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SHANNON M. GAUVRY
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, FA
v.
No. 2001-558
STEVEN A. GAUVRY
Defendant
CIVIL ACTION - 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 Section 3301 c of the Divorce Code.
2. Date and manner of service of the Complaint: Acceptance of Service by first class mail,
certified return receipt requested, delivery and acceptance dated February 10,2001.
3. (Complete either paragraph (a) or (b))
(a) Date of execution of the Affidavit of Consent required by Section 330 I (c) of the
Divorce Code: by Plaintiff on May 16, 2001; and signed by Defendant on May 14, 2001.
(b) (1) Date of execution of the PLAINTIFF'S Affidavit required by Section 3301(d)
of the Divorce Code:
(2) Date of service of the PLAINTIFF'S Affidavit upon the
DEFENDANT:
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4. Related claims pending: All claims settled by agreement.
5. Date and manner of service of the Notice of Intention to File Praecipe to Transmit
Record, a copy of which is attached: (check one)
(a) Decree to be entered under 3301(d) (1) of the Divorce Code;
(b) Decree to be entered under 3301 @ of the Divorce Code;
x (c) Not Applicable. (See Waiver filed by Defendant on May 14,2001 and filed by
Plaintiff on May 16, 2001.)
Date:5)~~/ ~I
Byff/~
ryan S. Walk
Attorney ID No. 63881
Counsel for Plaintiff
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POST-NUPTIAL AGREEMENT
THIS AGREEMENT made and entered into thisllJl-lday of JAtVIJI'WY ,2001 by and
between;
SHANNON M. GAUVRY, of 1904 Dickinson Avenue,
Building 10, Apartment B, Camp Hill, Cumberland County,
Pennsylvania, party of the first part, hereinafter called
"Wife",
AND
STEVEN A. GAUVRY, of2014 Harvard Avenue, Camp Hill,
Cumberland County, Pennsylvania, party of the second part, hereinafter
caned "Husband";
WITNESSETH:
WHEREAS, Husband and Wife were married to each other on December 18, 1993 in
Cumberland County, Pennsylvania and last resided together at 2014 Harvard Avenue, Camp Hill,
Pennsylvania; and
WHEREAS, the parties are the natural parents of one minor child named Caitlin Shea
Gauvry, born February 15, 1996; and
WHEREAS, during their marriage the parties accumulated various assets and property
which is more fully itemized and identified in a certain list or schedule attached hereto marked
"Exhibit A" and incorporated herein by reference thereto; and
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WHEREAS, certain differences have arisen between the parties, as a consequence of
which they have separated and now live separate and apart from each other; and
WHEREAS, the parties intend to commence an action in divorce in the Court of
Common Pleas of Cumberland County, Pennsylvania (hereinafter called "Divorce Action"); and
WHEREAS, Husband is represented by Philip H. Spare, Esquire of the firm ofSnelbaker,
Brenneman & Spare, P. C. and Wife has upon her own accord freely and voluntarily elected not
to retain legal counsel although she has been informed of her right to do so and of the advisability
of doing so; and
WHEREAS, the parties having a full opportunity to be advised of their respective rights,
duties and obligations arising out of the marriage and each having a full opportunity to
investigate and evaluate the assets, liabilities and all other aspects of each other's property and
their jointly owned assets and liabilities, have come to an agreement for the final settlement of
their property and affairs.
NOW THEREFORE, in consideration of these presents and the mutual covenants,
promises, terms and conditions hereinafter set forth and to be kept and performed by each party
hereto, and intending to be legally bound hereby, the parties mutually agree as follows:
1. INCORPORATION OF PREAMBLE. The foregoing preamble and paragraphs are
incorporated by reference herein in their entirety.
2. DECLARATION AS TO ASSETS AND WAIVER OF EVALUATION.
The parties agree that the items of property set forth in "Exhibit A" are all of the assets
which they acquired during their marriage and which would be the subj ect of equitable
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distribution if submitted to a court for division under the provisions of the Pennsylvania Divorce
Code. The parties declare and agree that they are familiar with said assets and hereby waive the
evaluation thereof, although each party declares that shelhe has had full opportunity obtain such
evaluation.
3. DIVISION OF ASSETS. Upon the execution of this Agreement and except as
otherwise provided, the parties agree to divide, allocate, retain andlor transfer the assets shown
on "Exhibit A" as follows (the items numbers refer to the corresponding numbers on "Exhibit
A"):
A. ASSETS TO WIFE
3. Wife's pension and/or retirement benefits from her current employer, the
County of Dauphin, and former employers;
4. 2000 Chrysler Cirrus automobile;
7. Household goods, furniture and other tangible personal property currently in
Wife's possession;
B. ASSETS TO HUSBAND
1. Marital residence located at 2014 Harvard Avenue, Camp Hill, Cumberland
County, Pennsylvania;
2. The Parties' joint savings account at Pennsylvania State Employees Credit
Union (PSECU) Account No. 208-42-4365 and joint checking account No.
208-42-4365 at PSECU;
5. Husband's pension and lor retirement benefits from his current,employer, Big
Spring School District, and former employers;
6. 1999 Subaru Legacy Outback automobile;
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7. 3000 shares of Broadband Wireless stock valued at nine cents ($0.09) per
share as of December 21,2000;
9. Household goods, furniture and other tangible personal property currently in
Husband's possession.
4. MARITAL HOME. Husband shall use good faith efforts to refinance the marital
home located at 2014 Harvard Avenue, Camp Hill, Cumberland County, Pennsylvania within
three (3) years ofthe date of this Agreement. In the event Husband has not refinanced the
property and removed Wife's name from the note and mortgage within three (3) years of the date
of this agreement, the home shall be promptly listed for sale with a reputable real estate broker or
agent at or below its fair market value. Upon sale of the home, Husband may retain the net
proceeds after payment of: a) reasonable, customary and necessary closing costs (including, but
not limited to, radon remediation, if any; and b) the note and mortgage obligation, any home
equity loan or other liens against the property.
Any return of escrow amounts from the mortgage lender or refund from the homeowners'
insurance policy shall become the sole property of Husband. Husband shall be solely responsible
for payment of the mortgage, utilities, miscellaneous household expenses, repairs, taxes and any
and all other costs and expenses relating to the home whether incurred prior to or after execution
of this Agreement and shall indemnify and hold Wife harmless for such payments, costs and
expenses.
5. CUSTODY AND CHILD SUPPORT. The parties shaI1 enjoy shared legal custody
and shared physical custody of the parties' minor child, Caitlin Shea Gauvry, as follows.
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A. Wife shall have primary physical custody subject to the following partial physical
custody rights of Husband:
1. During the school year, alternating weekends from 5:00 p,m. Friday until 7:00
p.m. Sunday;
2. Two (2) evenings per week from 5:00 p.m. until 8:30 p.m.;
3. 9:00 a.m., December 26 through 5:00 p.m. January 1;
B. During the summer when school is not in session, Husband shall have primary
physical custody and Wife shall have an alternating weekend schedule and two (2)
evenings per week as set forth above.
C. Holidays:
1. In odd years, Easter (Saturday at 5:00 p.m until Sunday at 7:00 p.m.)and
Christmas Eve (5:00 p.m.untiI9:00 a.m. Christmas Day) with Husband;
Thanksgiving (5:00 p.m. Wednesday until 9:00 a.m. Friday) and Christmas Day
(9:00 a.m. until 9:00 a.m. December 26) with Wife;
2. In even years, Easter and Christmas Eve with Wife; Thanksgiving and Christmas
Day with Husband.
Husband agrees to pay child support in the amount of$ 740 per month ($440 for child
care which may be paid directly to provider and $300 to Wife) for the minor child based upon the
current custody arrangement. Husband shall also pay for Wife's car insurance until the 2000
Chrysler Cirrus is paid for or until she no longer uses the car. Husband shall continue to provide
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health insurance for the child so long as it remains available at no cost to him through his current
employer. Husband shall be entitled to claim the child as a dependent for purposes of income
taxation. The parties shall cooperate in the completion and execution of any and all forms or
documents as may be required to accomplish the foregoing objectives. In the event of changed
circumstances, the parties will attempt to negotiate an agreement. In the event an agreement
cannot be reached, either party may file for a modification with an appropriate court or domestic
relations office.
6. MARITAL DEBT. The parties agree that the only marital debts are the mortgage
obligation, the home equity loan, a car loan from Chrysler Credit in both names for the 2000
Chrysler Cirrus driven by wife and substantial credit card debt, primarily in Wife's name. Wife
intends to investigate the possibility of filing for personal bankruptcy to address the credit card
debt in her name. Husband shall be responsible for the mortgage and home equity loan payments
as set forth elsewhere in this Agreement. Husband shall be solely responsible for all credit card
debt in his name alone. Wife shall be solely responsible for all payments due to Chrysler Credit.
7. MUTUAL CONSENT DIVORCE. It is the intention of the parties, and the parties
agree, that by this Agreement they have resolved all ancillary economic issues related to the
dissolution of their marriage and that a no-fault divorce shall be granted by mutual consent of the
parties.
S. LIFE INSURANCE. The parties have the following life insurance policies:
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A. Insured: Catlin S. Gauvry; Owner: Shannon M. Gauvry. Northwestern Mutual
Life Insurance Company Policy No. 15101714.
B. Insured: Shannon M. Gauvry; Owner: Shannon M. Gauvry. Northwestern
Mutual Life Insurance Company Policy No. 14510144.
C. Insured: Steven A. Gauvry; Owner: Steven A. Gauvry. Minnesota Life Policy
No. 27530-625201
Ownership of the insurance policies shall remain the same as indicated above. Each
owner is responsible for premium payments and may change the beneficiary at will.
9. POST-SEPARATION OBLIGATIONS. The parties agree that any and all obligations
incurred subsequent to December 26, 2000, the date of separation, shall be the sole and separate
liability and responsibility of the party incurring the obligation. Each party agrees that he/she
will not incur or attempt to incur any obligations for or on behalf of the other party and will
indemnify and hold harmless the other party of and from any and all liability arising from such
post-separation and/or future obligations.
10. RELEASE OF RIGHTS UNDER DIVORCE CODE. Except only as specifically
provided to the contrary hereinabove in this Agreement, each party hereby waives and forever
releases the other party of and from any and all claims which either may have against the other by
reason of and pursuant to the Pennsylvania Divorce Code (and the divorce law of any other
jurisdiction) including, but not limited to, alimony, alimony pendente lite, equitable distribution
of marital property, counsel fees, costs and expenses, except that the performance of any
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obligations created hereunder may be enforced by any remedies under the Pennsylvania Divorce
Code.
11. INDIVIDUAL PROPERTY. Except only as may be provided specifically to the
contrary hereinabove, each party shall retain all property, real, personal and otherwise, which is
presently titled in his or her name and ownership, whether or not said property is or would be
deemed to be marital property under the Pennsylvania Divorce Code and each party hereby
expressly releases the other of and from any and all right of equitable distribution in and to said
individually owned property of such other party.
12. GENERAL RELEASE. Husband relinquishes his inchoate intestate right in the
estate of Wife, and Wife relinquishes her inchoate intestate right in the estate of Husband, and
each of the parties hereto by these presents, for himself or herself, his or her heirs, executors,
administrators or assigns, does hereby remise, release, quit-claim and forever discharge the other
party hereto, his or her heirs, executors, administrators or assigns, or any of them, of any and all
claims, demands, damages, actions, causes of action or suits at law or in equity of whatsoever
kind or nature, for or because of any matter or thing done, omitted or suffered to be done by such
other party prior to the date hereof, except that this release shall in no way exonerate or discharge
either party from the obligations and promises made or imposed by reason of this Agreement.
This Agreement shall not be construed to affect or bar the right of either party to an action for the
enforcement or performance of this Agreement which may be instituted pursuant to the remedies
available under the Pennsylvania Divorce Code.
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13. SURVIVAL OF AGREEMENT. It is the intention of the parties that this Post-
Nuptial Agreement shall survive any action in divorce which may be instituted or prosecuted by
either party, and no order, judgment or decree of divorce, temporary, interlocutory, final or
permanent, shall affect or modify the terms of this Agreement, but said Agreement may be
enforced by any remedy at law or in equity, including enforcement proceedings under the
Pennsylvania Divorce Code. The parties agree to incorporate this Agreement into a separate
order of court to be entered in the Divorce Action, but this Agreement shall not be merged into
said order or decree in divorce.
14. COOPERATION. The parties agree to cooperate with each other and to make,
execute, acknowledge and deliver such instruments and take such further action as may hereafter
be determined to be requisite and necessary to effect the purposes and intention of this Post-
Nuptial Agreement.
15. VOLUNTARY EXECUTION. Each party acknowledges that this Post-Nuptial
Agreement is fair and equitable, that it is being entered into voluntarily, with full knowledge of
the assets of both parties, and that it is not the result of any duress or undue influence. The
parties acknowledge that they have been furnished with all information relating to the financial
affairs of the other to the extent same has been requested by each of them.
16. ENTIRE AGREEMENT. This Post-Nuptial Agreement contains the entire
understanding of the parties and there are no representations, warranties, covenants or
undertakings other than those expressly set forth herein. The parties acknowledge and agree that
the provisions of this Agreement with respect to the distribution and division of marital and
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separate property are fair, equitable and satisfactory to them based on the length of their marriage
and other relevant factors which have been taken into consideration by the parties. Both parties
hereby accept the provisions of this Agreement with respect to the division of property in lieu of
and in full and final settlement and satisfaction of all claims and demands that they may now
have or hereafter have against the other for equitable distribution of their property by any court of
competent jurisdiction pursuant to the Pennsylvania Divorce Code or any amendments thereto.
Each party voluntarily and intelligently waives and relinquishes any right to seek a coilrt ordered
determination and distribution of marital property, but nothing herein contained shall constitute a
waiver by either party of any rights to seek the relief of any court for the purpose of enforcing the
provisions of this Agreement.
17 . WAIVER. The waiver of any term, condition, clause or provision of this Agreement
shall in no way be deemed or considered a waiver of any other term, condition, clause or
provision of this Agreement.
18. APPLICABLE LAW. This Agreement shall be construed, interpreted and enforced
according to the laws of the Commonwealth of Pennsylvania.
19. HEADINGS. The headings or titles of the numbered paragraphs of this Agreement
have been used only for the purpose of convenience and shall not be resorted to for the purposes
of interpretation or construction of the text of this Agreement.
20. BREACH. It is expressly stipulated that if either party fails in the due performance
of any of his or her material obligations under this Agreement, the other party shall have the
right, at his or her election, to sue for damages for breach thereof, to sue for specific performance
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or to seek any other legal remedies as may be available, and the defaulting party shall pay the
reasonable legal fees for any services rendered by the non-defaulting party's attorney in any
action or proceeding to compel performance hereunder.
21. AFTER-ACOUIRED PROPERTY. Each of the parties shall hereafter own and enjoy
independently of any claim or right of the other, all items of property, be they real, personal or
mixed, tangible or intangible, which are hereafter acquired by him or her, with full power in him
or her to dispose of the same as fully and effectively, in all respects and for all purposes as
thongh he or she were unmarried.
22. COUNSEL FEES, COSTS AND EXPENSES. Each party shall be responsible for
his or her own legal fees, costs and expenses, if any, incurred in connection with their separation
and/or the dissolution of their marriage.
23. INDEMNIFICATION. Each party represents and warrants to the other that he or she
has not incurred any debt, obligation, or other liability, other than described in this Agreement,
on which the other party is or may be liable. Each party covenants and agrees that if any claim,
action or proceeding is hereinafter initiated seeking to hold the other party liable for any other
debts, obligations, liability, act or omission of such party, such party will at his or her sole
expense, defend the other against any such claim or demand, whether or not well-founded, and
that he or she will indemnify and hold harmless the other party in respect of all damages as
resulting therefrom. Damages as used herein shall include any claim, action, demand, loss, cost,
expense, penalty, and other damage, including without limitation, connsel fees and other costs
and expenses reasonably incurred in investigating or attempting to avoid same or in opposing the
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imposition thereof or enforcing this indemnity, resulting to Husband or Wife from any inaccurate
representation made by or on behalf of either Husband or Wife to the other in this Agreement,
any breach of any of the warranties made by Husband or Wife in this Agreement, or breach or
default in performance by Husband or Wife of any of the obligations to be performed by such
party hereunder. The Husband or Wife agrees to give the other prompt written notice of any
litigation threatened or instituted against either party which might constitute the basis for a claim
for indemnity pursuant to the terms of this Agreement.
24. MODIFICATION. No modification, rescission or amendment to this Agreement
shall be effective unless in writing signed by each of the parties hereto.
25. SEVERABILITY. If any provision of this Agreement is held by a Court of
competent jurisdiction to be void, invalid or unenforceable, the remaining provisions hereof shall
nevertheless survive and continue in full force and effect without being impaired or invalidated
in any way.
IN WITNESS WHEREOF, the parties have hereunto set their respective hands and seals
the day and year first above written intending to legally bind themselves and their respective
heirs, personal representatives and assigns.
WITNESSED BY:
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Shanoon M. au
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COMMONWEALTH OF PENNSYLVANIA )
SS.
COUNTY
OF CUMBERLAND )
On this, thed.;;>.dday of ::JO r>(.t zl ,- '1' 2001, before me, a Notary Public in
and for the Commonwealth and County aforesaid, the undersigned officer,
personally appeared STEVEN A. GAUVRY, 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 purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
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On this, the /iP / day of ,<f7t.t , 2001, before me, a Notary Public in
and for the Commonwealth a countXaid, the undersigned officer,
personally appeared SHANNON M. GAUVRY, 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 purposes therein contained.
SS.
COMMONWEALTH OF PENNSYLVAt;HA )
COUNTY
)
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
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Notarial seal -".-
Lucy Filizlani, Notal)' Publtc
Swatara Twp.; DauphIn CounlY
My Commission Expires Apr. 12.2004
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EXHIBIT A to GAUVRY POST-NUPTIAL AGREEMENT
1. Marital residence located at 2014 Harvard Avenue, Camp Hill, Cumberland
County, Pennsylvania;
2. The Parties' joint savings account at Pennsylvania State Employees Credit Union
(PSECU) Account No. 208-42-4365 and joint checking account No. 208-42-4365
at PSECU;
3. Wife's pension andlor retirement benefits from her current employer, the County
of Dauphin, and former employers;
4. 2000 Chrysler Cirrus automobile;
5. Husband's pension and lor retirement benefits from his current employer, Big
Spring School District, and former employers;
6. 1999 Subaru Legacy Outback automobile;
7. Household goods, furniture and other tangible personal property currently in
Wife's possession;
8. 3000 shares of Broadband Wireless stock valued at nine cents ($0.09) per share as
of December 21, 2000.
9. Household goods, furniture and other tangible personal property currently in
Husband's possession.
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IN THE COURT OF COMMON PLEAS
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OF CUMBERLAND COUNTY
STATE OF
PENNA.
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~HANNnN M ~ATnT'DV
NO.
2001-558
PLAINTIFF
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VERSUS
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R1'RVRN A. GAIJVRY
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DEFENDANT
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DECREE IN
DIVORCE
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AND NOW,
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2001 , IT IS ORDERED AND
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DECREED THAT RHANNON M GAmlRY
, PLAINTIFF,
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AND
STEVEN A. GAUVRY
, DEFENDANT,
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ARE DIVORCED FROM THE BONDS OF MATRIMONY.
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THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECOIJ.o,IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED; l.A)~
l:he Post Nuptual Se:ttlement Agreement of the Parties dated, January 16, 2001
and attachea heretd as Exhibit A; is hereby incorporated by reference hereto an
shall have the same force and effect as if it had been originaljoy entered as an
Order fo Court, proved however, that said Agreement shall not merge with this
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Order, but shall retain its contracted signifigance as well. .
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SHANNON M. GAUVRY
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
v.
No.
2001 - S'SP C;(j~L "'-T~
STEVEN A. GAUVRY
Defendant
CIVIL ACTION - DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
YOU HA VB 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
Prothonotary Dauphin County Courthouse, Harrisburg, P A.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULl\1ENT 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 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.
Lawyer Referral Service
Court Administrator
Cumberland County Courthouse
Carlisle, Pa 17013
240-6200
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SHANNON M. GAUVRY
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
v.
No.
2001- 55K' ~ TL<.-
STEVEN A. GAUVRY
Defendant
CIVIL ACTION - DIVORCE
COMPLAINT UNDER SECTION 3301(c)
OF THF. DIVORCE CODE
TO THE HONORABLE, JUDGES OF SAID COURT:
AND NOW, comes Plaintiff, Shannon M. Gauvry, by Bryan S. Walk Esq., and
represents as follows:
COUNT I
DIVORCE UNDER SECTION 3301(c)
OF THE DIVORCE CODE
L Plaintiff is Shannon M. Gauvry, who currently resides at 1904 Dickinson Ave., Apt lOB,
Camp Hill, Pennsylvania 17111, and has resided there for approximately 1 month.
2. Defendant is Steven A. Gauvry, who currently resides at 2014 Harvard Ave., Camp Hill,
Pennsylvania 17111, and has resided there for approximately 5 years.
3. Plaintiff has been a bona fide resident in the Commonwealth for at least six (6) months
immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on December 18, 1993, in Cumberland County.
5. There have been no prior actions of divorce or annulment between the parties.
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6. Plaintiff avers that there is 1 child lUlder the age of 18.
7. The Plaintiff is a citizen of the United States of America.
8. The Defendant is not a member of the Armed Services of the United States of America or its
Allies.
9. The marriage is irretrievably broken.
10. The Plaintiff has been advised that cOlUlseling is available and that Plaintiff may have the
right to request that the Court require the parties to participate in cOlUlseling.
WHEREFORE, Plaintiff requests the Court to enter a Decree in Divorce pursuant to
Section 330 l( c) of the Divorce Code dissolving the marriage between the Plaintiff and the
Defendant.
By: &~ ~
LD.# 63881
108 - 112 Walnut Street
Harrisburg, P A 17101
(717) 238-5113
ATTORNEY FOR PLAINTIFF
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VERIFICATION
I verify that the statements made herein are true and correct. I understand that false
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falsification to authorities.
Date:
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Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
v.
No.
2001
STEVEN A. GAUVRY
Defendant
CIVIL ACT][ON - DIVORCE
CERTIFICATE OF SERVICE
I hereby certify that on the 2. S Day of January, 2001, A copy of the Divorce Complaint
was served by certified mail, restricted delivery,retum receipt requested, addressee copy of
Plaintiff's Complaint In Divorce upon the person named below, in accordance with the
applicable Rules of Procedure, addressed as follows:
Steven Gauvry
"2014 Harvard Ave.
Camp Hill, Pa 17111
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Bry . Walk
Attorney ill No. 63881
108-112 Walnut Street
Harrisburg, PA 17101
(717) 238-5113
Counsel for Plaintiff
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Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
v.
No. 558-S-2001
STEVEN A. GAUVRY
Defendant
CIVIL ACTION - DIVORCE
ACCEPTANCE OF SERVICE
: . Complete items 1, 2, and 3. Also complete
item 4 if Restricted Delivery is desired.
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Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
v.
No. 2001-558
STEVEN A. GAUVRY
Defendant
CIVIL ACTION - DIVORCE
PLAINTIFF'S AFFIDAVIT OF CONSENT AND WAIVER OF COUNSELING
1. A Complaint in Divorce under Section 3301(C) of the Divorce Code was filed on
January 26, 2001.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have
elapsed from the date of filing 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. Section 4904 relating to unsworn
falsification to authorities.
Date: S-!lIJ-DI
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Shannon Gauvry
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SHANNON M. GAUVRY
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
v.
No. 2001-558
STEVEN A. GAUVRY
Defendant
CIVIL ACTION - DIVORCE
DEFENDANT'S AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301 (C)of the Divorce Code was filed on January
26, 2001.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have
elapsed from the date of filing the Complaint.
3. I consent to the entry of a fmal 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. Section 4904 relating to
unsworn falsification to authorities.
Steven Gauvry
Date: ~/'I/o1
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Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
v.
No. 2001-558
STEVEN A. GAUVRY
Defendant
CIVIL ACTION - DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE
DECREE UNDER SECTION 3301 (c)OF THE DIVORCE CODE
1. I consent to the entry of a final Decree of Divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees
or expenses if! 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. Section 4904 relating to
unsworn falsification to authorities.
Date:
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Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
v.
No. 2001-558
STEVEN A. GAUVRY
Defendant
CIVIL ACTION - DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUEST 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 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. Section 4904 relating to
unsworn falsification to authorities.
Steven Gauvry
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