HomeMy WebLinkAbout00-07351
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IN THE COURT OF COMMON PLEAS
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OF CUMBERLAND COUNTY
STATE OF
PENNA.
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JULIE A. BANKES,
No. 00-7351 CIVIL TERM
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Plaintiff
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VERSUS
ROBERT E. BANKES '.
Defendant
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DECREE IN
DIVORCE
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AND NOW,
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do6' , IT IS ORDERED AND
DECREED THAT
Julie A. Bankp5l
PLAINTIFF,
AND
Robert E. Bankes
, DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
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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;
The parties' Separation Aqreernent dated March 26. 2001 is incorporated
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herein, but not lIlerlqed:;
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BY~
AmST OUftfjjf2,
PROTHONOTARY
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SEPARATION AND PROPERTY SETTLEMENT AGREEMENT
THIS AGREEMENT made this)& ~ay of I~ ,200], by and
between JULIE A. BANKES, of 7 Pine Road, Apartment 606, Mount Holly Springs,
Cumberland County, Pennsylvania, pany of the fil'st part, hel'einaftel' referred to as .. Wife,"
AND
ROBERT E. BANKES, of 114 Second Street, Boiling SPl'ings, Cumberland County,
Pennsylvania, 17201, party of the second part, hel'einafter referred to as "Husband,"
WITNESSETH:
WHEREAS, Husband and Wife were married on August 10, 1991, in Staeben County,
New York; and
VlHEREAS, Husband and Wife are residents of the Commonwealth of Pennsylvania and
have been so for at least the past six months;
WHEREAS, certain differences have al'isen between the parties hel'eto which have made
them desirous ofliving sepal'ate and apart from one anothel'; and
WHEREAS, Husband and Wife desire to settle and determine certain of their mal'ital
rights and obligations, and make an equitable distl'ibution of their marital property. determine
their rights to alimony and support and any other matteI's which may be considel'ed under the
Divorce Code; and
WHEREAS, it is the intention and purpose of this Agreement to set forth the I'espective
rights and duties of the parties while they continue to live apart from each other and to settle all
financial and property I'ights between them; and
WHEREAS, the parties hereto have mutually entered into an agreement fol' the division
of theil' jointly owned assets, the provisions for the liabilities they owe, and pl'ovisions for the
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resolution of their mutual differences, after both have had full and ample opportunity to consult
with attorneys of their respective choice, the parties now wish to have that agl'eement reduced to
\vriting.
NOW, THEREFORE, the parties hereto in considel'ation of the mutually made and to be
kept promises set forth hereinafter and for other good and valuable consideration, and intending
to be legally bound and to legally bind theil' heil's, successors, assigns, and personal
representatives, do hel'eby covenant, pl'Omise and agl'ee as follows:
ARTICLE I
SEPARATION
1.1
It shall be lawful for Husband and Wife at all times hereafter to live separate and apart
from each other and to reside fl'Om time to time at such place or places as they shall respectively
deem fit fl'ee fl'om any contl'Ol, restl'aint, or intel'fel'ence, direct or indil'ect, by each other.
Neither party shall molest the othel' or compel or endeavol' to compel the othel' to cohabit or
dwell with him 01' her by any legal or other pl'oceedings. The fOl'egoing pl'Ovisions shall not be
taken to be an admission on the part of either Husband or Wife of the lawfulness of the causes
leading to them Jiving sepal'ate and apart.
ARTICLE II
DIVORCE
2.1
This Agl'eement is not pl'edicated on divorce. It is specifically undel'stood and agreed by
and between the pal'ties hereto that each of the said parties does hel'eby warrant and I'epl'esent to
the other that the execution and delivery of this Agreement is not predicated upon nor made
subject to any agreement for institution, pl'Osecution, defense, or fol' the non-pl'Osecution 01' non-
defense of any action for divorce; provided, howevel', that nothing contained in this Agreement
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shall prewnt or preclude either of the parties hereto from commencing, instituting or prosecuting
any action 01' actions for divorce, eithel' absolute or othel'Wise, upon just, legal and pl'oper
grounds; not to pl'event eithel' party from defending any such action which has been, may, or
shall be instituted by the othel' party, or from making any just or propel' defense thereto. It is
\\arranted. co\enanted, and represented by Husband and Wife, each to the other, that this
Agreement is lawful and enforceable and this warranty, covenant, and I'epresentation is made for
the specific purpose of inducing Husband and Wife to execute the Agreement. Husband and
Wife each knowingly and understandingly hel'eby waive any and all possible claims that this
Agreement is, for any reason, illegal, 01' for any reason whatsoever of public policy,
unenforceable in whole or in part. Husband and Wife do each hereby warrant. covenant and
agree that. in any possible event, he and she are and shall forevel' be estopped from asserting any
illegality or unenfol'ceability as to all or any part of this Agreement.
2.2
It is furthel' specifically understood and agl'eed that the provision of this Agl'eement
relating to the equitable distl'ibution of property of the parties are accepted by each party as a
final settlement fol' all purposes whatsoever. Should eithel' of the parties obtain a decree,
judgment or ol'del' of separation 01' divorce in any other state, country, or jurisdiction, each of the
pal'ties to this Agreement hel'eby consents and agrees that this Agreement and all its covenants
shall not be affected in any way by any such separation and divol'ce.
2.3
This Agreement shall sUJvive any decl'ee in divol'ce and shall be forever binding and
conclusive on the pat1ies. It is understood by and between the parties that this Agreement shall
be incorporated into any decl'ee, divol'ce or separation, but it shall not be deemed mel'ged in such
decl'ee.
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ARTICLE III
EOUITABLE DISTRIBUTION OF MARITAL PROPERTY
3.1
The parties have attempted to divide their marital pl'Operty in a manner \vhich confom1s
to the criteria set forth in the Pennsylvania Divorce Code, and taking into account the following
considerations: the length of the maniage; the pl'ior marriages of the parties; the age, health,
station, amount and sources of income, vocational skills, employability; estate, liabilities, and
needs for each of the parties; the contribution of one party to the education, tl'aining or increased
earning powel' to the other party; the opportunity of each party for future acquisition of capital
assets and income; the sources of income of both parties, including but not limited to medical,
retirement. insurance or othel'. benefits; the contl'ibution or dissipation of each part in the
acquisition, preservation, depreciation, or appreciation of marital property, including the
contribution of a party as a homemaker; the value of the pl'Operty set apart to each party: the
standard of living of the parties established dUl'ing their marriage; the economic cil'cumstances of
each party, including federal, state and local tax I'amifications, at the time of the division of the
pl'Operty is to become effective; and whethel' the parties will be serving as the custodian of any
dependent minor childl'en.
3.2
The division of existing marital pl'Operty is not intended by the parties to constitute in any
way a sale or exchange of assets and the division is being effected without the intl'Oduction of
outside funds or other pl'Operty not constituting mal'ital pl'Operty. The division of pl'Operty under
this A areement shall be in full satisfaction of all rights of equitable distribution of the parties.
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3.3
Personal Property. The parties acknowledge that they have divided theil' personal
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property, tangible and intangible, to their mutual satisfaction, The parties further acknowledge
that they have the cash, accounts, or other tangible and intangible property in theil' possession
that they \\ish to have and neither will make any claim whatsoever against the other party for
any other items of personal property or assets that al'e in the other party's possession.
3.4
Life Insurance. Each party agrees that the other party shall have sole ownel'ship and
possession of any life insurance policies owned by the other, The parties agree that Husband
shall maintain Courtney Lynn Bankes as beneficiary of any life insurance policy that Husband
now owns until Courtney Lynn Bankes has successfully completed secondary education.
Husband agl'ees to provide a copy of said policy documenting Courtney Lynn Bankes as
beneficiary to Wife immediately. Each party agrees to sign any documents necessary to waive,
relinquish, or transfel' any I'ights on such policies to the I'espective party who pl'esently owns
such policies.
3.5
Subsequentlv Acquired ProDerty. Husband and Wife agl'ee to waive and I'elinquish any
and all right that he or she may now have 01' hel'eafter acquil'e in any I'eal or tangible pel'sonal
property subsequently acquil'ed by the other party. Husband and Wife specifically agl'ee to
waive and relinquish any I'ight in such property that may arise as a result of the marriage
relationship.
3.6
Pension. Retirement. Profit-Sharing. Wife agl'ees to waive, relinquish 01' tl'ansfel' any
and all of hel' right, title and interest she has or may have in Husband's pension through his
present or prior employment Wife hel'eby waives, relinquishes and tl'ansfers any and alll'ight,
title and interest she has in any present I'etil'ement account, as well as other accounts that
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Husband may have in his individual name or may have secured through his pl'esent or prior
employment.
Husband agrees to waive, relinquish 01' tl'ansfer any and all of his right, title and intel'est
he has or may have in Wife's pension through her pl'esent or prior employment. Husband hel'eby
waives, relinquishes and tl'ansfers any and all I'ight, title and intel'est he has in any pl'esent
retirement account, as well as other accounts that Wife may have in her individual name or may
have secUl'ed through hel' pl'esent or prior employment,
3.7
Vehicles. The parties acknowledge that Wife has and shall retain sole and exclusive
ownership and possession of a certain 1994 Ford Escort vehicle which was ol'iginally titled in the
parties' names jointly. Husband shall execute the title of the vehicle within fifteen (15) days of
being requested to do so by Wife 01' Wife's legal counsel to Wife's name individually. Husband
shall make no claim whatsoever relati\e to access to or use of the aforesaid vehicle and shall
make no ownership claims of any natUl'e whatsoever to the afol'esaid vehicle from the date of
execution of this Agl'eement forward.
The parties acknowledge that Husband has and shalll'etain sole and exclusive ownership
and possession of the parties' 1988 Ford F150 pickup truck, which was ol'iginally titled in the
parties name jointly. Wife shall execute the title to the vehicle within fifteen (15) days upon
request to do so by Husband. Wife shall make no claim whatsoever relative to access to or use
of the afol'esaid vehicle and shall make no ownership claims of any natul'e whatsoevel' to the
aforesaid vehicle from the date of execution of this Agreement forward.
3.8
Intangible Personal ProverfJ!. The parties have already tl'ansferred or waived I'ights and
interest in other intangible personal pl'operty, including theil' various bank accounts, credit union
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accounts, and the like. Each party agrees to sign any documents necessary to close any joint
accounts within fifteen (15) days of signing this Agreement. Neithel' party shall make any claim
of any nature whatsoever against the other party I'elative to the financial accounts or other
investments or intangible pel'sonal property that have all'eady been retained by that party as
described herein_
ARTICLE IV
DEBTS OF THE PARTIES
4.1
The parties acknowledge that they have outstanding debts or liabilities due and owing to
a VISA account. Fl'om the date of execution of this Agl'eement forwal'd, Husband shall retain
sole and exclusive responsibility and obligation for the repayment of the aforesaid debts.
Husband shall indemnify Wife and hold her harmless fl'om and against any and all demands fol'
payment or collection activity of any nature whatsoever I'elative to the aforesaid credit card debt.
Husband shall refinance the VISA account debt into his sole and individual name andlor I'emove
Wife's name from said debt within ninety (90) days of signing this Agreement.
The parties acknowledge that they have outstanding debts fol' liability due and owing to a
consolidation loan held jointly at AmeriChoice. From the date of execution of this Agl'eement
forward, Husband shall retain sole and exclusive responsibility and obligation for the repayment
of the aforesaid debt in the amount of $2,130.00, an amount equal to approximately forty (40%)
percent of the aforesaid debt at the time of separation. Husband agrees to make twenty-four (24)
monthly payments dil'ectly to Wife in the amount of $88.75 by or before the thirtieth (30'h) day
of each month to satisfy payment of the afol'esaid debt. Said payments to begin fifteen (15) days
after the signing of this Agreement. In addition, in the event that Husband should default upon
the aforesaid consolidation loan, Wife shall be entitled to immediately initiate action against
Husband through the filing of amicable Alimony action to which Husband will not object in an
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amount to include not only the debt itself, but also any late fees, interest, legal fees, or costs
associated with any related collection proceedings plus interest in the amount of fifteen (15%)
percent to aCCl'ue per annum to compensate Wife fOl' any tax loss she may suffel'. The requested
amount of alimony shall be collected thl'ough wage attachment by Domestic Relations..
Husband shall not defend against Wife's request for alimony in that amount and may not I'aise
the defense of Wife's cohabitation to any claim for alimony under this paragl'aph. Further,
Husband agrees to execute any and all necessary documents to have Wife's name removed from
any and all debts which Husband has agreed to be I'esponsible for under this paragl'aph.
4.2
Each party I'epresents to the other that except as is otherwise set forth in this Agreement,
and more particularly as set forth in subpal'agl'aph 4.1 above, thel'e are no major outstanding
obligations of the parties; that since the separation neither party has contl'acted 01' any debts for
which the othel' will be I'esponsible and each party indemnifies and holds harmless the othel' for
all obligations separately incurred or assumed under this Agl'eement.
ARTICLE V
MISCELLANEOUS PROVISIONS
5.1
Advice of COl/llsel. The parties acknowledge that they have either I'eceived independent
legal ad\'ice from counsel of their own selection, that they fully understand the facts and have
been fully infoffi1ed as to theil' legal I'ights an obligation or otherwise understand those legal
rights and obligations. They acknowledge and accept that this Agreement is, in the
circumstances. fair and equitable, that it is being entered into freely and voluntarily, after having
received such advice and with such knowledge that execution of this Agl'eement is not the I'esult
of any duress or undue influence, and furthel' that it is not the result of any collusion or impl'opel'
or illegal agreement or agl'eements.
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5.2
Mutual Release. Husband and Wife each do hereby mutually remise, release, quitclaim,
and forever discharge the other and the estate of such other, for all times to come and fol' all
purposes whatsoever, of and from any and alll'ight, title and intel'est, or claims in or against the
property \ including income and gain from property hel'eafter accruing) of the other or against the
estate of such other, of whatever nature and wheresoever situate, which he or she now has or at
any time hereafter may have against such other, the estate of such other, or any part thereof,
whether arising out of any formeI' acts, contracts, engagements, or liabilities of such othel' as by
way of dower or curtesy, or claims in the natul'e of dower or curtesy or widow's or widowel"s
I'ights, family exemption, 01' similal' allowance, 01' under the intestate laws, 01' the I'ight 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, whethel'
al'ising under the laws of (a) Pennsylvania, (b) any state, commonwealth 01' territory of the
United States, or (c) any othel' country, 01' any rights which eithel' party may have or at any time
hel'eafter have for past. present, 01' futul'e support 01' maintenance, alimony, alimony pendente
lite. counsel fees. costs or expenses, whether al'ising as a I'esult of the mal'ital I'elation 01'
otherwise. except and only except, all rights and agreements and obligations of whatsoevel'
natul'e arising or which may arise under this Agreement or for the breach of any thereof. It is the
intention of Husband and Wife to give to each othel' by execution of this Agreement a full,
complete. and generall'elease with respect to any and all pl'Operty of any kind 01' natul'e, real or
personal. not mixed, which the other now owns or may hereafter acquire, except and only
except, all rights and agreements and obligations of whatsoever nature arising or which may
arise under this Agl'eement or for the breach of any thel'eof.
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5.3
BallkruDtcl'. The parties agree that any and all financial obligations assumed herein shall
not be subject to dischal'ge through bankruptcy pl'Oceedings. This includes, but is not limited to,
all financial obligations assumed under Paragraph 3.6, 3.8 and 4.1 of this Agl'eement. In the
event either party attempts to avoid financial obligations described herein thl'Ough bankruptcy
proceedings the other party shall have an independent claim against the party claiming
bankruptcy for any and all sums that the other party assumes or is requil'ed to pay due to the
actions of the party claiming bankruptcy. Further, all I'ights available to the othel' party
pl'Ovided for in Pal'agl'aph 6.14 hel'einaftel' shall be available to the party not filing bankruptcy.
5.4
Warranties. Each party represents that they have not hel'etofore incurred or contl'acted
fol' any debt 01' liability or obligation for which the estate of the other party may be responsible
or liable, except as may be pl'Ovided for in this Agreement. Each party agl'ees to indemnify 01'
hold the other party harmless fl'Om and against any and all such debts, liabilities 01' obligations of
every kind, including those fol' necessities, except for the obligations arising out of this
Agreel11em. Husband and Wife each warrant, covenant, I'epl'esent and agl'ee that each will, now
and at all times hereafter, save harmless and keep the other indemnified fl'Ol11 all debts, chal'ges,
and liabilities incurred by the other after the execution date of this Agl'eement, except as is
otherwise specifically pl'Ovided for by the terms of this Agl'eement and that neither of them
hereafter incur any liability whatsoevel' for which the estate of the other may be liable.
5.5
No waiver or modification of any of the temlS of this Agreement shall be valid unless in
wl'iting and signed by both parties and no waiver of any bl'each hereof or default hel'eundel' shall
be deemed a waiveI' of any subsequent default of the same or similal' nature.
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5.6
Husband and Wife covenant and agree that they will forthwith execute any and all
written instruments, assignments, releases, satisfactions, deeds, notes or such other wl'itings as
may be necessal'Y or desirable for the proper implementation of this Agl'eement, and as their
respectiw counsel shall mutually agree should be so executed in order to carry fully and
effectively the terms of this Agreement.
5.7
This Agreement shall be construed in accol'dance with the laws of the Commonwealth of
Pennsylvania which al'e in effect as of the date of the execution of this Agl'eement.
5.8
This Agreement shall be binding and shall inure to the benefit of the parties hel'eto and
their respective heil's, executors, administratol's, successors and assigns.
5.9
This Agreement constitutes the entire undel'standing of the parties and supersedes any
and all prior agl'eements and negotiations between them. Thel'e al'e no I'epl'esentations or
warranties other than those expressly set forth herein.
5.10
Severabili~'. If any term, condition, clause, section, 01' provision of this Agl'eement shall
be determined 01' declal'ed to be void 01' invalid in law 01' otherwise, then only that term,
condition. clause or provision shall be stl'icken from this Agreement, and in all other I'espects,
this Agreement shall be valid and continue in full force, effect, and opel'ation. Likewise, the
failure of any party to meet his or her obligation undel' anyone or more of the articles and
sections herein shall in no way void or alter the remaining obligations ofthe parties.
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5.11
It is specifically undel'stood and agl'eed that this Agreement constitutes the equitable
distribution of property, both I'eal and pel'sonal, which was legally and beneficially acquired by
Husband and Wife. or either of them, dUl'ing the marriage as contemplated by the Divorce Code
of th.e Commonwealth of Pennsylvania.
5.12
Disclosure. The parties each warrant and I'epresent to the other that he 01' she has made a
full and complete disclosUl'e to the other of all assets of any natul'e whatsoever in which party
has an interest, of the SOUl'ces, and amount of the income of such party of every type whatsoever,
and all other facts I'elating to the subject mattel' of this Agl'eement.
5.13
Enforceability and Consideration. This Agl'eement shall survive any action for divorce
and decree of divorce and shall forever be binding and conclusive on the parties; and any
independent action may be brought, eithel' at law 01' in equity, to enforce the terms of the
Agreement by either Husband or Wife until it shall have been fully satisfied and pel'formed. The
consideration fol' this contract and agreement is the mutual benefits to be obtained by both of the
pal1ies hereto and the covenants and agreements of each of the parties to the other. The
adequacy of the considel'ation for all agreements herein contained is stipulated, confessed, and
admitted by the parties, and the parties intend to be legally bound hel'eby. In the event either
party breaches the aforesaid Agreement and it is determined through appropl'iate legal action that
the alleged party has so breached the Agreement, the bl'eaching party shall be I'esponsible fol' any
and all attorney's fees as well as costs and expenses associated with litigation incurred by the
non-breaching party to enforce this Agreement against the bl'eaching party. In the event of
bl'each, the non-bl'eaching party shall have the I'ight, at his or her election, to sue fol' damages for
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such breach or to seek such other and additional I'emedies as may be available to him or her
including equitable enforcement of this Agreement.
I!\ WITNESS WHEREOF, the parties hel'eto have set their hands and seals the day and
year first above written"
WITNESSED BY:
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COMMO?\'WEALTH OF PENNSYLVANIA
COUNTY OF ~.~
On this J&!:i-nay of iA...w-</"-
, 2001, befol'e me, the undersigned
officer, personally appeared JULIE A. BANKES, known to me (or satisfactory pl'oven) to be the
person whose name is subscribed to the within Agreement and acknowledged that she executed
the same for the purpose therein contained.
lJ\ WITNESS WHEREOF, I hereunto set my hand and official seal.
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Notarial Saal
Robin ,; GOShorn Notary Public
Carflsl~ eora CUi"'~berland County
My CM'"',emun E.p:res Apr. 17. 2003
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CU/11h.vt/()Ild
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On this t?":; day of
, 2001, befol'e me, the undel'signed
officer, pel'sonally appeared ROBERT E. BANKES, known to me (or satisfactory proven) to be
the pel'son whose name is subscl'ibed to the within Agl'eement and acknowledged that he
executed the same for the purpose therein contained.
['.; WITNESS WHEREOF, I hereunto set my hand and official seal.
No!arial Seal
Lynn L. Nettei. Notary Public
South r\t1iddleton Twp., Cumberland. County
J My Commissio!l Expires July 28. 2003
Member, Pennsylvania Association ot Notaries
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JULIE A. BANKES,
Plait),uiff
. IN THE COURT OF COMMON PLEAS
CUMBERBANJ:1t,I)' COUNTY, PENNSYLVANIA
VS.
ROBERT E. BANKES,
Defendant
CIVIL DIVISION
NO. 00-7351 CIVIL TERM
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)
~ the Divorce Code.
(Strike out inapplicable section).
2. Date and manner of service of the complaint: by certified mail, restricted delivery,
on OctnhPr 7.6, 7.000
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 3/26/01 ; by defendant 2/06/01
(b) (1) Date of execution of the affidavit required by 93301 (d)
of the Divorce Code:
(2) Date of filing and service of the plaintiff's affidavit upon the respondent:
4.
Related claims pending:
Nonp
5. Complete either (a) or (b).
(a) Date and manner of service of the notice of intention to file praecipe to transmit record. a
copy of which is attached:
(b) Date of plaintiff's Waiver of Notice in 93301 (c) Divorce was filed with
the Prothonotary: 3/29/01
Date defendant's Waiver of Notice in 93301 (c) Divorce was filed with
the Prothonotary:
Feb. 7, 2001
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Marylou Matas, . orney for Plaintiff ~
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Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v,
: CIVIL ACTION - LAW
: NO, JoOo - 735" CIVIL TERM
ROBERT E. BANKES,
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 pl'Ompt action. You al'e warned that if you fail to do so, the
case will pl'oceed without you and a decl'ee of divol'ce or annulment may be entel'ed against
you fol' any claim 01' I'elief I'equested in these papel's by the Plaintiff. You may lose money 01'
pl'operty 01' othel' I'ights important to you, including custody 01' visitation of yoU!' childl'en.
When the gl'ound fol' the divol'ce is indignities 01' irretrievable bl'eakdown of the
marriage, you may I'equest marriage counseling. A list of marriage counselol's is available in
the Office of the Pl'Othonotary at Cumberland County Courthouse, Carlisle, Cumberland
County, Pennsylvania, 17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL
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 HA VB 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 Bal' Association
Two Liberty Avenue
Carlisle, Pennsylvania 17013
(717) 249-3166
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JULIE A. BANKES,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
v.
: CIVIL ACTION - LAW
: NO. flV- '788'1 CIVIL TERM
ROBERT E. BANKES,
Defendant
: IN DIVORCE
COMPLAINT IN DIVORCE
NO FAULT
1. Plaintiff is Julie A. Bankes, an adult individual currently I'esiding at 7 Pine Road,
Apt. 606, Mount Holly Springs, Cumberland County, Pennsylvania.
2. Defendant is Robert E. Bankes, an adult individual currently I'esiding at 114
Second Street, Boiling Springs, Cumberland Connty, Pennsylvania, and whose
mailing addl'ess is P.O. Box 316, Boiling Springs, Pennsylvania.
3. Plaintiff is a bonafide I'esident of the Commonwealth of Pennsylvania and has
been so for at least six months immediately pl'evious to the filing of this
Complaint.
4. Plaintiff and Defendant were married on August 10, 1991, in Staeben County,
New YOI'k.
5. Thel'e have been no othel' priOI' actions fol' divol'ce 01' annulment between the
parties.
6. Neithel' the Plaintiff nol' the Defendant are membel's of the United States Armed
FOl'ces 01' its Allies.
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7. Plaintiff has been advised of the availability of counseling and the I'ight to I'equest
that the Court I'equil'e the parties to participate in counseling. Knowing this,
Plaintiff does not desil'e that the Court requil'e the parties to participate in
counseling.
8. Plaintiff and Defendant are citizens of the United States of Amel'ica.
9. The parties' marriage is irretrievably bl'oken.
10. Plaintiff desil'es a divol'ce based upon the belief that the Defendant will, ninety
(90) days from the date ofthe filing of this Complaint, consent to this divol'ce.
WHEREFORE, Plaintiff requests your Honorable Court to enter a divol'ce pursuant to
23 P.S. Section 3301 (c) of the Domestic Relations Code.
Respectfully submitted,
GRIFFIE & ASSOCIATES
~
Attorney fol' Plaintiff
GRIFFIE & ASSOCIATES
200 North Hanover Street
Carlisle, P A 17013
(717) 243-5551
(800) 347-5552
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VERIFICATION
I vel'ify that the statements made in the foregoing Complaint al'e true and correct. I
undel'stand that false statements hel'ein made al'e subject to the penalties of 18 Pa.C.S. Section
4904 I'elating to unsworn falsification to authorities.
DATE: JO/ II/Off)
~JlJ 11,-~
JU IE A. BANKES, Plaintiff
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Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
ROBERT E. BANKES,
Defendant
: NO. 00-7351 CIVIL TERM
: IN DIVORCE
AFFIDAVIT OF CONSENT
1. A. Complaint in Divorce under 93301 (c) of the Divorce Code was filed on
October 19, 2000, and served on October 26,2000.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90)
days have elapsed from the date of filing and service ofthe Complaint.
,
3.
I consent to the entry of a final Decree of Divorce after service of notice of
intention to request entry of the decree.
1 VERITY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT
ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN
ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. 94904 RELATING TO
UNSWORN FALSIFICATION TO AUTHORITIES.
DATE: 3h.~ //JI
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Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
ROBERT E. BANKES,
Defendant
: NO. 00-7351 CIVIL TERM
: IN DIVORCE
AFFIDAVIT OF CONSENT
1. A. Complaint in Divorce under 93301 (c) of the Divorce Code was filed on
October 19,2000, and served on October 26,2000.
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. 1 consent to the entry of a final Decree of Divorce after service of notice of
intention to request entry of the decree.
I VERITY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT
ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN
ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. 94904 RELATING TO
UNSWORN FALSIFICATION TO AUTHORITIES.
DATE: ,,7- (, .. 0 I
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Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
: CIVIL ACTION - LAW
v.
ROBERT E. BANKES,
Defendant
: NO. 00-7351 CIVIL TERM
: IN DIVORCE
WAIVER ON NOTICE OF INTENTION TO REQUEST
THE ENTRY OF A DIVORCE DECREE
UNDER ~3301(c) OF THE DIVORCE CODE
I. I consent to the entry of a final decree in divorce without notice.
2. 1 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. 1 understand that I will not be divorce until a divorce decree is entered by the
Court and that a copy of the decree will be sent to me immediately after it is files with the
Prothonotary.
1 VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT
ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN
ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. 94904 RELATING TO
UNSWORN FALSIFICATION TO AUTHORITIES.
DATE:
3}?-tp/ot
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Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
ROBERT E. BANKES,
Defendant
: NO. 00-7351 CIVIL TERM
: IN DIVORCE
WAIVER ON NOTICE OF INTENTION TO REQUEST
THE ENTRY OF A DIVORCE DECREE
UNDER ~3301(c) OF THE DIVORCE CODE
1. I consent to the entry of a final decree in divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses if! do not claim them before a divorce is granted.
3. 1 understand that I will not be divorce until a divorce decree is entered by the
Court and that a copy of the decree will be sent to me immediately after it is files with the
Prothonotary.
I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT
ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN
ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. 94904 RELATING TO
UNSWORN FALSIFICATION TO AUTIIORITIE/7 h"'D ~
DATE: ,-2,0/..,-01 ~~
ROBERT E. BANKES, Defendant
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Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
ROBERT E. BANKES,
Defendant
: NO. 00-7351 CIVIL TERM
: IN DIVORCE
AFFIDAVIT OF SERVICE
AND NOW, this 1" day of November, 2000, comes Marylou Matas, Esquire, Attorney
for Plaintiff, and states that she mailed a certified and true copy of a Complaint in Divorce to the
Defendant, Robert E. Bankes, at P.O. Box 316, Boiling Springs, Pennsylvania, by certified mail,
restricted delivery, return receipt requested. A copy of said receipt is attached hereto indicating
service was made on October 26, 2000.
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Marylou as, Esquire
Attorney for Plaintiff
GRIFFIE & ASSOCIATES
200 North Hanover Street
Carlisle, PA 17013
(717) 243-5551
(800) 347-5552
Sworn and subscribed to
be~e this J!... day
of tMbtv', 2000.
t!atfJC1 ~ .~an
NOTAR UBLIC
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c Notarial Saal
. . Kare J. Lahman, Notary Public
CB~lille BolO, Cumberland County
\illy CO!'lrnlsslon Expires Aug. 25, 2003
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ENDER: COMPLEtE tHIs !>fiCTION' ,
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. Complete items 1, 2, and 3. Also complete
item 4 if Restricted Delivery is desired.
. Print your name and address on the reverse
so that we can" return the card to-you.
III Attach this card to the back of the mailpiece,
or on the frpl1t if space permits.
1. Article Addressed to:
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D. Is delivery address dlffe nt from item 1? 0 Ves
If YES, enter delivery address below: R No
3. Service Type
J.:5 Certified Mail 0 Express Mall
o Registered 0 Return Receipt for Merchandise
o Insured Mail 0 C.O.D.
4. Restricted Delivery? (Extra Fee) )l. Yes
2. Article Number (Copy from service label)
-IV 0 0 0 (J..O 0 DO ~ 1 '-rh\1- -4 (.pC( V
PS Form 3811, July 1999 Domestic Return Receipt
10259S-00-M-0952
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JULIE A. BANKES,
Plaintifli'Petitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
CIVIL ACTION - DIVORCE
ROBERT E. BANKES,
DefendantIRespondent
NO. 00-7351 CIVIL TERM
IN DIVORCE
DR# 30369
Pacses# 512102993
ORDER OF COURT
AND NOW, this 18th day ofJanuary, 2001, upon consideration of the attached Petition for
Alimony Pendente Lite and/or counsel fees, it is hereby directed that the parties and their respective counsel
appear before R.J. Shaddav on Fehruarv 6. 2001 at 10:30A.M. for a conference, at 13 N. Hanover St.,
Carlisle, PA 17013, after which the conference officer may recommend that an Order for Alimony
Pendente Lite be entered.
YOU are further ordered to bring to the conference:
(I) a true copy of your most recent Federal Income Tax Return, including W-2's as filed
(2) your pay stubs for the preceding six (6) months
(3) the Income and Expense Statement attached to this order, completed as required by Rule
1910.11\:l
(4) verification of child care expenses
(5) proof of medical coverage which you may have, or may have available to you
IF you fail to appear for the conference or bring the required documents, the Court may issue a
warrant for your arrest.
BY THE COURT,
George E. Hoffer, President Judge
Mail1i1QjliesIOi\'.
,jM<$'"O!l,t9.~
Petitioner
< Respondent
Marylou Matas, Esquire
~ ..;JL
Date of Order: January 18,2001
YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND
REPRESENT YOU. 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 MAY GET
LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIA nON
2 LffiERTY AVE.
CARLISLE, PENNSYLVANIA 170 I3
(717) 249-3166
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PlaintifflPetitioner
DR#:
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
v.
CIVIL ACTION - LAW
ROBERT E. BANKES, : NO. 00-7351 CIVIL TERM
Defendant/Respondent: IN DIVORCE
PETITION FOR ALIMONY PENDENTE LITE.
INTERIM COUNSEL FEES AND EXPENSES
AND NOW comes Petitioner, Julie A. Bankes, by and through her counsel of records,
Marylou Matas, Esquire, and petitions the Court as follows:
1. Your Petitioner is the above named Plaintiff, Julie A. Bankes, an adult individual
currently residing at 7 Pine Road, Apartment 606, Mount Holly Springs, Cumberland
County, Pennsylvania.
2. Your Respondent is the above named Defendant, Robert E. Bankes, an adult
individual currently residing at 114 Second Street, Boiling Springs, Cumberland
County, Pennsylvania, and whose mailing address is P.O. Box 316, Boiling Springs,
Pennsylvania.
3. Petitioner's date of birth is June 6, 1968, and her Social Security number is 077-64-
5878.
4. Respondent's date of birth is December 20, 1965, and his Social Security number is
204-60-1921.
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5. The divorce action filed to the above docketed number in the Court of Common Pleas
of Cumberland County requests a divorce based upon Section 330l(c) of the Divorce
Code of 1980 as amended.
6. Petitioner has employed counsel and will incur certain costs and expenses in pursuit
of the aforementioned divorce action, but is without sufficient assets or income to
support herself, pay for attorney's fees, or pay for the costs and expenses associated
with this action.
7. Respondent has sufficient income and earning capacity, as well as assets, to support
the Petitioner or to assist in supporting Petitioner, and to pay alimony pendente lite to
Petitioner, as well as assist in paying her counsel fees, costs and expenses.
8. Petitioner no longer resides in the property owned by Respondent and Respondent is
providing no financial assistance to Petitioner.
WHEREFORE, Petitioner request you Honorable Court to enter an Order of Alimony
Pendente Lite, Interim Counsel Fees, Costs and Expenses in this matter.
Respectfully submitted,
()
tas, quire
Attorney PlaintifflPetitioner
GRIFFIE & ASSOCIATES
200 North Hanover Street
Carlisle, PA 17013
(717) 243-5551
(800) 347-5552
.
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VERIFICATION
I verify that the statements made in the foregoing document are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section
4904, relating to unsworn falsifications to authorities.
DATE:JJ/2o/00
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In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
JULIE A. BANKES ) Docket Number 00-7351 CIVIL
Plaintiff ) 51210299~O.3G,q
vs. ) P ACSES Case Number
ROBERT E. BANKES )
Defendant ) Other State ID Number
ORDER
AND NOW, to wit on this
6TH DAY OF FEBRUARY, 2001
IT IS HEREBY
ORDERED that the 0 Complaint for Support or 0 Petition to Modify or (i) Other
REQUEST FOR APL CONFERENCE
filed on DECEMBER 28, 2001 in the above captioned
matter is dismissed without prejudice due to:
THE PARTIES INCOMES AND THE PENNSYLVANIA SUPPORT GUIDELINES AND DEFENDANT
HAVING AN OBLIGATION FOR THE PARTIES' DAUGHTER.
o The Complaint or Petition may be reinstated upon written application of the plaintiff
petitioner.
BY THE COURT:
~
Edward E. Guido
JUDGE
DRO: RJ Shadday
xc: pWntiff
defendant
Marylou Matas, Esquire
~
Service Type M
Form OE-506
Worker ID 21005
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