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HomeMy WebLinkAbout07-4672 CHANTELLE L. GREENINGER, PLAINTIFF vs. TIMOTHY P. GREENINGER, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: 07 - ~(o7a C ivi I ~ erm CIVIL ACTION -LAW IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth ui 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 ox annulment may be entered against you by the Court. A judgment may also be entered against you fox 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, One Courthouse Square, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DNISION OF PROPERTY, LAWYERS'S FEES OR EXPENSES BEFORE A DNORCE 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 UNTY BAR ASSOCIATION LAWYER REFER R AT .SERVICE 32 South Bedford Suet Carlisle, PA 17013 TELEPHONE: 717-249-3166 i ` Q~OM ~' I~uTU~ls Michelle L Sommer, Esguire Attorney I.D. #: 93034 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 CHANTELLE L. GREENINGER, PLAINTIFF vs. TIMOTHY P. GREENINGER, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: m ~- yL 7-2 -'c.~ Tom. CIVIL ACTION -LAW IN DIVORCE 1. Plaintiff is Chantelle L. Greeninger, who currently resides at 839 Kimmerlings Road, Lebanon, Lebanon County, Pennsylvania 17046. 2. Defendant is Timothy P. Greeninger, who currently resides at 210 Oak Knoll Road, York County, Pennsylvania 17070. 3. The Plaintiff has been a bona fide resident of the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were warned on September 28, 2002, in Lebanon, Lebanon County. COUNT I -DIVORCE 5. Paragraphs one (1) through four (4) of this Complaint are incorporated herein by reference as though set forth in fiill. 6. 'T'here 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), in that: a. The marriage is irretrievably broken. 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. WHEREFORE, the Plaintiff requests the Court to enter a decree of Divorce. COUNT II - EOUITABLE DISTRIBUTION 10. Paragraphs one (1) through nine (9) of this Complaint are incorporated herein by reference as though set forth in full. 11. Plaintiff and Defendant have acquired property, both real and personal, during their marriage from September 28, 2002, until June 16, 2007, which property is "marital property". 12. Plaintiff and Defendant may have owned, prior to marriage, property which has increased in value during the marriage and/or which has been exchanged for other property, which has increased in value during the marriage, all of which property is "marital property". 13. Plaintiff and Defendant have been unable to agree as to an equitable division of said property prior to the filing of this Complaint. WHEREFORE, the Plaintiff requests this Honorable Court to equitably divide all marital property. Da'1"E ~ (~- ~ 0~- Respectfully submitted, ABO~r ~ Ku~vLAxrs, L.L.P. Michelle L. So r, Esquire Attorney ID No. 93034 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 Attorney for Plaint I, CHANTELLE L. GREENINGER, 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. ~ 4904 relating to unsworn falsification to authorities. Date ~ . (~ ~ V~ ~ t wV l CHANTELLE . GREENINGER . ,. CHANTELLE L. GREENINGER, PLAINTIFF vs. TIMOTHY P. GREENINGER, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: CIVIL ACTION -LAW IN DIVORCE AND NOW, this 7~' day of August, 2007, I, Michelle L. Sommer, 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 and Regular Mail, postage prepaid addressed to the following: Tiunothy P. Greeninger 210 Oak Knoll Road New Cumberland, Pennsylvania 17070 Pro Se Defendant Respectfully submitted, Abom ~ Kutulakis, L.L.P. ~- Michelle L. Somm r, Esquire Attorney ID No. 93034 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 C~ n ..D L o~ G 7 ..C ~) j C'? C 'TJ t7 -' - `~T '~ r. .._ l~ i -~ "'C rv Q 0 --.~ A C F -..1 xm O "-~~ ~~ r _ C? ~ L7 {~~) J ('f1 "~ ~. - .- CHANTELLE L. GREENINGER, : IN THE COURT OF COMMON PLEAS PLAINTIFF :CUMBERLAND COUNTY, PENNSYLVANIA vs. NO: 07-4672 TIMOTHY P. GREENINGER, :CIVIL ACTION -LAW DEFENDANT IN DIVORCE AFFIDAVIT OF SERVICE I, Michelle L. Sommer, Esquire, hereby certify that I did serve a true and correct copy of the Complaint under Section 3301 (c) & (d) of the Divorce Code, upon the Defendant, by depositing, or causing to be deposited, same in the U.S. mail, certified, postage prepaid, on August 7, 2007, at Carlisle, Pennsylvania, addressed as follows: Timothy Greeninger 210 Oak Knoll Road New Cumberland, PA 17070 Return card acknowledging receipt on August 14, 2007, is attached as Exhibit "A". ABOM & KUTULAKIS, LLP r. Date: Michelle L. Somme , squire Supreme Court I.D. 93034 36 South Hanover Street Carlisle, Pennsylvania 17013 (717) 249-0900 Attorney for Plaint ~" ~ r _ ~ ., . ^ Complete items q, 2, and 3. Also complete ftem 4 if'Restricted Delivery is desired. ^ Print your name and address on the reverse so that we can return the card to you. ^ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Artlcle Addressed to: ~ mv~ ~'. z~ d C~~k Knoi~ d 9J ~.~ Gvrnl~.+~lzrd ~A ~ , 1 'j O7C~ A. X B. Received (Pifn~ecf Name) C~bate of DeNvay i~ b. Is deifve address ditle t m Item 1? O Yes It YES, enter delivery address t~elow: ^ No 3. Service Type ~Rffled Mail ^ Express Mail D Registered ^ Return Receipt for MerchancHse ^ Insured Mail ^ C.O.D. 4. Restricted Delivery? (Extra Fee) ^ Yes z. ArtldeNutl~r 7005 2570 ~~00 3804 0575 (-lar-sfer from servk PS Form 3811, February 2004 Dorrrsstic Rewm Receipt ,a¢s%-oz-tir.,sto Exhibit "A" C~ ~ ,., C ~ ~n ~; ;- ~ ~r _ ~ r; _. ., , u ~. . . ~ _ .., + ~~ ~-..> r^ ~ ~ J .., CHANTELLE L. GREENINGER VS. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0. 07-4672 TIMOTHY P. GREENINGER CIVIL ACTION-LAW DIVORCE NOTICE OF APPEAIItANCE Please accept this notice of my appearance on behalf of the Plaintiff, Chantelle L. Greeninger, in reference to the above captioned matter. William M. Shreve Supreme Court ID # 82337 P.0. Box 5292 Harrisburg, PA 17110 (717) 571-0956 /' ., CHANTELLE L. GREENINGER VS. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0. 07-4672 TIMOTHY P. GREENINGER CIVIL ACTION-LAW DIVORCE CERTIFICATE OF SERVICE AND NOW, this ~" da of M y ay, 2008, I, William M. Shreve, hereby certify that I have or will serve the within document upon the persons and in the manner indicated below: Service by First Class Mail• Suzanne H. Griest, Esquire 129 East Market Street York, PA 17401 Michelle Sommer 36 South Hanover Street Carlisle, PA 17013 ~~ William M. Shreve .~"' ~~' ' ~~ ~, 4' CHANTELLE L. GREENINGER, PLAINTIFF vs. TIMOTHY P. GREENINGER, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: 07-4672 CIVIL ACTION -LAW IN DIVORCE PRAECIPE FOR WITHDRAWAL OF APPEARANCE Please withdraw my appearance on behalf of the Plaintiff, Chantelle L. Greeninger, in the above-captioned matter. ABOM & KUTULAKIS, L.L.P. Date: 10~~(~g Michelle L. Somme ,Esquire 36 South Hanover Street Carlisle, PA 17013 (717) 249-0900 Attorney ID 93034 as ~ Q ~T ~~ ~~~ ~~ i ~ ,~ ,~' cr- w -„~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ~r . P1 'ff . Vs File No. 0 ~ -" ~ (JJ ~ 2 • IN DIVORCE -Tim Def ant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff /defendant in the above matter, [select one by marking "x"] _~ prior to the entry of a Final Decree in Divorce, or after the entry of a Final Decree in Divorce dated hereby elects to resume the prior surname of rn~, ~C~ 1 Tom. ,and gives this written notice avowing his /her intention pursuant to the provisi ns of 54 PS. 704. Date: (~ • UZ . (~ Signature Signature of name being r COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF ~{ On the ~~day of -iU,~~_, 200 ~ before me, the Prothonot or the ~'Y notary public, personally appeared the above afftant known to me to be the person whose name is subscribed to the within document and acknowledged that he /she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand hereunto set my hand and official seal. .// Notary Public PROTHONOTARY NOTARY PUBLIC CARLISLE CUMBERLAND COUNTY COURTHOUSE MY COMMISSION EXPIRES JANUARY 4, 2010 ~, ~~ ~,~ ~ - ---~ ,R r4 ~ ~..: i ~.1 ~ ~~r .~ .~ca. y ~., ^ ~ ~ ~ ~ ~i fit ~~ ,{ 1 `\J ~ .~ t~ -``tiY 'MJ Commonwealth of Pennsylvania County of Cumberland, ss: CHANTELLE L. GREENINGER, ) Plaintiff ) ) vs. ) TIMOTHY P. GREENINGER, ) Defendant ) In the Court of Common Pleas of Cumberland County, Pennsylvania No. 2007-4672 CIVIL TERM Motion for Appointment of Master CHANTELLE L. GREENINGER, Plaintiff moves the court to appoint a Master with respect to the following claims: (xxx) Divorce ( )Annulment ( )Alimony ( }Alimony Pendente Lite (xxx) Distribution of Property ( )Support ( )Counsel Fees ( )Costs and Expenses and in support of the motion states: 1. Discovery is complete as to the claim(s) for which the appointment of a Master is requested. 2. The Defendant has not appeared in the action by any attorney. 3. The statutory ground(s) for divorce is/are: 3301 (D) or 3301 (d} of the Divorce Code. 4. Check the applicable paragraph(s). ( )The action is not contested. ( ) An agreement has been reached with respect to the following claims: (xxx) The action is contested with respect to the following claims: 5. The action does not involve complex issues of law or fact. 6. The hearing is expected to take 1 day. 7. Additional information, if any, relevant to the motion: ~'1 a ~7~G Date uel L. n es Attorney for Plaintiff AND NOW, 2009, ,Esquire, is appointed Master with respect to the following claims: divorce. BY THE COURT, J. tt"~ dv ' ~ ~ =~' ~ '~ r ~ ~ --, .. ~-;-, ~r ;,~ ~` :~ _ ,::', -- ~r_~ :~ r' `i _~ ~ C i ~„N 7 ~ 2aD9~ ~~'~ Commonwealth of Pennsylvania County of Cumberland, ss: CHANTELLE L. GREENINGER, ) Plaintiff ) vs. ) TIMOTHY P. GREENINGER, ) Defendant ) In the Court of Common Pleas of Cumberland County, Pennsylvania No. 2007-4672 CIVIL TERM Motion for Appointment of Master CHANTELLE L. GREENINGER, Plaintiff moves the court to appoint a Master with respect to the following claims: (xxx) Divorce ( )Annulment ( )Alimony ( )Alimony Pendente Lite (xxx) Distribution of Property ( )Support ( )Counsel Fees ( )Costs and Expenses and in support of the motion states: 1. Discovery is complete as to the claim(s) for which the appointment of a Master is requested. 2. The Defendant has not appeared in the action by any attorney. 3. The statutory ground(s) for divorce is/are: 3301 (D) or 3301 (d) of the Divorce Code. 4. Check the applicable paragraph(s). ( )The action is not contested. ( ) An agreement has been reached with respect to the following claims: (xxx) The action is contested with respect to the following claims: 5. The action does not involve complex issues of law or fact. 6. The hearing is expected to take 1 day. 7. Additional information, if any, relevant to the motion: 27 c~~., ~C7G Date uel L. n es Attorney for Plaintiff AND NOW, ~ 2009, ~ l~~i~-(~J2(~ ~~.~ 1~ Esquire, is appointed Master wit respect t the following claims: divorce. ~_ ~~ ~' THE U G`"1 J. [~ ~.~. F~,.a -= ~'> C ..- ~^ti C.L. ~} ~1. J ~' ~~ ,~.. c ~4 ..~ .++' %'~. ~. :~i ..J -~'~` i .~ Q r v~ ~~~ ~_ Q_ Q fl ---_.. r1 --`~ ~\ '~~' ~ -, , _ ~:~ ~:~ ~. .~ .~ 'r...~ v ` "-n '~ _..... -~-~ ,-, i-. , ~} :~ CHANTELLE L. GREENINGER, now CHANTELLE L. RATCLIFFE, Plaintiff vs. TIMOTHY P. GREENINGER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 2007-4672 IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the foregoing 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 the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at: Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 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, PA 17013 Telephone: (717) 249-3166 CHANTELLE L. GREENINGER, now CHANTELLE L. RATCLIFFE, Plaintiff vs. TIMOTHY P. GREENINGER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 2007-4672 IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302 (d) of the Divorce Code, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. .. CHANTELLE L. GREENINGER, now CHANTELLE L. RATCLIFFE, Plaintiff vs. TIMOTHY P. GREENINGER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 2007-4672 IN DIVORCE AMENDED COMPLAINT IN DIVORCE AND NOW comes the above-named Plaintiff, Chantelle L. Greeninger, by her attorney, Samuel L. Andes, and files the following Amended Complaint in Divorce: The Plaintiff is Chantelle L. Ratcliffe, formerly Chantelle L. Greeninger, an adult individual who currently resides at 2905 Winchester Drive, Apartment 508 in Camp Hill, Cumberland County, Pennsylvania. 2. The Defendant is Timothy P. Greeninger, an adult individual who currently resides at 210 Oak Knoll Road in New Cumberland, York County, Pennsylvania. 3. Both the Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on 28 September 2002 in Lebanon, Lebanon County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised of the availability of marriage counseling and the Plaintiff may have the right to request that the Court require the parties to participate in counseling. COUNT I -IRRETRIEVABLE BREAKDOWN 8. The Plaintiff requests this Court to enter a Decree in Divorce. WHEREFORE, Plaintiff requests this Court to enter a Decree in Divorce pursuant to the Divorce Code of Pennsylvania. COUNT II -EQUITABLE DISTRIBUTION 9. During the course of the marriage, the parties have acquired numerous items of property, both real and personal, which are held in joint names and in the individual names of each of the parties hereto. WHEREFORE, Plaintiff prays this Honorable Court, after requiring full disclosure by the Defendant, to equitably divide the property, both real and personal, owned by the parties hereto as marital property. COUNT III -COUNSEL FEES AND EXPENSES 10. Plaintiff, although gainfully employed, cannot alone meet the costs and expenses to litigate this matter, particularly without full cooperation from the Defendant. 11. Plaintiff requires competent counsel to adequately protect her rights in this matter. 12. Defendant has sufficient income to contribute to the costs of this litigation. WHEREFORE, Plaintiff prays this Honorable Court to order Defendant to pay his reasonable share of the legal fees and expenses incurred by Plaintiff in the litigation of this action. Sa el L. Andes Attorney for Plaintiff Supreme Court tD # 17225 525 North 12th Street Lemoyne, Pa 17043 (717) 761-5361 h l I verify that the statements made in this Complaint are true and correct. I understand that any false statements in this Complaint are subject to the penalties of 18 Pa. C.S. 4904 (unsworn falsification to authorities). Date: ~ ~~ ~~~_ CHANTELL . RATCLIFFE n ~ ~"" ~ ~` `~, V ~ Z. 2 -~. ~'! Co (;,, U^. n .6,3 Q ~- _".~"~ ..... ~ .~~- , ~.r r~ ,~, . „ : ~:~ ~ ~ ~~! ~ _ t~ ;~J ~ ~ C,~_k t„~ CHANTELLE L. GREENINGER, ) IN THE COURT OF COMMON Plaintiff ) PLEAS OF CUMBERLAND } COUNTY, PENNSYLVANIA vs. ) No. 2007-4672 CIVIL TERM TIMOTHY P. GREENINGER, ) IN DIVORCE Defendant ) PRAECIPE TO THE PROTHONOTARY: Please enter my appearance for the Plaintiff in the above matter. Date ~~- Samuel L. Andes Attorney for Plaintiff Supreme Court ID # 17225 TO THE PROTHONOTARY: Please withdraw my appearance as attorney for the Plaintiff in the above matter. Date William .Shreve Attorney at Law Supreme Court ID # ~- 3,~/~' a ~ ~, .,~ ~a ~_: -,,,. -... -~ rn r - ° ) :,:3 ~Tr -' .` ..,,j f7`j ~, ,~: CHANTELLE L. GREENINGER, PLAINTIFF vs. TIMOTHY P. GREENINGER, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 07-4672 CIVIL TERM IN DIVORCE NOTICE TO DEFENDANT If you wish to deny any of the statements set forth in this Affidavit, you must file a Counter Affidavit within twenty (20) days after this Affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301 (d) OF THE DIVORCE CODE 1. The parties to this action separated in early April 2007 and have continued to live separately and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. Date: /~}Ti 1 `~, 7~x~ ~...,. _ - ~Q CHANTELLE INGER FEL~~:i=r'i~ 20Q9 ~P~ 22 ~'~i4°~ ~~ ! ~ v,ti _ i ~ •~~ , ~ , ~~rn'° ~?ta .. ~ w IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHANTELLE L. GREENINGER Plaintiff NO. 07-4672 v. TIMOTHY P. GREENINGER Defendant CIVIL ACTION -LAW DIVORCE PRAECIPE TO WITHDRAW/ENTER APPEARANCE GRIEST~ HIME$ HERROLD~ SCHAUMANN~ FERRO LLP ATTORNEYS AT Lnw 129 E15T MnRRer $TRFbT YORK, PermsnvAHU ]7401 To,pnrorm (717) 846-8856 TO THE PROTHONOTARY: Please let the record reflect that I, Suzanne H. Griest, Esq., enter my appearance as counsel for Defendant, TIMOTHY P. GREENINGER, in the above-referenced case. Suzar,~e H. ~e~t, Esquire Supt. I.D. No. 34362 Dated: , 2009 ~ _. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHANTELLE L. GREENINGER Plaintiff v. TIMOTHY P. GREENINGER Defendant NO. 07-4672 CIVIL ACTION -LAW DIVORCE CERTIFICATE OF SERVICE GRIFST~ HIML+S. HERROLD, SCHAUMANN, FVJtRO LLP ATTORNEYS AT LAW 129 EAST MAaKer STREET YORK, PENNSYLVANIA 17401 TFI.EPFK)NE (777) 546-88$6 AND NOW, TO WIT, this ~2~1 day of May, 2009, I, Suzanne H. Griest, Esquire, a partner of the law firm of GRIEST, HIMES, HERROLD, SCHAUMANN, FERRO LLP, of 129 East Market Street, York, Pennsylvania, hereby certify that I served a true and correct copy of the PRAECIPE TO ENTER APPREANCE filed in the above captioned matter on this date by First Ctass U.S. Mail on: Samuel L. Andes, Esq. 525 North Twelth Street P.O. Box 168 Lemoyne, PA 17043 Respectfully Submitted: GRIEST HIMES HERROLD SCHAUMANN FERRO LLP By: uza H. riest, Esquire Att ey for Defendant Supreme Court I.D. #34362 129 East Market Street York, Pennsylvania 17401 (717) 846-8856 ~°i[~E~~ ! ; ~r F ~JI i :1., i ~ , ~ .. .~ r. ~E, 3 {~, ~''`i ~ w J ~ ~ r~~;u ,Uk t:.:_ ,. iv; f [ ",'t ir~ CHANTELLE L. RATCLIFFE, formerly CHANTELLE L. GREENINGER, PLAINTIFF vs. TIMOTHY P. GREENINGER, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 07-4672 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on 7 August 2007 and served upon the Defendant on or about 15 August 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of both the filing and service of the complaint. 3. I consent to the entry of a final decree in divorce after service of a Notice of Intention to Request Entry of the Decree. 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 in 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. Section 4904 relating to unsworn falsification to authorities. q 22`O`~ Dated: GRANTEE . RATCLIFF ormerly CHANTELLE L. GREE GER ~~ THE ~~„'~~'~r,~ "r~;T~AF?'f 2009 SAP 23 F'i'i 2~ ~~ v :~~°V,: ;; ~, r z_~ CHANTELLE L. RATCLIFFE, formerly CHANTELLE L. GREENINGER, PLAINTIFF vs. TIMOTHY P. GREENINGER, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 07-4672 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on 7 August 2007 and served upon the Defendant on or about 15 August 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of both the filing and service of the complaint. 3. I consent to the entry of a final decree in divorce after service of a Notice of Intention to Request Entry of the Decree. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(cl OF THE DIVORCE CODE 1. I consent to the entry of a final decree in divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees, or expenses if I do not claim them before a divorce is granted. I understand that I will not be divorced until a divorce decree is entered by the court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. -~ °I 1 ~ ~°i Dated: TIMOTHY . GREENINGER FiLF.~- ~::;~-,uF ;~, 20D9 SEA 23 f'~`~ 2~ r C~.+~ ~~ f f l:~~, rti CHANTELLE L. GREENINGER, THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. N0. 07 - 4672 CIVIL TIMOTHY P. GREENINGER, . Defendant IN DIVORCE ORDER OF COURT AND NOW, this 3 ~ day of ~11~, ~ 2009, the economic claims raised in the proceedings having been resolved in accordance with a property settlement agreement dated August 18, 2009, 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. cc: ~ Samuel L. Andes Attorney for Plaintiff -~ Suzanne H. Griest Attorney for Defendant ~~,~~C~C g~~3 /off ~~ BY T OURT, ~~ a~ Edgar B. Bayley, P.J. 2009 SEP 23 i;~~9 ~~ ~ U~t+~ti ; ;;~t-r~, ~.~~~ PROPERTY SETTLEMENT AGREEMENT THIS AGREEMENT, made this ~0 ~ day of 2009, is by and between: TIMOTHY P. GREENINGER, of 210 Oak Knoll Road in New Cumberland, Pennsylvania, hereinafter referred to as "Husband"; and CHANTELLE L. RATCLIFFE, formally Greeninger, of 2905 Winchester Drive, Apartment 508 in Camp Hill, Pennsylvania, hereinafter referred to as "Wife." WITNESSETH: WHEREAS, the parties hereto are Husband and Wife, having been married on 28 September 2002 and no children were born of this marriage; and WHEREAS, certain difficulties have arisen between the parties hereto which have made them desirous of living separate and apart from one another and Wife has initiated an action in divorce filed to No. 07-4672 before the Court of Common Pleas of Cumberland County, Pennsylvania; WHEREAS, the parties hereto, Wife being represented by Samuel L. Andes, Esquire,. and Husband by Suzanne H. Griest, Esquire, have each exchanged full and complete information as to the property, assets, and liabilities owned and owed by each and have disclosed to each other and to their respective attorneys full information as to the financial status of both parties hereto; and WHEREAS, the parties hereto have mutually entered into an agreement for the division of their assets, the provision for the liabilities they owe, and provision for the resolution of their mutual differences, after both parties have had full and ample opportunity to consult with their respective attorneys, and the parties now wish to have that agreement reduced to writing. NOW, THEREFORE, the parties hereto, in consideration of the above recitals, the mutually made and to be kept promises set forth hereinafter, and for other good and valuable considerations, and intending to be legally bound and to legally bind their heirs, successors, assigns, and personal representatives, do hereby covenant, promise, and agree as follows: Page 1 of 12 1. RESIDENCE.. Wife shall convey to Husband all of her right, title, and interest in the formal marital residence located at 210 Oak Knoll Road in Fairview Township, York County, Pennsylvania for the following terms and conditions: A. The conveyance shall be made by Special Warranty Deed which shall be prepazed by Husband or his attorney, signed by Wife, and held by Wife's attorney until delivery in accordance with this Pazagraph. B. Husband shall refinance the debt owed now or formally to National City Mortgage Company which is secured by a first mortgage against the property and, any other lien or charge against the property for which Wife is or maybe liable, or shall otherwise obtain Wife's unconditional release from such obligations, within six months of the date of this Agreement. At settlement on such refinancing, or at such other time and other conditions as the parties' counsel may agree, Wife's attorney shall deliver the Deed held in escrow in accordance with Sub Paragraph A hereof, to Husband's counsel. C. In the event that Husband does not secure Wife's unconditional release from the debts secured by the mortgage and' any other liens against the property within six (6) months of the date of this Agreement, the parties shall promptly list the property for sale, complete a sale as soon as possible, and apply the proceeds of the sale to pay and satisfy all liens, charges, or debts arising out of their ownership of the property any remaining proceeds of such sale, after the payment of all customary sale costs and the debts and obligations secured by liens against the property,-the balance of -any proceeds shall Vie-distributed to-Husband. _ In the_ event that such sale becomes necessary, the parties will cooperate to list the property for sale with a Realtor selected by their mutual agreement, at a price selected by them giving proper consideration to the recommendation of their Realtor, and shall cooperate to effect the sale as promptly as possible. In the event that the property is not listed or sold within ten (10) months of the date of this Agreement, either party may have the Court of Common Pleas of Cumberland Page 2 of 12 County appoint a Special Master to oversee and control the sale of the property as promptly as possible thereafter. D. On the date of this Agreement until conveyance of the property to Husband or its sale, Husband shall have the exclusive right to occupy the property and shall be solely responsible to pay, and shall pay in a timely fashion, all installments on the mortgage against the property and all other debts, expenses, and obligations arising out of the property and shall, further, indemnify and save Wife harmless from any loss, cost; or expense caused to her by his failure.to do.so. The parties shall cooperate with each other, their attorneys, the real estate broker or agent they select, and any Special Master appointed by the court to implement and execute the terms and provisions of this Agreement as promptly as possible after the date of this Agreement. 2. PENSIONS AND RETIREMENT BENEFITS. The parties acknowledge that, during the marriage, Wife was employed by Giant Foods/Ahold USA, Inc. and that, as a result, she accrued certain benefits within the Ahold USA Defined Benefit Pension Plan and the Ahold USA 401 (k) Plan. The parties acknowledge that they have exchanged information about the .; marital value of these assets and have agreed that Wife shall retain them free of any further claim by Husband. Accordingly, Husband does hereby waive, remise, relinquish, and release any claim to or interest in Wife's said benefits and confirms them to be the sole and separate property of Wife free of any further claim by Husband hereafter. 3. MOTOR VEHICLES. The parties agree that they will divide, distribute, and otherwise dispose of the motor vehicles owned by them, and any debt associated with those ~ ~ vehicles, as follows: _ _ _ _ _ _ _ _ ~ A. Wife shall retain ownership of the 2006 Mazda 3 four door sedan currently titled in her name and in her possession. Husband hereby releases and waives any further claim to or interest in aid vehicle. Wife shall be responsible to pay and discharge, in accordance with its terms, the debt owed to Sun Trust which encumbers the title to the vehicle. Page 3 of 12 B. Husband shall retain the Ford F-250 pickup truck currently titled in his name and in his possession, which Husband represents to Wife is free of any debt or encumbrance. The parties will make, execute, acknowledge, and deliver any and all documents necessary to implement the terms and provisions of this Paragraph. Further, each of the parties shall pay any and all debt, expenses, or obligations arising out of their ownership, use, or possession of either motor vehicle from the date they obtain the vehicle through the future and shall, further, indemnify°and~save-the other.harmless from any loss, cost~or expense caused to the other party. by their failure to do so. 4. STOCK OPTIONS, The parties acknowledge that, as a result of her employment by Giant Foods/Ahold USA, Inc. Wife has been granted certain options to purchase stock in Ahold USA. The parties have exchanged information about those stock options and Husband is satisfied to, and hereby agrees to, release any claim he has to those stock options or their proceeds. Accordingly, Husband does hereby waive, remise, relinquish, and release any claim to or interest in stock options held by Wife or in her name and confirms those stock options, and ,_ the proceeds thereof, to be the~sole and sepazate property of Wife. 5. ASSETS TO BE TRANSFERRED TO OR RETAINED BY WIFE. The parties agree that Wife shall be the sole and sepazate owner of the following assets, whether those assets 'I are now held in joint names or the name of either of the parties individually: A. Wife's checking account with M & T Bank. B. Wife's savings account with M & T Bank. E. W-if~'s-accounts-at i~lembers l~`-Federat Credit Union: The parties agree that they will make, execute, acknowledge and deliver, within thirty (30) days after the date of this agreement, all documents necessary to transfer such items to Wife's name alone and for Husband to waive any further claim to or interest in such assets and Husband does hereby acknowledge those assets to be the sole and separate property of Wife from and after the date of this agreement. Page 4 of 12 6. ASSETS TO BE TRANSFERRED TO OR RETAINED BY HUSBAND. The parties agree that Husband shall be the sole and separate owner of the following assets, whether those assets are now held in joint names or the name of either of the parties individually: A. Husband's accounts at Americhoice Federal Credit Union. The parties agree that they will make, execute, acknowledge and deliver, within thirty (30) days after the date of this agreement, all documents necessary to transfer such items to Husband's name alone and for Wife to waive any further claim to or interest in such assets and Wife does hereby acknowledge those assets to~ be~~the sole and separate..property of Husband from and--after the date of this agreement. 7. PERSONAL PROPERTY. Wife shall have those items of personal property listed on Schedule A and shall retrieve them from the residence within twenty (20) days of the date of this Agreement. Husband will cooperate to make the items available to Wife to retrieve and to coordinate a time for her to do so. Otherwise, the parties hereto mutually agree that they have effected a satisfactory division of the furniture, household furnishings, appliances, and other household and personal property between them and they mutually agree that each party shall, from;and after the date hereof, be the sole and separate owner of all such tangible personal property presently in his or her possession, whether said property was heretofore owned jointly or individually by the parties hereto, and this agreement shall have the effect of an assignment or receipt from each party to the other for such property as maybe in the individual possessions of each of the parties hereto, the effective date of said bill of sale to be contemporaneous with the date of the execution of this Agreement. g. SUPPOi~~' ORI~ER~-Husband-an~Wif~ acknowledge that they are parties to a support action before the Court of Common Pleas of York County, Pennsylvania, filed to Docket No. 1112 SA 2008 (PACSES # 595110008), which obligates Wife to pay spousal support to Husband. The parties agree that that order shall be terminated effective 31 May 2009 and that Wife shall have no further obligation to pay support to or contribute financially to the support of Husband after that date. Further, in the event that any payments are made on that order, through wage attachment or otherwise, after 31 May 2009, the amounts paid after that date shall be Page 5 of 12 applied to Wife's obligation to make. the cash payment to Husband as provided in the following Paragraph. The parties will execute all documents necessary to terminate the support order effective 31 May 2009 promptly upon the request of the Domestic Relations Office, either counsel, or the other party. 9. CASH PAYMENT. As equitable distribution of marital property, Wife shall pay Husband the sum of $5,500.00 within fifteen (15) days of the date the court enters the final decree in divorce in the action now pending between the parties. Wife shall receive credit against-such payment for. any support payments deducted-:from her income,. or otherwise paid -- --~~~• ~~ : •.-: -..: through the York County Domestic Relations Office, on the support order described in the foregoing paragraph, with such payments reducing the balance owed on the cash payment pursuant to this Paragraph, dollar for dollar; by the amount of such support payment after 31 May 2009. 10. REPRESENTATION AS TO NO DEBTS. The parties hereto mutually represent to the other than neither of them has incurred any debts in the name of the other not previously disclosed or provided for in this agreement. Each of the parties hereby represents to the other that neither one of them have incurred or contracted for debts in the name of the other or for which the other is or would be legally liable from and after the date of the parties' separation. Both parties hereto mutually agree and promise that neither will contract or otherwise incur debts in the other's or joint names without the prior permission and consent of the other party hereto. Both parties hereto represent and warrant to the other party that they have not so contracted any debts unbeknownst to the other up to the time and date of this Agreement. - _ 11. -_WA~E-It OF-FI~R~H~-l~EQUPFAHL-E-Di~T-Ri~i.fFION. Thy p-artier acknowledge that each of them have had a full and ample opportunity to consult with counsel of their choice regarding their claims arising out of the marriage and divorce and that they have specifically reviewed their rights to the equitable distribution of marital property, including rights of discovery, the right to compel a filing of an Inventory and Appraisement, and the right to have the court review the assets and claims of the parties and decide them as part of the divorce action. Being aware of those rights, and being aware of the marital property owned by Page 6 of 12 each of the parties, the parties hereto, in consideration of the other terms and provisions of this agreement, do hereby waive, release and quitclaim any further right to have a court or any other tribunal equitably distribute or divide their marital property and do hereby further waive, release and quitclaim any and all claim against or interest in assets now currently in the possession or held in the name of the other, it being their intention to accept the terms and provisions of this agreement in full satisfaction of all of their claims to the marital property of the parties and the equitable distribution of the same. :~. 12: ,..,VV~I~~El~Y~OF ALIMONY . SUPPORT~AND ~Ah~IQ1vY..PENDENTE~ LITE. ~.. ~~~ The parties acknowledge that they are aware of the income, education, income potential, and assets and holdings of the other or have had full and ample opportunity to become familiar with such items. Both parties acknowledge that they are able to support and maintain themselves comfortably, without contribution from the other beyond that as provided for in this Property Settlement Agreement, upon the income and assets owned by each of them. The parties hereby accept the mutual covenants and terms of this Agreement and the benefits and properties passed to them hereunder in lieu of any and all further rights to support or alimony. for themself, counsel -fees, and alimony pendente lite at this time and during any and all further or future.actions of divorce brought by either of the parties hereto and the parties do hereby remise, release, quit claim, and relinquish forever any and all right to support, alimony, alimony pendente lite, counsel fees and expenses beyond those provided for herein, during the pendency of or as a result of any such actions, as provided by the Divorce Code of Pennsylvania or any other applicable statute, at this time and at any time in the future. 13: -~VA~i~ER OI'-~JR~~ER FROCEEI7I1`~S BEFORE C(i~JR~~ The parties -_ hereby represent that they have agreed to the foregoing division or distribution of property in an effort to resolve all disputes relating to their marital property and obligations and to make an equitable distribution of their marital property as contemplated by the Divorce Code of Pennsylvania. The parties acknowledge that they have the right to ask a court of appropriate jurisdiction to make equitable distribution of their marital property and to engage in formal litigation to have the court do so. Because of the division or distribution of marital property to Page 7 of 12 which they have agreed, as provided for in this Property Settlement Agreement, and knowing their rights to have the court equitably distribute or divide their marital property following litigation by the parties, the parties hereto do hereby waive and release any right to have the court make such equitable distribution or for them to litigate any claims relating to equitable distribution in the divorce action contemplated by the parties. 14. WAIVER OF ESTATE RIGHTS. Husband releases his inchoate intestate rights in the estate of Wife and Wife releases her inchoate intestate rights in the estate of Husband, and each ofthe parties hereto by~these~presents for himself.or_herself~hs or:her heir~•oxeEUtors, ti administrators, or assigns, does remise, release, quit claim, and forever discharge the other party hereto, his or her heirs, executors, administrators, or assigns, or any of them, of any and all claims, demands, damages, actions, causes of action or suits of law or in equity, of whatsoever kind or nature, for or because of any matter or thing done, omitted, or suffered to be done by such other party prior to the date hereof; except that this release shall in no way exonerate or discharge either party hereto from the obligations and promises made and imposed by reason of this agreement and shall in no way affect any cause of action in absolute divorce which either party may have against the other. 15. WAIVER OF PROPERTY CLAIMS AND ESTATE CLAIMS. Except as herein otherwise provided, each party hereto may dispose of his or her property in any way, and each party hereby expressly 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, the right-to-equitable-division-a£martal-property, alimony, alimony-pen-dente lite and-counsel-fees, - - except as provided for .otherwise in this Agreement, dower, curtesy, 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 maybe necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interests, rights, and claims. Page 8 of 12 16. DISCLOSURE. Both of the parties hereto represent to the other that they have made full disclosure of the assets and income sources owned, controlled, or enjoyed by either of them and that neither party hereto has withheld any financial information from the other. Each of the parties represents that they have reviewed such information, as well as the law of Pennsylvania as it relates to their rights, obligations, and claims arising out of their marriage and of any divorce action which has or maybe filed between the parties with an attorney of their choice, or had the opportunity to review such matters with an attorney of their choice and y decide not to do~~so~-• Further,~thefparties~~ach acknowledge that they are aware that~r~~~~: ~ ~ ~~ :_- they have the right to compel the other party to provide full financial information about all assets owned by either party and all liabilities owned by either party and have the right to have a court force such disclosure in a divorce action. Being aware of those rights, the parties expressly waive the right to further disclosure or discovery regarding marital assets, liabilities, incomes, and finances and agree that they are satisfied with their understanding of their legal rights and obligations. Being so aware and satisfied, the parties mutually accept the terms and provisions of this agreement in full satisfaction of any and all rights or obligations arising of their marital status or the divorce action now pending or to be filed between them: 17. CONCLUSION OF DIVORCE. The parties acknowledge that this agreement is made in contemplation of the conclusion by both of them of an action in divorce which has been filed or will be filed shortly by one of the parties hereto. Both of the parties hereto agree that they shall, contemporaneously with the execution of this agreement, execute and deliver to their respective attorney or attorneys, an Affidavit of Consent under Section 3301(c) of the Divorce Code, consenting-tv the-entry-of a Tinal -decree in-divorce, and a Waiver of further notice for the entry of such decree. Both parties agree that they shall accept the terms and provisions of this agreement in full satisfaction of any claims they may have under the Divorce Code of the Commonwealth of Pennsylvania, including, but not limited to, alimony, alimony pendente lite, counsel fees, equitable distribution, and the like. 18. RELEASE. Each party does hereby waive, relinquish, and release any claim they have against the other for bank accounts, stocks, bonds, and other and similar investment assets Page 9 of 12 which are now owned by or in possession of the other, regardless of whether such assets were owned by the parties jointly or separately prior to the date of this agreement. Each party hereto does hereby waive and release any claim they may have under the laws of the Commonwealth of Pennsylvania for the equitable distribution or the other division of such assets or any claim to them as marital property. 19. CHOICE OF LAW. This Agreement shall be interpreted, applied and enforced in accordance with the laws of, and by the courts of, the Commonwealth of Pennsylvania. °~ - - 20~S~~VERABILITY. If for an 7eason-whatsoever~a~ .~ art of this A Bement shall~be- y ~ y p ~' declared void or invalid, only such part shall be deemed void and in all other respects this Agreement shall remain valid and fully enforceable. 21. NON-WAIVER. The waiver of any term, condition, clause, or provision of this Agreement shall in no way be deemed or considered a waiver of any other term, condition, clause or provision of this Agreement. IN WITNESS WHEREOF, the parties hereto have set their hands and seals the day and year first above written. CL Page 10 of 12 -- - -~-- rtne - COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND ~ SS.: On this, the I( day of , 2009, before me, the undersigne o cer, personally appear own to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that said person executed same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. ~ ~ v. .fir.:~~y~~, h;}4'. h>I'Lr . .. . JOANN MED'NC"Y . ~~ y o sion xpires: wnwov~ eoROU~H, York courm My Commiaalon Expires Ap- a, 2010 COMMONWEALTH OF PENNSYLVAI~TIA ) COUNTY OF CUMBERLAND ~ SS.: On this, the day of 2009, before me, the undersigne o icer, personally appeare own to me (or satisfactorily proven) to be the person whose Warne is subscribed to the within instrument; and acknowledged that said person executed same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. y o ssion xpues: _ COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL AMY M. HARKINS, Notary Public Lemoyne Boro., Cun~beriand Comity F 4, 13 Page 11 of 12 SCHEDULE A 1. 4-piece glass dinner set which belonged to her grandmother (dishes, cups and matching candle sticks) that were in the cupboard above the microwave oven. 2. Her highschool softball videos and her softball glove. 3. Her small wooden desk. 4. Her CD player and stereo. 5. Her green quilt with horses that was made by her grandmother. 6. Her Aunt Vickie's red and black boots. 7. Her Mother's Coming Ware deep casserole dish and baking pan and the rack or holder for each of them. Page 12 of 12 CHANTELLE L. RATCLIFFE, formerly CHANTELLE L. GREENINGER, Plaintiff vs. TIMOTHY P. GREENINGER, Defendant TN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 07-4672 IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for Divorce: Irretrievable breakdown under Section 3301(c). 2. Date and manner of service of the Complaint: August 14, 2007 by certified mail upon Defendant (Certificate of Service filed on August 15, 2007). 3. Complete either Paragraph (a) or (b): (a} Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff: 22 September 2009 by Defendant: 11 September 2009. Code: (b) (1) Date of execution of the Affidavit required by Section 3301(d) of the Divorce (2) Date of filing and service of the Plaintiff's Affidavit upon the Respondent: 4. Related claims pending: None 5. Complete either (a) or (b): (a) Date and manner of service of the Notice of Intention to File Praecipe to Transmit Record, a copy of which is attached: (b) Date Plaintiff s Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: Dated 22 September 2009 and filed 22 September 2009. Date Defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: Dated 11 September 2009 and filed 22 September 2009. Date: ~- ~ c,/ By ,,S uel L. des Attorney for Plaintiff "~'' ~ ~F{'~J Zi~9 E3CT -2 AM 11= 25 PEP,4~SY~V~'~fl~ CHANTELLE L. GREENINGER, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. TIMOTHY P. GREENINGER NO. 07-4672 DIVORCE DECREE AND NOW, DrJ~sb~' S ~ , i ~ ° ~ , it is ordered and decreed that CHANTELLE L. GREENINGER, plaintiff, and TIMOTHY P. GREENINGER defendant, are divorced from the bonds of matrimony. 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, ,.t.~• Y ~ ~~~ `v