HomeMy WebLinkAbout99-04169
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
Plaintiff .
Versus
MICHAEL ALLEN SEILER,
STATE OF PENNA.
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...JUNE. _LOUISE SEILER,.
NO. _9,9-41.6,9 . .................
Defendant -
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DECREE IN
DI VORCE
AND NOW .............. 190 ..., it is ordered and
decreed that ......... June..Louise . Sailer .................... plaintiff,
and ....... Michael.Allen . Seller ........................... 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;
The Marriage, Settlement, Agreement, between .the• •pa> ti, $, shall. kq
incorpo but .sha.Ll.nat.merge. with.the.£inal.Decree.In •Divorce.
By T Co y,rt:
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Attest:
Prothonotary
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MARRIAGE SETTLEMENT AGREEMENT
By and Between
JUNE L. SEILER
- A N D -
MICHAEL A. SEILER
Dated: r c2, 1999
INDEX
Page
1. Divorce and Separation . . . . . . . . . . . . . . . . . . 2
2. Division of Property . . . . . . . . . . . . . . . . . . 2-5
3. Income Tax Prior Returns . . . . . . . . . . . . . . . 5
4. 1999 Income Tax Returns . . . . . . . . . . . . . . . 5-6
5. Execution of Additional Documents . . . . . . . . . . . . . 6
6. Transfers Subject to Liens . . . . . . . . . . . . . . . . 6
7. Complete Listing of Property . . . . . . . . . . . . . . . 6
8. Equitable Distribution of Property . . . . . . . . . . . . 7
9. Relinquishment of ownership . . . . . . . . . . . . . . . . 7
10. After-Acquired Property . . . . . . . . . . . . . . . . 7
11. Debts . . . . . . . . . . . . . . . . . 8-9
12. Bankruptcy or Reorganization Proceedings . . . . . . . . . 9
13. Alimony . . . . . . . . . . . . . . . . . . . . . . . . 10
14. Full Disclosure . . . . . . . . . . . . . . . . . . . . . 10
15. Releases . . . . . . . . . . . . . . . . . . . . 10
16. Indemnification . . . . . . . . . . . . . . . . . . . . 11-12
17. General Provisions . . . . . . . . . . . . . . . . . . . 12
18. Fair and Equitable Contents . . . . . . . . . . . . . 12
19. Breach . . . . . . . . . . . . . . . . . . . . 12-13
20. Independent Separate Covenants . . . . . . . . . . . . . 13
21. Void Clauses . . . . . . . . . . . . . . . . . . . . 13
22. Execution of Documents . . . . . . . . . . . . . . . . . 13
23. Applicable Law . . . . . . . . . . . . . . . . . . . . . 13
24. Non-Merger . . . . . . . . . . . . . . . . . . . . 14
25. Representation of Parties . . . . . . . . . . . . 14
Signature Page . . . . . . . . . . . . . . . . . 15
Acknowledgement Page . . . . . . . . . . . . . . . . . . 15
Exhibit "A" . . . . . . . . . . . . . . . . . . . . . . 16-17
MARRIAGE SETTLEMENT AGREEMENT
AGREEMENT MADE this lm `day of
1999,
by and between JUNE L. SEILER - A N D - MICHAEL A.
SEILER, at
Harrisburg, Pennsylvania.
WHEREAS, the parties hereto are husband and wife having
been married on July 11, 1984, at Cumberland County,
Pennsylvania.
WHEREAS, diverse unhappy differences, disputes and
difficulties have arisen between the parities 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
fully and finally their respective financial and property rights t
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and obligations as between each other including, without
limitation by specification: settling of all matters between p
them relating to the ownership and equitable distribution of real t'
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 I`
by one against the other or against their respective estates.
{
NOW, THEREFORE, in consideration of the fozegoing
premises and of the mutual promises, covenants and undertakings
I
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 interference 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 cause leading to their living apart. A
reconciliation will not void the provisions of this Agreement.
2. Division of Property. Husband and Wife agree
that the following constitutes an equitable distribution of the
marital property:
A. The following shall become the sole and exclusive
property of Husband:
1. Husband shall retain any pension plans and/or
retirement plans and/or employee stocks or savings
plans, and/or 40IK plans and/or any and all other
employment benefits, which he has accumulated
during the course of his past and/or present
employment. Specifically included herein are all
benefits to which Husband is entitled through his
employment with the Commonwealth of Pennsylvania,
as well as his Deferred Compensation Plan.
2. Husband shall retain his coin collection
located in the Commerce Bank safe deposit box.
3. Husband shall retain ownership of his 1996
Plymouth Voyager and shall. be fully responsible
for any loans or encumbrances thereon. It is
further agreed that Husband shall indemnify Wife
for any losses which she may incur as a result of
his failure to satisfy said loans or encumbrances.
B. The following shall become the sole and exclusive
property of Wife:
1. Wife shall retain any pension plans and/or
retirement plans and/or employee stocks or savings
plans, and/or 401K plans and/or any and all other
employment benefits, which she has accumulated
during the course of her past and/or present
employment.
2. Wife shall assume sole ownership of the
marital home located at 333 Charles Road,
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Mechanicsburg, Cumberland County, Pennsylvania
17055. Wife shall assume full responsibility for
the outstanding mortgage with York Federal and
shall indemnify Husband for any losses which he
may sustain as a result of her failure to satisfy
this mortgage. The parties agree that Husband
shall vacate the premises no later than September
30, 1999. The parties agree that Husband shall
execute a deed transferring ownership unto Wife
contemporaneously with the execution of this
Agreement.
3. Wife shall retain ownership of her 1997 Chevy
Prism and shall be fully responsible for any
existing loans or encumbrances thereon. It is
further agreed that Wife shall. indemnify Husband
for any losses which he may incur as a result of
her failure to satisfy said loans or encumbrances.
4. Wife shall retain ownership of the computer
upon which she is currently making payments.
C. It is hereby further agreed that the parties shall
ecually divide the household articles located in the marital home
as set forth in Exhibit "A". Any remaining household articles
shall be divided to the parties' mutual satisfaction prior to
Husband's vacating of the marital home.
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D. The parties acknowledge that they have each made
to the other a full accounting of their respective assets,
estate, liabilities, and other sources of income and based
thereon they mutually agree that the property listed above
constitutes the entire marital property.
3. Income Tax Prior Returns. The parties have
heretofore filed joint federal and state tax returns. Both
parties agree that in the event any deficiency in federal, state
or local income tax is proposed, or any assessment of any such
tax is made against either of them, each will indemnify and hold
harmless the other from and against any loss or liability for any
such tax deficiency or assessment and any interest, penalty and
expense incurred in connection t.herewith. 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.
4. 1999 INCOME TAX RETURNS. The parties agree that
they shall file joint federal and state income tax returns for
the year of 1999. The parties agree that they shall equally
divide any resulting income tar, return or income tax obligation
within three days of its receipt. It is further agreed that the
parties shall. maintain the same number of dependents which they
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currently claim for withholding purposes with their respective
employers for the year of 1999.
5. Execution of Additional Documents. The parties
agree to each sign Affidavits of Consent upon the expiration of
ninety (90) days following the filing and service of the Divorce
Complaint. The parties agree to execute any deeds, assignments,
titles or other instruments necessary and appropriate to
accomplish the aforesaid division of property.
6. Transfers Subject to_Liens. Notwithstanding any
other provisions in this document all property transferred
hereunder is subject to the existing li.c:n 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. Complete Listing of Property. 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.
6
8. Equitable Distribution of Property. By this
Agreement, the parties have intended to effect an equitable
distribution of their jointly 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
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j exchange of assets, and the division is being effectuated without
the introduction of outside funds or other property not
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constituting a part of the marital estate. It is the intention
of the parties to treat all transfers of property herein as non-
taxable.
9. Relinquishment of ownership. Except as provided
herein, Husband forever relinquishes any right and interest he
may now or hereafter have in any assets now belonging to Wife,
and Wife forever relinquishes any right or interest she may now
or hereafter have in any assets now belonging to Husband.
10. After-Acquired Property. Each of the parties shall
hereafter own and enjoy independently of any claim or right of
tho 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.
7
11. Debts.
A. Husband and wife agree to be responsible for
the joint debts of the parties as follows: Wife shall be fully
responsible for the FNBNA credit card with an outstanding balance
of approximately $5,600 and the Fleet VISA credit card with an
outstanding balance of approximately $6,900. wife shall be fully
responsible for the remainder of the mortgage on the marital home
with York Federal, as more fully set forth in Paragraph 2(B)(2).
Husband shall assume full responsibility for the balance of the
PSECU VISA credit card with an approximate balance of $5,000.
B. 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
8
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. Bankruptcy or Reorganization Proceedings. In the
event that either party becomes a debtor in any bankruptcy or
financial reorganization proceedings of any kind while any
obligations remain to be performed by that party for the benefit
of the other party pursuant to the provisions of this Agreement,
the debtor spouse hereby waives, releases and relinquishes any
right to claim any exemption (whether granted under State or
Federal law) to any properLy remaining in the debtor as a defense
to any claim made pursuant hereto by the creditor--spouse as set
forth herein, including all attorney fees and costs incurred in
the enforcement of this paragraph or any other provision of this
Agreement. No obligation created by this Agreement shall be
discharged or dischargeable, regardless of Federal or State law
to the contrary, and each party waives any and all right to
assert that obligation hereunder is discharged or dischargeable.
The parties mutually agree that in the event of
bankruptcy or financial reorganization proceedings by either
party in the future, any monies to be paid to the other party, or
to a third party, pursuant to the terms of this Agreement shall
constitute support and maintenance and shall not be discharged in
bankruptcy.
9
13. Alimony. The parties mutually agree to forego
or waive any right to alimony, alimony pendente lite, and spousal
support.
14. Full Disclosure. The respective parties do
hereby warrant, represent and declare that he and she have made a
f.u].1 and complete disclosure to the other of all assets of any
nature whatsoever in which such party has an interest and any
further enumeration or statement thereof in this Agreement is
specifically waived. Each party agrees that he or she shall not
at any future time raise such a defense or otherwise the lack of
such disclosure in any legal proceeding involving this Agreement
with the exception of disclosure that may have been fraudulently
withheld.
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 Cormer 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 or as otherwise stated in this
Agreement.
10
16. Indemnification. Each party represents and I
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 may be 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. Damac;es 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 the
warranties made by Husband or Wife to the other in this
Agreement, or breach or default- in performarice by Husband or Wife
of an7 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
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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 advise
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. 2t is expressly stipulated that if
either party fails in the due performance of any of his or her
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malfrnla1. ob]Lgations under this Agreement, the other party shall
have the right, at his or her election, to sue for damages for
broach thereof, to sue for specific performance, or to seek any
nlhor 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 any action or
proceeding to compel performance hereunder.
20. Independent Separate Covenants. It is
spec if.ical.ly understood and agreed by and between the parties
hereto that each paragraph hereof shall be deemed to be a
separate and independent Agreement.
21. Void Clauses. 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 provision shall be stricken from this
Agreement- and in all other respects this Agreement shall be valid
arui continue in full force, effect and operation.
22. 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.
23. Applicable Law. This Agreement shall be
construed under the laws of the Commonwealth of Pennsylvania.
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24. Non-Merger. This Agreement shall not merge with
any subsequent decree in divorce between the parties but shall
survive such decree and be entirely independent thereof. This
Agreement shall be incorporated for the purposes of enforcement
only into any Decree in Divorce which may be entered with respect
to the parties, but shall not be deemed to have been merged with
such Decree.
25. Representation of Parties. The parties have
mutually worked out the terms of this Marriage Settlement
Agreement. Wife has been represented by Kristin R. Reinhold,
Esquire. Husband has been advised of his right to retain an
independent counsel to represent him in this matter, however,
being so advised that he is entitled to independent legal
counsel, he hereby waives his right to the same.
IN WITNESS WHEREOF, the parties hereto have set their
hands and seals the day and year first above written.
Witness:
w/ x rI r
. rig S,,r,,
ea6'I, Meta Pnr u.. i.
C:nn!;.r and ,.
C: p+,, I County
Apj 1, 2002
Witnn:&am&A,,c
,w0sn a rk+Wnes
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J e L. Seiler
Michael A.Aei
Notarial Seal
Conatanco J. Martini, Notary Public
Hampden Twp.. Cumi:ar! :nd County
My Ciemmla5ioa Ex;"o, AO:ii 1, 2002
S'T'ATE OF PENNSYLVANIA Member,Penn;yluaniaAse;.c;a:; ornro;anss
SS:
COUNTY OF DAUPHIN
On this day of 1999, before me
day and year
aforesaid.
Notary Publit
My C Ex ires-
Notari^i Seal
Constance J. .I, ,r ry p+.Mie
Hampden TA,p.,r•s
- ;.r. i..lq
STATE OF PENNSYLVANIA My Comm!r,lc::; c'; i, ?C:!2
SS: Mambos naacay!r:.nla ?•,.,._..,r? a i;olz•es
COUNTY OF DAUPHIN
On this ? day of `y0,y u'1. 1999, before me
Subscriber, a Notary Public, for the Commonwealth of
Pennsylvania, came Michael A. Seiler, known to me or
satisfactorily proven to be the Husband in the aforegoin
Marriage Settlement Agreement.
Michael A. S er
o
Pennsylvania, came June L. Seiler., known to me or satisfactorily
proven to be the Wife in the aforegoing marriage Settlement
F+greement .
Subscriber, Witness a Notary my hand Publica, and f r Notarial the rial seal, Commonwealtheth of
.J1 e L. Seile
Witness my hand and Notarial seaithe day and year
aforesaid.
Notary Pus. c bl?ic
My Commission Expires:
1S
a,
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EXHIBIT "A"
DISTRIBUTION OF HOUSEHOLD ITEMS
ITEMS TO WIFE:
1.
2.
3.
4.
5.
6.
7.
8.
9.
10
11
12
13
14
15
16
'17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
Computer and Computer Desk
Washer and Dryer
Stove
Living Room Chair
Rocker
Mattress and Box Springs
Chest of Drawers (2)
Kitchen Table and 4 Chairs
Lawn Mower
Snow Blower
Telephone /Message Machine
Small Suitcase
Refrigerator
Futon Mattress
Desk
Bookshelf
Hope Chest
Vacuum
Chalkboard
Electric. Heaters
4 Wood Chairs
Black Closet
Foot Locker
School Chair
School Desks (2)
Fan
Air Conditioner (Living Room)
Air Conditioner (Downstairs Bedroom)
Air Conditioner (Upstairs Bedroom)
Nesting Tables
Picnic Table
Adirondack Chairs (2)
Personal Belongings (Clothes)
Books
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ITEMS TO HUSBAND:
1.
2.
3.
4.
i.
6.
7.
8.
9.
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Television
VCR
TV/VCR Butch
Entry Table
Wall Mirror.
Microwave
Tools
Sofa
Mattress/Box Spring
Chest of Drawers
File Cabinet
Large Suitcase
Small Suitcase
Travel Bag
Wine
Spool Table
Coffee Table
Crocks
Stool
wood chair (1)
Beer Making Equipment
Gas Grill
Golf Equipment
Books
Personal Belongings (Clothes)
17
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IN THE COURT OF COMMON PLEAS
JUNE LOUISE SEILER, CUMBERLAND COUNTY, PENNSYLVANIA
VS.
CIVIL DIVISION
MICHAEL ALLEN SEILER, NO. 99_4169 CIVILTERM
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)
R%lffibd ftkR1Y5t%2*-
(Strike out inapplicable section).
2. Date and manner of service of the complaint: dilly 14, 1999 by nersonn 1 cervi re
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 o .nb r Li. 1 QQQ ; by defendant nrf•.nher 23, 1999,
(b) (1) Date of execution of the affidavit required by §3301(d)
of the Divorce Code:
(2) Date of filing and service of the plaintiff's affidavit upon the respondent:
4. Related claims pending:
parties shall be incorporated but shall not merge with
the final Decree in Divorce.
5. Complete either (a) or (b).
(a) Date and manner of service of the notice of intention to file praecipe to transmit record, a
copy of which is attached:
(b) Date of plaintiff's Waiver of Notice in §3301 (c) Divorce was filed with
the Prothonotary: nrtnher 27, 14x4
Date defendant's Waiver of Notice in §3301 (c) Divorce was filed with
the Prothonotary: October 27, 1999:
Plaintiff / Defendant
uj
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JUNE LOUISE SEILER,
Plaintiff
v.
MICHAEL ALLEN SEILER,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
N0. ?el_ &411
CIVIL ACTION - LAW
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 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 marriage, you may request marriage
counseling. A list of marriage counselors is available in the
Office of the Prothonotary, Cumberland County Courthouse, One
Courthouse Square, Carlisle, Pennsylvania, 17013.
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 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
Telephone: (717) 249-3166
JUNE LOUISE SEILER, IN THE COURT OF COMMON PLEAS
Plaintiff. CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 91- ?IUq
MICHAEL ALLEN SEILER, CIVIL ACTION - LAW
Defendant IN DIVORCE
COMPLAINT IN DIVORCE
1. The Plaintiff is June Louise Seiler, an adult
individual currently residing at 333 Charles Road, Mechanicsburg,
Cumberland County, Pennsylvania, 17055.
2. The Defendant is Michael Allen Seiler, an adult
individual currently residing at 333 Charles Road, Mechanicsburg,
Cumberland County, Pennsylvania, 17055.
3. Plaintiff and Defendant have been bona fide residents
in the Commonwealth of Pennsylvania, for a period in excess of six
(6) months immediately previous to the filing of this Complaint.
4. Plaintiff and Defendant were married on July 11, 1984
in Cumberland County, Pennsylvania.
5. There have been no prior actions of divorce or
annulment between the parties in this or any other jurisdiction.
6. This action is not collusive.
7. Plaintiff and Defendant have not yet separated.
8. The grounds for divorce are: The marriage is
irreLrievably broken, and Defendant has offered such indignities to
the Plaintiff, Lhe innocent and injured spouse, as to render her
condition intolerable and her life burdensome.
9. Plaintiff and Defendant have no children.
10
marriage counseling and understands that she may request that
her spouse and she participate in counseling.
11. Plaintiff does riot request that the Court require
that: her spouse and she participate in counseling prior to a
divorce decree being handed down by this Court.
WHEREFORE, Plaintiff requests this Honorable Court enter
a final Decree in Divorce.
COUNT I - EQUITABLE DISTRIBUTION
12. Paragraphs one through eleven are incorporated by
reference herein.
13. During their marriage, Plaintiff and Defendant have
acquired various items of marital property, both real and personal,
which are subject to equitable distribution under Sections 3501 et.
s g - of the Divorce Code of 1980.
Plaintiff has been advised of the availability of
WHEREFORE, Plaintiff respectfully requests this Honorable
Court equitably distribute all marital property.
Date: c? C Respectfu?._ submitted,
Kris n R./ReinVold, Esquire
5922 Linglestown Road
Har i.sburg, PA 17112
(717) 671-1500
I.D. No. 57911
A F F I D A V I T
I> hdli<e Sp,?F?, hereby certify that the aforegoing
is true and correct to the best of my knowledge, information and
belief. I understand that false statements herein are made
subject to the Penalties of 18 Pa. C.S. 4904 relating to unsworn
falsification to authorities.
Dated: ?6• Jai_
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JUNE LOUISE SEILER,
Plaintiff
v.
MICHAEL ALLEN SEILER,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-4169 CIVIL
. CIVIL ACTION - LAW
. IN DIVORCE
AFFIDAVIT OF CONSENT AND
WAIVER OF COUNSELING
1. A Complaint in Divorce under Section 3301(c) of the
Divorce Cede was filed o. Ju]y 8, 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. T consent to the entry of a final Decree of Divorce after
service of notice of intention to request entry of the decree.
4. I have been advised of the availability of marriage
counseling and understand that I may request that the Court require
that my spouse and I participate in counseling. I further
understand that the Court maintains a list of marriage counselors
in the Prothonotary's Office, which list is available to me upon
request. Being so advised, I do not request that the Court require
that my spouse and I participate in counseling prior to a Decree
being handed down by the Court.
WAIVER OF NOTICE OF INTENTION TO RE UEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301 (c) OF THE DIVORCE CODE
1. T consent' to the entr,r of a ?inal D•ocree of Divorce
without further 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 subject
to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn
falsification to authorities. ,/Jn
Date (SA • L3
/ June Louise Seiler
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JUNE LOUISE SEILER,
Plaintiff
v.
MICHAEL ALLEN SEILER,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-4169 CIVIL
CIVIL ACTION -- LAW
IN DIVORCE
AFFIDAVIT OF CONSENT AND
WAIVER OF COUNSELING
1. A Complaint in Divorce under Section 3301(c) of the
Divorce Cnde ,,,as find on 3,111, 8, 1000
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 have been advised of the availability of marriage
counseling and understand that I may request that the Court require
that my spouse and I participate in counseling. I further
understand that the Court maintains a list of marriage counselors
in the Prothonotary's Office, which list is available to me upon
request. Being so advised, I do not request that the Court require
that my spouse and I participate in counseling prior to a Decree
being handed down by the Court.
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 ent^y of a Final Decree of Divorce
without further 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 subject
to the penalties of 18 Pa. C.S. Section 4904 relatirr§ o unsworn
falsification to authorities.
Date i ri - 2?, -1h Ck
Michael-1 en Seiler
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JUNE LOUISE SEILER, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 99-4169 CIVIL
MICHAEL ALLEN SEILER, CIVIL ACTION - LAW
Defendant IN DIVORCE
CERTIFICATE OF SERVICE
The undersigned,
, hereby certifies that
a copy of the Complaint in Divorce of June Louise Seiler v.
Michael Allen Seiler, No. 99-4169 Civil in the Court of Common
Pleas, Cumberland County, Pennsylvania, was served upon Michael
Allen Seiler, Defendant, on July 14, 1999 , at 9:45 a.m. at
his place of employment, Liquor Control Board, Northwest Office Building, Room 215,
Harrisburg, PA by handing a copy to the Defendant.
I hereby certify that the aforegoing is true
and correct to the best of my knowledge, information and belief.
I understand that false statements made herein are made subject
to the penalties of 18 Pa.C.S. §4904 relating to unsworn
falsification to authorities.
Date: July 14, 1999
Brent L. Stine
300 Hummel Ave.
Lemoyne, PA 17043
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