITNESSED BY:
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STEVEN s. COHICK
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COMMONWEALTH OF PENNSYL VANIA
COUNTY OF CUMBERLAND
On this /L/6-day of ~
, 2000, before me, the undersigned
officer, personally appeared STEVEN S. COlliCK, known to me (or satisfactory proven) to be
the person whose name is subscribed to the within Agreement and acknowledged that he executed
the same for the purpose therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
Notarial Seal
Robin J. Goshorn, Notary Public
Carlisle Bom, Cumberiand County
My Commission Expires Apr. 17, 2003
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COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
On this / I(~of ~ ' 2000, before me, the undersigned
officer, personally appeared KAREN S. COHICK, known to me (or satisfactory proven) to be the
person whose name is subscribed to the within Agreement and acknowledged that she executed
the same for the purpose therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
Notarial Seal .
Robin J. Goshorn, Notary Public
Carlisle Bom, Cumbarland County
My Commission Expires Apr. 17, 2003
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STEVEN S. COHICK,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
KAREN S. COHICK,
Defendant
: NO. 00-5479 CIVIL TERM
: IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
TO THE PROTHONOTARY:
Transmit the record, together with the following information to the court for entry of a
divorce decree:
I. Ground for divorce:
Irretrievable breakdown under 9330l(c)
330l(d)(1) efthe Divorce Code.
(Strike out inapplicable section).
2. Date and manner of service of the Complaint: by certified mail, restricted delivery to
Defendant, Karen S. Cohick, on August 14, 2000.
3. Complete either paragraph (a) or (b).
(a) Date of execution of the Affidavit of Consent required by 93301 (c) of the Divorce
Code: by Plaintiff: November 27,2000 by Defendant: November 20, 2000
(b) (1) Date of execution of the affidavit required by 93301 (d) of the Divorce Code:
(2) Date of filing and service of the plaintiffs affidavit upon the respondent:
4. Related claims pending: none
5. Complete either (a) or (b).
(a) Date and manner of service of the notice of intention to file Praecipe to Transmit
record, a copy of which is attached:
(b) Date of plaintiffs Waiver of Notice in 93301 (c) Divorce was filed with the
Prothonotary: November 28, 2000
Date defendant's Waiver of Notice in 93301 (c) Divorce was filed with the
Prothonotary: November 21,2000
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STEVEN S. COHICK,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
KAREN S. COHICK,
Defendant
.: NO.OO- S'1.11? CIVIL TERM
: IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in Court. If you wish to defendant 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 will proceed without and a decree in 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 inlportant 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 the Prothonotary at Cumberland County Courthouse, Carlisle,
PennsylvarUa, 17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY. DIVISION OF MARITAL
PROPERTY, LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE 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
Two Liberty Avenue
Carlisle, PennsylvarUa 17013
(717) 249-3166
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STEVEN S. comCK,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: NOiPlP-SY7r CIVIL TERM
KAREN S. comeK,
Defendant
: IN DIVORCE
COMPLAINT IN DIVORCE
1. Plaintiff is Steven S. Cohick, an adult individual currently residing at 625 Grahams
Woods Road, Newville, Cumberland County, Pennsylvania. Plaintiff has resided at
this address for approximately 14 years.
2. Defendant is Karen S. Cohick, an adult individual currently residing at 406 Mohawk
Road, Newville, Cumberland County, Pennsylvania. Defendant has resided at this
address since July 23,2000.
3. Plaintiff is a bonafide resident of the Commonwealth of Pennsylvania and has been so
for at least six months immediately previous to the filing of this Complaint.
4. Plaintiff and Defendant were married on March 13, 1982 in Carlisle, Cumberland
County, Pennsylvania.
5. There have been no prior actions for divorce or annuhnent between the parties.
6. The Defendant is not a member of the Unites States Armed Forces or its Allies.
7. Plaintiff has been advised of the availability of counseling and the right to request that
the Court require the parties to participate in counseling. Knowing this, Plaintiff does
not desire that the Court require the parties to participate in counseling.
8. Plaintiff and Defendant are citizens of the United States of America.
9. The parties' marriage is irretrievably broken.
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10, Plaintiff desires a divorce based upon the belief that Defendant will, ninety days from
the date of service of this Complaint, consent to this divorce.
WHEREFORE, Plaintiff requests your Honorable Court to enter a decree in
divorce pursuant to Section 3301(c) of the Domestic Relations Code.
Respectfully submitted,
GRIFFIE & ASSOCIATES
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I verifY that the statements made in the foregoing document are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S.
Section 4904, relating to unsworn falsification to authorities.
DATE:
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STEVEN S. COHICK
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STEVEN S. COHICK,
Plaintiff
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: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
KAREN S. COHICK,
Defendant
: NO. 00-5479 CIVIL TERM
: IN DIVORCE
AFFIDAVIT OF CONSENT
1. A. Complaint in Divorce under 93301 (c) of the Divorce Code was filed on
August 8, 2000, and served on August 14, 2000.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90)
days have elapsed from the date of 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 VERITY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT
ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN
ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. 94904 RELATING TO
UNSWORN FALSIFICATION TO AUTHORITIES.
DATE:
1Ib,7/M
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STEVEN S. COHICK, Plaintiff
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STEVEN S. COHICK,
Plaintiff
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: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
KAREN S. COHICK,
Defendant
: NO. 00-5479 CIVIL TERM
: IN DIVORCE
WAIVER ON NOTICE OF INTENTION TO REQUEST
HIE ENTRY OF A DIVORCE DECREE
UNDER ~3301(c) 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! do not claim them before a divorce is granted.
3. I understand that I will not be divorce 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 files with the
Prothonotary.
I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT
ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN
ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. 94904 RELATING TO
UNSWORN FALSIFICATION TO AUTHORITIES.
DATE: /I j:J '1! f} 0
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STEVEN S. COHICK, Plaintiff
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STEVEN S. COHICK,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
: CIVIL ACTION - LAW
KAREN S. COHICK,
Defendant
: NO. 00-5479 CIVIL TERM
: IN DIVORCE
AFFIDAVIT OF CONSENT
1. A. Complaint in Divorce under S3301 (c) of the Divorce Code was filed on
Augnst 8, 2000, and served on Augnst 14,2000.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90)
days have elapsed from the date of 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 ofthe decree.
I VERITY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT
ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN
ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. 94904 RELATING TO
UNSWORN F ALSIFICA TION TO AUTHORITIES.
DATE:
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STEVEN S. COHICK,
Plaintiff
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: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
KAREN S. COHICK,
Defendant
: NO. 00-5479 CIVIL TERM
: IN DIVORCE
WAIVER ON NOTICE OF INTENTION TO REQUEST
THE ENTRY OF A DIVORCE DECREE
!LNDER ~3301(c) 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 ifI do not claim them before a divorce is granted.
3. I understand that I will not be divorce 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 files with the
Prothonotary.
I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT
ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN
ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. g4904 RELATING TO
UNSWORN FALSIFICATION TO AUTHORITIES.
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STEVEN S. COHICK,
Plaintiff
v.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
KAREN S. COHICK,
Defendant
: NO. 00-5479 CML TERM
: IN DIVORCE
AFFIDAVIT OF SERVICE
AND NOW, this 16TH day of August, 2000, comes Bradley L. Griffie, Esquire, Attorney
for Plaintiff, and states that he mailed a certified and true copy of a Complaint in Divorce, to the
Defendant, Karen S. Cohick, to 406 Mohawk Road, Newville, Pennsylvania, by certified mail,
restricted delivery, return receipt requested. A copy of said receipt is attached hereto indicating
service was made on August 14,2000.
Sworn and subscribed to
before me this lilt- day
of ..:AwjiA 'St ' 2000.
~tlifi~
OT' PUBLIC
. NqjaiIal Seal
KIlrisa J. Lehnian. No"'ft' Public
CaI1IsIe BolO, Cuiiibelt8iia County
My commission expires Aug. 25. 2003
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