HomeMy WebLinkAbout04-5399SUSAN E. ANSPACH,
Plaintiff
BENJAMIN A~ ANSPACH
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - DIVORCE
NO. ~/- ~3,'2~ CIVIL TERM
IN DIVORCE
SAIDIS
SHuFF, FLOWER
& LINDSAY
_~,~,~w.
26 W. Hl~h Su'eeE
Carlisle, PA
NOTICE
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, 17013.
IM FOR ALIMONY, DIVISION OF PROPERTY,
IF YOU DO NOT FILE A___C_L~_~ ,, '"=r'REE OF DIVORCE OR ANNULMENT IS
S OR EXPENSES 61:I'uM" ~
LAWYERS FEE _ mr. T TO CLAIM ANY OF THEM.
· ,.~,~,o'rcn YOU MAY LOSE THE .... H
~a.~, ...... _ ..... ,= vnll DO NOT
YOU SHOULD TAKE THIS pAPER TO YOUR LAWYER Al
R OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET
HAVE A LAWYE ......... u=~c U CAN GET LEGAL HELP.
FORTH BELOW TO FIND uu/vvn~,~,- YO
CUMBERLAND COUNTY BAR ASSOCIATION
32 BEDFORD STREET
CARLISLE, PENNSYLVANIA 17013
(717) 249-3166
SAIDIS, SHUFF, FLOWER & LINDSAY
Attorneys for Plaintiff
By:_
26 West High Street
Carlisle, PA 17013
(717) 243-6222
SUSAN E. ANSPACH,
Plaintiff
BENJAMIN A. ANSPACH
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - DIVORCE
NO. oy- 5'3 9 ? CIVIL TERM
IN DIVORCE
COMPLAINT
Susan E. Anspach, Plaintiff, by attorneys, SAIDIS, SHUFF, FLOWER & LINDSAY,
respectfullY represents:
1. The Plaintiff is Susan E. Anspach, who currently resides at 15 Focht Road,
Robesonia, Berks County, Pennsylvania, 19551 where she has resided since October
1,2004.
2. The Defendant is Benjamin A. Anspach, who currently resides at 941
Woodbridge Drive, Enola, Cumberland County, Pennsylvania, 17025 where he has
resided since 1986.
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 July 21, 1978, at Wormleysburg,
SAIDiS
sHUFF, FLOWER
& LINDSAY
26 W. High Stree~
Pennsylvania.
5. That there have been no prior actions of divome or for annulment between
the parties in this or in any other jurisdiction.
6. The Plaintiff avers that she is entitled to a divorce on the ground that the
marriage is irretrievably broken and Plaintiff is proceeding under Sections 3301 (c)
and/or (d) of the Divorce Code.
7. Plaintiff has been advised of the availability of marriage counseling and of the
right to request that the Court require the parties to participate in marriage counseling,
and does not request counseling.
WHEREFORE, Plaintiff requests the Court to enter a decree of divorce.
SAIDIS, SHUFF, FLOWER & LINDSAY, P.C.
Attorneys for Plaintiff
26 West High Street
Carlisle, PA 17013
(717) 243-6222
SAIDIS
SIttJFF, FLOWER
LINDSAY
w. t~l~h St~et
Carlisle. PA
VERIFICATION
I, the undersigned, hereby verify that the statements made herein are tree and
correct. I understand that false statements herein are made subject to the penalties of
18 Pa. C.S. § 4904, relating to unsworn falsifi_cai7auth°rities'
Susan E. Anspach
Date:_
SAIDIS
StlUFF, FLOWEn
& LINDSAY
26 W. Hi~lt Street
SUSAN E. ANSPACH, :
Plaintiff :
..
VS. .'
BENJAMIN A. ANSPACH :
Defendant :
.'
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION- DIVORCE
NO. ~- j~'3c7c~ CIVILTERM
IN DIVORCE
ACCEPTANCE OF SERVICE
I, BENJAMIN A. ANSPACH, Defendant above, accept service of the Complaint
in Divorce in the above captioned matter.
Benja~mi A. Anspach, Defendant
SUSAN E. ANSPACH,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
BENJAMIN A. ANSPACH
Defendant
CIVIL ACTION - DIVORCE
NO. 04-5399 CIVIL TERM
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under 93301 (c) of the Divorce Code was filed October 27,2004.
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. I 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 falslflca~)authonties.
~/1 I ~ ~ lt~?<< u,& Cit,
I Benja n A. Anspach, Defen ant
Date:
A
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF
A DIVORCE DECREE UNDER!; 3301 (C:l 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 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:
JII/tJ~
~UM (U;~ li G~
Benjamin A. Anspach, Defendan
cl
('.I
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c:-
SAIDIS
SHUFF, FLOWER
& LINDSAY
ATIORNEYS.AT.LAW
26 W. High Street
Carlisle, P A
SUSAN E. ANSPACH,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V5.
BENJAMIN A. ANSPACH
Defendant
CIVIL ACTION - DIVORCE
NO. 04-5399 CIVIL TERM
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under !;3301 (c) of the Divorce Code was filed October 27, 2004.
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. I 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 aut rities.
Date:
et/cr ~j
I /
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF
A DIVORCE DECREE UNDERIi 3301 eel 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 to the best of rny
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:
~/q~~
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~
Susan E. Anspach, Plaint;
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(r)
SUSAN E. ANSPACH,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V5.
BENJAMIN A. ANSPACH
Defendant
CIVIL ACTION. DIVORCE
NO. CIVIL TERM
IN DIVORCE
PROPERTY SETTLEMENT AND SEPARATION AGREEMENT
THIS AGREEMENT made this /dl day Of~'2004'
BY AND BETWEEN Susan E. Anspach, of 15 Foch Road, Robesonia, Berks
County, Pennsylvania 19551, hereinafter referred to as Wife, AND Benjamnin A.
Anspach, of 941 Woodbridge Drive, Enola,Cumberland County, Pennsylvania 17025,
hereinafter referred to as Husband.
RECITALS:
R.1: The parties hereto are husband and wife, having been joined in
marriage on, July 21, 1978 at Wormleysburg, 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
() QO <-;- "3 7r <-rr
, 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, of all matters
between them relating to the ownership of real and personal property, claims for
spousal support, alimony, alimony pendente lite.
NOW THEREFORE, in consideration of the covenants and promises
1
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 molesll 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. Wife has filed a complaint in divorce and Husband
shall accept service of the complaint. Ninety days after the service is made, the
parties will execute affidavits of consent and waivel"s of notice and provide those to
Wife's counsel so that the divorce can be finalized.
If either party fails or refuses to execute the affidavits of consent and waivers
of notice within ten (10) days of a request by the other party, then, the other party can
at his or her sole discretion terminate this agreement and the parties can proceed
through the courts to equitable distribution and alimony.
(3) REAL PROPERTY: The parties are the owners of certain real estate
2
with improvements thereon erected and known and numbered as 941 Woodbridge
Road, Enola, Cumberland County, Pennsylvania 17025. Husband shall receive the
house in equitable distribution. He shall refinance the house within sixty (60) days of
the date of this agreement. At the time of refinance, Wife shall execute a deed
provided by Husband to transfer to him all her right title and interest in the marital
home. Pending refinance and thereafter Husband shall be solely and exclusively
responsible for any obligations on account of the marital home including but not
limited to the mortgage payment, taxes, insurance ,md utilities and he shall indemnify
and hold the Wife harmless on account of any claim by any creditor for claims
resulting of ownership of the marital home. At the time of the refinance Husband
shall pay to Wife $60,000.00.
(4) DEBT:
A. Marital Debt: Husband and Wife acknowledge and agree that there
are no outstanding debts and obligations which are marital or for which the other
might be liable incurred prior to the signing of this Agreement.
Should the parties become aware of any such debt they shall be the sole
and exclusive responsibility of Husband to pay.
B: Post Separation Debt: In the event that either party contracted or
incurred any debt since the date of separation on October 1, 2004, 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
3
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. Within ten (10) days of the date of this agreement each party shall execute
any documents necessary to have said vehicles properly registered in the other
party's name with the Pennsylvania Department of Transportation. Each party shall
assume full responsibility of any encumbrance on the motor vehicle received by said
party, and shall hold harmless and indemnify the olther party from any loss thereon.
Husband shall retain the 2004 Honda CRY. Husband shall be solely responsible for
the obligation to Honda Credit Corporation and shall indemnify and hold Wife
harmless on account of that obligation. Within ten (10) days of the date of this
agreement, Husband shall refinance the obligation to Honda Credit Corporation so
Wife is no longer liable thereon. Wife will retain the '1994 Honda Civic.
(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
4
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.
Attached hereto as Exhibit "A" is a list of personal property which shall be the
sole and exclusive of Wife. Husband agrees that Wife may store those items of
personal property which she will retain at the marital home. Husband will keep them
safe until such time as Wife can remove them from the home.
(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, Husband will
retain his pension plan, his Legg Mason account and any life insurance policy which
he owns. Wife will retain her Legg Mason account, her pension plan and any life
insurance policy which she may own.
(8) ALIMONY: 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
5
been provided a copy of this agreement with which to consult with counsel, Wife is
represented by Carol J. Lindsay and, Husband has been advised that he may be
represented by counsel of 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.
(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:
A: 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
6
separate income on the aforesaid joint returns.
B: For the tax year ending December 31, 2004 the parties may
decide whether they wish to file a joint tax return or individual tax returns. In the event
they decide to file a joint tax return, they may decide the manner in which they wish to
pay any additional tax owed to the Internal Revenue Service or dispose of any tax
refund which they rnay receive. They also may decide on a division of costs for the
preparation of the return.
(12) BANKRUPTCY: The parties hereby agree that the provisions of this
Agreernent shall not be dischargeable in Bankruptcy and expressly agree to reaffirrn
any and all obligations contained herein. In the event a party files such bankruptcy
and pursuant thereto obtains a discharge of any obligations assurned hereunder, the
other party shall have the right to declare this Agreement to be null and void and to
terrninate 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 sarne 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 inforrned of, and
is familiar with, the wealth, real and personal property, estate and assets, earnings
and incorne of the other and has made any inquiry he or she desires into the incorne
or estate of the other and received any such inforrnation requested. Each has made a
full and cornplete disclosure to the other of his and her entire assets, liabilities,
in corne and expenses and any further enumeration or statement thereof in this
7
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
8
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, lIiabilities 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;
I. All rights, claims, demands, liabilities and obligations each party now
9
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 A!;)reement 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
10
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 hands and seals the day and year first written above.
,ovP~
\
Benjam n A.
WITNESS:
11
EXHIBIT A - LIST
PIE SAFE CABINET
ROCKING CHAIR (FAMILY ROOM)
CHAIR (DINING ROOM)
TABLE ON PORCH
CHAIR (LIVING ROOM)
BUREAU (FRONT BEDROOM)
SMALL DRESSER (BACK BEDROOM)
COFFEE TABLE (FAMILY ROOM)
BOOK CASE (KITCHEN)
BOOK CASE (BASEMENT)
SCHOOL BENCH
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SUSAN E. ANSPACH,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
BENJAMIN A. ANSPACH
Defendant
CIVIL ACTION - DIVORCE
NO. 04-5>399 CIVIL TERM
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the following information to the court for entry of a
divorce decree:
1. Ground for divorce:
Irretrievable breakdown under 3301 (c)
3301 (d) (1) of the Divorce Code.
(Strike out inapplicable section)
2. Date and manner of service of the complaint: Acceptance of Service on
Defendant dated October 29, 2004 and filed with Prothonotary on
November 1, 2004.
3. Complete either paragraph (a) or (b).
a. Date of execution of the affidavit of consent required by 3301 (c) of the
Divorce Code:
by plaintiff Februarv 9. 2005:- by defendant: Februarv 7. 2005
b. (1) Date of execution of the affidavit required by 3301 (d) of the Divorce
Code:
(2) Date of filing and service of the plaintiff's affidavit upon the
respondent:
4. Related Claims pending: None: The terms of the Property Settlement and
Separation AQreement of November 10, 2004 are incorporated but not
merQed into the Decree in Divorce
4
Complete either (a) or (b)
a. Date and manner of service of the notice of intention to file Praecipe to
transmit record, a copy of which is attached:
b. Date of plaintiff's Waiver of Notice in 3301 (c) Divorce was filed with the
Prothonotary: Februarv 11. 2005
Date defendant's Waiver of Notice in 3301 -Piv ce was filed with the
, ,
Prothonotary: February 10. 20.05
/ .
SAIDIS
SHUFF, FLOWER
& LINDSAY
ATTORNEYS-AT-LAW
26 w. High Street
Carlisle, P A
{tuu
Carol J. Lindsay,
Supreme Court I
Said is, ShufLE er & Lindsay
26 West High Street
Ca{psle PA 17013
Phone: 717.243.6222
Attorney for Plaintiff
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF
PENNA.
SUSAN E. ANSPACH
PLAINTIFF
No.
04-5399
VERSUS
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DEFENDANT
DECREE IN
DIVORCE
AND NOW,
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Zcof, IT IS ORDERED AND
DECREED THAT
Susan E. Anspach
AND
Benjamin A. Anspach
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
, PLAINTIFF,
, DEFENDANT,
THE COURT RETAINS JURISDICTION OF THE FOl.LOWING CLAIMS WHICH HAVE
YET BEEN ENTERED;
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
None.
The terms of the Property Settlement and Separation Agreement of
Nmvember 10, 2004 are incorporated but not merqed into the Decree in Divorce
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By THE COUR4d
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PROTHONOTARY
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