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Home My WebLink About01-06479 ,. ~ I ,.,1 ,-",'"" -""-',k. ; -')"--'~ .",' ;.i.Io-~--~'i' .. , . . . . . .. .. . . . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY . . . . PENNA. . . . STATE OF . . . . . MICHAEL J. SHEEDY, Plaintiff No. 2001-6479 CIVIL VERSUS TINA MARIE ROSS SHEEDY, Defendant .. DECREE IN DIVORCE AND NOW, ~,) ~ II:P AA . /06" IT IS ORDERED AND DECREED THAT MICHAEL J. SHEEDY , PLAINTIFF, .. TINA MARIE ROSS SHEEDY AND , 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 BEE:N ENTERED; .. . .. THE PARTIES MARITAL SETTLEMENT AGREEMENT DATED DECEMBER 18, 2001 .. . IS INCORPORATED BUT NOT MERGED HEREIN. ATTEST: ~ J. . . . PROTHONOTARY . . . . . . .. .. . . . . .. . . .. .. . . . . . .. . . . . . .. . . .. .. .. . . . . .. .. . . . . .. .. .. .. .. .. . .. .. . . . . . . . . .. .. .. .. . . .. . ," - ~ ,-~~ ~ ,'--,~ ---'~-"~' -, "~~,,,,^"" - I i ~ 11 I ~\ Ii II ~:'M_ - ."~" -. ~ 1/..;J..3 ~ol 'I'd] -Ool '~-~J"-_'" v~-,"' , --,,,.,.,,",,,-,,~,.- -- .-- -~."~-~~~.., =-~ w--~~~4~ ~ ItU~4,,; ~ q~.../ ~ ~ ^' e,.. p.."."" . '_" '''''';'''''" ~"_,;mc~_",_~ 'I 'r.!,7'1"~J!Il!!!l!t!!!,",. ,~~,~~W1W!~I_'liP~~~~e!'~'?f~-'E~_\W'!11~~~~~~~'~'f ~ '-/.-- . - ,~",' .,' - ~~ :-;--~---..,,-,-, ----"-----";"...;-~^.- - -- w~" -~ , . , " MARITAL SETTLEMENT AGREEMENT TIllS AGREEMENT, made this /8 day of ~, 2001, by and between MICHAEL JOHN SHEEDY (hereinafter "Husband") of 21 Carter Place, Carlisle, Cumberland County, Pennsylvania and TINA MARIE ROSS SHEEDY (hereinafter "Wife") of 38 Woodcrest Drive, Carlisle, Cumberland County, Pennsylvania, WTINESSETII: WHEREAS, the parties are Husband and Wife, married on June 5, 1993, in Carlisle, Cumberland County, Pennsylvania; and WHEREAS, no children were born of the marriage; 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, respectively in a divorce action filed in the Court of Common Pleas of Cumberland County, Pennsylvania, to No. 2001-6479; 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 ilie ownership and equitable distribution of real and personal property; past, present and future support, alimony and/or maintenance; and any and all claims which eiilier party has, or may have, against ilie other or the other's estate. NOW, THEREFORE, in consideration of the mutual promises, covenants and undertakings hereinafter set forth and for oilier good and valuable consideration, receipt of which DocumeH' #: 222424.1 I I ~I:,:~-,~,',:,- ~'. ~ .,~ '," . '-''',- '>oX:; "', ~_ > ""''''';':!'; '. the parties acknowledge, Husband and Wife, each intending to be legally bound, hereby covenant and agree as follows: 1. SEPARATION 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. HUSBAND'S AND WIFE'S DEBTS 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 harmless the other party from any and all claims or demands made against the other by reason of debts or obligations incurred by that party. 3. WANER OF RIGHTS AND MUTUAL RELEASES Except as provided in this Agreement, both parties absolutely and unconditionally release 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 former 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 -2- Docu~nt#:22242~1 -', .1 I '~-.~ ~,:_-",;;~~i_-,~::~ ,',: - _~ . . 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 parnes 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. 4. REAL ESTATE The parties own as tenants by the entireties improved real property situated at 38 Woodcrest Drive, Carlisle, Cumberland County, Pennsylvania. Said property is currently encumbered with a first mortgage with M&T Banle Wife has obtairied refinancing through Members First and the anticipated closing date on the refinancing is December 18,2001. (a) At the time of said refinancing of the aforesaid property, Wife agrees to satisfy the M&T mortgage and pay to Husband the sum of $8,000.00. In exchange, Husband agrees to execute a Deed transferring all of his right, title, and interest, including, but not limited to, all rights under the Divorce Code of 1980, as amended, to the individual name of Wife. (b) Husband agrees to sign those documents reasonably necessary to effectuate the foregoing transaction including signing the Deed at the time specified by Members First to facilitate the refmancing. (c) Husband agrees to deliver to Wife on or before the aforesaid closing date all keys to said property. - 3- Document #: 222424.1 -, 1- '~ .~ -I' .,-" - ",-~;}~~"~-^,,',..;,, ""~,"-,- '~l"--'I:r -<"4-i!~~,j 5. DIVISION OF PERSONAL PROPERTY All personal property currently in the possession of Wife shall be the sole and separate property of Wife with the exception of the items listed on Exhibit "A" which shall be Husband's. The listed items on Exhibit "A" shall be picked up by Husband from Wife within thirty (30) days from date this Agreement is executed. All personal property currently in the possession of Husband shall be the sole and separate property of Husband. 6. MOTOR VEmCLES (a) Wife shall retain sole and exclusive ownership of the 1995 Hyundai Sonata GLS vehicle in her possession and agrees to assume sole responsibility for all outstanding encumbrances, if any. (b) Husband shall retain sole and exclusive ownership of the 2001 Ford Escape vehicle in his possession and agrees to assume sole responsibility for all outstanding encumbrances, if any. 7. JOINT DEBTS The parties acknowledge that they have no debts which were jointly incurred during their marriage. Any debts or obligations incurred by either party in hislher 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. Husband agrees to assume full and sole responsibility for the payment of the following debts and agrees to indemnify Wife for any loss sustained as a result of his failure to do so: Providian credit card account -4- Document #: 222424.1 " ~ ,- I ~~' L -' '"' -: ;_;, " ','C~d_ - '-"~; . , Merrill Lynch loan against retirement account Wife agrees to assume full and sole responsibility for the payment of the following debts and agrees to indemnify Husband for any loss sustained as a result of her failure to do so: First USA credit card Capital One credit card SLCS Student Loan PMSCO computer loan 8. RETIREMENT BENEFITS AND IRA's During the marriage, Husband acquired a 403b account with the Merrill Lynch. Wife specifically waives, releases, renounces and forever abandons all of her right, title, interest or claim, whatever it may be, in any pension/retirement/profit sharing/401K or like plan of Husband whether acquired through Husband's employment or otherwise, and hereafter said plan shall become the sole and separate property of Husband. During the marriage, Wife acquired an investment/retirement/40IK account with PMS and TIAA-CREF account. Husband specifically waives, releases, renounces and forever abandons all of her right, title, interest or claim, whatever it may be, in any pension/retirement/profit sharing/40lK or like plan of Wife whether acquired through Wife's employment or otherwise, and hereafter said planes) shall become the sole and separate property of Wife. 9. DIVISION OF BANK ACCOUNTS Husband and Wife aclmowledge that all joint bank accounts have been closed or divided to their mutual satisfaction prior to the execution of this Agreement. 10. AFTER-ACOUIRED PROPERTY - 5 - Document #: 222424.1 .:li!) .' " Ic"; -,.. .,---, I. " . ~. " i ';,., "'-"""";':,"i" ,', , :- ,'-., ,- ',- - - ,'- ~ -"'~il'r~~; . , 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. 11. INTENDED TAX RESULT By this Agreement, the parties have intended to effectuate and by this Agreement have equally divided their marital property. The parties have determined that such equal division conforms 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 otherwise be expressly provided herein, intended by the parties to constitute in any way a sale or exchange of assets. 12. INCOME TAXES Husband and Wife have previously filed joint Federal and State income tax returns. In the event of any deficiency in any Federal, State or local income tax imposed or in the assessment of any such tax is made against either of them, each will indemnify and hold hannless the other from and against any loss or liability for any such tax deficiency assessment and any interest, penalty and expense incurred in connection with such tax deficiency or tax assessment. The party who is finally determined to have, through their actions or inactions, brought about the .tax liability or assessment of interest or penalty shall be responsible to pay said liability. Should both parties agree to file j oint tax returns for tax year 2001, the tax due or refund shall be paid or divided between the parties in proportion to their respective gross incomes as reflected on said return. In the event the parties do not file joint tax returns for the year 2001, they - 6- Document #: 222424.1 ::it ". ,'I ,:1 ,;,~""~'~".,~,',, ~~ , , , ".-. -.'" . , ,>, ."~ .;- ,;- -.-of'; .-'-. ~" :-~W~ agree to divide the deductible interest on the house and any other deductions in the following manner: Wife will be entitled to a deduction in the amOlmt of? /12. Husband will be entitled to a deduction in the amount of 5/12. 13. SPOUSAL SUPPORT. ALIMONY PENDENTE LITE. AND ALIMONY Husband and Wife waive . and relinquish all rights, if any, to spousal support, alimony pendente lite, and alimony. Any transfer of monies between the parties pursuant to any term of this Agreement shall not constitute alimony but is made as part of the parties' equitable distribution settlement. 14. LlFEINSURANCE Both parties have life insurance policies with State Farm. Husband shall retain his life insurance policy and all rights attributable thereto and Wife shall retain her life insurance policy and all rights attributable thereto. Each party hereby waives, releases, renounces and forever abandons all of their right or interest in the others life insurance. 15. COUNSEL FEES AND EXPENSES Except as otherwise specified herein, each party shall be responsible for payment of his/her own counsel fees and expenses. 16. ADVICE OF COUNSEL 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. - 7- Document #: 222424.1 ',' J '>C''''~ '_",. ~-,' ",,:-~;~_-- , -.1W:l ~-~',;~_~ Each party confirms that he/she understands fully theterms, 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 iIot the result of any duress, undue influence, collusion,' or improper or illegal agreement. 17. AFFIDAVITS OF CONSENT Each party agrees to execute an Affidavit of Consent for the obtaining of a no-fault divorce under the provisions of the Divorce Code of 1980, as amended. 18. EFFECT OF DIVORCE DECREE ON AGREEMENT Either party may enforce this Agreement as provided in section 3105(a) of the Divorce Code, as amended. As provided ill section 3 105 (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. 19. HEADINGS NOT PART OF AGREEMENT The descriptive headings preceding the paragraphs are for convenience and shall not affect the meaning, construction or effect of this Agreement. 20. SEVERABILITY AND INDEPENDENT AND SEPARATE COVENANTS Each separate obligation shall be deemed to be a separate and independent covenant and 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 term, condition, clause or provision - 8 - Document #: 222424.1 "" ','. , "-",.,-,~ "i. , L~ ~ , '''_''''_'rC__~''''_'-U'>~_"^':;-~: - '^" '" "'-:li shall be stricken from this Agreement and in all other respects this Agreement shall be valid and continue in full force, effect and operation. 21. AGREEMENT BINDING ON HEIRS This Agreement shall be binding on and shall ensure to the benefit of the parties and their respective heirs, executors, administrators, successors, and assigns. 22. INTEGRATION This 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. 23. MODIFICATION OR WAIVER TO BE IN WRITING No modification or waiver of any term of this Agreement shall be valid unless in writing and signed by both parties. 24. NO WAIVER OF DEFAULT 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 term. 25. VOLUNTARY EXECUTION 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. - 9 - Document #: 222424.1 .l....;;:.. - '" :;- .~--: - -~ ~ . , . . 26. APPLICABLE LAW This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania and more specifically under the Divorce Code of 1980, as amended. 27. ATTORNEYS' FEES FOR ENFORCEMENT 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 WITNESS WHEREOF, the parties have, set their hands and seals the day and year first written above. Ildit: ~ IYJ-~ f~~~~ ~;:i?~ ina arie Ross Sheedy . - 10- Document #: 222424.1 _l,_'_ ;,--,-_"~",,;_. '_~,. '~~. " '. COMMONWEALTH OF PENNSYLVANIA ss COUNTY OF On this, the 18 day of )).,fi'/ht'&r, 2001, before me, the undersigned officer, personally appeared Michael John Sheedy, known to me or satisfactorily proven to be the person whose name is subscribed to in the foregoing Marital Settlement Agreement, and acknowledge thathe executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. ~. '.-.../--., ~ ' '. . "';' -- ~/; .',,:~- ::.:~:';' - ~""',' -. ~ OTARlAl~EAt" , ITH, Notary Public em, ,~fngs Borough, Cumberland Co, My Commission Expires Feb, 18, 2002 *************************************************************** COMMONWEALTH OF PENNSYLVANIA ss COUNTY OF On this, the l'l day of J)fA..f./)o",JU/, 2001, before me, the undersigned officer, personally appeared Tina Marie Ross Sheedy, 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~~~lod:;~ffJ " .-1 - ""'-/,'; >,' , 0 NOT ARIAlseAL~::~,:, :",)" CHERYL D. SMITH, Notary Public MI. Holly Springs Borough, Cumberland Co. '; , My Commission Expires Feb. 18, 2002 "!1!!:,f'''";. Document #: 222424.1 , " . -, -",,--, , ,.1 : I~:- ~- ~ i -" " -:... . '.;,.,,- ~--,.~, . . EXlllBIT "A" 1. Family Heirloom Tea Set 2. Ansel Adams Print (Fiat Lux) 3. Brita Water pitcher 4. Griddle pan 5. Assorted Cephalon & Kitchen Shop utensils 6, Sheedy Crest glasses 7. Tea Maker 8. Cappuccino Maker 9. Coffee Maker 10. Pasta Maker 11. Pasta Rack 12, Beer glasses 13. Coffee Mugs 14. Cephalon cookware 15. Cookbooks 16. Wall hanging (Multnomah Falls Oregon) 17. Two silver pieces 18. Childhood items (boxed in shed) Document #: 222424.1 ;ill] -, ..' . . ,R;i;:J,>i~'-:':;i;t;i~('''':''&~'~~ij:;ffi~.'N~ll~Mil~'~'~~'''~M,~;'~:j#~~~r;';'" ;w'-ilftiljJl_ili~~"" t' [,,,; ;;"",', - ~ ,,','';;,- "__i.'~' --' - "'-;-,- ,,_. " ""n ..~',.( (") c.:,') 0 c: ;-',3 uq ~~- 1~ :::::j U cr.: ."<:1 ri""r"" ;;0 , ::, -,'1 z::b 7:" t." .. ['Tl CD -' C] -<' , " r'O c) - C) ~ ~ -c) :)~ 'T; .- "....., '-n ..;:.- ~. -.I ---,'" , . (; SO;; Q ~~ () ill ~- Z ==-.--1 -~ ::> :0 -<. t...> -< "~., , - ~ -~~ ,. ~?_""=~"' " ---"'-"~y--,~ ^ ^,,,,' ~, ~ ~,. - ~,-~ ,-' ~" "--, ,"",., - .~ -, I ~~~",;i ~ , il,_y ,'~ '... >~D!'-"'-~;'^;-d,-,-'_:"',;;.:~j: c_,;.i':~' .- , .....---- '- .-, MICHAEL J. SHEEDY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2001-6479 CIVIL TERM TINA MARIE ROSS SHEEDY, Defendant CIVIL ACTION-LAW IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section 330l(c) of the divorce code. 2. Date and manner of service of the complaint: Service upon the Defendant via certified mail, restricted delivery on November 16, 2001. 3. (Complete either paragraph (a) or (b).) (a) Date of execution of the affidavit of consent required under Section 330l(c) of the divorce code: by the plaintiff March 8. 2002 by the defendant March 18. 2002 (b) (1) the divorce code Date of execution of the plaintiff's affidavit required by Section 330l(d) of N/A (2) Date of service of the plaintiff's affidavit upon the defendant N/A 4. Related claims pending NONE 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: N/A (b) Date plaintiffs waiver of notice in Section 3301(c) divorce was filed with the Prothonotary: March 28, 2002 Date defendant's waiver of notice in Section 330 I ( c) 'vorce was filed with the Prothonotary: A ril12 2002 ~/ David A. Baric, Esquire Attomey for Plaintiff, Michael J. Sheedy H .j~~~[i'~*~;I~-fMil.~~~lliOii.J!\n~;Ji("~$:,,jk~l~~"";:o ""~'-':iI'niK~'; ~ ., H_~",,~-, =". _~~,<,~~,,~" .n_. ~'.' _, ~-, - ,', -" ~ '" ~,~ - - , ,"" ~-- "'-~ ~ i. "":i-,,:..i".-~''';;C.diGl ,k.,;...- >,";,' -,",,#;' ~" '.O-"~l~ I " I , I I I I I I 0 I;::> 0 c: 1"0 -Tl ~ ':CO > ,~'" v-(n -..':] :::--.:\:':~ ~~~: ::0 , ".--. Z C._ _.,~:;:.j ~ ~r -' ,-... t ':::~O '<0 -0 i~~; >r~' :~'f. ~M 0~ )>or::: "" ~ ::> ~ ~ =< .~ '-, "; '" '-~ "' ~ , r I ., C'" , " ,-"..---~-- '----""dl-' ",J._-,:;;,.:;.<<,,;' ';,',,~-, ",---:k'~-,h".U"';-",.c,_~ '-","0_. /" \fa$,",'. '" ~.. " MICHAEL J. SHEEDY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO.2001- t;lf1-9 CIVIL TERM TINA MARIE ROSS SHEEDY, Defendant CIVIL ACTION-LAW 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 without you and a decree of divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMON~ MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY 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 ';';!A';''ffi-,*;t,\,'),-ii~Z-' -J~ .".." " j, ,. _ ;,.:~,;-'"".'_ ,";,;','.~k':1'~ c;, -".:; ,^ ",.:"i-:~~),~,,~. ~~,~i~':'d~.;;';,-? .:',/:~:__..:., " '. ,'., " ''"''~'rtii@;..'';1:l~''Yj Ii . MICHAEL J. SHEEDY, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001- G41q CIVIL TERM TINA MARIE ROSS SHEEDY, Defendant CIVIL ACTION-LAW IN DIVORCE COMPLAINT UNDER SECTIONS 330l(C) AND 3301(0) OF THE DNORCE CODE L Plaintiff is Michael J, Sheedy, an adult individual who currently resides at 21 Carter Place, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Tina Marie Ross Sheedy, an adult individual who currently resides at 38 Woodcrest Drive, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on June 5, 1993, in Cumberland County, Pennsylvania. COUNT I - DNORCE 5. Plaintiff hereby incorporates by reference paragraphs I through 4 above. 6, There have been no prior actions of divorce or for annulment between the parties as to their current marriage, 7. Neither Plaintiff nor Defendant is in the Armed Forces of the United States. 8. Plaintiff avers that the marriage between the parties is irretrievably broken. 9. The Plaintiff has been advised of the availability of counseling and that he may have the right to request that the court require the parties to participate in counseling. 2', -~; ';-l,~~ :. -:, ,;:~::,: ,~:;", ~ '''::;,'i.~'':~'~ ~ ,,"~., , . . ~ WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a decree in divorce. COUNT II -EOUITABLE DISTRIBUTION 10. Plaintiff hereby incorporates by reference paragraphs 1 through 9 above. II. The parties have acquired personal property, including automobiles, bank accounts and other items of miscellaneous property during the course of their marriage, some of which is marital property. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a decree which effects an equitable distribution of marital property. Respectfully submitted, ;r~;(l~R DATE: 1)/1/ In David A. Baric, Esquire LD. # 44853 17 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 dab,dir/domestic/sheedy/complaint.pld II ,-'<;''', i,-; ~I~' ,," O:.Ld 1",.,--" ,.', ';:- ,;;: ";,-;&,..;',1,.-;, _ .""-~",'!", ';;;';;;_~. ': - ", .'"'.',,,.--"- ,-~: ;",' '~"'''''' ~'jj'ili,\~~ I <, . VERlFICArION I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 9 4904, relating to unsworn falsification to authorities. I J. Sheedy DATED: JI/14/o I , I , . ~~;-,;o;j,;l~0'.i,. ,'-~:+"~":;"1it~~~~~;li!&..1!~t~W!;:M'~ ..i..-;",,:"Q' ,- '." "~:.."""...,,,,,.i, . . ~ f ,~-, ,~., . ~N.~ ,,,.~,,,>., ","",., '. - . $ ,,-",,,, ,- ---,.. .',--- - - ,-~ ",..,-;-\ o c: =<::- -rJce mrri z::n W~ -</- ~O ~C") ~c >2 ..,.. ~ .-"-" ,,~-- > ,~,'~ . >~,-'" ". q ~,~ ,~~ --~ " / C) D un :,:;..1 :'''r:::rJ: , 'S:; -"r--; .'-, .'( ~.~~;;~ ~3: i:J 1:5"-" ~ :1:) -< - :'.":5 ::r:: c.n ~ -"... u::l '~ ..0 "' ~. ~, , ~"'- _I 1-' ".,-. ",.., '" 'ol~,t,.;::;"'''-'~~~''''i''>~L~'':'' . c, '~,. ,0:"-"""';/:. ,,< ::, ii""1"'~ir- MICHAEL J. SHEEDY, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001-6479 CIVIL TERM TINA MARIE ROSS SHEEDY, Defendant CIVIL ACTION-LAW IN DIVORCE CERTIFICATE OF SERVICE I, Qavid A. Baric, Esquire, attorney for the Plaintiff in the above-captioned divorce action, do hereby certify that I served a certified copy of the Complaint in Divorce to the Defendant, as per the attached U.S. Postal Service Certified Mail, return receipt card, EN'B~C~"! BY David A. Baric, Esquire DATE: '-1/11 /tJ,? f I i R: c .' o J~mplet&--derris 1 and/or 2 for additional services ;;.,Cqnplele items 3, 4a, and 4b. . c ~:t foo~~~ame and aqdress on the reverse of this form so tQat,;ve ;an li'tum this :~~,this fo~ to the front of the mailpiece, oron the back ifspac;e dO~s ntlt ':~;::e:::m f1~Pt..Requested. on the mailpiece below the article number ."),, re~. Receipt Will, show to whom the article was delivered and the dat~ Ie Addressed -to: I also wish t6 receive tM'fbllow- ing services (for an extra fee); 1, '0 Addressee1s Address 2. ~ Restricted Delivery :. 5. Received By: (Prinl Name) 4a. Article Number 10Q DOl'?> fqqb ~I06 4b. SerVice Type o Registered o Express Mail !J Retum Receipt for Merchandise 7. Date of Deli~ .a 8. Addressee's Address (Only if requested and fee Is paid) ~Certjfied o Insured DeOO i 1l. 'il &! " ~ '" ij ~, ~ ~ J2 " o '" ... c' m t= :, ! , 102595~99-B"0223 Damestic As_ Ii ~J)'Y-':~~~{' .,>>'" -0. ~tl~'@-kIli.14t~\{""~~,il1.w~.(~;;;';;":;'''~i'i'.i\i.~'i' "'~-." ~'"->. ~ ~~~ ~ ""~ -"~';; ,.","".- . '.'-'~'"'" ".t~,;,."".",~-"",,<,~ ~" - 0 0 0 C f" --q ~ ",. -ocrl -0 -,-'1 mrn :;0 ;::::: Z:~"'" ~, ;"'n zr :;JCJ co ]2', -~ -<'c !'~~~ ~~) ~~~ -V S.J~ _ld.. )>c. S~ ~]rp C~ z ::> :~ ~ (.oJ -< , "' I , , '-", -~'''-;,.;.;':t''''';__ 'I..;,.,; ,,.i:; ';:,.."", ,< ' ;',:,; 'j~,.,i' ;~~ ~,~;~,;X,;:Z)(:,.\;;~:'".~', - , "'''~cl \_/ MICHAEL J. SHEEDY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO, 2001-6479 CIVIL TERM TINA MARIE ROSS SHEEDY, Defendant CIVIL ACTION-LAW IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF I)IVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on November 15,2001. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of a final decree in divorce without notice. , : I I ,I 4. 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, 5. 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 . 6, I have been advised of the availability of marriage counseling and understand that I may request that the court require counseling, I do not request that the court require counseling. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: s/<g)o:! I I ~l~~ II I ~-:!r "--'-':' ijj~:~'~M:".\wli*I!mmltim.-ji~j;,.gtj;g{,'i;ID"iI!'MUi:il':~;i~iliI!~~~-: ',7_.',~ "~__ "" __ _'.'.,,~n" ~,",~"'" _ ',,,- _'~'~,<",- ~,,'v' -, '.."-",~.' "" ,..'L ~"'~C_ ", 0__ 'r_ .. ........ -".h,.:P' 1St'" ,..,~ -" ".-,,, .. -' ''"'''''~'ijjr''-<''''-- o 92[: ---;," (..T-:- rs,:- ::;. "'.:;:.. ,..;::-> ~ ::> ( :-:~ f::S /3IJ >~ ~ I I I I I I I -:.", '\.: 0" '.~.i <="V'V'~'~'v '_ 7~_",:<" .,.~ ,,_ ."'~" "II:.. -, , ~i"..' _,ic~';:j,'~I'""_,,;-';"'~",,,,,,'- " ,-, ,,,,i '";'}~;{!.I;":;':..;\~~;0",,r: ,- - c' '". "J-l~.~1 . > MICHAEL J. SHEEDY, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA NO. 2001-6479 CIVIL TERM TINA MARIE ROSS SHEEDY, Defendant CIVIL ACTION-LAW IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT, ACCEPTANCE OF SERVICE AND W AIYlER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on November 15,2001. 2. Defendant acknowledges receipt and accepts service of the Complaint on November 16, 2001. 3. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 4. I consent to the entry of a [mal decree in divorce without notice. 5. I understand that I may lose rights conceming alimony, division of property, lawyer's fees or expenses ifI do not claim them before a divorce is granted. 6. 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. 7. I have been advised of the availability of marriage counseling and understand that I may request that the court require counseling. I do not request that the court require counseling, I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa,C.S. Section 4904 relating to unsworn f!\l.sification to authorities. Date: -aJ.r);d . , il ~~iMJm~-lIiil~*_~~;ii,~,~.;~:;Jcli!:--df,~i~-;';;"-','"'-:i'\'.'V 't'r~'*iii;1t'_--c, k-'--- ;-:~ >__~ _","_k-",_~,_",..,"~ _ ~ __ _~ ~, ~_".' _-We' _~_"*'_,,"__ . "-< ,""'>' _,_", '" "'Af'\~kn'-' _, , ,,__, , , . ~ -~,~. -- " -~ ~ . ~ ,0, .. .-- ,..",""",,,,,,,,._~" 0 0 C) C "., " S ",. -00:.1 " mnl :7.1 Z.:_I) zr' (f);g-;. f'.) ~c, )> -- Zl...) -0 W :~ J>C Z => ~; -;1 -.. C? :< ,,~,o" ____~_.< ..'"",,, __~,<,,,. ._~ _ !lM:1: IFs 8.-1( ,,lli,,,~l ~ ~"_.~-. ,= ~ ~"" ".'0' -~ "............... ,.,~" """. 1ll"..,.,L.,.=, = ~ I ~ ~'........,-, ~.~IIiI!JlIili""";""_ .~'~, -~~..,;" :.ll-~~~_~ ..) 'C -- , MICHAEL J. SHEEDY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2001-6479 CIVIL TERM TINA MARIE ROSS SHEEDY, Defendant CIVIL ACTION - LAW IN DIVORCE ENTRY OF APPEARANCE To the Prothonotary: Kindly enter my appearance on behalf of Defendant, Tina Marie Ross Sheedy, in the above referenced matter. METZGER, WICKERSHAM, KNAUSS & ERB, P,C. By~N.~~...c-~ Karl R. Hildabrand, Esquire Attorney LD. No. 30102 P.O. Box 5300 3211 North Front Street Harrisburg, P A 17110-0300 (717) 238-8187 r Attorneys for Defendant Dated: I;)..../I~../D( I { Document #: 222703.1 ,~,- """'_'"~~ -~ ..",,", ~.i ~ ':'~'''''''''_~J''''_ '....'""'-l""""."..""'""~'7 .:IIIIi.i.-J:l..J'~~ "i.J.~""""",A~tfu,,, -' , . " CERTIFICATE OF SERVICE I, Karl R. Hildabrand, Esquire, of the law firm of Metzger, Wickersham, Knauss & Erb, P,C., hereby certifY that I served a true and exact copy of the Entry of Appearance with reference to the foregoing action by First Class Mail, postage prepaid, this l2-day of December, 2001, on the following: David A. Baric, Esquire O'Brien, Baric & Scherer 17 West South Street Carlisle, P A 17013 METZGER, WICKERSHAM, KNAUSS & ERB, P.c. ~77cr:;~p Karl R. Hildabrand, Esquire ..~ I Document #: 222703,] I ~nj,~~;;!~iitiJ:'ft~iMs~&W~IJh'I .. 'J-l:""t~~~i:.\~~",",,~!li*~~:M'~1 t ". '--... k. 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