HomeMy WebLinkAbout06-2395Johnson, Duffle, Stewart & Weidner
By: Melissa Peel Greevy
I.D. No. 77950
301 Market Street
P. O. Box 109
Lemoyne, Pennsylvania 17043-0109
(717) 761-4540
Attorneys for Plaintiff
MARISSA SEEGER, IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
NO. CSC ?295 l 'ir?cC l
V.
CIVIL ACTION - LAW
GEORGE E. SEEGER, JR.,
IN DIVORCE
Defendant
NOTICE TO DEFEND AND CLAIM RIGHTS
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 Courthouse, Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE THE 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS
OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
Telephone: (717) 249-3166
Johnson, Duffle, Stewart & Weidner
By: Melissa Peel Greevy
I.D. No. 77950
301 Market Street
P. O. Box 109
Lemoyne, Pennsylvania 17043-0109
(717) 761-4540
Attorneys for Plaintiff
MARISSA SEEGER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
GEORGE E. SEEGER, JR.,
Defendant
NO. 06 - 1391
CIVIL ACTION - LAW
IN DIVORCE
COMPLAINT IN DIVORCE
UNDER SECTIONS 3301(c) OR 3301(d) OF THE DIVORCE CODE
AND NOW, comes the Plaintiff, Marissa Seeger, by and through her attorneys, Johnson,
Duffie, Stewart & Weidner, and files the following Divorce Complaint against the Defendant,
George Seeger:
1. The Plaintiff is Marissa Seeger, an adult individual, residing at 775 Erford Road,
Camp Hill, Cumberland County, Pennsylvania 17011. Plaintiffs Social Security Number is 187-
62-9160.
2. The Defendant is George E. Seeger, an adult individual, residing at 69 Fairview
Street, Carlisle, Cumberland County, Pennsylvania 17013. Defendant's Social Security Number
is 176-54-3846.
3. The Plaintiff and Defendant were married on May 27, 2000 in Mechanicsburg,
Cumberland County, Pennsylvania.
4. The Plaintiff has been a bona fide resident of the Commonwealth of
Pennsylvania at least six months immediately prior to the filing of this Complaint.
5. There have been no prior actions for divorce or annulment of marriage between
the parties in this or any other jurisdiction.
6. The parties separated on or about November 7, 2005.
7. Neither of the parties in this action is presently a member of the Armed Forces on
active duty.
8. The marriage is irretrievably broken.
9. The Plaintiff has been advised of the availability of marriage counseling and she
may have the right to request that the Court require the parties to participate in counseling.
WHEREFORE, the Plaintiff respectfully requests your Honorable Court enter a Decree in
Divorce.
COUNT H - EQUITABLE DISTRIBUTION
10. Plaintiff incorporates herein by reference, the allegations set forth in Paragraphs
1 through 9 inclusive, of the Complaint as if the same were set forth herein at length.
11. Plaintiff and Defendant have legally and beneficially acquired certain real and
personal property during their marriage.
12. The parties may, but have not yet, enter agreements for the resolution of their
divorce and equitable distribution.
WHEREFORE, the Plaintiff respectfully requests the Court to enter an Order dividing the
marital property.
vvV I r §I III - FTE'Juca 1. I-LIM INJUNCTION PURSUANT TO 23 Pa. §3505(a) and 3323(i) TO PREVENT FURTHER DISSIPATION OF MARITAL ASSETS 23 Pa
13. Plaintiff incorporates herein by reference, the allegations set forth in Paragraphs
1 through 12, of the Complaint as if the same were set forth herein at length.
14. Plaintiff separated from Defendant on November 7, 2005 and files this Compliant in
Divorce, requesting economic relief, including a request for equitable distribution.
15. Since separation, Defendant has sold marital property including, but not limited to,
a Jet Ski, a Honda 400EX All-terrain vehicle, and performance auto racing vehicle parts.
16. Defendant has refused to disclose proceeds or consideration received from such
dissipations.
17. Plaintiff believes that Defendant may sell, transfer, dissipate, damage, destroy,
alienate or encumber marital property of the parties.
18. Defendant has retained for himself all but Fifty Dollars ($50.00) of proceeds
received for marital property sold by him.
WHEREFORE, the Plaintiff respectfully requests that the Court enter an Order prohibiting
further dissipation of marital assets without leave of Court or a written agreement signed by both
parties.
JOHNSON,
By:
Greevy
WEIDNER
:273842
VERIFICATION
I, Marissa Seeger, verify that the statements made in this Complaint in Divorce are true
and correct to the best of my knowledge, information and belief. I understand that false
statements made herein are made subject to the penalties of 18 Pa. C.S.A §4904, relating to
unsworn falsification to authorities.
Date: 4/ s/-O¢
arissa Seger
Johnson, Duffie, Stewart & Weidner
By: Melissa Peel Greevy
I.D. No. 77950
301 Market Street
P. O. Box 109
Lemoyne, Pennsylvania 17043-0109
(717) 761-4540
MARISSA SEEGER,
Plaintiff
V.
GEORGE E. SEEGER, JR.,
Defendant
AFFIDAVIT
Attorneys for Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO.
CIVIL ACTION - LAW
IN DIVORCE
MARISSA SEEGER, being duly sworn according to law, deposes and says:
1. 1 have been advised of the availability of marriage counseling and understand
that I may request that the court require that my spouse and I participate in counseling.
2. 1 understand that the court maintains a list of marriage counselors in the
Prothonotary's Office, which list is available to me upon request.
3. Being so advised, I do not request that the court require that my spouse and I
participate in counseling prior to a divorce decree being handed down by the court.
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:
?o% 1 ?????LZ1E Z?
Ma issa Seeger
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MARISSA SEEGER, IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
GEORGE E. SEEGER, JR., :
DEFENDANT : 06-2395 CIVIL
ORDER OF COURT
AND NOW, this 5t' day of May, 2006, upon consideration of the Plaintiff's
Request for an Injunction Preventing Dissipation, Alienation or Encumbering of Marital
Assets, a Rule is issued upon the Defendant to show cause why the Plaintiffs request
for Relief should not be granted.
1. The Defendant shall file an answer to paragraphs 13 through 18 of the
Plaintiffs Complaint on or before May 19, 2006.
2. A copy of said Answer will be filed with this Court.
3. A hearing on this matter will be held on Thursday, June 1, 2006 at 10:30 a.m.
in Courtroom No. 5 of the Cumberland County Courthouse, Carlisle, Pennsylvania.
IT IS FURTHER ORDERED AND DIRECTED that the Defendant shall not
Dissipate, Alienate or Encumber any Marital Assets of the parties without leave of Court
or a written agreement signed by both parties.
By the Court,
? -1, CLA\
M. L. Ebert, Jr., J.
NAMNVs
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Melissa Peel Greevy, Esquire
Attorney for Plaintiff
George E. Seeger, Jr.
Defendant
bas
Alan Michael Ross, Esquire
I.D. No. 81301
2001 North Front St.
Ste. 220
Harrisburg, Pennsylvania 17102
(717) 238-6311
MARISSA SEEGER,
PLAINTIFF
V.
GEORGE E. SEEGER, JR.,
DEFENDANT
Attorney for Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No.: 06-2395 CIVIL
CIVIL ACTION - LAW
IN DIVORCE
-- RuLt rv SHOW CAUSE
TO THE HONORABLE M.L. EBERT, JR., JUDGE OF SAID CO
AND NOW, this 18"' day of May, 2006, comes COURT:
the defendant, George Seeger, Jr., by
and through his attorney, Alan Michael Ross, Esquire, who moves t
extension of time to respond to the Rule to Show Cause h his Court to grant an
thereof the following is averred: sued on May 5, 2006, and in support
1 • On or about May 5, 2006, this Honorable Court issued a Rule
defendant to show cause why the Plaintiff's request for an in'unc i upon the
dissipation, alienation or encumbering of marital assests , ton preventing
2. The rule was returnable on or before should not be granted.
May 19, 2006.
3• A hearing on this matter is presently scheduled for June 1
a. m. , 2006, at 10:30
4• Undersigned counsel was retained by the defendant on or about May 16,
5. On may 17, 2006, undersigned counsel spoke with Melissa Peel Greevy,
counsel for Plaintiff, and it is believed, based upon representations made, that it is likely
the parties can come to an amicable agreement concerning the dissipation of the marital
property, should an extension of time to answer the rule be granted.
6. Melissa Peel Greevy, Esquire, concurs in this request for an extension of
time to answer the aforementioned Rule.
WHEREFORE, the Defendant respectfully requests that this Motion for Extension
of Time to Answer Rule to Show Cause be granted until June 1, 2006.
Respectful L miffed,
Alan Michael Ross, Esquire
I.D. No. 81301
VERIFICATION
I verify that the facts contained in the attached pleading are true
and correct to the best of my knowledge, information and belief. I understand that
the facts herein are verified subject to the penalties for unsworn falsification to
authorities under Crimes Code, Section 4904 (18 Pa.C.S. § 4904).
Alan Michael Ross, Esquire
ID. 81301
CERTIFICATE OF SERVICE
The and correct copy o undersigned e ehereby certifies that on this 18"' day of Ma, 2006, a defendant's Motion for Extension of Time to Answerue
Rule to Show Cause was served upon the following
person(s) by first class mail:
Melissa Peel Greevy, Esquire
Johnson, DufFe, Stewart & Wiedner
301 Market Street
P.O. Box 109
Lemoyne, PA 17043-0109
A a el Ross, Esquire
Attorney for Defendant
Supreme Court No. 81301
2001 N. Front St., Ste. 220
Harrisburg, PA 17102
(717) 238-6311
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Alan Michael Ross, Esquire
I.D. No. 81301
2001 North Front St.
Ste. 220
Harrisburg, Pennsylvania 17102
(717) 238-6311
Attorney for Defendant
MARISSA SEEGER,
PLAINTIFF
V.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: No.: 06-2395 CIVIL
CIVIL ACTION - LAW
GEORGE E. SEEGER, JR.,
DEFENDANT
To the Prothonotary
IN DIVORCE
ENTRY OF APPEARANCE
Kindly enter my appearance for the defendant, George Seeger, Jr., in the above-
captioned case.
Respectfully submitted,
Alan is ael Ross, Esq.
ID # 81301
2001 N. Front St., Ste. 220
Harrisburg, PA 17102
ATTORNEY FOR DEFENDANT
Dated: May 18, 2006
tl. C= O
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Johnson, Duffle, Stewart & Weidner
By: Melissa Peel Greevy
I.D. No. 77950
301 Market Street
P. O. Box 109
Lemoyne, Pennsylvania 17043-0109
(717) 761-4540
Attorneys for Plaintiff
MARISSA SEEGER,
Plaintiff
V.
GEORGE E. SEEGER, JR.,
Defendant
RETURN OF SERVICE
The undersigned makes the following return of service:
IN DIVORCE
The Order of Court dated May 5, 2006, was mailed to the Defendant, George E. Seeger, Jr., on
May 11, 2006 at 69 Fairview Street, Carlisle, PA 17013:
X A copy of the signed return receipt indicating service was completed on May 13, 2006
is attached hereto.
The mail, refused and returned, is attached. A copy mailed to the Defendant at the
same address by ordinary mail with the return address of the sender appearing
thereon has not been returned within fifteen days after mailing.
I, Melissa Peel Greevy, certify that I am a competent adult not a party to the action.
I verify that the statements made in this affidavit and return of service are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to
unswom falsification to authorities.
Date:
:275382
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
JOHNSON, DUFFIIE, STEWART & WEIDNER
Peel Greevy
NO. 06-2395
CIVIL ACTION - LAW
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Johnson, Duffle, Stewart & Weidner
By: Melissa Peel Greevy
I.D. No. 77950 Attorneys for Plaintiff
301 Market Street
P. O. Box 109
Lemoyne, Pennsylvania 17043-0109
(717) 761-4540
MARISSA SEEGER, IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
NO. 06-2395
V.
CIVIL ACTION - LAW
GEORGE E. SEEGER, JR.,
: IN DIVORCE
Defendant
RETURN OF SERVICE
The undersigned makes the following return of service:
The Divorce Complaint was mailed to the Defendant, George E. Seeger, Jr., on May 3, 2006 at 69
Fairview Street, Carlisle, PA 17013:
X A copy of the signed return receipt indicating service was completed on May 4, 2006
is attached hereto.
The mail, refused and returned, is attached. A copy mailed to the Defendant at the
same address by ordinary mail with the return address of the sender appearing
thereon has not been returned within fifteen days after mailing.
I, Melissa Peel Greevy, certify that I am a competent adult not a party to the action.
I verify that the statements made in this affidavit and return of service are true and correct. I
understand that false statements herein are made subject to the penaltie 18 Pa.C.S. § 4904 relating to
unsworn falsification to authorities.
Date
:2754!
JOHNSON, DUFFIFE, STEWART & WEIDNER
Peel Greevy
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MARISSA SEEGER, IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
GEORGE E. SEEGER, JR.,
DEFENDANT 06-2395 CIVIL
ORDER OF COURT
AND NOW, this 24th day of May, 2006, upon consideration of the Motion
for Extension of Time to Answer the Rule to Show Cause,
IT IS HEREBY ORDERED AND DIRECTED that the Motion is GRANTED and the
Answer shall be filed on or before 12:00 noon on May 31, 2006. A copy of said Answer
shall be filed with this Court.
By the Court,
Jj
M. L. Ebert, Jr., J.
elissa Peel Greevy, Esquire
Attorney for Plaintiff
In Michael Ross, Esquire -A
Attorney for Defendant
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Johnson, Duffle, Stewart & Weidner
By: Melissa Peel Greevy
I.D. No. 77950 Attorneys for Plaintiff
301 Market Street
P. O. Box 109
Lemoyne, Pennsylvania 17043-0109
(717) 761-4540
MARISSA SEEGER,
Plaintiff
V.
GEORGE E. SEEGER, JR.,
Defendant
NO. 06-2395
CIVIL ACTION - LAW
IN DIVORCE
STIPULATION
AND NOW, this day of , 2006, the parties agree as follows:
1. No later than June 30, 2006, a parties will provide each other with a complete
listing of all marital property which has been liquidated or dissipated since November 7, 2005.
This listing shall include all consideration received in exchange for said property, the date of the
liquidation or dissipation, the identification of the recipient of the asset, and any receipts or
otherwise valid documentation illustrating the value received.
2. In the event that any of the assets that were liquidated were encumbered with
debt, such documentation of the debt satisfied upon the sale or liquidation of the asset shall be
disclosed and documented.
3. No further dissipation or sale of marital assets shall occur in the absence of an
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Order of Court, or fully executed agreement of the parties.
NO. 06-2395 - CIVIL ACTION - LAW
4. By reason of the parties' agreement, as specified herein, the Hearing scheduled for
June 1, 2006 at 10:30 a.m. is CANCELLED.
5. The parties agree that this Stipulation shall be entered as an Order of Court.
Witness:
r,
Alzo
arissa Seger
Witness:
G ger, Jr.
:276179
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Johnson, Duffle, Stewart & Weidner JUN 0 5 2006
By: Melissa Peel Greevy
I.D. No. 77950 Attorneys for Plaintiff
301 Market Street
P. O. Box 109
Lemoyne, Pennsylvania 17043-0109
(717) 761-4540
MARISSA SEEGER, IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
NO. 06-2395
V.
CIVIL ACTION - LAW
GEORGE E. SEEGER, JR.,
IN DIVORCE
Defendant
ORDER
th t'E
AND NOW, this 8 day of SU , 2006, upon agreement of the parties, the attached
Stipulation is hereby made into an Order of Court.
BY THE COURT:
'?k --? Q V
M. L. Ebert. Jr. J.
Dist: /Aelissa Peel Greevy, Esquire, 301 Market Street, Lemoyne, PA 17043
an M. Ross, Esquire, 2001 N. Front Street, Ste 220, Harrisburg, PA 17102
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MARISSA SEEGER
V.
IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
GEORGE E. SEEGER, JR.,
Defendant
: CIVIL ACTION - LAW
NO. 06-2395 CIVIL TERM
IN DIVORCE
PRAECIPE
TO THE PRO'[ HONOTARY:
WITHDRAWAL OF APPEARANCE
Please withdraw my appearance on behalf of the Plaintiff in the above-captioned matter.
Resp tfully su itted,
Date: "A
Melissa P. Greevy, Esquire
ENTRY OF APPEARANCE
Please enter my appearance on behalf of the Plaintiff in the above-captioned matter.
Date: b d G
wire
200 North Hanover Street
Respectfully submitted,
1v, LJqintiff
4torney,LForPla
Carlisle, PA 17013
(717)243-5551
(800)347-5552
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MARISSA SEEGER IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
GEORGE E. SEEGER, JR., : NO. 06-2395 CIVIL TERM
Defendant : IN DIVORCE
PETITION FOR SPECIAL RELIEF PURSUANT TO PENNSYLVANIA RULE
OF CIVIL PROCEDURE 1920.15
AND NOW, comes Petitioner, Marissa Seeger by and through her counsel
Bradley L. Griffie, Esquire, and the law firm of Griffie and Associates petitions the Court
as follows:
1. Petitioner, Marissa Seeger is the above named Plaintiff and an adult individual
currently residing at 775 Erford Road, Camp Hill, Cumberland County
Pennsylvania, 17011.
2. Respondent, George E. Seeger, Jr., is the above named Defendant and an adult
individual residing at 69 Fairview Street, Carlisle, Cumberland County,
Pennsylvania, 17013.
3. The instant divorce action was initiated through the filing of a Complaint for
Divorce on April 27, 2006.
4. Respondent is represented in this action by Alan Michael Ross, Esquire, of 2001
North Front Street, Suite 220, Harrisburg, Pennsylvania, 17102, pursuant to his
appearance on behalf of Respondent in prior proceedings in this matter.
5. The parties are the joint owners of real estate located at 69 Fairview Street,
Carlisle, Cumberland County, Pennsylvania, 17013.
6. Respondent has resided at the aforesaid jointly owned property, the former marital
residence, since the time of the parties' physical separation in November 2005.
7. The aforesaid real estate is encumbered with the first mortgage due and owing to
Chase Mortgage Corporation and the second mortgage due and owing to
Homecomings Financial, a GMAC company.
8. The parties are also subject to a support proceeding docketed in the Court of
Common Pleas to DRS 006369 S 2006 and PASCES number 411108245.
9. Despite efforts by Petitioner, through counsel, the position of Respondent
concerning the means of ultimate distribution of the real estate in this divorce
action; has not been discussed; that is, whether Respondent will refinance the
mortgages on the property and buyout Petitioner's interest or whether the property
will be listed and sold with the net proceeds being distributed between the parties.
10. Pursuant to Pennsylvania Rule of Civil Procedure 1910.16-6(e) "The guidelines
assume that the spouse occupying the marital residence will be solely responsible
for the mortgage payment, real estate taxes, and homeowner's insurance."
11. Petitioner has become aware that Respondent has failed to make mortgage
payments on the second mortgage for the months of November and December.
12. Petitioner is aware that foreclosure proceedings will be initiated in the short term
if the mortgage payments are not made.
13. Petitioner hopes to avoid the expense of an expert for purposes of appraising the
real estate under circumstances where the property is going to be sold as her
resources for costs in this matter are limited
14. Petitioner has not been able to gain a response from the Respondent, individually
or through counsel, as to the Respondent's position relative to the disposition of
the real estate and, therefore, there is no pending resolution of the disposition of
the real estate.
15. Even if the Petitioner were to initiate the Master's proceedings process at this
time, this would not be able to be expedited in a manner that would allow for
resolution of the current situation of the delinquentsecond mortgage not being
paid by Respondent.
16. Contemporaneously with the filing of the within Petition, Petitioner, through
counsel, is submitting the names of three realtors whom Petitioner would accept
as impartial realtor with whom the property could be listed for sale.
17. Based upon the prior lack of responses, it is anticipated that Respondent will not
provide response that will allow for the property to be listed for sale in any time
frame that will also allow for a resolution of the current delinquency on the
second mortgage.
18. Court intervention will be necessary in order to secure an arrangement for listing
and sale of the real estate in an effort to stall or avoid foreclosure proceedings on
the delinquent second mortgage.
19. Based upon a prior Petition for Special Relief filed by the Petitioner in this matter,
a Stipulated Order was entered providing that the parties were obligated to
exchange information relative to the liquidation and dissipation of marital assets
with the information being exchanged no later than June 30, 2006, a copy of said
Stipulation and Order of Court by attached hereby and incorporated herein by
reference as Exhibit "A."
20. While both parties substantially complied with the direction of the Order,
Respondent has failed and refused to provide the name and identification of the
recipient of a certain Honda 400EX ATV, claiming that the individual who
purchased the ATV from Respondent was "unknown."
21. Request has been made of Respondent to identify the purchaser of the Honda
ATV, but the identification has not been made.
22. Respondent has failed to comply with the terms of the Courts prior Order of June
85 2006 as described above.
23. A copy of the within Petition has been forwarded by first class mail and facsimile
to Respondent's counsel prior to filing.
WHEREFORE, Petitioner requests your Honorable Court to enter a Rule upon the
Respondent to Show Cause, if any he has, as to why the following Relief should not
be granted:
1. Entry of an Order finding the Respondent in Contempt of the Court Order of
June 8, 2006 and further directing that he compensate Petitioner for her
attorney fees in this matter, and immediately identify the purchaser of the
Honda ATV;
2. Entry of an Order authorizing Petitioner to execute a listing contract with a
realtor of her selection for the sale of the property located at 69 Fairview
Street, Carlisle, Pennyslvania, and further, providing authority in the
Petitioner to execute any and all sale documents associated with the final sale
and settlement of the aforesaid real estate;
I Entry an Order providing that all attorney's fees and cost incurred by
Petitioner in this matter be paid by Respondent;
4. Entry of an Order providing such other relief as the Court deems just and
proper.
Respectively submitted,
130y f,. Griffie, Esquire
911-torneyfor Plaintiff/Petitioner
200 North Hanover Street
Carlisle, PA 17013
(717)243-5551
(800)347-5552
.1'
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 unworn falsifications to authorities.
a
Dated: I a (5 ?o
"SA SE ER
r
CERTIFICATE OF SERVICE
I, Bradley L. Griffie, Esquire, hereby certify that I did, the 7th day of December, 2006,
MARISSA SEEGER
V.
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 06-2395 CIVIL TERM
IN DIVORCE
GEORGE E. SEEGER, JR.,
Defendant
cause a copy of Plaintiff s Petition for Special Relief to be served upon Defendant by serving his
attorney of record, Alan M. Ross, Esquire, by facsimile and first-class mail, postage prepaid at
the following addresses:
Alan M. Ross, Esquire
Govenor's Plaza South
2001 North Front Street
Building 2, Suite 220
Harrisburg, PA 17102
Fax# 599-5658
DAB: rah 0
Tif e s, Secretary of
Bra a 'ffie, Esquire
Atto n for Plaintiff/Petitioner
GRIFFIE & ASSOCIATES
200 North Hanover Street
Carlisle, PA 17013
(717)243-5551
(800)347-5552
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MARISSA SEEGER, IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
GEORGE E. SEEGER, JR.,
DEFENDANT 06-2395 CIVIL
IN RE: PETITION FOR SPECIAL RELIEF
ORDER OF COURT
AND NOW, this 19`h day of December, 2006, upon consideration of the
Petition for Special Relief filed by the Plaintiff, IT IS HEREBY ORDERED AND
DIRECTED that:
1. A Rule is issued upon the Defendant to show cause why the relief
requested should not be granted;
2. The Defendant will file an answer on or before January 9, 2007;
3. The Prothonotary is directed to forward said Answer to this Court
4. A hearing shall be held on Thursday, February 22, 2007 at 3:30 p.m. in
Courtroom No. 5 of the Cumberland County Courthouse, Carlisle, PA.
By the Court,
Bradley L. Griffie, Esquire
Attorney for Plaintiff
Attorney for Defendant 1-L U-X? \/
Alan M. Ross, Esquire
N
M. L. Ebert, Jr., 16 J.
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MARISSA SEEGER IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V.
GEORGE E. SEEGER, JR.,
Defendant
CIVIL ACTION - LAW
NO. 06-2395 CIVIL TERM
IN DIVORCE
MOTION FOR APPOINTMENT OF MASTER
MARISSA SEEGER, Plaintiff, moves the court to appoint a master with respect to the following claims:
Additional information, if any, relevant to the motion:
(X) Divorce
() Annulment
() Alimony
() Alimony Pendente Lite
and in support of the motion states:
(X) Distribution of Property
() Support
O Counsel Fees
() Costs and Expenses
(1) Discovery is complete as to the claims (s) for which the appointment of a master is
requested.
(2) The defendant has appeared in the action by his attorney, Alan M. Ross, Esquire.
(3) The Statutory grounds for divorce are 0301(c).
(3) Delete the inapplicable paragraph(s):
C. The action is contested with respect to the following claims:
All of the above except divorce.
(4) The action does not involve complex issues of law or fact.
(5) The hearing is expected to take one (hems) (days).
(7)
None
Date: -7 ,7 r Plai f
ORDER APPOINTING MASTER
AND NOW, , 20 , _
appointed master with respect to the following claims:
Esquire is
By the Court:
J.
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MARISSA SEEGER
V.
IN THE COURT OF COMMON PLEAS OF
Plaintiff ; CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
GEORGE E. SEEGER, JR.,
Defendant
Additional information, if any, relevant to the motion:
NO. 06-2395 CIVIL TERM
IN DIVORCE
MOTION FOR APPOINTMENT OF MASTER
MARISSA SEEGER, Plaintiff, moves the court to appoint a master with respect to the following claims:
(X) Divorce
O Annulment
() Alimony
() Alimony Pendente Lite
and in support of the motion states:
(X) Distribution of Property
()Support
O Counsel Fees
O Costs and Expenses
(1) Discovery is complete as to the claims (s) for which the appointment of a master is
requested.
(2) The defendant has appeared in the action by his attorney, Alan M. Ross, Esquire.
(3) The Statutory grounds for divorce are 3301 (c).
(3)
(4)
(5)
(7)
Delete the inapplicable paragraph(s):
C. The action is contested with respect to the following claims:
All of the above except divorce.
The action does not involve complex issues of law or fact.
The hearing is expected to take one heirs) (days).
None
Date:=7 i 3' 7
r Plai ' f
ORDER APPOINTING MASTER
AND NOW, C-\ 11 , 20 0-7 E Esquire is
appointed master with rfpect(fo the following claims: T4L& gAxezd .
By the ourt:
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MARISSA SEEGER,
PLAINTIFF
V.
GEORGE E. SEEGER, JR.,
DEFENDANT
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,
PENNSYLVANIA
No.: 06-2395 CIVIL
CIVIL ACTION - LAW IN DIVORCE
MOTION TO WITHDRAW AS COUNSEL
TO THE HONORABLE JUDGES OF SAID COURT:
AND NOW, this 12"' day of October, 2007, Alan Michael Ross, Esquire,
hereby moves to withdraw as counsel, and represents:
1. Counsel, Alan Michael Ross, Esquire, represents the defendant in the
above captioned matter.
2. Counsel entered an Entry of Appearance on May 18, 2006.
3. The defendant in this case is requesting that undersigned counsel
withdraw immediately (see Exhibit A).
4. A copy of this Motion to Withdraw as Counsel has been sent to the
Defendant's address.
WHEREFORE, for each of the foregoing reasons, counsel respectfully
requests that he be permitted to withdraw as counsel.
Respectf41y,sutgnitted,
Alan Mchael-Ross, Esq.
ID # 81301
2001 N. Front Street, Suite 220
Harrisburg, PA 17102
ATTORNEY FOR DEFENDANT
10/04/2007 01:01 7175287421 KAIFFMAN
George Seeger Jr.
6959 wauville Rd.
Enola, PA 17025
Dear Mr. Ross,
Wobar, 4 2007
Due to my financial situations for the past 12 + months I am no longer able to
maintain your status as my attorney. I am requesting that you wdhdrsw yourself from
this case rely. I am very great full and thankful for A you have done. I know
that you have done all you could to try and bring resolution to this matter. Thanks again
for your time and effort.
George Seeger Jr.
PAGE 01
VERIFICATION
I verify that the facts contained in the attached pleading are true
and correct to the best of my knowledge, information and belief. I understand that
the facts herein are verified subject to the penalties for unsworn falsification to
authorities under Crimes Code, Section 4904 (18 Pa.C.S. § 4904).
A an Mi ael ss, Esquire
ID. 81301
CERTIFICATE OF SERVICE
The undersigned hereby certifies that on this 12'x' day of October, 2007, a
true and correct copy of the foregoing motion was served upon the following
person(s) by first class mail and/or facsimile:
Bradley L. Griffie, Equire
Griffie & Associates
200 North Hanover Street
Carlisle, PA 17013
E. Robert Elicker, 11
Divorce Master
Cumberland County Court of Common Pleas
9 North Hanover Street
Carlisle, PA 17013
George Seeger, Jr.
6959 Wertzville Road
Enola, PA 17025
By:
A an chael Ross, Esquire
Attorney for Defendant
Supreme Court No. 81301
2001 North Front Street, Suite 220
Harrisburg, PA 17102
(717) 238-6311
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MARISSA SEEGER,
Plaintiff
V.
GEORGE E. SEEGER, JR.,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 06-2395
CIVIL ACTION - LAW
IN DIVORCE
DEFENDANT'S PRETRIAL STATEMENT
1. LIST OF ASSETS:
See document attached hereto as Exhibit "A".
2. EXPERT WITNESSES:
(a) None.
3. NON-EXPERT WITNESSES:
(a) The Defendant's brothers will testify if necessary regarding the
amount of rent they paid while residing with Defendant.
Defendant will testify on his own behalf regarding all issues relevant to
equitable distribution and alimony.
(b) Defendant reserves the right to call additional witnesses for rebuttal if
necessary.
4. EXHIBITS: See 2005 Income Tax Return.
5. PARTIES' GROSS INCOME:
The Defendant is currently earning an income of approximately $36,000
per year.
6. CURRENT INCOME & EXPENSE STATEMENT:
The Defendant's current gross annual income is $36,000. A complete list
of the expenses will be provided prior to the hearing.
7. PENSION AND RETIREMENT BENEFITS:
Plaintiff - $8,000.
Defendant - None.
8. DISPUTED TANGIBLE PERSONAL PROPERTY:
None.
9. MARITAL DEBTS:
A $2,000 tax bill, paid by Defendant, for Plaintiff's IRA withdrawal.
Mortgage deficiency in the amount of $3,369.
10. PROPOSED RESOLUTION OF ECONOMIC ISSUES:
Defendant would simply suggest that the cash from the sale of the marital
residence be divided equally, and that he also receive a sum of $4,000.
This sum is equal to the amount of money which the Plaintiff took from
her IRA after separation.
Date: It / Respectfully submitted,
Mark T. Silliker, Esquire
5922 Linglestown Road
Harrisburg, PA 17112
(717) 671-1500
I.D. No. 33671
Attorney for Defendant
EXHIBIT "A"
LIST OF MARITAL ASSETS
item Asset Vale Date of Non-marital
Number Valuation Portion
1. 2001 Honda ATV - sold $1,800.00
at book value
2. Jet Ski - sold, no money
Cleared $0.00
3. Wife's IRA $8,000.00
4. Money in escrow from
sale of home, being held
by Attorney Griff a $15,866.60
Asset
LIST OF NON-MARITAL ASSETS
Value
Date of Valuation
Liens &
Encumbrances
liens &
ED-cumbiaam
None.
Department of the Treasury - Internal Revenue Service
Form 1040 U.S. Individual Income Tax Return
For the ear Jan 1 . Dec 31, 2005, or other tax
Label Your first name
(See instructions.) r---
Use the
IRS label.
Otherwise,
please print
or type.
If a joint return, spouse's first name
MI Last name
E Seege
MI Last name
larissa Seeger
Home address (number and street). If you have a P.O. box, see instructions.
69 Fairview Street
City, town or post office. If you have a foreign address, see instructions.
Presidential
Election
Campaign
05 I (99) IRS Use
i, ending .20
Apartment no.
ZIP code
Carlisle PA 17013
1 Check here if you, or your spouse if filing jointly, want $3 to go to this fund? (see instructions)
- Do not write or staple in this
OMB No. 1545-0074
Your social security number
176-54-3846
Spouse's social security number
187-62-9160
You must enter your
. social security
number(s) above.
Checking a box below will not
change your tax or refund.
?M
Filing Status
1 Single 4 ••••••••••...... You L_J Spouse
H
ead of household (with qualifying person). (See
2 Married filing jointly (even if only one had income) instructions.) If the qualifying person is a child
Check only 3 Married filing seParately. Enter spouse's SSN above & full name but not here your . dependent, enter this child's
one box. name here ? 5 n Qualifying widow(er) with dependent child (see instructions)
Exemptions
.. Boxes checked
6a Yourself. If someone can claim you as a dependent, do not check box 6a .......... on 6a and 66 . . 2
b LXJ spouse .................
..................... No
f
hild
c Dependents:
(2) Dependent's
p
s
(
D _
. o
c
ren
on 6c who:
social security e
lationshi
p Gua'ifying • lived
First name Last name number to you child for child with you ..... 1
tax credit • did not
Caedon R Seeger
207-80-8264
Son (see instrs) live with you
X due to divorce
If or separation
(see instrs) ...
more than
four dependents, Dependents
ec not
see instructions. en
entered above .
71 Add
b
d Total number of exemptions claimed ..........
............. num
ers
on lines
................................ above..... ?
3
Income
Attach Form(s)
W-2 here. Also
attach Forms
W-2G and 1099-R
if tax was withheld.
If you did not
get a W2,
see instructions.
Enclose, but do
not attach, any
payment Also,
please use
Form 1040-V.
Adjusted
Gross
Income
7 Wages, salaries, tips, etc. Attach Form(s) W-2 .........................................
8a Taxable interest. Attach Schedule B if required ...............
..........................
b Tax-exempt interest. Do not include on line 8a .............. I 8bl
9a Ordinary dividends. Attach Schedule B if required ............ .
..........................
Oualfd divs
(see instrs) .................. .
10 Taxable refunds, credits, or offsets of state and local income taxes (see instructions) .. , ..... .
.............
11 Alimony received .............. .
................................
.....................
12 Business income or (loss). Attach Schedule C or C.EZ ................................ .
13 Capital gain or (loss). Aft Sch D if reqd. If not reqd, ck here .......................... ? El
14 Other gains or (losses). Attach Form 4797
.....................
15a IRA distributions ........... 15a b Taxable amount (see instrs) . .
16a Pensions and annuities 16al b Taxable amount (see instrs) . .
17 Rental real estate, royalties, partnerships, S corporations, trusts, etc. Attach Schedule E . .
18 Farm income or (loss). Attach Schedule F ..............................................
19 Unemployment compensation .................. .
................................
.rs.).. .
20a Social security benefits ......... 20al b Taxable amount (see inst.
. .
21 Other income
22 Add the amounts in the far right column for lines 7 throw h 21. This is our total income. ?
23 Educator expenses (see instructions) ....................... 23
24 Certain business expenses of reservists, performing artists, and fee-basis
government officials. Attach Form 2106 or 2106-EZ .................... 24
25 Health savings account deduction. Attach Form 8889 ........ 25
26 Moving expenses. Attach Form 3903 ....................... 26
27 One-half of self-employment tax. Attach Schedule SE ........ 27
28 Self-employed SEP, SIMPLE, and qualified plans ............ 28
29 Self-employed health insurance deduction (see instructions) ............. 29
30 Penalty on early withdrawal of savings ..................... 30
31 a Alimony paid b Recipient's SSN .... ? .. 31 a
32 IRA deduction (see instructions) ........................... 32
33 Student loan interest deduction (see instructions) ............ 33
34 Tuition and fees deduction (see instructions) ................ 34
35 Domestic production activities deduction. Attach Form 8903 .............. 35
36 Add lines 23 - 31a and 32 - 35 ............................... .
37 Subtract line 36 from line 22. This is our adjusted ross income .. ?
77, 746.
10
11
12 -10,338.
13
14
15b
16b 8,187.
5-
18
19
20 b
595.
BAA For Disclosure, Privacy Act, and Paperwork Reduction Act Notice, see instructions. FDIA0112 11/07105Y, Form 1040 (2005)
N
N
INCOME AND EXPENSE STATEMENT OF GEORGE E. SEEGER, JR.
MARISSA SEEGER,
Plaintiff
V.
GEORGE E. SEEGER, JR.,
Defendant
INCOME:
Employer:
Address:
Type of Work:
Payroll Number:
Pay Period (weekly, bi-weekly, etc.):
Gross pay per pay period:
No. 06-2395
Date:
SGS Automotive
901 Range End Road
Dillsburg, PA 17019
Automotive
Bi-weekly
$1, 538.46
Itemized Payroll Deductions:
Federal Withholding:
Social Security:
Local Wage Tax:
State Income Tax:
Retirement:
Savings Bonds:
Credit Union:
Life Insurance:
SUI
Medicare
Domestic Relations
$224.00
$95.39
$24.62
$47.23
$22.31
$357.69
Net Pay per pay period
.
OTHER INCOME:
WEEK MONTH YEAR
INTEREST
Dividends
Pension
Annuity
Social Security
Rents
Royalties
Expense Account
Child & Spousal Support
Unemployment Compensation
Workmen's Compensation
Totals:
Total Income:
EXPENSES:
Weekh? Month Yearly
(Fill in appropriate column)
Home
Mortgage/Rent
Second Mortgage
Maintenance
Utilities-
Electric
Gas
Oil
Telephone
Refuse
Water, Sewer
Furniture
Employment
Public Transportation
Lunch
Taxes
Real Estate
Personal Property
$160.00
EXPENSES:
Week hr Month Yeses
Taxes
Income
Insurance
Homeowners
Automobile
Life
Accident
Health
Other
Automobile
Payments
Fuel
Repairs
Medical
Doctor
Dentist
Orthodontist
Hospital
Medicine
Special Needs
(glasses, braces,
125.00
$60.00
25.00
$450.00
$300.00
$50.00
$100.00
$100.00
orthopedic devices)
Education
Private School
Parochial School
College
Personal
Clothing
Food
Barber/Hairdresser
Credit Payments:
Credit Card
Charge Account
Personal loan
$50.00
$100.00
$50.00
$200.00
$250.00
EXPENSES:
Loans:
Weekly Month Yearly
(fill in appropriate column)
Credit Union
Loans
Miscellaneous:
Household help
Child Care
Papers/Books
Magazines
Entertainment
Pay Television
Vacation
Gifts
Legal Fees
Charitable Contributions
Other Child Support
Alimony payment
Other:
Totals:
TOTAL EXPENSES:
00
AFFIDAVIT
I, George E. Seeger, Jr., hereby certify that the
information, and belief. I understand that false
of 18 Pa.C.S. 4909 relating to unsworn falsificati
-7 S o <?
Dated: _
, Jr.
t to the best of my knowledge
subject to the penalties
V c S7 -
MARISSA SEEGER,
Plaintiff
V.
GEORGE E. SEEGER, JR.,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 06-2395
CIVIL ACTION - LAW
IN DIVORCE
INVENTORY OF DEFENDANT,
GEORGE E. SEEGER, JR.
Defendant files this inventory of all property owned or possessed by either
party at the time this action was commenced and all property transferred within the
preceding three years.
Defendant verifies that the statements made in this inventory are true and
correct. Defendant understands that false statements herein are subject to the penalties of
18 Pa. C. S. § 4904 relating to unsworn falsification to authorities.
.
George E. Seeger, Jr., Defendant
A.
ASSETS OF THE PARTIES
Defendant marks on the list below the items applicable to the case at bar
and itemizes the assets on the following pages.
O 1. Real Property
() 2. Motor Vehicles
() 3. Stocks, bonds, securities and options
() 4. Certificates of Deposit
(x) 5. Checking accounts, cash
() 6. Savings accounts, money market and savings certificates
() 7. Contents of safe deposit boxes
() 8. Trusts
() 9. Life insurance policies (indicate face value, cash surrender value
and current beneficiaries)
() 10. Annuities
() 11. Gifts
() 12. Inheritances
() 13. Patents, copyrights, inventions, royalties
() 14. Personal property outside the home
() 15. Business (list all owners, including percentage of ownership, and
officer/director positions held by a party with company)
() 16. Employment termination benefits-severance pay, Workers' Compensation
claim/award
() 17. Profit sharing plans
() 18. Pension plans (indicate employee contributions and date plan vests)
() 19. Retirement plans, Individual Retirement Accounts
() 20. Disability payments
O 21. Litigation Claims (matured and unmatured)
() 22. Military/V.A. benefits
O 23. Education benefits
() 24. Debts due, including loans, mortgages held
() 25. Household furnishings and personalty (include as a total category and
attach itemized list if distribution of such assets is in dispute)
() 26. Other
MARITAL PROPERTY
Defendant lists all marital property in which either or both spouses have a
legal or equitable interest individually or with any other person as of the date this action
commenced.
lte - Num) r Description of Prooem
2001 Honda ATV. This
was sold for book value.
2. Jet Ski - sold, no money
cleared
3. Wife's IRA
4. Money in escrow from
sale of home, being held
by Attorney Griffie
Name of ?? Value as of Date
Action commenced
$1,800.00
$0.00
$8,000.00
$15,866.60
NON-MARITAL PROPERTY
Defendant lists all property in which a spouse has a legal or equitable
interest which is claimed to be excluded from marital property:
Item Number Description of Property
Reason for Exclusion
None.
PROPERTY TRANSFERRED
Item Number Description of Pro
Date o_ f Transfer C°°s°°s- ideration Personom
Transferred
l 2001 Honda ATV
$1,800.00
2. Jet Ski
$0.00
3. Refrigerator
$700.00
LIABILITIES
Item Number Description of Pronertv
Name of all Name of all
Creditors Debtors Amount owed as
of _ date Action
Commenced
1 Tax liability paid by Husband
for Wife's IRA withdrawal
$2,000.00
2. Mortgage deficiency at time of
sale of home
$3,369.00
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MARISSA SEEGER,
Plaintiff
VS.
GEORGE E. SEEGER, JR.,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 06 - 2395 CIVIL
IN DIVORCE
ORDER OF COURT
AND NOW, this 4U day of ,
2008, counsel and the parties having entered i1 o agreement
and stipulation resolving the economic issues on July 22, 2008,
the date set for a Master's hearing, the agreement and
stipulation having been transcribed, the appointment of the
Master is vacated and counsel can conclude the proceedings by
the filing of a praecipe to transmit the record with the
affidavits of consent of the parties so that a final decree in
divorce can be entered.
? i
cc: Bradley L. Griff e
Attorney for Plaintiff
ZMark T. Silliker
Attorney for Defendant
coi'es rr-9 ACCL
CT OURT,
1 0vjG
Edgar B. Bayley, P.J.
N
Grp'-a ?
Q ? C
1
.
MARISSA SEEGER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. NO. 06 - 2395 CIVIL
GEORGE E. SEEGER, JR.,:
Defendant IN DIVORCE
THE MASTER: Today is Tuesday, July 22, 2008.
This is the date set for a hearing in the above-captioned
divorce proceeding. Present in the hearing room are the
Plaintiff, Marissa Seeger, and her counsel Bradley L.
Griffie, and the Defendant, George E. Seeger, Jr., and his
counsel Mark T. Silliker.
This action was commenced by a complaint
filed on April 27, 2006. The complaint raised grounds for
divorce of irretrievable breakdown of the marriage and the
economic claim of equitable distribution. No claims have
been raised by either party for alimony or counsel fees and
costs.
With respect to the grounds for divorce,
counsel have indicated that later this morning they are
going to provide the Master with signed affidavits of
consent and waivers of notice of intention to request entry
of divorce decree. The documents will be dated today and
will be filed with the Prothonotary by the Master's office.
The divorce can, therefore, conclude under Section 3301(c)
of the Domestic Relations Code.
1
v
After considerable negotiations, the Master
has been advised that the parties have reached an agreement
with respect to the outstanding economic issue of equitable
distribution. The agreement is going to be placed on the
record in the presence of the parties. The agreement as
stated on the record will be considered the substantive
agreement of the parties, not subject to any changes or
modifications except for correction of typographical errors
which may be made during the transcription. The parties,
therefore, are bound by the terms of the agreement when they
leave the hearing room, even though they have not
subsequently signed the agreement affirming the settlement.
The Master has been advised that the parties
intend to return with counsel later this morning to review
the agreement for typographical errors, make any corrections
as necessary, and then affix their signatures affirming the
terms of settlement.
Upon receipt by the Master of a completed
agreement, the Master will prepare an order vacating his
appointment and counsel can then file a praecipe
transmitting the record to the Court requesting a final
decree in divorce.
The parties were married on May 27, 2000, and
separated around November 7, 2005. There is one minor
child of the marriage who resides with wife. Mr. Griffie.
2
MR. GRIFFIE: The parties have agreed to
settle all matters raised in the divorce action through the
following agreement:
1. All personal property that the parties have in their
possession, including any vehicles, household furnishings,
and the like will remain with the party currently in
possession. The parties acknowledge that there are no
vehicles or other items that are titled with the parties
joint names and, therefore, there should be no need for the
execution of titles.
2. The parties acknowledge that from the sale of their
formal marital residence the net proceeds of $15,866.60 was
received. Of that amount the sum of $4,500.00 will be
disbursed to husband and the balance will be disbursed to
wife. After those disbursements, neither party will make
any claim against the other relative to any matters
associated with the sale of the home or proceeds received
from the sale of the home.
3. Neither party shall make any additional claim of any
nature against the other relative to the divorce
proceedings, and this agreement is intended to settle all
matters and all claims raised in the divorce proceedings.
4. 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, statutory
allowance, widow's allowance, right of intestacy, right to
take against the will of the other, and right to act as
administrator or executor in the other's estate. 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 interest, rights, and claims.
MR. GRIFFIE: Ms. Seeger, did you just hear
the agreement that I put on the record?
3
MS. SEEGER: Yes.
MR. GRIFFIE: Do you understand the terms of
the agreement?
MS. SEEGER: Yes, I do.
MR. GRIFFIE: Are you satisfied that this
agreement will resolve all issues raised in this divorce
action?
MS. SEEGER: Yes.
MR. GRIFFIE: And is that your agreement?
MS. SEEGER: Yes.
MR. SILLIKER: Mr. Seeger, you heard Mr.
Griffie's statements?
MR. SEEGER: Yes.
MR. SILLIKER: And you are in agreement that
you will essentially receive $4,500.00 from the funds being
held in escrow?
MR.
MR.
MR.
MR.
will go your separ,
MR.
THE
SEEGER: Yes, sir.
SILLIKER: The rest will be your wife's?
SEEGER: Yes, sir.
SILLIKER: And no further claims? You
ate ways and live happily ever after?
SEEGER: Yes, sir.
MASTER: Thank you.
I acknowledge that I have read the above
stipulation and agreement, that I understand the terms of
4
settlement as set forth herein, and that by signing below I
ratify and affirm the agreement previously made and intend
to bind myself to the settlement as a contract obligating
myself to the terms of settlement and subjecting myself to
the methods and procedures of enforcement which may be
imposed by law and in particular Section 3105 of the
Domestic Relations Code.
WITNESS:
"ice. G4ffie
y r Plaintiff
mark T. Silliker
Attorney for Defendant
DATE:
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:7 4441"
Ma issa S ge
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George er, .
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MARISSA SEEGER, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION -LAW
GEORGE E. SEEGER, JR., : NO. 06-2395 CIVIL TERM
Defendant : IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under §3301 (c) of the Divorce Code was filed on April
27, 2006 and served on May 4, 2006, as indicated in Return of Service.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90)
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 after service of notice of
intention to request entry of the decree.
I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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: yJ19f
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M ISSA S GE
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MARISSA SEEGER,
Plaintiff
VS.
GEORGE E. SEEGER, JR.,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION -LAW
NO. 06-2395 CIVIL TERM
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
THE ENTRY OF A DIVORCE DECREE
UNDER §3301(c) OF THE DIVORCE CODE
1. I consent to the entry of a final decree in 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 THE FOREGOING 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: 2 I,? I0 ^
14IS16AIS G
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MARISSA SEEGER, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
VS. : CIVIL ACTION - LAW
GEORGE E. SEEGER, JR., : NO. 06-2395 CIVIL TERM
Defendant : IN DIVORCE
AFFIDAVIT OF CONSENT
2. A Complaint in Divorce under §3301 (c) of the Divorce Code was filed on April
27, 2006 and served on May 4, 2006, as indicated in Return of Service.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90)
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 after service of notice of
intention to request entry of the decree.
I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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: -` f
GE E E. SEE ,
-,a f
`' ?`
MARISSA SEEGER, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION -LAW
GEORGE E. SEEGER, JR., : NO. 06-2395 CIVIL TERM
Defendant : IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
THE ENTRY OF A DIVORCE DECREE
UNDER §3301(c) OF THE DIVORCE CODE
1. I consent to the entry of a final decree in 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 THE FOREGOING 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:
GEOi?M . SEEGER, J .
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In'
MARISSA SEEGER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V.
GEORGE E. SEEGER, JR.,
Defendant
CIVIL ACTION - LAW
NO. 06-2395 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 Divef .e Gede
(Strike out inapplicable section).
2. Date and manner of service of the Complaint: by certified mail, restricted delivery on May 4,
2006.
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: July 22, 2008 by Defendant: July 22, 2008
(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
5. 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: July 22, 2008
Date defendant's Waiver of Notice in §3301 (c) Divorce was filed with the
Prothonotary: July 22, 2008
i?fie, Esquire
& ASSOCIATES
for Plaintiff
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF PENNA.
MARISSA SID ,-
Plaintiff
VERSUS
GEORGE E. SEE7GGER, JR.
Defendant
No. 06-2395
DECREE IN
DIVORCE
AND NOW, -J "**'j 10 2008 , IT IS ORDERED AND
DECREED THAT MARISSA SEEGER
AND
GEORGE E. SEEGER, JR.
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
PLAI NTI FF,
, 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;
The stipulation entered into before the Divorce Master on Tuesday,
July 22, 2008, is incorporated herein.
BY THE COURT:
ATTEST: J.
PROTHONOTARY
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