HomeMy WebLinkAbout07-2075CHARLOTTE TRIMBLE, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. .
NO.0T- 26 79'CIVIL TERM
RICKY L. TRIMBLE, CIVIL ACTION - LAW
Defendant IN DIVORCE
NOTICE
You have been sued in court. If you wish to defend against the claims set forth in the
following pages, you must take prompt action. You are warned that if you fail to do so, the case
may proceed without you and a decree in 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 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 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 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
32 South Bedford Street
Carlisle, Pennsylvania 17013
717-249-3166
1-800-990-9108
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.
CHARLOTTE E. TRIMBLE, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO.67• ,-o 7ACIVIL TERM
RICKY L. TRIMBLE, CIVIL ACTION - LAW
Defendant IN DIVORCE
COMPLAINT IN DIVORCE PURSUANT TO
SECTION 3301(c) AND 3001(d) OF THE DIVORCE CODE
NOW comes the Plaintiff, Charlotte E. Trimble, by her attorneys, Irwin & McKnight,
Esquires, and files this complaint in divorce against the Defendant, Ricky L. Trimble,
representing as follows:
1. The Plaintiff is Charlotte Trimble, an adult individual residing at 25 West Main Street,
Blain, Perry County, Pennsylvania 17006.
2. The Defendant is Ricky L. Trimble, an adult individual residing at 301 Belvedere Street,
Carlisle, Cumberland County, Pennsylvania 17013.
3. The Plaintiff and Defendant have been residents of the Commonwealth of Pennsylvania
at least six months prior to the filing of this action in divorce.
4. The Plaintiff and the Defendant were married on September 12, 1981 in Perry County,
Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the parties.
6. Pursuant to the Divorce Code, Sections 3301(c) and 3301(d), the Plaintiff avers as the
grounds upon which this action is based that the marriage between the parties is irretrievably
broken.
7. The Plaintiff avers that she has been advised of the availability of counseling and that said
party has the right to request that the court require the parties to participate in counseling.
WHEREFORE, the Plaintiff respectfully requests judgment dissolving the marriage
between the two parties.
IRWIN & McKNIGHT
Y
arcus A. Mc ig t, III, squire
Attorney for plain
60 West Pomfret Stree
Carlisle, Pennsylvania 170
717-249-2353
Supreme Court I.D. No. 25476
Date: April 13, 2007
VERIFICATION
The foregoing document is based upon information which has been gathered by
counsel and myself in the preparation of this action. I have read the statements made in this
document and they are true and correct to the best of my knowledge, information and belief. I
understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section
4904, relating to unsworn falsification to authorities.
11C1.?G? ? ?
RLOTTE E. TRIMBLE
Date: April 13, 2007
l~r
C. h l
?___a
`-f a
-._/
-_--?
__ - ._ (7%
- ?i:
' _
?
.,
`"7
?; ;? ?
_ ?? .,'J
?„?
CHARLOTTE TRIMBLE, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO.67-do ? S CIVIL TERM
RICKY L. TRIMBLE, CIVIL ACTION - LAW
Defendant IN DIVORCE
PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT
The plaintiff, being duly sworn according to law, deposes and says:
1. 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.
2. I understand that the court maintains a list of marriage counselors
in the Prothonotary's Office, which list is available to me upon
request.
3. Being so advised, I do not request that the court require that my
spouse and I participate in counseling prior to a divorce decree
being handed down.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein made are made subject to the penalties of 18 Pa. C. S. Section 4904
relating to unsworn falsification to authorities.
?L?%Gf 0`(iGC? G
RLOTTE TRIMBLE
Date: April 13, 2007
O
u1 ^.? iii
CIO
0 -u
CHARLOTTE TRIMBLE, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. 2007-2075 CIVIL TERM
RICKY L. TRIMBLE, CIVIL ACTION - LAW
Defendant IN DIVORCE
AFFIDAVIT OF SERVICE OF COMPLAINT
PURSUANT TO PA. R.C.P. RULE NO. 1920.4 (a)(1)(i)
COMMONWEALTH OF PENNSYLVANIA .
. SS:
COUNTY OF CUMBERLAND
NOW, Marcus A. McKnight, III, Esquire, being duly sworn according to law, does
depose and state:
1. That he is a competent adult and attorney for the plaintiff in the captioned action in
divorce.
2. That a certified copy of the Complaint in Divorce was served upon the defendant,
Ricky Trimble, on May 7, 2007, by certified, restricted delivery mail, addressed to him at 820
Belvedere Street, Carlisle, Pennsylvania 17013, with Return Receipt Number 7004 1350 0003
7289 3600.
hereof.
3. That the said receipt for certified mail is signed and attached hereto and made a part
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein made are subject to the penalties o 18 Pa. C. S. Section 4904, relating to
unsworn falsification to authorities.
C?
3 A. McKNIGHT, III, ESQUIRE
for Plaintiff
Date: May 8, 2007
r^ ?
¦ Compbflfi IMms 1, 2, and & Also complete
..._ J%m 4 If Rabicted Delivery Is desired.
¦ Print your name and address on the reverlte
so float we can return the card to you.
¦ Attach this card to the back of the mallpiece,
or on the front K space permit&
1. ArWe Addressed to:
MR RICKY TRIIEBLE
820 BELVEDERE STREET
CARLISLE PA 17013
X /. f/,/, i???' o adcrs
.V byl Y/_ Dial C? 7
D. b delmy addm a di faraat flan ram 1? ? Yea
If YE8, ~ d*my addlen below: ? No
1760
3. Servfoa Typo
Qkt,;erUlbd Mdf D E><prsae Mal
0 Reo dww ?W Retaam Reow for Merdaadae
a Irwired MW a CAA.
2. ArtldeNurnOer 7004 1350 0003 7289 3600
(>far?srtsrAoar earMrr ?
PS Form 3611, Fanuoryr 2004 Don+eeao RsMan %we"
CERTIFIED MAI
Doinestic Mail Only; No I
For delivery information visit
M1 st
P $
? 3 0
o
age I D o
N urulT
C3 Cerdfled Fee J (? o N:? 9
p R
t
R F C :
C3 urn
e
ee
(Endorsement Reclu Required)
? i '6 T
CO
o N
i
C3 Restricted DeiNer
Fee
J
y
(Endorsement Required) , 7 N 40
m Total Postage & Fees $ p
D p O '
I
y
C3
p
r?
0
r..:, - a
`
n ? a
r- ?: ??; .--?
i?
. r
-
Yj . ;
?
`
l?
CHARLOTTE E. TRIMBLE, : IN THE COURT OF COMMON PLEAS OF
Petitioner/Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. 2007-2075 CIVIL TERM
RICKY L. TRIMBLE, CIVIL ACTION - LAW
Respondent/Defendant IN DIVORCE
MOTION FOR APPOINTMENT OF MASTER
CHARLOTTE E. TRIMBLE, Plaintiff, moves the court to appoint a master with respect to the
following claims:
a. Equitable distribution of the marital assets;
b. Alimony;
C. Costs and expenses; and
d. Counsel fees.
and in support of the motion states:
1. Discovery is complete as the claims(s) for which the appointment of a master
is requested.
2. The Plaintiff, Charlotte E. Trimble, has appeared in this action by her attorney,
Marcus A. McKnight, III, Esquire.
3. The statutory ground for divorce is No-Fault 3301(c).
4. Delete the inapplicable paragraph(s):
a. The action is contested.
b. An agreement has been reached with respect to the following claims: Divorce
C. The action is contested with respect to the following claims:
Equitable distribution of the marital assets; Costs and expenses; and Counsel
fees.
5. The action does not involve complex issues of law or fact.
6. The hearing is expected to take one-half (1/2) day.
7. Additional informatio:
Date: 0.- rS- '-'11'V7
AND NOW
the following claims:
Esquire, is appointed Divorce Master with respect to
By the Court:
J.
?
C"?
?
p
T- .: ? ??
=?- -
. ;
??
--
=? rU ``?i
;.?
?
. _ c..?
ra
CHARLOTTE E. TRIMBLE, : IN THE COURT OF COMMON PLEAS OF
Petitioner/Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. 2007-2075 CIVIL TERM
RICKY L. TRIMBLE, CIVIL ACTION - LAW
Respondent/Defendant IN DIVORCE
PETITION FOR ECONOMIC RELIEF
AND NOW, this 15th day of October 2007, comes the Plaintiff/Petitioner, Charlotte E.
Trimble, by her attorneys, IRWIN & McKNIGHT, and makes the following Petition for
Economic Relief against the Defendant/Respondent, Rickey L. Trimble, as follows:
1.
The Petitioner is Charlotte E. Trimble who is the Plaintiff in a divorce action filed at in
Cumberland County, Pennsylvania. Her address is 25 West Main Street, Blain, Perry County,
Pennsylvania 17006.
2.
The Respondent is Ricky L. Trimble who is the Plaintiff in this divorce action. His
address is 301 Belvedere Street, Carlisle, Cumberland County, Pennsylvania 17013.
3.
The petitioner seeks the following relief from the Court:
a. Equitable distribution of the marital assets;
b. Alimony;
C. Costs and expenses; and
d. Counsel fees.
WHEREFORE, the Petitioner, Charlotte E. Trimble, requests the relief set forth above.
Respectfully submitted,
IRWIN & McKNIGHT
By: Ale, ( ?9'
Marcus tmfret Mc i tII Esq.
60 West Street
Carlisle, PA 17013
717-249-2353
Supreme Court I.D. No: 25476
Attorney for the Petitioner
Date: October 15, 2007
2
VERIFICATION
The foregoing document is based upon information which has been gathered by counsel
and myself in the preparation of this action. I have read the statements made in this document
and they are tme and correct to the best of ?ray knotviedge, irfo*_-ma ion and belief. I under-,tand
that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904,
relating to unsworn falsification to authorities.
ARLOTTE E. TRIMBLE
Date: October 15, 2007
3
t
w
?w
t
ag
J
a
0
c-
a
C "'9
^-i
C71
?"tl
OCT 1 7 2007/'
CHARLOTTE E. TRIMBLE, : IN THE COURT OF COMMON PLEAS OF
Petitioner/Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. 2007-2075 CIVIL TERM
RICKY L. TRIMBLE, CIVIL ACTION - LAW
Respondent/Defendant IN DIVORCE
MOTION FOR APPOINTMENT OF MASTER
CHARLOTTE E. TRIMBLE, Plaintiff, moves the court to appoint a master with respect to the
following claims:
a. Equitable distribution of the marital assets;
b. Alimony;
C. Costs and expenses; and
d. Counsel fees.
and in support of the motion states:
1. Discovery is complete as the claims(s) for which the appointment of a master
is requested.
2. The Plaintiff, Charlotte E. Trimble, has appeared in this action by her attorney,
Marcus A. McKnight, III, Esquire.
3. The statutory ground for divorce is No-Fault 3301(c).
4. Delete the inapplicable paragraph(s):
a. The action is contested.
b. An agreement has been reached with respect to the following claims: Divorce
C. The action is contested with respect to the following claims:
Equitable distribution of the marital assets; Costs and expenses; and Counsel
fees.
5. The action does not involve complex issues of law or fact.
6. The hearing is expected to take one-half ('h) day.
7. Additional information, if any, relevant to the
Date: Qc L•604 fro. VV7
AND NOW / 4 .?OV7i lQo-?ec?ire, is appointed Divorce Master with respect to
the following claims:
v
I
zzzz
-Ml
rn T- ,
w?
X: 2= IZZJ
C;> N •-
t++
r-L
C7
rn
CHARLOTTE E. TRIMBLE, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 2007-2075 CIVIL ACTION - LAW
RICKY L. TRIMBLE, IN DIVORCE
Defendant
PRAECIPE TO ENTER APPEARANCE
TO THE PROTHONTARY OF SAID COURT:
Please enter my appearance on behalf of Defendant, Ricky L. Trimble, in the
above captioned matter.
Respectfully submitted,
Date: (a ruprecqu aM. Verney, Esquire
me Ct. ID # 23167
44 S. Hanover Street
Carlisle, PA 17013
(717) 243-9190
u
ra
X
33
Y€..
?
C CV ?
CHARLOTTE E. TRIMBLE,
Plaintiff
V.
RICKY L. TRIMBLE,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2007-2075 CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was
filed on April 13, 2007.
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.
section 4904, relating to unsworn falsificatio
Date: (J - 13 -o k
fir,
CHARLOTTE E. TRIMBLE,
Plaintiff
V.
RICKY L. TRIMBLE,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2007-2075 CIVIL ACTION - LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE
DECREE UNDER SECTION 3301 (C) OF THE DIVORCE CODE
1. I consent to the entry of a final decree of divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by the Court
and that a copy of the decree will be sent to me immediately after it is filed with the
prothonotary.
I verify that the statements made in this affidavit are true and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating
to unsworn falsification to authorities.
Date: 14- (-5 -0k
?
?? o
c?
`?+
<'. "'
?
?
t~-
?,..
?
?. ?
t? F?
(
'
CHARLOTTE E. TRIMBLE, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. NO. 07 - 2075 CIVIL
RICKY L. TRIMBLE,
Defendant IN DIVORCE
ORDER OF COURT
AND NOW, this /& a day of 0_e'? ,
20081 the economic claims raised in the proceedings having been
resolved in accordance with a marriage settlement agreement
dated October 13, 2008, the appointment of the Master is
vacated and counsel can file a praecipe transmitting the record
to the Court requesting a final decree in divorce.
BY THE COURT,
cc: arcus A. McKnight, III
Attorney for Plaintiff
Jacqueline M. Verney
Attorney for Defendant S
w--
C ce)
ts1 .? -> ?_?
CL- =
? N ?
MARRIAGE SETTLEMENT AGREEMENT
THIS AGREEMENT made this to day of October 2008 by and between
CHARLOTTE E. TRIMBLE, (hereinafter referred to as "WIFE") and RICKY L. TRIMBLE,
hereinafter referred to as "HUSBAND")
WITNESSETH:
WHEREAS, HUSBAND and WIFE were lawfully married on September 12, 1981, in
Perry County, Pennsylvania. WIFE filed a Complaint in Divorce in Cumberland County,
Pennsylvania, docketed at 2007-2075 Civil Term on April 13, 2007. The parties hereto agree
and covenant as follows:
1.
The parties intend to maintain separate and permanent domiciles and to live apart from
each other. It is the intent and purpose of this Agreement to set forth the respective rights and
duties of the parties while they continue to live apart from each other.
2.
The parties have attempted to divide their matrimonial property in a manner which
conforms to a just and right standard, with due regard to the rights of each party. It is the intent
of the parties that such division shall be final and shall forever determine their respective rights.
The division of existing marital property is not intended by the parties to constitute in any way a
sale or exchange of assets.
3.
Further, the parties agree to continue living separately and apart from the other at any
place or places that he or she may select as they have heretofore been doing. Neither party shall
molest, harass, annoy, injure, threaten or interfere with the other party in any matter whatsoever.
Each party may carry on and engage in any employment, profession, business or other activity as
he or she may deem advisable for his or her sole use and benefit. Neither party shall interfere
with the uses, ownership, enjoyment or disposition of any property now owned and not specified
herein nor property hereafter acquired by the other.
4.
The consideration for this contract and agreement is the mutual benefit to be obtained by
both of the parties hereto and the covenants and agreements of each of the parties to the other.
The adequacy of the consideration for all agreements herein contained is stipulated, confessed,
and admitted by the parties, and the parties intend to be legally bound hereby.
Each party to the Agreement acknowledges and declares that he or she, respectively:
a. is represented by counsel of his or her own choosing;
b. is fully and completely informed of the facts relating to the subject
matter of this Agreement and of the rights and liabilities of the parties;
c. enters into this Agreement voluntarily after receiving advice of counsel;
d. has given careful and mature thought to the making of this Agreement;
e. has carefully read each provision of this Agreement; and
f. fully and completely understands each provision of this Agreement,
both as to the subject matter and legal effect.
This Agreement shall become effective immediately as of the date of execution.
2
5.
It is the purpose and intent of this Agreement to settle forever and completely the interest
and obligations of the parties in all property that they own separately, and all property that would
qualify as marital property under the Pennsylvania Divorce Code, Title 23, Section 401(e), and
that is referred to in this Agreement as "Marital Property", as between themselves, their heirs and
assigns. The parties have attempted to divide their Marital Property in a manner that conforms to
a just and fair 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 further purpose of this Agreement to settle forever and completely any obligation
under the Pennsylvania Divorce Code relating to spousal support or alimony.
6.
Each party represents and warrants that he or she has made a full and fair disclosure. to the
other of all of his or her property interests of any nature, including any mortgage, pledge, lien,
charge, security interest, encumbrance, or restriction to which any property is subject. Each party
further represents that he or she has made a full and fair disclosure of all debts and obligations of
any nature for which he or she is currently liable or may become liable. Each further represents
and warrants that he or she has not made any gifts or transfers for inadequate consideration of
Marital Property without the prior consent of the other.
Each Party acknowledges that, to the extent desired, he or she has had access to all joint
and separate State and Federal Tax Returns filed by or on behalf of either or both Parties during
marriage.
3
7.
REAL ESTATE: The parties own the property known as 25 West Main Street, Blain.
Pennsylvania 17006. HUSBAND agrees to convey his right, title and interest in the property to
WIFE. WIFE agrees to refinance the mortgage into her own name within one hundred twenty
(120) days of the signing of this Agreement.
8.
DEBTS: HUSBAND will be solely responsible for his own debts. WIFE will be solely
responsible for her debts. HUSBAND will indemnify and hold harmless WIFE from all
obligation related to his debts. WIFE will be solely responsible and will indemnify and hold
harmless HUSBAND from any claim made against him related to her debts.
9.
SPOUSAL SUPPORT AND ALIMONY: The parties hereby agree that the
HUSBAND will pay WIFE the sum of Three Hundred and no/100 ($300.00) Dollars per month
to be paid in bi-weekly payments of $138.47 for eighteen (18) months or until WIFE
cohabitates, remarries, or the death of one of the parties.
10.
PERSONAL PROPERTY: The parties agree that the personal property shall be divided
as follows:
HUSBAND shall receive the following items:
a. The personal property in his possession;
b. All items listed on attached Exhibit "A";
c. His bank accounts;
d. Any life insurance policy;
e. His employee benefits; and
e. Fifty percent (50%) of his marital retirement with the Commonwealth of
Pennsylvania.
4
WIFE shall receive the following items:
a. The personal property in her current possession;
b. Her bank accounts;
c. Any life insurance policy;
d. The cemetery plots at Blain Cemetery; and
e. Fifty percent (50%) of HUSBAND's marital retirement with the
Commonwealth of Pennsylvania.
The WIFE hereby waives all right and title which she may have in any personal property
of the HUSBAND. HUSBAND likewise waives any interest which he has in the personal
property of the WIFE. Henceforth, each of the parties shall own, have and enjoy independently
of any claim or right of the other party, all items of personal property of every kind, nature and
description and wherever situated, which are then owned or held by or which may hereafter
belong to the HUSBAND or WIFE with full power to the HUSBAND or the WIFE to dispose
of same as fully and effectually, in all respects and for all purposes as if he or she were
unmarried. Each party agrees that neither will incur obligations, liens or liabilities on account of
the other and that from the date of this Agreement, neither party shall contract or incur
obligations, liens or any liability whatsoever on account of the other.
11.
AUTOMOBILES:
a. HUSBAND agrees to waive any and all interest which he may have in the
automobiles in possession of the WIFE.
b. WIFE agrees to waive any and all interest which she may have in the
automobiles in possession of the HUSBAND. HUSBAND agrees to
convey title to WIFE's 1992 Pontiac Grand Prix automobile.
They each waive any claim which they have in any automobile owned by the other party.
5
12.
INSURANCE AND EMPLOYEE BENEFITS: Except for the HUSBAND's
retirement with the Commonwealth of Pennsylvania, the parties waive all interest in the benefits
of one another.
13.
BENEFITS AND BANK ACCOUNTS: WIFE agrees to waive all right, title and
interest which she may have in the savings or checking or any other bank accounts of the
HUSBAND. The HUSBAND agrees to waive all interest which he may have in the savings or
checking or any other bank accounts of the WIFE.
14.
DIVORCE: The parties both agree to cooperate with each other in obtaining a final
divorce of the marriage. It is agreed that the parties will execute and file the consents necessary
to obtain the divorce. Any party who fails to cooperate with obtaining the Divorce shall pay all
the costs and legal fees of the party who is seeking the divorce.
15.
BREACH: If either party breaches any provisions of this Agreement, the other party
should have the right, at his or her election, to sue for damages for such breach or seek such other
remedies or relief as may be available to him or her, and the party breaching this contract will be
responsible for payment of legal fees and costs incurred by the other in enforcing their rights
under this Agreement.
16.
ADDITIONAL INSTRUMENTS: Each of the parties shall from time to time, at the
request of the other, execute, acknowledge and deliver to the other party any and all further
instruments that may be reasonably required to give full force and effect to the provisions of this
Agreement.
6
17.
VOLUNTARY EXECUTION: The provisions of this Agreement and their legal effect
have been fully explained to the parties by their respective counsel, and each party
acknowledges that the Agreement is fair and equitable, and that it is being entered into
voluntarily, and that it is not the result of any duress or undue influence. The provisions of this
Agreement are fully understood by both parties and each party acknowledges that the Agreement
is fair and equitable, that it is being entered into voluntarily, and that it is not the result of any
duress or undue influence.
18.
ENTIRE AGREEMENT: This Agreement contains the entire understanding of the
parties and there are no representations, warranties, covenants or undertakings other than those
expressly set forth herein.
19.
APPLICABLE LAW: This Agreement shall be construed under the Laws of the
Commonwealth of Pennsylvania.
20.
PRIOR AGREEMENTS: It is understood and agreed that any and all property
settlement agreements which may or have been executed prior to the date and time of this
Agreement are null and void and of no effect.
21.
PAYMENT OF COSTS AND LEGAL FEES: The parties agree to pay for their own
costs and legal fees required to obtain and complete the divorce.
22.
SCHOOL LOAN OF NICOLE TRIMBLE: The parties agree that the school loan will
be paid by daughter, Nicole Trimble; or the parties will split the costs of her school debt equally.
23.
WAIVER OF CLAIMS AGAINST ESTATES: Except as herein otherwise provided,
each party may dispose of his or her property in any way, and each party hereby waives and
relinquishes any and all rights he or she may now have or hereafter acquire, under the present or
future laws of any jurisdiction, to share in the property or the estate of the other as a result of the
marital relationship, including without limitation, dower, courtesy, statutory allowance, widow's
allowance, right to take in intestacy, right to take against the Will of the other, and right to act as
administrator or executor of the other's estate, and each will, at the request of the other, execute,
acknowledge and deliver any and all instruments which may be necessary or advisable to carry
into effect this mutual waiver and relinquishment of all such interests, rights and claims.
IN WITNESS WHEREOF, the parties hereunto have set their hands and seals the day
and year first above written.
WITNESSES:
8
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
. SS:
PERSONALLY APPEARED BEFORE ME, this ? day of , 2008, a
Notary Public, in and for the Commonwealth of Pennsylvania and County of Cumberland.
CHARLOTTE E. TRIMBLE, known to me (or satisfactorily proven) to be the person whose
name is subscribed to the within Marriage Settlement Agreement, and acknowledges that she
executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and official seal.
COMIMONIMALTH OF MNSYLVANLA
Notarial Seal
Martha L. Noel, Notary Public
Carlisw filoro, Cumberland County
My Commission Expires Sept. 1 B, 2011
Pen-w0vaft AssoclaGon or Notarise
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
. SS:
PERSONALLY APPEARED BEFORE ME, this 13 day of 2008, a
Notary Public, in and for the Commonwealth of Pennsylvania and County of Cumberland,
RICKY L. TRIMBLE, known to me (or satisfactorily proven) to be the person whose name is
subscribed to the within Marriage Settlement Agreement, and acknowledges that he executed the
same for the purposes therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and official seal.
COMMONWEALTH OF PENNSYLVANIA
NOTARIAL SEAL
VALERIE F. GSELL, Notary Public
Carlisle 8oro., Cumberland County
My Commission Expires October 9, 2010
9
List of Items Wanted
1. Roll top Desk - My Mother bought for me.
2. Coin Collection in safety box - My Father's - Not much value, sentimental value to me.
3. Steamer Trunk - It was my Sister's, she left it with me.
4. Utility Trailer
5. All Firearms remaining that are mine.
6. All tools:
• Hand powdered tools - automotive and woodworking
• Air compressors
• Large woodworking tools: table saw, radial arm saw, wood lathe, band saw, scroll saw,
chain saws
• All hand tools, both automotive and woodworking
7. Butchering Equipment
• Large iron kettle and 3 foot stand
• Large meat grinder
• Lard press
• Kettle stirrer, kettle ladles, kettle strainer
8. Hunting and sporting equipment
9. Animal mounts
10. Family pictures of my parents, brother and my kids
I ask that nothing be placed out in the environment; I do not want the weather to damage or ruin any of
my items.
??
CHARLOTTE E. TRIMBLE,
Plaintiff
V.
:I IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2007-2075 CIVIL TERM
CIVIL ACTION - LAW
RICKY L. TRIMBLE,
Defendant
1. A complaint in divorce
2007.
2. The marriage of plaintiff
from the date of the filing of the con
3. I consent to the entry of a
IN DIVORCE
Section 3301(c) of the Divorce Code was filed on April 13,
defendant is irretrievably broken and ninety days have elapsed
decree in divorce.
4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or
expenses if I do not claim than before a divorce is granted.
I verify that the statements
statements herein made are subject to
falsification to authorities.
Date: lap lo?
in this affidavit are true and coned. I understand that false
the penalties of 18 Pa. C. S. Section 4904 relating to unworn
wcyj- 9- 7A"
CHARLOTTE E. TRIMBLE
Plaintiff
N
C9
Q
Ca
co
i7
N
cn co
a ?
CHARLOTTE E. TRIMBLE, IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 2007-2075 CIVIL TERM
CIVIL ACTION - LAW
RICKY L. TRIMBLE,
Defendant IN DIVORCE
1. I consent to the entry of a fi?W Decree of Divorce without notice.
2. I understand that I may to 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 no? 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 i
statements herein made are subject
falsification to authorities.
Date: be
le in this affidavit are true and correct. I understand that false
the penalties of 18 Pa. C.S. Section 4904 relating to unworn
a Jek e, ` -/- A-- ?L CHARLOTTE E. TRIMBLE
Plaintiff
C
C
c"? t ? a t"3 t?1
co
71,x, . b ?- - 0 7 S CZ,,'p ' ,c?,.-
THIS AGREEMENT
CHARLOTTE E. TRIMBLE,
hereinafter referred to as
SETTLEMENT AGREEMENT
this I day of October 2008 by and between
fter referred to as "WIFE") and RICKY L. TRIMBLE,
WITNESSETH:
WHEREAS,
Perry County, Pennsylvania.
and WIFE were lawfully married on September 12, 1981, in
IFE filed a Complaint in Divorce in Cumberland County,
Pennsylvania, docketed at 2007-4075 Civil Term on April 13, 2007. The parties hereto agree
and covenant as follows:
The parties intend to m
each other. It is the intent and
duties of the parties while they
The parties have
conforms to a just and right sta
of the parties that such division
The division of existing marital
1.
separate and permanent domiciles and to live apart - from
of this Agreement to set forth the respective rights and
inue to live apart from each other.
2.
to divide their matrimonial property in a manner which
with due regard to the rights of each party. It is the intent
be final and shall forever determine their respective rights.
is not intended by the parties to constitute in any way a
sale or exchange of assets.
3.
Further, the parties agree
place or places that he or she ma`
molest, harass, annoy, injure, thre
Each party may carry on and
he or she may deem advisable
with the uses, ownership, enjoyn
herein nor property hereafter acq
o continue living separately and apart from the other at any
select as they have heretofore been doing. Neither party shall
ten or interfere with the other party in any matter whatsoever.
e in any employment, profession, business or other activity as
his or her sole use and benefit. Neither party shall interfere
or disposition of any property now owned and not specified
by the other.
4.
The consideration for this
both of the parties hereto and
The adequacy of the consideral
and admitted by the parties, and
Each party to the
:ontract and agreement is the mutual benefit to be obtained by
covenants and agreements of each of the parties to the other.
t for all agreements herein contained is stipulated, confessed,
: parties intend to be legally bound hereby.
I acknowledges and declares that he or she, respectively:
a. is represented by counsel of his or her own choosing;
b. is fully and completely informed of the facts relating to the subject
matter of this A eement and of the rights and liabilities of the parties;
c. enters into this ?greement voluntarily after receiving advice of counsel;
d. has given careful and mature thought to the making of this Agreement;
e. has carefully real each provision of this Agreement; and
f, fully and
both as to the subject
This Agreement shall
understands each provision of this Agreement,
and legal effect.
e effective immediately as of the date of execution.
2
S.
It is the purpose and
of this Agreement to settle forever and completely the interest
and obligations of the parties in all property that they own separately, and all property that would
qualify as marital property under the Pennsylvania Divorce Code, Title 23, Section 401(e), and
that is referred to in this Agreement as "Marital Property", as between themselves, their heirs and
assigns. The parties have attempt d to divide their Marital Property in a manner that conforms to
a just and fair standard, with due regard to the rights of each Party. The division of existing
Marital Property is not intended y 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 he marital estate.
It is the further purpose of his Agreement to settle forever and completely any obligation
under the Pennsylvania Divorce C de relating to spousal support or alimony.
6.
Each party represents and arrants that he or she has made a full and fair disclosure to the
other of all of his or her property interests of any nature, including any mortgage, pledge, lien,
charge, security interest, encumb ce, or restriction to which any property is subject. Each party
further represents that he or she h made a full and fair disclosure of all debts and obligations of
any nature for which he or she is currently liable or may become liable. Each further represents
and warrants that he or she has n6t made any gifts or transfers for inadequate *consideration of
Marital Property without the prior c
Each Party acknowledges tl
and separate State and Federal Tax
marriage.
of the other.
to the extent desired, he or she has had access to all joint
Returns filed by or on behalf of either or both Parties during
3
7.
REAL ESTATE: The V
Pennsylvania 17006. HUSBANI
WIFE. WIFE agrees to refinan
(120) days of the signing of this Y
arties own the property known as 25 West Main Street, Blain,
) agrees to convey his right, title and interest in the property to
?e the mortgage into her own name within one hundred twenty
8.
DEBTS: HUSBAND i
responsible for her debts. Hl
obligation related to his debts.
harmless HUSBAND from any
be solely responsible for his own debts. WIFE will be solely
LAND will indemnify and hold harmless WIFE from all
VIFE will be solely responsible and will indemnify and hold
im made against him related to her debts.
9.
HUSBAND will pay WIFE the
to be paid in bi-weekly ? f
cohabitates, remarries, or the
as follows:
'D ALIMONY: The parties hereby agree that the
of Three Hundred and no/100 ($300.00) Dollars per month
of $138.47 for eighteen (18) months or until WIFE
of one of the parties.
10.
The parties agree that the personal property shall be divided
HUSBAND shaft receive the following items:
a. The personal property in his possession;
b. All items listed ?n attached Exhibit "A";
c. His bank
d. Any life
e. His employee
e. Fifty percent (50
Pennsylvania.
policy;
and
%) of his marital retirement with the Commonwealth of
4
WIFE shall receive the f0owing items:
a. The personal pr perry in her current possession;
b. Her bank accounts;
c. Any life insuran?e policy;
d. The cemetery plots at Blain Cemetery; and
e. Fifty percent (5q%) of HUSBAND's marital retirement with the
Commonwealthl of Pennsylvania.
The WIFE hereby waives *11 right and title which she may have in any personal property
of the HUSBAND. HUSBANDS likewise waives any interest which he has in the personal
property of the WIFE. Henceforth, each of the parties shall own, have and enjoy independently
of any claim or right of the other arty, all items of personal property of every kind, nature and
description and wherever situated which are then owned or held by or which may hereafter
belong to the HUSBAND or WIFE with full power to the HUSBAND or the WIFE to dispose
of same as fully and effectually, in all respects and for all purposes as if he or she were
unmarried. Each party agrees that
the other and that from the
obligations, liens or any liability
will incur obligations, liens or liabilities on account of
of this Agreement, neither party shall contract or incur
on account of the other.
11.
AUTOMOBILES:
a.
HUSBAND agrees to waive any and all interest which he may have in the
automobiles in possession of the WIFE.
b. WIFE agree to waive any and all interest which she may have in the
automobiles in possession of the HUSBAND. HUSBAND agrees to
convey title o WIFE's 1992 Pontiac Grand Prix automobile.
They each waive any claim
they have in any automobile owned by the other party.
5
12.
IMURANCE AND E PLVYEE BENEFITS: Except for the HUSBAND's
retirement with the Commonwealth of Pennsylvania, the parties waive all interest in the benefits
of one another.
13.
WIFE agrees to waive all right, title and
interest which she may have in the savings or checking or any other bank accounts of the
HUSBAND. The HUSBAND agrees to waive all interest which he may have in the savings or
checking or any other bank accounts of the WIFE.
14.
DIVORCE: The parties both agree to cooperate with each other in obtaining a final
divorce of the marriage. It is agreed that the parties will execute and file the consents necessary
to obtain the divorce. Any party ho fails to cooperate with obtaining the Divorce shall pay all
the costs and legal fees of the part' who is seeking the divorce.
15.
BREACH: If either p breaches any provisions of this Agreement, the other party
should have the right, at his or her election, to sue for damages for such breach or seek such other
remedies or relief as may be available to him or her, and the party breaching this contract will be
responsible for payment of legal fees and costs incurred by the other in enforcing their rights
under this Agreement.
16.
request of the other, execute,
instruments that may be reasoi
Agreement.
BENTS: Each of the parties shall from time to time, at the
nowledge and deliver to the other party any and all further
? required to give full force and effect to the provisions of this
6
17.
have been fully explained to
acknowledges that the Agreen
voluntarily, and that it is not the
Agreement are fully understood
is fair and equitable, that it is 1
duress or undue influence.
ON: The provisions of this Agreement and their legal effect
ie parties by their respective counsel, and each party
t is fair and equitable, and that it is being entered into
sult of any duress or undue influence. The provisions of this
both parties and each party acknowledges that the Agreement
g entered into voluntarily, and that it is not the result of any
18.
parties and there are no
expressly set forth herein.
This Agreement contains the entire understanding of the
warranties, covenants or undertakings other than those
19.
APPLICABLE LAW:
Commonwealth of Pennsylvania.
Agreement shall be construed under the - Laws ' of the
20.
PRIOR AGREEMENTS It is understood and agreed that any and all property
settlement agreements which may or have been executed prior to the date and time of this
Agreement are null and void and o no effect.
21.
PAYMENT OF COSTS AND LEGAL FEES: The parties agree to pay for their own
costs and legal fees required to obtain and complete the divorce.
22.
: The parties agree that the school loan will
be paid by daughter, Nicole
or the parties will split the costs of her school debt equally.
23.
each party may dispose of his or
INST ESTATES: Except as herein otherwise provided,
property in any way, and each party hereby waives and
relinquishes any and all rights he o she may now have or hereafter acquire, under the present or
future laws of any jurisdiction, to sh a in the property or the estate of the other as a result of the
marital relationship, including with ut limitation, dower, courtesy, statutory allowance, widow's
allowance, right to take in intestacy right to take against the Will of the other, and right to act as
administrator or executor of the oth is estate, and each will, at the request of the other, execute,
acknowledge and deliver any and 1 instruments which may be necessary or advisable to carry
into effect this mutual waiver and re inquishment of all such interests, rights and claims.
IN WITNESS WHEREOF the parties hereunto have set their hands and seals the day
and year first above written.
WITNESSES:
8
COMMONWEALTH OF PEN SYLVANIA .
SS:
COUNTY OF CUMBERLAND
PERSONALLY APPEARED BEFORE ME, this day of 2008, a
Notary Public, in and for the Commonwealth of Pennsylvania and County of Cumberland,
CHARLOTTE E. TRIMBLE, own to me (or satisfactorily proven) to be the person whose
name is subscribed to the within Marriage Settlement Agreement, and acknowledges that she
executed the same for the purpose therein contained.
IN WITNESS
Mwft L No.[, Nof."
cuWw 1&0. cun*oftn
COMMONWEALTH OF
COUNTY OF CUMBERLAND
, I have hereunto set my hand and official seal.
VANIA .
. SS:
PERSONALLY APPEARED BEFORE ME, this 13 day of &&&, 2008, a
Notary Public, in and for the C mmonwealth of Pennsylvania and County of Cumberland,
RICKY L. TRIMBLE, known t me (or satisfactorily proven) to be the person whose name is
subscribed to the within Marriage Settlement Agreement, and acknowledges that he executed the
same for the purposes therein cont fined.
IN WITNESS WHEREOF, I have hereunto set my hand and official seal.
COMMONWWALTH OF PENNSYLVANIA
NOTARIAL SEAL
VALERIE F. GSELL, Notary P blic
Carkie 8oro., Cumberland Co my
Commission Expires October , 2010
9
List of Items Wanted
1. Roll top Desk - My Mother bo
2. Coin Collection in safety box -
3. Steamer Trunk - It was my Sist
4. Utility Trailer
5. All Firearms remaining that are
6. All tools:
• Hand powdered tools -
• Air compressors
• Large woodworking to
chain saws
• All hand tools, both au
7. Butchering Equipment
• Large iron kettle and 3
• Large meat grinder
• Lard press
• Kettle stirrer, kettle la(
8. Hunting and sporting equipme
9. Animal mounts
10. Family pictures of my parents,
it for me.
r Father's - Not much value, sentimental value to me.
s, she left it with me.
mine.
automotive and woodworking
table saw, radial arm saw, wood lathe, band saw, scroll saw,
tive and woodworking
stand
es, kettle strainer
r and my kids
I ask that nothing be placed out in the I nvironment; I do not want the weather to damage or ruin any of
my items.
?'t
C`s g
-n
cz
TJe-r,
tt f; ?
,,? ?m
7P,
r
CHARLOTTE E. TRIMBLE,
Plaintiff
V.
RICKY L. TRIMBLE,
Defendant
To the Prothonotary:
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2007-2075 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
Transmit the record, together with th? following information, to the court for entry of a divorce decree:
1. Ground for Divorce: irretrievable breakdown under Section 3301(c) and or (d) of the Divorce Code.
2. Date and manner of service of c mplaint: A certified copy of the Complaint in Divorce was served upon the
defendant, Ricky L. Trimble, on or about ay 7, 2007, by certified, restricted delivery mail, addressed to him at 820
Belvedere Street, Carlisle, Pennsylvania, 170 3, with Return Receipt Number 7004 1350 0003 7289 3600.
3. Complete either paragraph (a) or ).
(a) Date of execution f the Affidavit of Consent required by Section 3301(c) of the Divorce Code:
by plaintiff. October 20, 2008; by defendant: October 13, 2008.
(b)(1) Date of execution
(b)(2) Date of filing and
4. Related claims pending: NONE.
5. Complete either (a) or (b).
(a) Date and manner
of which is attached:
(b) Date plaintiffs
October 28, 2008.
October 13, 2008.
Date defendant's
affidavit required by Section 3301(d) of the Divorce Code:
of the plaintiffs affidavit upon the defendant:
service of the Notice of Intention to file Praecipe to Transmit Record, a copy
of Notice in Section 3301(c) Divorce was filed with the Prothonotary:
of Notice in Section 3301(c) Divorce was filed with the Prothonotary:
Marcus A. McKnight, III, Esquire
attorney for Plaintiff
Date: October 28, 2008
ra
Q
t
r
r
h
r
e
t?
r
?
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF PENNA.
CHARLOTTE E. TRIMBLE.
PLAINTIFF
NO. 2007 - 2075
VERSUS
RICKY L. TRIMBLE,
A- :1:n
DECREE IN
DIVORCE
AND NOW, ?4ME IT IS ORDERED AND -ivlw 1014? (I DECREED THAT CHARLOTTE E. TRIMBLE , PLAINTIFF,
AND RICKY L. TRIMBLE
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
,DEFENDANT,
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; kit) A
The Marriage Settlement Agreement dated October 13, 2008 and signed by the
s is
BY THE COLUCT:
ATTEST: - J.
PROTHONOTARY
w
??,
r `s
CHARLOTTE TREMBLE,
Plaintiff
V.
RICKY L. TREMBLE,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO.2007-207 CIVIL ACTION - LAW
IN DIVORCE
STIPULATION AND AGREEMENT
FOR THE ENTRY OF "DOMESTIC RELATIONS ORDER"
AND NOW, this T day of C,L06f , 2008, the parties,
Charlotte Trimble, Plaintiff and Ricky L. Trimble, Defendant, having been divorced by
Decree dated 11/04/2008 of the Court of Common Pleas of Cumberland County,
entered at Docket Number 2007-2075, do hereby Stipulate and Agree as follows:
The Defendant, Ricky L. Trimble, hereinafter referred to as "Member" is
a member of the Commonwealth of Pennsylvania State Employees' Retirement System,
(hereinafter referred to as "SERS").
2. SERS, as a creature of statute, is controlled by the State Employees'
Retirement Code, 71 Pa. C. S. §§5101-5956 ("Retirement Code")
3. Member's date of birth is March 4, 1956, and the Member's Social
Security number is o?0 %4& -34
Slq
4. The Plaintiff Charlotte Trimble, (hereinafter referred to as "Alternate
Payee") is the former spouse of Member. Alternate Payee's date of birth is September
15, 1957 and Alternate Payee's Social Security number is /1111 • 6;-6
5. Member's last known mailing address is:
Ricky L. Trimble
820 Belvedere Street Apt #I
Carlisle, Pennsylvania 17013.
6. Alternate Payee's last known address is:
Charlotte Trimble
25 West Main Street
Blain. Pennsylvania 17006
It is the responsibility of the Alternate Payee to keep a current mailing address on
file with SERS at all times.
7. (a) The marital property component of Member's retirement benefit on the
effective date of Member's retirement calculated using the Retirement Code if effect on
May 1, 2006,. the date of the parties' separation, and Member's final average salary as of
the effective date of retirement.
(b) The Coveture Fraction is a fraction with a value less than or equal to one.
The numerator is the amount of Member's service, as defined by SERS, for the period of
time from September 12, 1981 (date of marriage), to May 1, 2006 (date of separation).
The denominator is the total amount of Member's service, as defined by SERS, on the
effective date of Member's retirement.
(c) Fifty percent (50%) of the marital property component of Member's
retirement is to be allocated to Alternate Payee as the equitable distribution portion of this
marital asset.
Member's retirement benefit is defined as all monies paid to or on behalf
of Member by SERS, including any lump sum withdrawals or scheduled or ad hoc
increases, but excluding the disability portion of any disability annuities paid to Member
by SERS as a result of a disability which occurs before Members marriage to Alternate
Payee or after the date of Member's and Alternate Payee's final separation. Member's
retirement benefit does not include any deferred compensation benefits paid to member
by SERS or any enhancements to the Member's retirement benefit arising from
postseparation monetary contributions made by Member. The equitable distribution
portion of the marital property component of Member's retirement benefit, as set forth in
Paragraph Seven (7) shall be payable to Alternate Payee and shall commence as soon as
administratively feasible on or about the date Member actually enters pay status and
SERS approves a Domestic Relations Order incorporating this Stipulation and
Agreement, whichever is later.
9. Member hereby nominates Alternate Payee as an irrevocable beneficiary .
to the extent of the Alternate Payee's equitable distribution interest in Member's
retirement benefit for any death benefits payable by PSERS. This nomination shall
become effective upon approval by the Secretary of the Retirement Board, or other
authorized representative of the Secretary, of any Domestic Relations Order
incorporating this Stipulation and Agreement. The balance of any death benefit
remaining after the allocation of the equitable distribution portion payable to Alternate
Payee and any other alternate payees named under other SERS-approved Domestic
Relations Orders ("Balance") shall be paid to the beneficiaries named by Member on the
last Nomination of Beneficiaries Form filed with the Retirement Board prior to Member's
Death.
If the last Nomination of Beneficiaries Form filed by Member prior to Member's
death (a) predates any approved Domestic Relations Order incorporating this Stipulation
and Agreement, and (b) names Alternate Payee as a beneficiary, then: (1) the terms of the
Domestic Relations Order shalt alone govern Alternate Payee's share of any death
benefit, and (2) for purposes of paying the Balance via the last Nomination of
Beneficiaries Form filed with the Retirement Board prior to :Member's death, Alternate
Payee shall be treated as if Alternate Payee predeceased Member. No portion of the
Balance shall be payable to Alternate Payee's estate.
In addition, Member shall execute and deliver to Alternate payee an authorization,
in a form acceptable to SERS, which will authorize SERS to release to Alternate Payee
all relevant information concerning Member's retirement account.
10. The term and amounts of Member's retirement benefits payable to
Alternate Payee after SERS approves a Domestic Relations Order incorporating this
Stipulation and Agreement depends upon which option(s) member selects at retirement.
Member and Alternate Payee expressly agree that:
(a) Member shall select the following retirement option upon filing an
Application for Retirement Allowance with SERS:
(b) Special Option 4. A joint and equitable distribution percent (as defined in
paragraph 7) annuity payable during the lifetime of the Member, with an equitable
distribution percent (as defined in paragraph 7) of such annuity payable thereafter, to the
Member's survivor annuitant, if living at the Member's death, as set forth in 71 Pa.C.S.
§5705(a)(40, or any succeeding statute. The Member shall designate the Alternate Payee
as an irrevocable survivor annuitant. The intent of this Special Option 4 selection is to
maintain level payments to the Alternate Payee for the Alternate Payee's life in the event
of Member's death after retirement. The Alternate Payee's portion of the Member's
benefit will be deducted from the Member's monthly annuity payment and paid by SERS
to the Alternate Payee during the Member's lifetime. If the Alternate Payee dies while
the Member is receiving retirement benefits, the Alternate Payee's portion of the
Member's annuity shall revert to the Member for the remainder of the member's lifetime.
If the Member predeceases the Alternate Payee after retiring, the Alternate Payee will
receive the Alternate Payee's equitable distribution portion of the Member's benefit in
the form of survivor annuity payable to the Alternate Payee for the duration of the
Alternate Payee's life. In any event, all payments to any person or estate will stop when
both the Member and Alternate Payee have died.
(c) Member may select any option offered by SERS under the Retirement
Code at the time of retirement for the portion of the retirement benefit payable to
Member.
11. Alternate Payee may not exercise any right, privilege or option offered by
SERS. SERS shall issue individual tax forms to Member and Alternate Payee for
amounts paid to each.
12. In the event of the death of Alternate Payee prior to receipt of all of
payments payable from SERS under a Domestic Relations Order incorporating this
Stipulation and Agreement, any death benefit or retirement benefit payable to Alternate
Payee by SERS shall revert to Member.
13. In no event shall the Alternate Payee have benefits or rights greater than
those which are available to the Member. Alternate Payee is not entitled to any benefit
not otherwise provided by SERS. Alternate Payee is only entitled to the specific benefits
offered by SERS as provided in this Stipulation and Agreement. All other rights,
privileges, and options offered by SERS not granted to the Alternate Payee by this
Stipulation and Agreement are preserved for Member. Member and Alternate Paycc
acknowledge that benefits paid pursuant to this Stipulation and agreement are and shal l
remain subject to the Public Employee Pension Forfeiture Act, 43 P.S. X1311, et.seq.
14. It is specifically intended and agreed by the parties hereto that any
Domestic Relations Order incorporating this Stipulation and Agreement:
(a) Does not require SERS to provide any type of benefit, or any option, not
otherwise provided under the Retirement Code;
(b) Does not require SERS to provide increased benefits (determined on the
basis of actuarial value) unless increased benefits are paid to Member
based upon cost of living adjustments or increases based on other than •
actuarial values.
15. The parties intend and agree that the terms of this Stipulation and Agreement
shall be approved, adopted, and entered as a Domestic Relations Order.
16. The Court of Common Pleas of Cumberland County, Pennsylvania, shall
retain jurisdiction to amend any Domestic Relations Order incorporating this Stipulation
and Agreement, but only for the purpose of establishing it or maintaining it as a Domestic
Relations Order; provided, however, that no such amendment shall require SERS to
provide any type or form of benefit, or any option not otherwise provided by SERS, and
further provided that no such amendment or right of the Court to so amend will not
invalidate the parties' existing Domestic Relations Order.
17. Upon its entry as a Domestic Relations Order incorporating this Stipulations
and Agreement, a certified copy of the Domestic Relations Order and this Stipulation and
Agreement and any attendant documents shall be served upon SERS immediately. Such
Domestic Relations Order shall take effect immediately upon SERS approval and SERS
approval of any attendant documents and then shall remain in effect until such time as a
further Order of Court amends or vacates the Domestic Relations Order.
WHEREFORE, the parties, intending to be legally bound by the terms of this
Stipulation and Agreement, do hereunto place their hand and seals.
Dated: f6 - r 3 m
/Lk
Rick L. TriiAble, ENDANT/MEMBER
Dated: 10 / 7 /09'-
0arIctte Trimble, PLAINTIFF/ALTERNATE PAYEE
Dated: lO - / 3 -o k
Dated: G
i
acqu ine M. Verney, Esq., Atto for Defendant/Member
Marcus
, Attorney for Alternate Payee
7r_ p..r.T l;Y
• OCT 2 0 20994
CHARLOTTE TRIMBLE, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 2007-2075 CIVIL ACTION - LAW
RICKY L. TRIMBLE, : IN DIVORCE
Defendant
ORDER OF COURT
FOR THE ENTRY OF "DOMESTIC RELATIONS ORDER"
Upon consideration of the Parties' Stipulation and Agreement for the Entry of a
Domestic Relations Order, the Court of Common Pleas of Cumberland County,
Pennsylvania hereby orders as follows:
1. The Defendant, Ricky L. Trimble, hereinafter referred to as "Member" is a
member of the Commonwealth of Pennsylvania State Employees' Retirement System,
(hereinafter referred to as "SERS").
2. SERS, as a creature of statute, is controlled by the State Employees'
Retirement Code, 71 Pa. C. S. §§5101-5956 ("Retirement Code").
3. Member's date of birth is March 4, 1956, and the Member's Social
Security number is 202-48-3649.
4. The Plaintiff, Charlotte Trimble, (hereinafter referred to as "Alternate
Payee") is the former spouse of Member. Alternate Payee's date of birth is September
15, 1957 and Alternate Payee's Social Security number is 199-50-2218.
5. Member's last known mailing address is:
Ricky L. Trimble
820 Belvedere Street Apt #1
Carlisle, Pennsylvania 17013.
6. Alternate Payee's last known address is:
Charlotte Trimble
25 West Main Street
Blain, Pennsylvania 17006
It is the responsibility of the Alternate Payee to keep a current mailing address on
file with SERS at all times.
7. (a) The marital property component of Member's retirement benefit on the
effective date of Member's retirement calculated using the Retirement Code if effect on
May 1, 2006, the date of the parties' separation, and Member's final average salary as of
the effective date of retirement.
(b) The Coveture Fraction is a fraction with a value less than or equal to one.
The numerator is the amount of Member's service, as defined by SERS, for the period of
time from September 12, 1981 (date of marriage), to May 1, 2006 (date of separation).
The denominator is the total amount of Member's service, as defined by SERS, on the
effective date of Member's retirement.
(c) Fifty percent (50%) of the marital property component of Member's
retirement is to be allocated to Alternate Payee as the equitable distribution portion of this
marital asset.
8. Member's retirement benefit is defined as all monies paid to or on behalf
of Member by SERS, including any lump sum withdrawals or scheduled or ad hoc
increases, but excluding the disability portion of any disability annuities paid to Member
by SERS as a result of a disability which occurs before Members marriage to Alternate
Payee or after the date of Member's and Alternate Payee's final separation. Member's
retirement benefit does not include any deferred compensation benefits paid to member
by SERS or any enhancements to the Member's retirement benefit arising from
postseparation monetary contributions made by Member. The equitable distribution
portion of the marital property component of Member's retirement benefit, as set forth in
Paragraph Seven (7) shall be payable to Alternate Payee and shall commence as soon as
administratively feasible on or about the date Member actually enters pay status and
SERS approves a Domestic Relations Order incorporating this Stipulation and
Agreement, whichever is later.
9. Member hereby nominates Alternate Payee as an irrevocable beneficiary
to the extent of the Alternate Payee's equitable distribution interest in Member's
retirement benefit for any death benefits payable by PSERS. This nomination shall
become effective upon approval by the Secretary of the Retirement Board, or other
authorized representative of the Secretary, of any Domestic Relations Order
incorporating this Stipulation and Agreement. The balance of any death benefit
remaining after the allocation of the equitable distribution portion payable to Alternate
Payee and any other alternate payees named under other SERS-approved Domestic
Relations Orders (`Balance") shall be paid to the beneficiaries named by Member on the
last Nomination of Beneficiaries Form filed with the Retirement Board prior to Member's
Death.
If the last Nomination of Beneficiaries Form filed by Member prior to Member's
death (a) predates any approved Domestic Relations Order incorporating this Stipulation
and Agreement, and (b) names Alternate Payee as a beneficiary, then: (1) the terms of the
Domestic Relations Order shall alone govern Alternate Payee's share of any death
benefit, and (2) for purposes of paying the Balance via the last Nomination of
Beneficiaries Form filed with the Retirement Board prior to Member's death, Alternate
Payee shall be treated as if Alternate Payee predeceased Member. No portion of the
Balance shall be payable to Alternate Payee's estate.
In addition, Member shall execute and deliver to Alternate payee an authorization,
in a form acceptable to SERS, which will authorize SERS to release to Alternate Payee
all relevant information concerning Member's retirement account.
10. The term and amounts of Member's retirement benefits payable to
Alternate Payee after SERS approves a Domestic Relations Order incorporating this
Stipulation and Agreement depends upon which option(s) member selects at retirement.
Member and Alternate Payee expressly agree that:
(a) Member shall select the following retirement option upon filing an
Application for Retirement Allowance with SERS:
(b) Special Option 4. A joint and equitable distribution percent (as defined in
paragraph 7) annuity payable during the lifetime of the Member, with an equitable
distribution percent (as defined in paragraph 7) of such annuity payable thereafter, to the
Member's survivor annuitant, if living at the Member's death, as set forth in 71 Pa.C.S.
§5705(a)(40, or any succeeding statute. The Member shall designate the Alternate Payee
as an irrevocable survivor annuitant. The intent of this Special Option 4 selection is to
maintain level payments to the Alternate Payee for the Alternate Payee's life in the event
of Member's death after retirement. The Alternate Payee's portion of the Member's
benefit will be deducted from the Member's monthly annuity payment and paid by SERS
to the Alternate Payee during the Member's lifetime. If the Alternate Payee dies while
the Member is receiving retirement benefits, the Alternate Payee's portion of the
Member's annuity shall revert to the Member for the remainder of the member's lifetime.
If the Member predeceases the Alternate Payee after retiring, the Alternate Payee will
receive the Alternate Payee's equitable distribution portion of the Member's benefit in
the form of survivor annuity payable to the Alternate Payee for the duration of the
Alternate Payee's life. In any event, all payments to any person or estate will stop when
both the Member and Alternate Payee have died.
(c) Member may select any option offered by SERS under the Retirement
Code at the time of retirement for the portion of the retirement benefit payable to
Member.
11. Alternate Payee may not exercise any right, privilege or option offered by
SERS. SERS shall issue individual tax forms to Member and Alternate Payee for
amounts paid to each.
12. In the event of the death of Alternate Payee prior to receipt of all of
payments payable from SERS under a Domestic Relations Order incorporating this
Stipulation and Agreement, any death benefit or retirement benefit payable to Alternate
Payee by SERS shall revert to Member.
13. In no event shall the Alternate Payee have benefits or rights greater than
those which are available to the Member. Alternate Payee is not entitled to any benefit
not otherwise provided by SERS. Alternate Payee is only entitled to the specific benefits
offered by SERS as provided in this Stipulation and Agreement. All other rights,
privileges, and options offered by SERS not granted to the Alternate Payee by this
Stipulation and Agreement are preserved for Member. Member and Alternate Payee
acknowledge that benefits paid pursuant to this Stipulation and agreement are and shall
remain subject to the Public Employee Pension Forfeiture Act, 43 P.S. § 1311, et seq.
14. It is specifically intended and agreed by the parties hereto that any
Domestic Relations Order incorporating this Stipulation and Agreement:
(a) Does not require SERS to provide any type of benefit, or any option, not
otherwise provided under the Retirement Code;
(b) Does not require SERS to provide increased benefits (determined on the
basis of actuarial value) unless increased benefits are paid to Member
based upon cost of living adjustments or increases based on other than
actuarial values.
15. The parties intend and agree that the terms of this Stipulation and Agreement
shall be approved, adopted, and entered as a Domestic Relations Order.
16. The Court of Common Pleas of Cumberland County, Pennsylvania, shall
retain jurisdiction to amend any Domestic Relations Order incorporating this Stipulation
and Agreement, but only for the purpose of establishing it or maintaining it as a Domestic
Relations Order; provided, however, that no such amendment shall require SERS to
provide any type or form of benefit, or any option not otherwise provided by SERS, and
further provided that no such amendment or right of the Court to so amend will not
invalidate the parties' existing Domestic Relations Order.
17. Upon its entry as a Domestic Relations Order incorporating this Stipulations
and Agreement, a certified copy of the Domestic Relations Order and this Stipulation and
Agreement and any attendant documents shall be served upon SERS immediately. Such
Domestic Relations Order shall take effect immediately upon SERS approval and SERS
approval of any attendant documents and then shall remain in effect until such time as a
further Order of Court amends or vacates the Domestic Relations Order.
18. This Court reserves jurisdiction to issue further orders as needed to
execute this Order.
IT IS SO ORDERED this -045)day
EDGAR B. BAYLEY,
iL -r-
OF THE P-,"'HK,Nl")TAPY
2009 OCT 21 Pi 2 UO
IV!
xpl/o?? C?o I ;)IiEj mvt&CL
14? ? N - Ac-L-4 ? tLz