HomeMy WebLinkAbout99-02696
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IN THE COURT OF COMMON PLEAS
OFCUMBERLANDCOUNTY
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PENNA.
CATHY WIMER.
. Plaintiff No. 99-2696
VERSUS
DONALD K. 11IMER,
Defendant
.
DECREE IN
DIVORCE
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AND NOW,
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. IT IS ORDERED AND
2000
DECREED THAT
rJ~rhy {o]; mt:lor
, PLAINTIFF,
AND
Donald K. Wimer
_, DEFEN DANT,
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 Property Settlement Agreement between the parties dated
March 1, 2000, is hereby incorporated but not merged.
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IN THE COURT OF COMMON PLEAS
CATHY WIMER,
Plaintiff
OF CUMBERLAND COUNTY
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STATE OF ' ~~. ;
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PENNA.
No. 99-2696
DECREE IN
DIVORCE
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2000 .
IT IS ORDERED AND .
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PLAINTIFF, .
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DEFENDANT, .
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VERSUS
DONALD K. WIMER,
.
Defendant
AND NOW,
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DECREED THAT
C'.1thy loJi mPT
AND
Donald K. Wimer
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 Property Settlement Agreement between the parties dated
March 1, 2000, is hereby incorporated but not merged.
By THE COURT' .
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Pl/'-HHONOTARY i
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up to the date of execution hereof.
~. (3) The parties are the owners of certain real estate
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! with improvements thereon erected known as 400 Raymon Avenue,
, Boiling Springs, Cumberland County, Pennsylvania.
The parties agree that Wife shall enjoy exclusive
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pOssession of said property until such time as the youngest of
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j the parties' children graduates from high school. While Wife
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j is living in the marital home, Husband agrees to pay the sum of
'I $1,000.00 to Wife, which represents the payment of the mortgage
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I to PNC Bank, the real estate taxes, insurance, and other
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I utility payments or one-halt of all household expenses,
whichever is greater. Wife shall assume full responsibility
for the remaining household expenses while she is residing
there.
As soon as the youngest child graduates from high school,
the property will be listed for sale and sold, and the net
proce8ds will be divided equally. In the event that Husband
has not paid to Wife the payments as stated above, and Wife is
required to make any mortgage payments, then she shall be
credited with these payments and their equivalent before the
I proceeds are split.
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(4) In the event that either party contracted or incurred
SAlOIS, ' any debts sJ.nce the date of separation on April 15, 1999,
SHUFF &
MAS LAND ' the party who incurred sa.id debt shall be responsible for the
AT1"OR.~~AT-u.W
26 W. I1I&h Sir.., , payment thereof regardless of the name in which the debt may
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have been incurred.
Husband and Wife acknowledge and agree that they have no
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and Wife incurred prior to the signing of this Agreement.
(5) Each party relinquishes any right, title and interest
he or she may have to any and all motor vehicles currently in
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other outstanding joint. debts and Ob~.1.go.t:._on:s oi:t:Fle--rtuii'C>O:~1.'~
possession of the other party including the Camaro and the van
in the possession of Husband, and the Pathfinder in the
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1 possession of Wife. Each party shall execute any documents
I necessary to have said vehicles properly registered in the
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other party's name with the Pennsylvania Department of
Transportation.
Each party shall assume full responsibility of
any encumbrance on the motor vehicle received by said party,
, and shall hold harmless and indemnify the other party from any
loss therein.
(6) The parties hereto mutually agree that they have
effected a satisfactory division of the furniture, household
furnishings, appliances, tools and other household personal
property between them, and they mutually agree that each party
shall from and after the date hereof be the sole and separate
owner of all such property presently in his or her possession
whether said property was heretofore owned jointly or
individually by the parties hereto. Husband shall receive all
property as listed in Exhibit A, and Wife shall receive all
SAIDIS. remaining household property. This agreement shall have the
SHUFF &
MASLAND effect of an assignment or bill of sale from each party to the
AllJ2IU'I'EYS.AT-LAW
26W.HlcbStr.., ,other for such proper.ty as may be in the individual possession
C..lill.. PA
of each of the parties hereto.
(7) Each party hereby relinquishes any right, title or
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interest he or she may have in or to any intang~ble personal
,. property except that the Keough plan held at Fahnestock shall
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be divided equally.
(8) Except as otherwise provided herein, Husband shall
not pay to Wife nor Wife to Husband any sum whatsoever as
alimony, alimony pendente lite, or for his or her support or
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,I maintenance.
,
(9) Each party is now represented by counsel of his and
,I he,r own choice, and each shall pay his or her own attorney for
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all legal services rendered or to be rendered on his or her
behalf .
( IO)
Neither party shall contract or incur any debt or
liability for which the other party or his or her property or
estate might be responsible and shall indemnify and save the
other party harmless from any and all claims or demands made
against him or her by reason of debts or obligations incurred
by the other party.
(11) Each of the parties shall from time to time, at the
request of the other, execute, acknowledge and deliver to the
other party any and all further instruments that may be
reasonably required to give full force and effect to the
SAlOIS,
SHUFF &
MAS LAND
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26 W. Hlelt Str..,
Carll.)., Ph
provision of this Agreement.
(12) Both parties agree to file a jOint 1999 federal,
Pennsylvania and local income tax return and any liabilities
will be shared equally and any refund will be shared equally.
(13) The parties do hereby warrant, represent, acknowledge
and agree that each is fully and completely informed of, and is
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SAlOIS,
SHUFF &
MAS LAND
ATTOR..\'EYS-I\T.UW
26 W, Hlch Street
Carllti., Ph
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income of the other and that each has~
disclosure to the other of his and her
:1' and assets, earnings and
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entire assets and liabilities and any further enumeration or
statement thereof in this Agreement is specifically waived.
(14 )
Husband and Wife acknowledge that each of them has
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:! read and understand his and her rights and responsibilities
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under this Agreement and that they have executed this Agreement
under no compulsion to do so but as a 'lollJntary act.
(15)
It is further specifically understood and agreed by
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i and between the parties hereto that each party accepts the
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i provisions herein made in lieu of and in full settlement and
,
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I satisfaction of any and all of said partyls rights against the
other for past, present and future claims on account of
support, maintenance, alimony, alimony pendente lite, counsel
fees, costs and expenses, equitable distribution of marital
property and any other claims of each party, including all
claims which have been raised or may be raised in an action for
. divorce.
(16) Except as may be otherwise specifically provided in
this Agreement, Husband and ~Iife, for themselves, their heirs,
representatives and assigns, each hereby forever releases,
remises, discharges and quitclaims the other, and such other's
heirs, representatives, assigns and estate, from and with
respect to the following:
A. All liability, claims, causes of action, damages,
costs, contributions, expenses or demands whatsoever in
SAlOIS,
SHUFF &
MASLAND
A.Tl'OP.NEl'S-AToU.W
2& W, H1eb SlT<d
Carlill., P ^
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be amended from time to time, and under the provisions of
any similar statute enacted by any other country, state,
territory or political subdivision;
I. All rights, claims, demands, liabilities and
obligations each party now has, or may hereafter have,
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'I the Commonwealth of Pennsylvania.
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:1 Agreement is determined to be invalid or unenforceable, all
against or with respect to the other.
(17 )
This Agreement shall be construed under the law of
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If any provision of this
other provisions shall continue in full force and effect.
(18) In the event that either of the parties shall recover
a final judgment or decree of absolute divorce against the
other in a court of competent jurisdiction, the provisions of
this Agreement may be incorporated by reference or in substance
but shall not be merged into such judgment or decree and this
Agreement shall survive any such final judgment or decree of
absolute divorce and shall be entirely independent thereof.
(19) In the event that either party breaches any provision
of this Agreement, and the other party retains co;,,1sel to
assist in enforcing the terms thereof, the parties hereby agree
that the breaching party will pay all attorney's fees, court
costs and expenses incurred by the other party in enforcing the
Agreement.
(20) This Agreement constitutes the entire understanding
between the parties and there are no covenants, conditions,
representations, or agreements, oral or written, of any nature
whatsoever, other than those herein contained.
Febuary 13, 2000
Supplement to property settlement, Don Wimer's
personal property & access agreement. As listed:
1
2
3
4
5
6
7
8
2 antique wall clocks
wooden corner hutch
beer glasses & Mugs
business phone
certain business supplies
antique display tools
coal stove
boat, motor, trailer
9 oil paintings
10 coats of arms
11 owl carving
12 musket & horn
13 sword! spear
14 knick knacks
15 boat accys.
16 storage items
All power and hand tools, equiptment, chemicals, and
supplies in the garage, less the lawn type tools, belong
to Donald Wimer. The 8hp snowblower and garden
tractor will remain to be used, but upon sale of the
house, go to Don Wimer.
Don Wimer shall have access to the garage and house,
fully respecting Cathy Wimer's privacy, giving notice
before entry. Garage to be used for business and
maintance of house and cars, to the benefit of both
parties. This generally to be done during daylight
hours.
O&-KJ~
Donald K Wimer
82 Silver Crown Dr
Mechanicsburg PA 17055
697-6811
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CATHY WIMER,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 99-2696 Civil Term
DONALD K. WIMER,
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. Ground for divorce: Irretrievable breakdown under
Section 3301(c).
2. Date and manner of service of the Complaint:
Certified mail dated 5/6/99 as attached.
3. (Complete either paragraph (a) or (b):
(A) Date of execution of the Affidavit of Consent required
by Section 330l(c) of the Divorce Code:
By the Plaintiff:
By Defendant:
3/10/00;
3/12/00
(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: No claims were raised.
5. Complete either (a) or (b).
(al Date and manner of service of the notice of
intention to file praecipe to transmit record, a copy of which is
attached:
(b) Date Plaintiff's Waiver of NotJce in Section
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3301(c) Divorce was filed with the Prothonotary: Even date
herewith
Date Defendant's Waiver of Notice in Section 3301(c)
Divorce was filed with the Prothonotar: Even date herewith.
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a J. eil, Esq.
ney or P aintiff
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'" SENDER:
~ . Complate itf;ms 1 Hnd/or 2 for additional serviccs.
'" . Comple:e 110m! 3, 481, and 4b.
!!i!: . Print )'Ol.lf name l!.nd address on the ra\'orse 01 this form so that VOQ can return this
J: card 10 you.
~ Il Ana. ch this form 10 the fronl ollhe mailpieco. or on Ihe back II space does nol
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CI . WII.la .Rotum Rocoipt Requostod' on Ih, mailplece below the Qrtlclo numbof,
or: . rhe Retum R(lcelpl will show 10 whom the article was delivered and Iho dale
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11007
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I also wish 10 receive the
following servIces (lor an
extra. fee):
1, 0 Addressee's Address
2,'s"ReslriCled Delivery
Consult postmaster tor fee.
4a. Article Number
01
4b. Service ype
o Registered
o Expres:) Mail
iJ Retum Receipt for Merchandise
7. Date of Delivery S--~-
8. Addressee's Address (Only if tequesled
and fee ;s paid)
~ Certified
o Insured
o COD
5, Received By: (Print Namo)
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CATHY WIMER,
PlaintH f
v,
IN THE COURT OF COM~lON PLEAS
CUMBERLAND COUNT'h. PENNSYLVANIA
97 - ;1.107'b \...: IUl\
NO. CIVIL TE~~
CIVIL ACTION - LAW
IN DIVORCE
DONALD K. WIMER,
Defendant
NOTICE
You have been sued in court. If you wish to defend against
the claims set forth in the following pages, you must take
prompt action. You are warned that if you fail to do so, the
case may proceed without you and a decree of divorce or
annulment may be entered against you by the Court. A judgment
may also be entered against. you for any other claim or relief
requested in these papers by the Plaintiff. You may lose money
or property or other rights important to you, including custody
or visitation of your children.
When the ground for the divorce is indignities or
irretrievable breakdown of the marriage, you may request
marriage counseling. A list of marriage counselors is available
in the Office of the Prothonotary at the Cumberland County Court
House, High and Hanover Street, Carlisle, Pennsylvania.
IF
PROPERTY,
ANNULMENT
THEM.
YOU DO NOT FILE
LAWYER'S FEES
IS GRANTED, YOU
A CLAIM FOR
OR EXPENSES
I'lAY LOSE THE
ALIMONY, DIVISION
BEFORE A DIVORCE
RIGHT TO CLAIM ANY
OF
OR
OF
YOU SHOULD TAY..E THIS PAPER TO YOUR !'..J'''\'lYER 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.
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SHUFF &
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Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
Date: +'1-9,
SAIDIS, SHUFF & VU,SLAND
(':\' \:{,\
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All"hoUGce,
Court ID # 78014
26 We.t High Strceet
Carlis e, PI\ nUl3
(717) 243-6222
Counsel for Plaintiff
26 W. tU~h SUt't't
Clr11~1r'. PA
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request that the Court require the parties to participate in
counseling.
Having been so advised Plaintiff does not desire
the Court to order counseling.
7. The marriage is irretrievably broken.
WHEREFORE, Plaintiff requests Your Honorable Court to enter
a decree in divorce.
COUNT II - EOUITABLE DISTRIBUTION
8. The allegations of Paragraph 1 through 7 inclusive are
hereby incorporated by referenced as if set forth in full
hereat.
9. Plaintiff and Defendant have acquired property both
real and personal during their marriage,
WHEREFORE, Plaintiff requests This Honorable Court to
return the marital property and order an equitable distribution
thereof.
COUNT III
SUPPORT. ALIMONY. ALIMONY PENDENTE LITE
10. The allegations of Paragraphs 1 through 9 inclusive
are hereby incorporated by referenced as if set forth in full
hereat.
SAlOIS,
SHUFF & I
MAS LAND
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26 W, llIeb Sir.....
Carll,lt, Ph I
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11. plaintiff lacks suffi.cient property to provide for her
reasonable needs and is unable to support herself and the
parties three minor children through appropri.ate employment.
3
SAlOIS,
SHUFF &.
MAS LAND
^TJ'OtNr1"S-AT.~W
26 W, Web Sir'"
Carll,.., PA
25, The Plaintiff does not know a person not a party to
the proceedings who has physical custody of the children or
claims to have custody or visitation rights with respect to any
of the children.
26. The best interests and permanent welfare of the
children will be served by granting the relief requested because
the children have lived with Plaintiff all of their natural
lives and the children will be able to remain in the same school
district and same family home environment.
27. Each parent whose parental rights to the children have
now been terminated and the person who has physical custody of
the child have been named as parties to this action.
WHEREFORE, Plaintiff requests this Court to grant her joint
legal custody and sole physical custody of the children, subject
to periods of visitation by Defendant,
Respectfully submitted,
SAIDIS, SHUFF & MASLAND
Date:
If - 9 - q~
By: r' \
Mar W. Allshouse,
Supr me Court ID #
26 Weat High Street
Carlisle, PA 17013
(717) 243-6222
Counsel for Plaintiff
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AFFIDAVIT
I, Cathy Wimer, being duly sworn according to law, depose
and say:
(1) I have been advised of the availability of marriage
counselling and understand that I may request that the court
require that my spouse and I participate in counselling.
(2) I understand that the court maintains a list of
marriage counselors in the Prothonotary's Office, which list is
available to me upon request.
(3) Being so advised, I do not request that the court
require that my spouse and I participate in counselling 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. Section 4904 relating to unsworn
falsification to authorities.
Dated:
tI-9-91
(~ LJ~~
Cathy w~er, Plaintiff
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Cnlblt. PA
CATHY WIMER,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO, 99-2696 Civil
v.
DONALD K. WIMER,
Defendant
IN DIVORCE
DEFENDANT'S
AFFIDAVIT OF CONSENT. ACCEPTANCE OF SERVICE AND
WAIVER OF NOTICE OF INTENTION TO REOUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301(c) OF THE DIVORCE CODE
1, A Complaint in divorce under Section 3301(c) of the
Divorce Code was filed on May 5, 1999.
2. Defendant acknowledges and accepts service of the
Complaint on May 6, 1999.
3, The marriage of Plaintiff and Defendant is irretrievably
broken and ninety days have elapsed from the date of the filing
of the Complaint.
4. I consent to the entry of a final decree of divorce
without notice,
5. 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,
6. I understand that I will not be divorced until a divorce
decree is entered by the Court and that a copy of the decree will
be sent to me immediately after it is filed with the
Prothonotary.
7, I have been advised of the availability of marriage
counselling and understdnd that I may request that the court
require counselling. I do not request that the court require
counselling.
I verify that the statements made in this affidavit are true
and correct. I understand that false statements herein are made
subject to the penalties of 18 Pa. C.S. Section 4904 relating to
I unsworn falsification to auth i ies.
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DATED:
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