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THE COURT OF COMMON PLEAS
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OF CUMBERLAND COUNTY
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STATE OF PENNA.
KEITH R. HUNTZINGER, ,
.... i
........ .
Plaintiff, NU....3597 ............ ................. 19 99
A
Q,
Versus
KIMBERLY A. CROSTLEY,
Defendant.
i
DE CRE E IN
DIVORCE
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AND NOW, .... . Z ?!! . ) 9 it is ordered and
decreed that ..... Keith R. ...... n&er, plaintiff,
and • ............ • Kimberly A. Crostley defendant,
7 are divorced from the bonds of matrimony.
is
41 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;
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None. The Marital Settlement Agreement executed by the parties dated
October 7. 1999, shall be incorporated herein, but shall not be merged
........ ........................................................
into said Decree.
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MARRIAGE SETTLEMENT AGREEMENT
by and between
KIMBERLY A. CROSTLEY
and
KEITH R. HUNTZINGER
MARRIAGE SETTLEMENT AGREEMENT
AGREEMENT MADE this I Yk day of CIC?i C?e? , 1999, by and
between KIMBERLY A. CROSTLEY ("Wife") - A N D - KEITH R. HUNTZINGER ("Husband"),
at Harrisburg, Pennsylvania.
WHEREAS, the parties hereto are husband and wife having been married on May 22, 1996, in
Jamaica.
WHEREAS, no children were born of this marriage;
WHEREAS, diverse unhappy differences, disputes and difficulties have arisen between the
parties and it is the intention of Wife and Husband to live separate and apart for the rest of their natural
lives, and the parties desire to settle fully and finally their respective financial and property rights and
obligations as between each other including, without limitation by specification: settling of all matters
between them relating to the ownership and equitable distribution of real and personal property; settling
of all matters between them relating to the past, present and future support, alimony and/or maintenance
of Wife by Husband or of Husband by Wife; and in general, the settling of any and all claims and
possible claims by one against the other or against their respective estates.
NOW, THEREFORE, in consideration of the foregoing premises and of the mutual promises,
covenants and undertakings hereinafter set forth and for other good and valuable consideration, receipt
of which is hereby acknowledged by each of the parties, Wife and Husband, each intending to be legally
bound hereby, covenant and agree as follows:
1. Divorce and Separation. The parties agree to the entry of a decree in divorce pursuant
to Section 3301(c) of the Divorce Code of 1980. Husband and Wife shall at all times hereafter have the
right to live separate and apart from each other and to reside from time to time at such place or places as
they shall respectively deem fit, free from any control, restraint, or interlerence whatsoever by the other.
Neither party shall molest the other or endeavor to compel the other to cohabit or dwell with him or her
by any legal or other proceedings. The foregoing provision shall not be taken to be an admission on the
part of either Husband or Wife of the lawfulness or unlawfulness of the causes leading to their living
apart.
The parties acknowledge that a divorce action has been filed in the Court of Common Pleas of
Cumberland County, Pennsylvania at docket number 99-3597. The parties agree that they will execute
Affidavits of Consent in the aforementioned matter.
1. Division of Property. Husband and Wife agree that the following constitutes an
equitable distribution of the marital property.
A. Husband's Property. The following property shall become the sole and
exclusive property of Husband:
1. 1996 Nissan Maxima, subject to all existing liens and obligations.
Husband shall remove Wife's name from the obligations associated with this vehicle
within 90 days of the execution of this Agreement. If Husband is unable to do so, then
the vehicle shall be sold at Husband's sole cost and expense. Husband shall be entitled to
all proceeds of sale. Husband shall provide Wife with verification that she has been
removed from all obligations associated with the vehicle.
2. Merck Stock. Wife will execute the documentation to transfer the
Merck stock concurrently with the execution of this Agreement.
3. Country Club Membership.
4. All retirement benefits in Husband's name.
B. Wife's Property. The following property shall become the sole and
exclusive property of Wife:
I. Property and lot situate at 85 Eastgate Drive, Camp Hill,
Cumberland County, Pennsylvania, subject to all existing liens and obligations. Wife
agrees to be responsible for all costs associated with the property, including the mortgage,
taxes, insurance and all other obligations and indemnify and hold Husband harmless from
said obligations.
Wife agrees to remove Husband's name from the mortgage associated
with the property by refinancing or other appropriate measures. Wife shall complete this
within 90 days of the execution of this Agreement. If Wife is unable to remove
Husband's name from the mortgage obligation within 90 days of the execution of this
Agreement, then the property shall be sold. Wife shall be responsible for all costs
associated with the sale of the property. Wife shall be entitled to all proceeds of sale.
Husband shall execute a deed transferring all interest in the property to
Wife. The deed shall be held in escrow by Husband's counsel pending Wife's refinance
of the property or assumption of the mortgage by Wife alone.
2. 1999 Volkswagen Jetta.
3. All retirement benefits in Wife's name.
4. Husband shall reimburse the sum of $250 to Wife upon the
forwarding of the consents and waivers to the court for filing. This payment constitutes
3
Husband's contribution to the mortgage payment on the marital home for the month of
October, 1999.
C. The parties have divided between them to their mutual satisfaction the
personal effects, household fbrniture and furnishings and all of the property which
heretofore has been held by (Item in common.
3. Relinquishment of Rights. Except as expressly provided herein, Husband forever
relinquishes any right, title or interest he may now or hereafter have in any tangible or intangible assets
now belonging to Wife, and Wile forever relinquishes any right, title or interest she may now or
hereafter have in any tangible or intangible assets now belonging to Husband.
4. Taxes. The parties have heretofore filed joint federal and state tax returns. Both parties
agree that in the event tiny deficiency in federal, state or local income tax is proposed, or any assessment
of any such tax is made against either of (heat, each will indemnify and hold harmless the other from and
against any loss or liability for any such lax deficiency or assessment and any interest, penalty and
expense incurred in connection therewith. Such tax, interest, penalty or expense shall be paid solely and
entirely by the individual who is finally determined to be the cause of the misrepresentations or failures
to disclose the nature and extent of his or her separate income on the aforesaid joint returns.
I lusband shall be entitled to claim $3,202.46 in mortgage interest as a deduction on his 1999
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Ifusband and Wife shall equally divide the capital gains tax liability for the stock sold between
January I, 1999 and September I, 1999.
5. Additional Documentation. The parties agree to execute any deeds, assignments, titles
4
or other instruments necessary and appropriate to accomplish the aforesaid division of property.
6. Transfers Subject to Existing Liens. Notwithstanding any other provisions in this
document all property transferred hereunder is subject to the existing lien or liens set forth above. The
respective transferee of such property agrees to indemnify and save harmless the other party from any
claim or liability that such other party may suffer or may be required to pay on account of such lien or
encumbrance.
7. Representations and Warranties. The parties represent and warrant to each other that
the property described in this Agreement represents all of the property in which they have any right, title
and interest, and that such property is subject to no mortgage, pledge, lien, security interest,
encumbrance or charge except those which are disclosed herein.
8. Equitable Division. By this Agreement the parties have intended to effect an equitable
division of theirjointly owned property. The parties have determined that an equitable division of such
property conforms to a just and right standard, with due regard to the rights of each party. The division
of existing marital property is not intended by the parties to constitute in any way a sale or exchange of
assets, and the division is being effected without the introduction of outside funds or other property not
constituting a part of the marital estate. It is the intention of the parties to treat all transfers herein as
non-taxable.
9. After-Acquired Property. Each of the parties shall hereafter own and enjoy
independently of any claim or right of the other, all items of property, be they real, personal or mixed,
tangible or intangible, which are hereafter acquired by him or her, with full power in him or her to
dispose of the same as fully and effectively, in all respects and for all purposes as though he or she were
unmarried.
10. Debts. Husband and Wife shall each be solely responsible for all debts in their respective
names, including but not limited to personal loans, charge accounts and credit cards. Both parties
represent and warrant to the other that as of the date of this Agreement they have not incurred, and in the
future will not contract or incur, any debt or liability for which the other or the estate of the other might
be responsible.
11. Liabilities. All debts, contracts, obligations or liabilities incurred at any time in the past
or future by either party will be paid promptly by said party, unless and except as otherwise specifically
set forth in this Agreement; and each of the parties hereto further promises, covenants and agrees that
each will now and at all times hereafter save harmless and keep the other or his or her estate indemnified
and save harmless from all debts or liabilities incurred by him or her, as the case may be, and from all
actions, claims and demands whatsoever with respect thereto, and from all costs, legal or otherwise, and
counsel fees whatsoever pertaining to such actions, claims and demands. Neither party shall, as of the
date of this Agreement, contract nor incur any debt or liability for which the other or his or her property
may be responsible, and shall indemnify and save harmless the other from any and all claims or demands
made against him or her by reason of debts or obligations incurred by him or her and from all expenses,
legal costs, and counsel fees unless provided to the contrary herein.
12. Counsel Fees, Costs and Expenses. Each party shall be responsible for his or her own
legal fees, costs and expenses incurred in connection with their separation and/or the dissolution of their
marriage.
13. Waiver of Alimony. In exchange for and in consideration of the promises and
representations made hereunder, Husband and Wife hereby waive and release any and all right, title,
interest, claims or demand of whatsoever nature which he or she now has or hereafter can, shall or may
have against the other or the respective separate property of the other under the laws of the
Commonwealth of Pennsylvania or any other governing state, country, territory or jurisdiction in the
nature of spousal support, separate maintenance or support, alimony, either pendente lite, temporary,
rehabilitative, permanent or lump sum and right to seek equitable or community distribution or division
or assignment of property or similar marital rights.
14. Full Disclosure. The respective parties do hereby warrant, represent and declare and do
acknowledge and agree that each is and has been fully and completely informed of and is familiar with
and cognizant of the wealth, real and/or personal property, estate and assets, earnings and income of the
other and that each has made a full and complete disclosure to the other of his or her entire assets and
liabilities and any further enumeration or statement thereof in this Agreement is specifically waived.
15. Releases. Each party does hereby remise, release, quitclaim and forever discharge the
other and the estate of the other from any and every claim that each other may now have, or hereafter
have or can have at any time, against the other, or in and to or against the other's estate, or any part
thereof, whether arising out of any former contracts, engagements or liabilities of the other, or by way of
dower or claim in the nature of dower, widow's rights, or under the intestate laws, or the right to take
against each other's will, or for support or maintenance, or of any other nature whatsoever, except any
rights accruing under this Agreement.
16. Indemnification. Each party represents and warrants to the other that he or she has not
incurred any debt, obligation, or other liability, other than described in this Agreement, on which the
other party is or maybe liable. Each party covenants and agrees that if any claim, action or proceeding
is hereinafter initiated seeking to hold the other party liable for any other debts, obligations, liability, act
or omission of such party, such party will at his or her sole expense, defend the other against any such
claim or demand, whether or not well-founded, and that he or she will indemnify and hold harmless the
other party in respect of all damages as resulting therefrom. Damages as used herein shall include any
claim, action, demand, loss, cost, expense, penalty, and other damage, including without limitation,
counsel fees and other costs and expenses reasonably incurred in investigating or attempting to avoid
same or in opposing the imposition thereof or enforcing this indemnity, resulting to Husband or Wife
from any inaccurate representation made by or on behalf of either Husband or Wife to the other in this
Agreement, any breach of any of the warranties made by Husband or Wife in this Agreement, or breach
or default in performance by Husband or Wife of any of the obligations to be performed by such party
hereunder. The Husband or Wife agrees to give the other prompt written notice of any litigation
threatened or instituted against either party which might constitute the basis for a claim for indemnity
pursuant to the terms of this Agreement.
17. General Provisions. This Agreement constitutes the entire understanding of the parties
and supersedes any and all prior agreements and negotiations between them. There are no
representations or warranties other than those expressly set forth herein.
18. Fair and Equitable Contents. The provisions of this Agreement and their legal effect
have been fully explained to the parties by their respective counsel. 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. 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 or illegal agreement or agreements.
19. Breach. It is expressly stipulated that if either party fails in the due performance of any
of his or her material obligations under this Agreement, the other party shall have the right, at his or her
election, to sue for damages for breach thereof, to sue for specific performance, or to seek any other
legal remedies as may be available, and the defaulting party shall pay the reasonable legal fees for any
services rendered by the non-defaulting party's attorney in arty action or proceeding to compel
performance hereunder.
20. Execution of Documents. Each party shall on demand execute any other documents that
may be necessary or advisable to carry out the provisions of this Agreement.
21. Modification. No modification, rescission or amendment to this Agreement shall be
effective unless in writing signed by each of the parties hereto.
22. Severability. If any provision of this Agreement is held by a Court of competent
jurisdiction to be void, invalid or unenforceable, the remaining provisions hereof shall nevertheless
survive and continue in full force and effect without being impaired or invalidated in any way.
23. Applicable Law. This Agreement shall be construed under the laws of the
Commonwealth of Pennsylvania.
24. Agreement Not to be Merged. This Agreement may be filed with the Court for
incorporation into the Decree of Divorce 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.
IN WITNESS WHEREOF, the parties hereto have set their hands and seals the day and year
first above written.
Witness:
KIMBERLY A CROSTLEY
KEITH R. HUNTZ GER
10
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF DAUPHIN
. ss.
Personally appeared before me, a Notary Public in and for the aforesaid Commonwealth and
County, Kimberly A. Crostley, who being duly sworn according to law deposes and says that she is a
party of the foregoing Agreement and she a ecuted same for the purposes therein contained.
Witness my hand and seal this 7 '" day of & c -tc,/a e" , 1999.
I?
\? ?-c ice, '4).
Notary Public
My Commission Expires:
Notarial Seal
Vicky L. Fitz, Notary Public
Harrisburg, Dauphin County
My Commisalon Expires Dec. 5, 2002
Member, Pennsylvania Association of Notaries
COMAMONWEALTH OF PENNSYLVANIA
COUNTY O:; CUMBERLAND
ss.
Personally appeared before me, a Notary Public in and for the aforesaid Commonwealth and
County, Keith R. Huntzinger, who being duly sworn according to law deposes and says that he is a
party of the foregoing Agreement and he executed same for the purposes therein contained.
Witness my hand and seal this _1-'h_ day of &At r , 1999.
liu'a (,tr k j-
Notary Public
My Commission Expires:
Nolanal Seal
l.on A. Rlcnartl. Notary Publ,c
Camp VIII Sono. Cumberland County
My Commraeion E?plres Oct !, 200!
1 1 Member. PennsylvanL9 Assocutnw u! NUlnllP>
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October 9, 1999
KEITH R. HUNTZINGER,
V.
: IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-3597
Plaintiff
CIVIL ACTION - LAW
KIMBERLY A. CROSTLEY,
Defendant IN DIVORCE
PRAE .IP . TOTRANSMIT RECORD
TO THE PROTHONOTARY:
Transmit the record, together with the following information, to the court for entry of an
appropriate divorce decree:
1. Ground for divorce: Irretrievable breakdown under § 3301(c) of the Divorce Code.
2. Date and manner of service of complaint: The Complaint was filed on June 14, 1999,
and was served on Kimberly A. Crostley by certified mail on June 17,1999.
3. (Complete either paragraph (a) or (b):
(a) Date of execution of the affidavit of consent required by § 3301(c) of the Divorce
Code: by Plaintiff October 7,1999; by Defendant Oetober 7,1999.
(h)(1) bate of executinn of the affidavit required by § 7301(d) of the Divorce
code. ;
(7y1 Clots of filing and service of the Plaintiffs affidavit upon the
recnnndent
4. Related claims pending: None.
5. (Complete either (a) or (b).)
(a) Date and manner of servicp. of the. notice of intention to file nraecipe to transmit
rernrd ,.g copy of whi h is attached-
(b) Date Plaintiffs Waiver of Notice in § 3301(c) Divorce was filed with the
Prothonotary: October 11, 1999.
Date Defendant's Waiver of Notice in § 3301(c) Divorce was filed with the
Prothonotary: October 11, 1999.
Respectfully Submitted,
REAGER & DLER, PC
Date: October 11, 1999
DBE N ON CANTOR, ESQUIRE
mey . o. 66378
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REAGER & ADLER, PC
BY: DEBRA DENISON CANTOR, ESQUIRE
Attorney I.D. No. 66378
2331 Market Street
Camp Hill, PA 17011
Telephone: (717) 763-1383
Attorneys for Plaintiff
KEITH R. HUNTZINGER,
V.
Plaintiff
: IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYLVANIA
NO. J 4' -3 5-9 7 64va -
CIVIL ACTION - LAW
KIMBERLY A. CROSTLEY,
Defendant IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the
following ages, 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
1udgment 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, Room 101, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania.
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, PA 17043
(717) 249-3166
KEITH R. HUNTZINGER,
V.
: IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
KIMBERLY A. CROSTLEY,
Defendant
NO.
CIVIL ACTION - LAW
IN DIVORCE
AVISO PARA DEFENDER Y RECLAIMAR DERECHOS
USTED HA DISO DEMANDANDO EN LA CORTE. Is desea defenderse de ]as quejas
expuestas en las p6ginas siguientes, debar tomar accion con prontitud. Se la avisa que is no se defiende,
el caso purde proceder sin usted y decreto de divorcio o anulamiento puede set emitado en su contra por
la Corte. Una decision puede tambidn ser emitida en su contra per caulquier otra queja o compensacuon
reclamados por el demandante. Usted puede perder dinero, o sus propiedades o otros derechos
importantes para usted.
Cuando la base para el divorcio es indignadades o rompimiento irreparable del matrimonio, usted
puede solicitar consejo matrimonial. Una lista de consejeros matrimoniales est5 disponible en la ofcina
del Prothonotary, en la Cumberland County Court of Common Pleas, Room 101, Cumberland County
Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania.
St USTED NO RECLAMA PENSION ALIMENTACIA, PROPIEDAD MARITAL,
HONORARIOS DE ABOGADO U OTROS GASTOS ANTES DE QUE EL
DECRETO FINAL DE DIVORCIO 0 ANULAMIENTO SEA EMITIDO, USTED
PUEDE PERDER EL DERECHO A RECLAMAR CUALQUIERA DE ELLOS.
USTED DEBE LLEVAR ESTE PAPEL A UN ABOGADO DE INMEDIATO.
SI NO TIENE O NO PUEDO PAGAR UN ABOGADO, VAYA O LLAME A LA
OFICINA INDICADA ABAJO PARA AVERIGUAR DONDE SE PUEDE
OBTENER ASISTENCIA LEGAL.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17043
(717)249-3166
REAGER & ADLER, PC
BY: DEBRA DENISON CANTOR, ESQUIRE
Attorney I.D. No. 66378
2331 Market Street
Camp Hill, PA 17011
Telephone: (717) 763-1383
Attorneys for Plaintiff
KEITH R. HUNTZINGER,
V.
Plaintiff
: IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-3597 0-,ZcATip---
CIVIL ACTION - LAW
KIMBERLY A. CROSTLEY,
Defendant IN DIVORCE
COMPLAINT IN DIVORCE
UNDER 5 3301(C) OR (D) OF THE DIVORCE CODE
1. Plaintiff is Keith R. Huntzinger, an adult individual who currently resides at 85 Eastgate
Drive, Camp Hill, Cumberland County, Pennsylvania, 17011.
2. Defendant is Kimberly A. Crostley, an adult individual who currently resides at 85
Eastgate Drive, Camp Hill, Cumberland County, Pennsylvania, 17011.
3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least
six (6) months immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on May 22, 1996 in Jamaica.
There have been no prior actions of divorce or for annulment between the parties.
6. Neither Plaintiff nor Defendant is in the military or naval service of the United States or
its allies within the provisions of the Soldiers' & Sailors' Civil Relief Act of the Congress of 1940 and
its amendments.
7. Plaintiff avers that there are no children of this marriage.
8. The marriage is irretrievably broken.
9. Plaintiff has been advised that counseling is available and that Defendant may have the
right to request that the court require the parties to participate in counseling. Plaintiff declines
counseling.
10. After ninety (90) days have elapsed from the date of the filing of this Complaint, Plaintiff
intends to file an Affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such
an affidavit.
11. In the alternative, Plaintiff will file an Affidavit of Consent and provide the appropriate
notices two (2) years from the date of separation.
WHEREFORE, Plaintiff respectfully requests the Court to enter a decree of divorce pursuant to
Section 3301(c) or (d) of the Divorce Code.
COUNTI
EQUITABLE DISTRIBUTION
12. Paragraphs one (1) through eleven (11) of this Complaint are incorporated herein by
reference.
13. Plaintiff and Defendant have acquired property, both real and personal, during their
marriage.
14. The parties have acquired marital debt during the course of the marriage.
15. The parties are unable to amicably resolve the property issues in this matter.
WHEREFORE, Plaintiff respectfully requests this Honorable Court to equitably divide all
marital property and debt.
Respectfully Submitted,
& ADLER, PC
Date: June 14, 1999
By:
No. 66378
2331 Market Street
Camp Hill, PA 17011-4642
Telephone No. [7171763-1383
Attorneys for Plaintiff
3
VERIFICATION
I, KEITH R. HUNTZINGER, 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. Section
4904, relating to unsworn falsification to authorities.
KEITH R. HUNTZINGER
Date: ?_?_ %9
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READER & ADLER, PC
BY: DEBRA DENISON CANTOR, ESQUIRE.
Attorney I.D. No. 66378
2331 Market Street
Camp Hill, PA 17011
Telephone: (717) 763.1383
Attorneys for Plaintiff
KEITH R. HUNTZINGER,
Plaintiff
: IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99.3597
KIMBERLY A. CROSTLEY,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
Before me, the undersigned Notary Public, this day, personally appeared Debra Denison Cantor,
Esquire, attorney for the Plaintiff, to me known, who being duly sworn according to law, deposes the
following:
I, Debra Denison Cantor, Esquire, being duly sworn according to law, depose and state that
service of the Complaint in Divorce in the above-captioned matter was served by Certified
Mail, Return Receipt Requested, on Defendant, Kimberly A. Crostley, 85 Eastgate Drive,
Camp Hill, Pennsylvania, 17011 on June 17, 1999. The Certified Receipt is attached hereto
as "Exhibit A."
REAGER & ADLER, P.C.
Subscribed and sworn to before me
this A I'" day of _ ,)u r]e _ 11999.
Votary Public
Notarial Seal
Lon A. Richard, Notary PuINk
Camp Hal so. CumbeAand County
My Cnmmtssan Eapfre:.Oct t 2001
Memhdr Pennsylvamd Assocu?huo of pulyne.
By: ..._? -
D R Is ANTOR, ESQUIRE
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KEITH R. HUNTZINGER, : IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
V. NO. 99-3597
KIMBERLY A. CROSTLEY, CIVIL ACTION -LAW
Defendant IN DIVORCE
AFFIDAVIT OF CONSENT
A Complaint in divorce under section 3301(c) of the Divorce Code was filed on June 14,
1999.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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.
4. 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.
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 unswom falsification
to authorities.
Dated: to /--? /S
KEITH R. HUNT ZINGER
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KEITH R. HUNTZINGER,
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: IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
KIMBERLY A. CROSTLEY,
Defendant
NO. 99-3597
CIVIL ACTION - LAW
IN DIVORCE
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.
I understand that I will not be divorced until a divorce decree is entered by the Court and
that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary.
I verify that the statements made in this affidavit are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification
to authorities.
Dated: ( 0 / -) /? /
KEITH R. HUNT ZINGER
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KEITH R. HUNTZINGER,
Plaintiff
V.
KIMBERLY A. CROSTLEY,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 99 - 3597
CIVIL ACTION - DIVORCE
AFFIDAVIT OF CONSENT AND WAIVER OF COUNSELING
1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on June 14, 1999.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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 unsworn falsification
to authorities.
Date: ?G % Cl / ?% I' t f. -) ( A I Ar v
KIMBERLY A. CROST-LEY, DEFE ANT
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KEITH R. HUNTZINGER,
PLAINTIFF
V.
KIMBERLY A. CROSTLEY,
DEFENDANT
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 99-3597
CIVIL ACTION - DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301(c) OF THE DIVORCE CODE
I consent to the entry of a final decree of divorce without notice.
2. I understand that 1 may lose 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 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. Section 4904 relating to unsworn
falsification to authorities.
Date: lD 7 99t.,.,"'N,?I?ii- 4e..-
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KEITH R. HUNTZINGER,
V.
KIMBERLY A. CROSTLEY,
Defendant
: IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-3597
CIVIL ACTION - LAW
IN DIVORCE
Plaintiff
TO THE PROTHONOTARY:
The Social Security number of the Plaintiff, Keith R. Huntzinger, is 195-56-2404.
The Social Security number of the Defendant, Kimberly A. Crostley, is 195-60-6412.
Respectfully Submitted,
REAGER,& ADLER, PC
Date: October 11, 1999
Audmey I. o. 66378
2331 Market Street
Camp Hill, PA 17011-4642
Telephone No. [717] 763-1383
Attorneys for Plaintiff
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