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HomeMy WebLinkAbout08-0788STEPHAN KOCH : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 08 - 188 CIVIL TERM SUSAN COCKRELL : CIVIL ACTION - LAW Defendant : IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case will proceed without you and a decree in divorce or annulment may 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 the First Floor, Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL PROPERTY, LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE 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 (717) 249-3166 STEPHAN KOCH : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 08 - 'f88 CIVIL TERM SUSAN COCKRELL : CIVIL ACTION - LAW Defendant : IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Stephan Koch, an adult individual who resides at 203 Acre Drive, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant is Susan Cockrell, an adult individual who resides at 7278 Cahaba Valley Road, Birmingham, Jefferson County, Alabama 35242. 3. The Plaintiff is a bonafide resident of the Commonwealth of Pennsylvania and has been so for at least six months immediately previous to the filing of this complaint. 4. Plaintiff and Defendant were married on April 20, 2000, in Huntington, Cabell County, West Virginia. 5. There have been no prior actions for divorce or annulment between the parties. 6. The Defendant is not a member of the Armed Forces of the United States of America, or its Allies. 7. The Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, the Plaintiff does not desire that the Court require the parties to participate in counseling. 8. The parties have lived separate and apart since April, 2007, and continue to live separate and apart as of the date of this Divorce Complaint. 9. The parties' marriage is irretrievably broken. 10. Plaintiff desires a divorce based upon the belief that Defendant will, after ninety days from the date of the filing of this Complaint, consent to this divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a decree in divorce. to Respectfully Submitted, TURO LAW OFFICES Palen R. W th ire 28 Sou Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff VERIFICATION I verify that the statements made in the foregoing Divorce Complaint are true and correct. I understand that false statements herein made are subject to the penalties of Pa.C.S. §4904 relating to unsworn falsification to authorities. 0/ d 2o6d' Date Oiephan Koch CERTIFICATE OF SERVICE I, Galen R. Waltz, Esquire hereby certify that I served a true and correct copy of the Complaint in Divorce, by certified, return receipt requested, postage pre-paid nd depositing same in the United States Mail, first class, postage pre-paid on the day of J; ?arvp r. 2008, from Carlisle, Pennsylvania, addressed as follows: Susan Cockrell 7278 Cahaba Valley Road Birmingham, AL 35242 TURO LAW OFFICES en R. Waltz, s re 28 South Pitt Str Carlisle, PA 17013 (717) 245-9688; FAX 717.245.2165 Iva ?ll W L w ? 6 77 c7.. K C-= `t r rr ' cx? O TI F. X47 ? y SEPARATION AGREEMENT AND PROPERTY SETTLEMENT This Agreement, made and entered into this ? day of =-, 2008, between Stephan Koch of 203 Acre Drive, Carlisle, Cumberland County, Pennsylvania herein referred to as "Husband," and Susan R. Cockrell Kocb of 7278 Cahaba Valley Road, Apartment 1106, Birmingham, Jefferson County, Alabama hereinafter referred to as "Wife." WHEREAS, the parties hereto are now Husband and Wife, having been lawfully married to each other on April 20, 2000, in Huntington, Cabell County, West Virginia; WHEREAS, there have been no children born of this marriage. WHEREAS, the parties hereto are now living separate and apart and desire to enter into an Agreement respecting their property rights regardless of the actual separation or other character thereof and their other rights, including the Wife's right to support and maintenance; WHEREAS, both and each of the parties hereto have been advised of their legal rights and the implications of this Agreement and the legal consequences that may and will ensue from the execution hereof, and each has had the opportunity to consult with his or her own competent legal counsel independent of each other; Galen R. Waltz, Esq. represents Husband; Wife has elected not to reveal her attorney if she has one; WHEREAS, each party warrants, as part of the consideration of this Agreement, that each has fully and completely disclosed all information of a financial nature requested by the other, and that no information of such nature has been subject to distortion or in any manner being misrepresented; and WHEREAS, other than as set forth herein, Wife desires finally and forever to relinquish all of her rights to be supported by Husband and all of her rights of dower, rights as heir or surviving spouse or otherwise, actual, currently existing, or inchoate, in and to the real and personal property of the Husband, now owned by him or which in the future may be owned by him, and all rights to counsel fees, or expenses and, other than as set forth herein, Husband likewise wishes to relinquish all his rights of curtsey, rights as heir or surviving spouse or otherwise, actual and currently existing or inchoate in and to the real and personal estate of the Wife, currently owned by her or which she may own in the future; NOW THEREFORE, the parties hereto intending to be legally bound do hereby mutually agree as follows: 1. Separation. Husband and Wife do hereby mutually agree and consent to live separate and apart and do further agree that it shall be lawful for the Husband and Wife at all times hereafter to live separate and apart from each other, and to reside, from time to time, at such place or places as they respectfully shall deem fit, free from any control or restraint or interference, direct or indirect, by each other. 2. No Molestation, Harassment or Interference. Neither party shall molest, harass or interfere with the other or compel or endeavor to compel the other to cohabit or dwell with him or her by any means whatsoever. 3. Mutual Power and Estate Waiver. Except as otherwise expressly set forth herein, in which event such express provision shall take precedence over this paragraph, the parties hereto intend that from and after the date of this Agreement, neither shall have any spouse's rights in property or estate of the other, and to that end both parties waive, relinquish and forbear the rights of dower of curtsey, rights to inherit, rights to claim or take the Husband or Wife's or family exemption or allowance, to be vested with letters of administration or letters testamentary, or to take against any will of the other, and each agrees with the other if either should die intestate, his or her share shall descend to vest in his or her heirs at law, personal representatives, and next of kin, excluding the other as though he or she had died a widow or widower. And each further agrees that should the other die testate, his or her property shall descend to and vest in those persons set forth in the other's Last Will and Testament as though the spouse so designated as beneficiary had predeceased the testator. The parties further agree that they may and can hereafter, as though married, without any joinder by him or her, sell, convey, transfer or encumber any and all real estate and personal property which either of them now or hereafter own or possess and further agree that the recording of this Agreement shall be conclusive evidence to all of his or her right to do so. The said Husband and Wife do hereby irrevocably grant, each to the other, should the exercise of this power hereby given be necessary, the right and the power to appoint one or more times any person or persons whom the Husband or Wife shall designate to be the attorney-in-fact for the other, in their 2 name and in their stead, to execute and acknowledge any deed or deeds, releases, quit claims, or satisfactions, under seal or otherwise, to enable either party hereto to alienate his or her real personal property, but without any power to impose personal liability for breach of warranty or otherwise. Each of the parties hereto further waives any right of election contained in Chapter 22 of the Pennsylvania Probate Estates and Fiduciaries Code, and any right to seek or have an equitable distribution or married property ordered by the Court subsequent to Section 3502 of the Divorce Code. Each of the parties hereto further agrees that neither shall :iereafter be under any legal obligations to support the other, pay any expenses for maintenance, funeral, burial, or otherwise for the other, and to that end each of the parties hereto does hereby waive any right to receive support, alimony, alimony pendente lite, counsel fees, expenses, or any type of financial assistance whatsoever from the other, except as otherwise expressly provided for herein. 4. Support. Husband and Wife mutually agree to waive and relinquish their right, claim and interest in spousal support. 5. Distribution of Marital Assets. a. The parties agree that the items of personal property are to be divided in accord with the attached Exhibit A; otherwise all property has been previously divided to the satisfaction of both Husband and Wife. All other personal property obtained by the parties during the marriage shall be the sole and exclusive property of the Husband/Wife. Henceforth, each of the parties shall own, have and enjoy, independently of any claim of right of the other party, all items of personal property of every kind, nature and description and wheresoever situated which are now owned or held by or which may hereinafter belong to the Husband or Wife respectively, with full power to the Husband or Wife to dispose of the same as fully and effectually in all respects and for all purposes as if he or she were unmarried. b. Personal effects. All items of personal effects such as but not limited to jewelry, luggage, sports equipment, hobby collections and books but not including furniture or any other property, personal or otherwise specifically disposed of pursuant to this Agreement shall become the absolute and sole property of the party who has had the principal use thereof or to whom the property was given or 3 from whom it was purchased, and each party hereby surrenders any interest he or she may have in such tangible personal property of the other. 6. Debt. The parties amassed debt as described in the attached Exhibit B. Wife agrees to be completely responsible for the debt listed on Exhibit B described as Liabilities Assumed By Susan Roberta Cockrell Koch and Husband agrees to be responsible for the debts listed at Exhibit B titled Liabilities Assumed By Stephan Koch. The marital residence shall be sold and the mortgage thereto paid and the equity divided according to the formula described below in the paragraph titled Real Estate. 7. Future Debts. The parties further agree that neither will incur any more future debts for which the other may be held liable, and if either party incurs a debt for which the other will be liable, that party incurring such debt will hold the other harmless from any and all liability thereof; however, future discovery of debt incurred during the marriage shall be borne equally and evenly between Husband and Wife. 8. Real Property. The parties agree that the real property located at 203 Acre Drive, Carlisle, Cumberland County, Pennsylvania shall be sold and the proceeds divided as follows: a) Mortgage held by Wells Fargo, Account No. 0145143988 with a payoff amount of $181,587.77, b) Remaining proceeds shall first pay the remaining real estate expenses related to the sale and maintenance of the house followed by the division of the equity in the following manner: $11,000.00 paid to Wife for reimbursement to her for the $7,000.00 down payment borrowed from Nathaniel's life insurance and $4,000.00 borrowed from Susan's father's estate to pay Husband's credit cards; the remainder of the equity shall be divided equally and evenly between Husband and Wife. Any interest and taxes determined to be due for the marital residence shall be paid 75% by Husband and 25% by Wife. In the event of a "shortfall" upon the sale of the marital residence, the parties shall be equally liable 50150 thereto. All tax and insurance refunds from the sale of the marital residence shall be divided equally between Husband and Wife. Each party shall claim their equity received as capital gain on their 2008 taxes. The parties shall execute all documents concerning the sale of the marital residence in a prompt fashion. Both parties agree to execute any and all future documents reasonably related to the transfer of interest and title of the marital home from Husband and Wife to purchasers. 4 9. Additional Documentation. The parties agree to execute any deeds, assignments, titles or other instruments necessary and appropriate to accomplish the aforesaid and following division of property. 10. Indemnification. Each party represents and warrants to the other that he or she has not incurred any debt, obligation, or other liability, other than described in this agreement, on which the other parry is or may be liable. Each party covenants and agrees that if any claim, action or proceeding is her6aafter initiated seeking to hold the other party liable for any other debts, obligations, liability, act or omission of such party will at his or her sole expense, defend the other against any such claim or demand, whether or not well- founded, and that he or she will indemnify and hold harmless the other party in respect of all damages as resulting therefrom. Damages as used herein shall include any claim, action, demand, loss, cost, expense, penalty, and other damage, including without limitation, counsel fee and other costs and expenses reasonably incurred in investigating or attempting to avoid same or in opposing the imposition thereof or enforcing this indemnity, resulting to Husband or Wife from any inaccurate representation made by or on behalf of either Husband or Wife to the other in this Agreement, any breach of any of the warranties made by Husband or Wife in this Agreement, or breach or default in performance by Husband or Wife of any of the obligations to be performed by such party hereunder. The Husband or Wife agrees to give the other prompt written notice of any litigation threatened or instituted against either party which might constitute the basis for a claim for indemnity pursuant to the terms of this Agreement. 11. Waiver of Alimony. In exchange for and in consideration of the promises and representations made hereunder, Husband and Wife hereby waive and release any and all right, title, interest, claims or demand of whatsoever nature which he or she now has or hereafter can, shall or may have against the other or the respective separate property of the other under the laws of the Commonwealth of Pennsylvania or any other governing state, country, territory or jurisdiction in nature of spousal support, separate maintenance or support, alimony, either pendente lite, temporary, rehabilitative, permanent or lump sum and right to seek equitable or community distribution or division or assignment of property or similar marital rights. 12. Pension. Husband waives all right and interest to Wife's pension, IRA, 401k or any other retirement program and Wife shall waive all claims to Husband's pension, IRA, 401 K and all other retirement programs in consideration thereto. 13. Counsel Fees and Court Costs. Each party agrees to pay their own attorney fees and cost incurred in the preparation of this document, as well as the preparation and filing of the divorce action captioned at 2008-788 Civil Term. If either party incurs any other legal fees or court costs, those costs will be borne by the party exclusively. 14. Divorce. The parties acknowledge that an action for divorce between them has been filed by Husband and is presently pending a divorce between them in the Court of Common Pleas of Cumberland County to the caption Stephan Koch, Plaintiff v. Susan Cockrell, Defendant, 2008- 788 Civil Term. The parties acknowledge their intention and agreement to proceed in said action to obtain a final decree in divorce by mutual consent on the grounds that their marriage is irretrievably broken, and to settle amicably and fully hereby all claims raised by either party in the divorce action. The parties acknowledge they have executed simultaneously herewith the necessary Affidavits of Consent for the entry of a final divorce decree in that action. The parties agree that Wife may change her name from Susan R. Cockrell Koch to Wife's pre-marital name of Susan R. Cockrell. 15. Breach. It is expressly stipulated that if either party fails in the due performance of any of his or her material obligations under this Agreement, the other party shall have the right, at his or her election, to sue for damages for breach thereof, to sue for specific performance, or to seek any other legal remedies as may be available, and the defaulting party shall pay the reasotiablr legal fees, costs and expenses for any services rendered by the non-defaulting party's attorney in any action or proceeding to compel performance hereunder. 16. Enforcement. The parties agree that this marital settlement agreement or any part or parts hereof may be enforced in any Court of competent jurisdiction. 17. Applicable Law and Execution. The parties hereto agree that this Marital Settlement Agreement shall be construed under the laws of the Commonwealth of Pennsylvania and shall bind the parties hereto and their respective heirs, executors and assigns. This document shall be executed as original and multiple copies. 18. The Entire Agreement. The parties acknowledge and agree that this Marital 6 f Settlement Agreement contains the entire understanding of the parties and supersedes any prior agreement between them. There are not other representatives, warranties, promises, covenants or understandings between the parties other than those expressly set forth herein. 19. Additional Instruments. Each of the parties shall on demand or within a reasonable period thereafter, execute and deliver any and all other documents and do or cause to be done any other act or things that may be necessary or desirable to effectuate the provisions and purposes cf this .\greement. If either party fails on demand to comply with this provision, that party shall pay to the other all attorney's fees, costs, and other expenses reasonably incurred as a result of such failure. 20. Agreement Not to be Merged. This Agreement may be filed with the Court for incorporation into the Decree of Divorce for purposes of enforcement only, but otherwise shall not be merged into said Decree. The parties shall have the right to enforce this Agreement under the Divorce Code of 1980, as amended, an in addition, shall retain any remedies in law or equity under this Agreement as an independent contract. Such remedies in law or equity are specifically not waived or released. IN WITNESS WHEREOF, the parties have set their hands and seals the day and year first written above. WITNESSES: Am d re w Pe iS VJ4., 4t'? Aa'u ,-A ez-lz?- N&rs ons tephan Koch/ d Susan R. Cockrell Koch 7 C:P ?n vr- ? F, n J STEPHAN KOCH : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 08 - 788 CIVIL TERM SUSAN COCKRELL : CIVIL ACTION - LAW Defendant : 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 § (3301(c)) of the Divorce Code. 2. Date and manner of service of the complaint: Certified, Returned Receipt mail delivered on or about February 11, 2008. 3. Date of execution of the Affidavit of Consent required by §3301(c) of the Divorce Code. By Plaintiff: April 17, 2007 By Defendant: May 13, 2008 4. Related claims pending: None. Date the Waiver of Notice in §3301(c) divorce was filed with the Prothonotary: MAY 14 4r By Plaintiff: ApFif , 2009 By Defendant: May 1X 2008 MLLVIIICY IVI LJIUIV C a ? - rj t Z 7 -•c Q STEPHAN KOCH Plaintiff V. SUSAN COCKRELL Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08 - 788CIVIL TERM : CIVIL ACTION - LAW : IN DIVORCE ¦ Complete items 1, 2, and 3. Also complete Nam 4 If Restricted Deliveryis-dasired. • 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. Article Addressed to: IC) ?'rfYl?;(??,' CJ?i 1 , ?- 3?42 A ? Agent ? AddrnM B. ived by (Printed Narne) C. Date of DWlvwy D. Is delivery address r item 1? ? Yes If YES, enter delivatf dd?? ; ? No ? / uin1 3. rvice Type ACertimed Mail aspress ? Registered ? i&um Receipt for Merchandise ? Insured Mail ? C.O.D. 4. Restricted Delivery? p" Fee) ? yes 2. Article Number Mwmrwfrom service &W 7006 0100 0007 1051 8392 PS Form 3811, February 2004 Donw"c Rehrm Reoelpt 1025W o C rntTt ' 17- ( /// VVVPPYI -f t STEPHAN KOCH : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 08 - 788 CIVIL TERM SUSAN COCKRELL : CIVIL ACTION - LAW Defendant : IN DIVORCE A FIDAI o?' OF CONSENT 1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on February 4, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing of the Complaint. 3. 1 consent to the entry of the final Decree in Divorce after service of Notice of Intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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. 7 Z Coe Date %ephan Koc erg .- - ? un -D w STEPHAN KOCH : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 08 - 788 CIVIL TERM SUSAN COCKRELL : CIVIL ACTION - LAW Defendant : IN DIVORCE WAIVER OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 3301(c) OF THE DIVORCE CODE 1. 1 consent to the entry of a final Decree of Divorce without notice. 2. 1 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. 1 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 THE FOREGOING 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. Lt- (7 T Date tephan Koch r1a F .o m VAd `? STEPHAN KOCH : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 08 - 788 CIVIL TERM SUSAN COCKRELL : CIVIL ACTION - LAW Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on February 4, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing of the Complaint. 3. 1 consent to the entry of the final Decree in Divorce after service of Notice of Intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN I ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. §4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. /.3 ?00V ko Date Susan Cockrell-Koch cry goo>l-llaamooO uesns r aled Ope P "'? 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Stephan Koch Plaintiff No. 08-788 VERSUS Susan Cockrell Defendant DECREE IN DIVORCE AND NOW, , `0'V ZI ,2008 , IT IS ORDERED AND DECREED THAT Stephan Koch , PLAINTIFF, AND Susan Cockrell DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; Separation and Property Settlement Agreement is incorporated herein but not merged in the Divorce Decree. Wife's name shall revert to the pre-marital name of Susan R. Cockrell. BY THE COURT: ATTEST: J. PROTHONOTARY ?©? ??,s e aw 1 .?