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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
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PENNA.
STATE OF
KEITH A. HARRISON,
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No.
01-3221 Civil Term
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Plaintiff
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VERS\JS
KRISTINE L. HARRISON,
Defendant
DECREE IN
DIVORCE
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AND NOW,
CJ~D I..v z.-,.
2-4''1, IT IS ORDERED AND
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DECREED THAT
KEITH A. HARRISON
, PLAINTIFF,
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AND
KRISTINE L. HARRISON
, 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 RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERE:D; THE TERMS AND PROVISIONS OF THE MARITAL
SETTLEMENT AGREEMENT SIGNED BY BOTH PARTIES AND FILED WITH
THE COURT ON OCTOBER 6, 2004 ARE HEREBY INCORPORATED BUT NOT
M~~~~V LN ~H~ V~C~~~ IN DIVORC~ AND REMAIN BINDING UPON THE
PARTIES.
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PROTHONOTARY
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KEITH A. HARRISON,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: OF CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: No. 01-3221 Civil Term
KRISTINE L. HARRISON,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
TO THE PROTHONOTARY:
Transmit the record, together with the following information, to the Court for entry of a
divorce decree:
1. Grounds for Divorce: Irretrievable breakdown under Section 3301(c).
2. Date and manner of service of the Complaint:
Certified Mail. Return Receipt Requested. Restricted Delivery. mailed on
June 1.2001 and delivered on June. 7. 2001. An Affidavit of Service was filed
with the Court on June 22. 2001.
3. Complete either Paragraph (a) or (b):
(a) Date of execution of the Affidavit of Consent required by Section 3301 (c) of
the Divorce Code: By Plaintiff: October S. 2004; By Defendant: October S.
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(b) (1) Date of execution of the Affidavit required by Section 3301(d) of the
Divorce Code: NLA (2) Date of filing and service of the Plaintiffs Affidavit
upon the Respondent: N/A.
4. Related claims pending:
All related daims were settled by a Marital Settlement Agreement dated
October 5, 2004 and filed with the Court on October 6. 2004.
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:
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(b) Date Plaintiff's Waiver of Notice in Section 3301(c) Divorce wasflledwith
the Prothonotary: October 6, 2004; Date Defendant's Waiver of Notice in
Section 3301(c)Divorce was filed with the Prothonotary: October 6.2004.
Date: (0- N-Oy
By:
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TimothyJ.Cmgan,Esqurre
Supreme Court I.D. #77944
130 West Church Street, Suite 100
DiJlsburg,PA 17019
(71 7) 432-9666
(Attorney for Plaintiff)
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MARITAL SETTLEMENT AGREEMENT
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THIS AGREEMENT, made this ~ day of D:i6her- 2004, by and
between KEITH A. HARRISON, of Dillsburg, York County, Pennsylvania (hereinafter referred
to as "HUSBAND") and KRISTINE L. HARRISON, of Mechanics burg, Cumberland County,
Pennsylvania (hereinafter referred to as "WIFE");
WITNESSETH:
WHEREAS, the parties hereto are husband and wife, having been married on June 22,
1985.
WHEREAS, diverse unhappy differences, disputes and difficulties have arisen between
the parties and it is the intention of Husband and Wife to live separate and apart for the rest of
their natural lives, and the parties desire to settle fully and fmally their respective fmancial and
property rights and obligations as between each other including, without limitation by
specification; settling of all matters between them relating to the ownership and equitable
distribution of real and personal property; settling of all matters between them relating to the
past, present, and future support, alimony and/or maintenance of Wife by Husband or of Husband
by Wife; and in general, the settling of any and all claims and possible claims by one against the
other or against their respective estates.
NOW, THEREFORE, in consideration of the premises and of the mutual promises,
covenants and undertakings hereinafter set forth and for other good and valuable consideration,
receipt of which is hereby acknowledged by each of the parties hereto, Husband and Wife, each
intending to be legally bound hereby covenant and agree as follows:
1. INTERFERENCE: Each party shall be free from interference, authority, and contact
by the other, as fully as though 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 to
endeavor to molest the other, nor compel the other to cohabitate with the other, or in any way
harass or malign the other, nor in any way interfere with the peaceful existence, separate and
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6. MUTUAL RELEASE: Husband and Wife each do hereby mutually remise, release,
quit-claim and forever discharge the other and the estate of such other, for all time to come, and
for all purposes whatsoever, of and from any and all rights, title and interest, or claims in or
against the property (including income and gain from property hereafter accruing) of the other or
against the estate of such other, of whatever nature and wheresoever situated, which he or she
now has or at any time hereafter may have against the other, the estate of such other or any part
hereof, whether arising out of any former acts, contracts, engagements or liabilities of such other
or by way of dower or courtesy, or claims in the nature of dower or courtesy or widow's or
widower's rights, family exemption or similar allowance, or under the intestate laws, or the right
to take against the spouse's will; or the right to treat a lifetime conveyance by the other as a
testamentary, or all other rights of a surviving spouse to participate in a deceased spouse's estate,
whether arising under the laws of (a) Pennsylvania, (b) any State, Commonwealth or territory of
the United States, or (c) any country or any rights which either party may have or at any time
hereafter shall have ,for past, present or future support or maintenance, alimony, alimony
pendente lite, counsel fees, division of property, costs or expenses, whetheJ:' arising as a result of
the marital relations or otherwise, except, all rights and agreements and obligations of
whatsoever nature arising or which may arise under this Agreement or for the breach of any
provisions thereof. It is the intention of Husband and Wife to give each other by the execution of
this Agreement a full, complete and general release with respect to any and all property of any
kind or nature, real, personal or mixed, which the other now owns or may hereafter acquire,
except and only except allrights and agreements and obligations of whatsoever nature arising or
which may arise under this Agreement or for the breach of any provision thereof. It is further
agreed that this Agreement shall be and constitute a full and fmal resolution of any and all claims
which each of the parties may have against the other for equitable division of property, alimony,
counsel fees and expenses, alimony pendente lite or any other claims pursuant to the
Pennsylvania Divorce Code or the divorce laws of any other jurisdiction.
7. REPRESENTATION BY COUNSEL: The provisions of this agreement and the
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legal effect have been fulling explained to the parties by their respective counsel, Timothy J.
Colgan, Esquire of Wiley, Lenox, Colgan & Marzzacco, P.C., for husband, and Robert E. Rains,
Esquire and Lucy Johnston-Walsh, Esquire supervising attorneys for the Dickinson Family Law
Clinic, counsel for wife. The parties acknowledge that each has received independent legal
advice from counsel of his or her own selection, that each has fully disclosed his or henespect .
iinancialsituations to the other including his or her property, estate, assets, liabilities, income and
expenses, that each is familiar with and fully understands the facts, including the property, estate,
asset, earnings and income of the other, and that each has been fully informed asto his or her
legal rights and obligations. Each of the parties acknowledges and agrees that, after having
received such advise and with such knowledge, this agreement is, in the circumstances fair,
reasonable and equitable, that it is being entered into freely, voluntarily, and in good faith and
that the execution of this Agreement is not the result of any duress, undue influence, coercion,
collusion and/or improper or illegal agreement. The parties further acknowledge that they have
each made to the other a full and complete disclosure of their respective assets, estate, liabilities,
and sources of income and that they waive any specific enumeration thereof for the purposes of
this Agreement.
8. WARRANTY AS TO EXISTING OBLIGATIONS: Each party represents that they
have not heretofore incurred or contracted for any debt or liability or obligation for which the
estate of the other party may be responsible or liable except as may be provided for in this
Agreement. Each party agrees to indemnify and hold the other party harmless for and against any
and all such debts, liabilities or obligations of every kind which may have heretofore been
incurred by them, including those for necessities, except for the obligations arising out of this
Agreement.
9. WARRANTY AS TO FUTURE OBLIGATIONS: Husband and Wife covenant,
warrant, represent and agree that, with the exception of obligations set forth in this Agreement,
neither of them shall hereafter incur any liability whatsoever for which the estate of the other may
be liable. Each party shall indemnify and hold harmless the other party for and against anyand all
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debts, charges and liabilities incurred by the other after the execution date of this Agreement,
except as may be otherwise specifically provided for by the terms of this Agreement.
10. PERSONAL PROPERTY AND DEBTS: The parties have divided between them,
to their mutual satisfaction, the personal effects, household furniture and furnishings, and all
other articles of personal property which have heretofore been used by them in common, 'and
neither party will make any claim to any such items 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.
By these presents, each of the parties hereby specifically waives, releases, renounces and
forever abandons whatever claims he or she may have with respect to any personal property
, which is in the possession of the other, and which shall become the sole and separate property of
the other from the date of execution hereof.
11. WAIVER OF ALIMONY: Except as otherwise provided herein, Husband and Wife
recognize and acknowledge that the foregoing provisions for their individual benefit are
satisfactory with regard to support and maintenance, past, present and future. The parties release
and discharge the other absolutely and forever for the rest of their Jives for all claims and
demands, past, present or future, for alimony, alimony pendente lite, or for any other provisions
for support and maintenance. The parties further acknowledge that in consideration of the
transfers made herein, each completely waives and relinquishes any and all claims and/or
demands they may now have or hereafter have against the other for alimony, alimony pendente
lite, spousal support, counsel fees, and court costs.
12. DOMESTIC RELATIONS ORDERS: Wife agrees to drop all arrears owed by
Husband on any Domestic Relations Orders, including Orders through the Domestic Relations
Office of Cumberland County. The parties intend and agree that the terms of this Marital
Settlement Agreement shall be approved, adopted and entered as a Domestic Relations Order.
The Court of Common Pleas of CumbeiIand County, Pennsylvania, shall retain jurisdiction to
amend any Domestic Relations Order based on this Marital Settlement Agreement. The
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Domestic Relations Order shall take effect immediately upon its approval and remain in effect
until further Order of Court.
13. SOCIAL SECURITY BENEFITS: The parties hereto stipulate and agree that
HUSBAND shall make no claim for all or any part of the social Security Disability Benefits that
'.. WIFE receives either now or in the future.
'14. lVlOTOR VEillCLES: Husband agrees to transfer title of his vehicle, specifically a
1971 cbevelle, to Wife. Should it be necessary, Husband would agree to sign any titles or
documents necessary to give effect of the transfer of the chevelle upon request. Any vehicles
owned by Husband, other than the 1971 Chevelle, will not be transferred and will remain the sole
property of Husband. Similarly, any vehicle that Wife currently owns will remain owned solely
by Wife.
15. AFTER-ACQUIlRED 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 though he or she were unmarried.
16. INCOME TAX: The parties have heretofore filed joint Federal and State tax returns.
Both parties agree that in the event any deficiency in Federal, State or local income tax is
proposed, or any assessment of any such tax is made against either of them, each will indemnify
and hold harmless the other from and against any loss or liability for any such tax deficiency or
assessment and any interest, penalty and expense incurred in connection therewith. Such tax,
. interest, penalty or expense shall be paid solely and entirely by the individual who is finally
determined to be the cause of the misrepresentations or failures to disclose the nature and extent
of his or her separate income on the aforesaid joint returns.
17. APPLICABILITY OF TAX LAW TO PROPERTY TRANSFERS: The parties
hereby agree and express their intent that any transfer of property pursuant to this Agreement
shall be within the scope and applicability of the Deficit Reduction Act of 1984 (hereinafter the
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"Act"), specifically, the provisions of said Act pertaining to the transfers of property between
spouses andformer spouses. The parties agree to sign and cause to be filed any elections or other
documents required by the Internal Revenue Service to render the Act applicable to the transfers
set forth in this Agreement without recognition of gain on such transfer and subject to the carry-
over basis provisions of said Act.
18. . EFFECT OF DIVORCE DECREE: The parties agree that, except as otherwise
specifically provided herein, this Agreement shall continue in full force and effect after such time
as it fmal Decree in Divorce may be entered with respect to the parties.
19. 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 or seek such other
remedies orrelief as may be available to him or her, and the party breaching this contract shall be
responsible for payment of reasonable legal fees and costs incurred by the other in enforcing their
rights under this Agreement.
20. WAIVER OF CLAIMS: Except as herein otherwise provided, each party may
dispose of his or her property in any way, and each party hereby waives and relinquishes any and
all rights he or she shall now have or hereafter acquire, under the present and future laws of any
jurisdiction, to share in the property or the estate of the other as a result of the marital
relationship, including without limitation, dower, courtesy, statutory allowance, widow's
allowance, right to take in intestacy, right to take against the Will of the other, and the right to act
as administrator or executor of the other's estate, and each will, at the request of the other,
. execute, acknowledge and deliver any and all instruments which may be necessary or advisable
to carry into effect this mutual waiver and relinquishment of such interests, rights and claims.
21. 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.
22. AGREEMENT BINDING ON HEms: This Agreement shall be binding and shall
inure to the benefits of the parties hereto and their respective heirs, executors, administrators,
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successors and assigns.
23. ADDITIONAL INSTRUMENTS: Each of the parties shall from time to time, at the
request of the other, execute, acknowledge and deliver to the other any and all further
instruments that may be reasonably required to give full force and effect to the provisions of this
Agreement.
24. VOID CLAUSES: If any term, condition, clause or provision of this Agreement shall
be determined or declared to be void or invalid in law or otherwise, then only that term,
condition, clause or provision shall be stricken from this Agreement and in all other respects this
Agreement shall be valid and continue in full force, effect and operation.
25. INDEPENDENT SEPARATE COVENANTS: It is specifically understood and
agreed by and between the parties hereto that each paragraph hereof shall be deemed to be
separate and independent Agreement.
26. FINANCIAL DISCLOSURE: The parties confirm that they have relied on the
completeness and substantial accuracy of the financial disclosure of the other as an inducement to
the execution of this Agreement. The parties acknowledge that there has been no formal
discovery conducted in the preparation of this Agreement. Notwithstanding the foregoing, the
rights of either party to pursue a claim for equitable distribution, pursuant to the Pennsylvania
Divorce Code, of any interest owned by the other party in an asset of any nature at any time prior
to the date of execution of this Agreement that was not disclosed to the other party or his or her
counsel prior to the date of the within Agreement is expressly reserved. In the event that either
party, at any time hereafter, discovers such an undisclosed asset, the party shall have the right to
. petition any court having jurisdiction to make equitable distribution of said asset. The non-
disclosing party shall be responsible for payment of counsel fees, costs or expenses incurred by
the other party in seeking equitable distribution of said asset. Notwithstanding the foregoing the
Agreement shall in all other respects remain in full force and effect.
27. 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 with the
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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
defaults of the same or similar nature.
28. DESCRIPTIVE HEADINGS: The descriptive headings used herein are for
convenience only. They shall have no affect whatsoever in determining the rights or obligations
of the parties.
29. APPLICABLE LAW: This Agreement shall be construed under the laws of the
Commonwealth of Pennsylvania and more specifically under the Divorce Code of 1980 and any
amendments thereto.
IN WITNESS WHEREOF, the parties hereto have set their hands and seals the date and
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.KElT . HARRISON
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COMMONWEALTIf OF PENNSYLVANIA
SS
COUNTY OF
On this, the ~ -Ii- day of rxfoh<<- , 2004, before me, the undersigned
officer, personally appeared KEITH A. HARRISON, 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 have here t
d official seal.
(SEAL)
MY COMMISSION EXPIRES:
. NOTARIAL SEAL
Mi~1 H. Sholley,.Nolary Public
. FranIdin Twp., YorkCo~
My commission expires 1ll1luary 19,2008
COMMONWEALTH OF PENNSYLVANIA
SS
COUNTY OF
On this, thesr- day of 'D:.ibr-r.
, 2004, before me, the undersigned
officer, personally appeared KRISTINE L. HARRISON, 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.
IN WITNESS WHEREOF, I have hereunto
MY COMMISSION EXPIRES:
I. . NOTARIAL SEAL
Micbael H. Sholley, Notary Public
Franklin Twp., York County
My commission expires 1anuary 19, 2008
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KEITH A. HARRISON,
Plaintiff
v.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: NO. (Ji- 32~i ~
: IN DIVORCE
KRISTINE L. HARRISON,
Defendant
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 dQ
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
Prothonotary's Office, Cumberland County Courthouse, Harrisburg, Pennsylvania.
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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KEITH A. HARRISON,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: NO. 0/- :g2.1--1 ~ i,U..-
KRISTINE L. HARRISON
Defendant
: IN DIVORCE
COMPLAINT IN DIVORCE
AND NOW, comes the above-named Plaintiff, KEITH A. HARRISON, by and through
his attorney, ROBERT B. LIEBERMAN, ESQUIRE, and seeks to obtain a Decree in Divorce
from the above-named Defendant, KRISTINE 1. HARRISON, upon the grounds hereinafter set
forth:
1. Plaintiff is KEITH A. HARRISON, an adult individual, residing at 315 North Market
Street, Mechanicsburg, Cumberland County, Pennsylvania.
2. Defendant is KRISTINE 1. HARRISON, an adult individual, residing at 26 York
Circle, Mechanicsburg, Cumberland County, Pennsylvania.
3. Plaintiff and Defendant have been bona fide residents of the Commonwealth of
Pennsylvania for at least six (6) months previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on June 22, 1985 in Camp Hill, Cumberland
County, Pennsylvania.
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5. There have been no prior actions of divorce or for annulment between the parties.
6. The Plaintiff and Defendant are both citizens of United States of America.
7. The Defendant is not a member of the Armed Services of the United States.
8. The Plaintiff has been advised of the availability of marriage counseling and
understands that he may request that the Court require the parties to participate in counseling.
9. The Plaintiff avers that the marriage is irretrievably broken.
10. Plaintiff requests the Court to enter a Decree in Divorce.
WHEREFORE, Plaintiff prays that your Honorable Court enter a Decree in Divorce
dissolving the marriage between the parties.
Respectfully submitted,
DATED: 5-) -0)
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Robert B. Lieberman, Esquire
500 N. Third Street, 12th Floor
P.O, Box 1004
Harrisburg, PA 17108-1004
(717) 236-1485
Attorney for Plaintiff
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VERIFICATION
I verify that the statements made in the foregoing Complaint in Divorce are true and
correct based upon my personal knowledge, information and belief I understand that false
statements herein are made subject to the penalties of 18 Pa,C,S, 94904, relating to unsworn
falsification to authorities.
DATED:
5.lo/
~ ~-
Keith A Harrison, Plamllff
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llil1l';';I'""~~W ~c
K1OS.1t17RE\I.&.aQ
COMMONWEAcrHOFPENNSYl~~
CEPARTMENT OF HEALTH
VITAL RECORDS
COUNTY
Cumberland
DIVORCE
o
RECORD OF
OR ANNULMENT
(CHECK ONE) 0
STATE FILE NUMBER
STATE FILE DATE
H SSN 209-56-0144
1. NAME (First)
HUSBAND
Keith
(Middle)
A.
Harrison
(Last) 2. DATE
OF
BIRTH
State 4. PLACE
OF
PA SIRTH
7. USUAL OCCUPATION
(Month)
10
(Day)
25
Year
65
3. RESIDENCe
Street or R.D.
City. Bora. or Twp.
County
(Slate or Foreign Country)
315 North Market St. Mechanicsburg
5. NUMBER 6. RACE
OF THIS WHITE
MARRIAGE
Cumberland
PA
BLACK
KJ
o
OTHER (Specify)
o
WIFE
Driver
W SSN 196-58-9925
8, MAIDEN NAME (First) (Middle) (Last) 9, DATE (Month) (Day) Year
Kristine Sharp OF 6 2 65
L. BIRTH
10, ReSIDENCE Street or R.D. City. Bora. or Twp. County State 11, PLACE (State or Foreign Country)
OF
26 York Circle Mechanicsburq Cumberland PA BIRTH PA
12. NUMBER 6. RACE 14. USUAL OCCUPATION
of THIS WHITE SLACK OTHER (Specify)
MARRIAGE 1 IX] 0 0 Housewife
15. PLACE OF (County) (Slate or Foreign Country) 16, DATE OF (Month) (Day) (year)
THIS Curriberland PA THIS 6 22 85
MARRIAGE MARRIAGE
17A. NUMBER OF 17B. NUMBER OF DEPENDENT 18, PLAINTIFF 19, DECREE GRANTED TO
CHILDREN THIS CHILDREN UNDER 18 HUSBAND WIFE OTHER (Specify) HUSBAND WIFE OTHER (Specify)
MARRIAGE 1 1 [] 0 D Kl D D
20. NUMBER OF HUSBAND WIFE SPUT CUSTODY OTHER (Specify) 21. LEGAL GROUNDS FOR
CHILDREN TO 0 f[] D DIVORCE OR ANNULMENT Mutual Consent
CUSTODY OF
22. DATE OF DECREE (Month) (Day) (Ye-ar} 123 DATE REPORT SENT (Monlh)" . (Day) (Year)
TO VITAL RECORDS
24. SIGNATURE OF
TRANSCRIBING CLERK
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KEITH A. HARRISON,
Plaintiff
v.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: NO. 01-3221 CIVIL
KRISTINE L HARRISON,
Defendant
: IN DIVORCE
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA:
SS.
COUNTY OF DAUPHIN
Personally appeared before me, a Notary Public, in and for said Commonwealth and
County, ROBERT B. LIEBERMAN, ESQUIRE, who, being duly sworn according to law,
deposes and says:
1. That on May 25, 2001, a Complaint in Divorce was filed on behalf of Plaintiff
and against Defendant in the above case.
2. That on June I, 2001, I forwarded by certified mail, return receipt requested, a
certified copy of the Complaint in Divorce to the Defendant, KRISTINE 1. HARRISON, 26
York Circle, Mechanicsburg, Cumberland County, Pennsylvania, as evidenced by the sender's
receipt attached hereto.
3. That the aforesaid certified copy of the Complaint in Divorce sent to Defendant,
KRISTINE 1. HARRISON, was delivered on June 7, 2001, as evidenced by the return receipt
card signed by Defendant and attached hereto.
Complete items 1, 2, and 3. Also complete
item 4 if Restricted Delivery is desired.
II Print your name and address on the reverse
"::80 that we can return the card to you.
III Attach this card to the back of the mailplece,
or on the front if space permits.
1. Article Addressed to:
i4uStli\L6 L. l-tA(2i<1SDN
J./,J) YORK ClVC.i.-~
M6WAN,(C6f1~ I fA
11060
Q~
xpress Mail
o Return Receipt for Merchandise
D O,O,D,
L. t'iS4<H
DI
4. Restricted Delivery? (Extra F$e)
es
2. Article Number (Copy from service label)
fOOO N5::LD 0023
PS F",m 3J11,July 1999
of~7 {3207
Domestic Return Receipt
102595-00'M-0952
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f'- Postage $
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r-=J ,Certlfled Fee
CJ
Return ReceIpt Fee
rn (Endorsement Required)
nJ
CJ RestrIcted Delivery Fee
J::J (Endorsement Required)
Total Postage & Fees
Postmai'k
"ore
(,,!r I~ I
CJ
nJ
Ul Ff~!!ient'5 Name rPlea~y) (To be comple.ted by mailer) :
~ ~~~~~~;'~~e-----S'?_~Lm_"--_nm___'------l'
CJ CIty, SiJri:ZlP+ 4 ____.m___m___~______mm.___.
f'- -E- . PI! 7060 .
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4. That to the best of my information and belief, the signature on the return receipt
card is, in fact, the signature of KRISTINE 1. HARRISON.
~~.~
ROBERT B. LIEBERMAN, Esquire
Attorney for Plaintiff
SWORN AND SUBSCRIBED
before me this do~ day
of ::::lu N E. ,2001.
~~l~'f~
My Commission Expires:
NOTARIAL SEAL .
OHERYL L. FERGUSON, Notary PubUc
Hal'l'lsburg. Dauphin County
Commilllllon expires A '16. 2004
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KEITH A. HARRISON, * IN THE COURT OF COMMON PLEAS
Plaintiff, * CUMBERLAND COUNTY, PENNSYLVANIA
*
vs. * No. 01-3221 Civil Term
*
KRISTINE L. HARRISON, * CIVIL ACTION LAW
Defendant * IN DIVORCE
AFFIDAVIT OF CONSENT
1. A complaint in Divorce under ~3301(c) of the Divorce Code was filed on May 25,
2001.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days
have elapsed from the date of filing and service of the Complaint.
3. I consent to the entry of a final decree of divorce after service of notice of intention to
request entry of the decree.
I verifY that the statements made in this affidavit are true and correct. I understand that
false statements made herein are subject to the penalties of 18 Pa. C.S. ~4904 relating to
unsworn falsification to authorities.
/O-S'"'.O$l
Date.
~ ~
I'Keith A. Harrison
Plaintiff
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KEITH A. HARRISON, * IN THE COURT OF COMMON PLEAS
Plaintiff, * CUMBERLAND COUNTY, PENNSYLVANIA
*
vs. * No. 01-3221 Civil Term
*
KRISTINE L. HARRISON, * CML ACTION LAW
Defendant * IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301(c) OF THR 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 in 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 made herein are subject to the penalties of 18 Pa. C.S. 94904 relating to unsworn
falsification to authorities.
/0-0- -dY
Date
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KEITH A. HARRISON, * IN THE COURT OF COMMON PLEAS
Plaintiff, * CUMBERLAND COUNTY, PENNSYLVANIA
*
vs. * No. 01-3221 Civil Term
*
KRISTINE L. HARRISON, * CIVIL ACTION LAW
Defendant * IN DIVORCE
AFFIDAVIT OF CONSENT
1. A complaint in Divorce under ~3301(c) of the Divorce Code was filed on May 25,
2001.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days
have elapsed from the date of filing and service of the Complaint.
3. I consent to the entry of a final decree of divorce after service of notice of intention to
request entry of the decree.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements made herein are subject to the penalties of 18 Pa. C.S. ~4904 relating to
unsworn falsification to authorities.
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KEITH A. HARRISON, * IN THE COURT OF COMMON PLEAS
Plaintiff, * CUMBERLAND COUNTY, PENNSYLVANIA
*
vs. * No. 01-3221 Civil Term
*
KRISTINE L. HARRISON, * CML ACTION LAW
Defendant * IN DNORCE
W AlVER OF NOTICE OF INTENTION TO REOUEST
ENTRY OF A DNORCE DECREE UNDER
SECTION 3301(c) OF THE DNORCE CODE
I. I consent to the entry of a fmal 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 made herein are subject to the penalties of 18 Pa. C.S. ~4904 relating to unsworn
falsification to authorities.
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KEITH A. HARRISON,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
: CIVIL ACTION - LAW
: IN DIVORCE
KRISTINE L. HARRISON,
Defendant
: NO. 01-3221 CIVIL TERM
CERTIFICATE OF SERVICE
I, Sarah Johnson, hereby certifY that I am serving a true and correct copy of the PRAECIPE TO
ENTER APPEARANCE on Robert B. Leiberman, Attorney at Law, at 500 North Third Street,
Twelfth Floor, P.O. Box 1004, Harrisburg, Pennsylvania, 17108, by depositing a copy of the
same in the United States mail, first class, postage prepaid, on this date,
Date
~ 1;)/0 3
Respectfully submitted,
~t.~
Sarah E. Johnson, ertified Legal Intern
Robert E. Rains, Supervising Attorney
Lucy Johnston-Walsh, Staff Attorney
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, P A 17013
717-243-2968
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KEITH A. HARRISON,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
; IN DIVORCE
KRISTINE L. HARRISON,
Defendant
: NO. 01-3221 CIVIL TERM
PRAECIPE TO ENTER APPEARANCE
To the Prothonotary:
Please enter the appearance ofthe Family Law Clinic on behalf of Kristine L. Harrison,
the Defendant in the above captioned matter.
Date f1 /;J./o:3
Respectfully submitted,
JCQ51JQf1f~
Sarah E. Johnson
Certified Legal Intern
QL~ ~'-0~
THO M. LACE
ROBERT E. RAINS
LUCY JOHNSTON-WALSH
Supervising Attorneys
F AMIL Y LAW CLINIC
45 North Pitt Street
Carlisle, P A 17013
717-243-2968
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KEITH A. HARRISON,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
; CUMBERLAND COUNTY, PENNSYL VANIA
v.
: CIVIL ACTION - LAW
: IN DIVORCE
KRISTINE 1. HARRISON,
Defendant
: NO. 01-3221 CIVIL TERM
PETITION FOR ALIMONY
AND NOW comes the defendant in the above-captioned divorce action by and through
her attorneys, the Family Law Clinic, and sets forth the following petition for alimony and
equitable distribution, pursuant to Pa.R.C.P. 1920.l5(b):
1. The defendant/petitioner is Kristine 1. Harrison, residing at 26 York Circle,
Mechanicsburg, Cumberland County, Pennsylvania.
2. The plaintiffj respondent is Keith A. Harrison, residing at 14 North Chestnut
Street, Dillsburg, York County, Pennsyivania.
3. Defendant/ petitioner requires reasonable support to adequately maintain herself
in accordance with the standards ofliving established during the marriage.
4. Defendant/ petitioner lacks sufficient property to provide for her reasonable
needs.
5. The only income defendant/ petitioner currently receives is her monthly Social
Security Disability Insurance (SSDI) check.
6. The defendant/ petitioner would also be receiving long term disability benefits
from her employer, however, due to an overpayment, she is not currently
receiving those benefits. Atthe time of the overpayment, defendant/petitioner
was supporting the family with her benefits and plaintiff/ respondent was
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unemployed.
7. The plaintiffi' respondent is employed and is able to provide for the reasonable
needs of the defendant/ petitioner.
8. The defendant/ petitioner is disabled and is unable to work, thus the plaintiff!
respondent's earning capacity exceeds the defendant/ petitioner's earning
capacity .
9, The couple's minor child, Andrew, age 15, is in the care of defendant/petitioner.
WHEREFORE, defendant/petitioner requests the Court to enter an award of reasonable
alimony, and such other relief as the Court deems just.
Respectfully submitted,
Date tf /;;L~ 103
~e.~
Sarah E. Johnson, Certified Legal Intern
~~-Ja%(
THOM 'S M. PLACE
ROBER . RAINS
LUCY JOHNSTON- WALSH
Supervising Attorneys
F AMIL Y LAW CLINIC
45 North Pitt Street
Carlisle, P A 17013
717-243-2968
VERIFICATION
I hereby verifY that the statements made in the foregoing Petition for Alimony are true
and correct, to the best of my knowledge, information and belief. I understand that making a
false statement would subject me to the penalties of 18 Pa. C.S. Section 4904, relating to
unsworn falsification authorities. ~_ ,AA
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Dated{~f;f
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KEITH A. HARRISON,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: IN DIVORCE
KRISTINE 1. HARRISON,
Defendant
: NO. 01-3221 CIVIL TERM
CERTIFICATE OF SERVICE
I, Sarah Johnson, hereby certifY that I am serving a true and correct copy ofthe PETITION FOR
ALIMONY on Robert B. Leiberman, Attorney at Law, at 500 North Third Street,
Twelfth Floor, P.O. Box 1004, Harrisburg, Pennsylvania, 17108, by depositing a copy ofthe
same in the United States mail, first class, postage prepaid, on this date.
Date ~ /30/0 3>
Respectfully submitted,
Jwwh e: 9!!:U11Pl
Sarah E. Johnson, Certified Legal Intern
Robert E. Rains, Supervising Attorney
Lucy Johnston-Walsh, Staff Attorney
F AMIL Y LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
717-243-2968
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KEITH A. HARRISON,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: IN DIVORCE
KRISTINE L. HARRISON,
Defendant
: NO. 01-3221 CIVIL TERM
PRAECIPE TO PROCEED IN FORMA PAUPERIS
Kindly allow Kristine L. Harrison, Plaintiff, to proceed in forma pauperis.
The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies
that we believe the party is unable to pay the costs and that we are providing free legal service to
the party.
Date
1/:2/03
Respectfully submitted,
~&o~
Sarah E. Johnson
Certified Legal Intern
~-w.Q;l
THO S . LACE
ROBERT E. RAINS
LUCY JOHNSTON-WALSH
Supervising Attorneys
F AMIL Y LAW CLINIC
45 North Pitt Street
Carlisle, P A 17013
717-243-2968
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Plaintiff Name; rce\~ . A. ~--\,c,uT\~_
Defendant Name: kn':::~i\re 1-.. H:1_rriSCf\
Docket Number: 0 \ - ~"):z \
PACSES Case Number:
Other State ID Number;
Please note: All ~olTespoDdence must include the P ACSES Case Nwnber.
Income and Expense Statement
THIS FORM MUST BE FI!-LED OUT
(If you are self-employed or if you are salaried by a business of which you are owner in whole or part, you must
also fill out the Supplemental Income Statement which appears on page two of this income anu expense
statement. )
INCOME STATEMENT OF
k'ri6\O\\0I-. l-br-r\60n
INCOME:
Section I: Income and Insurance
NA - See
0,'t0e\ I n( (('(\e.
Employer
Addre.u
Type of Work
Payrot! No. Gross Pay per Pay Period $
Itemized Payroll Deductions:
Pay Period (wkly., bi,wkly" er<:.)
Federal Witltholding S Social Security $ Local Wa.. Talc $
State Income Tax S Retirement $ Savings Bonds $
Credit Union S Life Insurance $ Health Insurance $
Oilier Deductions (specity) $ S
- $ S
Net Pay per Pay Period S
OTHER
INCOME
(Fill in A ro riate Column)
WEEK MONTH YEAR
$ $ $
Iruerest
Dividends
Pension
Annult
Social Securit
Rents
Ro altie-s
Ex ense Account
Gifts
Unem loymen!
Workmen's
Com ensalion
Other
Other
TOTAL
~ TOTAL INCOME
$-
s
PROPERTY Ownership *
OWNED DESCRIPTION VALUE H W J
Checking AccountS S ;;2..0 ./
Savin2s Accounts fi) ?)~ V
Credit Union
Stock&!Bond$
Real Esrate
Other
- Is :::>S-
TOTAL
* H==Husband; W=Wife; I==Ioint
Fonn 11'1,008
Worker to
.
-.-~"- "'- '-"'Ma
.,
'.
Income and Expense Statemem
PACSES Case Number
INSURANCE
Coverage *
COMPANY
POLICY #
H W C
HQsvital
Blue Cross
Other
Medical ~
91.- . :~u
Q!her
Health! Accident
Di~ability Income
Dental
Other
* H=Husband; W=Wife; C=Child
Section II: Supplemental Income Statement
a. This fOIm is to be filled out by a person
o (1) who operates a business or practices a profession, or
o (2) who is a member of a partnership or joint venture, or
D (3) who is a shareholder in and is salaried by a closed corporation or similar entity.
b. Attach 10 this statement a copy of the following documents relating to lite partnership, joint venture, business, prOfession,
corporation or similar entity:
(I) the most recent Federallncome Tax Return. and
(2) the most recent Profit and Loss Statement
c. Name of business:
Address and telephone number:
d. Nature of business (check one)
o (t) partnership
D (2) joint venture
o (3) professinn
D (4) closed corporation
o (5) n!her
e. Name of accountant, controller or other person in charge of fmancial records:
f. Annual income from business:
(1) How often is income received?
(2) Gross income per pay period:
(3) Net income per pay period:
(4) Specified deductions, if any:
Page 2of3
Form IN,008
Worker ID
Service Type
,
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[ncome and Expense Statement
-
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Secfion HI: Expenses
P ACSES Case Number
InSlmt;tions: Only show extraordinary expenses in this set'lion unless you filled OUl Section II on page 1\\\1. The categories
in nOLI> FONT are especially important for calculaling child support. ffyou arc requesting Spousal Support/APL or if
you assert your case cannot be determined according to the guideline grids or formula, this section must be fully completed.
(Fill in Appropriate Column)
EXPENSES
WEEK MONTH YEAR
Home
Mortgage/Ren( $ S 3Q7.fJ) $"11 (( )
Mainlcnance
Utilities
Electric $ S 22."5. s A "fC)
Gas
Oil
Telephone / '-I"'J 1f7 · "'\
Water 17 .~ f.-
Sewer 2'J ;),( n Y
Emnlovrncnt
Puhlic Transport. S S S~
Lunch
Taxes'
Real csJale S S
Pcr:-;onal Property
Insurance
Homeowner's S S - S
Automobile L '1,\ J.-f; I(
Life "l ( ~
Accident
Health
Olher :;H', :;JLjf )
Automobile
Payments $ S $
Fuel J{Xl 1.:1(' I )
Repairs 3n ?Jr,C )
Medical
~DoclOr $ S .91 $ (/0(' r
Dentist ,fW~ IL.{ t-j(
Onhodomisf ~
k Hospital
Medicine ,'t-,-;<J'Yj Q[",(1
I SpecIal needs d3:9o $2~O
(glasses, braces,
/o-rthonedic devices
EXPENSES (Fill in Appropriate Column)
(continued) WEEK MONTH YEAR
Education
Private School $ S S -
Parochial School -
College - ~
Religious -
Personal
Clothing $ t;q) ~vrn
Food < - '. . U'"R~ , . ~O
BarberI j;Lfni:,l I~
"';""~s"r
Credit Payments $\;0 plY l-/O
Credit Card
Charge
Memberships 1J>\,...1n &~J
Loans
Credit Union $ S S
Miscellaneous
Household Help S S $
CbDd care
Paperslbooks \S~ jJ~L-\
Mac:oazines
Entertainment " :rll I ~l.\l >-..)
, \:>:2 ,Ll
Vacation K ,7. -, , '}
Gifts ~ t:;1 f':I. )
Legal fees -
Charitable
Contributions'
Utber I,;biId '
<..n~rl
Alimony
P.vments
other~ ~Q\ . '1 F;n
$ J."ln s :;;'0
I,
eriiy that the statements made in this Income and Expense Statement are true and correct. I understand that false
'ements herein are subject to the criminal penalties of 18 Pa. C.S. ~ 4904 latin to unsworn falsification to authorities.
~ ~::~.
e Type
Page 3 of3
Form IN-OD8
Worker 10
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KEITH A. HARRISON,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
: CIVIL ACTION - LAW
: NO. 01-3221 CIVIL
KRISTINE L. HARRISON,
Defendant
: IN DIVORCE
NOTICE
If you wish to deny any ofthe statements set forth in this affidavit, you must file a counter-
affidavit within twenty days after this affidavit has been served on you or the statements will be
admitted.
AFFIDAVIT UNDER
SECTION 330Hd) OF THE
DIVORCE CODE
The parties to this action separated on February 1,2001 and have continued to live separate and
apart for a period of at least two years,
The marriage is irretrievably broken.
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,
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.
Date:
b-C,-03
~~~~ '
'''Keith A. H ison,
Plaintiff
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KEITH A. HARRISON,
Plaintiff
v.
: IN TIIE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CNIL ACTION - LAW
: IN DNORCE
KRISTINE 1. HARRISON,
Defendant
: NO. 01-3221 CNIL TERM
PETITION FOR EOUlT ABLE DISTRIBUTION
AND NOW comes the Defendant (hereinafter "Wife") in the above captioned divorce
action by and through her attorneys the Family Law Clinic, and sets forth the following petition
for equitable distribution, pursuant to Pa. R. C. P. 1920.15(b):
1. Wife is Kristine 1. Harrison, currently residing at 26 York Circle, Mechanicsburg,
Cumberland County, Pennsylvania.
2. The Plaintiff (hereinafter "Husband") is Keith A. Harrison, currently residing at
14 North Chestnut Street, Dillsburg, York County, Pennsylvania.
3. Wife is disabled, and therefore unable to work.
4. Wife's only source of income is her monthly Social Security Disability Insurance
(SSDI) checks, which amounts to $937.00 per month.
5. Husband is employed full time as a tow-truck driver, and his monthly gross
income is $2, 382.00.
6. The parties' child, Andrew, age 15, is in the care of Wife.
7. The parties have acquired marital assets and debts subject to equitable distribution
under the Divorce Code, including, but not limited tothe following:
a. The parties' 1986 Terry 5th wheel camper;
b. The parties' 1995 Ford truck;
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c. The parties' furniture and other various items of personal property.
WHEREFORE, Wife respectfully requests that this Court equitably divide the marital property
and debts between the parties and grant such other relief as the Court deems just.
Respectfully submitted,
Date: S..""" ;).'5 .:lOCJ ~
J
~~
Nicholas Aloia
Certified Legal Intern ~~
~~~
LUCY HNSTON-WALSH
SuperVising Attorneys
FAMILY LAW CLINIC
Carlisle, P A 17013
(717) 243-2968
I
VERIFICATION
I verify that the statements made in this Petition for Equitable Distribution are true and
correct to the best of my personal knowledge, information and belief. I understand that false
statements made herein are made subject to the penalties of 18 Pa. C. S. S 4904, relating to
unsworn falsification to authorities.
Date: S...." <- J-:S; J. ~() ~
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KEITH A. HARRISON,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
: CIVIL ACTION - LAW
: IN DIVORCE
KRISTINE 1. HARRISON,
Defendant
: NO. 01-3221 CIVIL TERM
CERTIFICATE OF SERVICE
I, Nicholas Aloia, do hereby certify that on this date I am serving a true and correct copy
of Petition for Equitable Distribution, on opposing counsel, Robert B. Lieberman, 500 North
Third Street, 12th Floor, P.O. Box 1004, Harrisburg, P A 17108-1004, by depositing the same in
the United States mail, first class, postage prepaid.
Date: 5,^V\~ J-,S" :hG a ::,
,
~~
Nicholas Aloia
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KEITH A. HARRISON,
Plaintiff, Respondent
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v,
: CIVIL ACTION - LAW
: IN DIVORCE
KRISTINE L HARRISON,
Defendant, Petitioner
: NO, 01-3221 CIVIL TERM
IN RE: PETITION FOR SPECIAL RELIEF
ORDER OF COURT
AND NOW, this JIIrt, day of 9' ~ ,2003, upon consideration of the Defendant's
Petition for Special Relief it is Ordered and Decreed that:
1. A hearing regarding Defendant's Petition for Special Relief is scheduled for
UuF ;l '7, 2003 at(3~'clock f' m., in Courtroom No. 'I , Cumberland County
Courthouse, Carlisle, P A.
2. Pending said hearing and further Order of Court, the Plaintiff is enjoined from
destroying, harming, encumbering or hiding the parties' 1986 Terry 5th Wheel Camper.
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KEITH A. HARRISON,
Plaintiff, Respondent
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: IN DIVORCE
KRISTINE L. HARRISON,
Defendant, Petitioner
: NO. 01-3221 CIVIL TERM
PETITION FOR SPECIAL RELIEF PURSUANT TO Pa. R. C. P. 1920.43
AND NOW comes the Defendant/Petitioner (hereinafter "Wife") in the above captioned
divorce action by and through herattomeys, the Family Law Clinic, and sets forth the following
petition for special relief:
1. Wife is Kristine L. Harrison, currently residing at 26 York Circle, Mechanicsburg,
Cumberland County, Peunsylvania.
2. Plaintiff/Respondent (hereinafter "Husband) is Keith A. Harrison, currently
residing at 14 North Chestnut Street, Dillsburg, York Connty, Pennsylvania.
3. Husband and Wife were married on June 22, 1985 in Camp Hill, Cumberland
County, Peunsylvania.
4. On May 1, 200 I Husband filed the instant divorce action.
5. During the parties' marriage, Wife's mother, Nancy L. Sharp, pursuant to an oral
agreement, loaned the parties $8, 000.00 for the purchase of the parties' Terry 5th
wheel camper, which Husband and Wife own jointly, and which served as the
marital residence for appr,oximately 2 years.
6. Husband and Wife to this date have made no payment to Ms. Sharp on the loan.
7. In 1998, the parties took out a loan with Arcadia Financial for the purchase of a
1995 Ford F350 truck, which the parties used to haul the aforementioned camper,
and which currently is in Husband's sole possession.
8. On August 12,2002 Husband and Wife took the parties' camper to Radabaughs
Camping Trailers, Inc., 2464 Valley Road, Marysville, PA and placed the camper
on consignment in an attempt to sell the camper and repay a portion ofthe
$8,000.00 loan. Husband and Wife signed an agreement with Radabaughs
Camping Trailers, Inc., dated August 12, 2002, which provides that the proceeds
from any sale are to go to Wife's mother, Nancy L. Sharp. A true and correct
copy of the agreement is appended hereto as Petitioner's Exhibit I, and is
incorporated herein by reference.
9. On May 3, 2003 Husband unilaterally removed the camper from Radabaughs
Camping Trailers, Inc. without the consent, or prior knowledge, of Wife, and has
since denied Wife access to the camper.
10. Husband has not disclosed to Wife the camper's location.
II. Husband has allowed the insurance on the camper to lapse, and currently the
camper is uninsured,
12. Despite the fact that the camper is uninsured, Husband continues to enjoy the use
of the camper.
13. Husband has informed acquaintances of Wife that because the camper is
uninsured he would "burn the camper," so that Wife's mother will receive no
compensation for the $8, 000 loan. Based on this information, Wife fears that
Husband might destroy the camper.
14. Husband's actions could cause immediate and irreparable injury to the parties'
most significant marital asset.
15. Wife desires that the parties' camper be placed in her possession, at her
residence, 26 Yark Circle, Mechanicsburg, P A 17050.
16. Radabaughs Camping Trailers, Inc. has informed Wife that the camper must be
insured before it can be placed on consignment. Accordingly, Wife desires that
Husband execute all documents necessary to transfer his title in the camper to
Wife, so that Wife can in turn transfer title to her mother, Nancy L. Sharp, who
will then provide the necessary insurance through her automobile insurance.
17. Thereafter, Wife desires returning the situation to its status quo, by having the
camper returned to Radabaughs Camping Trailers, Inc
18. Pursuant to C.C.R.P. 206-2(c) the Family Law Clinic informed opposing counsel
of its intention to file this petition for special relief, and opposing counsel did not
concur.
WHEREFORE, Wife asks the Court to enter an order as follows:
1. Immediately enjoin Husband from destroying, harming, encumbering or hiding the
parties' 1986 Terry 5th Wheel Camper.
2. Schedule a hearing on this petition and after that hearing:
a) Direct Husband to transport forthwith the parties' 1986 Terry 5th Wheel Camper
to Wife's residence.
b) Grant an injunction preventing Husband from thereafter removing the camper
from Wife's residence.
c) Direct Husband to execute forthwith all documents necessary to transfer title to
the camper to Wife.
d) Direct Husband to execute forthwith any documents necessary to authorize
Radabaughs Camping Trailers, Inc. to sell said camper.
Respectfully Submitted,
Date: .3""\'-,1 ") J-C)C) ":)
)
~~
Nicholas Aloia
Certified Legal Intern
lFa/4-5: ~
ROBERT E. RAINS
THOMAS M. PLACE
Supervising Attorney
LUCY JOHNSTON-WALSH
Staff Attorney
F AMIL Y LAW CLINIC
45 North Pitt Street
Carlisle, P A 17013
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VERIFICATION
I verifY that the statements made in this Petition for Special Relief are true and correct to
the best of my personal knowledge, information and belief. I understand that false statements
made herein are made subject to the penalties of 18 Pa. C. S. ~ 4904, relating to unsworn
falsification to authorities.
Date:7~3-0Y
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EXCLUSIVE CONSIGNMENT CONTRACT
FOR SALE OF MANUFACTURED HOME OR RECREATIONAL VEHICLE
~fi'A D~Ti3All &~ ~ '/i)/:j'lF,S
(RET leER OR AGENT)
(In this contract the words I, me and .!!!y. refer to the Owner(s) signing this
contract. The words YQ!! and your refer to the Retailer or Agent.)
In consideration of your agreement to use YOl!r efforts to find a Purchaser for the Manufactured Home or Recrea-
tional Vehicle, he~ejn desc.ribed I here~y 9iV~Jp}tlhe sole and. exclusive right to sell within described Manufactured
Home or Recreational Vehicle for a penod of ays from thiS d~te, and thereafter until this agreement shall have
been revoked by ten (10) days notice' of termination in writing delivered to you, but in any event for not longer than~L
month(s) from date. ~ _ ' ;::' JT.
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1A~"\OU a)rIJ~~r.eby. q.~thorized to negotiate for the tale_oJ., ana to sell, said Manufactured Home or Recreational Vehicle Tor
not I !:l':Ytf1'~n $ _~~,~\) T.{ , of which not less than $ J"{ s: J .0 , shall be paid as earnest money by the Purchaser, to be
held by you until closing. If sale is closed, I agree to pay you a minimum commission of ---t..C-% on the agreed selJing price, and,
if sold for more, to divide equally betwe~n you and me the excess over and above said selling price.
"p\ Or! agree to accept a net flat price of $,~~, authorizing YQu to retain any amount received over and above
said net p(ice as reimbursement for expenses involved and, as a selling commission.
2. I agree to deliver said Manufactured Home or Recreational Vehicle to Purchaser free and clear of all liens' including taxes,
assessments, license tees, etc., and thtlt said Manufactured Home or Recreational Vehicle is free and clear of all personal property
judgments or encumbrances and to pay for all personal and other taxes which may be levied thereon, other than as indicated herein.
3. I agree to carry liability and cOlnprehensive insurance to protect against theft, pilferage, fire, windstorm, water damage, hail
and vandalism, thereby releasing you from any and allliabHity.
4. Evidence of tille will be lurnished in the form of either a bill of sale or, in title states, a certificate of title.
5. You are authorized, on my behalf, to qualify and accept the offer of a Purchaser which shall be in accordance with said
terms, and to_execute a contract 01 sale therefor.
6. You are further authorized to negotiate ior the sale of and to sell said described Manufactured Home or Recreational Vehicle
lor such lesser sum or upon such different terms (induding the acceptance 01 other property in trade), if I shall accept such changes
in 'PJriting.
7. rhe exclusive right to advertise said Manufactured Home or Recreational Vehicle is granted to you which advertisement
may be done by insertion of ads in neWspapers, the broadcasting of same on radio, the placing of a "FOR SALE" sign on Ihe
Manufactured Home or Recreational Vehicle or by such other means of advertising as are commonly used. If, by mutual consent,
t~!e above described Manufactured Home or Recreational Vehicle be withdrawn from sale before the expiration of this listing contract
I agree to pay you one and one-half percent (1 V2%) of_ the last quoted sales price on said Manufactured Home or Recreational
Vehicle, as liquidated damages to reimburse you for advertising, sales costs and losses incurrep as the result of my failure to adhere
to the full term or period of this contract. '; - ,',. :}:' -.I', .
8. Ii:.-a-sale or ex~tJange iSf made or a purch~ser procured therefore by you, by me, or by any other person, at the price or
upon the terms specified herein, or at any other terms and price accepted by me during the life of this contract; (or within three (3)
months aiter the termination of Ihis cont(~ct, t~.anyo~e with whom you. negotia!ed or discussed the sale during the lif~ o! this coroact
and whose name you have filed with me In writing pnor to the termination of thiS contract) 1 agree to pay you a commiSSion of %
01 ihe saie price.
9. For the payment of said commission, which shall be due and payable upon r;:tosing of any contract to sell or sale made
hereunder, you shall hElve an equitable lien upon said Manufactured Home or Recreationa~ Vehicle therefor, and upon the proceeds
in whole or In palt of said sale.
10. While this contract continues, I agree not to lease, rent, sell or negotiate for the sate of said Manufactured Home or Recrea.
iional Vehicle except through you, nor give any brol(er, firm, or other person authority to sell, or negotiate for the sale of said Man-
ufactured Home or Recreational Vehicle. I agree to refer to you all inquiries received concerning the sale of said Manufactured Home
or Rl~creational Vehicie.
11. In the event any Purchaser forfeits the earnest money paid by him, all expenses of advertising and incidental costs actually
Incurred by you sllall be deoucted therefrom, with the remainder being equally divided between you and me.
'12. No deductions shall be made i/1 the amount of commission due and to be paid you in the event I accept as part considera-
tion, other property of any kind, in trade.
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-ITEMS INCLUDED WITH SALE OF ABOVE PROPERTY
(Strike Out Those Items Not Applicall!e - List All Appliances By Make, Model, Y,ear and Serial Number on Back of Form)
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CAf-jPETING DRAPES/CURTAINS ~'=L9.9.!J_DITIONE~/
DINING SET COUCH/CHAIRS Ce.r1-!J:a1._ Window_
END TABLES REFRIGERATOR TELEVISION ANTENNA
OVEN/RANGE WASHER/DRYER SEWER-WATER FITTINGS
DISH WASHER STORM WINDOWS
PORCH/STEPS AXLESITIRES
GAS BonLES STORAGE SHED
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KEITH A. HARRISON,
Plaintiff, Respondent
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
: CIVIL ACTION - LAW
: IN DIVORCE
KRISTINE L. HARRISON,
Defendant, Petitioner
: NO. 01-3221 CIVIL TERM
CERTIFICATE OF SERVICE
I, Nicholas Aloia, certify that on this date I am serving a true and correct copy of
Petition for Special Relief on Robert B. Lieberman, Esq., 500 North Third Street, 12th Floor,
Harrisburg, P A, P.O. Box 1004, by United States mail, first class, postage prepaid, and by fax
(717) 236-7777.
Date: 5<.-..\/7, )"DG)
~~
Nicholas Aloia
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KEITH A. HARRISON,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: IN DIVORCE
KRISTINE L. HARRISON,
Defendant
; NO. 01-3221 CIVIL TERM
INVENTORY
OF
KRISTINE L. HARRISON
Defendant files the following inventory and appraisement of all property owned or
possessed by either party at the time this action was commenced and all property transferred
within the preceding three years.
Defendant verifies that the statements made in this inventory and appraisement are
true and correct. Defendant understands that false statements herein are made subject to the
penalties of 18 Pa.C.S. 94904 relating to unsworn falsification to authorities.
~ IFftD3
. DeE dant (Date)
ASSETS OF PARTIES
Defendant marks on the list below those items applicable
to the case at bar and itemizes the assets on the following pages.
( ) 1. Real property
(x) 2. Motor vehicles
() 3. Stocks, bonds, securities and options
( ) 4. Certificates of deposit
() 5. Checking accounts, cash
( ) 6. Savings accounts, money market and savings certificates
( ) 7. Contents of safe deposit boxes
( ) 8. Trusts
(x) 9. Life insurance policies (indicate face value, cash surrender value and current
beneficiaries)
( ) 10. Annuities
( ) 11. Gifts
( ) 12. Inheritances
() 13. Patents, copyrights, inventions, royalties
,-,.
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( ) 14. Personal property outside the home
( ) 15. Business (list all owners, including percentage of ownership, and officer/director
positions held by a party with company)
( ) 16. Employment termination benefits - severance pay, workman's compensation
claim/award
( ) 17. Profit sharing plans
( ) 18. Pension plans (indicate employee contribution and date plan vests)
( ) 19. Retirement plans, Individual Retirement Accounts
(x) 20. Disability payments
(x) 21. Litigation claims (matured and unmatured)
() 22. MilitaryN.A. benefits
() 23. Education benefits
( ) 24. Debts due, including loans, mortgages held
(x) 25. Household furnishings and personalty (include as a total category and attach
itemized list if distribution of such assets is in dispute)
( ) 26. Other
MARITAL PROPERTY
Defendant lists all marital property in which either or both spouses have a legal or
equitable interest individually or with any other person as of the date this action was
commenced: .
Item
Number
1
Description
ofProuertv
Sofa
Names of
All Owners
"Kristine & Keith
Harrison"
2 Recliner
3 19" T.V.
4 King Size Bed
5 Lamps
6 End Tables
7 Sofa Tables
8 Coffee Table
9 27"T.V.
" "
" "
" "
" "
" "
" "
" "
" "
~ '
-. .-'.' '". j, -, ;" __;M',~_, - ~ --" ..-~_~_ '_.-;- _ ",'. i:,'",;;,~., -,. '"'''' ","'0.';;' - ,,; '.J',;.;- - ' '-,__~'-< " _ '",-_~: ~<:-:,,,,'; ~~~e: ...'f.!~.-' -~-, ~~: -- -', ,~-~, ,11
10 Dresser & Mirror " "
11 35 mm Minolta Camera " "
12 RCA Camcorder " "
13 DVD Player " "
14 Fishing Equipment " "
15 Microwave " "
16 China Set " "
17 Desk " "
18 File Cabinet " "
19 Book Case " "
20 1970 Ford Chevelle " "
21 Steel Tool Box " "
22 Kenwood AMlFM CD " "
player
22 Jensen AMlFM CD player " "
23 Two 100 Watt Amplifiers " "
24 Two 100 Watt Sub-Woofers" "
25 Accidental Life Insurance " "
Policy, $25,000 face value,
$0 cash surrender value,
current beneficiary is Keith
Harrison
'-','C'.-;
26
Litigation claim against
Allstate Insurance
and Larry Morrison for
$6,026 filed on November
10, 2003, in Silver Springs
District Court before Justice of the
Peace, Thomas Placey, District Court
No. 09-3-04
"
"
27
$400.00 child tax credit
check from the IRS
"
"
NON-MARITAL PROPERTY
Defendant lists all property in which a spouse has a legal or equitable interest which
is claimed to be excluded from marital property:
Item
Number
1
Description
of Property
Patio Set
Reason for
Exclusion
Purchased after
Plaintiff left the
marital residence and
with funds from an
insurance policy
in which only
Defendant is a policy
holder
2
HP Pavilion Computer
Purchased after
Plaintiff left the
marital residence and
with funds from an
insurance policy
in which only
Defendant is a policy
holder
3
VCR
Purchased by
Defendant's mother
as a gift for
Defendant
-
4
Item
Number
Item
Number
1
2
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Disability Benefits
including ssm &
private 3'd party
benefits from
Integrated Disability
Resources, Inc. Both SSDI
and private 3'd party
benefits are received on
a monthly basis.
Disability payments
do not constitute
marital property
PROPERTY TRANSFERRED
Description Date of
of ProDertv Transfer
Person to Whom
Transferred
Consideration
LIABILITIES
Description
of ProDertv
1995 Ford
F 350 Truck
Names of
All Creditors
Arcadia Financial
Names of
All Debtors
Kristine & Keith Harrison
3'd Party Disability Integrated Disability Kristine Harrison
Benefits Resources, Inc.
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KEITH A. HARRISON,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
; CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
; IN DIVORCE
KRISTINE L. HARRISON,
Defendant
: NO. 01-3221 CIVIL TERM
CERTIFICATE OF SERVICE
I, Nicholas Aloia ofthe Family Law Clinic certify that on this date I am serving a true and
correct copy of Inventory of Kristine L. Harrison on the following individual by depositing the
same in the United States mail, first class, postage prepaid:
Timothy J. Colgan, Esq.
1 South Baltimore Street
Dilsburg, P A 17019
Date:NOIIc.""'tx.,,, ~S-~OQ":>
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Nicholas Aloia
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KEITH A. HARRISON,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: IN DIVORCE
KRISTINE L. HARRISON,
Defendant
: NO. 01-3221 CIVIL TERM
PRAECIPE TO WITHDRAW CLAIM FQR EQUITABLE DISTRIBUTION
To the Prothonotary:
Kindly allow Defendant Kristine L. Harrison to withdraw her Claim for Equitable
Distribution filed in the above captioned matter on June 25, 2003.
Respectfully submitted,
Date 03/10/04
CaA""-_ fVl ~
Caro1~ M. Fenton
Certified Legal Intern
~S~'~~
ANNE MACDONALD-FOX
LUCY JOHNSTON-WALSH
Supervising Attorneys
F AMIL Y LAW CLINIC
45 North Pitt Street
Carlisle, P A 17013
717-243-2968
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KEITH A. HARRISON,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
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v.
: CIVIL ACTION - LAW
: IN DIVORCE
KRISTINE 1. HARRISON,
Defendant
: NO. 01-3221 CIVIL TERM
CERTIFICATE OF SERVICE
I, Carolyn M. Fenton, do hereby certifY that on this date I am service a true and correct
copy of Praecipe to Withdraw Claim for Equitable Distribution, on Attorney Timothy J. Colgan,
1 South Baltimore Street, Dillsburg, PA 17019, by the depositing the same in the United States
mail, first class, postage prepaid
Date: O:YIfY(y,t
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Carolyn M. Fenton
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KEITH A. HARRISON,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: OF CUMBERLAND COUNTY, PENNSYLVANIA
:
vs. : No. 01-3221 Civil Term
KRISTINE L. HARRISON, : CML ACTION - LAW
Defendant : IN DIVORCE
SOCIAL SECURITY INFORMATION SHEET
PURSUANT TO 23 Pa.C.S.A. SECTION 4304.1(a)(3) ALL DIVORCES MUST INCLUDE
THE PARTIES SOCIAL SECURITY NUMBER.
PLEASE FILL IN THE APPROPRIATE INFORMATION AND RETURN TO THE
PROTHONOTARY'S OFFICE.
DATE:
October 19,2004
DOCKET NO.:
01-3221-Civil Term
PLAINTIFF SS NO.:
209-56-0144
NAME:
Keith A. Harrison
DEFENDANT SS NO.:
196-58-9925
NAME:
Kristine L. Harrison