HomeMy WebLinkAbout01-06827
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IN THE COURT OF COMMON PLEAS
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OF CUMBERLAND COUNTY
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STATE OF
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TAMARA S. STINE,
Plaintiff
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VERSUS
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MARK K. STINE,
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Defendant
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PENNA.
No. 01-6827
DECREE IN
DIVORCE
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AND NOW,
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2-'1
2002
, IT IS ORDERED AND
TAMARA S. STINE
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DECREED THAT
MARK K. STINE
, DEFENDANT,
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AND
, PLAINTIFF,
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ARE DIVORCED FROM THE BONDS OF MATRIMONY.
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECOflJ.-lN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED; VV~
All matters have been resolved pursuant to the Marital Settlement
Agreement reached by the parties dated September 3, 2002 and
incorporated, but not merged, into the Decree.
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PROTHONOTARY .
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Barbara Sump Ie-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, P A 17070
(717) 774-1445
TAMARA S. STINE,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 01-6827
MARK K. STINE,
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 93301(c) of the Divorce
Code.
2. Date and manner of service of the complaint: Acceptance of Service dated
December 10, 2001.
3. Date of execution of the affidavit of consent required by 9 3301(c) of the Divorce
Code: by Plaintiff September 10, 2002; by Defendant September 3, 2002.
4. Related claims pending: All matters have been resolved pursuant to the Marital
Settlement Agreement reached by the parties dated September 3, 2002 and incorporated,
but not merged, into the Decree.
5. Date Plaintiff's Waiver of Notice in S3301(c) Divorce was fIled with Prothonotary:
September 11, 2002. Date Defendant's Waiver of Notice in 93301(c) Divorce was fIled with
Prothonotary: September 11, 2002.
arbara Sumple-Sullivan, Esquire
549 Bridge Street
New Cumberland, PA 17070-1931
(717)-774-1445
Supreme Court ID #32317
Attorney for Plaintiff
Dated: September'/o , 2002
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Barbara Sump1e-SuIlivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, pA 17070
(717) 774-1445
TAMARA S. STINE,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 01-6827
MARK K. STINE,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
CERTIFICATE OF SERVICE
I, Barbara Sumple-Sullivan, Esquire, do hereby certify that on this date, I served a true
and correct copy of the foregoing Praecipe to Transmit Record, in the above-captioned
matter upon the following individual by first class mail, postage prepaid, addressed as follows:
Mr. Mark K. Stine
1117 Wansford Road
Mechanicsburg, PA 1 5
Barbara Sumple-Sullivan, Esquire
Attorney for Plaintiff
549 Bridge Street
New Cumberland, PA 17070-1931
(717) 774-1445
Supreme Court J.D. No. 32317
DATED: September /.fL, 2002
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NUUUTALSETTLEMENTAGREEMENT
THIS AGREEMENT, made this .J..tj day o~ ~02, by and
between MARK K. STINE, hereinafter referred to as "HUSBAND", and TAMARA S. STINE,
hereinafter referred to as "WIFE".
WITNESSETH, That:
WHEREAS, the parties hereto are husband and wife, having been lawfully joined in
marriage on May 22,1992 in Cumberland County, Pennsylvania;
WHEREAS, two (2) children were born of this marriage being Paul K. Stine, born April
16, 1994 and Meredith F. Stine, born April 6, 1997;
WHEREAS, it is the intention of the parties to settle fully and finally their respective
financial and property rights and obligations as between each other arising out of the marriage
relationship or otherwise, including without limitation (1) the settling of all matters between
them relating to the ownership of real and personal property; (2) the settling of all matters
between them relating to the past, present and future support and/or maintenance of HUSBAND
and WIFE; (3) the settling of all matters between them relating to the past, present and future
support or maintenance of their minor children, and (4) the settling of all matters between them
relating to any and all rights, titles and interests, claims and possible claims in or against the
estate of the other.
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NOW THEREFORE, with the foregoing recitals being hereinafter incorporated by
reference and deemed an essential part hereof in consideration of the foregoing recitals, the
mutual promises, covenants and undertakings herein set forth, and for good and valuable
consideration, receipt of which is hereby acknowledged by each of the parties hereto,
HUSBAND and WIFE, each intending to be legally bound hereby, covenant and agree as
follows:
SECTION I
GENERAL PROVISIONS
1. ADVICE OF COUNSEL
HUSBAND and WIFE declare that they have each had a full and fair opportunity to
obtain independent legal advice of counsel of their selection. WIFE has been independently
represented by Barbara Sumple-Sullivan, Esquire. HUSBAND is cognizant of his right to legal
representation and declares that he has chosen not to retain an attorney notwithstanding the fact
that attorney for WIFE has told him that he has an absolute right to be represented by an attorney.
HUSBAND has chosen instead to negotiate directly with counsel and/or with his WIFE.
HUSBAND hereby acknowledges that he has done so willingly and the he fully understands the
facts and has been fully informed and understands that, had a Court decided this matter, he may
have received more or less than is provided for in this Agreement. HUSBAND knowingly
waives his rights, if any, to utilize the lack of her legal representation as a basis to attack the
validity of this Agreement.
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Both parties further acknowledge and agree that each has fully disclosed their respective
financial situations to the other, including their assets, liabilities and income. Each of the parties
acknowledge and agree that, after having received such information and with such knowledge,
this Agreement is fair, reasonable and equitable and that it is being entered into freely,
voluntarily and in good faith and that the execution ofthis Agreement is not the result of any
duress, undue influence, coercion, collusion and/or improper or illegal Agreement.
2. PERSONAL RIGHTS
HUSBAND and WIFE may and shall, at all times hereafter, live separate and apart. Each
shall be free from all control, restraint, interference or authority, direct or indirect, by the other in
all respects as if she or he were unmarried, except as may be necessary to carry out the provisions
of this Agreement. Each may reside at such place or places as she or he 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. This provision shall not be
taken, however, to be an admission on the part of either HUSBAND or WIFE of the lawfulness
ofthe causes which led to, or resulted in, the continuation of their living apart. HUSBAND and
WIFE shall not molest, harass, or malign the other or the respective families of each other, nor
compel the other to cohabit or dwell in any manner with him or her, nor in any way interfere with
the peaceful existence, separate from each other.
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3. FINANCIAL DISCLOSURE
The parties have fully disclosed to each other the extent of each other's income, assets,
liabilities, holdings and estate. Each party warrants that the information provided has fully and
accurately described the extent of his or her holdings. Each of the parties acknowledge that he or
she is aware of his or her right to seek discovery including, but not limited to, written
interrogatories, motions for document production, depositions, and other means of discovery
available through the Pennsylvania Rules of Civil Procedure. The parties acknowledge that they
have had the right to have property fully appraised. Each party is fully satisfied that no additional
information is necessary for the execution of this Agreement.
4. MUTUAL CONSENT DIVORCE
The parties intend to secure a mutual consent, no fault divorce pursuant to the provisions
of Section 330l(c) of the Divorce Code of 1980, as amended and will execute the documents
necessary to effectuate a divorce under those provisions concurrently with the execution of this
Agreement.
5. SUBSEOUENT DIVORCE
A decree in divorce, entered by the court of Cumberland County, shall not suspend,
supersede or affect the terms of this Agreement. This Agreement, and the terms and conditions
contained herein, as well as the enforcement of said terms and conditions, shall not be contingent
upon the granting of a Divorce Decree to either party by the Court of Common Pleas of
Cumberland County, Pennsylvania, or any other Court of competent jurisdiction. This
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Agreement shall remain in full force and effect even if the parties reconcile, cohabit as
HUSBAND and WIFE, or attempt reconciliation. This Agreement shall continue in full force
and effect and there shall not be a modification or waiver of any of the terms hereof unless the
parties, in a writing signed by both parties, execute a statement declaring this Agreement or any
tcrm ofthis Agreement to be null and void. Both parties hereto agree that this Agreement may
be incorporated by reference but shall not be deemed mcrged into any judgment or decree for
divorce obtained by either party.
6. OTHER DOCUMENTATION
HUSBAND and WIFE covenant and agree that upon request of the other party, they will
forthwith execute and deliver to the other party, any and all written instruments, assignments,
releases, satisfactions, deeds, notes or such other writings as may be necessary or desirable for
the proper effectuation of this Agreement.
,. MUTUAL RELEASES
Except as otherwise expressly provided by this Agreement.
A. Each party hereby absolutely and unconditionally releases and forever discharges
the other and the estate of the other for all purposes from any and all rights and obligations which
either may have or at any time hereafter have for past, present or future support or maintenance,
alimony pendente lite, alimony, equitable distribution, counsel fees, costs, expenses and any
other right or obligation, economic or otherwise, whether arising out ofthe marital relationship
or otherwise, including all rights and benefits under the Pennsylvania Divorce Code of 1980, its
supplements and amendments, as well as under any other law of any other jurisdiction, except
and only except all rights, agreements and obligations of whatsoever nature arising or which may
arise under this Agreement or for the breach of any provision thereof. Neither party shall have
any obligation to the other not expressly set forth herein.
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B. Each party hereby absolutely and unconditionally releases and forever discharges
the other and his or her 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 of
the parties or otherwise, whether now existing or hereafter arising. The above release shall be
effective regardless of whether such claims arise out of any former or future acts, contracts,
engagements or liabilities or the other or by way of dower, curtesy, widow's rights, family
exemption or similar allowance, or under the intestate laws, or the right to take against the
spouse's will, or the right to treat a lifetime conveyance by the other as testamentary, or all other
rights of a surviving spouse to participate in a deceased spouse's estate, whether arising under the
laws of Pennsylvania, any state, commonwealth or territory or the United States, or any other
country. It is expressly understood, however, that neither the provisions of this release nor the
subsequent entry of a divorce decree are intended to defeat the right of either party to receive any
insurance proceeds at the death of the other of which she or he is the named beneficiary (whether
the beneficiary designation was made prior or subsequent to execution hereof), nor to defeat the
right of either party to receive any legacy, bequest or residuary portion ofthe other's estate under
his or her will, or to act as personal representative or executor if so named by the will of the
other, whether such will was executed prior or subsequent to this Agreement.
C. Except for any cause of action for divorce which either party may have or claim to
have, and except for the obligations of the parties contained in this Agreement and such rights as
are expressly reserved herein, each party gives to the other by the execution of this Agreement 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.
8. SUCCESSOR'S RIGHTS AND LIABILITIES
This Agreement shall, except as otherwise provided herein, be binding upon and inure to
the benefit of the parties hereto, their respective heirs, executors, administrators, successors or
assigns.
9. SEVERABILITY
If any provision in this Agreement is held by a court of competent jurisdiction to be
invalid, void, or unenforceable, the remaining provisions shall nevertheless continue in full force
and effect without being impaired or invalidated in any way.
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10. ENTIRE AGREEMENT
HUSBAND and WIFE do hereby covenant and warrant that this Agreement contains all
of the representations, promises and Agreements made by either of them to the other for the
purposes set forth in the preamble hereinabove; that there are no claims, promises or
representations not herein contained, either oral or written, which shall or may be charged or
enforced or enforceable unless reduced to writing and signed by both of the parties hereto.
11. BINDING EFFECT OF AGREEMENT/WAIVER
This Agreement shall remain in full force and effect unless and until terminated under
and pursuant to the terms ofthis Agreement.
The failure of either party to insist upon strict performance of the provisions of this
Agreement shall not be construed as a waiver of any subsequent default of the same or similar
nature, nor shall such failure be construed as a waiver of any other term, condition, clause or
provision of this Agreement.
12. 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 reasonable legal fees and costs incurred by the other in enforcing their rights
under this Agreement.
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13. CONTROLLING LAW
This Agreement shall be construed and governed in accordance with the laws of the
Commonwealth of Pennsylvania.
SECTION II
EQUITABLE DISTRIBUTION
During the marriage, the parties have accumulated various assets and liabilities, the
disposition of which is intended as follows:
1. ASSETS
A. PERSONAL and HOUSEHOLD PROPERTY
HUSBAND and WIFE do hereby acknowledge that they have heretofore divided
the non-marital and marital personal and household property, including but without limitation,
jewelry, clothes, furniture, and other assets. HUSBAND agrees that all assets in possession of
WIFE or titled in WIFE's name shall be the sole and separate property of WIFE and, WIFE
agrees that all assets in the possession of HUSBAND or titled in HUSBAND's name shall be the
sole and separate property of HUSBAND. Each of the parties do hereby specifically waive,
release, renounce and forever abandon whatever claims, if any, he or she may have with respect
to any of the above said items which are the sole and separate property of the other.
This document shall constitute a bill of sale for said sole property.
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B. REAL ESTATE
The parties jointly own property at 1117 Wansford Road, Mechanicsburg, Cumberland
County, Pennsylvania. Said house has an estimated market value of THREE HUNDRED
FIFTEEN THOUSAND DOLLARS ($315,000.00). Said property is encumbered by a mortgage
held by Equity One, Inc. in the approximate amount of TWO HUNDRED FIFTY-SEVEN
THOUSAND DOLLARS ($257,000.00). WIFE desires to maintain said home and reside therein
with the children. HUSBAND agrees to convey his interest in this real estate to WIFE. WIFE
shall be fully responsible for any past, present and future principal, interest, penalties and costs as
well as any taxes, insurance and/or any debts associated with the real estate. WIFE hereby agrees
to indemnify and hold HUSBAND harmless from any and all liability as a result of non-payment
of the mortgage or any other obligations as enumerated above associated with the real estate.
HUSBAND agrees to execute a deed simultaneously with the execution of this Agreement
wherein he assigns, conveys and transfers to WIFE all of his interest, rights and title in the
marital residence.
c. MOTOR VEHICLES
There are two vehicles owned by the parties. WIFE shall have sole ownership of the 1995
Oldsmobile Silhouette. HUSBAND shall have sole ownership ofthe 2001 Oldsmobile Aurora.
The Oldsmobile Aurora is subject to a loan payment of which shall be the sole obligation of
HUSBAND. HUSBAND agrees to indemnify and hold WIFE harmless from any obligation due
and owing on said vehicle. HUSBAND agrees to seek a release of WIFE from said loan
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obligation. WIFE and HUSBAND agree to execute all documents necessary to effectuate the
provisions ofthis paragraph within thirty (30) days of the date of execution of this agreement.
D. FINANCIAL ASSETS
The parties have the following financial assets and agree to distribution as follows:
WIFE:
WIFE has the following accounts in her name.
VANGUARD Profit Sharing Plan (As of 12/31/01)
MFSIRA (As of 12/31/01)
$12,844.09
$ 6,507.40
The above referenced assets shall become the sole and separate property of WIFE.
HUSBAND hereby waives and relinquishes all claims, title and interest in said assets.
HUSBAND:
HUSBAND has the following accounts in his name.
Prudential Financial 401 (K)
(As of 12/31/01)
$21,889.92
The above referenced asset shall become the sole and separate property of HUSBAND.
WIFE hereby waives and relinquishes all claims, title and interest in said assets.
E. PENSION
Through his employment, HUSBAND has also vested in two pension defined benefit
plans. The first is the Commonwealth of Pennsylvania State Employee Retirement System. It has
a vested benefit value of$232.20 presently and $635.91 at the time of normal retirement. He
also has a benefit through the Pennsylvania Automotive Association Pension Plan which has an
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accrued monthly pension payable of $823.00 at normal retirement age. The actual value of
HUSBAND'S P AA Pension, as of date.of separation is $26,863.87. HUSBAND shall retain
both pensions as his sole and separate property.
F. INSURANCE
Each party shall retain ownership of any life insurance policy in his or her name.
HUSBAND warrants that no cash value exists in his life insurance. WIFE shall maintain her
ING insurance policy which has a cash value of$9,906.35.
Further, HUSBAND agrees to carry life insurance in a sum of not less than TWO
HUNDRED FIFTY THOUSAND DOLLARS ($250,000.00) on himself until the parties'
daughter, Meredith, reaches the age of eighteen (18) years. WIFE shall be named as irrevocable
beneficiary and trustee for the benefit ofthe children. HUSBAND shall provide proof of the
existence of said policy to WIFE on an annual basis.
G. BUSINESS INTEREST
WIFE operates a business in government relations and lobbying. Said business shall be
sole property of WIFE and HUSBAND waves any interest therein.
H. CASH PAYMENT TO HUSBAND
WIFE shall pay to HUSBAND the sum of$17,500.00. This payment shall be made
within sixty (60) days ofthe date of this Agreement.
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2. DEBTS
Each party represents that they have not contracted any debt or liability for the other for
which the estate of the other party may be responsible or liable except as otherwise provided
herein, and that except only for the rights arising out of this Agreement, neither party will
hereafter incur any liability whatsoever for which the other party or the estate of the other party
will be liable. Each party agrees to indemnifY and hold harmless from and against all future
obligations of every kind incurred by them, including those for necessities.
The parties confirm that no marital debts exist. The parties also confirm that all joint
credit cards are terminated.
SECTION III
CHILD SUPPORT, ALIMONY
1. SPOUSAL SUPPORT/ ALIMONY PENDENTE LITE/ALIMONY
Both parties acknowledge and agree that the provisions of this Agreement providing for
equitable distribution of marital property are fair, adequate and satisfactory to them and are
accepted by them in lieu of and in full and final satisfaction of any claims or demands that either
may now or hereafter have against the other for support, maintenance, alimony or alimony
pendente lite. HUSBAND and WIFE further, voluntarily and intelligently, waive and relinquish
any right to seek from the other any payment for spousal support, alimony, alimony pendente lite
and maintenance.
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2. CHILD SUPPORT
The parties agree that HUSBAND shall pay to WIFE the sum of ONE THOUSAND ONE
HUNDRED DOLLARS ($1,100.00) per month for support of their children. Said sum shaH be
paid directly to WIFE in two equal installments of FIVE HUNDRED FIFTY DOLLARS
($550.00) per month on the first and fifteenth day of each month. In addition to the base support,
HUSBAND agrees to pay to WIFE the sum equal to forty-three (43%) percent of the day care
expense incurred by WIFE, as well as forty-three (43%) percent of all non-covered medical
expenses. Said expenses shall be paid to WIFE within twenty (20) days of WIFE's presenting to
HUSBAND documentation of said costs. HUSBAND shall agree to continue to provide medical
insurance for the children. In the event HUSBAND fails to make the payments of support within
five days of their due date, WIFE shaH have the right to have this order entered for enforcement
at Domestic Relations for garnishment of HUSBAND's income. Either party shall have the right
to have this matter reviewed and administered through Domestic Relations upon the occurrence
of a changed circumstance.
3. CUSTODY
The parties shall share legal custody ofthe children. WIFE shall have primary physical
custody of the children subject to the following periods of partial custody with HUSBAND:
a)
b)
c)
d)
e)
t)
Every Friday from after work until Saturday at 12:00 noon;
Alternating Saturdays from 12:00 noon to Sunday at 12:00 noon;
Every Wednesday evening at the home of WIFE;
Each Thanksgiving morning through dinner at 4:00 p.m.
One week of vacation with the HUSBAND per calendar year; and
Such other times as the parties can mutually agree.
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4. COLLEGE EXPENSES
The parties agree that they shall be equally obligated to pay for the college expenses for
their children. In order to establish an agreement on the amount of expense, WIFE and
HUSBAND agreed to share equally the children's tuition, room, board, books, and fees for a full
time student at the main campus ofPeun State University at the time of the respective child's
emollment
SECTION IV
1. CONDITION PRECEDENT TO THE AGREEMENT'S EFFECTIVENESS
The parties acknowledge that this Agreement shall become effective when actually signed
by both parties.
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WITNESS
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TAMARA S. STINE
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COMMONWEALTH OF PENNSYLVANIA
COUNTY OF ~AUp t\qJ
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Before me, the undersigned officer, a Notary Public in and for said Commonwealth and
County, personally appeared MARK K. STINE who being duly affirmed according to law,
deposes and says that the facts and matter set forth in the within and foregoing Marital
Settlement Agreement are true and correct to the best of his knowledge, information and belief.
Affirmed and subscribed to before me this3 r) day of~QYI~ 2002.
My commission expires:
NOTARIAL SEAL
YVONNE L. PATURZO, Notary Public
Harrisburg, Dauphin County (SEAL)
My Commission Expires June 19, 2004
COMMONWEALTH OF PENNSYLVANIA
)
) SS.
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COUNTY OF CUMBERLAND
Before me, the undersigned officer, a Notary Public in and for said Commonwealth and
County, personally appeared TAMARA S. STINE, who being duly affirmed according to law,
deposes and says that the facts and matter set forth in the within and foregoing Marital
Settlement Agreement are true and correct to the best of her knowledge, information and belief.
~A plJDUe
. My commission expires:
ub ribed to before me this / If~ day Of~002.
(SEAL)
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Barbara Sump1e-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, P A 17070
(717) 774-1445
v.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 6/-iP'r.2.1 ~ "'f~
TAMARA S. STINE,
Plaintiff
MARK K. STINE,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
YOU HA VB 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 and visitation of your children.
When the gronnds for a divorce is indignities or irretrievable breakdown of the marriage,
you may request marriage connseling. A list of marriage connselors is available in the Domestic
Relations Office at the Connty Courthouse.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED,
YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
Carlisle, Pennsylvania 17013
(717) 249-3166
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Barbara Sump1e-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, P A 17070
(717) 714-1445
v.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 01- t.f':z 7 ~ I.w-.-
TAMARA S. STINE,
Plaintiff
MARK K. STINE,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
COMPLAINT IN DIVORCE
1. Plaintiff is Tamara S. Stine, an adult individual residing at 1117 Wansford Road,
Mechanicsburg, Cumberland County, Pennsylvania 17050.
2. Defendant is Mark K. Stine, an adult individual residing at 1117 Wansford Road,
Mechanicsburg, Cumberland County, Pennsylvania 17050.
3. Both Plaintiff and Defendant have been bona fide residents in the Commonwealth
of Pennsylvania for at least six (6) months prior to filing this complaint.
4. The Plaintiff and Defendant were married on May 22, 1992 in Cumberland County,
Pennsylvania.
5. There are two (2) minor children born of this marriage, being Paul K. Stine, born
April 16, 1994; and Meredith F. Stine, born April 6, 1997.
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6. The parties separated on November 1,2001.
7. There have been no prior actions for divorce or annulment between the parties.
8. Neither Plaintiff nor Defendant is in the military or naval service of the United States
or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of
1940 and its amendments.
9. Plaintiff has been advised that counseling is available and that Plaintiff has the right
to request that the court require the parties to participate in counseling.
COUNT I - DIVORCE
NO FAULT
10. The averments in paragraphs I through 9, inclusive, of Plaintiff's Complaint are
incorporated herein by reference thereto.
11. The marriage is irretrievably broken and no possibility of reconciliation exists.
WHEREFORE, Plaintiff requests entry of a divorce decree in her favor in accordance with
S 3301 of the Pennsylvania Divorce Code.
2
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WHEREFORE, Plaintiff, Tamara S. Stine, prays this Honorable Court to enter judgment:
A. Awarding Plaintiff a decree in divorce; and
B. Awarding other relief as the Court deems just and reasonable.
Dated: November 29,2001
.. Barbara Sumple-Sullivan, Esquire
Attorney for Plaintiff
549 Bridge Street
New Cumberland, PA 17070-1931
(717) 774-1445
Supreme Court I.D. No. 32317
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Barbara Sump Ie-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, P A 17070
(717)774-1445
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01-- (" 'tJ...1 ~ T"-<-
TAMARA S. STINE,
Plaintiff
MARK K. STINE,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT REGARDING COUNSELING
I. I have been advised of the availability of marriage counseling and understand that
I may request that the Court require that my spouse and I participate in counseling.
2. I understand that the Court maintains a list of marriage counselors in the Domestic
Relations Office, which list is available to me upon request.
3. Being so advised, I do not require that the Court require that my spouse and I
participate in counseling prior to a divorce decree being handed down by the Court.
I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A
Section 4904 relating to unsworn falsification to authorities.
Dated: ~ OJ 0
,
,2001
~xI~
TAMARA S. STINE
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Barbara Sump1e-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, P A 17070
(717) 774-1445
TAMARA S. STINE,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO.
MARK K. STINE,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
VERIFICATION
I, TAMARA S. STINE, hereby certify that the facts set forth in the foregoing
COMPLAINT IN DIVORCE are true and correct to the best of my knowledge, information and
belief. I understand that any false statements made herein are subject to penalties of 18 Pa. C.S.A.
Section 4904 relating to unsworn falsification to authorities.
Dated: Jh; rX <( / Jd3 /
/L/~
TAMARAS. STINE
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Barbara Sump1e-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, PA 17070
(717) 774-1445
TAMARA S. STINE,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 01-6827
MARK K. STINE,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
93301(c) OF THE DIVORCE CODE
1. I consent to the entry of a final decree of divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses if! do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by the
Court and that a copy ofthe decree will be sent to me immediately after it is filed with the
prothonotary.
I verify that the statements made in this affidavit are true and correct. I understand that
false statement herein are made subject to the penalties of 18 Pa.C.S. 94904 relating to unsworn
falsification to authorities.
DATE: '01...
~L
MARK K. STINE
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COMMONWEALTH OF PENNSYLVANIA
COUNTYOF0AVphi.J
)
) SS.
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Before me, the undersigned officer, a Notary Public in and for said Commonwealth and
County, personally appeared MARK K. STINE, who being duly affirmed according to law,
deposes and says that the facts and matter set forth in the within and foregoing WAIVER OF
NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER
93301(c) OF THE DIVORCE CODE are true and correct to the best of his knowledge,
information and belief.
Affirmed and subscribed to before me this 3 rJ day orjt;p!elYlbu,.-;2002.
NOTARIAL SEAL
YVONNE L. PATURZO, Notary Public
Harrisburg, Dauphin County
My Commission Expires June 19,2004
(SEAL)
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Barbara Sump Ie-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, PA 17070
(717) 774-1445
TAMARA S. STINE,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 01-6827
Defendant
CIVIL ACTION - LAW
IN DIVORCE
MARKK. STINE,
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
November 30, 2001.
2. The marriage of the Plaintiff and Defendant is irretrievably broken. Ninety days
have elapsed since the 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.
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 verify that the statements made in this affidavit are true and correct. I
understand that false statements are made subject to the penalties of 18 Pa. C.S.A. Section 4904
relating to unsworn falsification to authorities.
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""---TAMARA S. STINE
DATE~ t.r /0., 2&oZ-
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Barbara Sump1e-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, P A 17070
(717) 774-1445
TAMARA S. STINE,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 01-6827
Defendant
CIVIL ACTION - LAW
IN DIVORCE
MARK K. STINE,
WAIVER OF NOTICE OF INTENTION TO REOUEST
ENTRY OF A DIVORCE DECREE UNDER
~3301(c) OF THE DIVORCE CODE
I. 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 statement herein are made subject to the penalties of 18 Pa.C.S. S4904 relating to unsworn
falsification to authorities.
DATE:~ 10,1 ZooZ--
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Barbara Sump1e-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, P A 17070
(717) 774-1445
TAMARA S. STINE,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 01-6827
MARK K. STINE,
CIVIL ACTION - LAW
IN DIVORCE
Defendant
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
November 30, 2001.
2. The marriage of the Plaintiff and Defendant is irretrievably broken. Ninety days
have elapsed since the 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.
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 verify that the statements made in this affidavit are true and correct. I
understand that false statements are made subject to the penalties of 18 Pa. C.S.A. Section 4904
relating to unsworn falsification to authorities.
lL
DATE:~
MARK K. STINE
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COMMONWEALTH OF PENNSYLVANIA
COUNTY O(:Wupk-.J
)
) SS.
)
Before me, the undersigned officer, a Notary Public in and for said Commonwealth and
County, personally appeared MARK K. STINE, who being duly affirmed according to law,
deposes and says that the facts and matter set forth in the within and foregoing AFFIDAVIT OF
CONSENT are true and correct to the best of his knowledge, information and belief.
Affirmed and subscribed to before me this 3r J day or;pi-J'A h n.~2002.
OT PUBLIC
y Commission Expires:
NOTARIAL SEAL
VONNE L PATURZO, Notary Public
Harrisburg, Dauphin County
My Commission Expires June 19, 2004
(SEAL)
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Barbara Sump1e-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, P A 17070
(717) 774-1445
TAMARA S. STINE,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 01-6827
MARK K. STINE,
: CIVIL ACTION - LAW
: IN DIVORCE
Defendant
ACCEPTANCE OF SERVICE
I, MARK K. STINE, hereby personally accept service and acknowledge receipt of the
above-captioned Complaint in Divorce, having received said Complaint on the IJii day of .
UcUMllo^-
, 2001.
L~
K. STINE
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