HomeMy WebLinkAbout01-4894Stephanie M. Beecher
Christopher L. Beecher
1N THE COURT OF COMMON PLEAS OF
Cumberland COUP, PENNSYLVANIA
CYvqL DY~SION
NOTICE TO DEFEND AND CLAIM RIGHTS
YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIM
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 CHILDfREN}.
WHEN THE GROUND FOR THE DIVORCE ARE 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 1 Courthouse Square, Carlisle
, PENNSYLVANIA.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DMSION OF PROPERTY, LAWYERS
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.
LAWYERS REFERRAL SERVICE
Legal Services, Inc.
8 Irvihe Row, Carlisle, PA
Telephone: ( 7] 7 )
Stephanie M. Beecher~.~J~. ~f[,~
For Petitioner
Address:324 Walnut Lane
Carlisle, PA 17013
Telephone: (717) 691-9787
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Stephanie M. Beecher
Plaintiff
Christopher L. Beecher
Defendant
CIVIL ACTION NO. OI - ~ ~qq 51 ~ t I
COMPLAINT FOR DIVORCE
AND NOW, comes the Plaintiff, Pro Se, and hereby avers as follows:
1.
The Plaintiff has been a resident of Pennsylvania for at least six months prior to the filing of this
Petition.
The Plaintiffand/or Defendant is a resident of County, Pennsylvania, and is therefore subject to the
jurisdiction of this Court. The Plaintiffpresently resides at 324 Walnut Lane, Carlisle, PA 17013 and
the Defendant presently resides at 324 Walnut Lane, Carlisle, PA 17013.
Defendant may also be served at said residence.
The Plaintiffand Defendant mutually consent to this divorce pursuant to23 Pa.C.S. ~ 3301(C), one
from the other.
Defendant has waived service of process.
Page I
The parties are husband and wife, having been married on October 16, 1999 at Carlisle, PA, but who
did separate on January 25, 2001 and are now living in a bona fide state of separation. Plaintiff and
Defendant have been separated for at least six months immediately prior to filing this complaint.
There were no children born of issue as a result of this marriage.
There is no dispute as to the division of real property. There is no dispute as to any joint debts. There is
no dispute as to the division of personal property obtained before or during the marriage.
Plaintiffbrings this Complaint for Divorce on the grounds that the marriage is irretrievably broken
pursuant to 23 Pa.C.S. ~ 3301(C).
WHEREFORE, Plaintiffrespectfully prays:
(A) That Plaintiffbe granted a total divorce, avinculo matrimoni~
(B) That Plaintiffbe granted such other and further relief as the Court may deem just and fair.
~tephan~e M. Beecher, Pro Se
324 Walnut Lane, Carlisle, PA 17013
717-691-9787
Page 2
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Stephanie M. Beecher
Plaintiff
Christopher L. Beecher
Defendant
CIVIL ACTION NO.
VERIFICATION
Personally appeared before the attesting officer authorized by law to administer oaths, Stephanie M.
Beecher, who, first being duly sworn, on oath deposes and says that the facts alleged in the above and
foregoing are true and correct.
Stephanle M. Beecher, Affiant
Sworn and subscribed before me this. ¢ day of_~, 200~.
N~'t'~'eublic ~_~'~',.~ ' __ (~ -
· ACKNOWLEDGEMENT OF SERVICE AND WAIVER OF PROCESS
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Stephanie M. Beecher
Plaintiff
Vo
Christopher L. Beecher
Defendant
CIVIL ACTION NO.
ACKNOWLEDGEMENT OF SERVICE AND WAIVER OF PROCESS
COMES NOW, Christopher L. Beecher, defendant in the above styled case and acknowledges service
of the above styled complaint for divorce. Defendant further waives service and any other further
notice of subsequent hearings on this matter.
Christopher L. Beecher v/ .
Defendant
Sworn to and subscribed before me this ~ day of~_d~_, 2001.
Notarial Seal
Ta~lnly d. Mlslyan, Nota~/Public
Sou~ Mld~eton Twp., Cumberland Couont~
By ~ ~lr~ Ju~ 28, 2
M~ber, ~nn~ ~U~ ~
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Stephanie M. Beecher
Plaintiff
Christopher L. Beecher
Defendant
CIVIL ACTION NO.
CONSENT TO DIVORCE
COMES NOW the Plaintiff, Stephanie M. Beecher, and the Defendant, Christopher L. Beecher, in
the above-styled action and pursuant to 23 Pa.C.S. ~ 3301(C), give mutual consent to divorce, one
from the other. Defendant has waived service of process.
Step-hah-~e M. Beecher -
Plaintiff
Sworn and subscribed
Before me this ~ day
Of/Io~t~¢r- ,200~).
C '
hris~opher L. Beecher
Defendant
Sworn and subscribed
before me this c~ day
Of~, ~0-0 (~.
[sly'an, Notary
n TWO., Cumberland County
My Coftmllssion Expires June 28.
Member, Pennsylvania Assoc~flo~ ot Notaries
· ACKNOWLEDGEMENT OF SERVICE AND WAIVER OF PROCESS
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Stephanie M. Beecher
Plaintiff
CIVIL ACTION NO.
Vo
Christopher L. Beecher
Defendant
ACKNOWLEDGEMENT OF SERVICE AND WAIVER OF PROCESS
COMES NOW, Christopher L. Beecher, defendant in the above styled case and acknowledges service
of the above styled complaint for divorce. Defendant further waives service and any other further
notice of subsequent heatings on this matter.
Christopher L. Beecher~/~'/~
Defendant
Sworn to and subscribed before me this ~? day of~_.~ 2001.
Christopher Lynn Beecher
DEFENDANT.
{INTHECOURT OF COMMON PI~ASOF
{. Cumberland ~O~PENN~YLVA~
( CF~L DF~SION
[
[NO: 2001-04894
AFFIDAVIT OF CONSENT
1. A complaint in Divorce under Section 3301 (c) ofthe Divorce Code was ffied on (date:).s__/?fl / ~nnl
2. The marriage of the Plaintiff and Defendant is ineuievably broken and ninety days have elapsed from the
date of ~llng and Complaint.
3 I consent to the entry of a final decree of Divorce afte~ service of notice of intention to request entry of
the decre~
WAIVER OF NOTICE OF INTENTION TO REQUEST
]gNTRY OF A DIVORCE DECREE UNDER
SECTION 3301 [c) OF THE DIVORCE CODE
1. I consent to the entry of a final decree of Divorce without notice
2. I unde~umd 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 ngt be divorced until a Divorce decree is entered by the Court and that a copy of
the decree will be sent to me immediately aft~ it is filed with the prothonotary.
I verify that the statements made in tums affidavit are true and correct. I understand that false statements here-
in are made subject to the penalties of 18 Pa CS. Section 4904 relating to ,,n~vom falsification to anthoriti~s.
Date:
Stephanie Michelle Beecher
Christopher Lynn Beecher
DEFENDANT,
IN THE COURT OF COMMON PLEAS OF
Cumber 1 and .COUN~, PENNSYLVANIA
CT~L D~qSION
NO: 2001-04894
AFFIDAVIT OF CONSENT
1. A complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on (date.') 8 / ~o /_2D~l
2. The marriage of the Plaintiff and Defendant is irre~evably broken and ninety days have elapsed from the
date of filing and Complaint
3 I consent to the entry of a final decree of Divorce after service of notice of intention to request entry of
the decre~
WAIVER OF NOTICE OF INTENTION TO REQUEgF
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301 (c) OF THE DIVORGE GODE
1. I consent to the entry of a final decree of Divorce without notice.
2. I understand that I may lose fights 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 ~ed with the prothonotary.
I verify that the statements made in this affidavit are true and correct. I understand that false statements here-
in are made subject to the penalties of 18 Pa C.S. Section 4~)4 relating to unswom falsification to authorities.
Stephanie M. Beecher
PLAINTIFF,
Vo
Christopher L. Beecher
DEFENDANT.
( IN THE COURT OF COMMON PLEAS OF
(
( CUMBERLAND COUNTY, PENNSYLVANIA
(
( CIVIL DIVISION
(
( NO: 2001-04894
MARITAL PROPERTY SETTLEMENT AGREEMENT
THIS AGREEMENT, made this 1 day of
PLAINTIFF, Stephanie M. Beecher , residing at
(city) York Springs , Pennsylvania
called "Husband"/Wife," and
March ,2002 between
106 Cider Drive ~
17372 .(zip), hereinafter
DEFENDANT, Christopher L. Beecher , residing at 324 Walnut Lane
(city) Carlisle , Pennsylvania 17013 .(zip), hereinafter
called "Husband"/Wife."
WITNESSETH
WHEREAS, the parties were married on: (date) October 16, 1999;
WHEREAS, the parties filed for 3301 (c) Divome on: (date) August 20, 2001;
WHEREAS, the parties hereto desire to settle their property rights;
WHEREAS, both parties agree to relinquish any and all claims which either may have against
any property now owned or belonging to the other or which may hereinafter be acquired by either of them by
purchase, gift, devise, bequest, inheritance, or otherwise, except as to the obligations, covenants and agreements
contained herein; and
WHEREAS, both parties each have had opportunity to seek the benefit of competent and independent
legal advise by separate counsel.
1. INCORPORATION OF RECITALS
The recitals on Page 1 of this Agreement are incorporated herein as if set forth in full. Each paragraph
hereof shall be deemed to be a separate and independent covenant and agreement.
2. APPLICABLE LAW
This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania.
PROPERTY TO BE RETAINED BY WIFE.
Husband and Wife agree that, unless otherwise indicated in this agreement, the Wife shall keep all of her
own personal clothing and effects; and that the following property shall also be retained by the Wife:
(1) Oak Antique Bedroom Suite (Bed, Dresser with Mirror and Wash stand)
(1) Oak Full Length Mirror
(1) Berkline Reclining Sofa
(1) Pine Farm Table with 2 chairs
(1) Bissell Carpet Cleaner
(1) 27" Zenith TV with remote
(1) Oak Desk
(1) Cedar Chest
Collection of Longaberger Baskets
(1) Black and Decker Toaster Oven
(1) Full Mattress and Box Spring
(1) Pampered Chef Collection
(1) Red Mountain Bike
PROPERTY TO BE RETAINED BY HUSBAND.
Husband and Wife agree that, unless otherwise indicated in this agreement, the Husband shall keep all of his
own personal clothing and effects; and that the following property shall also be retained by the Husband:
(2) Pine Bar Stools
(1) Single Bed (Mattress, Box Spring and Bed Frame)
(1) Compaq Computer
(1) HP Printer
(1) Sofa bed
(1) Pine Comer Entertainment Center
(1) Gold Recliner
(2) Table Lamps
(1) Brass Floor Lamp
(1) Hoover Vacuum Cleaner
(2) Pine Chairs
(1) Antique Table
(1) Gas grin
(1) Lawn Mower
(1) Craftsman Weed Whacker
(1) Pine Unfinished Book Case
(1) Kenmore Washer
(1) Kemore Dryer
(1) Refrigerator
DEBTS TO BE PAID BY WIFE.
Husband and Wife agree that the wife shall pay the following debts and will not at any time hold the
Husband responsible for them:
(1) Cross Country Bank Visa Card, Amount owed $250.00
(1) Providian Visa Card, Amount owed $1,027.00
(1) Providian MasterCard, Amount owed $ 325.00
DEBTS TO BE PAID BY HUSBAND.
Husband and Wife agree that the Husband shall pay the following debts and will not at any time hold the
Wife responsible for them:
(1) Citi Financial Loan, in the amount of $3,737.30
Any and all debts that were accumulated before October 16,1999 (Student Loan, Credit Card Debt, Loans,
Vehicle Loans)
Any and all Utility bills past and present for the following address:
570 Range End Road, Apt #3
Dillsburg, PA 17019
831 East Louther Street
Carlisle, PA 17013
324 Walnut Lane
Carlisle, PA 17013
Any and all taxes associated with the residence at 324 Walnut Lane, Carlisle, PA 17013
PENSIONS AND/OR PROFIT SHARING PLANS, BANK ACCOUNTS, STOCKS, BONDS,
SECURITIES, CREDIT UNION ACCOUNTS, AND INDIVIDUAL RETIREMENT ACCOUNTS
Husband and Wife distribute the respective accounts as follows:
Husband and Wife will both retain each of their own 401K and Profit Sharing accounts in full.
8. REAL ESTATE
Husband will retain the real estate property at 324 Walnut Lane, Carlisle, PA 17013. Husband will take full
financial responsibility of the property including taxes and insurance. Wife will not be held financially
responsible for the property.
9. ALIMONY, ALIMONY PENDENTE LITE, SPOUSAL SUPPORT, EXPENSES AND ALL
MARTIAL RIGHTS
Each of the parties hereto release the other from subsequent claims for alimony, alimony pcndente lite, or
spousal support.
10. JOINT DEBTS
Husband and Wife warrant and certify to each other that there are no individual or joint martial obligations
outstanding, other than those listed in paragraphs 5 and 6 above.
11. DIVORCE
Husband and Wife agree that the marriage is irretrievably broken and will proceed with said Divorce under
23 Pa. C.A. Section 3301 (c).
12. TAX ADVICE
The transfers set forth herein may result in income, inheritance, estate and other tax consequences to the
parties. The parties specifically acknowledge that no attorney involved in the negotiating or drafting of this
Agreement has provided any tax advised regarding the dispositions contained herein. The parties have been
advised to seek separate tax counsel concerning the Divorce distributions.
IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the day and year first
above written.
On this ~T day of ~d ~.~ ,200 ~ , before me, a Notary Public, the
undersigned officer, personally appeared NAMES ~c__~¢,P~xE. F~:~£~V/:~ and
~oP~ ~ ~~e , ~o~ to me to be ~e pe~ons whose n~es ~e subscribed to ~e
~a~ insment, ~d ac~owl~ged ~at they executed ~e sine for ~e p~oses ~ein con.ned.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
Nota~-Phbiic '
Notarial Seal
Cynth a L. Thomas, Notary Public
Hampden Twp., Cumberland County
My Commission Expires Nov. 1,2004
Member, Pennsylvania Association of Notaries
Stephanie Michelle Beecher
;~hri stoDhe-r Lynn
DEFENDANT.
(INTHECOURTOF COMMON PLEAS OF
cumberland COUNTY, P~SYLVANIA
crVIL DMSION
{NO: 2001-04894
ACKNOi~.N. DGEN~T
Acompl~ntinIN¥orceund~Seclion330! (c) oftheDi~o~eCodewas~gedon-s ~20 /2001 .
I agree that the marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed
from the date of t~l!n[ the Complaint. All information contained within the attached documentation ts tree and
correct to the best of my knowledge, ir~ormation, and belief.
County Court of Common Pleas the.
It is my desire to fde with the C ~mh~r~ aha
attached Marital Property Settlement Agreement and to be bound fully and completely by the terms and
conditions as set forth within said Marital Property Settlement Agreement documentation.
iNwrrNEsSWHEEEOF, I set my hand and seal this ~--,..~,-i- day of ~-~J~L)~
cer, 1~ersonally appeared NAME ~'~9~-~ 1~-~-~-~-~. ~'
me to be the person whose name is subscribed to the written ir~umnent, and acknowledged that she executed
the same for the purposes therein contained.
IN WITNESS WHEREOF~ I hereunto set my hand and official seal.
Notary Public
Stephanie Michelle Beecher
jChri sto_oho-r Lynn
(INTHECOUI~OF COMMON PLEAS OF
( cumberland COUN~p~N~LV~qL~
-(
{ C~IL DIVL$1ON
(
(NO: 2001-04894
A complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on _ B / 20 /_2--001 .
- elap~l
pl_~iniiff alld D~eil-flint iS irret~ev~bly broken and ninety days have and
I agree that the marriage of the doo_,mentalion is lrue
from the date of t~lln~v the Compl*int All information con~ned ~hin the at~ched
correct to the best of my knowledge, information, and belief
Coun~J Court of Common Pleas the.
Iti~ my desire to file with the _ C?mh~r ~ ~na · - and completely by the terms
attsched Marital Property Settlement Ag~-~m~t ~ ~o be bound fully
.... , ..... ~ Marital Property Settlement Agreement doo:mentaffon.
conditions ~s set lorth w~v. nm ~u
N~m: ~hr,'~ ~¢r /- Z~ee c~ et'
me to be lhe person wno~c ~,~,, .
the same for the purposes therein contained.
IN ¥~rt~r~SS WHEREOF, I hereunto set my hand and offidal seal.
Notarial Seal. ~ -'lie
~a~issi~ Exp[~ Nov. 1,
.~om.,,. ........ "- . ........
c~ o
-- 0
...<
TIE FILE IALE E
PURSUANT TO THE 23 P.S. SECTION 4304-1(a3[3) PARTIES TO A DIVORCE ARE
REQUIRED TO PROVIDE THEIR SOCIAL SECURITY NUMBERS TO THE
COURT. PLEASE SUBMIT THE SOCIAL SE~ NUMBERS OF THE
pARTIES TO YOUR DIVORCE TO THE PROTHONOTARY.
PLEASE FILL 1N THE APPROPRIATE INFORMATION AND RETURN TO THE
PROTHONOTARY OFFICE--THESE INFORMATION SHEETS WILL BE KEPT IN
A SEPARATE FILE.
DATE:_ January 4, 2002
DOCKET NUMBER:
PLAIN~FF;PETr~ONER SS#: _181-68-5424
NAIVIE: Ste hanie Mi
DEFENDANT/RESPONDENTSS#:323-06-5617
NAME: Christo her
Office of Clerk of Recor&
Prothonotary Division
County Courthouse
DIVORCE INFORMATION SHEET
PURSUANT TO ACT 2001-82, VITAL STATISTIC FORMS ARE NOT
REQUIRED BY THE STATE EFFECTIVE JANUARY 1, 2002. THE
PROTHONOTARY IS REQUESTING THIS INFORMATION IN LIEU OF
THE VITAL STATISTICS FORM.
PLEASE FILL IN THE APPROPRIATE INFORMATION AND RETURN
TO THE PROTHONOTARY'S OFFICE.
DOCKET NUMBER:
DATE OF MARRIAGE:
_ Stephanie Michelle Beecher
Christopher Lynn Beecher
(INTHECOUKTOF COMMON PLEAS OF
( Cumberland COUNTY, PENNSYLVANIA
( CIVIL DWISION
(NO: 2001-04894
pRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Kindly Transmit the Record, together with the following information, to the Court for entry of a
divorce decree:
1. Ground for Divorce: irretrievable breakdown under Section 3301 (c) or ~id~ of the
Divorce COd~ {Strike out applicable section.)
2. DateandmarmerofserviceoftheComplaint~onoraboutGIVEDATE: August 20, 2001
via (cirde one]~xsonal Service~r Certified Mail.
3. (Complete either paragraph (a) or (b)0
(a) Date o£ execution of the Affidavit of ConsentdConsent Waiver required by Section 3301 (c) of the
Divorce Code: by Plaintiff ( I / ~ / o~); by Defendant ( / / ).
0a) (1) Date of execution of the Plaintiff's Affidavit required by Section 3301 (d) o£ the Divorce Code:
(2) Date of service of the Plaintiff's Affidavit required by Section 3301{d) of the Divorce Code:
o
Related claims pending:
Non~
pla~thef%
Ad&~: 106 cider Drive
York Springs, PA 17372
Phone: {717 } 528-4118
5. Date and manner of service of the Notice of Intention to file Praecipe to Transmit Record, a
copy of which is attached, if the Decree is to be entered under Section 3301 (d) of the Divorce Code~
~ ..<
IN THE COURT Of COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF ~
VERSUS
NO.
PENNA.
AND NOW, F~~
DECREED THAT ~.~)~l~i~_ ~r~c~\\e
AND Ch~-~oO-er t.,m,-, ~eec~,e c
Decree IN
DIVORCE
(~ec~e r
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
, IT iS ORDERED aND
, PLAINTIFF,
, DEFENDANT,
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD iN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENtered;
ATTEST:
PROTHONOTARY