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DIVORCE
AND NOW,.. ??,ceN,?ocf ..2.I......... , 19.1.1.., it is ordered and
Charles Shank
decreed that .................................................. Plaintiff,
Christel Shank
and .......................................................... defendant,
are divorced from the bonds of matrimony.
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF PENNA.
CHARLES SHANK, Plaintiff
..................... ........ .......... ......... ............
"'""" 3473 Civil Tenn 99
N c ? ......................... .................. 19
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;
...............................
By The Court
Atlcat ? J.
Prothonotary
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CHARLES SHANK, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. : No. 99 - 3473 Civil Term
CHRISTEL SHANK, ACTION IN DIVORCE
Defendant
MARRIAGE SETTLEMENT AGREEMENT
THIS AGREEMENT, made this SOZ7<Aay of ?r d???/?t GFh. 1999, by and between,
CHARLES H. SHANK, of Carl'sle, Pennsylvania, hereinafter referred to as "HUSBAND", and CHRISTEL
M. SHANK, of, Pocatello, Idaho, hereinafter referred to as "WIFE".
WHEREAS, Husband and Wife were lawfully married on December 15, 1972, in Germany, and;
WHEREAS, differences, disputes, and difficulties have arisen between the parties and it is the
intention of Husband and Wife to live separate and apart for the rest of their natural lives, and the parties
desire to settle their respective financial property rights and obligations as between each other,
WHEREAS, the provisions of this Agreement and their legal effect have been fully explained to
the parties by their respective counsel. The Husband has employed and had the benefit or counsel of
Jane Adams, Esquire, as his attorney. The Wife has employed and had the benefit or counsel of Austin
Grogan, Esquire, as her attorney. Each party acknowledges that he or she has received independent
legal advice from counsel of his or her selection and that each fully understands the facts and has been
fully informed as to his or her legal rights and obligations, and each party acknowledges and accepts that
this Agreement is, under 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 illegal agreement or agreements. In addition, each party hereto acknowledges that he or she
has been fully advised by his or her respective attorney of the impact of the Pennsylvania Divorce Code,
whereby the Court has the right and duty to determine all marital rights of the parties including divorce,
alimony, alimony pendente lite, equitable distribution of all martial property owned or possessed
individually by the other, counsel fees, and costs of litigation, each party hereto still desires to execute this
Agreement, acknowledge that the terms and conditions set forth herein are fair, just, and equitable to each
of the parties and waives his or her respective right to have the Court of Commons Pleas of Cumberland
County or any other Court of competent jurisdiction make any determination or Order affecting the
respective party's right to a divorce, alimony, alimony pendente lite, equitable distribution of all martial
property, counsel fees, and costs of litigation.
NOW THEREFORE, Wife and Husband, each intending to be legally bound, hereby covenant
and agree as follows:
1. SEPARATION. That the parties intend to maintain separate and permanent domiciles and to
live apart from each other. It is the intention and purpose of this agreement to set forth their respective
rights and duties while they continue to live apart from each other. Whereas a Complaint in Divorce was
filed, both parties will agree to a No-Fault Divorce after the applicable ninety (90) day time period has run.
The parties have attempted to divide their matrimonial property in a manner which conforms to a
just and right standard, with due regard to the rights of each party. It is the intention of the parties that
such division shall be final and forever determine their respective rights. The division of existing marital
property is not intended by the parties to constitute in any way a sale or exchange of assets.
2. INTERFERENCE. Further, the parties agree to continue living separately and apart from each
other at any place or places that he or she may select. Neither party shall harass, annoy, injure, threaten,
or interfere with the other party in any manner whatsoever. Each party may carry on and engage in any
employment, profession, business or other activity as he or she may deem advisable for his or her sole
use and benefit. Neither party shall interfere with the uses, ownership, enjoyment, or disposition of any
property now owned and not specified herein or property hereafter acquired by the other.
3. SUBSEQUENT DIVORCE. The parties hereby acknowledge that Husband has filed a
Complaint in Cumberland County, Pennsylvania, claiming that the marriage is irretrievably broken under
the no-fault mutual consent provision of Section 3301(c) of the Pennsylvania Divorce Code. Wife hereby
expresses her agreement that the marriage is irretrievably broken and expresses her intent to execute any
and all affidavits or other documents necessary for the parties to obtain an absolute divorce pursuant to
Section 3301(c) of the Divorce Code. The parties hereby waive all rights to request Court Ordered
counseling under the Divorce Code. It is further specifically understood and agreed by the parties that the
provisions of this Agreement relating to equitable distribution of property of the parties are accepted by
each party as a final settlement for all purposes whatsoever, as contemplated by the Pennsylvania
Divorce Code.
Should a decree, judgment, or order of separation or divorce be obtained by either of the parties
in this or any other state, country or jurisdiction, each of the parties hereby consents and agrees that this
Agreement and all of its covenants shall not be affected in any way by any such separation or divorce; and
that nothing in any such decree, judgment, order, or further modification or revision thereof shall alter,
amend, or vary any term of this Agreement, whether or not either or both of the parties shall remarry (it
being understood by and between the parties hereto that this Agreement shall survive and shall not be
merged into any decree, judgment, or order of separation.) It is specifically agreed, however, that a copy
of this Agreement or the substance of the provisions thereof, may be incorporated by reference into any
divorce, judgment, or decree. This incorporation, however, shall not be regarded as a merger, it being the
specific intent of the parties to permit this Agreement to survive any judgment and to be forever binding
and conclusive upon the parties.
4. DATE OF EXECUTION. The "date of execution" or "execution date" of this 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.
5. DISTRIBUTION DATE. The transfer of property, funds, and/or documents provided for herein
shall only take place on the "distribution date" which shall be defined as the date of execution of this
Agreement unless otherwise specified herein.
6. WIFE'S DEBTS. Wife represents and warrants to Husband that since the separation she has
not and in the future she will not contract or incur any debt or liability for which Husband or his estate
might be responsible and shall indemnify and save harmless Husband from any and all claims or
demands made against him by reason of debts or obligations incurred by her.
7. HUSBAND'S DEBTS. Husband represents and warrants to Wife that since the separation he
has not and in the future he will not contract or incur any debt or liability for which Wife or her estate might
be responsible and shall indemnify and save harmless Wife from any and all claims or demands made
against her by reason of debts or obligations incurred by him.
8. MUTUAL RELEASE. Subject to the provisions of this Agreement, each party has released
and discharged, and by this Agreement does for himself or herself and his or her heirs, legal
representatives, executors, administrators, and assigns, release and discharge the other of and from all
causes of action, claims, rights, or demands whatsoever, in law or equity, which either of the parties ever
had or now has against the other, except any or all cause or causes of action for divorce and except any
or all causes of action of breach of any of the provisions of this Agreement.
9. DIVISION OF PERSONAL PROPERTY. Husband and Wife do hereby acknowledge that they
have previously divided their tangible personal property including, but without limitation, jewelry, clothes,
furniture, furnishings, rugs, carpets, household equipment and appliances, pictures, books, works of art,
and other personal property. Except as may otherwise be provided in this Agreement, Wife agrees that all
of the property of Husband or in his possession shall be the sole and separate property of Husband; and
Husband agrees that all of the property of Wife or in her possession shall be the sole and separate
property of Wife. The parties do hereby specifically wavier, release, renounce, and forever abandon
whatever claim, if any, he or she may have with respect to the above items which shall become the sole
and separate property of the other.
10. EMPLOYMENT BENEFITS. The parties agree to waive any and all rights they have in and
to each other's employment benefits, including both parties pensions, retirement plans, Incentive Savings
Plans, 401(k) plans, profit sharing plans, or military retirement plans. The parties agree that this waiver
does not include Social Security benefits, and that either party shall have the right to make a claim on the
other's Social Security benefits when and if eligible to do so.
11. MOTOR VEHICLES. With respect to the motor vehicles, owned by one or both of the .
parties, they agree as follows:
(a) The 1988 Dodge Dynasty shall be and remain the sole and exclusive property of Wife. The
title to the Dodge Dynasty shall be executed by the parties, within 30 days of the date of execution
of this Agreement, and said executed title shall be delivered to Christel Shank. Christel Shank
agrees to be solely responsible for any amount presently due and owing against the Dodge
Dynasty.
(b) The 1997 Dodge Pickup truck shall be and remain the sale and exclusive property of
Husband. Husband shall be solely responsible for the amount presently due and owing against
the Dodge Pickup. The title to the Dodge Pickup truck shall be transferred to Husband once the
! amount due and owing against the Dodge Pickup is paid and the financing agreement is satisfied.
12. LUMP SUM PAYMENT TO WIFE. As part of the equitable distribution of the party's marital
property pursuant to the Divorce Code, 23 Pa.C.S.A. 3501 and 3502, Husband shall pay wife a lump sum
of $15,000.00 payable within 30 days of the execution date of this agreement.
13. REAL ESTATE. Husband and Wife hold as tenants by the entirety the premises identified as
99 South Middlesex Road, Carlisle, Cumberland County, Pennsylvania, 17013. The parties agree as
follows with respect to the marital residence:
(a) Within 30 days of the execution date of this agreement, Wife shall deliver to Husband a
Quitclaim Deed, conveying to Husband all of her right, title, and interest in and to the marital
residence. Thereafter, Husband shall be the sole owner of the marital residence and shall be
permitted to record the deed and take any other action with respect thereto that he deems
appropriate.
(b) Commencing on the execution date of this Agreement, and without regard to when all bills for
such items are incurred, received or due, Husband shall be solely responsible for all past, present
and future costs or liabilities associated with or attributable to maintaining the marital residence,
including but not limited to, all real estate taxes, water and sewer rents, gas, electric and
telephone service, homeowner's insurance, and gardening expenses and repairs, and Husband
shall keep Wife and her successors, assigns, heirs, and executors and administrators indemnified
and held harmless from any liability, cost, or expense, including attorney's fees which are incurred
in connection with such maintenance, costs, and expense.
(c) Commencing on the date of execution of this Agreement, Husband shall be solely responsible
for the timely payments of all past, present, and future principal, interest, and other fees due under
the mortgage. Husband and Wife agree to take all steps necessary to have the mortgage on the
property transferred to Husband's name alone.
14. ALIMONY PENDENTE LITE and LEGAL FEES. Each party hereby waives any right to
alimony pendente lite, and each party agrees to be responsible for his or her own legal fees and
expenses.
15. WAIVER OF ALIMONY. The parties herein acknowledge that by this Agreement, they have
respectively secured and maintained a substantial and adequate fund with which to provide for themselves
sufficient financial resources to provide for their comfort, maintenance, and support in the station of life to
which they are accustomed. Wife and Husband do hereby waive, release, and give up any rights they
may respectively have against the other for alimony, support, or maintenance. It shall be from the
execution of this Agreement the sole responsibility of each of the respective parties to sustain themselves
without seeking any support from the other party.
In furtherance of this paragraph, Wife agrees to withdraw any and all claims that she has
heretofore filed for alimony or alimony pendente lite with the Court of Common Pleas of Cumberland
County, Pennsylvania or any other Courts.
16. INCOME TAX RETURNS. Husband and wife represent to each other that to the best of their
knowledge all tax returns and other documents required to be filed with the Internal Revenue Service for
calendar years 1972 through 1999 have been filed and that no notices have been received from the
Internal Revenue Service which remain unresolved. Each party further represents to the other that to the
best of his or her knowledge, the information set forth in the joint tax return for these calendar years was
and remains accurate as relates to his or her sole income and acknowledges that the other party relied on
such representations in signing those returns. Therefore, if any deficiency in federal, state, or local
income taxes is proposed, or any assessment of any such tax is made against the other party by reason
of his or her having joined in the filing of joint federal, state or local income tax returns, Husband and Wife
shall indemnify and hold harmless the other against and from any and all tax, interest, penalty, or expense
relating from any such tax deficiency, including reasonable counsel and accounting fees, and such tax,
interest, and penalties or expenses shall be paid solely and entirely by the responsible party as
determined to be attributable to that party on account of misrepresentation or failure to disclose relevant
information of income on the aforesaid joint returns.
17. 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.
18. 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 further
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.
19. APPLICABLE LAW. The Agreement shall be construed in accordance with the laws of the
Commonwealth of Pennsylvania which are in effect as of the date of execution of this Agreement.
20. WAIVER OF CLAIMS AGAINST THE ESTATES. Except as herein otherwise provided,
each party may dispose of his or her property in any way, and each party hereby waives and relinquishes
any and all rights he or she may now have or hereafter acquire, under the present or future laws of any
jurisdiction, to share in the property or the estate of the other as a result of the marital relationship,
including without limitation, dower, curtesy, statutory allowance, widow's allowance, right to take intestacy,
right to take against the Will of the other, and right to act as administrator or executor of the other's estate,
and each will, at the request of the other, execute, acknowledge, and deliver any and all instruments which
may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such
interests, rights, and claims. This agreement shall be binding and shall insure the benefit to the parties
hereto and their respective heirs, executors, administrators, successors, and assigns.
21. INTEGRATION. This Agreement constitutes the entire understanding of the parties and
supersedes any and all prior agreements or negotiations between them. There are no representations or
warranties other than those expressly set forth herein.
22. OTHER DOCUMENTATION, Wife and Husband covenant and agree that they will forthwith
execute 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.
23. 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 default or breach of any provision hereof
by construed as a waiver of any subsequent default or breach of the same or similar nature, not shall it be
construed as a waiver or strict performance of any other obligations herein.
24. 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 his or her
obligations under any one or more of the paragraphs herein, with the exception of the satisfaction of the
conditions precedent, shall in no way avoid or alter the remaining obligations of the parties.
25. BREACH. If either party breaches any provisions of this agreement, the other party shall
have the right, at his or her election, to sue for damages for such breach, or seek other remedies or relief
as may be available to him or her, and the party breaching this contract should be responsible for payment
of legal fees and costs incurred by the other in enforcing their rights under this agreement.
IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the day and year
first above written:
WITNESS:
-CHARLES H. S ANK
Date: 12 Ozj ; / ! / l
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CHS E SHANK
nWitness
Date:
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SHANK, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. : No. 99 - 3473 Civil Term
CHRISTEL SHANK, ACTION IN DIVORCE
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 §3301(c) of the Divorce Code.
2. Date and manner of the service of the Complaint: Delivered by certified mail.
restricted delivery return receipt requested delivered on: June 14 1999,
3. Date of execution of the affidavit of consent required by 3301(c) of the Divorce Code:
By Plaintiff. 12/21/99
By Defendant: 12/20/99
4. Related claims pending: None.
5. Date Defe dant's Waiver of Notice in §3301(c) Divorce was filed with the
Prothonotary: /.' C" c
Respectfully Submitted;
Date: tome le C ?-
/ J to Adams, Esquire
I .D. No. 79465
117 South Hanover St.
Carlisle, Pa. 17013
(717) 245-8508
Attorney for Plaintiff
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CHARLES SHANK, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
vs. No. 99• 3Y 73 Ccrn? "T?--
CHRISTEL SHANK, : ACTION IN DIVORCE
Defendant
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.
Where 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 at the
Office of the Prothonotary, Cumberland County Courthouse.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS
GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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, Pa. 17013
(717) 249-3166
CHARLES SHANK, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
VS. No. 9 9. 3 V 73 C-;a -n,
CHRISTEL SHANK, ACTION IN DIVORCE
Defendant
COMPLAINT IN DIVORCE
1. Plaintiff is Charles Shank, an adult individual, who has resided at 99 Middlesex Road,
Carlisle, Cumberland County, Pennsylvania, since 1989.
2. Defendant is Cluistel Shank, an adult individual, who has resided at 4200 Philbin
Road, #90, Pocatello, Idaho, since April 26, 1999.
3. Plaintiff has been a bona fide resident of the Commonwealth for at least 6 months
immediately previous to the filing of this Complaint.
4. The Plaintiff and the Defendant were marred on December 12, 1972 in Germany.
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 that plaintiff may have the
right to request that the court require the parties to participate in counseling.
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7. Plaintiff and Defendant have one child together, Raymond Shank, who is an adult
individual.
8. Plaintiff and Defendant are both citizens of the United States of America.
9. Neither Plaintiff or Defendant are a member of the Armed Forces of the United States
of any of its allies.
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10. The Plaintiff avers that the grounds on which this action is based are: That the
marriage is irretrievably broken.
WHEREFORE, Plaintiff requests the court to enter a decree in divorce.
I verify that the statements made in this Complaint are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unswom
falsification to authorities.
Date: G • Lf • 019
Charles Shank, Plaintiff
Respectfully submitted,
e Adams, Esquire
.D. No. 79465
117 South Hanover St.
Carlisle, Pa. 17013
(717) 245-8508
ATTORNEY FOR PLAINTIFF
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SHANK,
Plaintiff
VS.
CHRISTEL SHANK,
Defendant
IN THE COURT OF COMMON PLE- AS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 99 - 3473 Civil Tenn
ACTION IN DIVORCE
AFFIDAVIT OF SF VI E BY CERTIFIED MAIL.
AND NOW, this June 21, 1999, 1, Jane Adams, Esquire, hereby certify that
on June 16, 1999, a true and correct copy of the Plaintiffs Notice to Defend and Complaint
were served, via certified mail, return receipt requested, addressed to:
Christel Shank
4200 Philbin Road #90
Pocatello, Idaho 83202
Respectfully Submitted:
Adams, Esquire
No. 79465
South Hanover St.
Carlisle, Pa. 17013
(717) 245-8508
ATTORNEY FOR PLAINTIFF
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CHARLES SHANK, : IN THE COURT OF COMMON VI-r-Mo
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
VS. No. 99 - 3473 Civil Term
CHRISTEL SHANK, ACTION IN DIVORCE
Defendant
AFFIDAVIT OF CONSENT
1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on June 8, 1999.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the
date of the filing of the Complaint.
3. 1 consent to the entry of a final decree of divorce.
4. 1 understand that I may lose my rights concerning alimony, division of property, lawyer's fees, or
expenses, if I do not claim them before a divorce is granted.
I understand that the statements made in this affidavit are true and correct. I also understand that false
statements therein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsifica ion to
authorities.
Date: 17 7 I CCC////J ? ?
ZI I ?LCI Charles Shank, Plaintiff
WAIVER FN OTICE OF INTENTION
TO REQUEST ENTRY OF A DIVORCE DECREE
NDER 6 01( 1 OF THE DIVORCE CODE
1. 1 consent to entry of a final decree of divorce without notice.
2. 1 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. 1 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 fats tatemen s
noes.
herein are made subject to the penalties of 18 Pa.C.S. §4904 relating unsw m fals? tion u?
Date: (49-1 (cl `]
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CHARLES SHANK, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 99-3473 CIVIL TERM
CHRISTEL SHANK, IN DIVORCE
Defendant
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
June 8, 1999.
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. § 4904 relating to unworn
falsification to authorities.
Date
CHRISTEL SHANK
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CHARLES SHANK, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 99-3473 CIVIL TERM
CHRISTEL SHANK, IN DIVORCE
Defendant
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301(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 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 unworn falsification to authorities.
Date: L % < <
CHRISTEL SHANK
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CHARLES SHANK,
Plaintiff
V.
CHRISTEL SHANK,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-3473 CIVIL TERM
IN DIVORCE
ANSWER AND NEW MATTER
cA-
AND NOW, this day of July, 1999, the Defendant, Christel Shank, by and
through her attorney, Austin F. Grogan, Esq., avers the following:
1. Admitted;
2. Denied. Defendant is currently residing at 360 North Main Street, Apt. 1,
Pocatello, Idaho 83204;
3. Admitted;
4. Admitted in part, denied in part. The Plaintiff and Defendant were married on
December 15, 1972 in Germany;
5. Admitted;
6. Admitted;
7. Admitted;
8. Admitted;
9. Admitted;
10. Admitted.
0
NEW MATTER
COUNT II - EQUITABLE DISTRIBUTION
11. Paragraphs 1 through 10 of this Answer are incorporated herein by reference as
though set forth in full.
12. Plaintiff and Defendant have acquired property, both real and personal, during
their marriage from December 15, 1972, until April 26, 1999, the date of their separation, which
property is "marital property".
13. Plaintiff and Defendant may have owned, prior to the marriage, property which
has increased in value during the marriage and/or which has been exchanged for other property,
which has increased in value during the marriage, all of which property is "marital property"
14. Plaintiff and Defendant have been unable to agree as to an equitable division of
said property prior to the filing of this Complaint.
WHEREFORE, Plaintiff requests this Honorable Court to equitably divide all marital
property.
COUNT III - ALIMONY PENDENTE LITE AND ALMONY
15. Paragraphs 1 through 14 of this Complaint are incorporated herein by reference as
though set forth in full.
16. Plaintiff lacks sufficient property to provide for her reasonable means and is unable
to support herself through appropriate employment.
17. Plaintiff requires reasonable support to maintain herself adequately in accordance
with the standard of living established during the marriage.
WHEREFORE, Plaintiff requests this Honorable Court to enter an award of alimony
pendente lite until final hearing and thereafter to enter an award for alimony.
Respectfully submitted,
Date _7
Austin F. Groga , Esq ' e
24 North 32nd Street
Camp Hill, PA 17011
(717) 737-1956
Attorney for Plaintiff
ID x/59020
VERIFICATION
I, Austin F. Grogan, Esq., verify that the statements made in the foregoing Answer with
New Matter are true and correct to the best of my knowledge, information, and belief. The
1
Defendant is out of this jurisdiction and has verified the accuracy of the statements by phone. I
i
understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904,
j relating to unswom falsification to authorities.
Date_ 1'2-??I 1 cI' z
Austin F. Grogat , Esq ire
24 North 32nd Street
Camp Hill, PA 17011
j (717) 737-1956
Attorney for Defendant
ID #59020
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CHARLESSHANK,
Plaintiff
V.
CHRISTEL SHANK,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-3473 CIVIL TERM
IN DIVORCE
ORDER
AND NOW, this day of July, 1999 upon consideration of the Defendant's
Motion it is hereby Ordered that an Alimony Pendente Lite hearing be scheduled the day
of 1999 at AM/PM in Courtroom N at the Cumberland County
Courthouse, Carlisle, PA.
BY THE COURT,
JUDGE
CHARLES SHANK, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. 99-3473 CIVIL TERM
CHRISTEL SHANK, IN DIVORCE
Defendant
MOTION TO SCHEDULE AN ALIMONY PFNDENfE LIT, CONFERENCE
AND NOW, this 15!'?day of July 1999, the Defendant, Christel Shank, by and
through her attorney, Austin F. Grogan, Esq., avers the following:
i
I. On or about June 8, 1999 the Plaintiff filed the above captioned Divorce
Complaint in Cumberland County;
2. On or about July 2, 1999 the Defendant filed an Answer and New Matter
requesting Equitable Distribution, Alimony Pendente Lite, and Alimony;
3. It is anticipated that the Plaintiff, Charles Shank, will defend against the
entitlement of spousal support.
WHEREFORE, the Defendant respectfully requests this Honorable Court to schedule a
Alimony Pendente Lite hearing.
Date g C
Austin F. Gro n,A
24 North 32 Strut
Camp Hill, PA 17
(717) 737-1956
Attorney for Defendant
ID #59020
CHARLES SHANK, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 99-3473 CIVIL TERM
CHRISTEL SHANK, IN DIVORCE
Defendant
ORDER
AND NOW, this day of July, 1999 upon consideration of the Defendant's
Motion it is hereby Ordered that an Alimony Pendente Lite hearing be scheduled the _ day
of 1999 at AM/PM in Courtroom # at the Cumberland County
Courthouse, Carlisle, PA.
BY THE COURT,
JUDGE
CHARLES SHANK,
Plaintiff
V.
CHRISTEL SHANK,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 99-3473 CIVIL TERM
IN DIVORCE
MOTION TO SCHEDULE AN ALIMONY PENDENTE LITE CONFERENCE.
AND NOW, this day of July 1999, the Defendant, Christel Shank, by and
through her attorney, Austin F. Grogan, Esq., avers the following:
1. On or about June 8, 1999 the Plaintiff filed the above captioned Divorce
Complaint in Cumberland County;
2. On or about July 2, 1999 the Defendant filed an Answer and New Matter
requesting Equitable Distribution, Alimony Pendente Lite, and Alimony;
3. It is anticipated that the Plaintiff, Charles Shank, will defend against the
entitlement of spousal support.
WHEREFORE, the Defendant respectfully requests this Honorable Court to schedule a
Alimony Pendente Lite hearing.
Date G
Austin F. Groan, Esquire
24 North 32nd Street
Camp Hill, PA 176x.
(717) 737-1956
Attorney for Defendant
ID #59020
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ATTORNEY AT LAW
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24 North 32nd Street
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Jane Adams, Esquire
117 SOunth Hanover Street
Carlisle, PA 17013
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ATTORNEY AT LAW U.S. POSTAGE
24 North 32nd Street
Camp Hill, PA 17011 ( !i:115S? 0 0"3 3. ;
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Austin F. Grogan Esquire
24 North 32nd Street
Camp Hill, PA 17011
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CHARLES SHANK, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 99-3473 CIVIL TERM
CHRISTEL SHANK, IN DIVORCE
Defendant
ORDER
AND NOW, this day of July, 1999 upon consideration of the Defendant's
Motion it is hereby Ordered that an Alimony Pendente Lite hearing be scheduled the _ day
of , 1999 at AM/PM in Courtroom # at the Cumberland County
Courthouse, Carlisle, PA.
BY THE COURT,
JUDGE
CHARLES SHANK, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 99-3473 CIVIL TERM
CHRISTEL SHANK, IN DIVORCE
Defendant
MOTION TO SCHEDULE AN ALIMONY PENDENTE LITE CONFERENCE
AND NOW, this day of July 1999, the Defendant, Christel Shank, by and
through her attorney, Austin F. Grogan, Esq., avers the following:
1. On or about June 8, 1999 the Plaintiff filed the above captioned Divorce
Complaint in Cumberland County;
2. On or about July 2, 1999 the Defendant filed an Answer and New Matter
requesting Equitable Distribution, Alimony Pendente Lite, and Alimony;
3. It is anticipated that the Plaintiff, Charles Shank, will defend against the
entitlement of spousal support.
WI-IEREFORE, the Defendant respectfully requests this Honorable Court to schedule a
Alimony Pendente Lite hearing.
Date C
Austin F. Grogan, Esquire
24 North 32nd Street
Camp Hill, PA 176x./
(717) 737-1956
Attorney for Defendant
ID #59020
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ATTORNEY AT LAW
24 North 32nd Street
Camp Hill, PA 17011
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P. METER 1763G8 n
Christel Shank
360 N. Main Street, Apt. i
Pocatello, ID 83204
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CHARLES SHANK, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 99-3473 CIVIL TERM
CHRISTEL SHANK, IN DIVORCE
Defendant
ORDER
AND NOW, this day of July, 1999 upon consideration of the Defendant's
Motion it is hereby Ordered that an Alimony Pendente Lite hearing be scheduled the _ day
of , 1999 at AM/PM in Courtroom # at the Cumberland County
Courthouse, Carlisle, PA.
BY THE COURT,
JUDGE
CHARLES SHANK,
Plaintiff
V.
CHRISTEL SHANK,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-3473 CIVIL TERM
IN DIVORCE
MOTION TO SCHEDULE AN ALIMONY PENDENTE LITE CONFERENCE
AND NOW, this/, /day of July 1999, the Defendant, Christel Shank, by and
through her attorney, Austin F. Grogan, Esq., avers the following:
1. On or about June 8, 1999 the Plaintiff filed the above captioned Divorce
Complaint in Cumberland County;
2. On or about July 2, 1999 the Defendant filed an Answer and New Matter
requesting Equitable Distribution, Alimony Pendente Lite, and Alimony;
3. It is anticipated that the Plaintiff, Charles Shank, will defend against the
entitlement of spousal support.
WHEREFORE, the Defendant respectfully requests this Honorable Court to schedule a
Alimony Pendente Lite hearing.
Date C L
Austin F. Grogan, Esquire
24 North 32nd Street
Camp Hill, PA 17du`
(717) 737-1956
Attorney for Defendant
ID #59020
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