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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF PENNA.
LIDDICKi..._ ..............................
Plaintiff II No ...... 3.634 ........ ................. 19 99
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..HAROLD ........... ............
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t Defendant
'J DECREE IN
DI VORCE
AND ............ 19• Zo9a it is ordered and
-decreed that ....Patricia A. Liddick
plaintiff,
and ............xarold s. Liddick,,,,. 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;
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By The `Court:
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Attest: /f J.
P - Prothonotary
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PATRICIA A. LIDDICK, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL DIVISION
HAROLD J. LIDDICK,
Defendant NO. 99-3634 CIVIL TERM
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the following information to the court for entry of a
divorce decree:
Ground for divorce: irretrievable breakdown under §3301(c) of the Divorce Code.
2. Date and manner of service of the complaint: June 17, 1999; service by U.S. mail,
certified, restricted delivery, return receipt requested, postage prepaid; and by first class U.S. mail,
postage prepaid, as evidenced by the Certificate of Service filed with the Prothonotary on June 21,
1999.
3. Date of execution of the affidavit of consent required by §3301(c) of the Divorce Code:
by plaintiff March 15, 2000 ; by defendant March 15, 2000.
4. Related claims pending: None.
5. Date Plaintiffs Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary:
March 16, 2000
Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary:
March 16, 2000 /
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Marcy Wrig
Certified Legal Intern for the Plaintiff
Dated: March Ll , 2000
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PATRICIA A. LIDDICK, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : CIVIL ACTION - LAW
IN DIVORCE/EQUITABLE DISTRIBUTION
HAROLD J. LIDDICK,
Defendant : NO. 99- 3103L4 CIVIL TERM
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 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, Cumberland County Courthouse, 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, Pennsylvania 17013
(717) 249-3166
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply
with the Americans with Disabilities Act of 1990. For information about accessible facilities
and reasonable accommodations available to disabled individuals having business before the
court, please contact our office. All arrangements must be made at least 72 hours prior to
any hearing or business before the court. You must attend the scheduled conference or
hearing.
PATRICIA A. LIDDICK, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : CIVIL ACTION - LAW
IN DIVORCE/EQUITABLE DISTRIBUTION
HAROLD J. LIDDICK,
Defendant : NO. 99-31.0'`4 CIVIL TERM
COMPLAINT
The plaintiff, Patricia A. Liddick, by her attorneys, the Family Law Clinic, sets forth
the following causes of action:
COUNT I
DIVORCE UNDER 23 Pa C S 3301(c) OF THE DIVORCE CODE
1. Plaintiff is Patricia A. Liddick, who currently resides at 52 Country View Estates;
Newville, Cumberland County, Pennsylvania 17241.
2. Defendant is Harold J. Liddick, who currently resides at 52 Country View
Estates; Newville, Cumberland County, Pennsylvania 17241.
3. Plaintiff has been a bona fide resident of Cumberland County and the
Commonwealth for at least six months immediately previous to the filing of this Complaint.
4. The plaintiff and defendant were married on July 5, 1996 in Winchester, Virginia.
5. There have been no prior actions of divorce or for annulment between the parties.
6. The marriage is irretrievably broken.
7. Plaintiff has been advised that counseling is available and that plaintiff or
defendant may have the right to request that the court require the parties to participate in
counseling.
WHEREFORE, plaintiff requests the court to enter a decree of divorce dissolving the
marriage.
COUNT II
EQUITABLE DISTRIBUTION
8. Plaintiff repeats and realleges paragraphs one through seven.
9. Plaintiff and defendant have acquired property during their marriage, including, but
not limited to a 401(k) Retirement Plan and other items of personal property.
WHEREFORE, plaintiff requests the court to enter a decree dividing the property
equitably between the parties and granting such other relief as the court deems just.
Date (o- /S- "
Judson B. Perry
Certified Legal Intern
THOMAS M. PLACE
ROBERT E. RAINS
Supervising Attorney
DONALD MARRITZ
Staff Attorney
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, Pennsylvania 17013
(717) 243-2968
Fax: (717) 243-3639
Understanding that the making of any false statement would subject me to the
penalties of 18 Pa.C.S. §4904, the undersigned verifies that the statements made in the
foregoing Divorce and Equitable Distribution Complaint are true and correct, to the best of
my knowledge, information and belief.
Date . _ / - / q ?` o X?w t . 4Y .r CQ• cl?
Patricia A. Liddick
Plaintiff
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PATRICIA A. LIDDICK,
Plaintiff
V.
HAROLD J. LIDDICK,
Defendant
To the Prothonotary:
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
IN DIVORCE/EQUITABLE DISTRIBUTION
NO. 99- 3(p,) 4 CIVIL TERM
PRAECIPE TO PROCEED IN
FORMA PAUPERIS
Kindly allow Patricia A. Liddick, Plaintiff, to proceed in forma pauperis.
The undersigned counsel for the parry proceeding in forma pauperis certify that they
believe the party is unable to pay the costs and that they are providing free legal service to the
party. The party's affidavit showing inability to pay the costs of litigation is attached hereto.
Judson B. Perry
Certified Legal Intern
W.. ROBERT E. RAINS
THOMAS M. PLACE
Supervising Attorney
DONALD MARRITZ
Staff Attorney
THE FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, Pennsylvania 17013
(717) 243-2968
Fax:(717)243-3639
PATRICIA A. LIDDICK, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : CIVIL ACTION - LAW
: IN DIVORCE/EQUITABLE DISTRIBUTION
HAROLD J. LIDDICK,
Defendant : NO. 99-D(03t4 CIVIL TERM
AFFIDAVIT SUPPORTING PRAE IPE FOR LEAVE
TO PROCEED IN FORMA PA ERI
I am the Plaintiff in the above matter and because of my financial condition am
unable to pay the fees and costs of prosecuting or defending the action or proceeding.
2. I am unable to obtain funds from anyone, including my family and associates, to
pay the costs of litigation.
3. I represent that the information below relating to my ability to pay the fees and
costs is true and correct.
(a) Name: Patricia A. Liddick
Address: 52 Country View Estates; Newville, PA 17241
Social Security No.: 206-56-5971
(b) Employment
If you are presently employed, state
Employer: N/A -- At the present, I am under a Doctor's care and not allowed to
work.
Address: N/A
Salary or wages per month: N/A
Type of work: N/A
If you are presently unemployed, state
Date of last employment: May 1999 -- I quit due to a chest injury that rendered
me unable to work.
Salary or wages per month: $400/month
Type of work: Cleaning
(c) Other income within the past twelve months
Business or profession: $0
Other self-employment: Babysitting -- $50
Interest: $0
Dividends: $0
Pension and annuities: $0
Social security benefits: $0
Support payments: $0
Disability payments: $0
Unemployment compensation and supplemental benefits: $0
Workman's compensation: $0
Public Assistance: $0
Other: $0
(d) Other contributions to household support
Name: Harold J. Liddick
If your husband is employed, state
Employer: Carlisle Syntec
Salary or wages per month: $1,600/month
Type of work: Laborer
My husband provides me with room and board. However, he refuses to
contribute to the filing fee. Furthermore, my husband does not grant me
access to his banking accounts.
Contributions from children: $0
Contributions from parents: $0
Other contributions: $0
(e) Property owned
Cash: $0
Checking account: $0
Savings account: $0
Certificates of deposit: $0
Real estate (including home): $0
Motor vehicle: None
Cost, Amount Owed: N/A
Stocks; bonds: $0
Other: $0
(f) Debts and obligations
Mortgage: N/A
Rent: $0
Loans: $0
Other: Past Due Debts Not in Repayment -- $500
Persons dependent upon you for support
Name: None
Children, if any: None
Name: N/A Age: N/A
Other persons: None
Name: N/A
Relationship: N/A
4. My husband provides me with room and board. However, my husband refuses
to contribute the funds necessary for the divorce filing fee. Furthermore, my husband does not
grant me access to his bank accounts. I have attempted to raise the filing fee through
employment; however, a chest injury forced me to quit my job. I am currently under a Doctor's
care. My Doctor has instructed me not to work.
5. I understand that I have a continuing obligation to inform the court of
improvement in my financial circumstances which would permit me to pay the costs incurred
herein.
6. 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.
Date
Patricia A. Liddick
Petitioner
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PATRICIA A. LIDDICK, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : CIVIL ACTION - LAW
IN DIVORCE/EQUITABLE DISTRIBUTION
HAROLD J. LIDDICK,
Defendant : NO. 99-3634 CIVIL TERM
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on June 15,
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 unswom
falsification to authorities.
Date k-/S-aOf? On fl- 4 A
Patricia A. Liddick, Wife
52 Country View Estates
Newville, Pennsylvania 17241
(717) 776-4689
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PATRICIA A. LIDDICK,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V. : CIVIL ACTION - LAW
HAROLD J. LIDDICK, : IN DIVORCE/EQUITABLE DISTRIBUTION
Defendant : NO. 99-3634 CIVIL TERM
AFFIDAVIT OF CONSF,NT
1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on June 15,
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 unswom
falsification to authorities.
Date / o
Harold J. ick, Husban
52 Country View Estates
Newville, Pennsylvania 17241
(717) 776-4689
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PAT RICIA A. LIDDICK,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V. : CIVIL ACTION - LAW
IN DIVORCE/EQUITABLE DISTRIBUTION
HAROLD J. LIDDICK,
Defendant : NO. 99-3634 CIVIL TERM
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
43301(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 unswom
falsification to authorities.
Date 3-20c-X)
Patricia A. Liddick, Wife
52 Country View Estates
Newville, Pennsylvania 17241
(717) 776-4689
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PATRICIA A. LIDDICK, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : CIVIL ACTION - LAW
HAROLD J. LIDDICK, : IN DIVORCE/EQUITABLE DISTRIBUTION
Defendant : NO. 99-3634 CIVIL TERM
WAIVER OF NOTICE OF INTENTION TO RE (JEST
ENTRY OF A DIVORCE DECREE UNDER
933i11(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 unsworn
falsification to authorities.
Date -
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Harold J. ' ick, Husband
52 Country View Estates
Newville, Pennsylvania 17241
(717) 776-4689
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PATRICIA A. LIDDICK, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : CIVIL ACTION - LAW
IN DIVORCE/EQUITABLE DISTRIBUTION
HAROLD J. LIDDICK,
Defendant ; NO. 99-3634 CIVIL TERM
CERTIFICATE OF SERVICE
I, hereby certify that I have served a true and correct copy of the Divorce Complaint
on Harold J. Liddick, at 52 Country View Estates; Newville, Cumberland County,
Pennsylvania 17241 by U.S. mail, certified, restricted delivery, return receipt requested,
postage prepaid; and by first class U.S. mail, postage prepaid. Service was complete upon
receipt by Harold J. Liddick on the 17th day of June, 1999 as evidenced by his signature on
the attached green card.
Z 332 848 820
US Postal Service
Receipt for Certified Mail
No Insurance Coveralls, Provided.
Do not use for Inlemational Mail See reverse
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Certified Legal Intern
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, Pennsylvania 17013
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PATRICIA A. LIDDICK, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA
V. : CIVIL ACTION - LAW
: IN DIVORCE/EQUITABLE DISTRIBUTION
HAROLD J. LIDDICK,
Defendant : NO. 99-3634 CIVIL TERM
CERTIFICATE OF SERVICE
I hereby certify that I served a true copy of the Affidavit of Consent and Waiver of
Notice of Intention to Request Entry of a Divorce Decree under 3301(c) of the Divorce
Code, on the Defendant, Harold J. Liddick, by handing him the same at the offices of the
Family Law Clinic, 45 North Pitt Street, Carlisle, Pa., on the 15" day of March, 2000.
Marcy E. i ht
Certified Legal Intern
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, Pennsylvania 17013
(717) 243-2968
Fax: (717) 243-3639
Dated: March A? , 2000
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PATRICIA A. LIDDICK, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA
V. : CIVIL ACTION - LAW
IN DIVORCE/EQUITABLE DISTRIBUTION
HAROLD J. LIDDICK,
Defendant : NO. 99-3634 CIVIL TERM
CERTIFICATE OF SERVICE
I hereby certify that I am serving a true copy of the Praecipe to Transmit Record and
the Vital Records, on the Defendant, Harold J. Liddick, at 52 Country View Estates;
Newville, Cumberland County, Pennsylvania, by first class U.S. mail, postage prepaid, on
the 24th day of March, 2000.
azcy E. V ig
Certified L gal Intern
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, Pennsylvania 17013
(717) 243-2968
Fax: (717) 243-3639
Dated: March ?, 2000
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MAR 2 2 20p",)
PATRICIA A. LIDDICK, : Ni THE COURT OF COMMON PLEAS OF
Plaintiff' : CUMBERLAND COUNTY, PENNSYLVANIA
V. : CIVIL ACTION - LAW
IN DIVORCE/EQUITABLE DISTRIBUTION
HAROLD J. LIDDICK,
Defendant : NO. 99-3634 CIVIL TERM
QUALIFIED DOMESTIC RELATIONS ORDER
AND NOW, this day of _!M„(,Ll , 2000, upon consideration of the parties'
Marital Settlement Agreement, the following Order is entered:
1. The terms of this Order are made pursuant to the Marital Settlement Agreement entered
into by the parties on the l1'" day of { q 5 &? , 2000. The terms of the Marital
Settlement Agreement are incorporated herein.
2. The parties agree that Husband, Harold J. Liddick, is participating in The Carlisle
Employee Incentive Savings Plan sponsored and administered by Carlisle Companies, Inc., 250
South Clinton Street, Suite 201, Syracuse, NY 13202-1258.
3. The parties agree that Wife, Patricia A. Liddick, has been married to Husband since
July 5, 1996, a period during which Carlisle Syntec, Inc. employed Husband.
4. The parties agree that Wife shall be paid directly from Husband's savings plan a lump
sum of $3,500. The plan administrator shall pay Wife the lump sum of $3,500 within sixty (60)
days of the entry of this Order. The parties agree that said $3,500 is not required to be paid to
another alternate payee. This lump sum distribution shall fully satisfy Wife's equitable
distribution claim.
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5. Husband's full name and social security number are: Harold J. Liddick, Jr. (S.S. # 194-
42-7537). Husband currently resides at 52 Country View Estates. Newville, Pennsylvania 17241.
Wife's full name and social security number are: Patricia A. Liddick (S.S. # 206-56-5971). Wife
currently resides at 52 Country View Estates, Newville, Pennsylvania 17241.
6. Husband's retirement benefits are marital property subject to equitable distribution by
the Court of Common Pleas of Cumberland County, Pennsylvania, pursuant to 23 Pa.C.S. 3502.
The Court of Common Pleas of Cumberland County, Pennsylvania has jurisdiction over this
action pursuant to Pa.R.Civ.P. 1920.2.
Having been stipulated to by both parties, this is a final Court Order under the provisions
of the Pennsylvania Divorce Code.
By the Court,
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51
PATRICIA A. LIDDICK,
Plaintiff
V.
HAROLD J. LIDDICK,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
IN DIVORCE/EQUITABLE DISTRIBUTION
NO. 99-3634 CIVIL TERM
MARITAL SETTLEMENT AGREEMENT
The parties to this action are Patricia A. Liddick, Plaintiff (hereinafter "Wife"),
who resides at 52 Country View Estates, Newville, Pennsylvania 17241, and Harold J. Liddick,
Defendant (hereinafter "Husband"), who resides at 52 Country View Estates, Newville,
Pennsylvania 17241.
2. In full and complete satisfaction of all economic claims, Husband shall timely
take all necessary steps to ensure that Husband's employer, Carlisle Syntec, Inc., shall disburse a
lump sum payment of $3,500 from Husband's Employee Incentive Savings Plan to Wife, said
sum t( be paid pursuant to the Qualified Domestic Relations Order within sixty (60) days of
entry of the Qualified Domestic Relations Order, which is attached and incorporated herein by
reference. Upon receipt of the $3,500, Wife shall promptly withdraw her Equitable Distribution
of marital property claim, and both parties shall take such action as is necessary on their part to
finalize the divorce.
3. Within ninety (90) days after Wife receives the distribution of the lump sum
payment of $3,500 from Husband's Employee Incentive Savings Plan to be paid pursuant to the
Qualified Domestic Relations Order, it is Wife's intention to remove herself and her personal
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belongings from the marital residence at 52 Country View Estates, Newville, Pennsylvania
17241.
4. The parties shall cooperate in the filing of tax returns for the years 1999, and 2000
(if applicable), and shall evenly split any tax refunds received as a result of the filing of joint tax
returns for the years 1999, and 2000 (if applicable).
5. Husband acknowledges that he has been informed that the Family Law Clinic
only represents Wife in this matter and has given him no legal advice other than to seek his own
counsel which he has chosen not to do.
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Harold J. Lfi dick, Husband Date Patricia A. Liddick, Wife Date
52 Country View Estates 52 Country View Estates
Newville, Pennsylvania 17241 Newville, Pennsylvania 17242
(717) 776-4689 (717) 776-4689
Pro Se
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Marcy W?ght, .gifted Legal Intern 15ate
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The Fam I Law uric
45 North Pitt Street
Carlisle, Pennsylvania 17013
(717) 243-2968
for Patricia A. Liddick, Wife
obert E. Rains, Supervising Attorney Date
The Family Law Clinic
45 North Pitt Street
Carlisle, Pennsylvania 17013
(717) 243-2968
for Patricia A. Liddick, Wife
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PATRICIA A. LIDDICK, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA
V. : CIVIL ACTION - LAW
IN DIVORCE/EQUITABLE DISTRIBUTION
HAROLD J. LIDDICK,
Defendant : NO. 99-3634 CIVIL TERM
CERTIFICATE OF SERVICE
I hereby certify that I served a true copy of the Marital Settlement Agreement and
Qualified Domestic Relations Order, on the Defendant, Harold J. Liddick, by handing him
the same at the offices of the Family Law Clinic, 45 North Pitt Street, Carlisle,
Pennsylvania, on the 15" day of March, 2000.
Marcy E. fight
Certified L gal Intern
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, Pennsylvania 17013
(717) 243-2968
Fax: (717) 243-3639
Dated: March /V, 2000
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PATRICIA A. LIDDICK, : IN THE COURTOF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : CIVIL ACTION - LAW
IN DIVORCE/EQUITABLE DISTRIBUTION
HAROLD J. LIDDICK,
Defendant : NO. 99-3634 CIVIL TERM
ORDER OF COURT
AND NOW, this ? day of 2000, upon presentation and consideration of
the attached Marital Settlement Agreement Modification, it is hereby ordered and decreed that
the attached agreement is made an Order of Court.
BY THE COURT.
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PATRICIA A. LIDDICK,
Plaintiff
V.
HAROLD J. LIDDICK,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
IN DIVORCE/EQUITABLE DISTRIBUTION
NO. 99-3634 CIVIL TERM
MARITAL SETTLEMENT AGREEMENT MODIFICATION
2.
4.
The parties to this action are Patricia A. Liddick, Plaintiff (hereinafter "Wife"), who
resides at 52 Country View Estates, Newville, Pennsylvania 17241, and Harold J.
Liddick, Defendant (hereinafter "Husband"), who resides at 52 Country View Estates,
Newville, Pennsylvania 17241.
A Marital Settlement Agreement between Husband and Wife was made an Order of Court
on March 29, 2000.
Paragraph three (3) of the Marital Settlement Agreement states as follows: "Within ninety
(90) days after Wife receives the distribution of the lump sum payment of $3,500 from
Husband's Employee Incentive Savings Plan to be paid pursuant to the Qualified
Domestic Relations Order, it is Wife's intention to remove herself and her personal
belongings from the marital residence at 52 Country View Estates, Newville,
Pennsylvania 17241."
Husband and Wife agree that Paragraph three (3) of the Marital Settlement Agreement
should be modified to read as follows: "Husband shall remove himself and his personal
belongings from the marital residence at 52 Country View Estates, Nexvville,
Pennsylvania 17241, on or before the `day of y 2000."
5. Husband acknowledges that he has been informed that the Family Law Clinic only
represents Wife in this matter and has given him no legal advice other than to seek his
own counsel which he has chosen not to do.
6. Husband and Wife desire that this Marital Settlement Agreement Modification be made
an Order of Court.
Zn" ?6
Harold J. Lid ck, Husband / D e
52 Country View Estates
Newville, PA 17241
(717) 776-4689
Pro Se
Patricia A. Llddlek, Wife Date
52 Country View Estates
Newville, PA 17241
(717) 776-4689
f ylA? I 61C A 7-ID-M
Melanie D. Walz Date
Certified Legal Intern
ROBERT E. RAINS Date
THOMAS M. PLACE
Supervising Attorneys
DONALD MARRITZ
Staff Attorney
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
(717) 243-2968
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