HomeMy WebLinkAbout04-1152JAMIE K. KUNKLE, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. No. 2004 - 11,Gol, CL' ls?
THOMAS P. KUNKLE, 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 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.
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
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
1-800-990-9108
JAMIE K. KUNKLE,
Plaintiff
VS.
THOMAS P. KUNKLE,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 2004- 1-7 ?
CIVIL ACTION - LAW
IN DIVORCE
COMPLAINT IN DIVORCE UNDER SECTION 3301(c)
OF THE DIVORCE CODE
1. The Plaintiff is Jamie K. Kunkle, an adult individual whose mailing address
is 3005 Hoffman Street, Harrisburg, Dauphin County, Pennsylvania 17110,
and whose social security number is 005-50-1775.
2. The Defendant, Thomas P. Kunkle, is an adult individual, whose current
address is 1812 Silver Pine Circle, Mechanicsburg, Cumberland County,
Pennsylvania 17055, and whose social security number is 182-38-9286.
3. Plaintiff and Defendant were married on March 25, 1972, in Portland,
Maine.
4. Plaintiff and Defendant have resided in the Commonwealth of Pennsylvania
for a period of at least six (6) months prior to this filing.
5. Defendant is not a member of the Armed Services of the United States or its
allies.
6. Plaintiff is a citizen of the United States and Defendant is a citizen of the
United States.
7. There has been no prior action for divorce filed in any jurisdiction,
8. Plaintiff has been advised of the availability of marriage counseling, and has
waived said right.
9. There are three children born of the marriage; however, all are of majority
age.
10. Plaintiff avers that the grounds on which this action is based are:
(a) That the marriage is irretrievably broken.
WHEREFORE, Plaintiff respectfully requests your Honorable Court to grant
a Decree in Divorce.
Respectfully submitted,
,J
BY:
'Diane M. Dils, Esquire
1017 North Front Street
Harrisburg, PA 17102
(717) 232-9724
I.D. No. 71873
Date: March 16, 2004
VERIFICATION
I verify that the statements made in this Complaint in Divorce 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.
lieiuti
/1AMIE K. KLJIt
1
Date; S11610 y
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JAMIE K. KUNKLE,
Plaintiff
vs.
THOMAS P. KUNKLE,
Defendant
TO THE PROTHONOTARY:
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 2004-1152
CIVIL ACTION - LAW
IN DIVORCE
PRAECIPE
Please withdraw the appearance of Diane M. Dils, Esquire, on behalf of the
Plaintiff, Jamie K. Kunkle, and enter the appearance of Ann V. Levin, Esquire, on
behalf of the Plaintiff, Jamie K. Kunkle.
Respectfully submitted,
BY:
Ann V. Levin, Esquire
4431 North Front Street
Harrisburg, PA 17110
(717) 234-2401
I.D. No.
Respectfully submitted,
r
BY.
Diane . Dils, Esquire
1400 North Second Street
Harrisburg, PA 17102
(717) 232-9724
I.D. No. 71873
Date:
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SMIGEL, ANDERSON & SACKS, LLP
Ann V. Levin, Esquire ID# 70259
4431 North Front Street, 3`d Fir.
Harrisburg, PA 17110-1778
(717) 234-2401
alevinia)sasllp.com
Attorney for Plaintiff
JAMIE K. KUNKLE,
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 2004-1152 CIVIL TERM
THOMAS P. KUNKLE,
DEFENDANT LAW IN -DIVORCE
PETITION RAISING MARITAL CLAIMS
AND NOW, comes Plaintiff, Jaime K. Kunkle, by and through her counsel, Smigel,
Anderson & Sacks, LLP, and files this Petition Raising Marital Claims and in support thereof states
as follows:
1. Plaintiff is Jamie K. Kunkle, who currently resides at 1812 Silver Pine Circle,
Mechanicsburg, Cumberland County, Pennsylvania, 17050.
2. Defendant is Thomas P. Kunkle, who currently accepts mail at 500 Brandt Avenue,
New Cumberland, Cumberland County, Pennsylvania, 17070.
3. Plaintiff and Defendant were married on March 25, 1972, in Portland, Maine.
4. A Complaint for Divorce was filed by Plaintiff on March 18, 2004, in Cumberland
County, Pennsylvania.
5. Plaintiff hereby raises the following marital claims:
COUNTI
EQUITABLE DISTRIBUTION
6. Plaintiff repeats and realleges the averments of paragraphs 1 through 5 which are
incorporated by reference herein.
7. Plaintiff and Defendant possess various items of both real and personal marital property
which is subject to equitable distribution by this Court.
WHEREFORE, Plaintiff respectfully requests that this Honorable Court equitably distribute
the marital property after an inventory and appraisement has been filed by the parties.
COUNT II
ALIMONY UNDER SECTION 3701 OF THE DIVORCE CODE
8. Plaintiff repeats and realleges the averments of paragraphs 1 through 7 which are
incorporated by reference herein.
9. Plaintiff requires support to adequately maintain herself in accordance with the standard
of living established during the marriage.
WHEREFORE, Plaintiff respectfully requests that this Honorable Court award her
reasonable alimony pursuant to Section 3701 of the Divorce Code.
COUNT III
ALIMONY PENDENTE LITE, COUNSEL FEES, COSTS AND
EXPENSES UNDER SECTION 3702
10. Plaintiff repeats and realleges the averments of paragraphs 1 through 9 which are
incorporated by reference herein.
11. Plaintiff has no adequate means of support for herself during the course of this litigation.
12. Plaintiff does not have sufficient funds to pay counsel fees, costs or expenses incidental
to this action.
13. Plaintiff has no health insurance other than that presently available to her through
Defendant's employment.
WHEREFORE, Plaintiff respectfully requests that this Honorable Court award her alimony
pendente lite, counsel fees, costs and expenses.
Date:
Respectfully submitted,
SMIGEL, ANDERSON & SACKS, LLP
By:_,
Ann V. Levin, Esquire ID #70259
4431 North Front Street
Harrisburg, PA 17110
(717) 234-2401
Attorney for Plaintiff
VERIFICATION
I, Jamie K. Kunkle, verify that the statements contained in the foregoing pleading are true and
correct to the best of my knowledge, information and belief. I understand that false statements therein
are made subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities.
Date: U 7 /C..
,L-2 a
mie K. Kunkle, Plaintiff
SMIGEL, ANDERSON & SACKS, LLP
Ann V- Levin, Esquire ID# 70259
4431 North Front Street, 3rd Flr.
Harrisburg, PA 17110-1778
(717) 234-2401
alcvin a)sasllp.com
Attorney for Plaintiff
JAMIE K. KUNKLE,
PLAINTIFF
V.
THOMAS P. KUNKLE,
DEFENDANT
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2004-1152 CIVIL TERM
LAW IN -DIVORCE
CERTIFICATE OF SERVICE
I, Ann V. Levin, Esquire, counsel for Plaintiff in the above-captioned matter, do hereby
certify that I served a true and correct copy of the foregoing Petition Raising Marital Claims on
Defendant by placing same in the U.S. Mail, first class, postage paid on the -2 day of July, 2007,
addressed as follows:
Dr. Thomas P. Kunkle
500 Brandt Avenue
New Cumberland, PA 17070
SMIGEL, NDERSON & SACKS, LLP
By:
Ann . Levin, Esquire I.D.#: 70259
4431 North Front Street
Harrisburg, PA 17110
(717) 234-2401
Attorney for Plaintiff
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JAMIE K. KUNKLE,
PLAINTIFF
V.
THOMAS P. KUNKLE,
DEFENDANT
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2004-1152
: CIVIL ACTION - LAW IN DIVORCE
CERTIFICATE OF SERVICE
I, Ann V. Levin, Esquire, counsel for Plaintiff in the above-captioned matter, do hereby
certify that I served a true and correct copy of the foregoing Plaintiff's Interrogatories to Defendant-
First Set on Defendant by placing same in the U.S. Mail, first class, postage paid on the 23 day of
July, 2007, addressed as follows:
THOMAS P. KUNKLE
500 BRANDT AVENUE
NEW CUMBERLAND, PA 17070
SMIGEL ANDERSON SACKS, LLP
By: U
Ann V. Levin, Esquire I.D.4: 70259
4431 North Front Street
Harrisburg, PA 17110
(717) 234-2401
Attorney for Plaintiff
17
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To the Court:
JAMIE K. KUIVKLE
Case No. 2004 - 1152 CIVIL
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Statement of Intention to Proceed ~ ~ o
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intends to proceed with the above captt>~ mater.
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Print Name Ann V. Levin, Esquire Sign Name
44 1 N. Front t. -
Harrisbuurrqg, PA 17110
Date: ~~ oZ,s ~~C~ Attorney for Plaintitt
Explanatory Comment
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The Supreme Court of Pennsylvania has promulgated new Rule of Civil Procedure 230.2 governing the termination of
inactive cases and amended Rule of Judicial Administration 1901. Two aspects of the recommendation merit
comment.
I. Rule of civil Procedure
New Rule of Civil Procedure 230.2 has been promulgated to govern the termination of inactive cases within the
scope of the Pennsylvania Rules of Civil Procedure. The termination of these cases for inactivity was previously
governed by Rule of Judicial Administration 1901 and local nines promulgated pursuant to it. New Rule 230.2 is
tailored to the needs of civil actions. It provides a complete procedure and a uniform statewide practice, preempting
local rules.
This rule was promulgated in response to the decision of the Supreme Court in Shop v. Eagle, 551 Pa. 360,710 A.2d
1104 (1998) in which the court held that "prejudice to the defendant as a result of delay in prosecution is required
before a case maybe dismissed pursuant to local rules implementing Rule of Judicial Administration 1901."
Rule of Judicial Administration 1901(b) has been amended to accommodate the new rule of civil procedure. The
general policy of the prompt disposition of matters set forth in subdivision (a) of that rule continues to be applicable.
II Inactive Cases
The purpose of Rule 230.2 is to eliminate inactive cases from the judicial system. The process is initiated by the
court. After giving notice of intent to terminate an action for inactivity, the course of the procedure is with the parties.
If the parties do not wish to pursue the case, they will take no action and "the Prothonotary shall enter an order as of
course terminating the matter with prejudice for failure to prosecute." if a party wishes to pursue the matter, he or she
will file a notice of intention to proceed and the action shall continue.
a. Where the action has been terminated
If the action is terminated when a party believes that it should not have been terminated, that party may proceed
under Ru1e230(d) for relief from the order of temunation. An example of such an occurrence might be the termination
of a viable action when the aggrieved party did not receive the notice of intent to terminate and thus did not timely file
the notice of intention to proceed.
The timing of the filing of the petition to reinstate the action is important. If the petition is filed within thirty days of
the entry of the order of termination on the docket, subdivision (d)(2) provides that the court must grant the petition and
reinstate the action. If the petition is filed later than the thirty-day period, subdivision (d)(3) requires that the plaintiff
must make a showing to the court that the petition was promptly filed and that there is a reasonable explanation or
legitimate excuse both for the failure to file the notice of intention to proceed prior to the entry of the order of
termination on the docket and for the failure to file the petition within the thirty-day period under subdivision (d)(2).
B. Where the action has not been terminated
An action which has not been terminated but which continues upon the filing of a notice of intention to proceed may
have been the subject of inordinate delay. In such an instance, the aggrieved party may pursue the remedy of a
common law non pros which exits independently of termination under Rule 230.2.
JAMIE K. KUNKLE
vs Case No. 2004-1152 Civil
THOMAS P. KUNKLE
Statement of Intention to Proceed
the Court: , r
Jamie K. Kunkle intends to pr ceed with the above aptionetter.=
Print Name Ann V. Levin, Esquire Sign Name
P.O.Box 1166,Harrisburg,PA 17108
Date: /D/'$/l3 Attorney for Plaintiff
Explanatory Comment
The Supreme Court of Pennsylvania has promulgated new Rule of Civil Procedure 230.2 governing the termination of
inactive cases and amended Rule of Judicial Administration 1901. Two aspects of the recommendation merit
comment.
I.Rule of civil Procedure
New Rule of Civil Procedure 230.2 has been promulgated to govern the termination of inactive cases within the
scope of the Pennsylvania Rules of Civil Procedure. The termination of these cases for inactivity was previously
governed by Rule of Judicial Administration 1901 and local rules promulgated pursuant to it. New Rule 230.2 is
tailored to the needs of civil actions. It provides a complete procedure and a uniform statewide practice, preempting
local rules.
This rule was promulgated in response to the decision of the Supreme Court in Shop v.Eagle, 551 Pa.360,710 A.2d
1104 (1998) in which the court held that"prejudice to the defendant as a result of delay in prosecution is required
before a case may be dismissed pursuant to local rules implementing Rule of Judicial Administration 1901."
Rule of Judicial Administration 1901(b) has been amended to accommodate the new rule of civil procedure. The
general policy of the prompt disposition of matters set forth in subdivision(a)of that rule continues to be applicable.
II Inactive Cases
The purpose of Rule 230.2 is to eliminate inactive cases from the judicial system. The process is initiated by the
court. After giving notice of intent to terminate an action for inactivity,the course of the procedure is with the parties.
If the parties do not wish to pursue the case,they will take no action and"the Prothonotary shall enter an order as of
course terminating the matter with prejudice for failure to prosecute." If a party wishes to pursue the matter,he or she
will file a notice of intention to proceed and the action shall continue.
a. Where the action has been terminated
If the action is terminated when a party believes that it should not have been terminated, that party may proceed
under Ru1e230(d)for relief from the order of termination, An example of such an occurrence might be the termination
of a viable action when the aggrieved party did not receive the notice of intent to terminate and thus did not timely file
the notice of intention to proceed.
The timing of the filing of the petition to reinstate the action is important. If the petition is filed within thirty days of
the entry of the order of termination on the docket,subdivision(d)(2)provides that the court must grant the petition and
reinstate the action. If the petition is filed later than the thirty-day period, subdivision(d)(3)requires that the plaintiff
must make a showing to the court that the petition was promptly filed and that there is a reasonable explanation or
legitimate excuse both for the failure to file the notice of intention to proceed prior to the entry of the order of
termination on the docket and for the failure to file the petition within the thirty-day period under subdivision(d)(2).
B. Where the action has not been terminated
An action which has not been terminated but which continues upon the filing of a notice of intention to proceed may
have been the subject of inordinate delay. In such an instance, the aggrieved party may pursue the remedy of a
common law non pros which exits independently of termination under Rule 230.2.
HIE t }T Lr
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` LI NBERL A
in WALLACE NURICK LLC PENi'�SY COUNT)/
By: Ann V Lev n Esquire LVq
Attorney I.D. No. 70259
100 Pine Street
P.O. Box 1166
Harrisburg, PA 17108-1166
(717) 237-5297
(717) 260-1667(fax)
Email: alevin @mwn.com
Attorneys for Plaintiff
JAMIE K. KUNKLE, : IN THE COURT OF COMMON PLEAS
PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA
v. : DOCKET NO. 2004-1152
THOMAS P. KUNKLE, •
DEFENDANT : CIVIL ACTION — DIVORCE
PRAECIPE TO CORRECT ADDRESS
TO THE PROTHONOTARY:
Please change the address on file for counsel of record to 100 Pine Street, P.O. Box
1166, Harrisburg, PA 17108-1166 to be reflected on any and all future correspondence,
notices or orders.
McNEES WALLACE & NURICK LLC
By V
A 1
nn V. Levin, Esquire
Attorney ID No. 70259
Attorneys for Plaintiff
Dated:
CERTIFICATE OF SERVICE
The undersigned hereby certifies that on this date a true and correct copy of the
foregoing Praecipe to Correct Address was served via email and first-class mail upon the
following:
Barbara Sumple-Sullivan, Esquire
518 Bridge Street
New Cumberland, PA 17070
V
Ann . Levin, Esquire
Dated:
/ — c.2. —/y--
McNEES WALLACE & NURICK LLC
By: Ann V. Levin
Attorney ID No. 70259
100 Pine Street
Harrisburg, PA 17108-1166
(717) 237 -5403
(717) 260 -1782 facsimile
alevinc mwn.com
Attorneys for Plaintiff
JAMIE K. KUNKLE,
Plaintiff
v. : NO. 2004 -1152
THOMAS P. KUNKLE, : IN DIVORCE
Defendant
PRAECIPE TO WITHDRAW ECONOMIC CLAIMS
TO THE PROTHONOTARY:
Please withdraw the economic claims pending in this matter.
McNEES WALLACE & NURICK LLC
_1 i-
20111 f;R 2 I Pf -i 1: 28
"FN SYEVAN A'''iY
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
By c124-
Ann V. Levin
Attorney ID No. 70259
Dated: .3/4/ y
CERTIFICATE OF SERVICE
The undersigned hereby certifies that on this date a copy of the foregoing document
was served by first class mail, postage prepaid, upon the following:
Barbara Sumple- Sullivan
549 Bridge Street
New Cumberland, PA 17070
gi/71_A
Kim an, Leg (Secretary
Dated: 3 024 f /y
F 1 L
ra
P R .f T I';I' O W TA I'
2014 APR —2 PM 1: 314
CUtIBERLANU COUNTY
PENNSYLVANIA.
JAMIE K. KUNKLE, : IN THE COURT OF COMMON PLEAS
PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA
v. : DOCKET NO. 2004 -1152
THOMAS P. KUNKLE,
DEFENDANT : CIVIL ACTION — DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
March 18, 2004.
2. The marriage of the plaintiff and defendant is irretrievably broken. Ninety days
have elapsed since the date of service of the Complaint.
3. I consent to the entry of a final decree of divorce after service of notice of
intention to request entry of the decree.
I verify that the statements made in this affidavit are true and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities.
Date: 3 — /3_ j I
A931505:1)
0-eFFILL
! At
I! Pf TFCND`A!'ti i
2014 APR -2 PM F: 34
CUMBERLAND C'OU'NTY
PENNSYLVANIA
JAMIE K. KUNKLE, : IN THE COURT OF COMMON PLEAS
PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA
v. : DOCKET NO. 2004 -1152
THOMAS P. KUNKLE,
DEFENDANT : CIVIL ACTION — DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF
A DIVORCE DECREE UNDER Section 3301(c) OF THE DIVORCE CODE
1. I consent to the entry of a final decree 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.
Date:
{A931507:1 }
Barbara Sumple- Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, PA 17070
(717) 774-1445
JAIME K. KUNKLE,
Plaintiff
v.
THOMAS P. KUNKLE,
Defendant
1.
: IN THE COURT
: CUMBERLAND
: NO: 2004 -1152
ri Dil "40Tiiii
2614 APR -2 PM 1; 3 L
CUMBERLAND COUNTY
OF COMMON PLEAS? E UN S Y LVA N I A
COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: IN DIVORCE
AFFIDAVIT OF CONSENT
A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
March 18, 2004.
2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety
days have elapsed from the 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 are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to
unsworn falsification to authorities.
DATE: 111 ///
THOMAS P. KUNKLE
Barbara Sumple - Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, PA 17070
(717) 774 -1445
JAIME K. KUNKLE,
Plaintiff
N14 Pril -2 l 1: 34
ntinERLAND COUNTY
PENNSYLVANIA
NIA
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v. : NO: 2004 -1152
•
THOMAS P. KUNKLE, : CIVIL ACTION - LAW
Defendant : IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
§3301(c) OF THE DIVORCE CODE
1. I consent to the entry of a final decree of divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by the
Court and that a copy of the decree will be sent to me immediately after it is filed with the
Prothonotary.
I verify that the statements made in this affidavit are true and correct. I understand that
false statement herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn
falsification to authorities.
DATE: O144,14/�
THOMAS P. KUNKLE
o 11,
MARITAL SETTLEMENT AGREEMENT
THIS AGREEMENT, made this 6th day of January, 2014, by and between Thomas P.
Kunkle, hereinafter referred to as "HUSBAND", and Jaime K. Kunkle, hereinafter referred to
.7)
as "WIFE".
Ztj
VT/
WITNESSETH, That:
r- I
(j) ro c;
WHEREAS, the parties hereto are husband and wife, having been lawfully joined in -9
marriage on March 25, 1972 in Portland, Maine and separated on March 18, 2004; ---
.---
WHEREAS, all children born of the marriage are emancipated;
WHEREAS, it is the intention of the parties to settle fully and finally their respective
financial and property rights and obligations as between each other arising out of the marriage
relationship or otherwise, including without limitation (1) the settling of all matters between
them relating to the ownership of real and personal property; (2) the settling of all matters
between them relating to the past, present and future support and/or maintenance of HUSBAND
and WIFE; and (3) the settling of all matters between them relating to any and all rights, titles
and interests, claims and possible claims in or against the estate of the other.
NOW THEREFORE, with the foregoing recitals being hereinafter incorporated by
reference and deemed an essential part hereof in consideration of the foregoing recitals, the
mutual promises, covenants and undertakings herein set forth, and for good and valuable
consideration, receipt of which is hereby acknowledged by each of the parties hereto,
HUSBAND and WIFE, each intending to be legally bound hereby, covenant and agree as
follows:
SECTION I
GENERAL PROVISIONS
I. ADVICE OF COUNSEL
HUSBAND and WIFE declare that they have each had a full and fair opportunity to
obtain independent legal advice of counsel of their selection; HUSBAND has been
independently represented by Barbara Sump le-Sullivan, Esquire. WIPE has been independently
represented by Ann V. Levin, Esquire. Each party further declares that they are executing this
Agreement freely and voluntarily, having obtained such knowledge and disclosure of their legal
rights and obligations. Each party acknowledges that this Agreement is fair and equitable and is
not the result of any fraud, coercion, duress, undue influence or collusion.
Both parties further acknowledge and agree that each has fully disclosed their respective
financial situations to the other, including their assets, liabilities and income. Each of the parties
acknowledge and agree that, after having received such information and with such knowledge,
this Agreement is fair, reasonable and equitable and that it is being entered into freely,
voluntarily and in good faith and that the execution of this Agreement is not the result of any
duress, undue influence, coercion, collusion and/or improper or illegal Agreement.
2. PERSONAL RIGHTS
HUSBAND and WIFE may and shall, at all times hereafter, live separate and apart. Each
shall be free from all control, restraint, interference or authority, direct or indirect, by the other in
all respects as if she or he were unmarried, except as may be necessary to carry out the
provisions of this Agreement. Each may reside at such place or places as she or he may select.
Each may, for his or her separate use or benefit, conduct, carry on and engage in any business,
occupation, profession or employment which to him or her may seem advisable. This provision
2
shall not be taken, however, to be an admission on the part of either HUSBAND or WIFE of the
lawfulness of the causes which led to, or resulted in, the continuation of their living apart.
HUSBAND and WIFE shall not molest; harass, or malign the other or the respective families of
each other, nor compel the other to cohabit or dwell in any manner with him or her, nor in any
way interfere with the peaceful existence, separate from each other.
3. FINANCIAL DISCLOSURE
The parties have fully disclosed to each other the extent of each other's income, assets,
liabilities, holdings and estate. Each party warrants that the information provided has fully and
accurately described the extent of his or her holdings. Each of the parties acknowledge that he or
she is aware of his or her right to seek discovery including, but not limited to, written
interrogatories, motions for document production, depositions, and other means of discovery
available through the Pennsylvania Rules of Civil Procedure. The parties acknowledge that they
have had the right to have property fully appraised. Each party is fully satisfied that no
additional information is necessary for the execution of this Agreement.
4. MUTUAL CONSENT DIVORCE
The parties intend to secure a mutual consent, no fault divorce pursuant to the provisions
of Section 3301(c) of the Divorce Code of 1980, as amended and will execute the consents and
waivers necessary to effectuate the entry of a divorce decree. The documents shall be held in
escrow and filed on or about April 1, 2014 with a praecipe prepared by counsel for HUSBAND
to effectuate the entry of the divorce decree.
5. SUBSEQUENT DIVORCE
A decree in divorce, entered by the Court of Cumberland County, shall not suspend,
supersede or affect the terms of this Agreement. This Agreement, and the terms and conditions
3
contained herein, as well as the enforcement of said terms and conditions, shall not be contingent
upon the granting of a Divorce Decree to either party by the Court of Common Pleas of
Cumberland County, Pennsylvania, or any other Court of competent jurisdiction. This
Agreement shall remain in full force and effect even if the parties reconcile, cohabit as
HUSBAND and WIFE, or attempt reconciliation. This Agreement shall continue in full force
and effect and there shall not be a modification or waiver of any of the terms hereof unless the
parties, in a writing signed by both parties, execute a statement declaring this Agreement or any
term of this Agreement to be null and void. Both parties hereto agree that this Agreement shall
be incorporated by reference but shall not be deemed merged into any judgment or decree for
divorce obtained by either party.
6. OTHER DOCUMENTATION
HUSBAND and WIFE covenant and agree that upon request of the other party, they will
forthwith execute and deliver to the other party, any and all written instruments, assignments,
releases, satisfactions, deeds, notes or such other writings as may be necessary or desirable for
the proper effectuation of this Agreement.
7. MUTUAL RELEASES
Except as otherwise expressly provided by this Agreement,
A. Each party hereby absolutely and unconditionally releases and forever discharges
the other and the estate of the other for all purposes from any and all rights and obligations which
either may have or at any time hereafter have for past, present or future support or maintenance,
alimony pendente lite, alimony, equitable distribution, counsel fees, costs, expenses and any
other right or obligation, economic or otherwise, whether arising out of the marital relationship
or otherwise, including all rights and benefits under the Pennsylvania Divorce Code of 1980, its
4
supplements and amendments, as well as under any other law of any other jurisdiction, except
and only except all rights, agreements and obligations of whatsoever nature arising or which may
arise under this Agreement or for the breach of any provision thereof. Neither party shall have
any obligation to the other not expressly set forth herein.
B. Each party hereby absolutely and unconditionally releases and forever discharges
the other and his or her heirs, executors, administrators, assigns, property and estate from any
and all rights, claims, demands or obligations arising out of or by virtue of the marital
relationship of the parties or otherwise, whether now existing or hereafter arising. The above
release shall be effective regardless of whether such claims arise out of any former acts,
contracts, engagements or liabilities of the other or by way of dower, curtesy, widow's rights,
family exemption or similar allowance, or under the intestate laws, or the right to take against the
spouse's will, or the right to treat a lifetime conveyance by the other as testamentary, or all other
rights of a surviving spouse to participate in a deceased spouse's estate, whether arising under the
laws of Pennsylvania, any state, commonwealth or territory or the United States, or any other
country. It is expressly understood, however, that neither the provisions of this release nor the
subsequent entry of a divorce decree are intended to defeat the right of either party to receive any
insurance proceeds at the death of the other of which she or he is the named beneficiary (whether
the beneficiary designation was made prior or subsequent to execution hereof), nor to defeat the
right of either party to receive any legacy, bequest or residuary portion of the other's estate under
his or her will, or to act as personal representative or executor if so named by the will of the
other, whether such will was executed subsequent to this Agreement.
C. Except for any cause of action for divorce which either party may have or claim
to have, and except for the obligations of the parties contained in this Agreement and such rights
5
as are expressly reserved herein, each party gives to the other by the execution of this Agreement
an absolute and unconditional release and discharge from all causes of action, claims, rights or
demands whatsoever, in law or in equity, which either party ever had or now has against the
other.
8. SUCCESSORS RIGHTS AND LIABILITIES
This Agreement shall, except as otherwise provided herein, be binding upon and inure to
the benefit of the parties hereto, their respective heirs, executors, administrators, successors or
assigns.
9. SEVERABILITY
If any provision in this Agreement is held by a court of competent jurisdiction to be
invalid, void, or unenforceable, the remaining provisions shall nevertheless continue in full force
and effect without being impaired or invalidated in any way.
10. ENTIRE AGREEMENT
HUSBAND and WIFE do hereby covenant and warrant that this Agreement contains all
of the representations, promises and Agreements made by either of them to the other for the
purposes set forth in the preamble hereinabove; that there are no claims, promises or
representations not herein contained, either oral or written, which shall or may be charged or
enforced or enforceable unless reduced to writing and signed by both of the parties hereto.
11. BINDING EFFECT OF AGREEMENT/WAIVER
This Agreement shall remain in full force and effect unless and until terminated under
and pursuant to the terms of this Agreement.
The failure of either party to insist upon strict performance of the provisions of this
Agreement shall not be construed as a waiver of any subsequent default of the same or similar
6
nature, nor shall such failure be construed as a waiver of any other term, condition, clause or
provision of this Agreement.
12. BREACH
If either party breaches any provision of this Agreement, the other party shall have the
right, at his or her election, to sue for damages for such breach or seek such other remedies or
relief as may be available to him or her, and the party breaching this contract shall be responsible
for payment of reasonable legal fees and costs incurred by the other in enforcing their rights
under this Agreement.
13. CONTROLLING LAW
This Agreement shall be construed and governed in accordance with the laws of the
Commonwealth of Pennsylvania.
14. TAX RETURNS
The parties shall file joint federal and state income tax returns for 2013. Any refund shall
be divided based upon a proration of the estimated payment or withholding tendered on each
party's behalf during the year. Any liability shall be divided between the parties based on the
same proration of the income earned to estimated payments or withholding tendered on each
party's behalf.
For all joint returns filed, the parties agree that in the future if any penalties or interest or
any liability for failure to declare income or the wrongful claiming of any deduction shall be
assessed by the United States Internal Revenue Service or the Commonwealth of, Pennsylvania,
or any other state as a consequence of the parties' Federal and State income tax returns which
were filed jointly by the parties, said tax, penalties or interest shall be the sole responsibility of
the party found to be responsible for the mistake or failure to report income or having taking an
7
inappropriate deduction or exemption. The party responsible for the mistake or failure shall
Suffer the consequences solely and hold the opposite party harmless, however, if the liability is
the result of a computation error or an error not attributable to the intentional or grossly negligent
conduct of either party, the parties shall share equally in all future tax liability or tax assessment,
penalties and interest.
8EC]1ONDD
EQUITABLE DISTRIBUTION
During the marriage, the parties have accumulated various assets and liabilities, the
disposition of which is intended as follows:
1. ASSETS
` `
A. PERSONAL and HOUSEHOLD PROPERTY
HUSBAND and WIFE do hereby acknowledge that the m jority of the marital household
items remain in the marital home. It is a ed that HUSBAND'S family's stone table shall be his
sole property. The parties further agree that WIFE shall retain the remaining personal property
and same shall be removed from the house b WIFE on or before January 20, 2014. This
document shall constitute a b l of sale for each party's sole property.
B. REAL ESTATE
The parties jointly own three parcels of realproperty. This includes:
a) 1812 Silver Pine Circle, Mechan PA, which property is subject to a
mortgage due and owing to Chase Bank with an approximate outstandi balance of
8
$318,973.78 and a home equity loan due and payable to PNC Bank with an outstanding balance
of approximately $43,000.00;
b) 500 Brandt Avenue, New Cumberland, PA, which property is not encumbered;
and
c) New Jersey beach property located at 103 N. Martindale Avenue, Ventnor City.
New Jersey 08406, which is encumbered with a mortgage due and payable to Chase Bank in the
approximate amount of $149,205.00.
a) Mechanicsburg Property: The Mechanicsburg property, hereinafter the Marital
Home, shall be the sole and separate property of HUSBAND. It is the intention of the parties
that HUSBAND shall have sole ownership of the marital home provided he removes WIFE from
and indemnifies her from any all future liabilities related to the home. The Marital Home shall
be listed for sale until sold or until such time as HUSBAND successfully causes WIFE's name to
be removed from any and all liability associated with the Marital Home, including but not
limited to the Chase mortgage and PNC line of credit. HUSBAND shall advance any monies
necessary to effectuate the repairs on the home. All net proceeds of sale shall be paid to
HUSBAND. HUSBAND shall be solely responsible for any costs of sale or sums due upon sale.
WIFE shall cooperate in signing the necessary documents to allow the Marital Home to
be sold. WIFE shall sign a deed and transfer any and all of her rights, title and interest in said
home to HUSBAND. The deed shall be held in escrow by WIFE's attorney. In the event
HUSBAND is successful in removing WIFE's name from any and all liabilities associated with
the Marital Home, including but not limited to the Chase mortgage and PNC line of credit or the
house is sold, WIFE's attorney shall release the deed to HUSBAND or to the settlement
company. The deed shall be prepared by counsel for HUSBAND.
9
WIFE shall vacate the home as of December 31, 2013. At the time of her separation
from the home, she shall have the home cleaned and leave the home in good condition for
showing and marketing. WIFE shall relinquish her keys and garage door opener to HUSBAND
on or before January 20, 2014. WIFE shall have until January 20, 2014 to remove all personalty
and all household goods from the Marital Home, with the exception of the stone table. In the
event WIFE does not remove all items by said date, any remaining items shall be deemed
abandoned. WIFE shall then be responsible to reimburse HUSBAND for the costs he incurs in
disposal of any remaining personal or household items left by WIFE and for any necessary
interior cleaning or damage caused by WIFE's move.
Effective January 1, 2014, HUSBAND shall pay and be solely responsible for all
expenses related to the home, including but not limited to the mortgage, equity line payment,
taxes, insurance, utilities, maintenance and repairs. HUSBAND shall keep WIFE and her
successors, assigns, heirs, executors and administrators indemnified and held harmless from any
liability, cost or expense, including attorney fees, which may be incurred in connection with such
liabilities and expenses or resulting from HUSBAND's obligations herein. It is specifically
noted that post separation, WIFE had withdrawn the sum of $40,000.00 from the Home Equity
Line of Credit. Interest has been paid monthly. WIFE shall be able to retain said withdrawal as
her sole and separate property. However, no further withdrawals on the line of credit shall occur
and neither party shall cause other debt to be incurred against the Marital Home pending its final
disposition.
There is an issue regarding an outstanding water bill associated with the Marital Home
that the parties contest. The bill was incurred during WIFE's sole occupancy of the home.
WINE shall cooperate and be responsible for confirming all prior water payments and problems
10
with the water meter and dealing with negotiations and resolution of this issue. WIFE shall pay
this bill in full from the cash payment of $18,500.00 provided for in this agreement and
indemnify and hold HUSBAND harmless for this expense.
b) New Cumberland Building: The parties own real estate located at 500 Brandt
Avenue, New Cumberland, Pennsylvania. The property is used as the office for HUSBAND's
medical practice. Said real estate shall be the sole and separate property of HUSBAND.
Simultaneously with the execution of this deed, WIFE shall execute a quitclaim deed transferring
all her rights, title and interest iii said property to HUSBAND. HUSBAND shall claim and
indemnify and hold WIFE harmless for any capital gain tax consequence upon sale of the
property.
c) New jersey Beach Property: The parties jointly own real estate located at 103
N. Martindale Avenue, Ventnor City, New Jersey 08406. Said property is subject to a mortgage
due and owing to Chase Bank. The parties agree that this property shall become the sole and
separate property of WIFE. HUSBAND shall transfer all his rights, title and interest in said
home to Wlith upon her successful refinance of the mortgage debt due and owing to Chase
Bank. WIFE shall refinance the home within sixty (60) days of being removed from all
responsibility associated with the Marital Home or within nine (9) months of the date of this
Agreement, whichever is later. In the event that WIFE does not successfully refinance the
property; said home shall be listed for sale. Pending sale, WIFE shall be obligated to timely pay
all mortgage, taxes and insurance costs related to the home current and paid in a timely manner.
The parties shall mutually agree upon a realtor for sale of the property and agree to be guided by
the advice of their chosen realtor in establishing a marketing and pricing strategy which will
effectuate prompt sale of the property. All costs related to repair and maintenance of the
11
property shall be WIFE's responsibility. Upon sale, all proceeds shall be the sole property of
WIFE. WIFE shall indemnify and hold HUSBAND harmless for any capital gain taxes incurred
upon sale of the beach house.
C. MOTOR VEHICLES
The parties had the following vehicles at the time of their separation:
2004 Mercedes Benz C Class Sport Coupe: Driven by WIFE
2000 Acura: Driven by HUSBAND
1996 Ford: Driven by HUSBAND
Since the date of separation, trades of the above referenced vehicles have occurred. The
parties agree that the net proceeds received by each incident to said trades shall be the sole and
separate property of the party receiving same. Each party does hereby release any claim against
the other for equity received by the other. Each party shall secure and pay for his or her car
insurance effective January 12, 2014. The joint policy shall be in effect through January 11,
2014. Simultaneously with execution of this Agreement, WIFE shall return to HUSBAND the
EZ Pass transponders he has provided to her.
D. FINANCIAL ASSETS
The parties acknowledge that the marital financial accounts which existed during the
marriage have been divided to the satisfaction of the parties. All jointly titled accounts have
been closed. Each party hereby waives, relinquishes and releases any claims to the financial
accounts in the possession of the other.
12
E. PENSION AND RETIREMENT ACCOUNTS
During the marriage, each party accumulated certain retirement benefits through his and
her employment. Each party shall retain all retirement investments titled in his or her name. The
other party does hereby release any and all claims to the pension and retirement accounts of the
other.
F. BUSINESSES
Each party operated a professional practice during the marriage. The professional
practice shall be the sole and separate property of the named party. Each party warrants the other
is not a signator or guarantor of any indebtedness related to the other's practice.
G. INSURANCE
Each party shall retain ownership of any life insurance policy in his or her name.
H. EQUITABLE DISTRIBUTION PAYMENT
Simultaneously with the signing of this Agreement, HUSBAND shall pay to WIFE the
sum of Eighteen Thousand Five Hundred ($18,500.00) Dollars as Equitable Distribution. The
parties agree that said check shall be made payable to WIFE's counsel who shall pay all
expenses related to the marital home incurred prior to January 1, 2014 prior to disbursing the
remainder of the funds to WIFE. This shall include the disputed water bill relative to the marital
home, all utilities for the marital home through December 31, 2013, and any outstanding medical
expenses of WIFE which are not specifically identified in subparagraph (2) below. The only
13
exception to this obligation is that HUSBAND has paid or shall pay the mortgage and equity line
payments on the marital home prior to December 31, 2013 and continue thereafter until transfer.
2. DEBTS
Each party represents that they have not contracted any debt or liability for the other for
which the estate of the other party may be responsible or liable except as otherwise provided
herein, and that except only for the rights arising out of this Agreement, neither party will
hereafter incur any liability whatsoever for which the other party or the estate of the other party
will be liable. Each party agrees to indemnify and hold harmless from and against all future
obligations of every kind incurred by them, including those for necessities.
Notwithstanding the above, WIFE has recently incurred the following expenses:
Watersedge bill dated January 2, 2013 $5,000.00
Riverside Anesthesia invoice dated July 17, 2013 $1,747.50
Quantum Imaging and Therapeutic Associates April 29, 2013 $692.45
Holy Spirit June 21, 2013 $1,537.50
West Shore Pathology dated May 30, 2013 $718.00
Ironwood Physicians $11.88
Desert Mountain dated May 30, 2013 $545.00
HUSBAND shall pay or has paid the above expenses on behalf of WIFE. Husband shall
indemnify and hold WIFE harmless from said expenses.
14
To the best of the parties' knowledge, the parties affirm no other joint debts exist and all
joint credit cards are terminated.
SECTION III
1. 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
the 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.
2. HEALTH INSURANCE
HUSBAND does hereby agree that he shall provide insurance coverage for WIFE
through April 30, 2014. However, in the event that WIFE is covered by Medicare effective
April 1, 2014, HUSBAND shall have no obligation to pay for WIPE's coverage for the month of
April. WIPE will make a good faith attempt for timely enrollment.
15
SECTION IV
. CONDITION PRECEDENT TO THE AGREEMENT'S EFFECTIVENESS
The parties acknowledge that this Agreement shall become effective when actually
signed by berth s ties.
WITNESS
NI?
Thomas P. Kunkle •
Jaime K. Kunide
16
Jandary 2-otik-
COMMONWEALTH OF PENNSYLVANIA
) SS.
COUNTY OF CUMBERLAND
Before me, the undersigned officer, a Notary Public in and for said Commonwealth and
County, personally appeared Thomas P. Kunkle, who being duly affirmed according to law,
deposes and says that the facts and matter set forth in the within and foregoing Marital
Settlement Agreement are true and correct to the best of his knowledge, information and belief.
nd subscribed to before me this 6th day of January, 2014.
-'NOTARY PUBLIC
My commis
11.utt expit es.
NIDTARIAL SEAL
BARBARA SUMPLE-SULLIVAN
Notary Public
NEW CUMBERLAND BORO., CUMBERLAND CNTY
My Commission Expires Nov 15, 2015
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF
)
) SS.
(SEAL)
Before me, the undersigned officer, a Notary Public in and for said Commonwealth and
County, personally appeared Jaime K. Kunkle, who being duly affirmed according to law,
deposes and says that the facts and matter set forth in the within and foregoing Marital
Settlement Agreement are true and correct to the best of her knowledge, information and belief.
Affirmed and subscribed to before mc this
NOTARY PUBLIC
day of , 2014.
My commission expires: (SEAL)
17
0
Barbara Sumple- Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, PA 17070
(717) 774 -1445
JAIME K. KUNKLE,
Plaintiff
v.
THOMAS P. KUNKLE,
Defendant
THE PRO
APR -8 PM 4: 15
CU.M[3CRLAND COUNTY
PENNSYLVANIA
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 2004 -1152
: CIVIL ACTION - LAW
: IN DIVORCE
ACCEPTANCE OF SERVICE
Thomas P. Kunkle, hereby accept service and acknowledge receipt of the above - captioned
Divorce Complaint having received said Complaint on the 11th day of April, 2004.
Date: April 7, 2014
Barbara Sumple- Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, PA 17070
(717) 774-1445
JAIME K. KUNKLE,
Plaintiff
v.
THOMAS P. KUNKLE,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 2004 -1152
: CIVIL ACTION - LAW
: IN DIVORCE
CERTIFICATE OF SERVICE
I, Barbara Sumple- Sullivan, Esquire, do hereby certify that on this date, I served a true and
correct copy of the foregoing Plaintiff's Acceptance of Service, in the above - captioned matter upon
the following individual by first class mail, postage prepaid, addressed as follows:
DATE: April 8, 2014
Ann Levin, Esquire
McNees, Wallace & Nurick, LLC
100 Pine Street
P.O. Box 1166
Harrisburg, PA 17108
Barbara Su e-Sullivan, Esquire
549 Bridge Street
New Cumberland, PA 17070
(717) 774-1445
Supreme Court I.D. No. 32317
Attorney for Defendant
Barbara Sump le-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, PA 17070
(717) 774-1445
JAIME K. KUNKLE,
Plaintiff
V.
THOMAS P. KUNKLE,
Defendant : IN DIVORCE
Th
r,UtIB:_hL
PEPISYLVAtAli\
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
MI \5
: NO. 2004-1152
: CIVIL ACTION - LAW
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: Acceptance of Service by Defendant on
April 11, 2004 and confirmed on April 7, 2014 (original Acceptance of Service lost).
3. Date of execution of the Affidavit of Consent required by § 3301(c) of the Divorce Code:
by Plaintiff: March 13, 2014; by Defendant: March 14, 2014.
4. Related claims pending: None. All matters have been resolved by the parties' Marital
Settlement Agreement dated January 6, 2014, which shall be incorporated, but not merged into
the Decree in Divorce.
5. Date Plaintiff's Waiver of Notice in §3301(c) Divorce- as filed with Prothonotary: April
2, 2014. Date Defendant's Waiver of Notice in §3301(c) orce d with Prothonotary: April
2, 2014.
Dated: April 8, 2014
Barbara Sumple-Sullivan, Esquire
549 Bridge Street
New Cumberland, PA 17070-1931
(717)-774-1445
Supreme Court ID #32317
Attorney for Defendant
Barbara Sump le-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, PA 17070
(717) 774-1445
JAIME K. KUNKLE,
Plaintiff
V.
THOMAS P. KUNKLE,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2004-1152
: CIVIL ACTION - LAW
: IN DIVORCE
CERTIFICATE OF SERVICE,
I, Barbara Sump le-Sullivan, Esquire, do hereby certify that on this date, I served a true and
correct copy of the foregoing Plaintiff's Praecipe to Transmit Record, in the above-captioned
matter upon the following individual by first class mail, postage prepaid, addressed as follows:
DATED: April 8, 2014
Ann Levin, Esquire
McNees, Wallace & Nurick, LLC
100 Pine Street
P.O. Box 1166
Harrisburg, PA 17
Barbara Sump le-Sullivan, Esquire
549 Bridge Street
New Cumberland, PA 17070
(717) 774-1445
Supreme Court I.D. No. 32317
Attorney for Defendant
: IN THE COURT OF COMMON PLEAS OF
JAIME K. KUNKLE : CUMBERLAND COUNTY, PENNSYLVANIA
V. •
•
THOMAS P. KUNKLE : NO. 2004-1152
DIVORCE DECREE
l 6 ' 1 2ac4
AND NOW, , it is ordered and decreed that
JAIME K. KUNKLE , plaintiff, and
THOMAS P. KUNKLE , 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. All matters have been resolved by the parties' Marital Settlement
Agreement dated January 6, 2014, which shall be incorporated, but not merged
into this Decree.
By the ou ,
dz
4,e ^x_n
67. PC Thomas A.Placey
= ��e !?£ /._, _ r ... .. • _ _• udge
Attest:
r
ri AM I •.I■, •
b .VIED p lt.LLI,P othonotary
Cex+appq r)-13 fled 4e) ant/ Levi
No-Fiat &pc( &rnple • 2tAllivign
• #