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Home My WebLink About01-04894 IN THE COURT OF COMMON PLEAS S}e hanie 1~1~c1-,el1e Lheecher ~lain~i~ VERSUS Clnr~s~o er ~.~nl. (~eecher ~e~endanl NO. o`lObl-Oy$q~l ~Uii DECREE [N DIVORCE ~~yt"A~v~ ~~wv~ ~ -~,•sgP.M . AND NOW, ~~- /1 ~ IT IS ORDERED AND DECREED THAT 5}epl~nie Michelle beeche (' PLAINTIFF, AND Christopher I.vnn dc~chef DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; N o +~ E BY ATTEST: J. PROTHONOTARY ~~ ~U ~~ ~ - ~ ~ ~o ~ ~ ~~~° ~• ~s~ ~~~~~~~~~a~ Stephanie M. Beecher PLAINTIFF, v. Christopher L. Beecher DEFENDANT. (IN THE COURT OF COMMON PLEAS OF ( (CUMBERLAND COUNTY, PENNSYLVANIA ( ( CIVIL DIVISION ( ( NO: 2001-04894 MARITAL PROPERTY SETTLEMENT AGREEMENT THIS AGREEMENT, made this 1 day of March , 2002 between PLAINTIFF, Stephanie M.13eecher ,residing at 106 Cider Drive (city) York Springs ,Pennsylvania 17372 (zip), hereinafter called "Husband"/Wife," and DEFENDANT, Christopher L. Beecher ,residing at 324 Walnut Lane , (city) Carlisle ,Pennsylvania 17013 (zip), hereinafter called "Husband"/Wife." WITNESSETH WHEREAS, the parties were married on: (date) October 16, 1999 ; WHEREAS, the parties filed for 3301 (c) Divorce on: (date) August 20, 2001; WHEREAS, the parties hereto desire to settle their property rights; WHEREAS, both parties agree to relinquish any and all claims which either may have against any property now owned or belonging to the other or which may hereinafter be acquired by either of them by purchase, gift, devise, bequest, inheritance, or otherwise, except as to the obligations, covenants and agreements contained herein; and WHEREAS, both parties each have had opportunity to seek the benefit of competent and independent legal advise by separate counsel. 1. INCORPORATION OF RECITALS The recitals on Page 1 of this Agreement are incorporated herein as if set forth in full. Each paragraph hereof shall be deemed to be a separate and independent covenant and agreement. 2. APPLICABLE LAW This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania. 3. PROPERTY TO BE RETAINED BY WIFE. Husband and Wife agree that, unless otherwise indicated in this agreement, the Wife shall keep all of her own personal clothing and effects; and that the following property shall also be retained by the Wife: (1) Oak Antique Bedroom Suite (Bed, Dresser with Mirror and Wash stand) (1) Oak Full Length Mirror (1) Berkline Reclining Sofa (1) Pine Farm Table with 2 chairs (1) Bissell Carpet Cleaner (1) 27" Zenith TV with remote (1) Oak Desk (1) Cedar Chest Collection of Longaberger Baskets (1) Black and Decker Toaster Oven (1) Full Mattress and Box Spring (1} Pampered Chef Collection (1) Red Mountain Bike 4. PROPERTY TO BE RETAINED BY HUSBAND. Husband and Wife agree that, unless otherwise indicated in this agreement, the Husband shall keep all of his own personal clothing and effects; and that the following property shall also be retained by the Husband: (2) Pine Bar Stools (1) Single Bed (Mattress, Box Spring and Bed Frame) (1) Compaq Computer (1) HP Printer (1) Sofa bed (1) Pine Corner Entertainment Center (1) Gold Recliner (2) Table Lamps (1) Brass Floor Lamp (1) Hoover Vacuum Cleaner (2) Pine Chairs (1) Antique Table (1) Gas grill (1) Lawn Mower (1) Craftsman Weed Whacker (1) Pine Unfinished Book Case (1) Kenmore Washer (1) Kenmore Dryer (1) Refrigerator 5. DEBTS TO BE PAID BY WIFE. Husband and Wife agree that the wife shall pay the following debts and will not at any time hold the Husband responsible for them: (1) Cross Country Bank Visa Card, Amount owed $250.00 (1) Providian Visa Cazd, Amount owed $1,027.00 (1) Providian MasterCazd, Amount owed $ 325.00 6. DEBTS TO BE PAID BY HUSBAND. Husband and Wife agree that the Husband shall pay the following debts and will not at any time hold the Wife responsible for them: (1) Citi Financial Loan, in the amount of $3,737.30 Any and all debts that were accumulated before October 16,1999 (Student Loan, Credit Card Debt, Loans, Vehicle Loans) Any and all Utility bills past and present for the following address: 570 Range End Road, Apt #3 Dillsburg, PA 17019 831 East Louther Street Cazlisle, PA 17013 324 Walnut Lane Carlisle, PA 17013 Any and all taxes associated with the residence at 324 Walnut Lane, Carlisle, PA 17013 7. PENSIONS AND/OR PROFIT SHARING PLANS, BANK ACCOUNTS, STOCKS, BONDS, SECURITIES, CREDIT UNION ACCOUNTS, AND INDIVIDUAL RETIREMENT ACCOUNTS Husband and Wife distribute the respective accounts as follows: Husband and Wife will both retain each of their own 401K and Profit Sharing accounts in full. 8. REAL ESTATE Husband will retain the real estate property at 324 Walnut Lane, Carlisle, PA 17013. Husband will take full financial responsibility of the property including taxes and insurance. Wife will not be held fmancially responsible for the property, 9. ALIMONY, ALIMONY PENDENTE LITE, SPOUSAL SUPPORT, EXPENSES AND ALL MARTIAL RIGHTS Each of the parties hereto release the other from subsequent claims for alimony, alimony pendente lite, or spousal support. 10. JOINT DEBTS Husband and Wife warrant and certify to each other that there are no individual or joint martial obligations outstanding, other than those listed in paragraphs 5 and 6 above. 11. DIVORCE Husband and Wife agree that the marriage is irretrievably broken and will proceed with said Divorce under 23 Pa. C.A. Section 3301 (c). 12. TAX ADVICE The transfers set forth herein may result in income, inheritance, estate and other tax consequences to the parties. The parties specifically acknowledge that no attorney involved in the negotiating or drafting of this Agreement has provided any tax advised regarding the dispositions contained herein. The parties have been advised to seek separate tax counsel concerning the Divorce distributions. IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the day and year first above written. i ' W' ess ~~'L~ Wi ress ~~ ~ PLAINT F i'~/~ DEF ANT On this •~= day of ~- ~ 200 a ,before me, a Notary Public, the undersigned officer, personally appeared N S STEP~kl~t,1~ ~r.~R and C4lP~STOP~.r~ L (3E,C-.Gt~P~, known to me to be the persons whose names are subscribed to the wntten instrument, and acknowledged that they executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. C~ A ` . _ ~ ~t Apt„ p) Notarial Seal ~~~1-~- Cynthia L.Thomas, Notary Public NO P b11C 'HampdenTwp., Cumberland County My Commission Expires Nov. t, 2004 Member, PennsyNaniaAssociationof Notaries Stephanie Michelle Beecher PLAINTIFF, v. Christopher Tvnn Rea h r DEFENDANT. ( IN THE COURT OF COMMON PLEAS OF ( Cumberland COUNTY, PENNSYLVANIA ( CIVIL DIVISION (NO: 2001-04894 ACKNO~ FDGEMEN7' A complaint 1n Divorce under Section 3301 (c) of the Divorce Code was filed on ~I 2200 l . I agree that the marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint.All information contained within the attached documentation is true and wrrect to the best of my knowledge, information, and belief. It is my desire to file with the ('nmhar l a n rl County Court of Common Pleas the. attached Marital Property Settlement Agreement and to be bound fully and completely by the terms and conditions as set forth within said Marital Property Settlement Agreement documentation. IN WITNESS WHEREOF, I set my hand and seal this S t day of 1Z Rl~, 200. ~ ~a eA ~Ni~LD^ ~v ~~ 112 NAME: S~ On this ~-`~T day of ~qUR'~~ 200a before me, a Notary Public, the undersigned officer, personally appeared NAME STEPii~ir` 1(3F~1_UEk ,known to me to be the person whose name is subscribed to the written instrument, and acknowledged that she executed the acme for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and of&dal seal. +~1 h ~ p _ ~ , ~ Notarial Seal r p ~~^. '~wu't~nn444~A~I// Cynthia L.Thomas, Notary Public ~~ iiampdenTwp., Cumberland County Notary Public MY Commission Expires Nov. 9, e"004 eber, Pannsiilvanta Association of Notaries Stephanie Michelle Beecher PLAINTIFI3 v -rhri Stnnher 7.vnn Ran hAr DEFENDANT. (IN THE COURT OF COMMON PLEAS OF ( Cumberland COUNTY, PP.NNSYLVANIA ( CIVIL DPJISION [ NO: 2001-04894 ACKNOWLEDGEMENT A complaint in Divorce under Section 3301 [c~ of the Divorce Code was filed on ~ 20 2001 . I agree that the marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. All information contained within the attached documentation is true and correct to the best of my knowledge, information, and belief It is my desire to file with the r ,mr, rl ~ Cormty Court of Common Pleas the attached Marital Property Settlement Agreement and to be bound fully and completely by the terms and condiflons as set forth within said Marital Property Settlement Agreement documentation. IN WITNESS WHEREOF, T set my hand and seal this ~~~ day of ~£P~ i )A~2.~1 .200 0~.. NAME: Chrls ~boher L Q ee c% er On this ~`~ l day of _~~ 200.,x_, before me, a Notary Public, the undersigned officer, personally appeared NAME ~SToP~~ ~-- ~<' Fli=~ known to me to be the person whose name is subscribed to the written instrument, and acknowledged that she executed the same for the purposes therein rnntained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. Notary Public t;ynthla L.Ttwmzs No4ary Public Hampden Twp., Cumberland County My Commission Expires Nov. t , 2004 ~~ c> ~ ~ i^ t'ti -~, Je' ";,i I ~1R e r r s ~, fC7 ~ ~ ~E~ ^~ (..._ ;fit i ~ -G •~~, Stephanie Michelle Beecher PLAINTIFF, v. Christopher Lynn Beecher DEFENDANT. (IN THE COURT OF COMMON PLEAS OF ( Cumberland COUNTY, PENNSYLVANIA ( CIVII. DIVISION ( NO: 2001-04894 PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Kindly 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) or ~~) of the Divorce Code. (Strike out applicable section.) Z. Date and manner of service of the Complaint: on or about GIVE DATE: August 20, 2001 via (circle one ersonal Service r Certified Mail. 3. (Complete either pazagraph (a) or (b).) (a) Date of execution of the Affidavit of Consent/Consent Waiver required by Section 3301 (c) of the Divorce Code: by Plaintiff (1 / a / ooi); by Defendant ( / / ). (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 Plaintiffs Affidavit required by Section 3301(d) of the Divorce Code: 4. Related claims pending: None. _.__'~('.~ A 1 ~ 1- rho C ,u ~ Plaintilf Address: sOh c~; ~ ,- nr; v York Springs, PA 17372 Phone: (717 ) 528-4118 5. Date and manner of service of the Notice of Intention to file Praecipe to Transmit Record, a copy of which is attached, if the Decree is to be entered under Section 3301 (d) of the Divorce Code. f'3 `'-'' "`3 C C ' f i ~ ,-,~ __, ~ ~ i i" i Vi ~_. ~~. _ ~~ ~~ ~ ~ __ ~ ` .a-~ r. ~~'`' ~ ~ ~ < .,.,~ = '~ "a ... .. .. ~ _, iB N~z.s.=x, a. -^. :_ .:.^.; xi.-.,~pnvu,..~.^,'~F~'4T~~N,ne^~,r9a»Fpia;;T.,~,rzs~T.~RSk~aIA.S~~tiA:'. Y I" '~ Stephanie M. Beecher (IN'I'gE COURT OF COMMON PLEAS OF ( Cumberland COUNTY, PENNSYLVANIA v PLAINTIFF, ( CIVIL DIVISION Christopher L. Beecher ~ _ _ (NO: ~!,- ~{~y `/o~C~~L~ DEFENDANT. NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIM 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 DNORCE OR ANNULMENT MAY BE ENTERED AGAINST YOU BY THE COURT. A NDGMENT 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 CHILD(REN). WHEN THE GROUND FOR THE DNORCE ARE INDIGNITIES OR IRRETRIEVABLE BREAKDOWN OF THE MARRIAGE, YOU MAY REQUEST MARRIAGE COUNSELING. A LIST OF MARRIAGE COUNSELORS IS AVAILABLE IN THE OFFICE OF THE PROTHONOTARYAT 1 Courthouse Square, Carlisle . PENNSYLVANIA. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES, OR EXPENSES BEFORE A DNORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. TF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIlVD OUT WHERE YOU CAN GET LEGAL HELP. LAWYERS REFERRAL SERVICE Services, Inc. 8 Irvihe Row. Carlisle, PA 17013 Telephone: rn7~ zas-aaoo Stephanie M. Beecher N'rj ~,(~ ~,. {~( ~~ 7J For Petitioner A(ldI'eSS:324 Walnut Lane Carlisle, PA 17013 Telephone: 1717) 691-9787 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Stephanie M. Beecher Plaintiff CIVIL ACTION NO. ~ - ~-~ ~ ! j 6/~ v. Christopher L. Beecher Defendant COMPLAINT FOR DIVORCE AND NOW, comes the Plaintiff, Pro Se, and hereby avers as follows: 1. The Plaintiffhas been a resident of Pennsylvania for at least six months prior to the filing of this Petition. 2. The Plaintiff and/or Defendant is a resident ofCounty, Pennsylvania, and is therefore subject to the jurisdiction of this Court. The Plainfiffpresently resides at 324 Walnut Lane, Carlisle, PA 17013 and the Defendant presently resides at 324 Walnut Lane, Carlisle, PA 17013. Defendant may also be served at said residence. 3. The Plaintiff and Defendant mutually consent to this divorce pursuant to23 Pa. C.S. @ 3301(C), one from the other. 4. Defendant has waived service of process. 5. Page 1 The parties are husband and wife, having been married on October 16, 1999 at Cazlisle, PA, but who did separate on January 25, 2001 and are now living in a bona fide state of separation. Plaintiff and Defendant have been sepazated for at least six months immediately prior to filing this complaint. 6. There were no children bom of issue as a result of this marriage. 7. There is no dispute as to the division of real property. There is no dispute as to any joint debts. There is no dispute as to the division of personal property obtained before or during the marriage . 8. Plaintiff brings this Complaint for Divorce on the grounds that the marriage is irretrievably broken pursuant to 23 Pa.C.S. @ 3301(C). WHEREFORE, Plaintiff respectfully prays: (A) That Plaintiff be granted a total divorce, avinculo matrimoni; (B) That Plaintiff be granted such other and further relief as the Court may deem just and fair. Stephanie M. Beecher, Pro Se 324 Walnut Lane, Carlisle, PA 17013 717-691-9787 ~ dcz:~ ~ P~qu.~ 300 s.,.,.~, ~~~~~ Page 2 w„ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Stephanie M. Beecher Plaintiff CIVIL ACTION NO. Christopher L. Beecher Defendant VERIFICATION Personally appeared before the attesting officer authorized by law to administer oaths, Stephanie M. Beecher, who, first being duly sworn, on oath deposes and says that the facts alleged in the above and foregoing are true and correct. Sworn and subscribed before me this ~ day of ~jmv t~, 2000. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Stephanie M. Beecher Plaintiff CIVIL ACTION NO. v Christopher L. Beecher Defendant CONSENT TO DIVORCE COMES NOW the Plaintiff, Stephanie M. Beecher, and the Defendant, Christopher L. Beecher, in the above-styled action and pursuant to 23 Pa.C.S @ 3301(C), give mutual consent to divorce, one from the other. Defendant has waived service of process. ,_~2 Steph ie M. Beecher Plaintiff Swom and subscribed Before me this ~' day Of, 200{1. Notary Pub ' ;r1%/ Chri opher L. Beecher Defendant Sworn and subscribed before me this 9 day Of /-~u°~, 2000. Notarial Seal J. Mistyan, Notary Public n rwp.; Cumberland Cou CortuniseWn Expires June 28, 2 PenrfryNanla Associ8fion of Notaries Notary Publi J. Nns~lya , Notary Pu611c Twp., Cumbeuand Cou b-Y Comndsslnn Expires June 28, 2 Member, PennsyNanle Assocfetion of Notarise C; ~ r7 -_ 1 ~~ ~ .~ ~ 1 7 V1 ~ ~~') _ r ~ ~ C ,^ " ( _ ~ s ~ (~ ~ C. <_, , ~ . ... Ti ~ ~ ~ v ~ ~ ~i 43'i G - : stephanie Michelle Beecher (IN THE COURT OF COMMON PLEAS OF PLAINTIFF, ( Cumberland COUNTY, PENNSYLVANIA v. ( CIVIL DIVISION Christopher Lynn Beecher (NQ;2001-04894 DEFENDANT: AFFIDAVIT OF CONSENT A complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on (date:) ~/ ~~ / ~n~.l 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and Complaint. 3 I consent to the entry of a final decree of Divorce after service of notice of intention to request entry of the deaee 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 deaee of Divorce without notice. 2. I understand that I may lose rights concerning alimony, division. of property, lawyer s fees, or expenses if I do not claim them before a Divorce is granted. 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 here- in are made subject to the penalties of 18 Pa C.S. Section 4904 relating to unsworn falsification to authorities. Date: ~ / ~l / Off. /_ITA ,[~(lC,tl''LA__D ~ • ~Q,(9~ e,c Plaintiff ~~ c~ o = c^ r~a ;, J f~lj miy _ ~~ f~?i / ~'.~ ~~ ~ 4 mv. `l - = , '~~ t ~ W~. ;-~ ~i' ~? D C ~ ~~ ~' °- K .Sr r, M• h ~i ®rhe~ PLAINTIFF, v. Christopher Lynn Beecher DEFENDANT. (IN THE COURT OF CONIMON PLEAS OF ( Cumberland COUN'T'Y, PENNSYLVANIA ( CIVIL DIVISION (NO: 2001-04894 AFF)DAV1T OF CONSENT I. A complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on (date:) .g_/.~12pp1 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of ailing and 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. WAVER OF NOTICE OF INTENTION TO REQUEST F.NTRU OF A DNORCE DECREE UNDER SECTION 3301 ~cl OF THE DNORCE CODE 1. I consent to the entry of a final decree of Divorce without notice. Z. I understand that I may lose rights concerning alimony, division of property, lawyer's fees, or expenses if I do not claim them before a Divorce is granted. 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 aze true and correct. I understand that false statements here- in are made subject to the penalties of 18 Pa C.S. Section 4904 relating to unswom falsification to authorities. Date: ~ /~ ~-2 -- (~~~~~ Defendant ~~ C> c-, , c~ ~v r ~ ,~ . `q Cn ~ ' ' • n ~r T s ~_ y = r- ~ c~~.; °_ ~~ c „- --r-' - ~, _ ~, _ 'r` ~~ u ACKNOWLEDGEMENT OF SERVICE AND WAIVER OF PROCESS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Stephanie M. Beecher Plaintiff CIVIL ACTION NO. D 1 ' "1 0 v Christopher L. Beecher Defendant ACKNOWLEDGEMENT OF SERVICE AND WAIVER OF PROCESS COMES NOW, Christopher L. Beecher, defendant in the above styled case and acknowledges service of the above styled complaint for divorce. Defendant fizrther waives service and any other further notice of subsequent hearings on this matter. Christopher L. Beecher Defendant Sworn to and subscribed before me this ~ day of A g _, 2001. Q ~. &~. f ~~Z _G, Q ~p C~ C~ ~. t O// ~ ~~ ~ G ~" O r°"' C%~ ~A NOTICE TO FILE SOCIAL SECURITY NUMBERS PURSUANT TO THE 23 P.S. SECTION 4304.1(a)(3) PARTIES TO A DNORCE ARE REQUIRED TO PROVIDE THEIR SOCIAL SECURITY NUMBERS TO THE COURT. PLEASE SUBMIT THE SOCIAL SECURITY NUMBERS OF THE PARTIES TO YOUR DNORCE TO THE PROTHONOTARY. PLEASE FILL IN THE APPROPRIATE WFORMATION AND RETURN TO THE PROTHONOTARY OFFICE--THESE INFORMATION SHEETS WILL BE KEPT IN A SEPARATE FILE. DATE: .7anuary 4, 2002 DOCKET NUMBER: PLAINTIFF/PETITIONER SS#: 181-68-5424 NAME: Stephanie Michell RPP(`YIPY DEFENDANT/RESPONDENT SS#: 223-06-551 ~ NAME: Christopher Lynn Beechar Office of Clerk of Records Prothonotary Division County Courthouse