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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF
PENNA.
BRIAN J. BEERS
PLAINTIFF
No. 2000-7178 Civil Term
VERSUS
DANIELLE C. BEERS
DEEJENDANT
DECREE IN
DIVORCE
AND NOW,
1u-
'Z4fJ'1 IT IS ORDERED AND
IS"
DECREED THAT
'R.~TlH\:T.T RRR'RQ
, PLAI NTI FF,
AND
DANIELLE C. BEERS
, 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;
NONE: The terms of the Marital Settlement Agreement of March 9, 2000
are incorporated but not merged into the Decree in Divorce.
.
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SAlOIS
SHUFF, FLOWER
& LINDSAY
ATIORNEYS-AT'LAW
26 w. High Street
Carlisle. P A
BRIAN J. BEERS,
Plaintiff,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V5.
CIVIL ACTION - DIVORCE
NO. 2000. 7178 CIVIL TERM
DANIELLE C. BEERS,
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 Gectiofl :3:301 (e) 3301 (d)
(1) of the Divorce Code. (Strike out inapplicable section).
2. Date and manner of service of the complaint: Attorney's Affidavit filed with
Prothonotary on December 31, 2001 (copy attached)
3. (Complete either paragraph (a) or (b)).
(a) Date of execution of the affidavit under Section 3301 (d) of the
Divorce code August 27, 2002 and filed with Prothonotary
Seteember 20,2002:
4. Related claims pending: None' Resolved by Marriage Rettlement
Agreement dated March 9 ?OOO
5. Complete either (a) or (b).
(a) Date and manner of service of the notice of intention to file
praecipe to transmit record: Via first class mail, September 10,
2002, a copy of which is attached:
(b)
Date Plaintiff's Waiver of Notice in 3301(c) Divorce was filed
with the Prothonotary: nla
Date Defendant's Waiver of NotLc:;~in 3301
the Prothonotary: n/a.
Carol J. Lindsa ,E
Supreme Co ID 693
Saidis, Shuff, er & Lindsay
26 West High Street
Carlisle PA 17013
Phone: 717.243.6222
Attorney for Plaintiff
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MARITAL SETTLEMENT AGREEMENT
THIS AGREEMENT made this qit.
day of ~&,
,2000,
by and between DANIELLE C. BEERS, hereinafter referred to as WIFE, and BRIAN J. BEERS,
of 3143 Gibner Road, Carlisle Barracks, Carlisle, Pennsylvania, hereinafter referred to as
HUSBAND,
WITNESSETH:
WHEREAS, the parties hereto are husband and wife, having been joined in
marriage on February 14,1999, in Fairbanks, Alaska; and
WHEREAS, a Complaint for Divorce is anticipated to be filed by the parties and a
divorce is contemplated by the parties; and
WHEREAS, 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, and in general, the settling of any and all claims and possible claims against the other
or against their respective estates.
NOW, THEREFORE, in consideration of these considerations, and the mutual
promises and undertakings hereinafter set forth, and for other good and valuable consideration,
receipt and sufficiency of which is hereby acknowledged by each of the parties hereto,
HUSBAND and WIFE, each intending to be legally bound, hereby covenant and agree as
follows:
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1. Advice of Counsel: The parties hereto acknowledge that each has been
notified of his or her right to consult with counsel of his or her choice, and have been provided a
copy of this agreement with which to consult with counsel. HUSBAND is represented by James
D. Flower, Jr., Esquire, and WIFE, has been advised that she may be represented by counsel of
her choice. Each party acknowledges and accepts 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 as each has sought from counsel, 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 improper or illegal agreement or agreements.
2. Divorce: The parties agree to the entry of a Decree in Divorce. The
parties will execute, on the date of this agreement, Affidavits of Consent and Waivers of Notice
under Section 3301 (c) of the Divorce Code, consenting to the entry of a Decree in Divorce.
3. Perso",il Property: WIFE agrees to deliver to HUSBAND certain items
which he owned prior to the marriage, including stereo equipment and Star Wars collectible
items. HUSBAND'S Mother is repaying to HUSBAND approximately One Thousand Three
Hundred ($1,300.00) Dollars, which was withdrawn from an account which was held jointly by
HUSBAND and his Mother. As said funds are paid back, they will be applied first to joint debts
of the parties and after all of said joint debts are paid, any amount remaining will be paid to
WIFE. The parties have otherwise satisfactorily divided all of their personal property, and the
personal property shall be the sole and individual property of the party in whose possession it is
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as of the date of this Agreement. To the extent that any property, which is to go to one party is
in the possession of the other, that property will be listed on an attachment to this Agreement.
To the extent that there may be any joint debts, which exceed the funds available, the parties
shall divide them equally.
4. Motor Vehicles: WIFE will retain the 1991 Nissan Sentra. HUSBAND will
execute any a~all doc,uments to transfer all his right, title and interest in said vehicle to WIFE)
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WIFE will pay the alancs of the loan for the purchase of said vehicle and shall indemnify and
hold HUSBAND harmless against any loss as a result of said loan. HUSBAND will retain the
1993 Nissan Altima. WIFE will execute any and all documents to transfer all her right, title and
interest in said vehicle to HUSBAND. HUSBAND shall pay the outstanding indebtedness on the
vehicle and indemnify and hold WIFE harmless against any loss on account of said loan.
5. Alimony: The parties waive any claim that they may have one against the
other for alimony or spousal support, acknOwledging that each has sufficient earning capacity
with which to maintain himself or herself after the divorce. HUSBAND agrees to pay the sum of
Six Hundred Eighty ($680.00) Dollars per month to the parties landlord, Cindy Cresta, by the
third of every month, for support of that residence. Once that Lease is terminated, HUSBAND
will pay the amount of Three Hundred Seventy-two and 46/100 ($372.46) Dollars, directly to
WIFE until the divorce is final, according to Military Regulation AR608-99. There shall be no
other spousal support between the parties. The parties acknowledge that each has sufficient
assets with which to maintain themselves after divorce.
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6. Marital Debt: The parties may have, in their own names, certain credit
card accounts which may include some marital debt. Each party will be responsible for the debt
on the credit card accounts in his or her name. Each party will incur no debt for which the other
may be liable, and will indemnify and hold the other harmless for any debt so incurred.
7. Modification: No modification, recision, or amendment of this agreement
shall be effective unless in writing signed by each of the parties hereto.
8. Applicable Law: All acts contemplated by this agreement shall be
construed and enforced under the laws of the Commonwealth of Pennsylvania.
9. Agreement Binding on Parties and Heirs: This agreement, except as
otherwise expressly provided herein, shall bind the parties hereto, and their respective heirs,
executors, administrators, legal representatives, assigns and successors in any interest of the
parties.
10. Agreement Not to be Merged: This agreement shall be incorporated into
the final decree of divorce of the parties hereto for purposes of enforcement only, but otherwise
shall not be merged into said decree. The parties shall have the right to enforce this agreement
under the Divorce Code of 1980, as amended, and in addition, shall retain any remedies in law
or in equity under this agreement as an independent contract. Such remedies in law or equity
are specifically not waived or released.
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11. Documents: The parties hereto agree that they will execute and deliver
one to the other any documents necessary to give effect to the terms of this Agreement.
12. Full and Final Settlement: WIFE and HUSBAND each do hereby
mutually remise, release, quitclaim and forever discharge the other and the estate of such other,
for all time to come, and for all purposes whatsoever, of and from any and all rights, titles,
interests 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 she or he now has or at any time hereafter may have against such other, the
estate of slilch other or any part thereof, whether arising out of any former acts, contracts,
engagements or liabilities of such other, or by way of dower or curtesy, or claims in the nature of
dower or curtsey of widows' or widowers' 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 other State,
or any other Country, or any rights which either spouse may have, or at any time hereafter have,
for past, present or future support or maintenance, alimony, alimony pendente lite, counsel 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 before the breach of any thereof. It is the intention of
HUSBAND and WIFE to give to each other by the execution of this Agreement a full, complete
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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 thereof, subject, however, to the implementation and
satisfaction of the condition precedent as set forth herein above.
IN WITNESS WHEREOF, the parties hereto have set their hands and seals the
day and year first above written.
WITNESS:
~JoU.
~i QQJ\.Jl:'\
Danielle C. Beers
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BRIAN J. BEERS,
Plaintiff,
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - DIVORCE
NO. 2000 - 7177
CIVIL TERM
DANIELL!:: C. BEERS,
Defendant.
IN DIVORCE
NOTICE
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set
forth in the following pages, you must take prompt action. You are warned that if you fail to do
so, the case may proceed without you and a decree of divorce or annulment may be entered
against you by the Court. A judgment may also be entered against you for any other claim or
relief requested in these papers by 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 at the Cumberland County Court House, Carlisle, Pennsylvania,
17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYERS FEES OR EXPENSES BEFORE A DECREE OF DIVORCE OR ANNULMENT IS
GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
(717) 249-3166 .
FLOWER, FLOWER & LINDSAY
Attorneys for the Plaintiff
James D. Flower, Jr., Es
ID # 27742
11 East High Street
Carlisle, PA 17013
(717) 243-5513
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BRIAN J. BEERS,
Plaintiff,
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - DIVORCE
NO. 2000 - '717 f'
CIVIL TERM
DANIELLE C. BEERS,
Defendant,
IN DIVORCE
COMPLAINT
BRIAN J. BEERS, Plaintiff, by his attorneys, FLOWER, FLOWER & LINDSAY,
respectfully represents:
1. The Plaintiff is BRIAN J. BEERS, who currently resides at Building 420, Carlisle
Barracks, Pennsylvania 17013, since January 2000.
2. The Defendant is DANIELLE C. BEERS, who currently resides at 1303
Rangeview Drive, North Pole, Alaska 99705, since May 2000.
3. The Plaintiff has been bona fide resident in the Commonwealth of Pennsylvania
for at least six months immediately prior to the filing of this Complaint.
4. The Plaintiff and Defendant were married on February 14, 1991 in Fairbanks,
Alaska.
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5. There have been no prior actions of divorce or for annulment between the
parties in this or in any other jurisdiction.
6. The Plaintiff avers that he is entitled to a divorce on the ground that the
marriage is irretrievably broken and Plaintiff is proceeding under Sections 3301 (c) and/or (d) of
the Divorce Code.
7. Plaintiff has been advised of the availability of marriage counseling and of the
right to request that the Court require the parties to participate in marriage counseling, and does
not request counseling.
8. Plaintiff requests the Court to enter a decree of divorce.
FLOWER, FLOWER & LINDSAY
Attorneys for the Plaintiff
Date: IP - /7-' ~
By
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James D. Flo er, Jr., Esquire
10 # 27742
11 East High Street
Carlisle, PA 17013
(717) 243-5513
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VERIFICATION
I, BRIAN J. BEERS, hereby verify that the statements made in this Complaint are
true and correct to the best of my knowledge. information and belief. 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: t / {}c} ?OO()
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SAIDIS I
SHUFF, FLOWER
& LINDSAY
A'ITORNEYSeAT'LAW
26 W. High Street
Carlisle, PA
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BRIAN J. BEERS,
Plaintiff,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - DIVORCE
vs.
NO. 2000 - 7178 CIVIL TERM
DANIELLE C. BEERS,
Defendant.
IN DIVORCE
AFFIDAVIT
NOW comes DALE F. SHUGHART, JR., Esquire, and states as follows:
1. I represented Danielle C. Beers, the Defendant in the captioned
action, as a pro bono referral, at least in October, 2000.
2. My representation terminated on December 5, 2001.
3. Danielle C. Beers did not give me authorization to accept service of
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the Complaint in Divorce. However, on October 26, 2000, Danielle C. Beers
telephoned my office to advise me that she had signed for the certified mail
containing the Complaint in Divorce.
FURTHER, the Affiant sayeth not:
Dale F. Shughart, Jr.
Attorney at Law
Dale . Shu
35 East High
Suite 203
Carlisle, PA 17013
(717) 241-4311
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SIRJFF, FLOWER
& LINDSAY Ii
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ATIORNEYS-AT-LAW
26 W. High Street
Carlisle, PA
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COMMONWEALTH OF PENNSYLVANIA
: 55.
COUNTY OF CUMBERLAND
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ON this, the c23~ day of ~ ,2002,
before me, the undersigned officer, personally appeared DALE F. SHUGHART,
JR., whose name is subscribed to the within instrument, and acknowledged that he
executed the same for the purposes therein contained.
IN witness whereof, I hereunto set my hand and official seal.
~p~~ <
NOfARIAL IlEAL
BONNIE L COYLE. NOTARY PUBLIC
BOAOOF CARIJSlE. CUMBERLAND CO. PA
M'tw-r-"BliilN ElCPlRES OCTOBER 17. 2008
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ATI'ORNEYS.AT-LAW
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Carlisle, PA
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Plaintiff,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - DIVORCE
VS.
DANIELLE C. BEERS,
Defendant.
NO. 2000 - 7178 CIVIL TERM
IN DIVORCE
AFFIDAVIT UNDER ~ 3301(d) OF
THE DIVORCE CODE
1. THE PARTIES TO THIS ACTION SEPARATED IN JANUARY 18, 2000, AND HAVE
CONTINUED TO LIVE SEPARATE AND APART FOR A PERIOD OF AT LEAST TWO YEARS.
2. THE MARRIAGE IS IRRETRIEVABLY BROKEN.
3. 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.
VERIFICATION
I, THE UNDERSIGNED, HEREBY VERIFY THAT THE STATEMENTS MADE HEREIN ARE TRUE
AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE
PENALTIES OF 18 PA. C.S. S 4904, RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES.
~
BRIA . BEERS
DATE:
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SAIDIS
SHUFF, FLOWER
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ATIORNEYS.AT.LAW
26 W. High Street
Carlisle, P A
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BRIAN J. BEERS,
Plaintiff,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - DIVORCE
vs.
NO. 2000 - 7178 CIVIL TERM
DANIELLE C. BEERS,
Defendant.
IN DIVORCE
CERTIFICATE OF SERVICE
AND now, this 7th day of June, 2004, I, James D. Flower, Jr., Esquire, of the law
firm of SAlOIS, SHUFF, FLOWER & LINDSAY Attorneys, hereby certify that I served the
within NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE;
NOTICE OF INTENTION TO TRANSMIT THE RECORD; NOTICE; AFFIDAVIT UNDER .
~3301(d) OF THE DIVORCE CODE; NOTICE TO OPPOSE; and COUNTER-
AFFIDAVIT UNDER SECTION 3301 (d) OF THE DIVORCE CODE on September 10,
2002 by depositing same in the United States Mail, First Class, Postage Prepaid, in
Carlisle, Pennsylvania, addressed to:
Daniel C. Beers
1303 Rangeview Drive
North Pole, Alaska 99705
SAIDIS, SHUFF, FLOWER & LINDSAY, P.C.
Attorneys for Plaintiff
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James D. Flower, Jr., Es
ID# 27742
26 West High Street
Carlisle, PA 17013
(717) 243-6222
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JAMES D. FLOWER
JOHN E. SLIKE
ROBERT C. SAIDIS
GEOFFREY S. SHUFF
JAMES D. FLOWER, JR.
CAROLJ. LINDSAY
JOHNNA J. KOPECKY
KARL M. LEDEBOHM
JOSEPH L. HITCHINGS
THOMAS E. FLOWER
FORREST N. TROUTMAN, II
LAW OFFICES
SAIDIS, SHUFF, FLOWER & LINDSAY
A PROFESSIONAL CORPORATION
26 WEST HIGH STREET
CARLISLE, PENNSYLVANIA 17013
TELEPHONE: (717) 243-6222 - FACSIMILE: (717) 243-6486
EMAIL: attomey@ssfI-Iaw.com
OF COUNSEL
ALBERT H. MASLAND
WEST SHORE OFFICE:
2109 MARKET STREET
CAMP HILL, P A 17011
TELEPHONE: (717)737-3405
FACSIMILE: (717)737-3407
REPLY TO CARLISLE
September 10. 2002
Mrs. Danielle Beers
1303 Rangeview Drive
North Pole, Alaska 99705
Dear Mrs. Beers:
I regret that we have not received back from you a signed Affidavit of
Consent. However, since two years have passed since you and Mr. Beers
separated, Mr. Beers will proceed to obtain the divorce without your assistance. I
am enclosing a 3301 (d) Affidavit and a Counter-Affidavit and also a Notice of
Intention to transmit the record and obtain a Decree in Divorce on or after
November 1 , 2002.
Thank you for your help.
Very truly yours,
SAlOIS, SHUFF, FLOWER & LINDSAY
fll E COpy
James D. Flower, Jr.
JDFJr:tjb
Enclosure
cc: Mr. Brian J. Beers (w/enc)
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SAlOIS
SHUFF, FLOWER
& UNDSAY
A'ITORNEYS-AT-L\W
Z6 W. High Slreet
Carlisle, P A
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BRIAN J. BEERS,
Plaintiff,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - DIVORCE
vs.
NO. 2000 - 7178 CIVIL TERM
DANIELLE C. BEERS,
Defendant.
IN DIVORCE
NOTICE OF IINTENTION TO
REQUEST ENTRY OF DIVORCE DECREE
TO: Oanielle C. Beers
1303 Rangeview Drive
North Pole, Alaska 99705
Brian J. Beers, Plaintiff, intends to file with the Court the attached Praecipe to
Transmit the record on or after November 1, 2002, requesting that a final Decree in
Divorce be entered.
SAlOIS, SHUFf, FLOWER & LINDSAY, P.C.
Attorneys for Plaintiff
By:
James O. Flower, Jr., Esquire
ID# 27742
26 West High Street
Carlisle, PA 17013
(717) 243-6222
I
SAlOIS
SHUFF, FLOWER
& UNDSAY
ATroRNEYS-AT-LA.W
26 W. High Street
Carlisle. PA
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BRIAN J. BEERS,
Plaintiff,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - DIVORCE
VS.
DANIELLE C. BEERS,
Defendant.
NO. 2000 - 7178 CIVIL TERM
IN DIVORCE
NOTICE OF INTE~TION TO REQUEST
ENTRY OF DIVORCE DeCREE
TO: Danielle C. Beers
1303 Rangeview Drive
North Pole, Alaska 99705
YOU HAVE BEEN SUED IN AN ACTION FOR DIVORCE. You have failed to answer the
Complaint or file a Counter-Affidavit to the Plaintiff's Affidavit. Therefore, on or after November 1,
2002 , the Plaintiff can request the Court to enter a final Decree in Divorce.
IF YOU DO NOT FILE with the prothonotary of the Court an Answer with your signature
notarized or verified, or a Counter-Affidavit by the above date, the Court can enter a final Decree
in Divorce. Unless you have already filed with the Court a written claim for economic relief, you
must do so by the above date or the Court may grant the divorce, and you will lose forever the
right to ask for economic relief. A COUNTER-AFFIDAVIT WHICH YOU MAY FILE WITH THE
PROTHONOTARY OF THE COURT IS ATIACHED TO THIS NOTICE.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER, OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PENNSYLVANIA 17013
(717) 249-3166
~~ .
SAlOIS
SHUFF, FLOWER
& LINDSAY
ATl'ORNEYSeATeLAW
26 w. High Street
Carlisle. PA
. .
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BRIAN J. BEERS,
Plaintiff,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - DIVORCE
vs.
NO. 2000 - 7178 CIVIL TERM
DANIELLE C. BEERS,
Defendant.
IN DIVORCE
NOTICE
If you wish to deny any of the statements set forth in this Affidavit, you must file a
Counter-Affidavit within twenty (20) days after this Affidavit has been served on you, or
the statements will be admitted.
SAlOIS, SHUFF, FLOWER & LINDSAY, P.C.
Attorneys for Plaintiff
By:
James D. Flower, Jr., Esquire
10# 27742
26 West High Street
Carlisle, PA 17013
(717) 243-6222
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SAlOIS
SHUFF, FLOWER
& LINDSAY
ATI'ORNBYSeATeLAW
26 W. High Street
Carlisle, PA
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BRIAN J. BEERS,
Plaintiff,
IN THE COURT OF COMMON PLEAS OF
CUMBERLANO COUNTY, PENNSYLVANIA
CIVIL ACTION - DIVORCE
VS.
NO. 2000 - 7178 CIVIL TERM
DANIELLE C. BEERS,
Oefendant.
IN DIVORCE
NOTICE
IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A
DIVORCE DECREE, AND YOU DO NOT WISH TO MAKE ANY CLAIM
FOR ECONOMIC RELIEF, YOU NEED NOT FILE THIS COUNTER.
AFFIDA VIT.
I
SAlOIS
SHUFF, FLOWER
& LINDSAY
ATl'ORNEYS.AT.LAW
26 w. High Street
Carlisle, P A
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BRIAN J. BEERS,
Plaintiff,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - DIVORCE
vs.
NO. 2000 - 7178 CIVIL TERM
DANIELLE C. BEERS,
Defendant.
IN DIVORCE
COUNTER AFFIDAVIT UNDER SECTION 3301ftO.
OF THE DIVORCE CODE
1. CHECK-EITHER (AI OR (BI:
(a) I do not oppose the entry of the divorce decree.
(b) I oppose the entry of a divorce decree because: (CHECK (I).(U) OR bolh),
(i) The parties to this action have not lived separate and
apart for a period of at least two years; and
(ii) The marriage is not irretrievable broken.
2. CHECK EITHER (A) OR (B):
(a) I do not wish to make any claims for economic relief. 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
(b) I wish to claim economic relief which may include alimony, division of
property, lawyer's fees or expenses or other important rights.
VERIFICATION
I, the undersigned, hereby verify that the statements made herein are true and
correct. I understand that false statements herein are made subject to the penalties of 18
Pa. C.S. S 4904, relating to unsworn falsification to authorities.
Danielle C. BeefS
Date:
. , ~
SAlOIS
SHUFF, FLOWER
& LINDSAY
ATIORNBYSeATeLAW
26 W. High Street
Carlisle, P A
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BRIAN J. BEERS,
Plaintiff,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - DIVORCE
VS.
NO. 2000 - 7178 CIVIL TERM
DANIELLE C. BEERS,
Defendant.
IN DIVORCE
AFFiDAViT OF CONSENT
1. A Complaint in Divofce undef !l 3301 (c) of the Divofce Code was filed on
Octobef 17, 2000.
2. The marfiage 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 Decfee in Divofce aftef service of notice of
intention to fequest entry of the Decfee.
I vefify that the statements made in this Affidavit are tfue and cOfrect to the
best of my knowledge, infofmation and belief. I understand that false statements
hefein afe made subject to the penalties of 18 Pa.C.S. 4904 felating to unsworn
falsification to authorities.
Date:
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Carlisle, PA
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BRIAN J. BEERS,
Plaintiff,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - DIVORCE
V5.
: NO. 2000 - 7178 CIVIL TERM
DANIELLE C. BEERS,
Defendant.
: IN DIVORCE
WAIVEROF NOTICE OF INTENTION. TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
~3301(c) OF THE DIVORCE CODE
1. I consent to the entry of a final Decfee of Divorce without notice.
2. I undefstand that I may lose fights concerning alimony, division of
property, lawyer's fees or expenses if I do not claim them befofe a divorce is
gfanted.
3. I undefstand that I will not be divofced until a DivOfce Decfee is
entefed 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 afe tfue and cOfrect to the
best of my knowledge, information and belief. I understand that false statements
hefein afe made subject to the penalties of 18 Pa.C.S. 4904 felating to unsworn
falsification to authorities.
Date:
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