HomeMy WebLinkAbout05-4399LISA L. RONAN,
Plaintiff
vs.
DWAIN D. RONAN,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
No. Zoos -Y3i9
IN DIVORCE
NOTICE
You have been sued in COUii. If you wish to defend against the olaims 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 he entered against you for any other claim or relief requested in
dxese 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 divorce is indignities or irretrievable breakdown of the marriage,
you may request marriage counseling. A list of marriage counselors is available at the Domestic
Relations Office. 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list
is kept as a convenience to you and you are not bound to choose a counselor from the list. All
necessary arrangements and the cost of counseling sessions are to be borne by you and your
spouse. If you desire to pursue counseling, you must make your request for counseling within
twenty (20) days of the date on which you receive this notice. Failure to do so will constitute a
waiver of your right to request counseling.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
COUNSEL FEF,S OR EXPENSES BEFORE THE FINAL 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, Pennsylvania 170 Li
(717)244-3166
LISA L. RONAN,
Plaintiff
vs.
DWAIN D. RONAN,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
NO.2005 - `Y.3~1~1
IN DIVORCE
COMPLAINT FOR DIVORCE UNDER SECTIONS 3301(c~ ar 3301(d~
OF THE DIVORCE CODE
COUNT I -DIVORCE
l . Plaintiff is Lisa Ronan, an adult individual who currently resides at 139 Kens Road,
Carlisle, Cumberland County, Pennsylvania 170]3 since 1998.
2. Defendant is Dwain D. Ronan, an adult individual who currently resides at l lb9 Easy
Road, Carlisle, Cumberland County, Pennsylvania ] 70 ] 3 since July 2005.
3. Plaintiff and Defendant have been a bona fide residents of the Commonwealth of
Pennsylvania for at least six months immediately previous to the filing of this Complaint.
4. Plaintiff and Defendant were married on December 3, 1994 in Cumberland County,
Pennsylvania.
5, There have been no prior actions of divorce or annulment between the parties.
6. The marriage is irretrievably broken.
7. Plaintiff has been advised of the availability of counseling and the right to request that
the Court require the parties to participate in counseling.
8. Defendant is not a member of the Armed Services of the United States or any of its
Allies.
4. Plaintiff avers that the grounds on which the action is based are:
a. Section 3301 (cl -the marriage is irretrievably broken.
b. Section 3301 (dl -the marriage is irretrievably broken and the parties are
now living separate and apart. Once the parties have lived separate and
apart for a period of two years, Plaintiff will submit an Affidavit alleging
that the parties have lived separate and apart for at least two years and that
the marriage is irretrievably broken. The parties have lived separate and
apart since April 25, 2005.
WHEREFORE, Plaintiff requests this Honorable Court to enter a decree in divorce,
divorcing the Plaintiff and Defendant.
Respectfully Submitted,
~~~
Megan alone, Esquire
Attorney for Plaintiff
Law Offices of LopezlVeuharth LLP
401 East Louther Street, Suite 101
Carlisle, PA 17013
(717) 258-9991
VERIFICATION
1 verify that the statements made in this Complaint 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. Section 4904, relating to unswom falsification to authorities.
Date: C~ ~7 ~~ /i~
Lisa Ronan
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LISA L. RONAN, : IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
vs. : CNIL ACTION -LAW
DWAIN D. RONAN, : NO. 2005 - 4399
Defendant : IN DIVORCE
Affidavit of Service
I, Megan Malone, Esquire hereby state that on August 27, 2005, i mailed by First Class
U.S. Mail and by Certified Mail, No.7004-2510-0003-5085-1339, Return Receipt Requested,
Addressee Only, a copy of the Complaint in Divorce to Defendant, Dwain Ronan, 1169 Easy
Road, Carlisle, Pennsylvania 17013, the last known mailing address of Defendant, which
documents were received on August 30, 2005, as evidenced by the attached Return Receipt Card.
Megan (alone
Law Offices of LopezNeuharth LLP
401 East Louther Street, Suite 101
Carlisle. PA 17013
(717)258-9991
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LISA L. RONAN, : IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY
PENNSYLVANI
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A
vs. :CIVIL ACTION -LAW
DWAIN D. RONAlV, : NO. 2005 - 4399
Defendant : IN DIVORCE
AFFIDAVIT OF CONSENT
1. A complaint in Divorce under § 3301(c) of the Divorce Code was filed on August 26,
2005.
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 of divorce.
4. I understand that I may have rights concerning alimony, division of property, lawyer's
fees or expenses if I do not claim them before a divorce is granted.
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. §4904 relating to unswort~
falsification to authorities.
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isa .Ronan
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LISA L. RONAN, : IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
vs. :CIVIL ACTION -LAW
DWAIN D. RONAN,
NO. 2005 - 4399
Defendant : IN DIVORCE
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 Waiver 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
falsification to authorities.
Date: d /. ,,7~f ,~~~
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MARRIAGE SETTLEMENT AGREEMENT
THIS AGREEMENT made this ~ ~~~ day of N 4 V e' Nl~jt,/ , 2006, by and
between LISA L. RONAN, (hereinafter referred to as "WIFE") and DWAIN D. RONAN,
(hereinafter referred to as "HUSBAND").
WITNESSETH:
WHEREAS, HUSBAND and WIFE were lawfully married on December 3, 1994, and
separated on or about Apri125, 2005; and
WHEREAS, diverse, unhappy differences, disputes and difficulties have arisen between
the parties and it is the intention of HUSBAND and WIFE to live separate and apart for the rest
of their natural lives, and the parties Hereto are desirous of settling fully and finally their
respective financial and property rights and obligation as between each other, including, but not
limited to the settling of all matters between them relating to the ownership and equitable
distribution of real and personal property, the settling of all claims and possible claims by one
against the other or against their respective estates, and the equitable distribution of property and
alimony for each party.
The parties hereto agree and covenant as follows:
The parties intend to maintain separate and permanent domiciles and to .live apart from
each. other. It is the intent and purpose of this Agreement to set forth the respective rights and
duties of the parties while they continue to live apart from each other.
2.
The parties have attempted to divide their marital property in a manner which conforms
to a just and right standard, with due regard to the rights of each party. It is the intent of the
parties that such division shall be final and shall forever determine their respective rights. The
division of existing marital property is not intended by the parties to constitute in any way a sale
or exchange of assets.
It is the intent of the parties hereto that this Agreement shall create contractual rights and
obligations entirely independent of any Court Order and that this Agreement may be enforced by
contract remedies in addition to any other remedies which may be available pursuant to the terms
of this Agreement or otherwise under law or equity. This Agreement may be incorporated into
the decree to be granted in any divorce action which may be filed by either party, but this
Agreement shall not merge with but shall survive the divorce decree and order, and the terms of
this Agreement shall not be open to modification by the Court. The parties further agree that the
Court of Common Pleas which may enter such divorce decree shall retain continuing jurisdiction
over the parties and the subject matter of the Agreement for the purpose of enforcement of any of
the provisions thereof.
3.
Further, the parties agree to continue living separately and apart from the other at any
place or places that he or she may select as they have heretofore been doing. Neither parry shall
molest, harass, annoy, injure, threaten or interfere with the other party in any matter whatsoever.
Each party may carry on and engage in any employment, profession, business or other activity as
he or she may deem advisable for his or her sole use and benefit. Neither party shall interfere
with the use, ownership, enjoyment or disposition of any property now owned and not specified
herein or property hereafter acquired by the other.
4.
The consideration for this contract and agreement is the mutual benefit to be obtained by
both of the parties hereto and the covenants and agreements of each of the parties to the other.
The adequacy of the consideration for all agreements herein contained is stipulated, confessed,
and admitted by the parties, and the parties intend to be legally bound hereby.
Each party to the Agreement acknowledges and declares that he or she, respectively:
(1) Is represented by counsel of his or her own choosing, or if not represented by
counsel, understands that he or she has the right to counsel: WIFE is represented
by Aazon J. Neuharth, Esquire of the Neuharth Law Offices; HUSBAND is
represented by Michael A. Scherer, Esquire of O'Brien, Baric & Scherer;
(2) Is fully and completely informed of the facts relating to the subject matter of
this Agreement and of the rights and liabilities of the parties;
(3) Is entering in#o this Agreement voluntarily after receiving the advice of
counsel or after choosing not to consult an attorney;
(4) Has given careful and mature thought to the making of this Agreement;
(5) Has carefully read each provision of this Agreement;
(6) Fully and completely understands each provision of this Agreement, both as to
the subject matter and legal effect of each provision.
This Agreement shall become effective immediately as of the date of execution.
5.
It is the purpose and intent of this Agreement to settle forever and completely the interest
and obligations of the parties in all property that they own separately, and all property that would
qualify as marital property under the Pennsylvania Divorce Code, Title 23, Section 3501(a), and
and antique bakelite, compact discs, one work bench, collection of Griswold iron skillets, one
carved and one concrete bear, antique high chair, wall clock, note box, lawn boy push mower,
bikes .for children, shadow box, picnic table, basketball net, fishing boat, children's toy boxes,
and a cash settlement of $19,000.00 ~~ 4-~ P«: cE' ~ ~,,;,~ .1t, ~,~~ ~ l y //• 2 y. ob , ` _
Any personal property not listed in this agreement shall be the sole and exclusive property of the ,~l
party in possession of said property at the time of execution of this agreement.
WIFE hereby waives all right, title and interest which she may have in any personal property of
the HUSBAND. HUSBAND likewise waives any right, title and interest which he has in the
personal property of WIFE. Henceforth, each of the parties shall own, have and enjoy
independently of any claim or right of the other party, all items of personal property of every
kind, nature and description and wherever situated, which are then owned or held by or which
may hereafter belong to HUSBAND or WIFE with full power to HUSBAND or WIFE to
dispose of the same as fully and effectually, in ail respects and for all purposes as if he or she
were unmarried.
Each party agrees that neither will incur obligations, liens or liabilities on account of the
other and that from the date of this Agreement, neither party shall contract or incur obligations,
liens or any liability whatsoever on account of the other.
10.
AUTOMOBILES: The parties agree that WIFE shall retain the 2000 Ford Taurus.
HUSBAND hereby waives all right, title and interest in any vehicle that WIFE currently owns or
any vehicle she may own in the future. WIFE shall hold HUSBAND harmless for any and all
liability associated with the use and purchase of any vehicle she may own, and shall be solely
responsible for all insurance and other financial responsibility associated with said vehicle.
HUSBAND shall retain the 1997 Ford Windstar GL Minivan, and the 1989 Ford F150
Short Bed Truck. WIFE hereby waives all right, title and interest in any vehicle that HUSBAND
currently owns or any vehicle he may own in the future. HUSBAND shall hold WIFE harmless
for any and all liability associated with the use and purchase of any vehicle he may own, and
shall be solely responsible for all insurance and other financial responsibility associated with said
vehicle.
11.
MARITAL DEBTS & BANKRUPTCY: It is further mutually agreed by and between
the parties that WIFE shall assume all liability for and pay and indemnify HUSBAND against all
debts incurred by WIFE after the date of separation. WIFE represents and warrants to
HUSBAND that since the parties' mutual separation she has not contracted or incurred any debt
or liability for which HUSBAND or his estate might be responsible and WIFE further represents
and warrants to HUSBAND that she will not contract or incur any debt or liability after the
execution of this Agreement, for which HUSBAND or his estate might be responsible. WIFE
shall indemnify and save HUSBAND harmless from any and all claims or demands made against
him by reason of debts or obligations incurred by her.
HUSBAND shall assume all liability for and pay and indemnify the WIFE against all
debts incurred by HUSBAND after the date of separation. HUSBAND represents and warrants
to WIFE that since the parties' marital separation he has not contracted or incurred any debt or
liability for which WIFE or her estate might be responsible and HUSBAND further represents
and warrants to WIFE that he will not contract or incur any debt or liability after the execution of
this Agreement, for which WIFE or her estate might be responsible. HUSBAND shall
indemnify and save WIFE harmless from any and all claims or demands made against her by
reason of debts or obligations incurred by him. The parties further acknowledge the existence of
their own names for which each shall be responsible for the payment of and indemnify and hold
harmless the other party from said balances.
12.
INSURANCE AND EMPLOYEE BENEFITS: The parties agree that any employee
benefits of HUSBAND yr WIFE including but not limited to retirement, profit sharing or medical
benefits of either party, shall be their own. HUSBAND waives all right, title and claim to
WIFE' S employee benefits, and WIFE waives all right, title and claim to HUSBAND' S
employee benefits, except as follows:
Wife agrees to transfer the amount of $24,197.00 via Qualified Domestic Relations Order
(QDRO) prepared by Wife's attorney to an account that Husband designates.
The parties hereby waive any and all rights he or she may have in any life insurance policy
of the other party. Each party is free to designate a beneficiary of his or her choosing.
13.
BENEFITS. STOCK AND BANK ACCOUNTS: HUSBAND shall retain the bank
accounts for the parties children, Meg and David Ronan. WIFE shall retain all monies in the Tap
529 college accounts for the parties children, Meg and David Ronan.
WIFE agrees to waive all right, title and interest which she may have in the savings or
checking or any other bank accounts of HUSBAND and likewise HUSBAND agrees to waive all
right, title and interest which he may have in the savings or checking or any other bank accounts
of WIFE.
14.
DIVORCE: Wife filed a divorce action in the Court of Common Pleas of Cumberland
County at 2005-4399 on August 26, 2005. It is agreed that this Agreement may be filed at said
divorce action and incorporated into, but will not merge with, the decree to be entered therein.
15.
RECONCILIATION: Husband and Wife shall only effect a legal reconciliation which
supersedes this Agreement by their signed Agreement containing a specific statement that they
have reconciled and that this Agreement shall be null and void. In the absence of such written
Agreement, this Agreement shall remain in full force and effect. Any attempt at reconciliation
which is not consummated by the above-referenced Agreement shall not amend or otherwise
affect the terms and conditions of this Agreement, nor cause any new marital rights or obligations
to accrue.
16.
BREACH: If either party breaches any provisions 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 legal fees and costs incurred by the other in enforcing their rights
under this Agreement.
17.
SEVERABILITY: If any term, condition, clause or provision of this Agreement shall be
determined or declared to be void or invalid in law or otherwise, then only that term, condition or
clause shall be stricken from this Agreement, and in all other respects, this Agreement shall be
valid and continue in full force and effect.
18.
ADDITIONAL INSTRUMENTS: Each of the parties shall from time to time, at the
Commonwealth of Pennsylvania.
22.
PRIOR AGREEMENTS: It is understood and agreed that any and all property
settlement agreements which may or have been executed prior to the date and time of this
Agreement are null and void and of no effect.
23.
PAYMENT OF COSTS: Each party shall be responsible for his or her own attorneys
fees and costs incurred in the filing of the divorce and settlement of economic issues involved
therein, including, but not limited to, support issues.
24.
WAIVER OF CLAIMS AGAINST ESTATES: Except as herein otherwise provided,
each party may dispose of his or her property in any way, and each party hereby waives and
relinquishes any and all rights he or she may now have or hereafter acquire, under the present or
future laws of any jurisdiction, to share in the property or the estate of the other as a result of the
marital relationship, including without limitation, dower, curtesy, statutory allowance, widow's
allowance, right to take in intestacy, right to take against the Will of the other, and right to act as
administrator or executor of the other's estate, and each will, at the request of the other, execute,
acknowledge and deliver any and all instruments which may be necessary or advisable to carry
into effect this mutual waiver and relinquishment of all such interests, rights and claims.
IN WITNESS WHEREOF, the parties hereunto have set their hands and seals the day
and year first above written.
WITNESS:
~~- (SEAL)
SA .RONAN
t > ~~AL)
DWAIN D. RONAN
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF C ,
PERSONALLY APPEARED BEFORE ME, this day of
2006, a Notary Public, LISA L. RONAN, known to me (or satisfactorily proven) to be the
person whose name is subscribed to the within Marriage Settlement Agreement, and
acknowledges that she executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and official seal.
Notary Public
COMMONWEALTH OF PENNSYLVANIA
SS:
COUNTY OF ~~I~i:IN C.c.~~ be~~a nc~ ,
PERSONALLY APPEARED BEFORE ME, this ~ 3~d day of (~ 0 ~ erY- ~;~ ,
2006, a Notary Public, DWAIN D. RONAN, known to me {or satisfactorily proven) to be the
person whose name is subscribed to the within Marriage Settlement Agreement, and
acknowledges that he executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and official seal.
Notary Public
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Amanda L. Fisher, Notary Public
Carlisle Boro, Cumberland County
My Commission Expires Apr. 17, 2010
Member, Pennsylvania Association of Notaries
COMMONWEALTH OF PENNSYLVANIA
SS
COUNTY OF FRANKLIN
Acknowledgment and Affidavit Taken Before Attorney at Law
On this o~ ,Q-`~ of ~-~ , 2006, before me, ~ ~ ~ ~ ~ r ~~ ~~P~ ,the
undersigned officer, personally appeared, Aaron J. Neuharth, Esquire, known to me or
satisfactorily proven to be a member of the highest Court of the Commonwealth of Pennsylvania,
and certified that he is a subscribing witness to the foregoing Marriage Settlement Agreement and
was personally present when the forgoing Marriage Settlement Agreement was executed by Lisa
Ronan and that Lisa Ronan acknowledged that she executed said agreement for the. purposes
contained therein.
In witness thereof, I hereunto set my hand and official seal.
f ~n~.ee~
O O~y H P PENNSYLVANIA
Notarial Seal
Linda E. Miller, Notary Public
Chambersburg Boro Franklin County
My commission Facpiies Sept. 21, 2007
Member, Ponns~~ivania Association of Notaries
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LISA L. RONAN,
Plaintiff
V.
DWAIN D. RONAN,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2005-4399 CIVIL
CIVIL ACTION-LAW
IN DIVORCE
1. A complaint in divorce under Section 3301(c), or 3301(d) of the Divorce Code
was filed on August 26, 2005.
3. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety
days have elapsed from the date of the filing of the Complaint.
3. I consent to the entry of a final decree in divorce without notice.
4. 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.
5. 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.
6. I have been advised of the availability of marriage counseling and understand
that I may request that the court require counseling. I do not request that the court require
counseling.
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.A. Section 4904
relating to unsworn falsification to authorities.
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Date: ~ ~Z , 2007 "~
Dwain D. onan
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LISA L. RONAN, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 2005-4399 CIVIL
DWAIN D. RONAN, CIVIL ACTION-LAW
Defendant 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 fordivorce: irretrievable breakdown under Section 3301(c)of the Divorce
Code.
2. Date and manner of service of the Complaint: Defendant received Divorce Complaint
via U.S.P.S. Certified Mail on August 30, 2005.
3. (complete either paragraph (a) or (b).)
A. Date of execution of the affidavit of consent required by Section 3301(c} of
the Divorce Code: by Plaintiff on November 24, 2006; and Defendant on March 12, 2007.
B. (1) date of execution of the Plaintiffs Affidavit required by Section 3301(d)
of the Divorce Code: N/A
(2) date of service of the Plaintiffs Affidavit upon the Defendant: N/A
4. Related claims pending: None.
5. Indicate date and manner of service of the notice of intention to file praecipe to transmit
record, and attach a copy of said notice under section 3301(d)(1)(i) of the Divorce Code: The
parties signed Waivers of Notice of Intent to Request Entry of Divorce Decree.
Respectfully submitted,
O'BRIEN, BARK & SCHERER
Michael A. Sch er, Esquire
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LISA L. RONAN, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
v. CIVIL ACTION -LAW
DWAIN D. RONAN,
Defendant NO. OS-4399 CIVIL TERM
ORDER OF COURT
AND NOW, this 15t" day of March, 2007, upon consideration of Plaintiff's
praecipe to transmit the record in the above-captioned matter, and it appearing that
Plaintiff's affidavit of consent was not filed within the 30-day time period as required, a
divorce decree will not be entered at this time, without prejudice to the parties' rights to
correct the deficiency and file a new praecipe to transmit the record.
BY THE COURT,
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J.
ichael A. Scherer, Esq.
19 West South Street
Carlisle, PA 17013
Attorney for Plaintiff
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'' LISA L. RONAN,
Plaintiff
v.
DWAIN D. RONAN,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2005-4399 CIVIL TERM
CIVIL ACTION-LAW
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 Section 3301(c) of the
Divorce Code.
2. Date and mannerofservice of the Complaint; Service upon the Defendant via U.S.
certified mail on August 30, 2005.
3. (complete either paragraph (a) or (b}.)
A. Date of execution of the affidavit of consent required by Section 3301(c) of
the Divorce Code: by Plaintiff on April 4, 2007; and Defendant on March 12, 2007.
B. (1) date of execution ofthe Plaintiffs Affidavit required by Section 3301(d)
of the Divorce Code: N/A
(2) date of service of the Plaintiffs Affidavit upon the Defendant: N/A
4. Related claims pending: None.
5. Indicate date and manner of service of the notice of intention to file praecipe to
transmit record, and attach a copy of said notice under section 3301(d)(1)(i) of the Divorce Code:
The parties signed Waivers of Notice of intent to Request Entry of Divorce Decree.
Respectfully submitted,
O'BRIEN, BARK & SCHERER
c erer, Esquire
19 West South Street
Carlisle, Pennsylvania 17013
(717) 249-6873
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LISA L. RONAN, : IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
vs. :CIVIL ACTION -LAW
DWAIN D. RONAN, : NO.2005 - 4399
Defendant : IN DIVORCE
AFFIDAVIT OF CONSENT
1. A complaint in Divorce under § 3301(c) of the Divorce Code was filed on August 26,
2005.
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 of divorce.
4. I understand that I may have rights concerning alimony, division of property, lawyer's
fees or expenses if I do not claim them before a divorce is granted.
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. §4904 relating to unsworn
falsification to authorities.
Date: ~ .~p~1 ~ ~ , 02 007 `
rsa .Ronan
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LISA L. RONAN,
Plaintiff
vs.
DWAIN D. RONAN,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
N0.2005 - 4399
IN 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 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 Waiver 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
falsification to authorities.
Date: 2~ ~ ~/ , 2007 ~
isa .Ronan
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t N THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNT'
STATE OF ~~ PENNA.
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LISA L. RONAN
Plaintiff
VERSUS
DWAIN D. RONAN,
Defendant
N O. 2005-4399 Civil
DECREE IN
DIVORCE
A,ND NOW, ~ ~ ~ 26°~, IT VS ORDERED AND
DECREED THAT LISA L. RONAN PLAINTIFF,
AND
DWAIN D. RONAN DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
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;
The parties Marital SE~ttlement Agreement dated November 13,2006
is incorporated but not merged herein as a final Order of Court.
BY THE COURT:
ATT T: ~ V J
~, PROTHONOTARY
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Lisa L. Ronan, : IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
v. :CIVIL ACTION -LAW
Dwain D. Ronan, : NO.2005 - 4399
Defendant : IN DIVORCE
QUALIFIED DOMESTIC RELATIONS ORDER
AND NOW THIS 16 ~ day of , 2007 it appears to the Court as
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follows:
1. The parties hereto were husband and wife, seek this Order in conjunction with a final
decree of dissolution of marriage dated April 18, 2007 in that action pending in this Court at the
above number.
2. Lisa L. Ronan, SSN: 201-62-6663, hereinafter referred to as "Participant," is
employed by Shippensburg University, is a participant in the Teachers Insurance and Annuity
Association -College Retirement Equities Fund, Hereinafter "TIAA-CREF" and has the
following annuities:
TIAA Retirement Annuities & Mutual Funds Contract Numbers: TIAA C535397-8,
CREF U535397-6
TIAA Group Retirement Annuities and Mutual Funds Contract Numbers: TIAA
3545055-0, CREF 4545055-8
Supplemental Retirement Annuities and Mutual Funds Contract Numbers: TIAA
L915443-0, CREF M915443-8
Lisa L. Ronan's current and last known mailing address is 139 Kerrs Road, Carlisle,
Pennsylvania 17015-9408 and daytime telephone number is 717-4771124.
3. The Alternate Payee is Dwain D. Ronan whose current and last known mailing
'y.
address is 101 Meals Drive, Carlisle, Pennsylvania 17013.
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The Alternate payee's Social Security Number is 198-50-6187, date of birth is
November 10, 1957, and daytime telephone number is 717-385-0488.
4. To the martial property distribution between the parties, IT IS ORDERED,
ADJUDICATED AND DECREED AS FOLLOWS:
A. That TIAA-CREF annuities previously-referenced are marital property:
B. Upon finalization of this Order and pursuant to the terms of said annuities, the
current values as of the valuation date of the Participant's TIAA-CREF
annuity accumulations for the Marital Portion defined below shall be awazded
as the Alternate Payee's sole and exclusive property to be applied to TIAA-
CREF annuities subject to the terms and limitations of said annuities.
i. The marital portion to be transferred to the Alternate Payee from
Participant's TIAA-CREF annuity accumulations has been determined
to be twenty-four thousand one-hundred ninety-seven dollazs
($24,197.00). Accumulations are to be valued as of November 13,
2006.
a. The marital portion to be transferred to the Alternate Payee
from Participant's TIAA-CREF annuity accumulations shall be
transferred to Alternate Payee in the amounts listed herein from the
from Participant's Funds as follows:
TIAA Retirement Annuity & Mutual Funds Contract Numbers:
TIAA C535397-8, CREF U535397-6, sixty-two percent (62%).
TIAA Group Retirement Annuities and Mutual Funds Contract
Numbers: TIAA 3545055-0, CREF 4545055-8, twenty-nine
percent (29%).
Supplemental Retirement Annuities and Mutual Funds Contract
Numbers: TIAA L915443-0, CREF M 915443-8, nine percent
(9%).
C. Conditions of division of annuity contracts:
i. All ownership and interest in the balance of the accumulations not
transferred in all annuities issued to the Participant by TIAA-CREF
will belong to the Participant.
ii. All ownership rights in the newly-issued annuities will belong to the
Alternate Payee.
iii. The beneficiary designation of the Alternate Payee's annuities will be
his or her estate, unless a beneficiary designation is submitted pursuant
to the provisions of the contracts, and accepted by TIAA-CREF. The
Alternate Payee must review the contracts at issuance for accuracy and
inform TIAA-CREF of any change of address.
iv. The Alternate Payee's annuities will be issued with the same
investment allocation as the Participant's applied pro rata. The
Alternate payee may change the investment allocation once his or her
annuities are issued in accordance with the contributing employer's
plan.
D. Termination of Alternate Payee's status as beneficiary of record:
i. As of the date of TIAA-CREF's receipt of the QDRO, all TIAA-
CREF's benefits otherwise payable to Alternate Payee as beneficiary
aze payable to the estate of the Participant. The Participant retains the
right to change the designation.
E. TIAA Traditional Retirement Annuities (RA's) do not allow single-sum
withdraws or transfers to alternate carvers. For other TIAA-CREF annuities,
the Alternate Payee's right to receive single-sum withdraws and/or transfer all
or part of the accumulation to an alternate carrier may be limited in
accordance with the contributing employer's plan.
F. The parties are directed to submit to TIAA-CREF all documents and releases
(if required by TIAA-CREF) to finalize this Order within thirty days of the
request for same.
5. This Order:
A. does not require any plan to provide any type of form of benefit, or any
options not otherwise provided under the plan, and
B. does not require TIAA-CREF to provide increased benefits, and
C. does not require the payment of benefits to an Alternate Payee which are
required to be paid to another Alternate Payee under another Order previously
determined to be Qualified Domestic Relations Order.
D. If any portion of this Order is rendered invalid, the balance of the order will
remain fully enforceable.
6. The Court reserves jurisdiction to issue further orders as needed to execute this Order.
By the Court,
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Participant, Date:
Lisa L. Ronan
Alternate Payee, Date: ~-" ZD ~n 7
Dwain D. Ronan
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