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HomeMy WebLinkAbout07-4405JULIE TRITT SCHELL PLAINTIFF vs. CHRISTIAN J. SCHELL DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ~. NO: ~ 7 - y~p ~ G r ~, f -{-,can,. CIVIL ACTION -LAW IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS YO U H~ VE BEEN S LIED IN CO UKT. 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 maybe entered against you by the Court. A judgment may also be entered against you for any other claim or reliefrequested In these papers by the Plaintifl`: You may lose money or property or other rights important to you, including custody of visitation ofyour 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, One Courthouse Square, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS'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 CO LINTY BAR ASSOCIATION LAWYER REFERRAL SERVICE 32 South Bedford Street Carlisle, PA 17013 TELEPHONE: 717-249-31 GG s- OM ~' LILAKIS Kara W. Haggerty, Esquire Attorney I.D. No.: 86914 36 South Hanover Street Carlisle, Pennsylvania 170]3 (7 t 7) 249-0900 JULIE TRITT SCHELL PLAINTIFF vs. CHRISTIAN J. SCHELL DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO: Q 7 - t-~yp ~c~ v ~ j -I-ec.~,, CIVIL ACTION -LAW IN DIVORCE 1. Plaintiff is Julie Tritt Schell, who currently resides at 1404 Chatham Road, Camp Hill, Cumberland County, Pennsylvania. 2. Defendant is Christian J. Schell, who currently resides at 2004 Hampton Court, Morgantown, Pennsylvania. 3. The Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on May 28, 2000 in Boiling Springs, Cumberland County, Pennsylvania. COUNT I -DIVORCE 5. Paragraphs one (1) through four (4) of this Complaint are incorporated herein by reference as though set forth in full. 6. There have been no prior actions of divorce or for annulment between the parties. 7. Divorce is sought pursuant to the provisions of the Divorce Code, ~ 3301(c) and 3301(d), ui that: The marriage is irretrievably broken. b. Plaintiff and Defendant have lived separate and apart since July, 2006, and continue to do so. 8. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the court require the parties to participate in such counseling. 9. The Plaintiff in this action is not a member of the Armed forces. 10. Plaintiff and Defendant have entered into a Marriage Settlement Agreement, signed and dated July 29, 2006, which divides all marital property, sets forth Financial Separation Terms and Child Support Terms, which shall be incorporated, but not merged, into a final Decree of Divorce. WHEREFORE, the Plaintiff requests the Court to enter a Decree of Divorce. Respectfully submitted, Aaolrr & KuTUlaxrs, L.L.P. •~ ~ DATE ~ ~ , ,~~ Kara W. Haggerty, Es~ " ' Attorney I.D. No.: 86 v 36 South Hanover Street Carlisle, Pennsylvania 17013 (717) 249-0900 Attorney for Plaint r I, JULIE TRITT SCHELL, verify that the statements made in this Divorce Complaint are 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. X4904 relating to unsworn falsification to authorities. Date 7' ~'"~ • ~ r CERTIFICATE OF SERVICE AND NOW, this ~~ y of July, 2007, I, Kara W. Haggerty, Esquire, of Abom & Kutulakis, L.L.P, hereby certify that I did serve a true and correct copy of the foregoing Divorce Complaint, upon the Defendant by depositing, or causing to be deposited, same in the United States Mail, Certified mail and First-class mail, postage prepaid addressed to the following: Christian J. Schell 2004 Hampton Court Morgantown, PA 19543 Pm Se Defendant Respectfully submitted, ABOM & KUTUI.A,KI'S, L.L.P. ~~,~. ~_ Kara W. Haggerty, E~q Attorney I.D. No.: 8 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 Attorney for Plaint t'? r- '~ Vv ^_ Q ^~.~ ... A.. s" d ~t F~ C .. ..3 C .., I, ~ . (,.,~ t ~~a ~ ;7 -~n 1 ,,f.~ -. ;~ (~ } t../ ~` '} _..~ ~C _ ~BOM ~' LiTLILAKIS Kara W. Haggerty, Esquire Attorney I.D. #: 86914 36 South Hanover Street Carlisle, PA ] 7013 (717) 249-0900 JULIE TRITT SCHELL, Plaintiff v. CHRISTIAN J. SCHELL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 07-4405 CIVIL TERM CNIL ACTION -LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce under ~3301(c) of the Divorce Code was filed on July 25, 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. X4904 relating to unsworn falsification to authorities. Date: ~ o'l~ -' LIE T SCHELL ~yj t i~~i " ..~~ i 1 ~~ 1 '41Y~~~ LUG ..)at' ! ~ ~7~'1 ~~• =~'J s..,, " _ `, i a~ uTUr~Is -- Kara W. Haggerty, Esquire Attorney I.D. #: 86914 36 South Hanover Street Carlisle, PA 17013 (717)249-0900 JULIE TRITT SCHELL, Plaintiff v. CHRISTIAN J. SCHELL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO.07-4405 CIVIL TERM CNIL ACTION -LAW IN DNORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~3301(c) OF THE DIVORCE CODE 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. X4904 relating to unsworn falsification to authorities. ~---• Date: ~ a'Z' d E TRI SCHELL z° 4'~ i ~'. ' ~ € t ~R ^ti~ T~`~ ~ - .. ~~~~ ~, d. ~~, ~~~ ~;~'r ~- , , ~,.- _ , r e <._, ~i.+ I ~ i i ~ I-i- -~C.~n.F.,l' ~ _..noG~- rL I~C) ~ D ~ - ~'~5 C{` v~' ~, AMENDMENT TO MARITAL SETTLEMENT AGREEMENT AMENDMENT TO MARITAL SETTLEMENT AGREEMENT, dated 1St day of May 2009, by and between Julia Naugle Tritt Schell, who resides at 1404 Chatham Rd., Camp Hill, PA 17011 and Christian Joseph Schell, who resides at 2004 Hampton Court, Morgantown, PA 19543. Child Support Terms The following terms have been agreed to by Christian Joseph Schell ("Christian") and Julie Naugle Tritt Schell ("'Julie"), hereafter referred to as "the Parties" and shall replace entirely the original Child Support Terms included in the original Marital Settlement Agreement dated July 2006. The terms listed below will serve as Christian's child support payment for Lauren Elizabeth Schell in lieu of a formal court- established support payment. • Beginning January 1, 2009, Christian will pay 8% of his monthly net income to Julie. Net income is defined as gross income less mandatory federal, state and focal taxes (where the number of dependents claimed on the W-4 is 0); and 401 K contributions. The payments shall be based on documented pay statements and be made in intervals no greater than every six (6) months. Payments will end when Lauren reaches age 18, unless otherwise agreed-to by both Parties. • Beginning January 1, 2010, Christian will contribute 5% of his annual net bonus payments, not to exceed $1000 annually, to a savings account (i.e., CD, mutual fund, money market, etc.) of Christian's choice. The details of this fund and the contributions made to the fund shall be provided to Julie on an annual basis. This fund will become available to Lauren when she reaches age 21 or sooner if agreed to by both Parties. Payments will end when Lauren reaches age 18, unless otherwise agreed to by both Parties. Should Christian's compensation package change to a commission-style salary structure, such as a sales or sales management position, the percentage net income and bonus payments will be restructured under this Agreement to reach a similar child support payment amount. • Beginning January 1, 2009, Christian will pay to Julie 50% of the costs of summer care, before and after-school care, and child care when school is closed. Payments shall be based on documented payment statements, where available. Payments will be made in intervals no greater than every six (6) months. • As of January 1, 2009, Christian will contribute $300/month to a 529 college savings plan for Lauren Schell. By January 2013, the Parties will re-evaluate the monthly contribution rate to determine if an increase or decrease to the amount is needed based on current conditions. The contributions will end no sooner than the month that Lauren reaches age 18, unless otherwise agreed-to by both Parties. • Should mutually agreed-upon large expenses arise (e.g., orthodontia, a car, school trips, medical bills, or other unanticipated events), Christian and Julie will each pay 50% of the costs of these expenses. Should Christian's or Julie's income levels decrease significantly (by 30% or more), the terms of this agreement will be re-evaluated and adjusted to reach mutually agreeable terms. Although not a condition of Christian's child support responsibility: • Julie will contribute $300/month to a 529 college savings plan for Lauren Schell. The contributions will end no sooner than the month that Lauren reaches age 18, unless otherwise agreed-to by both Parties. • If Julie should be employed in the future with a salary and bonus payment compensation structure, she also will contribute 5% of her annual net bonus payments, not to exceed $1000 annually, to a similar savings account and will report the details to Christian. This fund will become available to Lauren when she reaches age 21 or sooner if agreed to by both Parties. Payments will end when Lauren reaches age 18, unless otherwise agreed to by both Parties. Both Parties agree that Julie's self-employment compensation is not considered a salary and bonus payment compensation structure; therefore, as of the execution date of this Amendment, Julie does not earn annual net bonus payments. 10. FINAL AGREEMENT This Amendment to the Marital Settlement Agreement sets forth the entire agreement and understanding between Christian and Julie relating to the child support terms and supersedes all prior discussions between us. No modification of or amendment to this agreement, nor any waiver of any rights under this agreement, will be effective unless in writing signed by the party to be charged. 11. ACKNOWLEDGEMENT Christian and Julie acknowledge that each has entered into this agreement in good faith, without any duress or undue influence. Each understands his or her right to seek independent counsel regarding this agreement, and each has had the opportunity to seek independent counsel prior to signing this agreement. 12. CHOICE OF LAW Christian and Julie agree that this agreement shall be governed and construed in accordance with the laws of the Commonwealth of Pennsylvania. Signed and dated this 1S' day of May, 2009. '~ (. Julie Naugle Tritt Schell Christian Joseph Schell 4 f~ $ ~ 1 f MARITAL SETTLEMENT AGREEMENT AGREEMENT made on this 29 day of July 2006, by and between Julie Tritt Schell (hereinafter referred to as "Wife"), who resides at 1404 Chatham Rd., Camp Hi11, PA 17011 and Christian Joseph Schell (hereinafter referred to as "Husband"), who resides at 2004 Hampton Court, Morgantown, PA 19543. WHEREAS, we were married on the 28 day of May 2000, in Boiling Springs, State of Pennsylvania and we now mutually desire to dissolve our marriage and mutually agree to five permanently separate and apart from each other, as if we were single; WHEREAS, we each have exercised good faith and have made fair, accurate, and complete disclosure to each other regarding all financial and property matters pertaining to this marital settlement agreement; WHEREAS, we mutually desire to settle by agreement all matters regarding our marital affairs, persona{ and real property, and finances; WHEREAS, we mutually intend this agreement to be a final disposition regarding the marital issues addressed herein and intend that this agreement be incorporated into any subsequent DECREE OF DIVORCE. THEREFORE, in exchange for the mutual promises herein contained, we agree to five separately and to divide our property and finances according to the following mutually agreed upon terms and conditions: Financial Separation Terms The terms listed below will act as the final financial separation agreement between Chris and Julie. • As of July 3, 2006, there were 5 CDs at Citizen's Bank, worth $128,567.99, after penalties for early withdraw. Therefore Julie agreed to pay Chris $64,284 which is half of the final value of the CDs. • Chris and Julie agree that the house at 1404 Chatham Rd., Camp Hill is worth $200;000. The remaining mortgage on the house is $83,576.37. Thus there is $116,423.63 equity in the house. Julie has agreed to pay Chris $58,211.82, which is half of the equity value of the house, and this payment is considered abuy-out of the house by Julie. • Julie has already paid to Chris $73,000 since June 25, 2006, thus as of the signing of this agreement, Julie wi11 pay to Chris the remaining $49,495.82 ($122,495.82 - $73,000). • Chris will be removing the family room leather furniture, and the following furniture located in the home office: desk, file cabinet, side stand, lamp, in addition to all personal affects, from the home. All other items in the house were determined to be negotiable and Chris chose to leave them with Julie. • Although its unknown as of the signing of this agreement whether there will be any federal, state or local taxes, it is agreed that to the extent possible, both Chris and Julie agree to pay their respective shares of any taxes owed. • Chris has agreed to keep Julie on his health insurance plan at Cephalon until divorce is finalized, which is not expected to be before March 2007. Lauren will remain on Chris' health insurance for as long as he is gainfully employed. • Julie has agreed that Chris may have the time-share trip purchased at Olivia's House auction. Child Support Terms The terms listed below will act as the child support for Lauren in lieu of a formal court-established support payment requirement. • Chris will initiate a 529 plan for Lauren and will contribute a minimum of $250/month to this plan. Contributions will begin August 2006 and will end no sooner than the month that Lauren reaches age 18. The payment will be deducted automatically from Chris' account on a monthly basis. • Chris will pay 75%, up to $5000, of Lauren's school tuition which will include pre-school, and if Lauren is enrolled, will also include private kindergarten and child care expenses for before- school or after-school care, per further discussion and resolution. Julie will. pay for the remaining tuition. Any remaining percentage not paid for through the dependent care account will be paid to Julie prior to the end of the calendar year. • Upon Lauren attending public school, Chris will invest a minimum of 10% of his current year's net salary into a separate savings plan which may consist of a savings account, dependent care account, certificates of deposit, mutual funds, etc. Should Julie and Chris both agree, a portion of this savings also may be invested in Lauren's 529 plan. Such savings may be used for Lauren's extra curricular activities or expenses, as agreed to by Chris and Julie. 2 • Should mutually agreed-upon extra large expenses arise, such as braces, a car, medical bills, or other unanticipated events, Chris will pay for half of the costs of these items. • Julie will pay for all other expenses relating to Lauren's upbringing including clothes, food, shelter, etc. • Should Julie's or Chris's income levels decrease significantly (such as by more than 30%), the terms of this agreement will be revisited and adjusted to reach mutually agreeable terms. • Although not required as a condition of Chris's child support/529/savings payments for Lauren, Julie has agreed to invest a minimum of $250/month to Lauren's 529 plan. 10. FINAL AGREEMENT This agreement sets forth the entire agreement and understanding between the Husband and Wife relating to the settlement of martial property and finances and supersedes all prior discussions between us. No modification of or amendment to this agreement, nor any waiver of any rights under this agreement, will be effective unless in writing signed by the party to be charged. 11. ACKNOWLEDGEMENT Husband and Wife acknowledge that each has entered into this agreement in good faith, without any duress or undue influence. Each understands his or her right to seek independent counsel regarding this agreement, and each has had the opportunity to seek independent counsel prior to signing this agreement. 12. CHOICE OF LAW Husband and Wife agree that this agreement shall be governed and construed in accordance with the laws of the Commonwealth of Pennsylvania. Signed and dated this ~_ day of _, 20~, r ulie Tritt Schell Christian Joseph Schell CERTIFICATE OF ACKNOWLEDGMENT OF NOTARY PUBLIC COMMONWE LTH OF PE NSY~VANIA COUNTY OF T~h--is document wLai s a~ck~nowledged befo!r1e,me or?., ~r~"`" -[Date] by ~ 1~ )' 1 P. fit` ~1 1~ c~:~Vlu~_ ~ ~f 1 Srli~f\ ~~5~'.4~'1 ~ [name of principal]. [Notary Seal, if any}: COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL SUZANNf M. flEDEitIrR, N~sry Public Camp Hill Boro, Cutr~riand County My Comm'"~~on Expires Aug. 20, 20U9 Pennsylvania My commission expires: ~ 4 Notary Public for the Commonwealth of ~ ~ ~ ~ ,.. ~~BOM ~' LITLILAKIS Kara W. Ha~certy, Esquire Attorney LD. #: 86914 2 West High Street Carlisle, PA 17013 (717)249-0900 JULIE TRITT SCHELI,, Plaintiff ~-. CHRISTIAN J. SCHELL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 07-4405 CIVIL TE1~I CIVIL ACTION -LAW IN DIVORCE AFFIDAVIT OF SERVICE I, hara W. Haggerty, Esquire, hereby certify that I did sei~=e a true and correct copy of the Divorce Complaint, upon the Defendant, Christian J. Schell, by depositing, or causing to be deposited, same iii the L'.S. mail, certified, postage prepaid, addressed as follows: Christian J. Schell 2004 Hampton Court Morgantown, PA 19543 Document from the United States Postal Ser<-ice acknowledging receipt on August 2, 2007, is attached as Exhibit ` 1~". ABOM & KUTUI AKIS, LLP ,~ Date: ~~ Z~ ,,.~, ~. ",tC ~Cc L ~. ~ _ hara W. Haggett`-, Attorney LD. No: 8 ~ 2 West High Street Carlisle, PA 17013 (717) 249-0900 ~ttorne~~ for Plcri~zt~ Date: 06/29/2009 FRENCH: The following is in response to your 06/29/2009 request for delivery information on your Certified Mail(TM) item number 7005 2570 0000 3804 1732. The delivery record shows that this item was delivered on 08/02/2007 at 08:29 AM in MORGANTOWN, PA 19543. The scanned image of the recipient information is provided below. store' _ Signature of Recipient: ; j~ - _ /~ --- ~. ~ ted C~ ~S`kAr~ ~c`~-+- ~L C..- Address of Recipient: ~ rl~-~,~ ~~C14t~~~ C1~ Thank you for selecting the Postal Service for your mailing needs. If you require additional assistance, please contact your local Post Office or postal representative. Sincerely, United States Postal Service E)IHIBIT A Secretary2 From: Kara Haggerty [KWH@AbomKutulakis.com] Sent: Monday, June 29, 2009 9:27 AM To: 'Debbie Ryan ' Subject: FW: U.S. Postal Service Track & Confirm email Restoration - 7005 2570 0000 3804 1732 Kara W. Haggerty, Esquire Abom & Kutulakis, LLP 2 West High Street Carlisle, PA 17013 (717) 249-0900 Fax (717) 249-3344 **IMPORTANT NOTICE** The information contained in this email transmission is privileged and confidential and subject to the attorney/client privilege, and is otherwise protected from disclosure under applicable law. This transmission is intended only for the use of the individual or entity to which it is herein addressed. If the reader of this transmit>sion is not the intended recipient, you are hereby notified that any dissemination, di;>tribution, copying or use of this transmission or any information contained herein is strictly prohibited. If you have received this transmission in error, please call (717) 249-0900 and return the transmission to us via email, fax (717) 249-3344, or U.S. First Class rnail. We will promptly reimburse you for any costs you incur. -----Original Message From: U.S._Postal_Service_ [mailto:U.S._Postal_Service@usps.com] Sent: Sunday, June 28, 2009 12:49 PM To: kwh@abomkutulakis.com Subject: U.S. Postal Service Track & Confirm email Restoration - 7005 2570 0000 3804 1732 This is a post-only message. Please do not respond. Kara Haggerty has requested that you receive this restoration information for Track & Confirm as listed below. Current Track & Confirm e-mail information provided by the U.S. F~ostal Service. Label Number: 7005 2570 0000 3804 1732 Service Type: Certified Mail(TM) Shipment Activity Location Date & Time Delivered MORGANTOWN PA 19543 G8/02/1)7 8:29am Notice Left MORGANTOWN PA 19543 07/26/1)7 10:52am USPS has not verified the validity of any email addresses submitted via its online Track & Confirm tool. For more information, or if you have additional questions on Track & Confirm services and features, please visit the Frequently Asked Questions (FAQs) section o:E our Track & 1 ~~ THE ;=r".,. .,.,,~~.~,qY 20~~.~~~ 29 f'~ ,~ C~3 - .%. J I `v " ~;~ ,- ABOM ~' j~LITLILAKIS Kara W. Ha~eem~. Esquire Attorney LU. #: 86914 2 West Hieh Street Carlisle. PA 17013 (717)249-0900 JULIE TRITT SCHELL, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, Pry. v. CHP~ISTIAN j. SCHELL, Defendant NO. 07-4405 CIVIL'TERI'~I CIVIL ACTION - L,? W IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce under ~3301(c) of the Divorce Code -was filed on July 25, ?007. 2. The marriage of Plaintiff and Defendant is irretrie~-abh- broken and ninety- (90) da~-s have elapsed from the date of filing and ser~-ice of the Complaint. 3. I consent to the entry of a final decree of divorce after ser~~ice of notice of intention to request entry of the decree. I ~-erifv that the statements made in this affidavit are true and correc~~~t. I unc[erstand that false statements herein are made subject to the penalties of 18 Pa. C.S. 54904 relating to unsworn falsification to authorities. r' ! ~i ~+ Date: ~-Z ~~,~1v E V' ~ C/ --t~~ CHRISTIAN J. SCHELL za~4 ~~~ 2g F~- ~,: u ABOM ~' ICuTU~Kis Kara W. Hageerty. Esquire Attorney LD. #: 86914 2 West High Street Carlisle. PA 17013 (717)249-0900 JULIE TRITT SCHELL, Plaintiff ~-. CHRISTIAN J. SCHELL, Defendant IN THE COURT OF COMMON' PLEAS CUMBERLAND COUNTY, PA NO. 07-4405 CIVIL TEI~I CItiTIL ACTION -LAW IN DI~rORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~3301(c) OF THE DIVORCE CODE 1. I consent to the entt-y~ of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimon~~, division of property-, law~-er's fees or epenses if I do not claim them before a divorce is granted. 3. I understand that I will not be dig=orced 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 Prothonotarj-. 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. X4904 relating to unsworn falsification to authorities. Date: ~~'~~~-~°~ ~~ CHRISTIAN j. SCHELL 2G~9 ~~J~ 29 r'' ~: ~ ~ 3 r' ~;ri t ~'h ~t~ ~~ ~c~`~ ,.~ ; ,: ,, OM ~' LILAKIS .® Kara W. Hagerty. Esquire Attorney LD. #: 86914 2 West Hieh Street Carlisle, PA 17013 (717)249-0900 JULIE TRITT SCHELL, Plaintiff ~-. CHRISTIAN j. SCHELL, Defendant IN THE COURT OF COI~I~MON PLI/AS CUMBERLAND COUN'T'S', PA NO. 07-4405 CIVIL TERM:[ CIVIL ACTION -LAW IN DIVORCE PRAECIPE TO TRANSMIT THE RECORD To the Prothonotary-: Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground(s) for Divorce: a. Irretrievable Breakdown under ~~ ~301(c) of the Di~-orce Code. 2. Date and manner of sery-ice of the Complaint: a. Certified Mail on August 2, ?007, as e~-idenced by Affidavit of Service fled on June 29, 2009 3. Date of execution of the Affiday~it of Consent required bS ~3301(c) of the Divorce Code: a. by Plaintiff: Mai- ??, ?009; by- Defendant: June 22, ?009. 4. All economic claims previously- raised have been settled b~~ filing of the Marital Settlement Agreement dated May- 1, 2009. Date Wai~-er of Notice in ~3301(c) Dim orce was filed with the Prothonotary-: a. b~~ Plaintiff: June 19, 2009; b~~ Defendant: June 29, 2009 Respectfully submitted, D.~TF ~ ?cf C~c ABOM~ KUTUI.AKIS, L.L.P J 1 _ ~-~ ~ i1 ~ ~ Cam. ~ _ ~C ~ L ~ _---_ Kara W. Haggertt~, Esqu Supreme Court ID # 2 West High Street Carlisle, Pennsy~h~ania 17013 (717) 249-0900 _-lttorn~y fo1°Plai~itiff x- -. r C~ ~r . 't '~r,,(r~':~tgy 2009 ~E#~'~ ~9 P~ ~~ ,, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JULIE TRITT SCHELL V. CHRISTIAN J. SCHELL NO. 07-4405 CIVIL TERM DIVORCE DECREE AND NOW, J'~~_~ Zdo `~ , it is ordered and decreed that JULIE TRITT SCHELL CHRISTIAN J. SCHELL bonds of matrimony. plaintiff, and defendant, are divorced from the Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") NONE By the Court, 7. /O Off' `77e~ie~ ,i~Q..~ l ,,; ~ . ~ . i ~ ~'• R_A S• .