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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
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STATE OF
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CLINTON L. CRAIG,
.
Plaintiff
VERSUS
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CYNTHIA C. CRAIG,
.
Defendant
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PENNA.
No. 2001-6593
DECREE IN
DIVORCE
AND NOW,J~)) L 19
DECREED THAT
.
AND
2002 , IT IS ORDERED AND
CLINTON L. CRAIG
, PLAINTIFF,
CYNTHIA C. CRAIG
, DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
.
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED;
.
.
The attached Matital Agreement between the parties dated June 4, 2002, shall
be incorporated but not merged into this Decree in Divorce pnrsuant to the
said Agreement.
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PROTHONOTARY
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CLINTON L. CRAIG,
Plaintiff,
CIVIL ACTION - LAW
vs.
NO. 01-6593
CIVIL
CYNTHIA C. CRAIG,
Defendant.
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the following information, to the court for entry of a divorce
decree:
1. Grounds for divorce: irretrievable breakdown undeT S 3301(c) of the Divorce Code.
2. Date and manner of service of the complaint: November 28, 2001, by mailing postage paid,
certified mail, addressee only, and return receipt requested at Shippensburg, Pennsylvania.
3. Date of execution of the affidavit of consent required by S 3301(c) of the Divorce Code:
by Plaintiff, June 4, 2002; by Defendant March 11, 2002.
4. Related claims pending: The attached Marital Agreement between the parties dated June 4,
2002, shall be incorporated but not merged into this Decree in Divorce pursuant to the said
Agreement.
5. Date Plaintiffs WaiveT in S 3301(c) Divorce was filed with the prothonotary: June 6, 2002
Date Defendant's Waiver of Notice in S 3301(c) Divorce was filed with the prothonotary:
March 13,2002
WEIGLE & ASSOCIATES, P.
WEIGLE & ASSOCIATES, RC- - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397
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MARITAL AGREEMENT
THIS AGREEMENT, made this 4 M day of ~UA'\ 2 ,2002, by and between CLINTON L.
CRAIG, hereinafter referred to as Husband, presently of 234Neil Road, Shippensburg, Cumberland
County, Pennsylvania 17257, and CYNTHIA C, CRAIG, hereinafter referred to as Wife, presently of
26 Maple Avenue, Walnut Bottom, Cumberland County, Pennsylvania, 17266-0917.
WITNESSETH:
WHEREAS, the parties hereto are Husband and Wife, having been married on December 19,
1987, in Cumberland County, Pennsylvania, with no childTen having been born of the marriage; and
WHEREAS, diverse unhappy differences, disputes and difficulties have arisen between the
parties and it is the intention of Wife and Husband to live separate and apart, and the parties hereto are
desiTOus of settling some of their respective financial and property rights and obligations as between
each other including, without limitation by specification: the equitable division of marital property; and
the settling of all matters between them relating to the past, present and future support, alimony and lor
maintenance of Wife by Husband or of Husband by Wife.
NOW, THEREFORE, in consideration of the premises and of the mutual pTOmises, covenants
'I and under takings hereinafter set forth which are hereby acknowledged by each of the parties hereto,
Wife and Husband, each intending to be legally bound hereby, covenant and agree as follows:
AGREEMENT NOT A BAR TO DIVORCE PROCEEDINGS
This Agreement shall not be considered to affect or bar the right of Wife or Husband to a limited
or absolute divorce on lawful grounds, if such grounds exist or shall hereafter exist or to such defense as
may be available to either party. This Agreement is not intended to condone and shall not be deemed to
be a condonation, on the part of either party hereto, of any act or acts on the part of the other party which
have occasioned the disputes or unhappy differences which have occurred prior to or which may occur
subsequent to the date hereof. The parties intend to secure a mutual consent, no-fault divorce pursuant
to the terms of Section 3301(c) of the Pennsylvania Divorce Code of 1980, as amended.
EFFECT OF DIVORCE DECREE
The parties agree that unless otherwise specifically pTOvided herein, this Agreement shall
continue in full force and effect after such time as a fmal decree in divorce may be entered with respect
to the parties.
AGREEMENT TO BE INCORPORATED IN DIVORCE DECREE
The parties agree that the terms of this Agreement may be incorporated into any divorce decree,
which may be entered with respect to them.
WEIGL~ & ASSOCIATES, Re. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397
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Page 2 of8
DATE OF EXECUTION
The "date of execution" or "execution date" of the Agreement shall be defined as the date upon
which it is executed by the parties if they have each executed the Agreement on the same date.
Otherwise, the "date of execution" or "execution date" of this Agreement shall be defmed as the date of
execution by the party last executing this Agreement.
ADVICE OF COUNSEL
The provisions of this Agreement and their legal effect have been fully explained to Husband, by
Jerry A. Weigle, Esquire, who is attorney for Husband and who prepared this marital agreement. Wife
acknowledges that she has been advised of her right to seek independent legal counsel and she has
decided not to do so. Both parties acknowledge that they fully understand the facts and have been fully
informed as to theiT legal rights and obligations and understand the same. The parties hereto further
acknowledge and accept that this Agreement is, in the circumstances, fair and equitable and that it is
being entered into freely and voluntarily after having received such advice and with such knowledge,
and that execution of this Agreement is not the result of any duress or undue influence and that it is not
the result of any collusion or improper or illegal agreement or agreements.
PERSONAL RIGHTS
Wife and Husband may and shall, at all times hereafter, live separate and apart. They shall be
free from any control, restraint, interference or authority, direct or indirect, by the other in all respects as
fully as if they were unmarried. They may reside at such place as they may select. Each may, for his or
her separate use or benefit, conduct, carry on and engage in any business, occupation, profession or
employment, which to him or her may seem advisable. Wife and Husband shall not molest, harass,
disturb or malign each other or the respective families of each other nor compel or attempt to compel the
other to cohabit or dwell by any means or in any manner whatsoever with him OT her.
SEPARATION DATE
The parties do hereby acknowledge that although presently residing at the same address, they
have lived separate and apart since September 11,2001 . It is hereby agreed that September 11,2001,
shall be the separation date for purposes of equitable distribution under the Pennsylvania Divorce Code
unless altered by subsequent agreement of j:he parties in writing and signed by each of the parties. No
I attempt at reconciliation shall be considered to alter the separation date unless evidenced by written
agreement.
MOTOR VEHICLES
A. The parties agree that Wife shall become the sole and exclusive owner of the following
motor vehicles and that Wife shall be solely responsible for all payments on the automobile loan(s) if
any still exist for said vehicles and shall save Husband harmless from any repayment thereon.
WEIGLE & ASSOCIATES, RC. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397
II
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1. 1988 Ford Ranger Truck;
2. 1987 Force Escort GT; and
3. 1995 Pontiac Sunfire
B. The parties agree that Husband shall become the sole and exclusive owner of the parties'
1977 Chevrolet % ton pick-up truck motor vehicle. Husband shall assume sole responsibility fOT any
loan or loans on said vehicle and shall save Wife harmless from any repayment on the same.
PERSONAL PROPERTY. BANK ACCOUNTS AND PETS
Husband and Wife do hereby acknowledge that they have previously divided their tangible
personal property, bank accounts and pets, including but not limited to jewelry, clothes, furniture,
furnishings, rugs, carpets, household equipment and appliances, vehicles, pictures, books, works of art
and other persona! property and hereafter Wife agrees that all of the property in the possession of
Husband shall be the sole and separate property of Husband and Husband agrees that all of the property
in the possession of Wife shall be the sole and separate property of Wife. The parties do hereby
specifically waive, release, renounce and forever abandon whatever claims, if any, he or she may have
with respect to the above items, which shall become the sole and separate property of the other.
AFTER-ACOUlRED PERSONAL PROPERTY
Each of the parties shall hereafter own and enjoy, independently of any claim or right of the
other, all items of persona! property, tangible or intangible, hereafter acquired by him or her, with full
power in him or her to dispose of the same as fully and effectively, in all respects and for all purposes,
as though he or she were not married.
REAL ESTATE
The parties hereto acknowledge and agree that Wife is the owner of a residence located at 26
II Maple Avenue, Walnut Bottom, Pennsylvania, situate in South Newton Township, Cumberland County,
Ii and more specifically described in Cumberland County Deed Book 249 at Page 1604. For and in
II consideration of the mutual covenants and agreements herein contained in the body of this instrument,
" Husband and Wife further stipulate and agree that said real estate, together with an 18' x 26' shop
building and 10' x 12' shed building located on the premises, shall be retained by Wife.
Parties acknowledge and agree that Wife has previously refinanced the parties' Allfirst Mortgage
obligation on the above-referenced marital residence in the approximate amount of Thirty-six Thousand
Dollars ($36,000.00) so as to remove Husband's name from said obligation. The parties further agree
that Husband shall pay to Wife the full sum of Two Hundred Thirty-five Dollars ($235.00) per month to
be used toward Wife's present mortgage obligation payment to A11first Bank in the approximate amount
of Thirty-two Thousand Dollars ($32,000.00) [payable in monthly payments of Four Hundred Seventy
Dollars ($470.00)]. Said obligation shall remain in effect for a period of one hundred twenty (120)
months or until said mortgage obligation is paid in full, whichever event shall first occur.
WEIGLE & ASSOCIATES, P.e. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397
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HUSBAND'S 8EISTLE COMPANY PENSION BENEFIT
The parties hereto acknowledge and agree that Husband has a retirement benefit through his
employer (The Beistle Company, Shippensburg, Pennsylvania) having an approximate present value of
Thirty-five Thousand Dollars ($35,000.00) which Husband may not withdraw without penalty until
September 29, 2006. The parties further agree to let said benefit accumulate until September 29, 2006,
at which time said benefit shall be withdrawn by Husband and divided equally with Wife.
WAIVER OF SPECIFIED CLAIMS BY HUSBAND
Husband hereby waives any and all right to claim any interest or share in Wife's present pension
benefit through Hoffman Mills, Inc., Shippensburg, Pennsylvania, valued at approximately Two
Thousand Five Hundred Dollars ($2,500.00)
WARRANTY AS TO EXISTING OBLIGATIONS
Each party represents that he or she has not heretofore incurred or contracted for any debt or
liability or obligation for which the estate of the other party may be responsible or liable except as may
be provided for in this Agreement. Each party agrees to indemnify and hold the other party hannless
from and against any and all such debts, liabilities or obligations of every kind which may have
heretofore been incurred by them, including those for necessities, except for the obligations arising out
of this Agreement.
LEGAL FEES
Husband shall pay the cost of legal fees incurred in preparation of this marital agreement and all
legal fees and court costs in connection with obtaining a 3301(c) No-Fault Divorce. Wife agrees to
cooperate by executing the necessary consents and other documents required to effectuate said divorce,
as requested by Husband's attorney.
INCOME TAX RETURNS
The parties agree to file separate federal and state income tax returns.
WEIGLE & ASSOCIATES, Re. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397
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Page 5 of8
MUTUAL RELEASES
Husband and Wife each do hereby mutually remise, release, quitclaim and forever discharge the
other and the estate of each other, for all time to come, and for all purposes whatsoever, of and from any
and all rights, title and interest, or claims in or against the property (including income and gain from
property hereafter accruing) of the other or against the estate of such other, of whatsoever nature and
wheresoever situate, which he or she now has or at any time hereafter may have against such other, the
estate of such other or any part thereof, whether arising out of any former acts, contracts, engagements
or liabilities of such other or by way of dower, courtesy, or claims in the nature of dower or courtesy or
widow's or widower's rights, family exemption or similar allowance, or under the intestate laws, or the
right to take against the spouse's will; or the right to treat a lifetime conveyance by the other as
testamentary, or all other rights of a surviving spouse to participate in a deceased spouse's estate,
whether arising under the laws of (a) Pennsylvania, (b) any State, Commonwealth or territory of the
United States, or (c) any other country, except, and only except, all rights and agreements and
obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of
any provision thereof. It is the intention of Husband and Wife to give to each other by the execution of
this Agreement a full, complete and general release with respect to any and all property of any kind or
nature, real, personal or mixed, which the other now owns or may hereafter acquire, except and only
except all rights and agreements and obligations of whatsoever nature arising or which may arise under
this Agreement or for the breach of any provision thereof.
WAIVER OR MODIFICATION TO BE IN WRITING
No modification or waiver of any of the terms hereof shall be valid unless in writing and signed
by both parties and no waiver of any breach hereof or default hereunder shall be deemed a waiver of any
subsequent default of the same or similar nature.
DIVORCE
The parties hereto agree to enter into a mutual consent divorce under Section 3301(c) of the
Pennsylvania Divorce Code of 1980, as amended. Husband agrees to pursue the present divorce action
filed to No. 01-6593 Civil, 2001, in the Court of Common Pleas of Cumberland County, Pennsylvania,
and to be the Plaintiff therein. Wife agrees to sign the necessary documents, including the Affidavit of
Consent, at such time after the ninety (90) days of filing of the Complaint and further instruments that
may be reasonably required to give full force and effect to the provisions of this Agreement.
MUTUAL COOPERATION
Each party shall, at any time and from time to time hereafter, take any and all steps and execute,
acknowledge and deliver to the other party any and all future instruments and/or documents that the
other party may reasonably require for the purpose of giving full force and effect to the provisions of
this Agreement.
WEIGLE & ASSOCIATES, RC. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397
II
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LAW OF PENNSYL VANIA APPLICABLE
This Agreement shall be construed in accordance with the laws of the Commonwealth of
Pennsylvania.
AGREEMENT BINDING ON HEIRS
This Agreement shall be binding and shall insure to the benefit of the parties hereto and their
respective heirs, executors, administrators, successors and assigns.
BREACH
If either party breaches any provision of this Agreement, the other party shall have the right, at
his or her election, to sue for damages for such breach or seek such other remedies or relief as may be
available to him or her, and the party breaching this contract shall be responsible for payment of legal
fees and costs incurred by the other in enforcing their rights under this Agreement.
WAIVER OF ALIMONY AND OTHER RIGHTS
The parties hereto have been informed of their rights or have been advised to seek counsel to
inform them of their rights under and pursuant to the Divorce Code, Action of April 2, 1980, Number
1980-26, as amended, particularly the provisions for alimony, alimony pendente lite, equitable
distribution of marital property, counsel fees or expenses. Both parties agree that this Agreement shall
conclusively provide for the distribution of property under the said law and except as specifically
provided for in this agreement, hereby waive, release and relinquish any further rights they may
respectively have against the other for alimony, alimony pendente lite, equitable distribution of marital
property, counsel fees or expenses. From the date hereof, each party may acquire either personal or real
property in their own name. Any property so acquired shall be owned solely by the individual and shall
not be subject to any claim whatsoever by the other party.
FINANCIAL DISCLOSURE
The parties confirm that they have relied on the substantial accuracy of the fmancial disclosure
of the other as an inducement to the execution of this Agreement.
ENTIRE AGREEMENT
This Agreement constitutes the entire understanding of the parties and supersedes any and all
prior agreements and negotiations between them. There are no representations or warranties other than
those expressly set forth herein.
WtIGLE & ASSOCIATES, RC. - ATTORNEVS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397
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NO WAIVER OF DEFAULT
This Agreement shall remain in full force and effect unless and until terminated under and
pursuant to the terms of this Agreement. The failure of either party to insist upon strict performance of
any of the provisions of this Agreement shall in no way affect the right of such party hereafter to enforce
the same, nor shall the waiver of any breach of any provision hereof be construed as a waiver of any
subsequent default of the same or similar nature, nor shall it be construed as a waiver of strict
performance of any other obligations herein,
SEVERABILITY
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 provisions shall be
stricken from this Agreement and in all other respects this Agreement shall be valid and continue in full
force, effect and operation. Likewise, the failure of any party to meet her or his obligations under any
one or more of the paragraphs herein, with the exception of the satisfaction of the conditions precedent,
shall in no way void or alter the remaining obligations of the parties.
HEADINGS NOT PART OF AGREEMENT
Any headings pTeceding the text of the several paragraphs and subparagraphs hereof are inserted
solely for convenience of reference and shall not constitute a part of this Agreement nor shall they affect
its meaning, construction or effect.
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, and that it is not the resnlt of any duress OT undue influence.
IN WITNESS WHEREOF, the parties hereto have set their hands and seals the day and year first
above written.
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C TON :-CRAIG ~
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C IA C. CRAIG rs
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WEIGLE & ASSOCIATES. RC. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397
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COMMONWEALTH OF PENNSYL VANIA
SS
COUNTY OF CUMBERLAND
On this, the tj'li' day of '-.0//\ P ,2002, before me a Notary Public,
the undersigned officer, personally appeared Clinton L. Craig, known to me to be the person whose
name is subscribed to the within Agreement and acknowledged that he executed the same for the
purposes therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and seal.
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(SEAL)
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Notarial Seal
Patrlcla L. Tome, Notary Public
ShiIlDensburgBcro, CumbetlandCounty
MY OommlsSlon Expires June 7, 2004
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COMMONWEALTH OF PENNSYLVANIA
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COUNTY OF CUMBERLAND
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On this, the Lj day of Ju rJ , 2002, before me a Notary Public,
the undersigned officer, personally appeared Cynthia C. Craig, known to me to be the person whose
name is subscribed to the within Agreement and acknowledged that she executed the same for the
purposes therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and seal.
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Notarial Seal
Patricia L. Tome, Notary Public
~~pP&nsb~rg.Borc. Cumberland County
,vii CommissIon EXDlres June 7, 2004
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CLINTON L. CRAIG,
Plaintiff,
CIVIL ACTION - LAW
vs.
NO. 01- iPS'9.3
CIVIL
CYNTHIA C. CRAIG,
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
without you and a decree of divorce or annulment may be entered against you by the court. A
judgement 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 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 Cumberland County Courthouse, Carlisle, PA 17013.
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
"
I, 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
WEIGLE, PERKINS & AS::;OCIATES - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CLINTON L. CRAIG,
Plaintiff,
CIVIL ACTION - LAW
VS.
NO. 01-1. S- "J21
CIVIL
CYNTIllA C. CRAIG,
Defendant.
IN DIVORCE
COMPLAINT IN DIVORCE UNDER
SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE
COUNT I - IRRETRIEVABLE BREAKDOWN
AND NOW, comes the above named Plaintiff, Clinton L. Craig, by and through his attorneys,
Weigle, Perkins and Associates, and Jerry A. Weigle, Esquire, and seeks to obtain a Decree in Divorce
from the above-named Defendant, upon the grounds hereinafter more fully set forth:
1. Plaintiff, Clinton L. Craig, is an adult individual presently residing at 26 Maple Avenue, Walnut
Bottom, Cumberland County, Pennsylvania 17266, since 1990.
2. Defendant, Cynthia C. Craig, is an adult individual presently residing at 26 Maple Avenue,
Walnut Bottom, Cumberland County, Pennsylvania 17266, since 1990.
3. The Plaintiff and Defendant are nationals and citizens of the United States of America, and both
have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months
immediately previous to the filing of the Complaint in Divorce.
4. The Plaintiff and Defendant were married on December 19, 1987, in Shippensburg, Cumberland
County, Pennsylvania.
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 the Plaintiff may have the right to
request that the court require the parties to participate in counseling.
7. The marriage is irretrievably broken.
8. Although presently residing at the same address, the parties have lived separate and apart since
September 11, 2001.
9. The Plaintiff requests the court to enter a decree of divorce.
WEIGLE, PERKINS & ASSOCIATES - ATTORNEVS AT LAW - 126 EAST KING STREET - SHI!=>PENSBURG, PA 17257-1397
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WHEREFORE, the Plaintiff prays your Honorable Court to enter a Decree in Divorce from the
bonds of matrimony and for such other and further relief to which Plaintiff shall be entitled.
COUNT II INDIGNITIES GROUNDS FOR DIVORCE
10. Paragraphs 1 through 9 of this Complaint are incorporated herein by reference as though set forth
in full.
11. Defendant has offered to the person of the Plaintiff, Plaintiff being the innocent and injured
spouse, such indignities as to render Plaintiff s condition intolerable and Plaintiff slife
burdensome.
WHEREFORE, the Plaintiff prays your Honorable Court to enter a Decree in Divorce from the
bonds of matrimony and for such other and further relief to which Plaintiff shall be entitled.
WEIGLE, PERKINS & AS:O,CCf AT!
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Je A. Weigle, Esquire
Attorney for Plaintiff
Attorney ID #01624
126 East King Street
Shippensburg, P A 17257
Telephone 717-532-7388
By:
WEIGLE, PERKINS & ASSOCIATES - ATTORNEVS AT LAW - 126 EAST KING STREET - SHliPPENSBURG, PA 17257~1397
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VERIFICATION
I verifY that the statements made in the foregoing Complaint in Divorce 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.
Dated: \~~~"
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WEIGLE, PERKINS & ASSOCIATES - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG. PA 17257-1397
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CLINTON L. CRAIG,
Plaintiff,
CIVIL ACTION - LAW
vs.
NO. 01-6593
CIVIL
CYNTHIA C. CRAIG,
Defendant.
IN DIVORCE
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYL VANIA
SS
COUNTY OF CUMBERLAND
Rhonda R. Wolford, being duly sworn according to law, deposes and says that on November 28,
2001, a true and attested copy of Notice to Defend and Claim Rights along with Complaint in
Divorce Under Section 3301@ or 3301(d) of the Divorce Code were served upon the Defendant,
Cynthia C. Craig. Manner of service: by mailing the same postage paid, certified mail, addressee only,
and return receipt requested, at Shippensburg, Pennsylvania, addressed as follows:
26 Maple Avenue
w&nm&Arofii}( I#d
RHONDA R. WOLFORD
Swo~ to and subscribed before me this
:!:/ dayof J)oJ"D(nb.u ,2001.
Jl.t i I'J ' '/<- 0/rG S)
Notary Public
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MY Comjrii'!Sion Expires June 7, 2004
WEIGLE', PERjI(lNS & ASSOCIATES - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397
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IN THE COURT OF COMMON PLEAS OF
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CLINTON L. CRAIG,
Plaintiff,
CIVIL ACTION - LAW
VS.
NO. 01-6593
CIVIL
CYNTHIA C. CRAIG,
Defendant.
IN DIVORCE
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CLINTON L. CRAIG,
Plaintiff,
CIVIL ACTION - LAW
vs.
NO. 01-6593
CIVIL
CYNTHIA C. CRAIG,
Defendant.
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A complaint in divorce under ~ 3301(c) of the Divorce Code was filed on November 26,2001.
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 fmal 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, ,
Dated: \> -I-\. - D'"J..
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Clinton L. Craig, Plaintiff - ~
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WEIGLE & ASSOCIATES, RC. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397
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CUMBERLAND COUNTY, PENNSYLVANIA
CLINTON L. CRAIG,
Plaintiff,
CML ACTION - LAW
vs.
NO. 01-6593
CIVIL
CYNTIDA C. CRAIG,
Defendant.
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A
DIVORCE DECREE UNDER 6 3301(c) AND 6 3301(d) OF THE IDIVORCE CODE
1. I consent to the entry of a fmal decree of divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or
expenses if! do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a
copy of the decree will be sent to me immediately after it is filed with the prothonotary.
I verify that the statements made in this affidavit are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa. C.S. g 4904 relating to unsworn
falsification to authorities.
Dated: ~ - \.-\ ' ~ '<-
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Clinton L. Craig, Plaintiff "\.
WEIGLE & ASSOCIATES, RC. ~ ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSElURG, PA 17257-1397
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CLINTON L. CRAIG,
Plaintiff,
CIVIL ACTION - LAW
vs.
NO. 01-6593
CIVIL
CYNTHIA C. CRAIG,
Defendant.
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A complaint in divorce under 9 3301(c) of the Divorce Code was filed on November 26,2001.
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. 9 4904 relating to unsworn
falsification to authorities.
Dated:
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WEIGLE & ASSOCIATES, RC. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397
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CLINTON L. CRAIG,
Plaintiff,
CIVIL ACTION - LAW
vs.
NO. 01-6593
CML
CYNTHIA C. CRAIG,
Defendant.
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A
DIVORCE DECREE UNDER ~ 3301(e) AND ~ 3301(d) OF THE DIVORCE CODE
1. I consent to the entry of a fmal decree of divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or
expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a
copy of the decree will be sent to me immediately after it is filed with the prothonotary.
I verify that the statements made in this affidavit are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa. C.S. ~ 4904 relating to unsworn
falsification to authorities.
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IN THE COURT OF COMMON PLEAS
OF CUMBELRAND COUNTY - PENNSYLVANIA
Cynthia C. Craig
Plaintiff
vs.
Clinton L. Craig
Defendant
:No.01-6593
: Civil Action - Law
ORDER
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And now this '1 tl.. day of October, 2006 upon the motion of H.
Anthony Adams, and after consideration of the facts set forth in the attached
petition, a hearing in the matter is scheduled for the ,J?t:A- day of G,tvbCI, 1.886 /1~
at ,og '00 o'clock am/@in Court Room No. , of the Cumberland 800 "
County Courthouse, Carlisle, Pennsylvania, 17013
By the Court,
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IN THE COURT OF COMMON PLEAS
OF CUMBELRAND COUNTY - PENNSYLVANIA
Cynthia C. Craig
: No. 01-6593
Petitioner
vs.
: Civil Action - Law
Clinton L. Craig
, Respondent
PETITION FOR SPECIAL RELIEF
Now comes the Petitioner, Cynthia C. Craig, by and through her attorney,
H. Anthony Adams and sets forth the following:
1.
Petitioner is Cynthia C. Craig, an adult individual who resides at 123
Timber Lane, Shippensburg, Cumberland County, Pennsylvania.
2.
Respondent is Clinton L. Craig, an adult individual, whose last known
address is 234 Neil Road, Shippensburg, Pennsylvania.
3.
On or about June 4, 2002, Petitioner entered into a marital agreement
with Respondent. Petitioner was not represented by counsel. A copy of the
marital agreement is attached hereto.
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As set forth in the paragraph entitled HUSBAND'S BEISTLE COMPANY
PENSION BENEFIT. Husband was to divide his pension with wife after
September 29, 2006.
5.
Contact was made with Beistle Corporation on September 29, 2006 Trishia
Lacey, the President of Beistle Corporation, informed Petitioner through counsel
that RespDndent had already been paid the pension benefit.
6.
Petitioner believes and therefore avers that Respondent has the pension
benefit proceeds which he does not intend to distribute and has little or no
assets other than the pension benefit proceeds from which to make distribution.
7.
Petitioner has retained the services of H. Anthony Adams to protect her
interest and anticipates a legal fee of approximately $5,000.00.
8.
It is anticipated that Respondent will dispose of the property to defeat his
obligation under the agreement.
Wherefore, Petitioner prays your Honorable Court conduct a hearing,
granting all appropriate relief to Petitioner together with, counsel fees and cost.
c:1\~~ -
H. Anthony Adams, Esquire
Attorney for Plaintiff
49 W. Orange Street, Suite 3
Shippensburg, PA 17257
(717)-532-3270
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VERIFICATION
We verify that the statements made in this Petition are true and correct.
We understand that false statements herein are made subject to the penalties of
18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities.
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Page I of8
MARITAL AGREEMENT
THIS AGREEMENT, made this 4 ,!J\.day of ~u (\J ,2002, by and between CLINTON L.
CRAIG, hereinafter referred to as Husband, presently of 234NeiI Road, Shippensburg, Cumberland
County, Pennsylvania 17257, and CYNTHIA C. CRAIG, hereinafter referred to as V@:'e, Pfi:se~y of
26 Maple Avenue, Walnut Bottom, Cumberland County, Pennsylvania, 17266-0917. ,,,is; ,~_:
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WITNESSETH:
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WHEREAS, the parties hereto are Husband and Wife, having been marriecJ;'41 D~mb6'~9,
1987, in Cwnberland CO\lnty, Per.l..u3ylvffiiia, \-villi no c:hiIdren having-been tom oftbe +ag;e; an.!t
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WHEREAS, diverse unhappy differences, disputes and difficulties have arisen between the
parties and it is the intention of Wife and Husband to live separate and apart, and the parties hereto are
desirous of settling some of their respective financial and property rights and obligations as between
each other including, without limitation by specification: the equitable division of marital property; and
the settling of all matters between them relating to the past, present and future support, alimony and lor
maintenance of Wife by Husband or of Husband by Wife.
NOW, THEREFORE, in consideration of the premises and of the mutual promises, covenants
and under takings hereinafter set forth which are hereby acknowledged by each of the parties hereto,
Wife and Husband, each intending to be legally bound hereby, covenant and agree as follows:
AGREEMENT NOT A BAR TO DIVORCE PROCEEDINGS
This Agreement shall not be considered to affect or bar the right of Wife or Husband to a limited
or absolute divorce on lawful grounds, if such grounds exist or shall hereafter exist or to such defense as
may be available to either party. This Agreement is not intended to condone and shall not be deemed to
be a condonation, on the part of either party hereto, of any act or acts on the part of the other party which
have occasioned the disputes or unhappy differences which have occurred prior to or which may occur
subsequent to the date hereof. The parties inlend iv se~ure a fnuLual consent, no-fault divorce p~rsuant
to the terms of Section 3301(c) of the Pennsylvania Divorce Code of 1980, as amended.
EFFECT OF DIVORCE DECREE
The parties agree that unless otherwise specifically provided herein, this Agreement shall
continue in full force and effect after such time as a final decree in divorce may be entered with respect
to the parties.
AGREEMENT TO BE INCORPORATED IN DIVORCE DECREE
The parties agree that the terms of this Agreement may be incorporated into any divorce decree.
which may be entered with respect to them.
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DATE OF EXECUTION
The "date of execution" or "execution date" of the Agreement shall be defined as the date upon
which it is executed by the parties if they have each executed the Agreement on the same date.
Otherwise, the "date of execution" or "execution date" of this Agreement shall be defined as the date of
execution by the party last executing this Agreement.
ADVICE OF COUNSEL
The provisions of this Agreement and their legal effect have been fully explained to Husband, by
Jerry A. Weigle, Esquire, who is attorney for Husband and who prepared this marital agreement. Wife
acknowledges that she has been advised of her right to seek independent legal counsel and she has
decided not to do so. Both parties acknowledge that they fully unders!fu'1d the facts ~,nd have been fully
informed as to their legal rights and obligations and understand the same. The parties hereto further
acknowledge and accept that this Agreement is, in the circumstances, fair and equitable and that it is
being entered into freely and voluntarily after having received such advice and with such knowledge,
and that execution of this Agreement is not the result of any duress or undue influence and that it is not
thc result of any collusion or improper or illegal agreement or agreements.
PERSONAL RIGHTS
Wifc and Husband may and shall, at all times hercafter, live separate and apart. They shall be
frcc from any control, rcstraint, interference or authority, dircct or indirect, by the other in all respects as
fillly as if they were unmarried. They may reside at such placc as they may select. Each may, for his or
hcr separatc usc or benefit, conduct, carry on and engage in any business, occupation, profession or
employment, which to him or her may seem advisablc. Wife and Husband shall not molest, harass,
disturb or malign each other or the respeetive families of each othcr nor compel or attempt to compcl the
other to cohabit or dwell by any means or in any manner whatsoever with him or her.
SEPARATION DATE
Thc parties do hereby acknowledge that although prcscntly residing at the same address. thcy
havc lived scparate and apart since Seplcmbci ii, ZOGi . It is hereby agreed that September 11,2001,
shall be the separation date for purposes of equitable distribution under the Pennsylvania Divorce Code
unless altcred by subsequent agreement of the parties in writing and signed by eaeh of the parties. No
attempt at reeonciliation shall be considered to alter the separation date unless evidenced by written
agreemcnt.
MOTOR VEHICLES
A. The parties agree that Wife shall beeome the sole and exclusive owner of the follo':Yil1g
motor vehicles and that Wife shall be solely responsible for all payments on the automobile loan(s') if'
any still exist for said vehicles and shall save Husband harmless from any repayment thereon.
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1. 1988 Ford Ranger Truck;
2. 1987 Force Escort GT; and
3. 1995 Pontiac Sunfire
B. The parties agree that Husband shall become the sole and exclusive owner of the parties'
1977 Chevrolet 0/. ton pick-up truck motor vehicle. Husband shall assume sole responsibility for any
loan or loans on said vehicle and shall save Wife harmless from any repayment on the same.
PERSONAL PROPERTY. BANK ACCOUNTS AND PETS
Husband and Wife do hereby acknowledge that they have previously divided their tangible
personal property, bank accounts and pets, including but not limited to jewelry, clothes, furniture
furnishings, rugs, carpets, household equipmem and appliances, vehicles, pictures, beoks, works of lk,.(
and other personal property and hereafter Wife agrees that all of the property in the possession of
Husband shall be the sole and separate property of Husband and Husband agrees that all of the property
in the possession of Wife shall be the sole and separate property of Wife. The parties do hereby
specifically waive, release, renounce and forever abandon whatever claims, if any, he or she may have
with respect to the above items, which shall become the sole and separate property of the other.
AFTER-ACOUlRED PERSONAL PROPERTY
Each of the parties shall hereafter own and enjoy, independently of any claim or right of the
othcr, all items of personal property, tangible or intangible, hereafter acquired by him or her, with full
power in him or her to dispose of the same as fully and effectively, in all respects and for all purposcs,
as though he or she were not married.
REAL EST ATE
The parties hereto acknowledge and agree that Wife is the owner of a residcncc locatcd at 26
Maple Avenue, Walnut Bottom, Pennsylvania, situate in South Newton Township, Cumberland County,
and more specifically described in Cumberland County Deed Book 249 at Page 1604. For and in
consideration of the mutual covenants and agreements herein contained in the body of this instrument,
Husband and Wife further stipulate and agree that said fl;ai esUi,e, togethci' with an 18':: 26' shop
building and 10'" 12' shed building located on the premises, shall be retained by Wife.
Parties acknowledge and agree that Wife has previously refinanced the parties' Allfirst Mortgage
obligation on the above-referenced marital residence in the approximate amount of Thirty-six Thousand
Dollars ($36,000.00) so as to remove Husband's name from said obligation. The parties further agrce
that Husband shall pay to Wife the full sum of Two Hundred Thirty-five Dollars ($235.00) per month to ,',
be used toward Wife's present mortgage obligation payment to Allfirst Bank in the approximate amount
of Thirty-two Thousand Dollars ($32,000.00) [payable in monthly payments of Four Hundred Seventy
Dollars ($470.00)]. Said obligation shall remain in effect for a period of one hundred twenty (120)
months or until said mortgage obligation is paid in full, whichever event shall first occur.
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HUSBAND'S BEISTLE COMPANY PENSION BENEFIT
The parties hereto acknowledge and agree that Husband has a retirement benefit through his
employer (The Beistle Company, Shippensburg, Pennsylvania) having an approximate present value of
Thirty-five Thousand Dollars ($35,000.00) which Husband may not withdraw without penalty until
September 29, 2006. The parties further agree to let said benefit accumulate until September 29, 2006,
at which time said benefit shall be withdrawn by Husband and divided equally with Wife.
WAIVER OF SPECIFIED CLAIMS BY HUSBAND
Husband hereby waives any and all right to claim any interest or share in Wife's present pension
benefit through Hoffman Mills, Inc., Shippensburg, Pennsylvania, valued at approximately Two
Thousand Five Hundred Dollars ($2,500.00)
WARRANTY AS TO EXISTING OBLIGATIONS
Each party represents that he or she has not heretofore incurred or contracted for any debt or
liability or obligation for which the estate of the other party may be responsible or liable except as may
be provided for in this Agreement. Each party agrees to indemnify and hold the other party harmless
from and against any and all such debts, liabilities or obligations of every kind which may have
hcretofore been incurred by them, including those for necessities, except for the obligations arising out
of this Agreement.
WARRANTY AS TO FUTURE OBLIGATIONS
Wife and Husband each covenant, warrant, represent and agree that each will now and at all
times hereafter save harmless and keep the other indemnified from all debts, charges and liabilities
incurred by the other after the execution date of this Agreement, except as may be otherwise specifically
provided for by the terms of this Agreement and that neither of them shall hereafter incur a liability
whatsoever for which the estate of the other may be liable.
LEGAL FEES
Husband shall pay the cost oflegal fees incurred in preparation of this marital agreement and all
legal fees and court costs in connection with obtaining a 3301(c) No-Fault Divorce. Wife agrees to
cooperate by executing the necessary consents and other documents required to effectuate said divorce,
as requested by Husband's attorney.
INCOME TAX RETURNS
The parties agree to file separate federal and state income tax returns.
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MUTUAL RELEASES
Husband and Wife each do hereby mutually remise, release, quitclaim and forever discharge the
other and the estate of each other, for all time to come, and for all purposes whatsoever, of and from any
and all rights, title and interest, or claims in or against the property (including income and gain from
property hereafter accruing) of the other or against the estate of such other, of whatsoever nature and
wheresoever situate, which he or she now has or at any time hereafter may have against such other, the
estate of such other or any part thereof, whether arising out of any former acts, contracts, engagements
or liabilities of such other or by way of dower, courtesy, or claims in the nature of dower or courtesy or
widow's or widower's rights, family exemption or similar allowance, or under the intestate laws, or the
right to take against the spouse's will; or the right to treat a lifetime conveyance by the other as
testamentary, or all other rights of a surviving spouse to participate in a deceased spouse's estate,
whether arising under the laws of (a) PennsylvaI,ia, (b) a."1y St.ate,' COffifaonwealth or territory of the
United States, or (c) any other country, except, and only except, all rights and agreements and
obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of
any provision thereof. It is the intention of Husband and Wife to give to each other by the execution of
this Agreement a full, complete and general release with respect to any and all property of any kind or
nature, real, personal or mixed, which the other now owns or may hereafter acquire, except and only
except all rights and agreements and obligations of whatsoever nature arising or which may arise under
this Agreement or for the breach of any provision thereof.
WAIVER OR MODIFICATION TO BE IN WRITING
No modification or waiver of any of the terms hereof shall be valid unlcss in writing and signed
by both parties and no waiver of any breach hereof or default hereunder shall bc dcemed a waiver of any
subsequent default of the same or similar nature.
DIVORCE
The parties hereto agree to enter into a mutual consent divorce under Section 3301(c) of the
Pennsylvania Divorce Code of 1980, as amended. Husband agrees to pursue the present divorce action
filed to No. 01-6593 Civil, 2001, in the Court of Common Pleas of Cumberland County, Pennsylvania,
and to be the Piiiintifftherein. Wife agrees to sign the necessary d;;c,Jmcnts, j,.1cluding the Affidavit of
Consent, at such time after the ninety (90) days of filing of the Complaint and further instruments that
may be reasonably required to give full force and effect to the provisions of this Agreement.
MUTUAL COOPERATION
Each party shall, at any time and from time to time hereafter, take any and all steps and execute,
acknowledge and deliver to the other party any and all future instruments and/or documents that the
other party may reasonably require for the purpose of giving full force and effect to the provisions of
this Agreement.
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LAW OF PENNSYL VANIA APPLICABLE
This Agreement shall be construed in accordance with the laws of the Commonwealth of
Pennsylvania.
AGREEMENT BINDING ON HEIRS
This Agreement shall be binding and shall insure to the benefit of the parties hereto and their
respective heirs, executors, administrators, successors and assigns.
BREACH.
If either party breaches any provision of l.<iis Agreement, the otllC1" party shall have the right, at
his or her election, to sue for damages for such breach or seek such other remedies or relief as may be
available to him or her, and the party breaching this contract shall be responsible for payment of legal
fees and costs incurred by the other in enforcing their rights under this Agreement.
WAIVER OF ALIMONY AND OTHER RIGHTS
The parties hereto have been informed of their rights or have been advised to seek counsel to
inform them of their rights under and pursuant to the Divorce Code, Action of April 2, 1980, Number
1980-26, as amended, particularly the provisions for alimony, alimony pendente lite, equitable
distribution of marital property, counsel fees or expenses. Both parties agree that this Agreement shall
conclusivcly provide for the distribution of property under the said law and except as specifically
provided for in this agreement, hereby waive, release and relinquish any further rights they may
respectively have against the other for alimony, alimony pendente lite, equitable distribution of marital
propcrty, counsel fees or expenses. From the date hereof, each party may acquirc either personal or real
propcrty in thcir own name. Any property so acquired shall be owncd solely by the individual and shall
not bc subject to any claim whatsocvcr by the other party.
FINANCIAL DISCLOSURE
Thc panics confirm that they have relied on the substantial :;;:cura'2}' of the financial disclosure
of the other as an inducement to the execution of this Agreement.
ENTIRE AGREEMENT
This Agreement constitutes the entire understanding of the parties and supersedes any and all
prior agreements and negotiations between them. There are no representations or warranties other than
those expressly set forth herein.
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NO WAIVER OF DEFAULT
This Agreement shall remain in full force and effect unless and until terminated under and
pursuant to the terms of this Agreement. The failure of either party to insist upon strict performance of
any of the provisions of this Agreement shall in no way affect the right of such party hereafter to enforce
the same, nor shall the waiver of any breach of any provision hereof be construed as a waiver of any
subsequent default of the same or similar nature, nor shall it be construed as a waiver of strict
performance of any other obligations herein.
SEVERABILITY
If any term, condition, clause or provision of this Agreement shall be determined or declared to
be void or invalid in law or othf,:rwise, then only that tF:rIn, c;mdition, clause or provisions shall be
stricken from this Agreement and in all other respects this Agreement shall be valid and continue in full
force, effect and operation. Likewise, the failure of any party to meet her or his obligations under any
one or more of the paragraphs herein, with the exception of the satisfaction of the conditions precedent,
shall in no way void or alter the remaining obligations of the parties.
HEADINGS NOT PART OF AGREEMENT
Any headings preceding the text of the several paragraphs and subparagraphs hereof are inserted
solely for convenience of reference and shall not constitute a part of this Agreement nor shall they affect
its meaning, construction or effect.
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 Agreemcnt is fair and cquitable, that it
is being entered into voluntarily, and that it is not the result of any duress or unduc influence.
IN WITNESS WHEREOF, the parties hereto have set their hands and seals the day and year first
above written. (
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On this, the t..j 'I.r- day of '-0 I 1\ P , 2002, before me a Notary Public,
the undersigned officer, personally appeared Clinton L. Craig, known to me to be the person whose
name is subscribed to the within Agreement and acknowledged that he executed the same for the
purposes therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and seal.
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Notarial Seal
Patricia L. Tome. Notary Public
Shlppensburg Boro, Cumberland County
My Commission f,Oires June 7, 2004
COMMONWEALTH OF PENNSYLVANIA
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On this, the 7 day of .;;:r; { rJ , 2002, before me a Notary Public,
the undersigned officer, personally appeared Cynthia C. Craig, known to me to be the person whose
name is subscribed to the within Agreement and acknowledged that she executed the same for the
purposes therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and seal.
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LAW OFFICE
H. ANTHONY ADAMS
49 WEST ORANGE STREET, SUITE 3
SHIPPENSBURG, PENNSYLVANIA 17257
TELEPHONE (717) 532-3270
FAX (717) 532-6673
September 29,2006
Beistle Corporation
1 Beistle Plaza
Shippensburg, PA 17257
To Whom It May Concern:
I represent Cynthia C. Craig the ex-spouse of your employee Clinton L.
Craig.
Pursuant to a marital agreement between the parties the retirement
benefit at Beistle was to remain with the corporation until September 29,2006
and was then to be withdrawn and divided between the parties.
Please accept this letter as notice the wife desires her share of the said
pension plan paid to her and her right and interest therein.
Please forward any and all documents required for distribution to me.
Sincerely,
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H. Anthony Adams
HAA: dmb
cc: Jerry Weigle, Esquire
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IN THE COURT OF COMMON PLEAS
OF CUMERLAND COUNTY - PENNSYLVANIA
o 1-{,,5'i3
Cynthia C. Craig No. 96-(i!l'3
Plaintiff
vs.
Civil Action - Law
Clinton Craig
Defendant
PRAECIPE FOR ENTRY OF APPEARANCE OF COUNSEL
To the Prothonotary:
Please enter my appearance on behalf of the Defendant, Clinton Craig.
Dated:
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WEIGLE & ASSOCIATES, RC. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397
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IN THE COURT OF COMMON PLEAS
OF CUMERLAND COUNTY - PENNSYLVANIA
O/-~5Q3
Cynthia C. Craig No:1l6-6S93
Plaintiff
vs.
Civil Action - Law
Clinton Craig
Defendant
RESPONDENT'S ANSWER TO PETITION FOR SPECIAL RELIEF
AND NOW comes the Respondent, Clinton L. Craig, by and through his attorney,
Jerry A. Weigle, Esquire, who answers the Petition for Special Relief filed by Cynthia C.
Craig as follows:
1.
Admitted
2.
Admitted in Dart and denied in Dart
It is admitted that Clinton L. Craig, the Respondent herein, is an adult, sui juris
adult. His address stated in the Petition is in error. By way of further answer,
Respondent's current address is lIB Spruce Street, Mt Alto, Franklin Co. Pennsylvania
17237.
3.
Admitted
4.
Admitted
By way of further clarification, the intent of the parties was to divide
Respondent's Beistle Company Pension benefits on September. 29, 2006, or shortly
thereafter, because the parties assumed that such could be withdrawn at that time without
penalty.
WEIGLE & ASSOCIATES, P.c. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397
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Denied as stated
The Respondent is without sufficient information for form a belief as to either the
accuracy or relevance of the allegations contained in paragraph 5 of the Petition, and
strict proof thereof is demanded if at all relevant to this proceeding.
6.
Denied
Respondent does not physically have the Beistle Company pension benefit
proceeds in his possession and had no intent and has no present intent to deny Petitioner
her share of that pension benefit. By way of further answer, Respondent rolled over said
benefit to another plan in late September or early October 2006, when advised by Beistle
Company personnel of the taxes to be withheld and early withdrawal penalties he would
occur by a cash withdrawal of his said Beistle Company pension benefit. Furthermore,
Respondent is willing to enter into an Agreement with Petitioner to be enforced by an
Order of Court not to withdraw or modify his current pension benefit without further
Order of Court and to divide the same equally with Petitioner at the earliest possible time
that the benefit can be divided without penalty.
7.
Denied
It is specifically denied that Petitioner will incur reasonable legal fees of$5000.00
or that Respondent has a legal obligation to pay Petitioner's reasonable legal fees in this
matter, whatever they may be, and strict proof to the contrary is demanded at a hearing on
the Petition filed.
8.
Denied
Respondent's answer to paragraphs 1 through 7 of the Petition are incorporated
herein by reference hereto. By way of further answer, Respondent's actions will
substantially benefit both parties herein and were carried out only upon being made
aware of the mutual mistake of fact made by the parties relative Respondent's Beistle
Company benefit.
WEIGLE & ASSOCIATES, RC. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397
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WHEREFORE, Respondent prays your Honorable Court to deny Petitioner's request as
stated and to grant appropriate relief that will protect the interest's of both parties hereto
aIld to specifically deny counsel fees to Petitioner, since this matter could have been
easily resolved without Court intervention and without the involvement of much time
expended on behalf of the petitioner by counsel.
WEIGLE & ASSOCIATES, P.C.
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WEIGLE & ASSOCIATES, P.c. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPF'ENSBURG, PA 17257-1397
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VERIFICATION
I verify that the statements made ,in the foregoing Answer to
Petition for Special Relief 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.
Dated:
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Clinton L. Craig ~
WEIGLE & ASSOCIATES, P.C. - ATTORNEYS AT LAW - 126 EAST KING STREE':T - SHIPPENSBURG, PA 17257-1397
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IN THE COURT OF COMMON PLEAS
OF CUMERLAND COUNTY - PENNSYLVANIA
Cynthia C. Craig
No. 06-6593
Plaintiff
vs.
Civil Action - Law
Clinton Craig
Defendant
CERTIFICATE OF SERVICE
AND NOW, this 7~ day of ~~ , 2006, I, Patricia A. Frey, Office MaIlager,
hereby certifY that I have this day served the following person with a copy of the foregoing
docllnlent, by depositing same in the United States Mail, First Class, Postage Prepaid, addressed as
follows:
H. Anthony Adams, Esquire
49 West Orange Street Suite 3
Shippensburg, P A 17257
WEIGLE & ASSOCIATES, P.C.
Patricia A. Frey, Office M
126 East King Street
Shippensburg, P A 17257
Telephone; (717)532-7388
WEIGLE & ASSOCIATES, Pc. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397
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