HomeMy WebLinkAbout00-07818
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF
SANDRA J. LLOYD.
Plaintiff
VERSUS
KENNETH LLOYD ,
Defendant
AND NOW,
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PEN NA.
NO.00-7818
DECREE IN
DIVORCE
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,2004 ,IT 15 ORDERED AND
DECREED THAT
SANDRA J. LLOYD
, PLAINTIFF,
AND
KENNETH LLOYD
, 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.
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The Property Settlement Agreement between the parties shall be incorporated
into the final decree for purposes
the final Decree in Divorce.
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ATTEST,
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PROTHONOTARY
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PROPERTY SETTLEMENT AGREEMENT
This is a Property Settlement Agreement entered into this \o'h day Of~,
2004, by and between KENNETH E. LLOYD, of Cumberland County, Pennsylvania
(hereinafter referred to as "Husband"),
and
SANDRA J. LLOYD, of Cwnberland County, Pennsylvania (hereinafter referred to as
"Wife").
WITNESSETH:
WHEREAS, Husband and Wife were lawfully married on August 2, 1980, and;
WHEREAS, two children have been conceived of this marriage: Tamara J. Lloyd
whose date of birth is July 8,1981 and Kari E. Lloyd whose date of birth is February 8,
1983; and
WHEREAS, unhappy differences have arisen between Husband and Wife in
consequence of which they are now living separate and apart from each other; and
WHEREAS, Husband and Wife are now in the process of obtaining a divorce,
and, consequently, they desire to settle and determine finally and for all time both their
respective financial and property rights and obligations, including any and all claims
which either of them may have against the other, including, without limitation:
I. The settling of all matters between them relating to the ownership of real and
personal property, including property heretofore or subsequently acquired by either party;
2. The settling of all disputes, rights and/or interests between them arising out of
or by reason of their marriage, including, but not limited to, all matters relating to
equitable distribution of marital property, alimony pendent elite, spousal support and
counsel fees; and
3. In general, the settling of any and all actual and possible claims by each party
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against the other or against their respective estates.
NOW THEREFORE, in consideration of this Property Settlement Agreement,
and of the mutual promises, covenants and undertakings set forth herein, and
incorporating the above "WHEREAS" clauses herein by reference, the parties hereto,
each intending to be legally bound hereby, covenant and agree as follows;
1. SEPARATION: It shall be lawful for each party at all times hereafter to
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live separate and apart from the other party at such place as he or she may from time to
time choose or deem fit. The foregoing provisions shall not be taken as an admission on
the part of either party of the lawfulness or unlawfulness of the causes leading to their
living apart.
2. INTERFERENCE: Each party shall be free from interference, authority
and contact by the other, as fully as if he or she were single and unmarried except as may
be necessary to carry out the provisions of this Agreement. Neither party shall molest the
other or attempt or endeavor to molest the other, nor compel the other to cohabit with the
other, or in any way harass or malign the other, nor in any way interfere with the other's
peaceful existence, separate and apart from the other.
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3. WIFE'S DEBTS: Wife represents and warrants to Husband that since the
separation she has not and in the future she will not contract or incur any debt or liability
for which Husband or his estate might be responsible, and that she shall indemnify and
save harmless Husband from any and all claims or demands incurred by her.
4. HUSBAND'S DEBTS: Husband represents and warrants to Wife that
since the separation he has not and in the future he will not contract or incur any debt or
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liability for which Wife or her estate might be responsible, and that he shall indemnify
and save harmless Wife from any and all claims or demands made against her by reason
of debts or obligations incurred by him.
5. OUTSTANDING JOINT DEBTS: All debts, obligations or liabilities
incurred at any time in the past by either of the parties will be paid promptly by the party
which incurred such debt, obligation or liability, unless except as otherwise specifically
set forth in this Agreement. Each of the parties hereto further promises, covenants and
agrees that each will now and at all times hereafter save harmless and keep the other or
his or her estate indemnified and saved harmless from all debts or liabilities incurred by
him or her, as the case may be, and from all actions, claims and demands whatsoever
with respect thereto, and from all costs, legal or otherwise, and counsel fees whatsoever
appertaining to such actions, claims and demands.
Neither party shall, after the date of this Agreement, contract or incur any debt or
liability for which the other or his or her property might be responsible, and shall
indemnify and save harmless the other from any and all claims or demands made against
her or him by reason of debts or obligations incurred by her or him, and from all costs,
legal costs and counsel fees incurred in connection therewith unless provided to the
contrary herein.
6. SAVINGS. CHECKING. AND INVESTMENT ACCOUNTS:
Husband and Wife are owners of individual savings, checking and investment accounts at
various institutions, and Husband hereby releases all claims in and to all accounts in the
name of Wife, and Wife hereby releases all claims in and to all accounts in the name of
Husband, and each party shall retain as his or her separate property each account
currently titled to that party. Husband and Wife agree to sign, upon request and after
execution of this Agreement, any titles or any other documents reasonably necessary to
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give effect to this Section.
Husband agrees to pay Wife the sum of $6,839.08 in equitable distribution.
Husband will repay this debt to Wife at the rate of $150.00 per month due by the first of
every month until the same is paid in full. In addition, Husband agrees to place a lien
against any and all motor vehicles Husband owns, including his van, in favor of Wife in
the amount of $6,839.08. Once this debt has been paid in full to Wife, Wife agrees to
execute any necessary paperwork to remove the lien at the Department of Transportation;
however, Husband will be responsible for the cost of recording and removing the lien.
7. HUSBAND'S RELEASE: Husband does hereby release, remise,
quitclaim, and forever discharge Wife and the Estate of Wife from any and all claims that
he now has or may hereafter have against Wife, or in, to, or against her Estate or any part
thereof, whether arising out of any former contracts, agreements, engagements, or
liabilities of Wife, or by way of dower or claim in the nature of dower, spouse's right or
under any intestate laws or the right to take against Wife's Will, or for equitable
distribution, support, alimony, alimony pendente lite, or maintenance of any other nature
whatsoever, excepting only those rights accruing to Husband under this Postnuptial
Agreement.
8. WIFE'S RELEASE: Wife does hereby release, remise, quitclaim, and
forever discharge Husband and the Estate of Husband from any and all claims that she
now has or may hereafter have against Husband, or in, to, or against his Estate or any part
thereof, whether arising out of any former contracts, agreements, engagements, or
liabilities of Husband, or by way of dower or claim in the nature of dower, spouse's right
or under any intestate laws or the right to take against HusblWd's Will, or for equitable
distribution, support, alimony, alimony pendente lite, or maintenance of any other nature
whatsoever, excepting only those rights accruing to Wife under this Postnuptial
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9. MUTUAL INDEMNIFICATION: Each party represents that no debts,
liabilities, or obligations have been incurred or contracted for for which the other party or
the Estate of the other party may be responsible or liable, except those specifically
identified in this Agreement.
Each party hereto shall hereafter keep the other and his or her heirs and personal
representatives indemnified and saved harmless against and from all debts and liabilities
contracted for or incurred by or on behalf of the indemnifying party, and against and from
all actions, proceedings, claims, demands, costs, attorneys' fees and expenses incurred in
respect to any such debts or liabilities, excepting, however, obligations of the parties
hereto to each other under this Agreement.
10. SPOUSAL SUPPORT: Husband and Wife agree that after both parties
have fully executed the Property Settlement Agreement and the Federal Government has
processed the Military Qualifying Order for Husband's retirement, as soon as Wife
receives her first retirement payment, Wife will contact Domestic Relations and have her
spousal support action terminated as of the date of the first retirement payment.
11. DIVISION OF PERSONAL PROPERTY: The parties have divided
between them, to their mutual satisfaction, their personal property and the personal
effects, household furniture and furnishings, and all other articles of personal property
which have theretofore been used by them in common, and neither party will make any
claim to any items of personal property which are now in the possession or under the
control of the other. Should it become necessary, the parties each agree to sign any titles
or documents necessary to give effect to this paragraph upon request.
Wife shall retain the Buick Regal as her own. Wife will also retain the Buick
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12. PENSIONIRETIREMENT ACCOUNTS: Husband and Wife agree that
Wife shall maintain her retirement account with her employer as her sole and separate
property and Husband waives any claim in the same.
Husband and Wife also agree that Wife shall receive fifty (50%) percent of
Husband's Federal Retirement Account which resulted from his employment with the
United States Marine Corps. Husband and Wife shall effectuate this transfer pursuant to
and in accordance with the terms of the Military Qualifying Order ("the Stipulation,"
herein) executed by the parties contemporaneously with their execution of this
Agreement. A copy of the Stipulation is attached hereto as Exhibit A and incorporated
herein by reference.
Husband and Wife agree that Wife's Counsel shall submit the Stipulation to the
Court of Common Pleas of Cumberland County, Pennsylvania, requesting that the
Stipulation be entered as an Order of Court.
Husband and Wife further agree that Husband will pay directly to Wife her 50%
portion of Husband's retirement as of the date of execution of this Agreement until such
time as Wife receives the same from the Federal Government.
13. LIFE INSURANCE POLICIES: Husband and Wife agree to waIve
any and all claims and relinquish all rights and interest they may have in any and all life
insurance policies of the other. Husband agrees to maintain the various life insurance
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policies he had as of the date of separation until his death. Husband further agrees to
name the parties' daughters as the only beneficiaries to these policies.
14. COUNSEL FEES: Husband and Wife agree to pay their respective
counsel fees and hereby waive any claim against the other for the same.
IS. BREACH: If either party breaches any provision of this Agreement, the
other party shall have the right, at his or her election, to sue for damages for such breach,
to sue for specific performance, and to seek such other remedies or relief as may be
available to him or her, and the party breaching this contract shall be responsible for
payment of legal fees and costs incurred by the other in enforcing their rights under this
Agreement.
16. BANKRUPTCY: If Husband files for bankruptcy within five (5) years
of the date of this Agreement, this Agreement shall constitute conclusive evidence of the
parties' intent that the obligations of this Agreement are in the nature of equitable
distribution and are not dischargeable in bankruptcy under the current bankruptcy law or
any amendment thereto. If any payments made to Wife are deemed a preference by a
court of competent jurisdiction in bankruptcy, the parties agree that this Agreement shall
be null and void as a resolution of Wife's economic claims in a divorce action filed in the
Court of Common Pleas in and for Cumberland County, Pennsylvania at Docket Number
00-7818. Wife shall have the right to prosecute her economic claims in the divorce
action as if this Agreement had not been entered and any order of support in any form
shall be effective retroactive to the date of discharge or the date of receipt of any payment
Wife is required to repay. If Husband's bankruptcy petition does not, in any way, alter,
change or disrupt the terms and conditions of this Agreement, then this Agreement shall
remain in full force and effect.
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17. ADDITIONAL INSTRUMENTS: Each of the parties shall from time to
time, at the request of the other, execute, acknowledge, and deliver to the other party any
and all further instruments that may be reasonably required to give full force and effect to
the provisions of this Agreement.
18. VOLUNTARY EXECUTION: Wife has employed and had the benefit
of counsel from Elizabeth S. Beckley, Esquire, as her attorney. Husband has employed
and had the benefit of counsel from Melissa Van Eck, Esquire, as his attorney.
Each party acknowledges that he or she fully understands the facts and has been
fully infonned as to his or her legal rights and obligations, and each party acknowledges
and accepts that this Agreement is, under the circumstances, fair and equitable, and that it
is being entered into freely and voluntarily after having received such advice and/or with
such knowledge as each party desires, and that execution of this Agreement is not the
result of any duress or undue influence and that it is not the result of any collusion or
improper or illegal agreement or agreements. Also, each party hereto acknowledges that
under the Pennsylvania Divorce Refonn Act, the Court has the right and duty to
detennine all marital rights of the parties, including divorce, alimony, alimony pendente
lite, equitable distribution of all marital property or property owned or possessed
individually by the other, counsel fees and costs of litigation and, fully knowing the same
and being advised of his or her rights thereunder, each party hereto still desires to execute
this Agreement, acknowledging that the tenns and conditions set forth herein are fair,
just, and equitable to each of the parties, and each party waives their respective right to
have the Court of Common Pleas or any Court of competent jurisdiction make any
detennination or order affecting the respective parties' right to a alimony, alimony
pendente lite, equitable distribution of all marital property, counsel fees and costs of
litigation.
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19. WAIVER OF LIABILITY: Husband and Wife each knowingly and
understandingly waive any and all possible claims that this Agreement is, for any reason,
illegal or, for any reason whatsoever of public policy, unenforceable in whole or in part.
Husband and Wife each do hereby warrant, covenant and agree that, in every possible
event, he or she is and shall forever be estopped from asserting any illegality or
unenforceability as to all or any part of this Agreement.
20. ENTIRE AGREEMENT: This Agreement contains the entire
understanding of the parties, and there are no representations, warranties, covenants, or
undertakings other than those expressly set forth herein. This Agreement shall be binding
upon the parties hereto, and there respective heirs, executors, administrators and assigns.
21. MODIFICATION AND WAIVER: A modification or waiver of any of
the provisions of this Agreement shall be effective only if made in writing and executed
by both parties with the same formality as this Agreement. The failure of either party to
insist upon strict performance of any of the provisions of this Agreement shall not be
construed as a waiver of any subsequent default of the same or similar nature.
22. INVALID PROVISIONS: 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 the Agreement,
and in all other respects the Agreement shall be valid and continue in full force, effect
and operation. Likewise, the failure of any party to meet his or her obligations under any
one or more of the Paragraphs herein, with. the exception of the satisfaction of the
conditions precedent, shall in no way void or alter the remaining obligations of the
parties.
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23. LAW OF AGREEMENT: This Agreement shall be construed according
to the laws of the Commonwealth of Pennsylvania and the United States of America in
effect at the time of the Agreement's execution.
24. DESCRIPTIVE HEADINGS: The descriptive headings used herein are
for convenience only. They shall have no effect whatsoever in determining the rights or
obligations of the parties.
25. DATE OF EXECUTIONIEFFECTIVE DATE: The "date of
execution" or "execution date" of this Agreement shall be defined as the date upon which
the parties signed the Agreement, if they did so on the same date, or if not on the same
date, then the date on which the Agreement was signed by the last party to execute this
Agreement. This Agreement shall become effective and binding upon both parties on the
execution date.
IN WITNESS WHEREOF, the parties have hereunto set their hands and seals
the day and year first above-written.
Melissa Van Eck, Esquire
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COMMONWEAL TII OF PENNSYLVANIA
COUNTY OF <1) frtt ~ rfYt;U
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On this the /0 ~ay of Mif
officer, personally appeared KENNETH E.
, 2004, before me, the undersigned
LLOYD, known to me (or satisfactorily
proven) to be the person whose name is subscribed to the within instrument, and
acknowledged that he executed the same for the purpose therein contained.
IN WITNESS WHEREOF, I have hereunto set my h d and notarial s
No
My Commission Expires:
NOTARIAL SEAL
AMY S. MASON, Notary Public
City of Harrisburg, PA Dauphin County
My Commissiori Expires June 10, 2006
COMMONWEALTH OF PENNSYL VANIA
COUNTY OF Ua PIJP;J
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) SS.:
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On this the Jilay of
officer, personally appeared SAND
, 2004, before me, the undersigned
J. LLOYD, known to me (or satisfactorily
proven) to be the person whose name is subscribed to the within instrument, and
acknowledged that she executed the same for the purpose therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and notarial seal.
01' IIINNe'l1.VANlA
NOTAPllAL ilEAL
IIILIWITH I, BICKLEY, NQIarY PublIc
Olty at HlIIlllbUrg, Dauphin CouIltY
OommiMlcn Elcplrea March 12, 211115
My Commission Expires:
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SANDRA J. LLOYD,
Plaintiff
v.
KENNETH LLOYD,
Defendant
:IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
:CIVIL ACTION -- LAW
:IN DIVORCE
:NO.00-7818
MILITARY QUALIFYING ORDER
IT IS HEREBY ORDERED AS FOLLOWS:
1. Acknowledgement: The parties acknowledge that Kenneth Lloyd was
previously accruing a military retirement benefit on his service in the United States
Marine Corps. The parties further agree that his former spouse, Sandra J. Lloyd, has an
interest in such military retirement benefits, and shall receive from Kenneth Lloyd
disposable military retired pay in an amount as set forth below. Further, Kenneth Lloyd
shall assist Sandra J. Lloyd in submitting any application(s) necessary to secure her share
of his disposable military retired pay as awarded herein.
2. Military Member Information: The name, last known address social
security number, and date of birth of the "Member" are:
Name:
Address:
Social Security Number:
Birth date:
Kenneth Lloyd
92 Autumn Lane, Enola, Pennsylvania 17025
202-46-6905
4-21-1954
3. Alternate Payee Information: The name, last known address social
security number, and date of birth of the "Alternate Payee" are:
Name:
Address:
Social Security Number:
Birth date:
SandraJ. Lloyd
28 Southmont Drive, Enola, Pennsylvania 17025
196-48-4843
11-20-1956
The parties hereto were husband and wife, and a divorce action is in this Court at the
above captioned docket number. The parties were married on August 2, 1980.
4. Assignment of Benefits: The Member assigns to the Alternate Payee an
interest in the Member's disposable military retired pay. The Alternate Payee is entitled
to a direct payment in the amount specified below and shall receive payments at the same
times as the Member.
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5. Observance of Member's Rights Under the Soldiers' and Sailors'
Civil Relief Act of 1940: The Member's rights under the Soldiers' and Sailors' Civil
Relief Act of 1940 (50 App U.S.C. Section 521) were observed by the Court during the
proceeding.
6. Pursuant to State Domestic Relations Law: This Order is entered
pursuant to the authority granted in the applicable domestic relations laws of
Pennsylvania.
7. Amount of Alternate Payee's Benefit: This Order assigns to the
Alternate Payee an amount equal to Fifty percent (50%) of the Member's disposable
military retired pay under the Plan as of his benefit commencement date.
8. Survivor Benefit Plan (SBP): The Alternate Payee shall not be awarded
a Survivor Benefit Plan Annuity under the Military Retirement System Plan.
9. Duration of Payments: The monthly payments set forth under Paragraph
7 shall commence to the Alternate Payee as soon as administratively feasible and shall
continue during he joint lives of the parties, and, to the extent permitted under law, and
shall terminate only upon the death of either Member or Alternate Payee.
10. Jurisdiction: The jurisdictional requirements of 10 U.S.C. Section 1408
have been complied with, and this Order has not been amended, superceded, or set aside
by any subsequent order.
11. Duration of Marriage Acknowledgment: The Member and Alternate
Payee acknowledge that they have been married for a period of more than ten years
during which time the Member performed more than ten years of creditable military
service.
12. Overpayments: The Alternate Payee agrees that any future
overpayments to her are recoverable to involuntary collection from her estate.
13. Notification: The Alternate Payee agrees to notify DFAS about any
changes affecting these provisions of it, or in the eligibility of any recipient receiving
benefits pursuant to it.
14. Qualification: The Member and the Alternate Payee intend that this
Order qualify under the Uniformed Services Former Spouses' Protection Act, 10 U.S.C.
Section 1408 and following. All provisions shall be construed and modified to the extent
necessary in order to qualify as a Qualifying Court Order.
15. Continued Cooperation of Member: The Member agrees to cooperate
with the Alternate Payee to prepare an application for direct payment to the Alternate
Payee from the Member's retired or retainer pay pursuant to 10 U.S.C. Section 1408.
The Member agrees to execute all documents that the United States, Marine Corps may
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require to certify that the disposable military retired pay can be provided to the Alternate
Payee.
16. Merger of Benefits and Indemnification: The Member agrees not to
merge his disposable military retired pay with any other pension and not to pursue any
course of action that would defeat the Alternate Payee's right to receive a portion of the
disposable military retired pay of the Member. The Member agrees not to take any action
by merger of the military retirement pension so as to cause a limitation in the amount of
the total retired pay in which the Member has a vested interest, and, therefore, the
Member will not cause a limitation of the Alternate Payee's monthly payments as set
forth above. If the Member becomes employed or otherwise has his military pension
merged, which employment or other condition causes a merger of the Member's
disposable military retired pay the Member will pay the Alternate Payee directly the
monthly amount assigned to her in Paragraph 7 of this Order under the same terms and
conditions as if those payments were made pursuant to the terms of this Order.
17. Direct Payment by Member: If in any month, direct payment is not
made to Alternate Payee by DFAS (or the appropriate military pay center) pursuant to the
terms of this Order, Member shall pay the amounts called for above directly to Alternate
Payee by the fifth day of each month in which the military pay center fails to do so,
beginning on the date that Alternate Payee would have been otherwise entitled to
commence her payments.
18. Actions by Member: If the Member takes any action that prevents,
decreases, or limits the collection by the Alternate Payee of the sums to be paid
hereunder, he shall make payments to the Alternate Payee directly in an amount sufficient
to neutralize, as to the Alternate Payee, the effects of the actions taken by the Member.
19. Submission of Information: The parties acknowledge that the following
items must be sent by the Alternate Payee to DFAS (Cleveland Center), located at P.O.
Box 998002, Cleveland, Ohio 44199-8002. The Member agrees to provide any of this
information to the Alternate Payee at the Alternate Payee's request and to make all
necessary efforts to obtain any of this information that the Alternate Payee is unable to
obtain.
1. A copy of this Qualifying Court Order that divides retired
pay and any decree that approves this Order certified within
ninety (90) days immediately preceding its service on the
applicable military pay center for the United States Marine
Corps.
11. A statement by the Alternate Payee which verifies that the
divorce decree has not been modified, superceded or set
aside.
iii. The parties' marriage certificate
IV. The Member's name, Social Security Number, date of birth
and name of military service.
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v. The Alternate Payee's name, address and Social Security
Number.
20. Continued Jurisdiction: The Court shall retain jurisdiction to enter such
further orders as are necessary to enforce the award to the Alternate Payee of the military
retirement benefits awarded herein, including the recharacterization thereof as a division
of Civil Service or other retirement benefits, or to make an award of alimony in the event
that the Member or DFAS fail to comply with the provision contained above requiring
said payments to the Alternate Payee by any means.
21. Taxes: The Alternate Payee shall be liable for any federal, state or local
income taxes associated with her assigned share of the disposable military retired pay.
22. Discovery: The Member hereby waives any privacy or other rights as
may be required for the Alternate Payee to obtain inforination relating to the Members
date and time of retirement, last unit assigmnent, final rank, grade and pay, present or
past retired pay, or other such information as may be required to enforce the award made
herein, or required to revise this Order so as to make it enforceable.
23. Definition of Military Retirement: For the purpose of interpreting this
Court's intention in making the division set out in this Order, "military retirement"
includes retired pay paid or to which Member would be entitled for longevity of active
duty and/or reserve component military service and all payments paid or payable under
the provisions of Chapter 38 or Chapter 61 of Title 10 of the United States Code.
IT IS SO ORDERED.
, J.
AI~~a(Yd
Vi D h~a Ilw, f~l
Melissa VanEck, Esquire -
Attorney for Kenneth Lloyd
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SANDRA J. LLOYD,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: IN DIVORCE
KENNETH LLOYD,
Defendant
: NO. 00-7818
PRAECIPE TO TRANSMIT RECORD
TO THE PROTHONOTARY:
Please transmit the record, together with the following information, to the Court
for the entry of a Decree of Divorce.
I. Ground for divorce: irretrievable breakdown of the marriage under Section
3301(c) of the Divorce Code.
2. Date and manner of service of the Complaint: the complaint was served on
Kenneth Lloyd, on November 28, 2000, by certified mail.
3. Date of execution of the affidavit of consent required by Section 3301(c) of the
Divorce Code: by plaintiff on June 2, 2004; by defendant on May 10, 2004.
4. Related claims pending: All claims have been satisfied by the Property
Settlement Agreement.
5. (a) Date plaintiff's Waiver of Notice June 2, 2004, and it is being filed
contemporaneously herewith.
(b) Date defendant's Waiver of Notice May 10,2004, and it is being
filed contemporaneously herewith.
DATED: G.-j-t1j
of Counsel
Respectfully submitted,
BECKLEY & MADDEN
212 North Third Street
P.O. Box 11998
Harrisburg, PA 17108
(717)233-7691
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SANDRA J. LLOYD,
Plaintiff,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. [() - 7'1/t
Cu;d
KENNETH LLOYD,
Defendant
: CIVIL ACTION - LAW
: 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.
When the ground for 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 Courthouse, 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 TillS 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, P A 17013
(717) 249-3166
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MARIA P. COGNETTI & ASSOCIATES
H. ALLISON WRIGHT~ ESQUIRE
Attorney I.D. No. 60311
210 Grandview Avenue, Suite 102
Camp Hill, PA 17011
Telephone No. (717) 909-4060
Attorneys for Plaintiff
v.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 1}1). 7f1f ~-r~
SANDRA J. LLOYD,
Plaintiff,
KENNETH LLOYD,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
COMPLAINT UNDER SECTION 3301(c)
OF THE DIVORCE CODE
1. Plaintiff is Sandra J. Lloyd, who has resided at 37 Southmont Drive, Enola,
Cumberland County, Pennsylvania 17025 since 1997.
2. Defendant is Kenneth Lloyd, who has resided at 92 Autumn Lane, Enola,
Cumberland County, Pennsylvania 17025 since October 5, 2000.
3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at
least six (6) months immediately previous to the filing of this Complaint.
4. Plaintiff and Defendant were married on August 2, 1980 at Camp Hill,
Pennsylvania, and separated on October 5, 2000.
5. There have been no prior actions of divorce or for annulment between the parties,
6. Neither of the parties in this action is presently a member of the Armed Forces.
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7. Plaintiff and Defendant are both citizens of the United States.
8. Plaintiff has been advised of the availability of marriage counseling and that she
may have the right to request the Court to require the parties to participate in such counseling.
Being so advised, Plaintiff does not request the Court require the parties to participate in
counseling prior to a divorce decree being handed down by the Court.
9. Plaintiff avers there is one child of the parties under the age of eighteen (18),
namely Kari Lloyd, age 17, born February 8,1983.
COUNT I - DIVORCE
10. Paragraphs one (I) through nine (9) are incorporated herein by reference as though
set forth in full.
II. The marriage is irretrievably broken.
WHEREFORE, Plaintiff, Sandra 1. Lloyd, requests this Honorable Court enter a decree in
divorce.
COUNT II - EOUITABLE DISTRIBUTION
12. Paragraphs one (I) through eleven (II) are incorporated herein by reference as
though set forth in full.
13. The parties have acquired property, both real and personal, during their marriage.
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14.
The parties have been unable to agree as to an equitable division of said property.
WHEREFORE, Plaintiff, Sandra 1. Lloyd, requests this Honorable Court equitably divide
the marital property of the parties.
Respectfully submitted,
MARIA P. COGNETTI & ASSOCIATES
Date: October 30, 2000
By:
~~
H. ALLISON G, ESQUIRE
Attorney LD. No. 60311
210 Grandview Avenue, Suite 102
Camp Hill, PA 17011
Telephone No. (717) 909-4060
Attorneys for Plaintiff
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VERIFICATION
I, Sandra 1. Lloyd, verify the statements made in the within document are true and correct.
I understand false statements herein are made subject to the penalties of 18 Pa.C.S. 94904 relating
to unsworn falsification to authorities.
~~7
Date: October 27, 2000
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SANDRA 1. LLOYD,
Plaintiff
:IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYL VANIA
v.
:CIVIL ACTION - LAW
: IN DIVORCE
KENNETH LLOYD,
Defendant
:NO.00-7818
AFFIDAVIT OF CONSENT
I. A complaint in divorce under Section 3301(c) of the Divorce Code was
filed on November 27,2000.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety
days have elapsed from the date of filing and service of the Complaint.
3. I consent to the entry of a final decree of divorce after service of notice of
intention to request entry ofthe decree.
I verify that the statements made in this affidavit are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 9
4904 relating to unsworn falsification to authorities.
Dated: G - )...-cJj
<A~~
Sandra J. Lloyd
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Plaintiff
:IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
v.
:CIVIL ACTION - LAW
: IN DIVORCE
KENNETH LLOYD,
Defendant
:NO.00-7818
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE
DECREE UNDER SECTION 3301(C) 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 concernmg alimony, division of
property, lawyer's fees or expenses if! do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by
the Court and that a copy of the decree will be sent to me immediately after it is filed
with the prothonotary.
I verify that the statements made in this affidavit are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 9
4904 relating to unsworn falsification to authorities.
Dated: CJ; -;)-04
.d~ dg~
Sandra J. Lloyll
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Plaintiff
IN THE COURT OF COMMON PLEAS FOR
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO.00-7818-CV
KENNETH LLOYD,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
November 3, 2000.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90)
days have elapsed from the date of filing and service 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. Section 4904 relating to
unsworn falsification to authorities.
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SANDRA J. LLOYD,
Plaintiff
IN THE COURT OF COMMON PLEAS FOR
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO.
00-7818-CV
KENNETH LLOYD,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY
OF A DIVORCE DECREE UNDER Q330HC) or Q330HD)
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. 94904, relating to
unsworn falsification to authorities.
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MARIA P. COGNETTI & ASSOCIATES
H. ALLISON WRIGHT, ESQUIRE
LD. No. 60311
210 Grandview Avenue, Suite 102
(717) 909-4060
Attorneys for Plaintiff
SANDRA J. LLOYD,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
v.
: NO. 00-7SIS CIVIL
: CIVIL ACTION - LAW
KENNETH LLOYD,
Defendant
: IN DIVORCE
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA
t
COUNTY OF CUMBERLAND
Before me, the undersigned Notary Public, this day, personally appeared H. Allison
Wright, Esquire, attorney for the Plaintiff, to me known, who being duly sworn according to law,
deposes the following:
I, H. Allison Wright, Esquire, being duly sworn according to law,
depose and state that service of the Complaint in Divorce in the
above-captioned matter was served by Certified Mail, Return
Receipt Requested, on Defendant, Kenneth Lloyd, 92 Autumn
Lane, Enola, Cumberland County, Pennsylvania 17025, on
November 2S, 2000. The Certified Receipt is attached hereto as
"Exhibit A."
By:
MARIA P. COGNETTI & ASSOCIATES
H.~ESQUIRE
Subscribed and sworn to before me
this 5th day ofDecember12000.
~[).~
Notary Public
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RE: LLOYD, S. DIV. COMPT
MARIA P. COGNETTI, ESQUIRE
COGNETTI & ASSOCIATES
210 GRANDVIEW AVENUE, SUITE 102
CAMPHILL,PA 17011
4a.
P 902 067 192
Service Type
CERTIFIED
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8. Addressee's Address (ifdjfferentfromaddress lJsed by sandfJr,) 3. Article Addressed to:
MR. KENNETH LLOYD
'Second"lirynAiiiliiissTsuiieTApi:TFioo;m(P;aiisehpr;ni"Naa7(yj 92 AUTUMN LANE
ENOLAPA 17025
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PS Form 3811, December 1994 IUSA4I99 CMF-088
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SANDRA J. LLOYD,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: IN DIVORCE
KENNETH LLOYD,
Defendant
: NO. 00-7818
PRAECIPE TO WITHDRAW EQUITABLE DISTRIBUTION COUNT
TO THE PROTHONOTARY:
Kindly withdraw the Equitable Distribution Count filed in the above-captioned
action.
DATED: riJ-;1-EJf
Respectfully submitted,
of Counsel
BECKLEY & MADDEN
212 North Third Street
P.O. Box 11998
Harrisburg, P A 171 08
(717)233-7691
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SANDRA J. LLOYD,
v.
KENNETH LLOYD,
TO: Prothonotary
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff,
NO. 00-7818
CIVIL ACTION - LAW
IN DIVORCE
Defendant.
PRAECIPE FOR ENTRY OF APPEARANCE
Kindly enter the appearance of Melissa L. Stickel, Esquire, on behalf of Defendant
Kenneth Lloyd.
Date: December 5,2000
Document #: 190181.1
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Respectfully submitted,
METZGER, WICKERSHAM, KNAUSS & ERB, P.c.
lJ,U. 11 M1d ~('t 1'"l I
Melissa L. Stickel, Esquire
LD. No. 85869
3211 North Front Street
P.O. Box 5300
Harrisburg, PA 17110-0300
(717) 238-8187
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CERTIFICATE OF SERVICE
I, Melissa L. Stickel, Esquire, of the law firm of Metzger, Wickersham, Knauss & Erb,
P.C., hereby certify that I served a true and exact copy of Praecipefor Entry of Appearance with
reference to the foregoing action by First Class Mail, postage prepaid, this !:ofh day of
December, 2000 on the following:
H. Allison Wright, Esquire
Maria P. Cognetti & Associates
210 Grandview Avenue
Suite 102
Camp Hill, PA 17011
METZGER, WICKERSHAM, KNAUSS & ERB, P.C.
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Melissa L. Stickel, EsquIre
Document #: 190181.1
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SANDRA 1. LLOYD,
Plaintiff,
v.
KENNETH LLOYD,
Defendant
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: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
: NO. 00-7818 CIVIL
: CIVIL ACTION - LAW
: IN DIVORCE
PRAECIPE FOR WITHDRA WALIENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Kindly withdraw my appearance on behalf SANDRA J. LLOYD, the Plaintiff in the
above-captioned matter.
Date:
~//(plol
By:
TO THE PROTHONOTARY:
MARIA P. COGNETTI & ASSOCIATES
&~'
M~COG I, ESQUIRE
Attorney LD. No. 27914
210 Grandview Avenue, Suite 102
Camp Hill, PA 17011
Telephone No. (717) 909-4060
Attorney for Plaintiff
Kindly enter my appearance on behalf of SANDRA J. LLOYD, the Plaintiff in the
above-captioned matter.
Date:
Lj/IJ/O;
By:
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BECKLEY & MADDEN
QUIRE
'""O'--'P""'''-:'"''''''"-''__'''''''''f''''~''''-='''''''''''''''''''r'''''_~''''''''""~~"""""''1''r''''''''''<''f''''''''''~'''''''''I''''''''"l'I''''~''''''''''''''''''''''''''''''~'"'''''''~'r'''"'''"~':''''p".~,""~,,~,~,,,~=.,~..,....-"~~,"._,~"..~,., .,",'
CERTIFICATE OF SERVICE
I, Elizabeth S. Beckley, hereby certify that a true and correct copy of the foregoing
document was this day served upon the person and in the manner indicated below.
SERVICE BY FIRST CLASS MAIL:
Melissa L. Stickel, Esquire
Metzger Wickersham
3211 North Front Street
P.O. Box 5300
Harrisburg, PA 17110-0300
DATED: L/~J()-'Ol
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SANDRA J. LLOYD,
IN TIIE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff,
v.
NO. 00-7818
KENNETH LLOYD,
CIVIL ACTION - LAW
IN DIVORCE
Defendant.
PRAECIPE TO WITHDRAW APPEARANCE
Kindly withdraw the appearance of Melissa L. VanEck, Esquire, on behalf of Defendant,
Kenneth Lloyd.
METZGER, WICKERSHAM, KNAUSS & ERB, P.C.
Dated: \.:2 -3\ - ()~
BY~;yY:l M. VCln 2cL
Melissa L. Van Eck, Esquire
Attorney LD. No. 85869
P.O. Box 5300
3211 North Front Street
Harrisburg, PA 17110-0300
(717) 238-8187
PRAECIPE TO ENTER APPEARANCE
Kindly enter the appearance of Andrew Spears, Esquire, on behalf of Defendant, Kenneth
Lloyd.
METZGER, WICKERSHAM, KNAUSS & ERB, P.C
By
C~~~
Andrew Spears, Esquire
P.O. Box 5300
Harrisburg, P A 17110
(717) 238-8187
Dated: --n - '10 -~
Document #: 247795.1
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