HomeMy WebLinkAbout01-06087
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
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PENNA.
STATE OF
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STEPHEN C. ANDERSON
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No.
01-:6087
VERSUS
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SHANNON M. ANDERSON
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DECREE IN
DIVORCE
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AND NOW,
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, 2-/lb2, IT IS ORDERED AND
DECREED THAT
Stephen C. Anderson
, PLAINTIFF,
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AND
Shannon M. Anderson
, DEFENDANT,
. ARE DIVORCED FROM THE BONDS OF MATRIMONY,
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THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED;
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The Marital Settlement Agreement betwen the parties dated March 6, 2002
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is incorporated but not merged herein.
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By THE COURT:
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PROTHONOTARY
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M A RTT AT, SETTT ,EMF.NT A(;RF,EMF.NT
THIS AGREEMENT, made this '- day o~ 2002, by and between Stephen C.
Anderson, (hereinafter "Husband") of $j.!lJ~ Cumberland County, Pennsylvania and
Shannon M. Anderson, (hereinafter "Wife") of Miami, Florida.
WITNESSETH:
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WHEREAS, the parties are Husband and Wife, married on January 3, ftlSl8, iD.:North '-,~
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WHEREAS, two children, Carter Riley Anderson (D.G.B. 2/8/98) and k\.:pstiri.:. Tyl\:f
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Anderson (D.G.B. 2/18/00) were born of the marriage; and
WHEREAS, unhappy differences and difficulties have arisen between the parties, in
consequence of which the parties intend to live separate and apart for the rest of their natural lives;
and
WHEREAS, Husband and Wife are the Plaintiff and Defendant in a divorce action filed in
the Court of Connnon Pleas of Cumberland County, Pennsylvania docketed at 01-6087 and wish
that this Agreement be incorporated into the divorce action as a full and complete resolution of the
parties' property issues; and
WHEREAS, the parties desire to settle fully and finally their respective financial and
property rights and obligations as between each other, including but not limited to the ownership
and equitable distribution of real and personal property; past, present and future support, alimony
and/or maintenance; and any and all claims which either party has, or may have, against the other or
the other's estate; and
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NOW, THEREFORE, in consideration of the mutual promises, covenants and undertakings
hereinafter set forth and for other good and valuable consideration, receipt of which the parties
acknowledge, Husband and Wife, each intending to be legally bound, hereby covenant and agree as
follows:
l. ~FPARATION
Each party shall have the right to live separate and apart from the other party, free from the
other party's interference, authority and control. Neither party shall interfere with the other or
attempt to interfere with the other, nor compel the parties' cohabitation.
2. NO MOT R~T A TTON
Neither party shall in any way molest, disturb, or trouble the other or interfere with the
peace and comfort of the other or compel or ,seek to compel the other to associate, cohabit or dwell
with him or her by any action or proceeding for restoration of conjugal rights or by any means
whatsoever.
3. m T~HA Nn'~ A Nn WTFR'~ nRHT~
Except as otherwise set forth in this Agreement, the parties represent and warrant to each
other that they have not incurred and will not contract or incur any debt or liability for which the
other or the other's estate might be responsible. Each party shall indemnifY and save hannless the
other party from any and all claims or demands made against the other by reason of debts or
obligations incurred by that party.
4. WATVRR OF RTGHTS ANn MT TTI TAL RRLFASF~
Except as provided in this Agreement, both parties absolutely and unconditionally release
Document #: 169974.1
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and forever discharge each other and their heirs, executors, administrators, assigns, property and
estate from any and all rights, claims, demands or obligations arising out of or by virtue of the
marital relationship, whether such claims exist now or arise in the future. This release shall be
effective regardless of whether such claims arise out of fonner or future acts, contracts,
engagements or liabilities of the parties or by way of dower, curtesy, widow'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 testamentary, or all other rights of a
surviving spouse to participate in a deceased spouse's estate, whether arising under the laws of
Pennsylvania, any state, commonwealth or territory of the United States, or other country.
Except for any cause of action for divorce which either party may have or claim to have,
and except for the obligations of the parties contained in this Agreement, each party gives to the
other an absolute and unconditional release and discharge from all causes of action, claims, rights
or demands whatsoever, in law or in equity, which either party ever had or now has against the
other, including but not limited to alimony, alimony pendente lite, spousal support, equitable
distribution of marital property, counsel fees or expenses.
5. REAr ESTATE
The parties do not own any real property.
6. DIVISION OF PERSONAl, PROPERTY
(a) All personal property currently in the possession of Husband shall be the sole and
separate property of Husband. All personal property belonging to Husband prior to marriage shall
be the sole and separate property of Husband.
Document #: 169974.1
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(b) All personal property currently in the possession of Wife shall be the sole and
separate property of Wife. All personal property belonging to Wife prior to marriage shall be the
sole and separate property of Wife.
7. MOTOR VFffin ES
(a) Wife shall retain sole and exclusive ownership of any vehicle(s) in her possession
and agrees to assmne sole responsibility for all outstanding encmnbrances, if any.
(b) Husband shall retain sole and exclusive ownership of any vehicle(s)in his
possession and agrees to assmne sole responsibility for the outstanding encmnbrances, if any.
(c) Both parties agree to execute, within thirty (30) days ofthe date of this Agreement,
any and all forms, titles and docmnents necessary to transfer the aforesaid vehicles from joint
ownership to individual ownership, as specified herein.
8. JOINT DFRTS
The parties acknowledge that they have no debts which were jointly incurred during their
marriage with the exception of the following:
Ac.c.mlnt
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(a)
Nellie Mae serviced by Sallie Mae
Student Loan
Account Nmnber 465896673-1
approximate balance $8,120.37
Wife shall be solely respoIlSible for the monies owed on the on the aforesaid student loan
bearing account nmnber 465896673-1. The aforesaid amount ($8,120.37) represents Wife's
student loan obligation which was incorporated into Husband's student loan obligation. Husband
agrees to be responsible for his student loan obligations aside from his Wife's student loan
Document#:16997~1
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obligation mentioned hereinabove. Both parties agree to indemnify the other for their failure to
carry out the aforesaid obligations.
Any debts or obligations incurred by either party in his/her individual name, other than
those specified herein, whether incurred before or after separation, are the sole responsibility of the
party in whose name the debt or obligation was incurred.
9. RETTREMENTRFNRFTTS ANOIRA'.
Both parties waive, release, renounce and forever abandon all of their right, title, interest or
claim, whatever it may be in any individual retirement accounts/investment accounts of the other
party, ifany.
10. OTVTSTON OF RANK A(:r~OTJNTS
Husband and Wife acknowledge that all joint bank accounts have been closed or divided to
their mutual satisfaction prior to the execution of this Agreement. Any individual accounts shall be
the sole and separate property of the party in whose name the account is held.
11. AFTER-ArQTTTREO PROPERTY
Each of the parties shall own and enjoy, independently of any claims or rights of the other,
all real property and all items of personal property, tangible or intangible, hereafter acquired, with
full power to dispose of the same as fully and effectively as though he or she were unmarried. Any
property so acquired shall be owned solely by that party and the other party shall have no claim to
that property.
12.
SPOTJSA T STJPPORT AT .TMONY PENDENTE UTE A NO AT JMONY
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Husband and Wife waive and relinquish all rights, if any, to spousal support, alimony
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pendente lite, and alimony.
The parties' Agreement with respect to spousal support, alimony pendente lite and alimony
is non-modifiable for changed circumstances.
13. TAXMATTFRS
The parties have negotiated this Agreement with the understanding and intention to divide
their marital property. The parties have determined that such division confonns to a right and just
standard with regard to the rights of each party. The division of existing marital property is not,
except as may be otherwise expressly provided herein, intended by the parties to constitute in any
way a sale or exchange of assets. It is understood that the property transfers described in this
Agreement fall within the provisions of section 1041 of the Internal Revenue Code, and as such
will not result in the recognition of any gain or loss upon the transfer by the transferor.
Wife shall be entitled to claim the dependency exemption for Carter and Tyler on all
applicable tax returns and Husband agrees to take all necessary steps and sign all required
documents to effectuate Wife's claiming the exemption.
14. rTlSTOTW A Nfl rl-TTT fl Sl JPPORT
The parties will have joint legal custody of Carter Riley Anderson (D.O.B. 2/8/98) and
Austin Tyler Anderson (D.O.B. 2/18/00). Wife shall have primary physical custody and Husband
shall have partial physical custody of Carter and Tyler as follows:
(a). six (6) weeks during the summer break consisting of 2"3 week intervals. The
summer break will be defined by the school policy in Florida;
(b) Every other Christmas break beginning on the last day of school or the aftemoon
Document #: 169974.1
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before the holiday which ever occurs first and ending on the day before school resumes. Father
shall have custody on all even numbered years;
( c) Every other Spring break begiDning on the first day of spring break or on the
afternoon before break which ever occurs first and ending on the day before school resumes. Father
shall have custody on all odd numbered years;
(d) The parties shall enjoy such other partial custody with Carter and Austin as agreed
between them.
(e) The parties agree that the exchange/meeting place for custody shall take place
Savannah, Georgia. The exact place shall be determined by the parties.
(f) The parties agree to refrain from negative or derogatory comments about the other in
the presence of Carter and Austin.
(g) Both parties shall pennit liberal telephone calls to the minor children from the non-
custodial parent.
(h) The parties agree to cooperate with one another in the implementation of the
aforesaid Agreement and understand and agree that other changes or modifications in the aforesaid
schedule and/or times specified may be necessary to enable both parents to continue to foster and
develop a good and healthy relationship with the children. To that end, the parties agree to
cooperate with one another to encourage the relationship of the children with the other parent and
agree to refrain from any and all conduct, activity, or communication which would adversely affect
the childrens' relationship with either parent.
Document#:16997~1
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15. TIFE TNSlTRANCE
Any life insurance policies which each party has remain the separate property of that party.
Each party hereby waives, releases, renounces and forever abandons all of their right or interest in
the others life insurance, if any.
16. COllNSFT FEES ANn EXPENSES
The parties hereto agree to be responsible for their own attorney's fees related to their
divorce action.
17. AnVTCEOFCOllNSEL
The parties acknowledge that each has received or has had the opportunity to receive
independent legal advice from counsel of their selection and that they have been informed fully as
to their legal rights and obligations, including all rights available to them under the Pennsylvania
Divorce Code of 1980 as amended, and other applicable laws.
Each party confirms that he/she understands fully the terms, conditions, and provisions of
this Agreement and believes them to be fair, just, adequate and reasonable under the existing
circumstances. The parties further confirm that each is entering into this Agreement freely and
voluntarily and that the execution of this Agreement is not the result of any duress, undue influence,
collusion, or improper or illegal agreement.
18. nfVORCE
Each party agrees to execute an Affidavit of Consent and Waiver of Rights for the obtaining
of a no-fault divorce under the provisions of the Divorce Code of 1980, as amended.
19. EFFlWT OE nfVORCE nECREE ON AGREEMENT
L>ocument#: /699741
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It is agreed that this Agreement shall be incorporated by reference into the final divorce
decree, but not merged therein. Either party may enforce this Agreement as provided in section
310S(a) of the Divorce Code, as am"no"o.
As provided in section 31OS( c), provisions of this Agreement regarding equitable
distribution, alimony, alimony pendente lite, counsel fees or expenses shall not be subject to
modification by the court.
20. Sf JRSFQf JRNT DNORCE
There is pending between the parties an action for divorce instituted in the Court of
Common Pleas of Cumberland County, Pennsylvania. Husband and Wife agree that their marriage
is irretrievably broken and that the same shall be dissolved pursuant to Section 3301 (c ) of the
Divorce Code of Pennsylvania. The parties therefore agree as follows:
(a) Husband and Wife agree to sign the Court Affidavits of Consent agreeing to the entty
of a final decree of divorce as well as Waiver of Notices of Intention to request Entty of
a Divorce Decree under Section 3301 (c) of the Divorce Code,
(b) Neither party request counseling prior to the filing of said Affidavits of Consent and
therefore the right to request such counseling shall be deemed waived.
21. HFADTNGSNOTPARTOF AGRFEMFNT
The descriptive headings preceding the paragraphs are for convenience and shall not affect
the meaning, construction or effect of this Agreement.
22. SEVERARTT {TV AND TNf)EPENDENT AND SEPARATE COVENANTS
Each separate obligation shall be deemed to be a separate and independent covenant and
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Agreement. 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 tenn, 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.
23. AGRFFMFNT RTNnING ON HFTR~
This Agreement shall be binding on and shall ensure to the beneht of the parties and their
respective heirs, executors, administrators, successors, and assigns.
24. INTFGR A TTON
1bis Agreement constitutes the entire understanding of the parties and supersedes any and
all prior Agreements and negotiations between them. There are no representations, warranties,
covenants or promises other than those expressly set forth in this Agreement.
25. MOnTFTCA TTON OR W A NFR TO RF IN WRTTING
No modification or waiver of any tenn of this Agreement shall be valid unless in writing
and signed by both parties.
26. NO WANFR OFDFFATTT T
The failure of either party to insist upon strict performance of any term of this Agreement
shall in no way affect the right of such party hereafter to enforce the tenn.
27. VOTTTNTARYFXFCTlTTON
The parties acknowledge that this Agreement is fair and equitable, and that they have
reached this Agreement freely and voluntarily, without any duress, undue influence, collusion or
improper or illegal Agreements.
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28. APPT.TrARTET.AW
This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania
and more specifically under the Divorce Code of 1980, as ~menc1ec1.
29. A TTORNFYS' FFFS FOR FNFORrFMFNT
If either party breaches any provision of this Agreement, the breaching party shall pay all
reasonable legal fees and costs incurred by the other in enforcing this Agreement, providing that the
enforcing party is successful in establishing that a breach has occurred.
IN WIlNESS WHEREOF, the parties have set their hands and seals the day and year first
written above.
WITNESS:
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Document #: 169974,1
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STATE OF Pel\l\g"ltIV4//; q
COUNTY OF t"~(\e,,..,i'-
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On this, the & day of /i'lM9
2002, before me, the undersigned officer, personally
appeared Stephen C. Anderson known to me or satisfactorily proven to be the person whose name
is subscribed to in the foregoing Marital Settlement Agreement, and acknowledge that he executed
the same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my
***************************************
STATE OF- FLofUOf[
COUNTY OF. Vlt1 114 \1tIt l 0 If De
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On this, the .k!ttday of ~ 2002, before me, the undersigned officer,
personally appeared Shannon M. Anderson known to me or satisfactorily proven to be the person
whose name is subscribed to in the foregoing Marital Settlement Agreement, and acknowledge that
she executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
J"'es..... Romat.. L Rambo....
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Document#: 169974,1
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STEPHEN C. ANDERSON,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 01"6087
SHANNON M. ANDERSON,
Defendant
CIVIL ACTION - LAW
DIVORCE
PRAECIPE TO TRANSMIT RECORD
TO THE PROTHONOTARY:
Kindly transmit the record, together with the following infonnation, to the Court for entry
of a Divorce Decree:
I. Ground for divorce:
Irretrievable breakdown under g3301(c) of the Divorce Code.
2. Date and manner of service of Complaint:
Served upon Defendant: via certified mail, On December 6, 2001. Affidavit of
Service filed on January 15,2002,
3. Complete either paragraph (a) or (b):
(a) Date of execution of Plaintiffs and Defendant's Affidavits of Consent required by
Section 3301(c) of the Divorce Code and Waiver of Notice ofIntention to Request
Entry of a Divorce Decree under Section 3301(c) of the Divorce Code, pursuant to
Pa.R.C.P.1920.42(e)(I):
Plaintiff - 3/16/02 and filed 3/27/02
Defendant- 3/13/02 and filed 3/27/02
(b)(I) Date of execution of Plaintiffs affidavit required by Section 3301(d) of the Divorce
Code: nla
(2) Date of service of the plaintiffs affidavit upon the defendant: nla
4. Complete the appropriate paragraphs:
(a) Related claims pending: All claims have been resolved by a signed Marital
Settlement Agreement dated March 6 , 2002.
Document #: 230442.1
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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 ~3301(d)(I)(i) of the Divorce Code: nJa
METZGER, WICKERSHAM, KNAUSS & ERB, P.C.
Steven C. Co
J.D. No. 74669
3211 North Front Street
P.O. Box 5300
Harrisburg, PA 17110-0300
(717) 238"8187
Attorneys for Plaintiff
l)ocument#145617
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STEPHEN C. ANDERSON,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 01"6087
SHANNON M. ANDERSON,
Defendant
CIVIL ACTION - LAW
DIVORCE
CERTIFICATE OF SERVICE
~
AND NOW, this ~ day of March, 2002, I, Steven C. Courtney, Esquire, of Metzger,
Wickersham, Knauss & Erb, attorneys for Plaintiff, hereby certify that I served a copy of the
Praecipe to Trallsmit Record this day by depositing the same in the United States mail, postage
prepaid, at Harrisburg, Pennsylvania, addressed to:
Shannon M. Anderson
18450 S.W. 87th Avenue
Miami, Fl 33157
ERE
Document # 145617
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO: 01 - ,-of7 Cll>~l't-~
STEPHEN C. ANDERSON,
Plaintiff
SHANNONM. ANDERSON,
Defendant
CIVIL ACTION - IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
To: ShannonM. Anderson
18450 S.W. 871h Avenue
Miami, Florida 33157
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims
set forth in the following pages, you must take prompt action. You are warned that if you fail to do
so, the case may proceed without you and a Decree of Divorce or annulment may be entered against
you by the court. A judgment may also be entered against you for any other claim or relief
requested in these papers by the Plaintiff. You may lose money or property or other rights
important to you.
When the ground for divorce is indignities or irretrievable breakdown of the
marriage, you may request marriage counseling. A list of marriage counselors is available in the
office of the Prothonotary at the Cumberland County Courthouse, One Courthouse Square, Carlisle,
Pennsylvanial7013.
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 THIS 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 Court Administrator
4th Fl., Cumberland County Courthouse
Carlisle, P A 17013
(7l7) 240-6200
Document #: 218282.1
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STEPHEN C. ANDERSON,
Plaintiff
:
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,PENNSYL VANIA
NO: 01 - I.cPr (2.iC)~LT~
CIVIL ACTION - IN DIVORCE
v.
SHANNONM. ANDERSON,
Defendant
COMPLAINT UNDER SECTION 3301(c) OR
3301 Cd) OF THE DIVORCE CODE
COUNT I -DIVORCE
1. Plaintiff is Stephen C. Anderson, who currently resides at 421 Cherokee Drive,
Mechanicsburg, CwnberIand County, Pennsylvania 17055. Plaintiff's social security nwnber
465-89-6673.
2. Defendant is Shannon M. Anderson, who currently resides at IS450 S. w. silt
Avenue, Miami, Florida 33157. Defendant's social security number is
3. Plaintiff has been a bona fide resident in the Commonwealth for at least six
months immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on January 3, 1998, in North Carolina.
The parties separated on January 20, 2001.
5. There have been no prior actions of Divorce or for annulment between the parties.
6. Plaintiff has been advised that counseling is available and that Plaintiff may have
the right to request that the court require the parties to participate in counseling.
7. The marriage is irretrievably broken.
Document #: 218282,1
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8. Plaintiff requests the court to enter a decree of divorce.
WHEREFORE, Plaintiff, Stephen C. Anderson, requests the Court to enter a Decree in
Divorce and such other orders as may be just and appropriate.
HAM, KNAUSS & ERE, P.C.
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By:
Steven C. Courtney, Esquire
Attomey J.D. No. 74669
3211 North Front Street
P.O. Box 5300
Harrisburg, P A 17110-0300
(717) 238-8187
Dated:
Attomey for Plaintiff
Document #: 218282.1
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VERIFICATION
1, Stephen C. Anderson, do hereby verifY that the facts set forth in the foregoing Complaint
are true and correct to the best of my personal knowledge or information and belief. I understand
that false statements herein are made subject to the penalties of 18 Pa.C.S. g4904, relating to
unsworn falsification to authorities.
Date: IO~/7 ~O I
2f)W
Stephen C. Anderson
Document #: 218282.1
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IN THE COURT OF COMMON PLEAS OF ClUMBERLAND COUNTY,
PENNSYLVANIA
STEPHEN C. ANDERSON,
Plaintiff
NO. 01-6087
vs.
CIVIL ACTION - LAW
SHANNON M. ANDERSON,
Defendant
PROOF OF SERVICE BY MAIL
I, Steven C. Courtney, Esquire, do hereby certifY that on December 6,2001, a copy of the
Court of Common Pleas Complaint filed in the above referenced matter was served upon the
following person( s) by certified mail, as is evidenced by the Certified Mail Return Receipt attached
hereto.
SHANNON M. ANDERSON
18450 S.W. 8i" Avenue
Miami, Florida 33157
METZGER, WICKERSHAM, KNAUSS & ERB, P.C.
Dated: January 14,2002
. 0 ey, Es uire
321 Front ee
P.O. Box 5300
Harrisburg, P A 171l 0
Telephone No. (717) 238-8187
J.D. No. 74669
Attomey for Plaintiff
BY:
Docunrent#:22477QJ
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. Complete nems 1, 2, and 3. Also complete
item 4 if Restricted Delivery is desired.
. Print your name and address on the reverse
so that we can return the earn to you.
. Attach this card to the back of the mailpiece,
or on the front jf space permits.
1. Article Addressed to:
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STEPHEN C. ANDERSON,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 01-6087
SHANNON M. ANDERSON,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in divorce under Section 3301(c) and (d) of the Divorce Code was filed
on October 24, 2001 and served upon Defendant on December 6, 2001.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have
elapsed from the date of fIling and service of the Complaint.
3. I consent to the entry of a final decree of divorce after service of notice of intention
to request entry 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. ~ 4904 relating to unsworn
falsification to authorities.
Date: kl(." 0 ~
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Document#:22927~J
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STEPHEN C. ANDERSON,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 01"6087
SHANNON M. ANDERSON,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE UNDER ~ 3301(c) OF THE DIVOR€ECODE
1. 1 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 ofthe decree will be sent to me immediately after it is filed with the Prothonotary.
1 verify that the statements made in this Affidavit are true and correct. I understand that
false statements herem are made subject to the penalties of 18 Pa.C.S. ~ 4904 relatiDg to unsworn
falsification to authorities.
Date:~
s~~~L
Document #: 229279.1
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STEPHEN C. ANDERSON,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYL VANIA
vs.
NO. 01-6087
SHANNON M. ANDERSON,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in divorce under Section 3301(c) and (d) of the Divorce Code was filed
on October 24, 2001 and served upon Defendant on December 6, 2001.
2. The marriage of plaintiff and defendant is irretrievably broken and niDety 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 herein are made subject to the penalties of 18 Pa.C.S. S 4904 relating to unswom
falsification to authorities.
Date: ~ ~ I b1-
k fVl1 ~
sh on M. Anderson
Document #: 229279.1
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STEPHEN C. ANDERSON,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 01"6087
SHANNON M. ANDERSON,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE UNDER ~ 3301(c) OF TIlE 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. S 4904 relating to unsworn
falsification to authorities.
Date:~
~~~
Shannon M. Anderson
Document #: 229279.1
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
STEPHEN C. ANDERSON,
Plaintiff
No. 01-6087 Civil Term
CIVIL ACTION - In Divorce
v.
SHANNON M. ANDERSON,
Defendant
PRAECIPE TO REINSTATE COMPLAINT
TO THE PROTHONOTARY:
Please reinstate the Complaint with regard to Shannon M. Anderson in the above
captioned matter.
Respectfully submitted,
Dated: November 28, 2001
Steven
METZ
3211 N. F 0 Street
P.O. Box 5300
Harrisburg, P A 17110
(7l7) 238"8l87
J.D. #74669
Attorney for Plaintiff
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Document #: 221544,1
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