HomeMy WebLinkAbout08-63434
CHRISTINE STEPHENSON, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
NO. O$- W y
`ir,
JEFFREY STEPHENSON,
Defendant IN DIVORCE
NOTICE TO DEFEND
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set
forth in the following pages, you must take prompt action. You are warned that if you fail to
do so, the case may proceed without you and a decree of 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 the Cumberland County Court House, Carlisle,
Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYERS FEES OR EXPENSES BEFORE A DECREE OF 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
(717) 249-3166 or 800-990-9108
FLOWER SAID,
LIlVDSAY
26 West High Street
Carlisle, PA
SAIDIS, FLOWER & LINDS Y
Carol J. Lindsa ;
Attorney Id. 93
26 West Hi S
Carlisle, PA 17013
(717) 243-6222
Counsel for Plaintiff
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CHRISTINE STEPHENSON,
Plaintiff
V.
JEFFREY STEPHENSON,
Defendant
IN DIVORCE
COMPLAINT IN DIVORCE UNDER
SECTION 3301(c) or (d) OF THE DIVORCE CODE
1. The Plaintiff is Christine Stephenson, an adult individual, residing at 241
Walton Street, Lemoyne, Cumberland County, Pennsylvania.
2. The Defendant is Jeffrey Stephenson, an adult individual, residing at 714 16'h
Street, New Cumberland, Pennsylvania.
3. The Plaintiff and Defendant both have been bona fide residents in the
Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this
Complaint.
4. The Plaintiff and Defendant were married on May 27, 1978 in Cumberland
County, Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the
parties in this or in any other jurisdiction.
6. The Plaintiff has been advised that counseling is available and that she has
SAIDIS,
FLOWER &
LENDS"
26 West High Street
Carlisle, PA
the right to request that the court require the parties to participate in counseling.
7. The marriage is irretrievably broken.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 5?r G 3 (f 3 C',c-w:lt -7Z-?
WHEREFORE, Plaintiff requests entry of a divorce decree in her favor in accordance
with §3301 of the Pennsylvania Divorce Code.
SAIDIS, FLOVVER &
Attorney Id. 44693
26 West High-Stmg
Carlisle, PA 17013
(717) 243-6222
Counsel for Plaintiff
SAIDIS,
FLOWER &
LINDSAY
MUZOINUTAW
26 West High Street
Carlisle, PA
VERIFICATION
I verify that the statements made in the foregoing document 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 falsifications to authorities.
LA ILA" Ii.- A
Christine Stephenso
Date: 10-04- pFS
F? &
LINDSAY
26 West High Street
Carlisle, PA
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CHRISTINE STEPHENSON,
Plaintiff
V.
JEFFREY STEPHENSON,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 08-6343 CIVIL TERM
IN DIVORCE
AFFIDAVIT OF SERVICE
I, Carol J. Lindsay, Esquire, being duly sworn according to law, hereby deposes and
says that on November 15, 2008, 1 served a true and correct copy of the Complaint in
Divorce upon Defendant, by mailing those documents to the his address at 714 16th Street,
New Cumberland, PA 17070, by Certified U.S. Mail, Restricted Delivery, Return Receipt
Requested, as evidenced by the attached U.S. Postal Service Form 3811, Domestic Return
Receipt, the latter of which is signed by the recipient, Jeffrey Stephenson.
Respectfully submitted,
SAIDIS, FLQWER?? S, Y
Attorney Id. 414693
26 West Hig
Carlisle, PA 17013
(717) 243-6222
SAIDIS,
FLOWER &
LP4DSAY
26 West High Street
Carlisle, PA
Dated: November 19, 2008
Counsel for Plaintiff
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CHRISTINE STEPHENSON,
Plaintiff
V.
JEFFREY STEPHENSON,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 08-6343 CIVIL TERM
IN DIVORCE
PLAINTIFF'S AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed
October 27, 2008.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety
days have elapsed from the date of filing and service of the Complaint.
3. 1 consent to the entry of a final Decree in 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 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: 7- ) (70? --
Christine Stephenson
PLAINTIFF'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A
DIVORCE DECREE UNDER4 3301 (c) OF THE DIVORCE CODE
1. I consent to the entry of a final Decree of Divorce without notice.
SAIDIS,
LINDSAY
ATIOIWr AT uw
26 West High Street
Carlisle, PA
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 ilVil= 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 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: 1 0/
0,ku
Christine Stephenson
JUL 15 2009
T-l' f?l Qy
2909 .: i vim 1 1 AIli IG: s
CHRISTINE STEPHENSON,
. Plaintiff' "
V.
JEFFREY STEPHENSON,
Defendant
DEFENDANT'S AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed
October 27, 2008.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety
days have elapsed from the date of filing and service of the Complaint.
3. 1 consent to the entry of a final Decree in 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 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: a d a
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 08-6343 CIVIL TERM
IN DIVORCE
fy y e enson
DEFENDANT'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A
DIVORCE DECREE UNDER4 3301 (c) OF THE DIVORCE CODE
1. 1 consent to the entry of a final Decree of Divorce without notice.
SAMIS,
FLOWER &
LINDSAY
ATFOOM15.AMAW
26 West High Street
Carlisle, PA
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 this Affidavit 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: 3 3 u I y.1-3 , 9 _
Q$ftpKy Step nson
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CHRISTINE STEPHENSON,
Plaintiff
V.
JEFFREY STEPHENSON,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 08-6343 CIVIL TERM
IN DIVORCE
PROPERTY SETTLEMENT AND SEPARATION AGREEMENT
THIS AGREEMENT made this a ? day of I tx -\ ?L- , 2009, between
CHRISTINE STEPHENSON, of 241 Walton Street, Lemoyne, Cumberland County, Pennsylvania,
hereinafter referred to as Wife, and JEFFREY STEPHENSON, of 324 Rear Walton Street, Lemoyne,
Cumberland County, Pennsylvania, hereinafter referred to as Husband.
RECITALS:
R.1: The parties hereto are husband and wife, having been joined in marriage on May 27,
1978 in Cumberland County, Pennsylvania; and
R.2: A Complaint for Divorce has been filed in the Court of Common Pleas of Cumberland
County, Commonwealth of Pennsylvania, to Number 08-6343, Civil Term; and
R.3: The parties hereto desire to settle fully and finally their respective financial and
property rights and obligations including, but not limited to, all matters between them relating to the
ownership of real and personal property, claims for spousal support, alimony, alimony pendente lite,
counsel fees and costs, and the settling of any and all claims and possible claims against the other or
against their respective estates.
NOW THEREFORE, in consideration of the covenants and promises hereinafter to be
mutually kept and performed by each party, as well as for other good and valuable consideration and
intending to be legally bound, it is agreed as follows:
(1) SEPARATION: It shall be lawful for each party at all times hereafter to live separate
and apart from the other party at such place or places as he or she from time to time may choose or
deem fit, free from any control, restraint or interference from the other. Neither party will molest the
other or endeavor to compel the other to cohabit or dwell with him or her by any legal or other
proceeding. Each party shall be free of the interference, authority or contact by the other as if he or
she was single and unmarried except as maybe necessary to carry out the terms of this Agreement.
(2) DIVORCE: The parties acknowledge that the marriage is irretrievably broken and
that they will secure a mutual consent no-fault divorce decree in the above-captioned divorce action.
Upon the execution of this Agreement, the parties shall execute and file Affidavits of Consent and
Waivers of Notice, necessary to finalize said divorce.
(3) REAL PROPERTY: The parties are the owners of certain real estate with
improvements thereon erected and known and numbered as 241 Walton Street, Lemoyne,
Cumberland County, Pennsylvania. On the same day as he executes this Agreement, Husband shall
convey to Wife, by special warranty deed, all his right, title and interest in 241 Walton Street. Wife
shall be solely responsible for all expenses associated with the home including, but not limited to,
liens of record, utility bills, insurance and real estate taxes. With regard to all such expenses, Wife
shall hold Husband harmless and indemnify him from any loss thereon.
(4) DEBT:
A. Marital Debt: Husband and Wife acknowledge and agree that there are no other
outstanding debts and obligations which are joint. Any obligations in the names of one party or the
other shall be his or her own separate, individual obligation.
B: Post Separation Debt: In the event that either party contracted or incurred any debt
since the date of separation on October 15, 2007, the party who incurred said debt shall be
responsible for the payment thereof regardless of the name in which the debt may have been
incurred.
C: Future Debt: From the date of this Agreement, neither party shall contract or incur
any debt or liability for which the other party or his or her property or estate might be responsible and
shall indemnify and save the other party harmless from any and all claims or demands made against
him or her by reason of debts or obligations incurred by the other party.
(5) MOTOR VEHICLES: Each party relinquishes any right, title and interest he or she
may have to any and all motor vehicles currently in possession of the other party.
(6) TANGIBLE PERSONAL PROPERTY: The parties hereto mutually agree that they
have effected a satisfactory division of the furniture, household furnishings, appliances, tools and
other household 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 property presently in his or her
possession whether said property was heretofore owned jointly or individually by the parties hereto.
This Agreement shall have the effect of an assignment or bill of sale from each party to the other for
such property as may be in the individual possession of each of the parties hereto.
(7) INTANGIBLE PERSONAL PROPERTY: Each party hereby relinquishes any right,
title or interest he or she may have in or to any intangible personal property currently titled in the
name of or in the possession of the other party, including, but not limited to, stocks, bonds,
insurance, bank accounts, individual retirement accounts, employment benefits including retirement
accounts, savings plans, pension plans, stock plans, 401 K plans and the like.
Specifically, the parties have satisfactorily divided the joint Belco account. Wife is retaining
her Commerce Bank account and Husband is retaining his Belco account.
Nevertheless, Husband will roll over to Wife his Ameriprise Roth IRA (---2021) and his
Ameriprise IRA (---7021), in the amount of approximately $10,000.00 and $3,200.00, respectively.
Wife will also retain her Ameriprise IRA and her PA Farm Bureau 401(k).
Husband will retain his United States Postal Service Thrift Savings account, his US Letter
Carriers' Mutual Benefit Association account and his Ameriprise Variable Universal Life annuity.
Husband is the beneficiary of a Civil Service Retirement System with the Federal
government. The Civil Service Retirement pension shall be Husband's sole and separate property
except that upon his retirement, he will elect the maximum survivor annuity for which Wife shall be
the beneficiary. To give effect to this provision, the parties will execute a Domestic Relations Order
prepared by Conrad Seigel Actuaries within ten (10) days of presentation and will submit the Order to
the Office of Personal Management for implementation once it is signed by the Court. Wife will retain
her Pennsylvania Farm Bureau Pension.
For all 401(k) plans, IRAs, Roth IRAs or insurance policies retained by the parties, each will
initiate new beneficiary designations, naming the two parties' two children, or each child's spouse
should the child fail to survive, as beneficiaries of the death benefit for each asset, in equal shares.
The parties will provide a copy of the form so naming the children and their spouses as beneficiaries
within twenty (20) days of the date of this Agreement.
Wife will retain her Mass Mutual Life Insurance policy along with its cash value. Husband will
cash in the U.S. Savings Bonds and give to Wife the proceeds received within 10 days of the date of
this agreement.
(8) WAIVER OF ALIMONY: The parties acknowledge that each has income and
assets satisfactory to his and her own reasonable needs. Each party waives any claim he or she
may have one against the other for alimony, spousal support or alimony and alimony pendente lite.
(9) ADVICE OF COUNSEL: The parties hereto acknowledge that each has been notified
of his or her right to consult with counsel of his or her choice, and have been provided a copy of this
Agreement with which to consult with counsel. Wife is represented by Carol J. Lindsay, Esquire and
Husband has been advised that he may be represented by counsel of his choice. Each party
acknowledges and accepts that this Agreement is, under the circumstances, fair and equitable, and
that it is being entered into freely and voluntarily after having received such advice and with such
knowledge as each has sought from counsel, and the execution of this Agreement is not the result of
any duress or undue influence, and that it is not the result of any improper or illegal agreement or
agreements. Each party shall pay his or her own attorney for all legal services rendered or to be
rendered on his or her behalf.
Wife has borne the costs of the filing of the Complaint in Divorce and the preparation of this
Agreement and the Deed and she will bear the cost of the Domestic Relations Order provided,
however, that Husband will pay to Wife $1,000.00 within sixty (60) days of the date of this Agreement
as his contribution toward the costs attendant upon the divorce.
(10) ADDITIONAL INSTRUMENTS: Each of the parties shall from time to time, at the
request of the other, execute, acknowledge and deliver to the other party any and all further
instruments that may be reasonably required to give full force and effect to the provisions of this
Agreement.
(11) INCOME TAX: The parties have heretofore filed joint Federal and State Tax returns.
Both parties agree that in the event any deficiency in Federal, state or local income tax is proposed,
or assessment of any such tax is made against either of them, each will indemnify and hold harmless
the other from and against any loss or liability for any such tax deficiency or assessment and any
interest, penalty and expense incurred in connection therewith. Such tax, interest, penalty or expense
shall be paid solely and entirely by the individual who is finally determined to be the cause of the
misrepresentations or failures to disclose the nature and extent of his or her separate income on the
aforesaid joint returns.
(12) BANKRUPTCY: The parties hereby agree that the provisions of this Agreement shall
not be dischargeable in Bankruptcy and expressly agree to reaffirm any and all obligations contained
herein. In the event a party files such bankruptcy and pursuant thereto obtains a discharge of any
obligations assumed hereunder, the other party shall have the right to declare this Agreement to be
null and void and to terminate this Agreement in which event the division of the parties' marital assets
and all other rights determined by this Agreement including alimony shall be subject to court
determination the same as if this Agreement had never been entered into.
(13) COMPLETE DISCLOSURE: The parties do hereby warrant, represent, acknowledge
and agree that each is fully and completely informed of, and is familiar with, the wealth, real and
personal property, estate and assets, earnings and income of the other and has made any inquiry he
or she desires into the income or estate of the other and received any such information requested.
Each has made a full and complete disclosure to the other of his and her entire assets, liabilities,
income and expenses and any further enumeration or statement thereof in this Agreement is
specifically waived.
(14) RIGHTS AND RESPONSIBILITIES: Husband and Wife acknowledge that each of
them has read and understand his and her rights and responsibilities under this Agreement and that
they have executed this Agreement under no compulsion to do so but as a voluntary act.
(15) FULL SETTLEMENT: Except as herein otherwise provided, each party hereby
releases the other from any and all claims, or demands up to the date of execution hereof. It is
further specifically understood and agreed by and between the parties hereto that each party accepts
the provisions herein made in lieu of and in full settlement and satisfaction of any and all of said
party's rights against the other for past, present and future claims on account of support,
maintenance, alimony, alimony pendente lite, counsel fees, costs and expenses, equitable
distribution of marital property and any other claims of the party, including all claims which have been
raised or may be raised in an action for divorce.
(16) RELEASE OF ALL CLAIMS: Except as may be otherwise specifically provided in this
Agreement, Husband and Wife, for themselves, their heirs, representatives and assigns, each
hereby forever releases, remises, discharges and quitclaims the other, and such other's heirs,
representatives, assigns and estate, from and with respect to the following:
A. All liability, claims, causes of action, damages, costs, contributions and expenses or
demands whatsoever in law or in equity;
B. All rights, title, interest or claims in or to any property of the other, whether real,
personal or mixed and whether now owned or hereafter acquired;
C. All rights of courtesy and dower and all claims or rights in the nature of courtesy and
dower;
D. All widow or widower's rights;
E. All right, title, interest or claim in or to the other's estate, whether now owned or
hereafter acquired, including but not limited to all rights or claims:
(1) to take against the other's will;
(2) under the laws of intestacy;
(3) to a family exemption or similar allowance; and
(4) all other rights or authority to participate or intervene in a deceased spouse's
estate in any way, whether arising under the laws of Pennsylvania or any other country,
territory, state or political subdivision.
F. All rights or claims to any accounting;
G. All rights, claims, demands, liabilities and obligations arising out of or in connection
with the marital relationship or the joint ownership of property, whether real, personal or mixed;
H. All rights, claims, demands, liabilities and obligations arising under the provisions of
the Pennsylvania Divorce Code, as the same may be amended from time to time, and under the
provisions of any similar statute enacted by any other country, state, territory or political subdivision;
1. All rights, claims, demands, liabilities and obligations each party now has, or may hereafter
have, against or with respect to the other.
(17) GOVERNING LAW: This Agreement shall be construed under the law of the
Commonwealth of Pennsylvania. If any provision of this Agreement is determined to be invalid or
unenforceable, all other provisions shall continue in full force and effect.
(18) INCORPORATION INTO DECREE: In the event that either of the parties shall
recover a final judgment or decree of absolute divorce against the other in a court of competent
jurisdiction, the provisions of this Agreement may be incorporated by reference or in substance but
shall not be merged into such judgment or decree and this Agreement shall survive any such final
judgment or decree of absolute divorce and shall be entirely independent thereof.
(19) BREACH: In the event that either party breaches any provision of this Agreement, he
or she shall be responsible for any and all costs incurred to enforce the Agreement, including, but not
limited to, court cost and counsel fees of the other party. In the event of breach, the other party shall
have the right, at his or her election; to sue for damages for such breach or to seek such other and
additional remedies as may be available to him or her.
(20) ENTIRE UNDERSTANDING: This Agreement constitutes the entire understanding
between the parties and there are no covenants, conditions, representations, or agreements, oral or
written, of any nature whatsoever, other than those herein contained.
(21) AGREEMENT BINDING ON PARTIES AND HEIRS: This Agreement shall bind the
parties hereto, their respective heirs, executors and assigns.
IN WITNESS WHEREOF, the parties hereto intending to be legally bound have hereunto set
their haryds and seals the day and year first written above.
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Christine Stephenson
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CHRISTINE STEPHENSON,
Plaintiff
V.
JEFFREY STEPHENSON,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 08-6343 CIVIL TERM
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Kindly transmit the record, together with the following information, to the Court for
entry of a Decree in Divorce:
1. Grounds for Divorce: Irretrievable breakdown under Section 3301(c) of the
Divorce Code.
2. Date and manner of service of the Complaint: Defendant accepted service
of the Complaint on November 15, 2008, via certified mail. Proof of service was filed with
the Court on November 19, 2008.
3. Date Affidavit of Consent required under Section 3301(c) of the Divorce
Code was signed:
By Plaintiff: July 11, 2009 and filed with the Prothonotary
contemporaneously herewith.
By Defendant: July 3, 2009 and filed with the Prothonotary
contemporaneously herewith.
4. Related claims pending: The terms of the Property Settlement and
Separation Agreement dated June 26, 2009 are incorporated, but not merged, into the
Decree in Divorce.
5. Date Waiver of Notice under Section 3301(c) of the Divorce Code was
SAIDIS,
FLOWER &
LINDSAY
ATMRIEtS•Ai uw
26 West High Street
Carlisle, PA
By Plaintiff: July 11, 2009 and filed with the Prothonotary
contemporaneously herewith.
By Defendant: July 3, 2009 and filed with the Prothonotary
contemporaneously herewith.
signed:
SAIDIS, FLOWER & DSAY
Carol J. Lind ay, squire
Supreme Co No. 44693
26 West High Street
Carlisle, PA 17013
717-243-6222
Attorney for Plaintiff
OF ' .OTARY
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D09 J 1121- t A I1q: 5
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IN THE COURT OF COMMON PLEAS OF
CHRISTINE STEPHENSON CUMBERLAND COUNTY, PENNSYLVANIA
V.
JEFFREY STEPHENSON NO. 08-6343
DIVORCE DECREE
AND NOW, 'kO6q , it is ordered and decreed that
CHRISTINE STEPHENSON , plaintiff, and
JEFFREY STEPHENSON , 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.")
The terms of the Marital Settlement Agreement, dated June 26, 2009, are
incorporated but not merged into this Decree in Divorce.
By the Court,
Attest: J.
Prothonotary
7 .7.09
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441t
Christine Stephenson IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION - LAW
Jeffrey Stephenson NO. 08-6343
Defendant
DOMESTIC RELATIONS ORDER
1. This Domestic Relations Order ("DRO") creates and recognizes the existence of the
Alternate Payee's right to receive a portion of the benefits payable with respect to the Participant.
It is intended to constitute a DRO Acceptable For Processing under final regulations issued by the
Office of Personnel Management ("OPM").
2. This DRO is entered pursuant to authority granted under the applicable domestic
relations laws of the State of Pennsylvania.
3. This DRO relates to the provision of marital property rights to the Alternate Payee.
4. This DRO applies to the Civil Service Retirement System ("Plan") and any successor
thereto. Jeffrey Stephenson ("Participant") is a Participant in the Plan. Christine Stephenson
("Alternate Payee"), the former spouse, is the Alternate Payee for the purposes of this DRO.
5. The Participant's name, mailing address, Social Security number and date of birth are:
Jeffrey Stephenson
324 Walton Street Rear
Lemoyne, PA 17043
Social Security No.: See Addendum
Date of Birth: See Addendum
6. The Alternate Payee's name, mailing address, Social Security number and date of birth
are:
DRO
Page 2
Christine Stephenson
Lemoyne, PA 17043
Social Security No.: See Addendum
Date of Birth: See Addendum
It is the responsibility of the Alternate Payee to keep a current mailing address on file
with the Plan at all times.
7. The sole purpose of this DRO is to award a former spouse survivor annuity to the
Alternate Payee. The Alternate Payee is not entitled to any portion of the Participant's gross
monthly annuity.
8. The Alternate Payee is awarded a former spouse survivor annuity based on a pro rata
share. The parties were married on May 27, 1978, and they separated on October 15, 2007. The
former spouse survivor annuity shall be payable to the Alternate Payee if the Participant dies
before or after his retirement. The costs associated with providing this former spouse survivor
annuity coverage shall be deducted from the Participant's gross benefit. Participant agrees to take
all necessary steps to elect the Alternate Payee as designated beneficiary for the purposes of
establishing such former spouse coverage.
9. If Participant leaves Federal service before retirement and applies for a refund of
employee contributions under the Plan, the OPM is directed not to pay the Participant a refund of
such employee contributions.
10. In no event shall the Alternate Payee have greater benefits or rights other than those
which are available to the Participant. The Alternate Payee is not entitled to any benefit not
otherwise provided by the Plan. The Alternate Payee is only entitled to the specific benefits
offered by the Plan as provided in this Order. All other rights, privileges and options offered by
the Plan not granted to Alternate Payee are preserved for the Participant.
11. The Alternate Payee assumes sole responsibility for the tax consequences of any
payments made to her under this DRO.
DRO
Page 3
12. In the event that the Plan inadvertently pays to the Participant any benefits that are
assigned to the Alternate Payee pursuant to the terms of this DRO, the Participant shall
immediately reimburse the Alternate Payee to the extent that he has received such benefit
payments, and shall forthwith pay such amounts so received directly to the Alternate Payee within
ten (10) days of receipt. In the event the Plan inadvertently pays to the Alternate Payee any
benefits that are not assigned to her pursuant to the terms of this DRO, the Alternate Payee shall
immediately reimburse the Participant to the extent she has received such benefit payments and
shall forthwith pay such amounts so received directly to the Participant within ten (10) days of
receipt.
13. In the event the Participant makes a one-time irrevocable election to transfer into the
Federal Employees Retirement System ("FERS") before his retirement, then Alternate Payee shall
be entitled to a portion of the survivor benefits set forth under Section 8 above. Further, such
former spouse survivor annuity shall be payable directly from FERS.
14. The OPM shall notify the Alternate Payee and her legal representative when the
Participant makes an application for any benefit payments or withdrawals from the Plan.
I
•.1 .
DRO
Page 4
15. The Court of Common Pleas of Cumberland County, Pennsylvania shall retain
jurisdiction to amend this Order, but only for the purpose of establishing it or maintaining it as a
Domestic Relations Order, provided, however, that no such amendment shall require the Plan to
provide any form of benefit or any option not otherwise provided by the Plan, and further provide
that no such amendment or right of the Court to so amend will invalidate this Order.
EXECUTED this -ay of ? , 20 d
CONSENT TO ORDER:
BY THE COUR
Judge
PLAINTIFF/ALTERNATE PAYEE DEFENDANT/PARTICIPANT
]I n i +AJ
7 X9 A J?
Signature ate ture Date
ATTORNEY FOR
ALTERNATE PA'
J
Signature
FILED
CAF TFF FARY
2004 SEP - l
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n4y (2, 4?bdmf
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