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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
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PATRICIA A. CONNER,
PENNA.
STATE OF
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No.
CIVIL
00-5959
Plaintiff
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VERSUS
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STEPHEN S. CONNER,
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Defendant
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DECREE IN
DIVORCE
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CJe:.ML- 5 ~ ,7-(JQ L
IT IS ORDERED AND
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AND NOW,
PATRICIA A. CONNER
DECREED THAT
, PLAINTIFF,
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AND
~~RPHRN S rnNNRR
, DEFENDANT,
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ARE DIVORCED FROM THE BONDS OF MATRIMONY. The terms of the
Marriage Settlement Agreement entered into by the parties
on October 23, 2001, are incorporated herein.
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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None
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AGREEMENT
BETWEEN
PATRICIA A. CONNER
AND
STEPHEN S. CONNER
Kathleen Carey Daley, Esquire
Counsel for Wife
Stephen S. Conner
Pro se
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TABLE OF CONTENTS
SECTION I:
Introduction .................................................................. 3
SECTION II:
General Provisions. . . . . . . . . . . . . . . . . . . . . . . . . . . ' . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , 4
SECTION III:
Alimony, Alimony Pendente Lite and Custody Provisions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
SECTION IV:
Property Distribution Provisions ......'.......................................... 10
SECTION V:
Closing Provisions and Execution . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
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SECTION I
INTRODUCTION
THIS AGREEMENT made this ~.3 day of (JJ-:r~ ,2001, by and
between Patricia A. Conner ("Wife") and Stephen S. Conner ("Husband").
WITNESSETH:
WHEREAS, Patricia A. Conner, Social Security Number 195-56-3459, was born on January
20, 1962, and currently resides at 5253 Deerfie1d Avenue, Mechanicsburg, Cumberland County,
Pennsylvania 17050.
WHEREAS, Stephen S. Conner, Social Security Number 190-54-5850, was born on March
18, 1960, and currently resides at 500 Walnut Street, Apartment A5, Lemoyne, Cumberland County,
Pennsylvania 17043.
WHEREAS, the parties hereto are Husband and Wife, having been married on June 1, 1985,
in Camp Hill, Cumberland County, Pennsylvania.
WHEREAS, the parties have two minor children, to wit: Meghan Barbara Conner, DOB
September 3,1987, and Matthew Richard Conner, DOB May 11,1990.
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 for the rest of their
natural lives, and the parties hereto are desirous of settling fully and finally their respective financial
and property rights and obligations as between each other, including, without limitation, the settling
of all matters between them relating to the ownership of real and personal property, the equitable
distribution of such property; the settling of all matters between them relating to the past, present and
future support and/or maintenance of Wife by Husband or of Husband by Wife; and, in general, the
settling of any and all claims and possible claims by one against the other or against their respective
estates.
NOW, THEREFORE, in consideration of the mutual promises, set forth herein and for
other good and valuable considerations, Wife and Husband, each intending to be legally bound
hereby agrees as follows:
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SECTION II
GENERAL PROVISIONS
1. MUTUAL CONSENT DIVORCE
The parties intend to secure a mutual consent, no fault divorce pursuant to the provisions of
g3301(c) of the Divorce Code of 1980, as amended and will execute the documents necessary to
effectuate a divorce under those provisions concurrently with the execution of this Agreement.
2. 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.
3. AGREEMENT TO BE INCORPORATED BUT NOT MERGED IN DIVORCE
DECREE
The provisions of this Agreement may be incorporated by reference but shall not be deemed
merged into any judgment or decree for divorce obtained by either party. This Agreement shall
survive any such [mal decree of divorce, shall be entirely independent thereof, and the parties intend
that all obligations contained herein shall retain their contractual nature in any enforcement
proceedings, whether enforcement is sought in an action on the contract itself or in any enforcement
action filed to the divorce complaint.
4. DATE OF EXECUTION
The "date of execution" or "execution date" of this Agreement shall be defined as the date
upon which it is executed by the parties ifthey have each executed the Agreement on the same date.
Otherwise, the "date of execution" or "execution date" of this Agreement shall be defined as the date
of execution by the party last executing this Agreement.
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5. ADVICE OF COUNSEL
Kathleen Carey Daley, Esquire has prepared tbis Agreement on behalf of her client, Patricia
A. Conner, hereinafter Wife. Stephen S. Conner, hereinafter Husband, acknowledges that he has had
a right to have an attorney represent him in this matter. Husband further acknowledges that tbis is
an important legal document that is binding once both parties sign it, and that an adequate
opportunity to review the document and/or consult with an attorney has been provided to Husband
prior to signing tbis Marriage Settlement Agreement.
6. TAX PROVISIONS
The parties believe and agree, and have been so advised by their respective attorneys, that
the division of property heretofore made by this Agreement is a non-taxable division of property
between co-owners rather than a taxable sale or exchange of such property. Each party promises not
to take any position with respect to the adjusted basis of the property assigned to him or her or with
respect to any other issue wbich is inconsistent with the position set forth in the preceding sentence
on bis or her federal or state income tax returns.
The parties have heretofore filed joint federal and state tax returns. Both parties agree that
in the event any deficiency in federal, state or local income tax is proposed, or any assessment of any
such tax is made against either of them, each will indemnify and hold harmless the other from and
against any loss or liability for any such tax deficiency or assessment and any interest, penalty and
expense incurred in connection therewith. Such tax, interest, penalty or expense shall be paid solely
and entirely by the individual who is finally determined to be the cause ofthe misrepresentations or
failures to disclose the nature and extent of his or her separate income on the aforesaid joint returns.
7. PERSONAL RIGHTS
Wife and Husband may and shall, at all times hereafter, live separate and apart. They shall
be free from any contact, restraint, interference or authority, direct or indirect, by the other in all
respects as fully as if they were unmarried. Each may, for his or her separate use or benefit, conduct,
carry on and engage in any business, occupation, profession or employment wbich to bim 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 whatsoever with him or her.
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8. MUTUAL RELEASES
Except as otherwise expressly provided by this Agreement:
A. Each party hereby absolutely and unconditionally releases and forever discharges the
other and the estate of the other for all purposes from any and all rights and obligations which either
may have, or at any time hereafter have for past, present or future support or maintenance, alimony
pendente lite, alimony, equitable distribution, counsel fees, costs, expenses and any other right or
obligation, economic or otherwise, whether arising out of the marital relationship or otherwise,
including all rights and benefits under the Pennsylvania Divorce Code of 1980, its supplements and
amendments, as well as under any other law of any other jurisdiction, except and only except all
rights, agreements and obligations of whatsoever nature arising or which may arise under this
Agreement or for the breach of any provision thereof. Neither party shall have any obligation to the
other not expressly set forth herein.
B. Each party hereby absolutely and unconditionally releases and forever discharges the
other and his or her heirs, executors, administrations, assigns, property and estate from any and all
rights, claims, demands or obligations arising out of or by virtue of the marital relationship of the
parties or otherwise, whether now existing or hereafter arising. The above release shall be effective
regardless of whether such claims arise out of any former or future acts, contracts, engagements or
liabilities or the other or by way of dower, courtesy, widow'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 Pennsylvania, any state,
co=onwealth or territory or the United States, or any other country. It is expressly understood,
however, that neither the provisions of this release nor the subsequent entry of a divorce decree are
intended to defeat the right of either party to receive any insurance proceeds at the death of the other
of which she or he is the named beneficiary (whether the beneficiary designation was made prior or
subsequent to execution hereof), nor to defeat the right of either party to receive any legacy, bequest
orresiduary portion of the other's estate under his or her will, or to act as personal representative or
executor if so named by the will of the other, whether such will was executed prior or subsequent
to this Agreement.
C. Except for any cause of action for divorce which either party may have or claim to
have, and except for the obligations ofthe parties contained in this Agreement and such rights as are
expressly reserved herein, each party gives to the other by the execution of this Agreement an
absolute and unconditional release and discharge from all causes of action, claims, rights or demands
whatsoever, in law or in equity, which either party ever had or now has against the other.
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9. FINANCIAL DISCLOSURE
The parties have disclosed to each other and they are each aware of the extent of each other's
income, assets, liabilities, holdings and estate. Each of the parties acknowledges that he or she is
aware of his or her right to seek discovery including, but not limited to, written interrogatories,
motions for production of documents, depositions and all other means of discovery permitted under
the Pennsylvania Rules of Civil Procedure. Each party is satisfied that no additional information is
necessary for the execution of this Agreement.
10. PRESERVATION OF RECORDS
Each party will keep and preserve for a period offour (4) years from the date of their divorce
decree all financial records relating to the marital estate, and each party will allow the other party
access to those records in the event oftax audits.
11. 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 or any breach hereof or default hereunder shall be deemed a
waiver of any subsequent default of the same or similar nature.
12. REMEDIES IN THE EVENT OF A BREACH
Any party breaching this Agreement shall be liable to the other party for all costs, including
reasonable counsel fees incurred by the non breaching party to enforce his or her rights under the
provisions of this Agreement subsequent to the date of execution of this Agreement, regardless of
whether litigation is instituted. In the event of default of any ofthe provisions of this Agreement by
one ofthe parties, the remedies available to the other are cumulative and include all remedies at law
and in equity, including those for breach of contract, under theories or equity, under the Domestic
Relations Code as amended, including S 3105 of the Domestic Relations Code (which includes
contempt) as if this Agreement had been an Order of Court, and shall not be limited to those
remedies specifically referred to in this Agreement.
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13. LAW OF PENNSYLVANIA APPLICABLE
This Agreement shall be construed in accordance with the laws of the Commonwealth of
Pennsylvania.
14. AGREEMENT BINDING ON HEIRS
Except as may otherwise be provided, this Agreement shall be binding and shall inure to the
benefit of the parties hereto and their respective heirs, executors, administrators, successors, and
assigns.
15. INTEGRATION
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.
16. OTHER DOCUMENTATION
Wife and Husband covenant and agree that they will forthwith (within ten (10) days at most
after demand thereof) execute any and all written instruments, assignments, releases, satisfactions,
deeds, notes or such other writings as may be necessary or desirable for the proper effectuation of
this Agreement.
17. 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 hereofbe construed as a waiver
of any subsequent default of the same or similar nature, nor shall the waiver of any breach of any
provision hereof be construed as a waiver of strict performance of any other obligations herein.
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18. SEVERABILITY AND INDEPENDENT AND SEPARATE COVENANTS
The parties agree that each separate obligation contained in this Agreement shall be deemed
to be a separate and independent covenant and agreement. 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. Likewise, the
failure of any party to meet her or his obligations under anyone or more of the paragraphs herein,
with the exception ofthe satisfaction of any conditions' precedent, shall in no way avoid or alter the
remaining obligations of the parties.
19. MANNER OF GIVING NOTICE
Any notice required by this Agreement to be sent to Wife shall be sent by certified mail,
return receipt requested, to Patricia A. Conner, 5253 Deerfield Avenue, Mechanicsburg,
pennsylvania 17050, or counsel for Patricia A. Conner, or such other address as Wife from time to
time may designate in writing.
Any notice required by this Agreement to be sent to Husband shall be sent by certified mail,
return receipt requested, to Stephen S. Conner, 500 Walnut Street, Apartment A5, Lemoyne,
pennsylvania 17043, or counsel for Stephen S. Conner, or such other address as Husband from time
to time may designate in writing.
20. 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.
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SECTION III
ALIMONY AND ALIMONY PENDENTE LITE AND CUSTODY PROVISIONS
1. ALIMONY
The 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, alimony pendente lite
or alimony. Husband and Wife further, voluntarily and intelligently, waive and relinquish any right
to seek from the other payment for support, maintenance, alimony pendente lite or alimony.
2. CUSTODY
The parties acknowledge that they are the parents of Meghan Barbara Conner, DOB
09/03/87, and Matthew Richard Conner, DOB 05/11/90. Both children shall remain in the primary
legal and physical custody of their mother, Patricia A. Conner. Husband shall have periods of partial
custody with the children at such times as the parents can mutually agree.
SECTION IV
PROPERTY DISTRIBUTION PROVISIONS
1. PERSONAL PROPERTY
Husband and Wife do hereby acknowledge that they have previously divided their tangible
personal property including, but without limitation, jewelry, clothes, furniture, furnishings, rugs,
carpets, household equipment and appliances, pictures, books, works of art and other personal
property. 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 any claims which either may have with respect to the above items,
which shall thereafter be the sole and exclusive property ofthe other.
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2. RETIREMENT BENEFITS
Wife has accumulated benefits as the result of her employment with the Cumberland V alley
School District. The parties agree and acknowledge that these benefits shall be the sole and separate
property of Wife, free from any claim of any nature from Husband.
With regard to any other retirement benefits that may have been accumulated by either of the
parties, each party waives any right, title, interest or claim to the retirement benefits of the other
party.
3. BANK ACCOUNTS
During the course of their marriage, the parties had accumulated various accounts with
financial institutions. The parties have divided those accounts to their mutual satisfaction. The
parties hereby agree and acknowledge that there is one remainingjoint account that operates through
Commerce Bank at #0032077851 that continues to be used by Husband. Wife releases any right or
claim she may have to this account to Husband and Husband agrees to remove Wife's name from
this account within thirty (30) days of the date of this Agreement.
4. AUTOMOBILES
The 1997 Volvo Station Wagon currently operated by Wife and titled in her name, shall be
her sole and separate property, free from any claim of any nature by Husband. Wife shall indemnify
and hold Husband harmless from any liability related to the debt on this vehicle.
The parties agree and acknowledge that there is a leased BMW that is currently operated by
Husband. Husband agrees and acknowledges that he shall indemnify and hold Wife harmless from
any liability of any nature related to this vehicle.
5. CURRENT LIABILITIES
The parties are jointly and severely liable for a first and second mortgage on the residence
located at 5253 Deerfield Avenue, Mechanicsburg, Pennsylvania 17050. Wife has applied for a new
primary mortgage so as to satisfy these two existing joint liabilities. Until such time as these
liabilities are paid in full, Wife agrees to hold Husband harmless and indemnify him from any
liability related to these debts.
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With regard to any other liabilities of any nature that have been accumulated by the parties,
each agrees that any liabilities that have been accumulated since separation shall be the sole
responsibility of the party who has created that liability. Each party shall indemnify and hold
harmless the other party from his or her separate obligations.
6. LIFE INSURANCE
Any life insurance policies owned by either Husband or Wife shall be the sole and separate
property of the owner of the policy. Thus, any policies owned by Husband shall be his sole and
separate property, and any policies owned by Wife shall be her sole and separate property.
7. MISCELLANEOUS
Any property not specifically divided by this Agreement shall be owned and retained by the
party in whose name the property is titled or, if the property is not titled, shall be the property of the
party currently in possession ofthe property.
8. REAL ESTATE
A. Marital Residence - The parties acknowledge that Wife is the title owner of real
property known as 5253 Deerfield Avenue, Mechanicsburg, Pennsylvania 17050, which is subject
to a first and a second mortgage. The parties agree with respect to this property, that this is the sole
and separate property of Wife, free from any claim of any nature by Husband. As indicated above,
Wife has arranged for the satisfaction of the first and second mortgages on this property so as to
eliminate Husband's liability on these debts. Wife shall indemnify and hold Husband harmless from
any liability related to this real property.
B. Liberty Township. Adams County - The parties acknowledge that Wife is the owner
of certain real property located in Liberty Township in Adams County, Pennsylvania. Husband
hereby releases and waives any claim of any nature that he may have to this property.
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SECTION V
CLOSING PROVISIONS AND EXECUTION
Each of the parties has carefully read and fully considered this Agreement and all of the
statements, terms, conditions, and provisions thereof prior to signing below.
IN WITNESS WHEREOF, intending to be legally bound hereby, the parties hereto have
set their hands and seals on the date indicated below.
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DALEY LAW OFFICES
1029 SCENERY DRIVE . HARRlSBURG,PA 17109' (717)657-4795' FAX (717) 657-4996
October 25,2001
Cumberland County Courthouse
Office of Prothonotary
One Courthouse Square
Carlisle, PA 17013
Re: Conner v, Conner
No, 00-5959 - In Divorce
Dear Sir or Madam:
Enclosed please find the documents necessary to finalize the above-captioned divorce action.
Also enclosed is a check in the amount of $9.00 to cover the cost of the Defendant's certified copy
of the divorce decree, as well as the appropriate envelopes.
Thank you for your attention to this matter.
truly yours,
KCD:pap
Enclosures
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PATRICIA A. CONNER,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
v.
: NO. 00-5959 CIVIL
STEPHEN S. CONNER,
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. Ground for divorce: irretrievable breakdown under 93301(c) of the Divorce Code,
2, Date and manner of service ofthe complaint: September 21,2000 by certified mail,
restricted delivery.
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: 10/24/01; by Defendant: 10/23/01.
(b)( 1) Date of execution of the affidavit required by 9330 1( d) of the Divorce
Code: N/ A; (2) Date of filing and service of the Plaintiffs Affidavit upon the
respondent: N/ A.
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4, Related claims pending: None
5. (Complete either (a) or (b),)
(a) Date and manner of service of the notice ofintention to file praecipe to
transmit record; a copy of which is attached: N/A
(b) Date Plaintiffs Waiver of Notice in ~3301(c) Divorce was filed with the
Prothonotary: 10/26/01
Date Defendant's Waiver of Notice in ~3301(c) Divorce was filed with
the Prothonotary: 10/26/01
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PATRICIA A. CONNER,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
v.
: NO. t[) -5951' ~
STEPHEN S, CONNER,
Defendant
: IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth,
in the following pages, you must take prompt action. You are warned that if you fail to do so, the
case may proceed without you and a decree of divorce or annulment may be entered against you by
the Court. A judgment may also be entered against you for any other claim or relief requested in
these papers by the Plaintiff. You may lose money or property or other rights important to you,
including custody or visitation of your children.
When the ground for 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, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 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 COUNTY LEGAL SERVICES, INC,
8 IRVINE ROW
CARLISLE, PENNSYLVANIA 17013
(727) 243-9400
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NOTICIA
Le han demandado a usted en la corte, Si usted quiere defenderse de estas demandas
expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la
demanda y la notificacion. Usted debe presentar una apariencia escrita 0 en persona 0 por abogado
y archivar en la corte en
forma escrita sus defensas 0 sus objeciones alas demandas en contra de su persona. Sea avisado que
si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo
aviso 0 notificacion y por cualquier queja 0 alivio que es pedido en la peticion do demanda. Usted
puede perder dinero 0 sus propiedades 0 otros derechos importanates para usted.
LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTE. SI NO TIENE
ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE P AGAR TAL SERVICIO, V AY A
EN PERSONA 0 LLAME POR TELFONO A LA OFICINA CUY A DIRECCION SE
ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR
ASISTENCIA LEGAL.
CUMBERLAND COUNTY LEGAL SERVICES, INC,
8 IRVINE ROW
CARLISLE, PENNSYLVANIA 17013
(727) 243-9400
.....
PATRICIA A. CONNER,
Plaintiff
v.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION -LAW
: NO. (}().5'"159 ~-rR..--
STEPHEN S. CONNER,
Defendant
: IN DIVORCE
COMPLAINT IN DIVORCE UNDER
SECTION 3301(c) OR SECTION 3301(d)
OF THE DIVORCE CODE
AND NOW comes the above Plaintiff, Patricia A. Conner, by her attorney, Kathleen Carey
Daley, Attorney at Law, and seeks to obtain a decree in divorce from the above-named Defendant,
upon the grounds hereinafter set forth:
1. The Plaintiff, Patricia A. Conner, is an adult individual who resides at 5253 Deerfield
Avenue, Mechanicsburg, Cumberland County, Pennsylvania 17055.
2. The Defendant, Stephen S. Conner, is an adult individual who resides at 500 Walnut
Street, Apt, AS, Lemoyne, Cumberland County, Pennsylvania 17043.
3. The Plaintiff has been a bona fide resident of the Commonwealth of Penn sylvania for
at least six (6) months immediately prior to the filing of this Complaint.
4. The Plaintiff and Defendant were manied on June 1, 1985, in Camp Hill, Pennsylvania.
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7.
The Plaintiff and Defendant are both citizens of the United States of America,
There have been no prior actions in divorce between the parties.
The Plaintiff and Defendant are not members of the Armed Services of the United
States or any of its allies.
8, 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 in counseling.
9. The causes of action and sections ofDivorce Code under which Plaintiff is proceeding
are:
A. Section 3301(c). The marriage of the parties is irretrievably broken.
After ninety (90) days have elapsed from the date of the filing of this Complaint,
Plaintiff intends to file an Affidavit consenting to a divorce, Plaintiff believes that
Defendant may also file such an Affidavit.
B. Section 3301(d). The marriage of the parties is irretrievably broken,
The Plaintiff and Defendant separated on March 27,2000,
WHEREFORE, the Plaintiff prays your Honorable Court to enter a Decree in Divorce from
the bonds of matrimony,
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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.A. ~4904 relating to unsworn
falsification to authorities.
By: ~ttfxut~ tl ~/~
Patricia A. Conner, Plaintiff
Date:
ff' ~ 3/ J1i)
,
By:
Kat een Carey Daley, Es
Attorney No. 30078
1029 Scenery Drive
Harrisburg, P A 17109
(717) 657-4795
Attorney for Plaintiff
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PATRICIA A. CONNER,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYL VANIA
CIVIL ACTION - LAW
v.
NO. 00-5959 CIVIL
STEPHEN S. CONNER,
Defendant
IN DIVORCE
AFFIDAVIT OF SERVICE
KatWeen Carey Daley, Esquire, being duly sworn according to law, deposes and says that she
is an attorney at law duly authorized to practice in the Commonwealth of Pennsylvania, and that on
the 21st day of September, 2000, she did serve upon Stephen S. Conner, the Defendant in the
foregoing case, a true and correct copy of the Complaint in Divorce by sending to him, by certified
mail, restricted delivery, to c/o Association oflndependent Colleges and Universities ofPA, 100
North Front Street, Harrisburg, P A 17101, The receipt for said Complaint is attached.
Said copy ofthe Complaint was duly endorsed with notice to Defendant to appear and answer
or the matter would proceed without him.
Sworn to and subscribed before me this
~day of(0~
C
,2001
Ih
atWeen Carey Daley, E fl.
ttorney No. 30078
1029 Scenery Drive
Harrisburg, PA 17109
(717) 657-4795
Attorney for Plaintiff
By:
T ARIAL SEAL .
PATRICIA PATTON. No~ry Public
Lower Paxton Twp., DaUJPhln ~~~~2
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Street & Number
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Post o~ce. State, & ZIP Code \ 70 3
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PATRICIA A. CONNER,
Plaintiff
: IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
v.
: NO, 00-5959 CIVIL
STEPHEN S. CONNER,
Defendant
: IN DIVORCE
AFFIDAVIT OF CONSENT
I. A Complaint in Divorce under Section 330 I (c) ofthe Divorce Code was filed on August
29, 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 verifY that the statements made in this Affidavit are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa.C.S.A. g4904 relating to unsworn
falsification to authorities.
Date: /O,;;t(-C/
By: ~aa;A'I~ a, ~
PATRICIA A. CONNER, Plaintiff
Social Security No. r1'5"- 5~- 3'159
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PATRICIA A. CONNER,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
v.
: NO. 00-5959 CIVIL
STEPHEN S. CONNER,
Defendant
: IN DIVORCE
WAIVER OF NOTICE OF INTENTION
TO REQUEST ENTRY OF A DIVORCE DECREE
UNDER S330HC) OF THE DIVORCE CODE
I. 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! do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by the Court
and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary.
I verifY that the statements made in this affidavit are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa.C.S.A. 94904 relating to unsworn
falsification to authorities.
Date:
/(J -~I/-tJ/
By:
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PATRICIA A. CONNER, Plaintiff
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PATRIClAA. CONNER,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: CNIL ACTION - LAW
v.
: NO. 00-5959 CNIL
STEPHEN S. CONNER,
Defendant
: IN DNORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on August
29, 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 verify that the statements made in this Affidavit are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa.C.S.A. g4904 relating to unsworn
falsification to authorities.
Date: If) -.}3~o J
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By:
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STEPHENS. CONNER, Derendant
Social Security No. filJ-,fY-.J8rV
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PATRICIAA. CONNER,
Plaintiff
: IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
v.
: NO. 00-5959 CIVIL
STEPHEN S. CONNER,
Defendant
: IN DIVORCE
WAIVER OF NOTICE OF INTENTION
TO REQUEST ENTRY OF A DIVORCE DECREE
UNDER &330HC) OF THE DIVORCE CODE
I. 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! do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by the Court
and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary.
I verify that the statements made in this affidavit are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa.C.S.A. g4904 relating to unsworn
falsification to authorities.
Date: /0 -),3-6 J
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By: ./'" /" / ~ Z.
STEPHEN S. CONNER, Defendant ..........
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