Loading...
HomeMy WebLinkAbout99-01441 .~ ~ '1 t) " .,~ .,'~ ..~ 1 v .~ :-- - .':) ....: , ,>, ........ ,...,r ;..... '. '",,:,.,',', !I~ :2:~ ~.~~:}:':"':' , ?~tW7~<."~: ",.~: ,u,~,.., J!,t(~: ,',', ..,t~. ~@l"" '~"'W7i~t~ ',"^ .'*' ,;c. -...;. '*' '*' ~...' olOIo ~ ~'leo ~.;c. ,;c. .:.;. olOIo .;,t:..;oc. oW, .;c. ';,t:""-:C""leI<~.":C-...:C- -:+:' ~C-<C-::<4C(~ ~I -'- --~------ _"'~ ~ ?- ~ g ~ ~ ;'~ ~ ~ f.~ ~ ~.~ *- ... ;,; 8 ~ ~ ;II; ~ ,...-;. -'~},,:~:' .~:. .:ti ~ ~ ~ ,.; ~ ~ .' .'. ~ ~ ~ ~.I ~ ~.~ ~ ~.I ~ ~ ~ ~ ~ IN THE COURT OF COMMON PLEAS ;. " ~ ~ OF CUMBERLAND COUNTY STATE OF ;*t PENNA, ~ ~i .'/ ~ ,', ~ JUDY BEECHER, ~ $ i\: I), 99~1441 19 Plaintiff 8 \'PI':;II:-; ~ ~ DENNIS K. BEECHER. Defendant ~ .,', ~ ~ DECREE IN D I V 0 R C E j ~ t,I'2- FA AND NOW~..,1!?...........,~,., it is ordered and decreed that... .. . . . . .. . . .. . .~~~~ .~~~~~~~. .... ... , . . . .. .. . ,.. plaintiff, and . . . . . . . . . , . . . . . . . . . . . . . , ?~~~I~. ~: . ~~~~~~!'. . . . . . . . . . . . . . . " 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; None. The terms of the Marital Settlement Agreement are incorporated but .. .... ...... ............ ...................... .......... ................. " !l~):. !"!'F9'!'? !-!'):9. ):pi.~. P!=PI=!=!=.'. . . . . . . . . . . . . . . . . . . . . . , . . . . . . . . . . . . . , . . , . . . . . . . -- -po ...... J. 1'<1 '.' :t: '.' --.- --~_..__.------..-..-----~~~---~---~---....~,._-,--.- ,._._~...~...~ j ~ .,--,:.;. .::+:. .::.:.~.:. .::+:. .::.,. .:+;. .::.:.-::+:. .::+:. -:.:. .:+:. -:+;. .:+;. .:.:- .:~:..:+} .:+;. .:.;. ':-0-:' -:+:- .:+:." Prothonotary ,', * 8 ~ $ ~ ,~ ~ ,', ~ ~ ',' ~ " ~ ~.~ ,', ~ ,.; i'i (~ ~ ~ ~.~ ~ '.' ~ ~.~ " ~ ~ :~ ,', :, ~ ~.; ~ ~ '.~ ~ ~ ~ ~.~ ~ ~ '.' ~ '.' ~ '.' ~ '.~ ~ :;; ',' beech.. mI, ~b robruilfY 15. 2000 JUDY BEECHER, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99 -1441 CIVIL TERM IN DIVORCE Plaintiff vs. DENNIS K. BEECHER, Defendant MARITAL SETTLEMeNT AGREEMENT /& day of klJt,YLC<............... " between JUDY BEECHER. of 36 West Pomfret Street, Apt. 2, Carlisle, Cumberland County. THIS Agreement made this , 2000, by and Pennsylvania, hereinafter referred to as WIFE, and DENNIS K. BEECHER, of 20 Holly Estates Drive, Gardners, Cumberland County, Pennsylvania, hereinafter referred to as HUSBAND, WITNESSETH: WHEREAS, the parties hereto are husband and wife, having been joined in marriage on August 18,1973, in Carlisle, Pennsylvania; and WHEREAS, a Complaint for Divorce has been filed in the Court of Common Pleas of Cumberland County, Pennsylvania, to No. 99-1441 Civil Term on March 11,1999; and WHEREAS, the parties hereto are desirous of settling fully and finally their respective financial and property rights and obligations as between each other, including, without limitation, the settling of all matters between them relating to the ownership of real and personal property, claims for spousal support, alimony, alimony pendente lite, counsel fees and costs, and in general, the settling of any and all claims and possible claims against the other or against their respective estates. 1>oO<I1.. ma. ~b Fobruary 15, 2000 NOW, THEREFORE, in consideration of these considerations, and the mutual promises and undertakings hereinafter set forth, and for other good and valuable consideration, receipt and sufficiency 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: 1. Advice of Counsel: The parties hereto acknowledge that each has been notified of his or her right to consult with counsel of his or her choice, and have been provided a copy of this agreement with which to consult with counsel. WIFE is represented by Carol J, Lindsay, Esquire, and HUSBAND is represented by Hubert X. Gilroy, Esquire, Each party acknowledges and accepts 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 as each has sought from counsel, 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 improper or illegal agreement or agreements. 2. Divorce: The parties agree to the entry of a Decree in Divorce, The parties will execute, on the date of this agreement, Affidavits of Consent and Waivers of Notice under Section 3301 (c) of the Divorce Code, consenting to the entry of a Decree in Divorce. 3, Personal Property: HUSBAND will retain the Camero which he purchased subsequent to separation; the 1989 Chevrolet Pick up; a boat purchased subsequent to separation and a Harley Davidson motorcycle. WIFE will retain the 1989 Chevrolet Blazer. The parties will execute any and all documents necessary to effect the transfer of the named vehicles within ten (10) days of the date of this Agreement, and will be solely responsible for any debt or obligation on account of the vehicles retained and shall indemnify and hold one another harmless against any claims for such debt or obligation on a vehicle retained. be8cher mal qb February 15. 200ll HUSBAND will receive the balances in his AmeriChoice Federal Credit Union account, his IBM stock, and the balance of his IBM tax deferred savings 401-K plan after he has transferred to WIFE the Qualified Domestic Relations Order $25,153.00 from that plan with any eamings or loss thereon from the date of this Agreement until the time of transfer. HUSBAND will also retain his Fidelity and Guarantee life insurance policy and his Metropolitan life insurance policy. He will retain the Morrison Knuteson 401-K Plan. Additionally, within 45 days of the date of this Agreement, HUSBAND will pay to WIFE $55,000.00. Within ten (10) days of the date of this Agreement, HUSBAND will provide to WIFE's counsel the information from IBM necessary to the preparation of a Qualified Domestic Relations Order to transfer those monies set out herein from his IBM 401-K Plan. WIFE's counsel will prepare the Qualified Domestic Relations Order, review it with HUSBAND's counsel and submit it to the Court for the entry of an Order. WIFE shall retain her AmeriChoice Federal Credit Union savings, her Fidelity and Guarantee life insurance policy, her Metropolitan life insurance policy, and her Roadway stock, The parties waive any rights they may have in retirement benefits of the others aside from those rights set out herein. The parties also acknowledge that their personal property has been fairly and satisfactorily divided and that all household goods shall be the sole property of the person in whose possession it is as of the date of this Agreement. 4. Real Property: The parties are owners of a home at 20 Holly Estates Drive, Gardners, Cumberland County, Pennsylvania. Within 45 days of the date of this Agreement, HUSBAND will refinance the marital home so WIFE is no longer obligated on any of the liens thereon. At the time of the refinance, WIFE will provide to HUSBAND a Special Warranty Deed beOchtr...a ~b Fobruary 1~, 2000 transferring to him all her right, tille and interest In the marital home, The refinance and transfer of the Deed shall take place contemporaneously with the payment of $55,000.00 described In Section 3 above, subject to the relinquishment of HUSBAND's lender if the lender is providing the funds for the payment to WIFE, HUSBAND shall be solely and exclusively responsible for any and all obligations on account of the marital home, and shall indemnify and hold WIFE harmless against any such obligations. 5. Alimony: The parties waive any claim that they may have one against the other for alimony or spousal support, The parties acknowledge that each has sufficient assets with which to maintain themselves after divorce. Alimony pendente lite shall terminate upon the payment of $55,000.00 as set out in Paragraph 3 above, 6. Marital Debt: HUSBAND shall be solely responsible for the payment of the following debts: Boscov's charge account in his name; J, C. Penney card; Montgomery Ward card; The Bon Ton card in his name; Lowe's card; and the Visa card. WIFE will be solely and exclusively responsible for the payment of the following obligations: Boscov's charge account in her name; her obligation for a loan from her father; the Home Depot charge; and the obligation on her Fidelity and Guarantee life insurance policy. Within fifty (50) days of the date of this Agreement, HUSBAND will provide documentation that WIFE Is no longer liable on any joint account. Within fifty (50) days of this Agreement, WIFE will provide documentation that HUSBAND is not liable on her Boscov's and Home Depot charge card. a. FAMILY PICTURES: Within 20 days of the date of this Agreement, WIFE will review all of the family pictures in HUSBAND's possession and will determine which pictures she wishes to bHchet maa ~b February 1~, 2000 retain, The parties will equally share the cost of reproduction of one set of pictures of WIFE':; choosing. 9. Exchange of Information: The parties have requested from each other and received any information regarding their assets, liabilities, Income and expenses which the party requires prior to entering into the terms of this Agreement. The parties acknowledge that the terms of this Agreement are fair and equitable and constitute an equitable distribution of marital property and debt, taking into account all of the relevant factors set out In Section 3502 of the Divorce Code, 23 Pa. C.S.!l3502 including the length of the marriage; any prior marriage of the parties; the age, health, station, amounts and sources of income, vocational skills, employability, estate, liabilities and needs of each of the parties; the contribution by each party to the education, training or increased eaming power of the other; the opportunity of each party for future acquisitions of capital assets and income; the sources of income of both parties, including but not limited to, medical, retirement, insurance or other benefits; the contribution or dissipation of each party in the acquisition, preservation, depreciation, or appreciate of the marital property, including the contribution of a party as homemaker; the value of the property set apart to each party; the standard of living of the parties during the marriage; the economic circumstances of each party including federal, state and local tax ramifications at the time of the division of the property, and whether the party will be serving as custodian of any dependent minor children. 10. Modification: No modification, rescission, or amendment of this agreement shall be effective unless in writing signed by each of the parties hereto. 11. Applicable Law: All acts contemplated by this agreement shall be construed and enforced under the laws of the Commonwealth of Pennsylvania. ""<:hor m.. ~b Fobru./y 15, 2000 12, Agreement Binding on Parties and Heirs: This agreement, except as otherwise expressly provided herein, shall bind the parties heroto, and their respective heirs, executors, administrators, legal representatives, assigns and successors in any interest of the parties, 13, Agreement Not to be Merged: This agreement shall be Incorporated Into the final decree of divorce of the parties hereto for purposes of enforcement only, but otherwise shall not be merged into said decree, The parties shall have the right to enforce this agreement under the Divorce Code of 1980, as amended, and in addition, shall retain any remedies in law or in equity under this agreement as an Independent contract. Such remedies in law or equity are specifically not waived or released, 14. Documents: The parties hereto agree that they will execute and deliver one to the other any documents necessary to give effect to the terms of this Agreement. 15. Full and Final Settlement: WIFE and HUSBAND each do hereby mutually remise, release, quitclaim and forever discharge the other and the estate of such other, for all time to come, and for all purposes whatsoever, of and from any and all rights, titles, interests 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 whatever nature and wheresoever situate, which she or he 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 or courtesy, or claims in the nature of dower or courtesy, or widows' or widowers' 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 other State, or any other Country, or any rights which either spouse may boocllor mID I/b Fobruary 15,2000 have, or at any time hereafter have. for past, present or future support or maintenance. alimony, alimony pendenle lile. counsel fees, costs or oxpenses, whether arising as a result of the marlml relation or othelWise, 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 term 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 term thereof, subject, however. to the implementation and satisfaction of the condition precedent as set forth herein above. 16, BREACH: In the event that either party breaches any provision of this Agreement, he or she shall be responsible for any and all costs incurred to enforce the Agreement, including. but not limited to, court costs and counsel fees of the other party. In the event of breach, the other party shall have the right, at his or her election, to sue for damages for such breach or to seek such other and additional remedies as may be available to him or her. IN WITNESS WHEREOF, the parties hereto have set their hands and seals the day and year first above written. (Seal) I I I . (Seal) I ~, beaCho, dro order MarCh 7. 2000 JUDY BEECHER, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO, 99 -1441 CIVIL TERM IN DIVORCE Plaintiff vs, DENNIS K. BEECHER, Defendant PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section 3301(c) aaQ1 (8)(1) of the Divorce Code. (Strike out Inapplicable section). 2. Date and manner of service of the complaint: Acceptance of Service signed by Christopher C. Houston, Esquire, Attorney for Defendant, Dennis K. Beecher, March 25, 1999. 3. (Complete either paragraph (a) or (b)). (a) Date of execution of the affidavit of consent required by Section 3301 (c) of the Divorce Code: by the Plaintiff Februarv 22. 2000; by the Defendant Februarv 29. 2000. (b) (1) Date of execution of the Plaintiff's affidavit required by Section 3301 (d) of the Divorce Code: (2) Date of service of the Plaintiff's affidavit upon the Defendant: _ 4. Related claims pending: None 5. Complete either (a) or (b). (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: March 7, 2000. (b) Date Plaintiff's Waiver of Notice in 3301 (c) Divorce was filed with the Prothonotary: March 7, 2000. Date Defendant's Waiver of Notice in 3301 (c) Divorce was filed with the Prothonotary: March 7, 2000 JUDY BEECHER, Plaintiff va, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION. LAW NO. 99. /V-II CIVIL TERM IN DIVORCE DENNIS K, BEECHER, Defendant COMPLAINT IN DIVORCE JUDY BEECHER, Plaintiff, by her attomeys, FLOWER, MORGENTHAL, FLOWER & LINDSAY, P.C" respectfully represents: COUNT I - DIVORCE 1. The Plaintiff is JUDY BEECHER, who currently resides at 36 West Pomfret Street, Apartment No.2, Carlisle, Cumberland County, Pennsylvania, where she has resided since October 10, 1997. 2, The Defendant is DENNIS K. BEECHER, who currently resides at 20 Holly Estates Drive, Gardners, Cumberland County, Pennsylvania, where he has resided since 1983, 3, The Plaintiff and Defendant both have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4, The Plaintiff and Defendant were married on August 18, 1973 in Carlisle, Pennsylvania. 5. That there have been no prior actions of divorce or for annulment between the parties in this or in any other jurisdiction. 6. The Plaintiff avers that she is entitled to a divorce on the ground that the marriage is irretrievably broken and Plaintiff is proceeding under Sections 3301 (c) and/or (d) of the Divorce Code. ~ l " < ~ 'lJ ~ 1 r; ~,')~ "" ~ ....... c"' ,...", "'I",". ~ ~.\~ - '" ~ ;> 9- tl , ... \,\\-\ ~ ::>> l'o ~. l~ .... .1\ " ........ ,",' 14 \loo ..... ~ '" ~ .:., , . " . ll.! (.1:. ---, Cj' i U' 1:.:' (' , " <..; " "~ C'., boecner dro order February 21. 2000 JUDY BEECHER, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO, 99 -1441 CIVIL TERM IN DIVORCE Plaintiff vs. DENNIS K, BEECHER, Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under 93301 (cl of the Divorce Code was filed on March 11, 1999. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety d,;,ys have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree in 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 to the best of my knowledge. information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. Qudll A~ U Ju/'-.. JlJdy Beecher. Plaintiff Date:.,) !.J,!)!C 0 . -. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~3301 (e) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree of Divorce without notice, 2. I understand that I may lose rights concerning alimony. division of property. lawyer's fees or expenses if I do not claim them before a divorce 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 to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa,C.S. 4904 relating to unsworn falsification to authorities. '7t(1'~ br f (' JU\.. i Judy eecher, Plaintiff Date: ,..) !-J /l/(j() . - I beeche, dr. orde' February 21. 2000 . JUDY BEECHER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO, 99 -1441 CIVIL TERM IN DIVORCE V5. DENNIS K. BEECHER, Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under ~3301(c) of the Divorce Code was filed on March 11, 1999. 2, The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and seNice of the Complaint. 3, I consent to the entry of a final Decree in Divorce after seNice of notice of intention to request entry of the Decree. I verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information and belief, I understand that false statements herein are made subject to the penalties of 18 Pa.C.S, 4904 relating to unsworn falsification to authorities. (' / ^ )".A~ /< /fn~ _ Dennis K. Beecher, Defendant Date: ,;2 Ix <J ! ;1.0,'" . , WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER li3301(cl OF THE DIVORCE CODE 1. I consent to the entry of a final Decree of Divorce without notice. 2, I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce 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 to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa,C.S, 4904 relating to unsworn falsification to authorities. 1J,,~/<~ Dennis K. Beecher, Defendant Date: ,:;",4 $IOlO()() JUDY BEECHER, Plaintif f IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW DENNIS L. BEECHER, Defendant NO, 99-1441 CIVIL TERM IN DIVORCE ACCEPTANCE OP SERVICE 1, Christopher C, Houston, Esquire, accept service of the Complaint in Divorce on behalf of Dennis L, Beecher and certify that I am authorized to do so. Date: ') 1.< (/41. , I ~. Hou", on , Attorney for Defendant 52 West Pomfret Street Carlisle, PA 17013 717-241-5970 Esquire -- C,/ , '. rr; I:-~ " .? , /.:. 'j r.. , "'" , f~', ; ":"'1 c., , 0, " .-) LU I i7.fl'.~ C'~~ ..; : i-. ,. , ~,rr'j :~ , '- l./. C'J 0 .-'J <::::> (J :W';-i 1\:? ! ,:';d" .,::~{ h.;:.:..,ilLl ."\ " , t l . , , i . I I I . I I , . . I beech., dr. <><dor January 14,2000 JUDY BEECHER, Plaintiff/Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DOMESTIC RELATIONS SECTION DR 28,582 PACSES 982101040 CIVIL ACTION - LAW NO, 99 -1441 CIVIL TERM VS, DENNIS L, BEECHER, Defendant/Respondent IN DIVORCE PETITION FOR INCREASE IN ALIMONY PENDENTE LITE Now comes JUDY BEECHER, by and through her counsel, FLOWER, FLOWER & LINDSAY, P,C" and pelitions this Honorable Court as follows: 1. The parties hereto are husband and wife, having been joined in marriage on August 18,1973. 2. On June 17, 1999, this Honorable Court entered an Order for Alimony Pendente Lite in the amount of $200.00 per month effective April 29, 1999. A copy of said Order is attached hereto as Exhibit "A". 3. Petitioner is without means to provide for her own reasonable needs. 4. Petitioner seeks alimony pendente lite in the guideline amount. WHEREFORE, Petitioner prays this Honorable Court to amend the Order of Alimony Pendente Lite of June 17, 1999 to provide alimony pendente lite in the guideline amount. FLOWER, FLOWER & LINDSAY, P,C, Attorneys for Plaintiff fJa~"i. IW1l693 11 East High Street Carlisle, Pennsylvania 17013 (717) 243-5513 By: _It dr. CIder January 14.2000 JUDY BEECHER, Plaintiff/Petitioner vs, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DOMESTIC RELATIONS SECTION DR 28.582 PACSES 982101040 CIVIL ACTION - LAW NO. 99 -1441 CIVIL TERM IN DIVORCE DENNIS L. BEECHER, Defendant/Respondent AND now, this CERTIFICA ~ OF SERVICE I 1 day of ~ .t t. , 2000, I, Carol J, , Lindsay, Esquire, of the law firm of FLOWER, FL WE & LINDSAY, P,C., Attorneys, hereby certify that I served the within Petition for Increase in Alimony Pendente Lite this day by depositing same in the United States Mail, First Class, Postage Prepaid, in Carlisle, Pennsylvania, addressed to: Hubert X. Gilroy, Esquire 4 North Hanover Street Carlisle, PA 17013 FLOWER, FLOWER & LINDSAY Attorneys for Plaintiff/Petitioner By: Carol J. Lindsay, Esquire 10 # 44693 11 East High Street Carlisle, PA 17013 (717) 243-5513 i:= "- -I' ~ ~; I' 1> (';.: ~ s: ~,) .~ ',.),,~ c~.. .f '..I~~ " -.; ,- (~/~- "..':.:i 0:. . .,.. ~) . ,'ff) l__~1 '. . I/' '':7 {.( III :r: ')H; (', ./ ') _. -, ii 115 1:, <.:> I ..~ ~"-"'--I ..J:~ -r,- . . ~ , ...,,' -:>-" ~ f. ... J-.-...- ..<_.#..- , " - ------,.- . PETITIONER: JUDY BEECHER OOB: JANUARY 27, 1955 SS# 182-40,9311 ADDRESS: 36 WEST POMFRET STREET, CARLISLE, PENNSYLVANIA 17013 PHONE: (717) 258,8859 ATTORNEY: CAROLJ. LINDSAY, ESQUIRE PETITIONER'S EMPLOYMENT: ROADWAY EXPRESS How LONG? NET PAY: $30,000.00 PER YEAR JOB TITLE: MANAGER OTHER INCOME: (INCLUDE AMOUNT AND SOURCE) WA RESPONDENT: DENNIS K. BEECHER OOB: NOVEMBER 12,1953 SS# 206-36,3236 ADDRESS: 20 HOLLY ESTATES DRIVE, GARDNERS, PENNSYLVANIA 17324 PHONE: (717) ATTORNEY: CHRISTOPHER C. HOUSTON, ESQUIRE RESPONDENT'S EMPLOYMENT: How LONG? NET PAY: $60,000.00 PER YEAR JOB TITLE: COMPUTER TECH OTHER INCOME: (INCLUDE AMOUNT AND SOURCE) N/A WHEN MARRIED: AUGUST 18, 1973 WHERE: CARLISLE. PENNSYLVANIA 17013 DATE SEPARATED: OCTOBER 10,1997 WHERE LASTLIVEDTOGETHER: 20 HOLLY ESTATES DRIVE, GARDNERS, PENNSYLVANIA 17324 FOR DRS INFORMATION ONLY - 11""'"'" ",,",20, ,m JUDY BEECHER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99 -1441 CIVIL TERM IN DIVORCE VB, DENNIS L. BEECHER, Defendant CERTifICATE OF SERVICE AND now,this .:}.'1 day of ~ / ,1999, I, Carol J. Lindsay, Esquire, of the law firm of FLOWER, FLOJJER ~ LINDSAY, P.C., Attorneys, hereby certify that I served the within Petition for Alimony Pendente Lite this day by depositing same in the United States Mail, First Class, Postage Prepaid, in Carlisle, Pennsylvania, addressed to: Christopher C, Houston, Esquire 52 West Pomfret Street Carlisle, PA 17013 FLOWER, FLOWER & LINDSAY Attorneys for Plaintiff/Petitioner By: Carol J, Linds Esquire ID # 44693 11 East High Street Carlisle, PA 17013 (717) 243-5513 ~ .:r ~ - C'l ( , ~o 13< ~~ - u~ .- a- .")::.. ~.. ~ C,"': .~ C1' .... .... 'o.~\Z ,.- N U:y' (Yo ,rca; ..u F 0_ :lolL}.. "" . ~ C1' :::> C1' u " 1'D51' Domestic Relations Order Form--I'aJ:e 2 (January I, IIJ')H edition) 3. A loan to a participant is made by taking invested 1lll1ds out of the particip.mt's account. The total value of the account is the value of the invested funds and any loan amounts outstanding. The available account balance is the amount of invested funds, which balance docs not include amounts previously loaned out to the participant. The distrihution to the Alternate Payee specified by paragraph four (4) is made up to the limit of available funds as ofthe date of distribution and docs not alter the Participant's obligation to repay any loans then outstanding. 4. The Plan Administralor of the 1'DSI' is directed to make a lump sum distribution from the Participant's account in 1'D51' to the Alternate Payee of: (fill in only one option; put N/A for "not applicable" in the blanks for the other options.) a. $25,153.00 ,as well as a pro rata share from 2/18/2000 to the date of (dollar amount) (date) distribution of any gains or losses in the account on that amount. b. n/a , percent ( n/a %) of the available account balance as of n/a (in words) (date) (which balance does nol include loan amounts outstanding), as well as pro rata share from the date specified to the date of distribution of any gains or losses in the account on that amount. c'_IYa_, percent ( n/a %) of the total account value as of n/a (in words) (date) (which value includes loan amounts outstanding), as well as a pro rata share from the date specified to the date of distribution of any gains or losses in the account on that amount. d. n/a , as an absolute dollar amount. (dollar amount) e. n/a percent l:'~%) of the available account balance as of n/a (in words) (dale) (which balance does nol include loan amounts outstanding), as an absolute dollar amount. f. n/a , percent ( n/a %) of the total account value as of n/a (in words) (date) (which value includes loan amounts outstanding), as an absolute dollar amount. Effective May 19, 1995, distributions from 1'DSP are valued daily and the applicable valuation for the account as of any specified date is based upon the preceding valuation date, For orders with a specified date prior to May 19, 1995, a weekly (Thursday) valuation date will be used effective during the Plans weekly valuation period from 4/1/90 and 5118/95 and a monthly valuation date will be used if effective prior to 4/1/90. The prorata share of gains and losses is based upon the changes in unit values of the funds in which the account was allocated on the specified date. TUSI' Uomf!lIe Relntlons Order Form--I'nJ:e 3(January 1,1998 edilion) 5, If the Alternate Payee dies after the issuance of this order, rDSP is to make the applicable distribution to the alternate payee's estate. SO ORD~, this 2h day of t J.. un ~ (name of judge) Approved: (court seal) (dale) ~ , ~ ~ ~ ~ ... 1 a () ~' .~ l ~ j , '" "< . ,~ , In Ihc Court or Common PlcBS or CUMBERLAND Counly, Pcnnsylvanla DOMESTIC RELATIONS SECTION JUDY BEECHER ) Duck., Num""r 99-1441 CIVIL Plalmirr ) VS. ) PACSES Ca,. Numb.r 982101040/D28,582 DENNIS K. BEECHER ) D.r.udalll ) Olh.r SIal. fD Numb.r Ordcr AND NOW to wit, this MARCH 3, 2000 it is hereby Ordered that: THE ABOVE CAPTIONED ORDER OF ALIMONY PENDENTE LITE IS TERMINATED, PURSUANT TO WIFE WITHDRAWING HER PETITION FOR ALIMONY PENDENTE LITE. THERE IS NO BALANCE DUE. BY THE COURT: DRO: RJ Shadday xc: plaIntiff defendant Carol LIndsay, EsquIre Hubert G:I1roy, EsquIre JUDGE S.rvic. Typ. M M..;~A'JLED ~.~oo {8 Form OE-OOt Worhr fD 21005 , (0 (~ ~.I - , i ....- c ) ,. 0:0 , I L'_ {":':' .. ;. "c- o.. I '. (,":J ; C' c.J U