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Home My WebLink About00-05869 . ~ ~ ~ ~ ~ . ~ . . . ~ ~ ~ ~ ~ ~ ~~ ~ . . . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY . . . . . . PENNA. STATE OF . TERRY B. CHAMBERLIN . No. 2000-5869 . PLAINTIFF . . VERSUS . LISA D. CHAMBEIlLIN . . DEFENDANT . DECREE IN DIVORCE AND NOW, \C~4 ~'1 , 2001 ,IT IS ORDERED AND . . DECREED THAT TERRY B. CHAMBERLIN , PLAINTIFF, AND LISA D. CHAMBERLIN , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. . THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; \;tJ~- THE ATTACHED MARITAL AGREEMENT BETWEEN THE PARTIES DATED JANUARY 2. 2001. SHALL BE INCORPORATED BUT NOT MERGED !NT IS D VORCE PURSUANT TO THE SAID AGREEMENT. . . . . . . . . . By T , ATTEST: . OTHONOTARY . . . . . .. . . . . . . , . . . , . . . . . . . . . . . . . , . . . . . . . . , . . . . . . . . . . . . . . , . . . . . . . . , . . J. . . . . . . . . ,,' . .,,; "':" :;;,." ,~. - 1~~lJIliiH."'" r..' ,- " r ". _.' . ~ ..,;.... '~ r?(7l /} /.' - 1/1' '-2 ~fl"!:?I4( ~?(~ /;],9C:';' 07J;:t, ':2 f'l'f'P. "11&' Id(iT)' lL1?J /o-<;C: I 17 L. . T ;. . 11II ~__M".~,~, "'.<' ..~,."",,. <~ .~~ -~ ). ~f ,~' _ ..,,_ ~ ~~'>"''''~~' "~.' . _ V" ~, '" . ,C, ~,~,,<" ~,=" ,,,_ _ H '" .~, "-";'" ..I~I f Page 1 of8 MARITAL AGREEMENT THIS AGREEMENT, made this 2nd day of January, 2001, by and between Terry B. Chamberlin, hereinafter referred to as Husband, of 77 Rustic Drive, Shippensburg, Cumberland County, Pennsylvania 17257, and Lisa D. Chamberlin, hereinafter referred to as Wife, of Magnolia #3, 34 Brindle Drive, Fayetteville, Franklin County, Pennsylvania 17222. WITNESSETH: WHEREAS, the parties hereto are Husband and Wife, having been married on November 29, 1997, at the Middle Spring Presbyterian Church, Shippensburg, Cumberland County, Pennsylvania, with no children having been born of the marriage; and WHEREAS, diverse unhappy differences, disputes and difficulties have arisen between the parties and it is the intention of Wife and Husband to live separate and apart, and the parties hereto are desirous of settling some of their respective financial and property rights and obligations as between each other including, without limitation by specification: the equitable division of marital property; and the settling of all matters between them relating to the past, present and future support, alimony and/or maintenance of Wife by Husband or of Husband by Wife. NOW, THEREFORE, in consideration of the premises and of the mutual promises, covenants and under takings hereinafter set forth which are hereby acknowledged by each of the parties hereto, Wife and Husband, each intending to be legally bound hereby, covenant and agree as follows: AGREEMENT NOT A BAR TO DIVORCE PROCEEDINGS This Agreement shall not be considered to affect or bar the right of Wife or Husband to a limited or absolute divorce on lawful grounds, if such grounds exist or shall hereafter exist or to such defense as may be available to either party. This Agreement is not intended to condone and shall not be deemed to be a condonation, on the part of either party hereto, of any act or acts on the part of the other party which have occasioned 'the disputes or unhappy differences which have occurred prior to or which may occur subsequent to the date hereof. The parties intend to secure a mutual consent, no-fault divorce pursuant to the terms of Section 3301(c) of the Pennsylvania Divorce Code of 1980, as amended. EFFECT OF DIVORCE DECREE The parties agree that unless otherWise specifically provided herein, this Agreement shall continue in full force and effect after such time as a final decree in divorce may be entered with respect to the parties. WEiGLE, 'PERKiNS & ASSOCIATES - ATTORNEYS AT LAW - 126 EAST KING STREET - SH1PPENSBURG, PA 17257-1397 ','~''''~ I",' ,'. '..;......;.ili'" ~, "'~ai~: , Page 2 of8 AGREEMENT TO BE INCORPORATED IN DIVORCE DECREE The parties agree that the terms of this Agreement may be incorporated into any divorce decree, which may be entered with respect to them. DATE OF EXECUTION The "date of execution" or "execution date" of the Agreement shall be defmed as the date upon which it is executed by the parties if they have each executed the Agreement on the same date. Otherwise, the "date of execution" or "execution date" of this Agreement shall be defmed as the date of execution by the party last executing this Agreement. ADVICE OF COUNSEL The provisions of this Agreement and their legal effect have been fully explained to Terry B. Chamberlin, by Jerry A. Weigle, Esquire, who is attorney for husband and who prepared this marital agreement. Wife, Lisa D. Chamberlin, acknowledges that she has been advised of her right to seek independent legal counsel and she has decided not to do so. Both parties acknowledge that they fully understand the facts and have been fully informed as to their legal rights and obligations and understand the same. The parties hereto further acknowledge and accept that this Agreement is, in the circumstances, fair and equitable and that it is being entered into freely and voluntarily after having received such advice and with such knowledge, and that execution of this Agreement is not the result of any duress or undue influence and that it is not the result of any collusion or improper or illegal agreement or agreements. PERSONAL RIGHTS Wife and Husband may and shall, at all times hereafter, live separate and apart. They shall be free from any control, restraint, interference or authority, direct or indirect, by the other in all respects as fully as if they were unmarried. They may reside at such place as they may select. Each may, for his or her separate use or benefit, conduct, carry on and engage in any business, occupation, profession or employment, which to him or her may seem advisable. Wife and Husband shall not molest, harass, disturb or malign each other or the respective families of each other nor compel or attempt to compel the other to cohabit or dwell by any means or in any manner whatsoever with him or her. SEPARATION DATE The parties do hereby acknowledge that they separated on November 20, 1999. It is hereby agreed that November 20, 1999 shall be the separation date for purposes of equitable distribution under the Pennsylvania Divorce Code unless altered by subsequent agreement of the parties in writing and signed by each of the parties. No attempt at reconciliation shall be considered to alter the separation date unless evidenced by written agreement. WEIGLE, PERKINS & ASSOCIATES - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 '" ..., ' hi:!l'~' - ,.,:"'~::':: Page 3 of8 MOBILE HOME The parties agree that Husband shall become the sole and exclusive owner ofthe parties' marital residence - a 1998 Dutch Champion double-wide mobile home presently titled jointly. Parties further agree that Husband shall be solely responsible for all payments on a present installment sales loan for the purchase of said mobile home borrowed through the Pennsylvania National Bank with an approximate payoff balance of Thirty-eight Thousand Dollars ($38,000.00). Husband shall make any and all reasonable efforts to have Wife's name removed from said mobile home obligation at the earliest possible time after execution of this marital agreement. MOTOR VEHICLES A. The parties agree that Wife shall become the sole and exclusive owner of the parties' 1996 Ford Mustang convertible motor vehicle presently titled in both names. Wife shall be solely responsible for all payments on the automobile loan for this vehicle borrowed through the Farmers & Merchants Bank at Chambersburg, Pennsylvania, with an approximate payoff balance of Eleven Thousand Dollars ($11,000.00). Wife shall make any and all reasonable efforts to have Husband's name removed from said motor vehicle obligation at the earliest possible time after execution of this marital agreement. B. The parties agree that Husband shall become the sole and exclusive owner of a certain 1986 Ford F150 one-half ton pickup truck motor vehicle presently titled in Husband's name only which is presently owned free and clear of any debt thereon. PERSONAL PROPERTY Husband and Wife do hereby acknowledge that they have previously divided their tangible personal property, including but not limited to jewelry, clothes, furniture, furnishings, rugs, carpets, household equipment and appliances, vehicles, pictures, books, works of art and other personal property and hereafter Wife agrees that all of the property in the possession of Husband shall be the sole and separate property of Husband and Husband agrees that all of the property in the possession of Wife shall be the sole and separate property of Wife. The parties do hereby specifically waive, release, renounce and forever abandon whatever claims, if any, he or she may have with respect to the above items, which shall become the sole and separate property of the other. AFTER-ACOUIREDPERSONALPROPERTY Each of the parties shall hereafter own and enjoy, independently of any claim or right of the , other, all items of personal property, tangible or intangible, hereafter acquired by him or her, with full power in him or her to dispose of the same as fully and effectively, in all respects and for all purposes, as though he or she were not married. WEIGLE, PERKINS & ASSOCIATES - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257~1397 . ~",,'< , '~~ Page 4 of8 PENSION BENEFITS Parties hereby acknowledge and agree that Wife has no present pension benefit of any kind. Parties further acknowledge and agree that Husband will someday be entitled to a military pension benefit. Wife hereby waives any right, title or interest she may now have or ever have in Husband's military pension benefit. WARRANTY AS TO EXISTING OBLIGATIONS Each party represents that he or she has 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 and hold the other party harmless from and against any and all such debts, liabilities or obligations of every kind which may have heretofore been incurred by them, including those for necessities, except for the obligations arising out of this Agreement. WARRANTY AS TO FUTURE OBLIGATIONS Wife and Husband each covenant, warrant, 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 may be otherwise specifically provided for by the terms of this Agreement and that neither of them shall hereafter incur a liability whatsoever for which the estate of the other may be liable. LUMP SUM PAYMENT TO WIFE In consideration of Wife's waiver of all rights arising from the marital relationship except as provided in this Marital Agreement, Husband shall pay to Wife the sum of Three Hundred Dollars ($300.00) on or before December 31, 2000. LEGAL FEES Husband shall pay the cost of legal fees incurred in preparation of this marital agreement and all legal fees and court costs in connection with obtaining a 3301(c) No-Fault Divorce. Wife agrees to cooperate by executing the necessary consents and other documents required to effectuate said divorce, as requested by Husband's attorney. INCOME TAX RETURNS The parties agree to file separate federal and state income tax returns. WEIGLE, PERKINS & ASSOCIATES - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 '11iI " , ' ~,' ,~, - .'._.;.'~,:,,,', '<<'!" '1""L"""""""'j Page 5 of8 MUTUAL RELEASES Husband and Wife each do hereby mutually remise, release, quitclaim and forever discharge the other and the estate of each other, for all time to come, and for all purposes whatsoever, of and from any and all rights, 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 whatsoever 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 or by way of dower, courtesy, or claims in the nature of dower or cour(esy 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 testaInentary, or all other rights of a surviving spouse to participate in a deceased spouse's estate, whether arising under the laws of (a) Permsylvania, (b) any State, Commonwealth or territory of the United States, or (c) any other country, 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 provision thereof. It is the intention of Husband and Wife to give to each other by the execution of this Agreement a full, complete and general release with respect to any and all property of any kind or nature, real, personal or 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 provision thereof. WAIVER OR MODIFICATION TO BE IN WRITING No modification or waiver of any of the terms hereof 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. DIVORCE The parties hereto agree to enter into a mutual consent divorce under Section 3301(c) of the Pennsylvania Divorce Code of 1980, as amended. Husband agrees to pursue the present divorce action filed to No. 2000-5869 Civil, 2000, in the Court of Common Pleas of Cumberland County, Pennsylvania, and to be the Plaintiff therein. Wife agrees to sign the necessary documents, including the Affidavit of Consent, at such time after the ninety (90) days of filing of the Complaint and further instruments that may be reasonably required to give full force and effect to the provisions of this , Agreement. WEIGLE, PERKINS & ASSOCIATES - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 -,.1"' '.'~'~~j , Page 6 of8 MUTUAL COOPERATION Each party shall, at any time and from time to time hereafter, take any and all steps and execute, acknowledge and deliver to the other party any and all future instruments and/or documents that the other party may reasonably require for the purpose of giving full force and effect to the provisions of this Agreement. LAW OF PENNSYL VANIA APPLICABLE This Agreement shall be construed in accordance with the laws of the Commonwealth of Pennsylvania. AGREEMENT BINDING ON HEIRS This Agreement shall be binding and shall insure to the benefit of the parties hereto and their respective heirs, executors, administrators, successors and assigns. BREACH If either party breaches any provision of this Agreement, the other party shall have the right, at his or her election, to sue for damages for such breach or seek such other remedies or relief as may be available to him or her, and the party breaching this contract shall be responsible for payment of legal fees and costs incurred by the other in enforcing their rights under this Agreement. WAIVER OF ALIMONY AND OTHER RIGHTS The parties hereto have been informed of their rights or have been advised to seek counsel to inform them of their rights under and pursuant to the Divorce Code, Action of April 2, 1980, Number 1980-26, as amended, particularly the provisions for alimony, alimony pendente lite, equitable distribution of marital property, counsel fees or expenses. Both parties agree that this Agreement shall conclusively provide for the distribution of property under the said law and except as specifically provided for in this agreement, hereby waive, release and relinquish any further rights they may respectively have against the other for alimony, alimony pendente lite, equitable distribution of marital property, counsel fees or expenses. From the date hereof, each party may acquire either personal or real property in their own name. Any property so acquired shall be owned solely by the individual and shall not be subject to any claim whatsoever by the other party. FINANCIAL DISCLOSURE The parties confIrm that they have relied on the substantial accuracy of the financial disclosure of the other as an inducement to the execution of this Agreement. WEIGLE, PERKINS & ASSOCIATES - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 u ,. ..' " "' '''"-<','',- ~I.Ll.j~ , Page 7 of8 ENTIRE AGREEMENT 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. NO WAIVER OF DEFAULT This Agreement shall remain in full force and effect unless and until terminated under and pursuant to the terms of this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall in no way affect the right of such party hereafter to enforce 'the same, nor shall the waiver of any breach of any provision hereof be construed as a waiver of any subsequent default of the same or similar nature, nor shall it be construed as a waiver of strict performance of any other obligations herein. SEVERABILITY 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 provisions 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 her or his obligations under any one or more of the paragraphs herein, with the exception of the satisfaction of the conditions precedent, shall in no way void or alter the remaining obligations of the parties. HEADINGS NOT PART OF AGREEMENT Any headings preceding the text of the several paragraphs and subparagraphs hereof are inserted solely for convenience of reference and shall not constitute a part of this Agreement nor shall they affect its meaning, construction or effect. VOLUNTARY EXECUTION The provisions of this Agreement and their legal effect have been fully explained to the parties by their respective counsel, and each party acknowledges that the Agreement is fair and equitable, that it is being entered into voluntarily, and that it is not the result of any duress or undue influence. IN WITNESS WHEREOF, the parties hereto have set their hands and seals the day and year first above written. -- TNESS: q, Jtd It 1f1 -----. d . :7~ If. _Lt, TERR . ~ERLIN . ~m..-U Q 1n,cvk rUe ~ ') L A a. CHAMBERLIN WEIGLE, PERKINS & ASSOCIATES - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSSURG, PA 17257-1397 ;." '11' ~~1i , Page 8 of8 COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF CUMBERLAND On this, the ~ day of ~ , 2000, before me a Notary Public, the undersigned officer, personally appeared Terry B. Chamberlin, known to me to be the person whose name is subscribed to the within Agreement and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and seal. q, (SEAL) NOTARIAL SEAL . Jerry A, Weigle, Notary Pu Shippensburg. PA Cumbertand ounty M Commission Ex ire October 01 2002 COMMONWEALTH OF PENNSYL VANIA SS COUNTY OF J ~ ,),(}'O I On this, the cJfI day of 1) '-I IJ ,~, before me a Notary Public, the undersigned officer, personally ap ed Lisa t~hfunberlin, known to me to be the person whose name is subscribed to the within Agreement and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and seal. (SEAL) TAMMIE S. HOCK, Notary Public Fayetteville. Franklin County My Commission Expires ~ay 3, :.:004 WEIGLE, PERKINS & ASSOCIATES - ATTORNEYS AT LAW ~ 126 EAST KING STREET ~ SHIPPENSBURG, PA 17257-1397 ~"~~I<!irr ~~. 1 1 'ilimN_ ..~ _ ,~ ^"". ",." ,;,' -" ^,,"'(.- ,0< '1 '""--;"';~ " -. .~ '^""" , "," ,', ,-,' Ji.Jlli'ti. -'-"- '>;" _'''c'-' , ~. ^," ',i, '"', ,~ . - ~ -, -". .'Jr I, . ! I f!' .c 0 "~ i~ i;; '-..r'l ::;;:1 ~~ :e r:1J :J1 - r- \0 ::'g[Q ;:~'r' :;;;0 ~,."~ ,. lo ~ :;:1~} ::r :~{?1 ~ ~ ,~"srn ::::> .::-i C $ -< "-'~ , " ,,<,-, ," " -"~,~~ ~.~ "~, ~.~ ,,~ '" ~. <,' '" ".".'J " ~+ , ,. , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYL VANIA TERRY B. CHAMBERLIN Plaintiff, CIVIL ACTION - LAW vs. NO. 2000-5869 LISA D. CHAMBERLIN, Defendant. 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: 1. Grounds for divorce; irretrievable breakdown under 9 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: August 28, 2000, by mailing postage paid, certified mail, addressee only, and return receipt requested at Shippensburg, Pennsylvania. 3. Date of execution of the affidavit of consent required by 9 3301(c) of the Divorce Code: by Plaintiff, December 14,2000; by Defendant, December 2, 2000. 4. Related claims pending: The attached Marital Agreement between the parties dated January 2, 2001, shall be incorporated but not merged into this Decree in Divorce pursuant to the said Agreement. 5. Date Plaintiffs Waiver in 9 3301(c) Divorce was filed with the prothonotary: December 20, 2000. Date Defendant's Waiver of Notice in 9 3301(c) Divorce was filed with the prothonotary: December 20, 2000. Jerry A. Wei e, Esquire Attorney for Paintiff Attorney ID #01624 126 East King Street Shippensburg, P A 17257 Telephone (717)532-7388 WEIGLE, PERKINS & ASSOCIATES - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 ,- ,." ,),,,v _',~ ',,"' , .,c, _;" .;,c...._ '"" "^'_"~'_':.: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA TERRY B. CHAMBERLIN Plaintiff, CIVIL ACTION - LAW vs. NO. {)(XXJ:"''J'1iCo9 LISA A. CHAMBERLIN, Defendant. IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court. A judgement 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 grounds 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, PA 17013. 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 Connty Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 WEIGLE, PERKINS & ASSOCIATES - ATTORNEVS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 " ", , ". ~,' -" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA TERRY 8.. CHAMBERLIN Plaintiff, CIVIL ACTION - LAW vs. NO. i/V-S?&'l ~~ LISA A. CHAMBERLIN, Defendant. IN DIVORCE COMPLAINT IN DIVORCE COUNT I IRRETRIEVABLE BREAKDOWN AND NOW, comes the above named Plaintiff, Terry B. Chamberlin, by and through his attorneys, Weigle, Perkins & Associates, and Jerry A. Weigle, Esquire, and seeks to obtain a Decree in Divorce from the above-named Defendant, upon the grounds hereinafter more fully set forth: 1. Plaintiff, Terry B. Chamberlin, is an adult individual presently residing at 77 Rustic Drive, Shippensburg, Cumberland County, Pennsylvania, since 1998. 2. Defendant, Lisa A. Chamberlin, is an adult individual presently residing at, Magnolia #3, 34 Brindle Drive, Fayetteville, Franklin County, Pennsylvania, since March 2000. 3. The Plaintiff and Defendant are nationals and citizens of the United States of America, and both have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of the Complaint in Divorce. 4. The Plaintiff and Defendant were married on November 29, 1997, at the Middle Spring Presbyterian Church, Shippensburg, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties or in any other jurisdiction. 6. Plaintiff has been advised that counseling is available and the Plaintiff may have the right to request that the court require the parties to participate in counseling. 7. The marriage is irretrievably broken. 8. The parties have lived separate and apart since November 20,1999. 9. The Plaintiff requests the court to enter a decree of divorce. WEIGLE, PERKINS & A5S0CIATES - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG. PA 17257~1397 ~ "' ;," L " '< -';';-";;" '~'~~i , COUNT n - EQUITABLE DISTRIBUTION 10. Paragraphs 1 through 9 of Plaintiff's Complaint are incorporated herein by reference as though set forth in full. 11. Plaintiff and Defendant have legally and beneficially acquired property, both real and personal, during their marriage from November 28, 1997, until November 1999, date of separation, all of which property is "marital property". 12. Plaintiff and/or Defendant have acquired, prior to the marriage or subsequent thereto, "non-marital property" which has increased in value since the date of the marriage and or subsequent to its acquisition during the marriage, which increase in value a marital property. 13. Plaintiff and Defendant have been unable to agree as to an equitable division of said property to the date of the filing of this Complaint and substantial portions of said property are in the exclusive control of Defendant. 14. Plaintiff requests the Court to equitably divide all marital property. WHEREFORE, Plaintiff requests the Court to equitably divide all marital property and to enjoin Plaintiff and Defendant from the removal, disposition, alienation, or encumbering of all real and personal property of the parties. By: WEIGLE, PERKINS AND ASSO eigle, Es . re Attorney or Plaintiff Attorney 1D # 01624 126 East King Street Shippensburg, P A 17257 Telephone (717)532-7388 WEIGLE. PERKINS & ASSOCIATES - ATTORNEVS AT LAW - 126 EAST KING STREET - SHIPPENSBURG. PA 17257-1397 -;" <~,' ~,'^'~,'~,-'" -~ <, ..........., VERIFICATION I verify that the statements made in the foregoing Complaint in Divorce are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa C.S. 9 4904, relating to unsworn falsification to authorities. Dated; y4,'1/o0 -=;,r - .g, f'7L Terry if.' Chamberlin, Plaintiff WEIGLE, PERKINS & ASSOCIATES - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257~1397 -,- ". , --'. '" ,,;,~- - ""~:l . . " ~ ~ . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA TERRY B. CHAMBERLIN Plaintiff, CIVIL ACTION - LAW vs. NO. 2000-5869 LISA A. CHAMBERLIN, Defendant. IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER 11330Hc) AND 11330Hd) OF THE DIVORCE CODE 1. I consent to the entry of a [mal decree of 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 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. 9 4904 relating to unsworn falsification to authorities. Dated: / l..//l./ 100 WE'GLE, PERKINS 8 ASSOCIATES - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257~1397 I' .. _JiI'!rlVr~~ ',-",,-~ "J."~'"'L-';""""jt"'jl;;4j . ... --. ,',",,~ ,,,. "'~,='"",",, "",,,,. ..-; -~ f'-";"~~I~~'.:tfl . - ~- G~ #'-~i~'" tIM. ~ , ~ ... :.,,;' " l () (J~ Jnk~i .2::'"1' 0<S~';> r::~_-) ~"o .2:. C'" J:;: -, c:: .2:: =< Ul 'Jj C:-J c::; ':::J ''''1 ::-;, !'oJ t::'"i s~ 'i:----- --r, :::i G~ ~ - .;." ~ '~__~"'''' ~ "",0'"_,,,",: __ , ~~j .. , ... IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA TERRY B. CHAMBERLIN Plaintiff, CIVIL ACTION - LAW vs. NO. 2000-5869 LISA A. CHAMBERLIN, Defendant. IN DIVORCE AFFIDAVIT OF CONSENT I. A complaint in divorce under 9 3301(c) of the Divorce Code was filed on August 25, 2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety 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 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. 9 4904 relating to unsworn falsification to authorities. Dated: /2. /;yloO ------ ~ - J~ 6' .L.L Terry . Chamberlm, P1amtiff WEIGLE, PERKINS & ASSO<::JATE5 - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 ~~~~~Mil..'i\M~$.itolll~~ll1!j~~~~r-' .... l!>">;_," ~~,-,- ~""~ ..,.""""" V',_, ,_ r~' ' -~< -" b.:. ... ,,.. (') C: <'"" ""tJ-;~ rr"' c...~. ;;!/7::' ~~-~' f:$ ;~ ::::::' ' -p:- ZO -- ~-.. ~C z -j '"" ^~-- ~, ,~,~ ~'- :n <'0 - C;; C:) .c::::J r-i~l C") '--..' ';",1 :;-'1 ,....'J (::;, -,~ --;.: --,~ ~:~ - - ~ ~~!R: . , d _ _~ .." ' '.' -"'~ ",~". '. ~~ . . or . - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA TERRY B. CHAMBERLIN Plaintiff, CIVIL ACTION - LAW vs. NO. 2000-5869 LISA A. CHAMBERLIN, Defendant. IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER & 3301(c) AND & 3301(d) OF THE DIVORCE CODE 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. 9 4904 relating to unsworn falsification to authorities. Dated: I a ~ :;) r 00 c/~cJ).C,~~~~ Lisa A. Chamberlin, Defendant WEIGLE, PERKINS & ASSOCIATES - ATTORNEVS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 ~ ;\;.,;.;.ti* _ O"~""'_~^'~" ~~~:ti!r-.. ~~IEM?i\ii\ijIW ,""""',.-- -~M' - '<" "'-",~"'-..i-.VrJdlt"" ".'~'j.rrIM -- ~., " - 0 <:::> ,~".... 'j C 0 ;:Ch :<S. 0 -o,ca '-'., mrTi W !"--'~ 2:7,' 2:,; <'0 ~) fEI CJ ,'~ C/)~__ "... J -< " '7)~~ ~C v )::-,.C' -,? ,;-'\'::!J ZC,,' ~7:(2 ;po .' :.,:, br'l C ~-; :z: -:J'1 e -) ~J -~ \..{) -< , m:; . , ,'- '" ...' --, " : ''''Il!llIUlllrn!!iL " . , , , , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA TERRY B. CHAMBERLIN Plaintiff, CIVIL ACTION - LAW VS. NO. 2000-5869 LISA A. CHAMBERLIN, Defendant. IN DIVORCE AFFIDAVIT OF COl'!SENT 1. A complaint in divorce under 9 3301(c) of the Divorce Code was filed on August 25, 2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety 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 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. 9 4904 relating to unsworn falsification to authorities. Dated: I d~.:J -00 ~,~~) Lisa A. Chamberlin, Defendant WEIGLE, PERKINS & ASSOCIATES - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257~1397 '';'"-''-~1!IJ1''jililiJ~f!m'alioo:tl1~ a.b.liIitilllJ~ ~ "-Mr.~~lil.~;j' ,~~.. ". "'- ~ .-- ",-" , -~ < .,' ,'" -"" .~ u ;"..ki>,"'"~jj, ~ '......Li h "" " ~ ~," - " "~ " () a c .~ a '-,j :K~ a -Jj "1'1(':", mf-[: "1 2:r-;' 0 2:t;:'" !'~ CD" 0 ;:s ": " <c -CI :;':!i~) )> 2:C .. ,S~~~ ~O - Pc S~ 2: ~ =< ':.11 5;! tD 5:J "< fr1"'; ~ - ,< .-. ^ < ",,-,~ '"',,..,.'" ' ~,.- . . . .. ..... IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA TERRY B. CHAMBERLIN Plaintiff, CIVIL ACTION - LAW vs. NO. 2000-5869 LISA A. CHAMBERLIN, Defendant. IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA 9 COUNTY OF CUMBERLAND Jacolyn Moose, being duly sworn according to law, deposes and says that on August 28, 2000, she served true and attested copies of Complaint upon the Defendant, Lisa A. Chamberlin, by mailing the same postage paid, certified mail, addressee only, and return receipt requested, at Shippensburg, Pennsylvania, addressed as follows; Lisa Chamberlin Magnolia #3 34 Brindle Drive Fayetteville, P A 17222 SE Sworn lR and subscribed before me this 50 day of C!2d.-e!vA-- ,2000. Jl-bv ; j ~~ P, Notar,y Public -(~ Notarial Seal . Patricia L. Tome, Notary PUbleoic \y Shippensburg Bora, Cumbeiland un My Commission Expires June 7, 2004 .. WEIGLE, PERKINS & ASSOCIATES - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 ;~ ~-~ it ~"'~. - .. . -, I/O IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA TERRY B. CHAMBERLIN Plaintiff, CIVIL ACTION - LAW VS. NO. 2000-5869 LISA A. CHAMBERLIN, Defendant. IN DIVORCE PROOF OF SERVICE C;; SElNDl!!R: ~ . Complete items 1 and/or 2 for additional services. .(;j . Complete items 3, 4a, and 4b. Q) . Print your name and address on the reverse of this form so that we can return this ~ card to you. .. > . Attach this form to the fronl of the ml:1i1piece, or on the back if space does not 2:! permit. Q) . Write "Return Receipt Requested" on themailpiecE;l..below the article number. . The Return Receipt will show to whom the articleIWjts,-delivered and the dale -S delivered. 5 3. Article Addressed to: 'C .. 1ii ii. E o u L\~ A,Cha.ml::le("hi\ MacJf'lOha...* 3 , 34 6rll"d\e OrlVe fU'{e++evt\le) ?f\ l'\d.~~ oi u .~ .. CIl a .~ u .. 10 'f. 3Jao'ooo1-CjM -/ OS5~ 4b. Service Type :; o Registered ~ Certified ~ o Express Mail 0 Insured g ~ Return Receipt for Merchandise 0 COO .~ 7. ~Of~li ery -0 ~ '" 8. Addressee's Address (Only if requested .lI:: and fee is paid) i .<:: ' .... I also wish to receive the following services (for an extra fee): i.1St Addressee's Address 2, M Restricted Delivery Consult postmaster for fee. 4a. Article Number ~ " o '" :.lI.I '~$Fj:Jrm.11,1[)e<jember1~94 Ii! J38~ :::r~'0229 Domestic Return: Receipt 'T~-~ I: U.S. Postal Service CERTIFIED MAIL IRECEIPT (Domestic Mall Only; No Inswallce Covel age PrOVided) ;:r .-"I lr o ['- o o '0 Postage $ -- ...t.v':" LO d l\',,>,,- CnD.l'Y\berh;" r'l Certified Fee --- Retum Receipt Fee (Endorsement Required) Restricted Delivery Fee (Endorsement Required) ____\ r .' ~/ "oJ~ en}! ;<;ro J ./'1 / 1,'/ f.i:-:~ II:J '? Y -....0~ Total postage & Fees $ 3ZJ o ru ru Name (Please Print Clearly) (To be completed by mailer) I m _kj.?~"mCh(1mb_f..d!.C\..","m.mm'''...''''..''.m_.~...m.m.j [f"" Street, Apt. No.; or PO BOK No.. ' ~ ffi';\. 0.dJ.~..~_3.)......3..~...J~.Ll0.fJ.L~,.m;:QCt'!..~...m._..1 ['- ell" ata,ti'-te ,,\ e. f\ ) 'I d. cl. d- :11 . .'Ild~Mt'f8J'f~!imt,illill<~HW"JIk.t1~~~~~~,~~loIIlUil'''''"-''' -~....-~'"- ., . . 0_ ._ '~~,,'~. ,'-~.- "' ." ^ '""""'" -0'" ,_,'_,"~~ ~', .' -,". - ... (') C C c: :s: 2 -Ow C n1rT: <- Z:D Z, I --, ,', !:QE: <..: L ~O C ~O ::;: 5>0 r;.; c ':j;-j, ~ N (]'. .'jJ ~< " '. ,,," .,,~ ,~" H~I;; ~ . - f,'," , '........'. iil,;il;J ~,"', ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA TERRY B. CHAMBERLIN Plaintiff, CIVIL ACTION - LAW VS, NO. 2000-5869 LISA D. CHAMBERLIN, Defendant. IN DIVORCE PRAECIPE TO AMEND CAPTION TO THE PROTHONOTARY: Please amend the caption ill the above case to read "Terry B. Chamberlin vs. Lisa D. Chamberlin" thereby correcting the name of the Defendant which was erroneously captioned as "Lisa A. Chamberlin" . WEIGLE, PERKINS & ASSOCIA ES -' 01 Ie A. Wei Ie, Esquire Att rney for aintiff Attorney ID #0 624 126 East King Street Shippensburg, PA 17257 Telephone (717)532-7388 WEIGLE, PERKINS & ASSOCIATES - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 IIUI!IIII'"M' ~~"'~'. - __c_7'O;__, '0' ~~~1l'lr"""~'"~ '1lMlII '- ~~ Q ~~~ zc- (/)-'; ~t~.. ~~~ ).-":-C' :?3 .... , ,~ (;:"..; , ';'.1ID -'-,' ("v ::"..) '-' :;:;1 :0 -, .:..,.) ()1 ME _........-..---'"~.'"...... - "" " -, , ',- -"'IV.!' u IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW .. c, "O.J'r~L'" h '\ T e.rr~ ~. Plaintiff ,. File No. .;)60D - oS8 109 vs. IN DIVORCE UhClrnbe.r\" 1'\ \.:,<;0...... 1). Defendant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff/Defendant in the above matter. having been granted a Final Decree in Divorce on the ..jL\-:!:D day of 1I00(\I..J.(;u-Y '.' ~OO,. here~y elects to resume the prior surname of \...:\'Sa...1)o.'NY'\€_ 'v-l \ 1\ ,()..t\'\S , and gives this written notice pursuant to the provisions of 54 P.S. S 704. DATE: \l\0S'&, \ 1.\ ) 'd.OO2> ~I~ ( ~~~ . Signature ~~~f~sumed COMMONWEALTH OF PENNSYLVANIA: FrILl'll<. (,'n 55. COUNTY OF eUlIBEltLAl<lD On the J,t-fA day of fflafe...A bloo 3. before me, a Notary Public. personally appeared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged tha t he /she execu ted the foregoing for the purpose therein'contained. In Witness Whereof. r have here':"nto set my hand and official seaL , '1fa~ J ~t/k. c== Notary Public NOTARIAL SEAL TAMMIE S. HOCK, Notary Public Fayetteville, Franklin County My Commission Expires May 3. 2004 ,dS.':~""""~''''~:''''''~_Mli'JI'1~~t<'-i~ilt4iJf~~<ii~\lJJ~m;~r~iliJ1.d.Ji.'''i':'i''Jb''''>-'''",.,-"ol~ilUCi~'1iI_~!l.JI .' .rtl ~ -. :<"':"'"'il':m;li1'i~"~~."~~~ " "! r t -\J 0 (':::.' \~ c t,~,: >'- ;s: ""Dee . ~ Q)t~" ..-... \)V "I 7[~- v\ .-) (7) ';I~ 'cr,) -< ~i ~~,- "'"' l~- -D ..c.. g ; ",'" -",~ . '(C) "-tl :.0 ?:S~Tl { 7:" :::> 5~ -~ -< .' -< fr!'~