The URL can be used to link to this page

Home My WebLink About09-1953NANCY R. SPECK, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. r7 l ?1 S?3 ?e? BRIAN A. SPECK, 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 York 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 SAIDIS, FLOWERA LINDSAY SAIDIS, FLOWER & LINDSAY 26 West High Street Carlisle, PA Carol J: LindPy, bquire Attorney Id. 1469P 26 West Hig eet Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff NANCY R. SPECK, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. U • /g S3 ct,. -7Z- BRIAN A. SPECK, Defendant IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) or (d) OF THE DIVORCE CODE 1. The Plaintiff is Nancy R. Speck, an adult individual, residing at 172 East High Street, Carlisle, Cumberland County, Pennsylvania. 2. The Defendant is Brian A. Speck, an adult individual, residing at 157 North Hanover Street, Apartment 2, Carlisle, Cumberland County, 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 November 3, 1984 in Carlisle, SAIDIS, FLOWER & LINDSAY 26 West High Street Carlisle, PA 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 the right to request that the court require the parties to participate in counseling. 7. The marriage is irretrievably broken. WHEREFORE, Plaintiff requests entry of a divorce decree in her favor in accordance with §3301 of the Pennsylvania Divorce Code. SAIDIS, FLOWER & Attorney Id. 44693 26 West High t#eLOI Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff SAIDIS, FLOWER & LINDSAY 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. Nancy R. Spe Date: 3 .._p SAII)IS, FLOWER & LINDSAY 26 West High Street Carlisle, PA C-) n? e- rnn r =Zo t r •`.J r- fv Q,3 p LJ r Caa co .3 Ci NANCY R. SPECK, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 09-1953 BRIAN A. SPECK, Defendant IN DIVORCE ACCEPTANCE OF SERVICE I, Brian A. Speck, accept service of the Complaint in the above-captioned matter. r F ?J Date Brian A. Speck SAMIS, FLOWER & LINDSAY ATIUdU EY5•AMAW 26 West High Street Carlisle, PA FiLE'u--:?=rfCE OF THE PRK 'r°" mITARY 2009 APR °7 FAH 2: 31 NANCY SPECK, Plaintiff v. BRIAN A. SPECK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2009-1953 `- ~~' ~~;~ CIVIL ACTION -LAW ~ ~; ~~ ~,- :~ . IN DIVORCE ~`,,~; ~-,., :-~., Q ~:: Gti -~ c.., r~ .~ _~, ~'ir _ ,~ .-, =~~ ~ ~; ~, , _-~<-, :, ~~ -~-; ~:;~: - . STIPULATION AND AGREEMENT ~_ t,, THIS STIPULTION AND AGREEMENT is made this _~! day of i /~~fy'y~~;...~ ~ystr , 2012, by and between the plaintiff, Nancy Speck, n/k/a Nancy Weaver, and the defendant, Brian A. Speck. WHEREAS, the plaintiff and defendant are former spouses, having been divorced by decree dated August 5, 2009; and WHEREAS, prior to the entry of a divorce decree the parties executed a Property Settlement and Separation Agreement dated May 1 1, 2009; and WHEREAS, paragraph (9) of the Property Settlement and Separation Agreement called for defendant to make certain alimony payments to plaintiff; and WHEREAS, said alimony payments were subsequently modified to two hundred dollars ($200.00) per month for a period of thirty-six (36) months by Court Order dated December 1, 2011; and WHEREAS, plaintiff remarried on or about August 10. 2012; and WHEREAS, on September 2Ei, 2012, defendant filed a Petition to Terminate Alimony seeking termination of alimony payments, repayment of an alimony payment made fir the month of September 2012 and counsel fees, costs and expenses; and WHEREAS, a hearing on defendant's Petition to Terminate Alimony has been scheduled for November 7, 2012 at 8:45 a.m.; and WHEREAS, the plaintiff and the defendant have negotiated the ternls of a settlement to resolve defendant's Petition to Terminate Alimony; NOW THEREFORE, in consideration of the mutual covenants, promises and agreements as hereinafter set forth and intending to be legally bound, the parties hereto agree as follows: 1. The parties hereby agree that, subsequent to the filing of his Petition to Terminate .Alimony, the defendant has continued to make the required. two hundred dollar ($200.00) per month alimony payments for the months of October and November 2012 in accordance with the Honorable Albert H. Masland"s order dated C)ecember 1, 2011. 2. In addition, the parties acknowledge and agree that defendant has arranged fir the transfer to plaintiff of certain cemetery plots in accordance with paragraph (6) of the 2 Property Settlement and Separation Agreement dated May 1 1, 2009, whi<,h was not heretofore properly completed. 3. The parties hereby acknowledge and agree that the two (2) two hundred dollar ($200.00) alimony payments made to plaintiff' in October and November 2012, ;end the completion of the transfer of cemetery lots represents a full settlement of the outstanding issues between the parties and defendant's Petition to Terminate Alimony. 4. All of defendant's future obligations to make alimony payments pursuant to the Property Settlement and Separation Agreement dated May 11, 2009 and the Order of Court dated December 1, 2011 are hereby terminated. 5. The two hundred dollar ($200.00) alimony payments received by plaintiff for the months of September, October and November 2012 shall remain plaintiff's sole property and shall not be returned to defendant. 6. No counsel fees, costs or expenses shall be awarded to either party. IN WITNESS WHEREOF, the parties hereto, intending to be legally bound by the terms hereof; set forth their hands and seals the day and year first written above: -~ NANCY W ER, Plaintiff i ,~ , ~ C 'f _ ___ ~ ~, BRIAN A. SPECK, Defe dant ,, ~ , -~ -~ ~~ J- ANDREW J.. B NDER, ESQUIRE For Defendant ,i AR US A. McKNIG ,III, ESQUIRE For Plaintiff ,. COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF CUMBERLAND . :~ ~ ~ ~ ~ _, 2012, before me the undersigned On this, the - day of (,'v~vw officer personally appeared, BRIAN A. SPECK, known to me or satisfactorily proven to me to be the person whose name is subscribed to the within Stipulation and Agreement, an~1 acknowledged that he executed the same for the purposes therein. contained. ~-. ~~ ,. BRIAN A. SPECK !;' ~~ IN WITNESS WHEREOF, [hereunder set my hand and seal this ~` day of ~ ~'' -'~-~ ~' +'~ _, 2012. 5 COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF CUMBERLAND On this, the _~ ~~ day of _ ~~~ I~C" I T) ~.:~% f _, 201'2, before me the undersigned officer personally appeared, NANCY WEAVER, known to me or. satisfactorily proven to me to be the person whose name is subscribed to the within Stipulation and Agreement, anal acknowledged that she executed the same for the purposes therein contained. A]GTCY W~/AVE.R IN WITNESS WHEREOF, I hereunder set my hand and seal this day of / ~.!i`lLi {l ~~~ , 2012. OpMMpNW TH Of PENNSYLVANIP` ~~~NoLaN public ~,ren S. Noel, Goucriy ~~{~le poro, ~~ ~, g, '1015 My CON nON pf NOTARIES MEMBER,~NNSyLVANIA ASSOCIA ' , .1 -~ ~ ,. ~ ._ Not y Public 4