HomeMy WebLinkAbout01-06280
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF
PENNA.
SHARON K. PELLMAN,
.
PLAINTIFF
NO. 01 - 6280
Ve:RSUS
CIVIL ACTION - LAW
SCOTT C. PELLMAN,
iN DIVORCE
.
DEFENDANT
DECREE IN
DIVORCE
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AND NOW,
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DECREED THAT
SHARON K. PELLMAN
, PLAINTIFF,
AND
SCOTT C. PELLMAN
, DEFENDANT,
ARE DiVORCED FROM THE BONDS OF MATRIMONY,
l'HE 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 SEPARATION AND PROPERTY SETTLEMENT AGREEMENT DATED SEPTEMBER 'R :
2002 AND ORDER OF COURT AWARDING ALIMONY SIGNED HEREWITH SHALL BE
INCORPORATED BUT NOT MERGED IN THIS DECREE IN DIVORCE.
By THE
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Andrew C. Sheely, Esquire
127 S. Market street
P.O. l30x 95
Mechanicsburg, PA 17055
FA ID NO. 62469
717-697-7050 (Phone)
717-697-7065 (Fax)
SHARON K. PELLMAN,
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
SCOTT C. PELLMAN,
Defendant
01-6280 CIVIL TERM
IN DIVORCE
ORDER OF COURT
IN RE: ALIMONY
AND NOW, this 2..,~4. day of ~
r 2002, is hereby
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Ordered and Decreed that Defendant, Scott C. Pellman, shall pay ~.
Plaintiff, Sharon K. Pellman, alimony in the amount of $100.00 per
month in accordance with paragraph 12 of the attached Separation
and Property Settlement Agreement which shall be incorporated but
not merged in the Divorce Decree.
By the Court,
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Andrew C. Sheely, Esquire - ~ ~. ~ tJ /':";(0;)
Attorney for Sharon K. pellman, PL~intiff
R. Mark Thomas, Esquire - e~ ",~:fl.utl q!;;Js/t:>)
Attorney for Scott C. Pellm~n;-Defendant
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02 SEP 25 AN
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SEPARATION AND PROPERTY SETTLEMENT AGREEMENT
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THIS AGREEMENT, made this 0 day of September, 2002,
by and between SCOTT C. PELLMAN, hereinafter referred to as
"HUSElAND", and SHARON K. PELLMAN, party of the second part,
hereinafter referred to as "WIFE".
WITNESSETH:
WHEREAS, the parties hereto are husband and wife, having
been married on June 11, 1983, in Mechanicsburg, Pennsylvania, and
having separated on or about November 1, 2001; and
WHEREAS, there are two minor children to this marriage,
namely Jenna R. Pellman (11/21/85) and Tyler W. Pellman
(04/21/88); and
WHEREAS, certain differences have arisen by and between
HUSBAND and WIFE as a result of which they are currently separated
and the parties hereto are desirous of settling fully and finally
their respective financial and property rights and obligations as
between each other including, without limitation by specification:
the settling of all matters between them relating to the ownership
and equitable distribution of real and personal property; the
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; and
WHEREAS, the parties being fully advised as to their
respective rights, duties and obligations growing out of their
marital status, particularly with respect to the relevant sections
of the Divorce Code, Act of April 2, 1980, P.L. 63, Act No. 26, as
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amended, 23 P.S. 3101 et seq., and being fully aware of their
right to consult with or having consulted with their respective
legal counselor advisors and having had the opportunity and
ability to request a full and complete disclosure of income and
assets from the other, and reviewing this Agreement, have come to
an agreement as to each and all of their said matters of property
and relations; and
NOW, THEREFORE, in consideration of the above recitals
and the mutual covenants hereinafter set forth, each of the
parties hereto intending to be legally bound hereby by affixing
their hands and seals agree as follows:
1. ADVICE OF COUNSEL
Husband and Wife acknowledge that they have been given
the opportunity to obtain the advice of counsel regarding the
provisions of this Agreement and their legal effect in advance of
the date set forth above to permit such independent review.
Husband and Wife acknowledge that Andrew C. Sheely" Esquire, is
counsel for Wife and that Husband is represented by R. Mark
Thomas, Esquire. Each party acknowledges that he or she has had
the opportunity to receive independent legal advice from counsel
from his or her selection, and that each fully understands the
facts and has been fully informed as to his or her legal rights
and obligations, and each party acknowledges and accepts that this
Agreement is, and the circumstances, fair and equitable, after
having the opportunity to receive such advice and with such
knowledge, and that execution of this Agreement is not the result
of any improper or illegal agreement or agreements. In addition,
each party hereto acknowledges that he or she has had the
opportunity to be fully advised by his or her respective attorney
of the impact of the Pennsylvania Divorce Code, whereby the court
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has the right and duty to determine all marital rights of the
parties including divorce, alimony, alimony pendente lite,
equitable distribution of all marital property or property owned
or possessed individually by the other, counsel fees and costs of
litigation and, fully knowing the same and having the opportunity
to be fully advised of his or her rights thereunder, each party
hereto still desires to execute this Agreement, acknowledging that
the terms and conditions set forth therein are fair, just and
equitable to each of the parties, and waives his and her
respective right to have the Court of Common Pleas of Cumberland
County, or any other court of competent jurisdiction, make any
determination or order effecting the respective parties rights to
a divorce, alimony, alimony pendente lite, equitable distribution
of all marital property, counsel fees and costs of litigation.
2. SEPARATION
It shall be lawful for each party at all times hereafter
to live separate and apart from each other in such place or places
as he or she may from time to time choose or deem fit.
3. INTERFERENCE
Each party shall be free from interference, authority
and control, direct or indirect, by the other as fully as if he or
she were single and unmarried. Neither shall molest the other or
compel or endeavor to compel the other to cohabitate or dwell with
him or her, or to in any way harass or malign the other.
4. WAIVER OF CLAIMS AGAINST ESTATES
Except as otherwise provided herein, Husband
relinquishes his inchoate intestate right and his right to act as
a personal representative in the estate of Wife, and Wife
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relinquishes her inchoate intestate right and her right to act as
a personal representative in the estate of Husband. Each of the
parties hereto by their presents, for himself or herself, his or
her heirs, executors, administrators or assigns, does remise,
release, quit claim and forever discharge the other party hereto,
his or her heirs, executors, administrators or assigns or any of
them, of any and all claims, demands, damages, actions, causes of
actions, suits, at law or equity, of whatsoever kind or nature,
for or because of any matter or thing omitted or suffered to be
done by said other party prior to and including the date hereof,
except that this release shall in no way exonerate or discharge
either party hereto from the obligations and promises made and
imposed by reason of this Agreement and shall in no way affect any
cause of action in absolute divorce which either party may have
against each other.
5. MARITAL AND NON-MARITAL PROPERTY
The parties hereto acknowledge that during their
marriage they have acquired, individually or jointly, various
marital assets and the increased value of non-marital assets and
property, including the following:
(A) Jointly owned Real Estate located at 46 Mayberry
Lane, Mechanicsburg, Silver Spring Township, Cumberland
County, Pennsylvania, with an estimated value of $229,000.00;
and
(B) Husband's Mechanicsburg Borough Police Pension with
a current estimated monthly benefit of $1,700.00 as evidenced
by a valuation as of January 1, 2001; and
(C) 1981 DeLorean with an estimated value of $13,000.00;
and
(D) 1994 Ford Aerostar titled in wife's name with an
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estimated value of 4,000.00; and
(E) 1998 Grand Am titled jointly with an estimated value
of $9,000.00; and
(F) Miscellaneous Bank Accounts not exceeding $5,000.00;
and
(G) Miscellaneous personal property, including
furniture, personal items, dishes, tools, jewelry, increase
in value of non-marital property, equipment, coins and cash.
Husband and Wife acknowledge that they are aware of their
respective rights pursuant to the Divorce Code of 1980, as
amended, to obtain formal valuations or appraisals of the marital
residence, any and all retirement assets, and other items of
marital property. However, the parties agree that they will not
undertake this expense and acknowledge that no financial
disclosures are attached to this agreement as separate exhibits or
schedules. The parties hereby waive any necessity for completing
or attaching any financial disclosure(s). Each party further
acknowledges the opportunity to attach a full and complete
financial disclosure and that such disclosure is not desired to
effectuate a fair and equitable resolution of their marital
rights, duties and obligations as provided in the Divorce Code of
1980, as amended.
6 . PERSONAL PROPERTY
Husband and Wife hereto mutually agree that they have
effected a satisfactory division of the furniture, household
furnishings, appliances and other household personal property
between them, and they mutually agree that each party shall from
and after the date hereof be the sole and separate owner of all
such tangible personal property presently in his or her
possession, whether said property is heretofore owned jointly or
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individually by the parties hereto, and this Agreement shall have
the effect of an assignment or bill of sale from each party to the
other for such property as may be in the individual possessions of
each of the parties hereto.
Husband and Wife agree that they have divided between
themselves, to their mutual satisfaction, all items of tangible
and intangible marital property. Neither party shall make any
claim to any such items of marital property, or of the separate
personal property of either party, which are now in the possession
and/or under the control of the other.
From and after the date of the signing of this Agreement
both parties shall have complete freedom of disposition as to
their separate property which is in their possession or control
pursuant to this Agreement and may mortgage, sell, grant, convey
or otherwise encumber or dispose of such property, whether real or
personal, whether such property was acquired before, during or
after marriage, and neither Husband nor Wife need join in, consent
to, or acknowledge any deed, mortgage, or other instrument of the
other pertaining to such disposition of property.
7. REAL ESTATE 46 Mayberry Lane. Mechanicsburg,Pennsylvania
(i) Transfer Husband agrees to transfer by deed, any and
all legal or equitable right, title and interest in and to the
parcel of jointly-owned real estate with improvements thereon
situate at 46 Mayberry Lane, Mechanicsburg, Pennsylvania, (Deed
Book 192, page 543) to Wife, and to sign all documents necessary
to effect said transfer of any equitable or legal interest in such
property to Wife on or before the signing of this Agreement.
Further, upon execution of this Agreement, Husband waives any and
all interest in the marital real estate located at 46 Mayberry
Lane, Mechanicsburg, Pennsylvania. Wife shall hold Husband
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harmless from any current mortgage or other lien encumbering the
title to the property.
(ii) Capital Gains Tax Husband and Wife further agree
that Wife shall assume any and all liability for any capital gains
taxes which may be assessed hereafter as the result of a sale of
46 Mayberry Lane, Mechanicsburg, pennsylvania, by qualifying for
an exemption or by paying any taxes due, if applicable.
8. HUSBAND'S POLICE PENSION
Wife hereby agrees to waive her right to make a claim upon
the Husband for any marital or non-marital interest in said plan
through the his employment with the Borough of Mechanicsburg. wife
agrees to sign any and all documents within thirty (30) days after
the execution of this Agreement so as to waive interest in the
police pension and other retirement benefits, if necessary or as
required by the Plan Administrator. Husband and wife hereby
acknowledge that Husband may remove Wife as beneficiary under any
plan.
9. DEBTS OF HUSBAND AND WIFE
Husband and Wife acknowledge that they have incurred
various marital, (joint and separate) debts prior to separation.
Husband and Wife agree that Husband shall assume full liability
and hold Wife harmless from any liability for any and all consumer
or other debt in Husband's name. Husband and Wife agree that
Wife shall assume full liability and hold Husband harmless from
any liability for any and all consumer or other debt in wife's
name.
10. MOTOR VEHICLES
a. Possession Husband and Wife agree that Wife shall be
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entitled to have the sole and exclusive control, benefit, use and
title of the 1994 Ford Aerostar or the proceeds thereof. Husband
and Wife agree that Husband shall be entitled to have the sole and
exclusive control, benefit, use and title of the 1981 DeLorean and
the 1998 pontiac Grand Am or the proceeds thereof, and that he
shall hold wife harmless from any liability associated with such
motor vehicles. Titles to the motor vehicles shall be transferred
within thirty (30) days from the date of this Agreement to the
party receiving title in accordance with this Agreement, if
necessary.
11. MISCELLANEOUS
(A) Checking/Savings Accounts. The parties hereto
acknowledge and agree that any and all savings and checking
accounts, as well as certificates of deposit, owned by them
jointly or singly, have been divided to their mutual and
individual satisfaction.
(B) The parties hereto acknowledge and agree that any
and all life insurance policies owned by them jointly or singly
have been divided to their mutual and individual satisfaction.
Specifically, Husband and Wife agree that Husband shall maintain
Wife as the beneficiary of his current life insurance policy
through the Mechanicsburg Police Department through December 31,
2007, or until Husband retires, whichever shall occur first. In
the event of Husband's retirement prior to December 31, 2007,
Husband shall obtain another life insurance policy with at least
the same amount of benefits which are offered through the Borough
of Mechanicsburg, and continue to name Wife as beneficiary of such
policy. Husband shall provide evidence of the existence of such
beneficiary status to Wife at Wife's reasonable request.
(C) The division of existing marital property is not,
except as otherwise expressly provided herein, intended by the
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parties to constitute in any way, a sale or exchange of assets and
the division is being affected without the introduction of outside
funds or other property not constituting a part of the marital
estate. As a part of an equitable division of the marital
properties and the marital settlement herein contained, the
parties hereto agree to save and hold each other harmless from all
income taxes assessed against the other resulting from the
division of the property as herein provided.
(D) Each party represents and warrants to the other that
he or she has not incurred any debt, obligation or other
liability, other than those described in this Agreement, on which
the other party is or may be liable. A liability not disclosed in
this Agreement will be the sole responsibility of the party who
has incurred or may hereafter incur it, and such party agrees to
pay it as the same shall become due, and to indemnify and hold the
other party and his or her property harmless from any and all such
debts, obligations and liabilities.
(E) Each party represents and warrants to the other that
they shall file separate income tax returns for tax year 2002 and
thereafter. Information maintained by one party which is
necessary to complete any income tax return shall not be
unreasonably withheld upon the request of either party. Any and
all tax refunds payable to Husband and Wife shall be equally
distributed to Husband and wife as part of the equitable
distribution of marital assets.
12. ALIMONY, SUPPORT AND MAINTENANCE
Husband agrees to and shall pay Wife, as alimony, the
sum of one hundred dollars ($100.00) per monthr beginning on
October 1, 2002, and payable on the first day of each month
thereafter. The alimony amount of $100.00 per month shall be non-
modifiable through October 1, 2008. Thereafter, Husband may
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petition for a decrease in the amount of alimony for any reason.
Further, Wife shall not seek nor be entitled to an increase in the
payment of alimony for any reason.
In the event Husband unreasonably fails to make an
alimony payment on or before the fifteenth (15th) day of each
month, wife may file an action in the Court of Common Pleas of
Cumberland County seeking to enforce the provisions of this
Agreement or file an action for contempt of court, whichever
option wife shall agree to pursue. In such event, Husband agrees
to pay for any and all reasonable attorney fees incurred by Wife
in seeking to enforce the terms of this paragraph. Wife shall
deposit all checks paid by Husband as Alimony within seven (7)
days from receipt of such amount.
Alimony awarded pursuant to this paragraph shall cease
upon either Husband or Wife's death, Wife's remarriage or wife's
cohabitation. The alimony payments awarded pursuant to this
paragraph are intended to be and shall be taxable to Wife's income
at the amount of $100.00 per month commencing as of October 1,
2002, and deducted from Husband's income at the amount of $100.00
per month commencing as of February 1, 2002, in accordance with
all tax laws and applicable sections of the Internal Revenue
Service Rules and Regulations. The parties agree to reduce this
Agreement to an Order of Court simultaneously upon execution of
this Agreement and file such with the Court of Common Pleas along
with the documents necessary to conclude the divorce.
14. SUPPORT FOR CHILD
The parties hereto acknowledge that Wife's current net
monthly income is approximately $1,200.00 per month (excluding the
payment of alimony) and that Husband's current monthly income as a
Sergeant in the Mechanicsburg Police Department is approximately
$3,600.00 per month (excluding the payment of alimony and child
support). The parties combined net monthly incomes total
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approximately $4,800.00.
Based upon a combined monthly income of $4,800.00,
support obligation of both parties equals approximately $1,295.00
per month. Husband's percentage of the combined monthly income
equals approximately seventy-five percent (75%) and Wife's per-
centage of the combined monthly income equals approximately
twenty-five percent (25%).
Husband's basic child support obligation, based upon the
parties current incomes and number of children, equals
approximately $972.00 per month. However, Husband and Wife
acknowledge that Wife will forego the additional support at this
time and that Husband will pay an amount of $800.00 per month for
support of the two children at the present time.
In the event Husband unreasonably fails to make a child
support payment in accordance with this Agreement on or before the
fifteenth (15th) day of each month, this Agreement shall be
submitted to the Domestic Relations Office of Cumberland county or
any other county with appropriate jurisdiction for enforcement
purposes. In such event, each party agrees to execute any
documents as are required by the Domestic Relations Office to
effectuate the terms of this Agreement. Wife shall deposit all
checks paid by Husband as child support within seven (7) days from
receipt of such amount.
The parties hereto acknowledge that all issues
concerning the support of the minor child are presently resolved
without the necessity of attending a formal child support
conference. Notwithstanding the present circumstances, Husband
and Wife understand and acknowledge that circumstances may
necessitate an adjustment in the amount of support either upwards
or downwards, depending upon the child's circumstances and the
respective incomes or earning capacities of the parties hereto in
accordance with general support standards. In the event Husband
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and wife cannot agree upon the amount of child support at any time
hereafter, Husband and Wife agree that nothing set forth in this
paragraph or this Marital Property and Settlement Agreement shall
prejudice the right of either party to file a petition for
modification or entry of an amount of child support, at any time,
in any Court of appropriate jurisdiction. It is the specific
intent of the parties that this Agreement is designed to avoid the
present filing of formal child support proceedings only, and any
future award of child support will be governed by the applicable
support guidelines and case law.
15. CUSTODY
Husband and Wife agree and acknowledge as follows:
(A) Mother and Father shall have shared legal custody of the
children, meaning that both parents shall make joint decisions
concerning the childrens' education, serious medical decisions
affecting the child and religious instruction; and
(B) Mother shall have primary physical custody of the
children; and
(C) Mother and Father agree that Father shall have
periods of partial physical as the parties may agree.
(D) Father/Husband acknowledges that he carries a firearm as
a result of his current employment with the Mechanicsburg Police
Department, and Father/Husband further agrees to maintain such
firearm either in a secured position on his person or in an
appropriately secured safe or case during any period of physical
custody with the minor children.
16. SUBSEOUENT DIVORCE
A decree in divorce entered by a court of competent
jurisdiction to either party shall not suspend, supersede or
affect the terms of this Agreement. Both parties agree, if
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requested, to enter a Consent Order or Orders concerning the
provisions of this Agreement in the Court of Common pleas of
Cumberland County, Pennsylvania, or any other Court of competent
jurisdiction, as a part of a resolution of any divorce action
filed or to be filed. This Agreement, and the terms and
conditions contained herein, as well as the enforcement of said
terms and conditions, shall not be and is/are not contingent upon
the granting of a Divorce Decree to either party by the Court of
Common Pleas of Cumberland County, Pennsylvania, or any other
Court of competent jurisdiction. Furthermore, both parties hereto
agree, if requested, to execute the appropriate affidavits and
consents to secure a No-fault Divorce as may be required by the
Divorce Code, as amended, to terminate their marriage by mutual
consent without counselling.
17. 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. Husband
and wife acknowledge and agree that the provisions of this
Agreement with respect to the distribution and division of marital
and separate property are fair, equitable and satisfactory to them
based on the length of their marriage and other relevant factors
which have been taken into consideration by the parties. Both
parties hereby accept the provisions of this Agreement with
respect to the division of property in lieu of and in full and
final settlement and satisfaction of all claims and demands that
they may now have or hereafter have against the other for
equitable distribution of their property by any court of competent
jurisdiction pursuant to Section 3502 of the Divorce Code or any
amendments thereto. Husband and wife each voluntarily and
intelligently waive and relinquish any right to seek a court
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ordered determination and distribution of marital property, but
nothing herein contained shall constitute a waiver by either party
of any rights to seek the relief of any court for the purpose of
enforcing the provisions of this Agreement.
18. VOLUNTARY EXECUTION
The provisions of this Agreement and their legal effect
have been fully explained to the parties by their respective
counsel, and each party acknowledges that the Agreement is fair
and equitable, that it is being entered into voluntarily, with
full knowledge of the assets of both parties, and that it is not
the result of any duress or undue influence. The parties
acknowledge that they have been furnished with all information
relating to the financial affairs of the other which has been
requested by each of them or by their respective counsel.
19. ADDITIONAL INSTRUMENTS
Husband and Wife shall from time to time at the request
of the other, execute, acknowledge and deliver to the other party
any and all further instruments that may be reasonably required to
give full force and effect to the conditions of this Agreement.
20. MODIFICATION AND WAIVER
Any modification or waiver of any of the provisions of
this Agreement shall be effective only if made in writing and
executed with the same formality as this Agreement. The failure
of either party to insist upon strict performance of any of the
provisions of this Agreement shall not be construed as a waiver of
any subsequent default of the same or similar nature. The waiver
of any term, condition, clause or provision of this Agreement
shall in no way be deemed or construed as a waiver of any other
term, condition, clause or provision of this Agreement.
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21 . BREACH
If either party hereto breaches any provision of this
Agreement, the other party shall have the right, at his or her
election, to sue for such breach, or seek other remedies or relief
as may be available to him or her. Both parties agree and are
aware that noncompliance with any provision of this Agreement
permits either party to pursue appropriate legal remedies,
including sanctions as set forth in 23 Fa. C.S.A. S3105.
Each party further hereby agrees to save and hold
harmless the other party from any and all attorneys' fees, costs
and legal expenses and expenses that either may sustain, or incur
or become liable or answerable for, in any way whatsoever, or
shall pay upon, or in consequence of, any default or breach by the
other of any of the terms or provisions of this Agreement by
reason of which either party shall or shall be obliged to retain
or engage counsel to initiate or maintain or defend proceedings
against the other at law or equity or both or in any way
whatsoever, provided that the party who seeks to recover such
attorneys' fees, costs and legal expenses and expenses must first
be successful in whole or in part, before there would be any
liability for attorneys' fees, costs, legal expenses and expenses.
It is the specific agreement and intent of the parties that a
breaching or wrongdoing party shall bear the burden and obligation
of any and all costs and expenses and counsel fees incurred by the
other party in endeavoring to protect and enforce his or her
rights under this Agreement.
All remedies provided by law and all remedies provided
for in this Agreement for enforcement of the Agreement shall be
deemed to be cumulative and the exercise of one remedy shall not
bar or prevent the pursuit of any other remedy and either party
may elect to pursue such remedies simultaneously and the exercise
15
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of a remedy one or more times shall not exhaust its use or prevent
further pursuit of such remedy.
22. ATTORNEY FEES AND COSTS
Husband and wife shall each assume their respective
counsel fees as part of the divorce action commenced in the case.
23. DESCRIPTIVE HEADINGS
The descriptive headings used herein are for convenience
only. They shall not have any effect whatsoever in determining
the rights or obligations of the parties.
24. INDEPENDENT SEPARATE COVENANTS
It is specifically understood and agreed by and between
the parties hereto that each paragraph hereof shall be deemed to
be a separate and independent covenant and agreement.
25. APPLICABLE LAW
This Agreement shall be construed under the laws of the
Commonwealth of pennsylvania. For contract interpretation
parties, this Agreement was prepared jointly by both parties.
26. VOID CLAUSES
If any term, conditions, 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.
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27. BINDING AGREEMENT
This Agreement shall be binding and shall extend to the
benefit of the parties hereto and their respective heirs,
executors, administrators, successors and assigns.
IN WITNESS WHEREOF, the parties have hereunto set their
hands and seals the day and year first above written.
WITNESS:
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(SEAL)
SEAL)
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COMMONWEALTH OF PENNSYLVANIA
SS.
COUNTY OF CUMBERLAND
On this, the /t-rl-... day o~ , 2002, before
me, the undersigned officer, personally appeared Scott C. Pellman,
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.
seal.
IN WITNESS WHEREOF, I hereunto set my hand and official
Notarial Seal
Anne Carmody, Notary Public
Mechanicsburg Bore, Cumberland County
My Commission Expires Expires Mar. 11, 2006
~fru
Notary PUbl~
My Commission Expires~~/~
COMMONWEALTH OF PENNSYLVANIA
:SS.
COUNTY OF CUMBERLAND
On this, the / gf-II day of 5~{) t(!N'6~ , 2002,
before me, the undersigned officer, personally appeared Sharon K.
Pellman, 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 hereunto set my hand and official
seal.
,stt~~
Notary Publlc
My Commission Expires:
NOTARIAL SEAL
kATHt.EEN A. SHIELl, tlotory Public
Me.1IOniaburt Ioto, Cumberloll4l eounty
My CommIooion Expl... Au9fAl25, 2003
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SHARON K. PELLMAN,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
SCOTT C. PELLMAN,
Defendant
01-6280 CIVIL TERM
IN DIVORCE
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. Grounds for Divorce: Irretrievable breakdown under
Section 3301 (C) of the pennsylvania Divorce Code.
2. Date and Manner of service of the complaint:
certified mail, restricted delivery, on NOVEMBER 6, 2001.
3. Complete either paragraph (a) or (b).
(a) Date of execution of affidavit of consent required by
section 3301 (C) of the Pennsylvania Divorce Code: by Plaintiff on
September 18, 2002 and by Defendant on September 18, 2002.
(b) (1) Date of execution of the affidavit required by
Section 3301 (d) of ,the Divorce Code: Not applicable: (2) Date of
filing and service of the plaintiff's affidavit upon the
respondent: Not ap~licable.
4. Related claims pending: The Separation and Property
Settlement Agreement dated September 18, 2002 and Order of Court
awarding Alimony are incorporated but not merged in the Decree in
Divorce.
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:
Not applicable
(b) Date Plaintiff's Waiver of Notice in Section 3301 (C)
was filed with the Prothonotary. September 19, 2002.
Divorce was filed with the
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Andrew C. 6heely, Esquire
127 s. Mar~et street
P.O. Box 9S
Mechanicsburg, FA 17055
FA ID NO. 62469
717-697-7050 (Phone)
717-697-7065 (Fax)
SHARON K. PELLMAN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
vs,
SCOTT C. PELLMAN,
Defendant
01-6280 CIVIL TERM
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the
Divorce Code was filed on NOVEMBER 2, 2001. I acknowledge that I
received a copy of the divorce complaint on NOVEMBER 6, 2001.
2. The marriage of Plaintiff and Defendant is irretrievably
broken and ninety (90) days have elapsed from the date of filing
the Complaint.
3. I consent to the entry of a final decree of divorce after
service of notice of intention to request entry of the decree.
I verify that the statements made in this Affidavit are true
and correct. I understand that false statements herein are made
subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to
unsworn falsification to the authorities.
DATE:
9/;~~:J-
ldr C {)jl
Scott C. Pellman
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Andrew C. Sheely, Esquire
127 S. Ma~ket sereet
P.O. Box 95
Mechanicsburg, ~A 17055
PA ID NO. 62469
717-697-7050 (Poone)
717-697-7065 (FAX)
SHARON K. PELLMAN,
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
01 - & J. ~b CIVIL TERM
SCOTT C. PELLMAN,
Defendant
IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in Court. If you wish to defend against
the claims set forth in the following pages, you must take prompt
action. YOU are warned that if you fail to do so, the case may
proceed against you and a decree in 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 with your
children.
When the grounds for the divorce is indignities or
irretrievable breakdown of the marriage, you may request marriage
counseling. A list of marriage counselors is available in the
Office of the prothonotary at the Cumberland County Courthouse,
Carlisle, 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 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 BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PENNSYLVANIA 17013
(717) 249-3166
BY
ndrew C. Sheely, ire
PA. I.D. No. 6246
127 S. Market Street
P.O. Box 95
Mechanicsburg, PA 17055
717 697-7050
Attorney for plaintiff
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Andrew c. sheely, Esqui~e
127. S. Market Street
P.O. Box 95
Mechanicsburg, PA 17055
PA ID NO. 62469
717-697-7050 (Phone)
717-697-7065 (FaX)
SHARON K. PELLMAN,
plaintiff
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
SCOTT C. PELLMAN,
Defendant
: 01 - to '(1 g-O CIVIL TERM
IN DIVORCE
COMPLAINT
1. Plaintiff is SHARON K. PELLMAN, an adult individual who
currently resides at 46 Mayberry Lane, Mechanicsburg, Cumberland
County, Pennsylvania.
2. Defendant is SCOTT C. PELLMAN, an adult individual who
resides at 46 Mayberry Lane, Mechanicsburg, Cumberland County,
Pennsylvania.
3. Plaintiff and Defendant have been bona fida residents of
the Commonwealth of Pennsylvania for at least six (6) months
immediately previous to the filing of this Complaint.
4. Plaintiff and Defendant were married on June 11, 1983 in
Mechanicsburg, Pennsylvania.
5. There have been no prior actions of divorce or annulment
between the parties.
6. Neither party is a member of the armed forces of the
United States of America.
7. Plaintiff has been advised of the availability of
marriage counseling and understands that she may have the right to
request that the court require the parties hereto to participate
in counseling.
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8. The marriage between the parties is irretrievably broken.
9. This action is not collusive.
WHEREFORE, Plaintiff requests your Honorable Court to enter a
decree in divorce divorcing Plaintiff and Defendant absolutely.
Date: November I , 2001
e tfu It.
drew C. Sheely, Esqu
Attorney for Plaintiff
PA ID No. 62469
P.O. Box 95
127 S. Market Street
Mechanicsburg, PA 17055
697-7050
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VERIFICATION
I verify that the statements made in this Complaint are true
and correct. I understand that false statements herein are made
subject to penalties of 18 Pa.C.S.A. Section 4904, relating to
unsworn falsification to authorities.
Date: November ( , 2001
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sfIARON K. PELLMAN '
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Andrew C. Sheely, Esquire
127 s. Market street
P.O. Box 95
Mechanicsburg, PA 17055
PA ID NO. 62469
717-697-7050 (Phone)
717-697-7065 (Fax)
SHARON K. PELLMAN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
SCOTT C. PELLMAN,
Defendant
01 - GJ'86
: IN DIVORCE
CIVIL TERM
AFFIDAVIT
Sharon K. Pellman, being duly sworn according to law,
deposes and says:
(1) I have been advised of the availability of marriage
counseling and understand that I may request that the Court
require that my spouse and I participate in counseling.
(2) I understand that the Court maintains a list of
marriage counselors in the Domestic Relations Office, which list
is available to me upon request.
(3) Being so advised, I do not request that the Court
require that my spouse and I participate in counseling prior to a
Divorce Decree being handed down by the Court.
I understand that false statements herein are made
subject to the penalties of 18 pa.C.S.A. Section 4904 relating to
unsworn falsification to
authorities. ~,v
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Sffaron K. Pellman
. NOTMAl SEAL
ANN W. MARTJN. Notary Public
MeclllmicsbulIlBolO, CUmbet1ana Caun~
. My ClImmlsslon filS Sept. 29, @Il3
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127 S. Market Street
,'f,.o. Box 95
Mechanicsburq, PA 17055
PA'IO NO. 62469
717-697-7050 (Phone)
717-697-7065 (Fax)
SHARON K. PELLMAN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
SCOTT C. PELLMAN,
Defendant
01-6280 CIVIL TERM
IN DIVORCE
AFFIDAVI~ OF SERVING COMPLAIN~
COMMONWEALTH OF PENNSYLVANIA
SS
COUNTY OF CUMBERLAND
ANDREW C. SHEELY, being duly sworn according to law, deposes
and says that he caused a true and correct copy of the Divorce
Complaint in the above-captioned matter to be served upon SCOTT C.
PELLMAN, by Certified Mail, Restricted Delivery, Return Receipt
Requested, as indicated by the attached receipt cards, on November
6, 2001.
~HE~' ~
SWORN to and subscribed before me
this 9fh day of November, 2001.
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Notary Public
My Commission Expires~ber ;?9,JiJ/J3
NOTARIAL SEAL
ANN W. MARTiN, Notary Public
hanlcsllurg BolO, 0urnIJerIand
My CommIssTon ExpIIllS Sept. 29. m
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MECHANICSBURG, Penll.yl van!.
170553459
11/05/2001 (717)697-4641 10:36:18 AM
Sale. Receipt
Product Sale Unit
Description Qty Price
MECHANICSBURG PA 17050
First-Class
Restrl cted De liver)'
Return Receipt
Certified
Label Serial #:
Final
PI'ice
$0.57
$3.20
$1.50
$2,10
70011940000425998467
Issue PVI:
$7.37
Total:
Paid by:
Check
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$7.37
$7.37
Bi 11#:
Clerk:
1000500442453
04
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Postage $
Certified Fee
Return Receipt Fee
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(Endorsement Required)
Total Postage & Fees
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item 4 if Restricted ,Delivery 'is desired.
. Print your name and addrt;lss on the reverse
so that we can refurn the card to you.
. Attach this card to the backo! the mailpiece.
or on the front jf ~pace perniits.
1. Article Addressed to:
scott c PeUrYloI,
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D. Is delivery address different from item 11
If YES, enter delivery address below:
3., Service Type
k( Certified Mail 0 Express Mail
o Registered 0 Return Receipt for Merchandise
o Insured Mail 0 C.O.D.
4. Restricted Delivery? (Extra Fee) )i!t Yes
2. Article Number (Copy fr9m serv,iqe laQ~/) , , ' "
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102595-00-M-0952
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127 s. Market Street
P.O. Box 95
Mechanicsburg, PA 17055
PA ID NO. 62469
717-697-7050 (Phone)
717-697-7065 (Fax)
SHARON K. PELLMAN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
SCOTT C. PELLMAN,
Defendant
01-6280 CIVIL TERM
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the
Divorce Code was filed on NOVEMBER 2, 2001.
2. The marriage of Plaintiff and Defendant is irretrievably
broken and ninety (90) days have elapsed from the date of filing
and service the Complaint.
3. I consent to the entry of a final decree of divorce after
service of notice of intention to request entry of the decree.
I verify that the statements made in this Affidavit are true
and correct. I understand that false statements herein are made
subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to
unsworn falsification to the authorities.
DATE: 1/11/02--
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Sharon K. Pellman
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127 S. Ma~ket Street
P.O. Box 95
Mechaniospurgf PA 17055
PA ID NO. 62469
717-697-7050 (Phone)
717-697-7065 (Fax)
SHARON K. PELLMAN,
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
SCOTT C. PELLMAN,
Defendant
01-6280 CIVIL TERM
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
S3301 (C) OF THE DIVORCE CODE
1. I consent to the entry of a final decree of divorce
without notice.
2. I understand that I may lose rights concerning
alimony, division of property, lawyer's fees or expenses if I do
not claim them before a divorce decree 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.A. Section 4904
relating to unsworn falsification to the authorities.
DATE:
r; /!f/62-
h-:)(~ -
stiaron K. Pellman
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127 s. Market street
P.O. Box 95
Mechanicsburg, PA 17055
PA ID NO. 62469
717-697-7050 (Phone)
717-697-7065 (Fax)
SHARON K. PELLMAN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
CIVIL ACTION - LAW
SCOTT C. PELLMAN,
Defendant
01-6280 CIVIL TERM
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
S3301 (C) OF THE DIVORCE CODE
1. I consent to the entry of a final decree of divorce
without notice.
2. I understand that I may lose rights concerning
alimony, division of property, lawyer's fees or expenses if I do
not claim them before a divorce decree 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.A. Section 4904
relating to unsworn falsification
DATE:
9;J~~
to 7ith~e{?u
~cott C. Pellman
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