Loading...
HomeMy WebLinkAbout06-4038 KOPE & ASSOCIATES, LLC BY: SHANE B. KOPE, ESQ. ATTORNEY I.D. 92207 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 sbkonetalcomcast.net Attorney for Plaintiff vs. IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ~ NO. O~ - 'I6if {!,'u~L y~ : CIVIL ACTION - LAW : IN DIVORCE MELISSA CHRONISTER Plaintiff, TODD CHRONISTER Defendant. NOT ICE 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 action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. MELISSA CHRONISTER Plaintiff, TODD CHRONISTER Defendant. CIVIL ACTION - LAW IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302(d) of the Divorce Code, you may request the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania 17013. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this 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 days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. KOPE & ASSOCIATES, LLC BY: SHANE B. KOPE. ESQ. ATTORNEY 1.0.92207 4660 Trindle Road. Suite 201 Camp Hill, PA 17011 (717) 761-7573 sbkopecalcomcaslnet Attorney for Plaintiff MELISSA CHRONISTER Plaintiff, IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. ~ NO. 01.. - 46:iJ> Ciu~L T€fl-hJ.. TODD CHRONISTER Defendant. : CIVIL ACTION - LAW : IN DIVORCE COMPLAINT IN DIVORCE AND NOW comes the abov~named Plaintiff, MELISSA CHRONISTER, by and through her attorney, SHANE B. KOPE, ESQ., and makes the following Complaint in Divorce: 1. The Plaintiff is MELISSA CHRONISTER, an adult individual who currently resides at 133 E. Winding Hill Road, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. The Defendant is TODD CHRONISTER, an adult individual who currently resides on Marble Street, Mechanicsburg, Cumberland County, Pennsylvania, 17050. 3. Both the Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. . ' 4. The Plaintiff and Defendant were married on November 29, 2003 in Mechanicsburg, Cumberland County, Pennsylvania. 5. The Parties separated on July 26, 2005 when Defendant left the home, 6. Neither the Plaintiff nor Defendant is in the military service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 7, There has been no prior action for divorce or annulment instituted by either of the parties in this or any other jurisdiction. 8. Plaintiff has been advised of the availability of marriage counseling and the right to request that the Court require the parties to participate in counseling. COUNT I REQUEST FOR A NO-FAULT DIVORCE UNDER SECTION 3301 (c) OF THE DIVORCE CODE 9. The prior paragraphs of this Complaint are incorporated herein by reference as though set forth in full. 10. The marriage of the parties is irretrievably broken. WHEREFORE, if both parties file affidavits consenting to a divorce after (90) ninety days have elapsed from the date of service of this Complaint, Plaintiff respectfUlly requests that the Court enter a Decree of Divorce pursuant to Section 3301 (c) of the Divorce Code. . . COUNT II REQUEST FOR A NO-FAULT DIVORCE UNDER SECTION 3301 (d) OF THE DIVORCE CODE 11. The prior paragraphs of this Complaint are incorporated herein by reference as though set forth in full. 12. The marriage of the parties is irretrievably broken. 13. The parties are living separate and apart and at the appropriate time Plaintiff will submit an affidavit alleging that the Parties have lived separate and apart for at least two (2) years as Specified in Section 3301 (d) of the Divorce Code. WHEREFORE, Plaintiff respectfully requests that the Court enter a Decree of Divorce pursuant to Section 3301 (d) of the Divorce Code. COUNT III REQUEST FOR EQUITABLE DISTRIBUTION OF MARITAL PROPERTY UNDER SECTION 3502 (a) OF THE DIVORCE CODE 14. The prior paragraphs of this Complaint are incorporated herein by reference as though set forth in full. 15. Plaintiff and Defendant have acquired marital property as defined by the Divorce Code, which is subject to equitable distribution pursuant to Section 3502 (a) of the Divorce Code. 16. Plaintiff and Defendant have been unable to agree to the equitable distribution of said property, as of the date of filing of this Complaint. . . 17. Plaintiff requests that the Court equitably divide, distribute, or assign the marital property between the parties. WHEREFORE, Plaintiff respectfully requests that the Court enter an order of equitable distribution of marital property pursuant to Section 3502 (a) of the Divorce Code. COUNT IV ALIMONY 18. The prior paragraphs of this Complaint are incorporated herein by reference as though set forth in full. 19. Plaintiff, even though is currently working and makes substantial income, it is not enough to provide for her reasonable needs in accordance with the standard of living the parties established during their marriage. 20. The Defendant is employed and enjoys a substantial income from which he is able to contribute to the support and maintenance of the Plaintiff and pay her alimony in accordance with the Divorce Code of Pennsylvania. WHEREFORE, Plaintiff respectfully requests that the Court enter an Order awarding Plaintiff from Defendant permanent alimony in such sums as are reasonable and adequate to support and maintain Plaintiff in the station of life to which she has become accustomed during the marriage. . . COUNT V ALIMONY PENDENTE LITE 21. The prior paragraphs of this Complaint are incorporated herein by reference as though set forth in full. 22. Plaintiff, even though is currently working and makes a substantial income, it is not enough to support and maintain herself during the pendency of this action. WHEREFORE, Plaintiff respectfully requests that the Court Order Defendant to pay him reasonable alimony pendente lite during the pendency of this action. Respectfully Submitted, Dated: '0 z. / z ovt;, . . JUL 11 2006 16:50 FR JUL..-J,J.-~racJO ...J"c...J ,,,.,, ... ... ,.....--.... TO 97617572 P.02/02 " ."I , : ,'" , " " . . J .' . ,'.' . VERIFICATION , . . <:! I, Melissa Chronister, the Plaintiff in this matter, have read the foregoing Complaint. I verify that my averments in this Complaint are true and correct and based . . . ,", upon my personal knowledge. I understand that any false statements herein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsifications to authorities. I')' . ", ~~? ',:~: :~- ~r" Dated: =1-11- Dc... ~~~~(lW\l~ elissa Chr ter , . " '. ~ :' .... .' ,- :::,;:~.::' '~f. ~.": .~:~. ';'l .,' ". . ." t.: 1" .' ~" ,.: ',,' ',.. ~' ",; " . " ~ '. ".. , . "j " JUL 11 2006 15:21 :(:~ i~:. .,t:~:: fi"_. "'I". ""'f 1 . ~. <-. tI'" TOTAL p.as 717 737 6658 PAGE.0S ** TOTAL PAGE.02 ** ~ ~\\. L -lQ.. ~ - w~..o , ~""; 0 C C) .',i .-\ - "'0 ~.- - .." - ~ lrt , Co C> B ..... ..:s. I I , ~ ' " ~)-i . , "', , ' b 1~ r- ~ ... LAW OFFICES OF PETER J. RUSSO, P .C. 3800 Market Street Camp Hill, PA 17011 (717) 591-1755 MELISSA L. CHRONISTER, Plaintiff Attorneys for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 06-4038 Civil Term TODD A. CHRONISTER, Defendant CIVIL ACTION - LAW PETITION FOR SPECIAL RELIEF FOR THE PROTECTION OF MARITAL FUNDS AND NOW COMES the Petitioner, Todd A. Chronister, by his attorney, Elizabeth J. Saylor, Esquire, and files this, his Petition for Special Relief for the Protection of Marital Funds of which the following is a statement. 1. Petitioner is Todd A. Chronister (hereinafter "Husband"), an adult individual who currently resides at 403 West Marble Street, Mechanicsburg, Pennsylvania 17055. 2. Respondent is Melissa L. Chronister, (hereinafter 'Wife"), an adult individual who currently resides at 133 East Winding Hill Road, Mechanicsburg, Pennsylvania 17055. 3. Husband and Wife were married on November 29, 2003, in Mechanicsburg, Pennsylvania. 4. Husband moved out of the marital residence on or about July 26, 2005. 5. Husband and Wife held a joint savings account, checking account and other money management accounts held with Member's First Federal Credit Union of which Wife was the primary bookkeeper. ~ 6. Said accounts were the only accounts in which during the course of the marriage Husband and Wife both deposited earnings into and withdrew money from for marital expenses. 7. It is believed that in April, 2006, said accounts carried a balance of approximately $101,000.00. 8. In June, 2006, Husband learned that Wife had withdrawn approximately $65,000.00 from said accounts with intent of placing the $50,000.00 towards debt incurred solely in the name of Wife, 9. Husband concerned of misappropriation of marital assets withdrew the remaining funds held within said accounts of approximately $26,500.00. 10. Upon Wife's request, Husband deposited approximately $13,000.00 back into said accounts. 11 . Wife then withdrew all monies from said accounts. 12. Wife obviously cannot be trusted to safeguard the marital assets pending the agreement of the parties as to equitable distribution. WHEREFORE, Petitioner requests this Honorable Court to enter an Emergency Order requiring Wife to deposit $37,000.00 into an interest bearing account within Twenty (20) days of this Order, and prohibiting both Husband and Wife from withdrawing any funds from said accounts until an agreement of the parties as to equitable distribution is reached or an Order of Court is rendered. Wife shall be required to provide Husband with proof of said deposit within seven (7) days of the deposit. I < Elizabeth J. Saylor, squire I.D. No. 200139 The Law Offices of Peter J. Russo, P .C. 3800 Market Street Camp Hill, PA 17050 717-591-1755 Attorney for Todd A. Chronister MELISSA L. CHRONISTER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 06-4038 Civil Term TODD A. CHRONISTER, Defendant CIVIL ACTION - LAW VERIFICATION I, Todd A. Chronister, verify that the statements made in the foregoing document(s) are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. ~ 4904 relating to unsworn falsification to authorities. Date: 7- ~C <C:J r; ~.~-~<S- ~ Todd A. Chronister '- MELISSA L. CHRONISTER, Plaintiff v. TODD A. CHRONISTER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-4038 Civil Term CIVIL ACTION - LAW CERTIFICATE OF SERVICE I, Janet E. Bush, hereby certify that I am on this day serving a copy of the foregoing documents upon the person(s) and in the manner indicated below: US Mail and addressed as follows: Shane B. Kope The Law Offices of Shane B. Kope 4660 Trindle Road Suite 201 Camp Hill, PA 17011 Date: f) ~ dlQ - 0 ~ .J- c:;-... t-) -Tl :.:::! \~{l ( .. ~".; -.I "" r,) ., ~-() _. .1 ~-< LA WOFFICES OF PETER J. RUSSO, P.C. 3800 Market Street Camp Hill, P A 17011 (717) 591-1755 MELISSA L. CHRONISTER, Plaintiff v. TODD A. CHRONISTER, Defendant Attorneys for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-4038 Civil Term CIVIL ACTION - LAW ENTRY OF APPEARANCE AS COUNSEL Kindly enter my appearance as counsel on behalf of Todd A. Chronister, Defendant in the above matter. 7- .,l t- d (- Date: ~.. J ~~ La; Offices eter J. R:sso, P .C. 3800 Market Street Camp Hill, P A 17011 Peter J. Russo, Esquire I.D. No. 72897 Scott A. Stein, Esquire I.D. No. 81738 Elizabeth J. Saylor, Esquire I.D. No. 200139 i I I I i I I j ,~, :::''::J -:) ,",]'''' .r: " ,I ':f'J r.,:, -, l'o) \.D . LAW OFFICES OF PETER J. RUSSO, P.C. 3800 Market Street Camp Hill, P A 17011 (717) 591-1755 MELISSA L. CHRONISTER, Plaintiff Attorneys for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 06-4038 Civil Term TODD A. CHRONISTER, Defendant CIVIL ACTION - LAW DEFENDANT'S COUNTERCLAIM AND NOW, COMES the above-named Defendant by and through his attorney Elizabeth J. Saylor, and files this Answer and Counterclaim and, in support thereof, avers the following: 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. By way of further response, Defendant left the martial home upon Wife's request to do so. 6. Admitted. 7. Admitted. 8. Admitted. PLAINTIFF'S COUNT I 9. Denied. The rules of civil procedure do not require a response to the advent contained in paragraph 9. 10. Admitted. PLAINTIFF'S COUNT II 11. Denied. The rules of civil procedure do not require a response to the advent contained in paragraph II. 12. Admitted. 13. Admitted. PLAINTIFF'S COUNT III 14. Denied. The rules of civil procedure do not require a response to the advent contained in paragraph 14. 15. Admitted. 16. Admitted. 17. Admitted. PLAINTIFF'S COUNT IV 18. Denied. The rules of civil procedure do not require a response to the advent contained in paragraph 18. 19. Denied. Wife has earned an income approximately three (3) times that of Husband during the parties' twenty (20) months of marriage. By way of further response Wife is believed to be engaged in an extramarital affair. 20. Denied. Wife has earned an income approximately three (3) times that of Husband during the parties' twenty (20) months of marriage. By way of further response Wife is believed to be engaged in an extramarital affair. PLAINTIFF'S COUNT V 21. Denied. The rules of civil procedure do not require a response to the advent contained in paragraph 21. 22. Denied. Wife has earned an income approximately three (3) times that of Husband during the parties' twenty (20) months of marriage. By way of further response Wife is believed to be engaged in an extramarital affair. DEFENDANT'S COUNTERCLAIM COUNT I: DIVORCE - ALIMONY PENDENTE LITE, ALIMONY, COUNSEL FEES AND COSTS 1. Paragraphs 1-22 of Defendant's Answer and Counterclaim are incorporated herein by reference as though set forth in full. 2. Defendant is without sufficient resources so as to pay for his reasonable needs, counsel fees and costs of these proceedings. WHEREFORE, Defendant prays that a decree be entered in favor of the Defendant and against the Plaintiff as follows: That a decree in divorce be entered granting alimony in an amount sufficient to meet his reasonable needs, counsel fees and costs. Elizabeth J. or, Esquire J.D. No. 200139 The Law Offices of Peter J. Russo, P.C. 3800 Market Street Camp Hill, P A 17050 717-591-1755 Attorney for Defendant, Todd A. Chronister . MELISSA L, CHRONISTER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. TODD A. CHRONISTER, Defendant CIVIL ACTION - LAW VERIFICATION I, Todd A. Chronister, verifY that the statements made in the foregoing document( s) are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. ~ 4904 relating to unsworn falsification to authorities. Date: ? Z(:-06 c~~ Todd A. Chronister - . MELISSA L. CHRONISTER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. TODD A. CHRONISTER, Defendant CML ACTION - LAW CERTIFICATE OF SERVICE I, Janet E. Bush, hereby certify that I am on this day serving a copy of the foregoing documents upon the person(s) and in the manner indicated below: US Mail and addressed as follows: Shane B. Kope The Law Offices of Shane B. Kope 4660 Trindle Road Suite 201 Camp Hill, PA 17011 Date: ..J /).-\.0 - 6\.,.0 i r! ......, ,~~ C::::.J ) C. -,..1 , ::::1 ~". -il r....) -J -. r'.J , LC.' KOPE & ASSOCIATES, LLC BY: SHANE B. KOPE, ESQ. ATTORNEY 1.0. 92207 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 sbkope@comcast.net Attorney for Plaintiff MELISSA CHRONISTER Plaintiff, vs. IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 06-4038 : CIVIL ACTION - LAW : IN DIVORCE ACCEPTANCE OF SERVICE TODD CHRONISTER Defendant. I accept service of the Divorce Complaint on behalf of the Defendant and certify that I am authorized to do so. Dated: 7 - J-~ ~ <0 cfJ/ocS-~ Elizabeth J. Saylor, Esquire LAW OFFICE OF PETER J. RUSSO 3800 Market Street Camp Hill, PA 17011 Attorney for Defendant ~:-J " c:: , ,( ...... ~ ty JUL 2 8 2006r LAW OFFICES OF PETER J. RUSSO, P.C. 3800 Market Street Camp Hill, PA 17011 (717) 591-1755 MELISSA L. CHRONISTER, Plaintiff Attorneys for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 06-4038 Civil Term TODD A. CHRONISTER, Defendant CIVIL ACTION. LAW ORDER AND NOW, to wit, this b\ day of r::l" 0 -.>s--t ,2006, upon consideration of the within Motion, the following is ORDERED: 1. A hearing is scheduled for ()1'1;, q ,~tfJ' I in Courtroom / at It) ; t.f.,.. ----A-.M. number I ~ \ ..---... , - - -=-- 2. Pursuant to the agreement of the parties pending the hearing, Plaintiff and Defendant shall: a. Wife shall deposit $37,000.00 into an interest bearing account within Twenty (20) days of this Order, and b. Both Husband and Wife shall not withdraw any funds from said accounts until an agreement of the parties as to equitable distribution is reached or an Order of Court is rendered, Wife shall '. .---.) :') I t .. . be required to provide Husband with proof of said deposit within seven (7) days of the deposit. Distribution List: Elizabeth J. Saylor, Esquire Law Offices of Peter J. Russo, P.C. 3800 Market Street Camp Hill, PA 17011 Shane B. Kope The Law Offices of Shane B. Kope 4660 Trindle Road Suite 201 Camp Hill, PA 17011 ~ ~~~~ BY THE COURT, dJ~ . ' ~~...h~ J. f. b3-ol- ~ KOPE & ASSOCIATES, LLC BY: SHANE B. KOPE, ESQ. ATTORNEY 1.0. 92207 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 sbkope@comcast.net Attorney for Plaintiff MELISSA CHRONISTER Plaintiff, vs. IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 06-4038 TODD CHRONISTER Defendant. : CIVIL ACTION - LAW : IN DIVORCE MOTION FOR RECONSIDERATION OF ORDER FOR SPECIAL RELIEF AND NOW comes the above-named Plaintiff, MELISSA CHRONISTER, by and through her attorney, SHANE B. KOPE, ESQ., and makes the following Appeal of the Order for Special Relief of which the following is a statement: 1. The Plaintiff is MELISSA CHRONISTER, an adult individual who currently resides at 133 E. Winding Hill Road, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. The Defendant is TODD CHRONISTER, an adult individual who currently resides on Marble Street, Mechanicsburg, Cumberland County, Pennsylvania, 17050. 3. Husband and Wife were married on November 29,2003, in Mechanicsburg, Pennsylvania 17055. 4. The Parties separated on June 26, 2005 when Husband moved out of the marital home. 5. Husband and Wife held a joint savings account, checking account, CDs and other money management accounts with Member's First Federal Credit Union (hereinafter MFFCU) of which Wife was the primary bookkeeper. 6. Said accounts were the only accounts in which during the course of the marriage in which Wife and Husband deposited and withdrew money for marital expenses. 7. Husband also possessed a business account into which he placed the majority of his business income. 8. As of the date of separation, the balance of these joint accounts at MFFCU was approximately $33,350.84. 9. In January of 2006, Wife borrowed the sum of $70,000 from the MFFCU for improvements to her home, which she purchased in 1994 prior to her marriage to Husband. This sum was borrowed in her name only, post the date of separation. Said amount was automatically deposited on January 26, 2006, into Husband and Wife's joint checking account at MFFCU. 10. On May 14, 2006, Wife transferred $50,000 of said money out of the joint account into a personal account. On the same day, Wife withdrew $5,000 of said money to make a payment on the loan. 11. On June 4, 2006, Wife withdrew $5,000 of said money to make another payment on the loan. 12. On June 19, 2006, Wife transferred another $5,000 of said money to her personal account. Said withdrawals constituted $65,000, which was less than the loan amount deposited into the account. 13. As of June 19, 2006, therefore, Wife had only withdrawn the proceeds of a personal loan entered into post-separation from their joint account. 14. On June 26,2006, upon learning that Wife had removed the proceeds of her personal loan money, Husband withdrew all monies from the joint checking account, savings account, and CDs. This amount equaled $26,810.40. 15. Husband did not remove the monies from the joint money management accounts, the remaining sum at this time being $4,750. 16. Husband replaced some of the money into the joint checking account in two installments. On June 29,2006, Husband replaced $10,555. On July 3,2006, Husband replaced $2,500. Total of said replaced monies equaled $13,055. Husband thus retained $13,755.40 of the joint marital funds. 17. Fearing that her husband would once again withdraw all of the joint marital funds, Wife transferred $12,000 ofthese funds to her personal account on July 3. 18. On July 27, 2006, Husband filed a petition for special relief for the protection of marital funds, representing that the Wife had depleted approximately 83,000 of marital funds. 19. As regards this Petition, this Court granted as an Emergency Order without hearing on August 1, 2006, requiring the wife to deposit $37,000.00 into an interest-bearing account within Twenty (20) days of the Order. 20. Husband knew at all times that the $70,000 deposited in January was money borrowed only by his wife after their separation, and as such, did not constitute marital property . 21. As regards the monies from the joint account, Husband withdrew a greater proportion of these monies than Wife, and as such, has no cause to plead to the Court for special relief. 22. Husband's Petition for Special Relief contained draft orders for your Honor to enter. The Order entered by your Honor contained the scheduling information for the hearing on this issue, and provided for the Wife to deposit $37,000 into an interest- bearing account pursuant to "the agreement of the parties pending the hearing." At no time has an agreement been reached between the Parties regarding the protection of marital funds. 23. Husband has indicated that he is seeking this relief to exact revenge. WHEREFORE, Appellant requests this Honorable Court to reconsider and reverse its Emergency Order requiring Wife to deposit $37,000.00 into an interest- bearing account within Twenty (20) days of the Order. Respectfully Submitted, ~/LLC Dated: ~S'/O, KOPE & ASSOCIATES, LLC ATTORNEY 1.0. 92207 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 sbkoDe@comcaslnet Attorney for Plaintiff MELISSA CHRONISTER Plaintiff, vs. IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. TODD CHRONISTER Defendant. : CIVIL ACTION - LAW : IN DIVORCE CERTIFICATE OF SERVICE I, Shane B. Kope, do hereby certify that on this 14th day of August, 2006, I served a true and correct copy of the foregoing Plaintiff's Motion for Reconsideration of Order for Special Relief via regular U.S. First Class mail, postage prepaid, addressed as follows: Elizabeth Saylor, Esquire Law Office of Peter J. Russo 3800 Market Street Camp Hill, PA 17011 KOPE & ASSOCIATES, LLC ~~ S B. Ko e, ES;' 1.0. 92207 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 AUG 14 2006 17:23 FR ~uU-~~-'~~b ~~.~ ~ur~ . H~~~~HI~~. TO 97617572 P.04/04 I~r r~1 gg~g ~.~r VERIECATLQN I, Melissa Chronister. the Plaintiff in this matter, nave read the foregoing Complaint. I verify that my averments in this Complaint are true and correct and based upon my personal knowledge. I understand that any false statements herein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsifications to authorities. Dated: sf (4../ V" , 111~ Melissa Chr . er ',f j' '. ,,\ ~ '. J:~ ,: :"; :~~. i?f1;~!:: } ,~ 'Y". ~~~: ,,' .. ""\, ,.j' ~. \ ~'IL 't I'. .. ,,'... 1.,1 i. ~"~: :.:J~' , ~ ~', ;.~;>,~.~ f~:!:~:~>;,;i' di~>' :i'~~.. !' ~')J~"':: \ "~., ,,:, :., ~'i" 'i Ii' ': .,.... . '. .... I' . ,t" . I ',t . . ~ t' " ;, ", , ~ . .:~ ," I . t, ' it ". ;.~ '!. ~:,..; ';; i I; ., 0' " 0" ~ .i... ";l.~:j ~ ' ::,: ~ :,:: ~ ': :\'..~ ..~':;.' ~ , I:;, ';:t' " '. ,~~., ,.,.: ; ., I', ..:; ~ " '.. ::'" ,'f " , .... . i \if(,1 . .', , ..~~ ',: j. .. . ~ ; ':.........{ .! \.. 'r-..- "J, i : .,1: .;~'. :'. r l' '; :.~'..~~ ~, . ~ '\" , : : 'if;' ';.; ~< .f? ,,~'. t "". '1' .. ,', r / ,':','" \..'~1 f' r '...' l ' . ~ ~~.:,~, 'u ;..II -:: r: :~~.~. ~;~'.i ~: '~ ~,tY , " , , , , , .: , . . ' , J ". , ~ . ,'~,.. I I '., ., I . , . ',,\01.' ::.' '~,I . : "" I, '.: ., " 1\,. .,..~(~~' " " , I I. . I ." . I, :: <r.? ," -. t ' [;'., , , . 'oj "'1 " ',:'. ,'I.. 'f# 4,'" ,j. ~ ..f. I, , --,., , '{' i,' '\ ;\ .\! :';~ .,'1', ..~. " '" fIl. ~ t" ';.. TOTAL P. B7.'...~.... PAGE.a7 ** TOTAL PRGE.04 ** ALG 14 21211216 1:3: Bl2I ?1 7 737 6658 a c ->' ..::...~.~ dj\}' z (f) -.( S~: :~~: (",'" ~:C) r-.3 c::::> ,= <:::r' -... c: G') O::J Z :.:l -0 :3': f)? ~ ..... ~-n "'F -n IT, -")0 (~)b ~-S :l~ 2m O' --I ~ .r:.- 0:> - , KOPE & ASSOCIATES, LLC BY: SHANE B. KOPE, ESQ. ATTORNEY 1.0. 92207 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 sbkope@comcast.net Attorney for Plaintiff MELISSA CHRONISTER Plaintiff, vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-4038 TODD CHRONISTER Defendant. : CIVIL ACTION - LAW : IN DIVORCE PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of Lesley J. Beam, Esq, of Kope & Associates, LLC of 4660 Trindle Road, Suite 201, Camp Hill, Pennsylvania 17011, on behalf of the Plaintiff, Melissa Chronister, in connection with the above-captioned divorce action. Respectfully Submitted, BY: '~ esley . 10# 91 7 4660 Trindle Road Suite 201 Camp Hill, PA 17011 (717) 761-7573 Date: ~/;;JJo~ - " KOPE & ASSOCIATES, LLC BY: SHANE B. KOPE, ESQ. ATTORNEY 1.0. 92207 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 sbkope@comcaslnet Attorney for Plaintiff MELISSA CHRONISTER Plaintiff, vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-4038 : CIVIL ACTION - LAW : IN DIVORCE CERTIFICATE OF SERVICE TODD CHRONISTER Defendant. I, Lesley J. Beam, Esquire do hereby certify that on this 21st day of August, 2006, I served a true and correct copy of the foregoing Praecipe to Enter Appearance via regular U.S. First Class mail, postage prepaid, addressed as follows: Elizabeth Saylor, Esquire Law Office of Peter J. Russo 3800 Market Street Camp Hill, PA 17011 KOPE &A SOCIATES, LLC By: ,~, sley J B am, Esq. 1.0.911 5 4660 indle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 , -0 :;3: ~ ~-n ;B Db "'I..,.. ~:D '~:l;JfO :::-(n 9 - ;; ~ ~ <2 ~~ -0 it l~\~., <!} ~::.~ ~,> ~~Tt,~ ~ ~ ~ ~ en N - c "' MELISSA CHRONISTER,: Plaintiff IN TIlE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION - LAW TODD CHRONISTER, Defendant NO. 06-4038 CIVIL TERM ORDER OF COURT AND NOW, this 31st day of August, 2006, upon consideration of Plaintiff's Motion for Reconsideration of the order of court dated August 1, 2006, and following a telephone conference with counsel for the Plaintiff in the person of Lesley Beam, Esq., and counsel for the Defendant in the person of Elizabeth J. Saylor, Esq., in which both counsel indicated that the second paragraph of the order dated August 1, 2006, had not been agreed to by Plaintiff, and both counsel having consented to the amendment of the order as provided for hereinafter, the motion is granted to the extent that the second paragraph of the said order is amended to read in its entirety as follows; 2. Pending the hearing scheduled for October 9, 2006, and further order of court, neither party shall transfer, encumber, spend, give away, dispose of, or otherwise diminish in value any marital asset. BY TIlE COURT, J. ~\)~ ?\\) o l/JN\l~rv.})\jl\!::id 'i""''''' .-", '-', '", ""'rtf'\ ^ Pi! It,;, ! ":.<,:' "'~~r-j~~ ;,J 8 I :" \>1\1 1- d3S 900l AUWlO'-"'..I ,c" 'J "lHl ::10 a v _ I'lVru\....(j(J;J ::.rX:i:{)--Q311:l Lesley Beam, Esq. Kope and Associates, LLC 4660 Trindle Road Suite 20 I Camp Hill, P A 17011 Attorney for Plaintiff Elizabeth Saylor, Esq. Law Office of Peter J. Russo 3800 Market Street Camp Hill, PA 17011 Attorney for Defendant :rc , . f << LAW OFFICES OF PETER J. RUSSO, P.c. 3800 Market Street Camp Hill, PA 17011 (717) 591-1755 Attorneys for Defendant MELISSA L. CHRONISTER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. NO. 06-4038 Civil Term TODD A. CHRONISTER, Defendant CIVIL ACTION - LAW DEFENDANT'S ANSWER TO PLAINTIFF'S MOTION FOR RECONSIDERATION OF ORDER FOR SPECIAL RELIEF AND NOW, COMES the above-named Defendant by and through his attorney Elizabeth J. Saylor, and files this Answer and Counterclaim and, in support thereof, avers the following: 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. 6. Admitted. 7. Admitted. 8. Defendant, after investigation, is without sufficient knowledge to affirm or deny as Wife was the primary bookkeeper of the marital assets. 9. Admitted in part and denied in part. Admitted that Wife borrowed a sum of $70,000.00 for improvements to her home which she purchased prior to the parties' marriage. It is admitted that this sum was borrowed post separation. It is denied that the sum was deposited into Husband and Wife's joint checking account, as $70,000 was deposited into Husband and Wife's joint savings account on January 26,2006. Further, Husband and Wife lived at the aforementioned home in which improvements were to be made during their marriage. Husband is without sufficient knowledge to affirm or deny as to whether Wife borrowed the sum of$70,000.00 in her name only or as to whether the amount was automatically deposited into a MFFCU account belonging to Husband and Wife. 10. Admitted in part and denied in part. It is admitted that on May 14, 2006, the banking statements state that Wife transferred $50,000.00 into a personal account and withdrew an additional $5,000.00. Defendant is without sufficient knowledge to affirm or deny for what purpose this money was withdrawn. 11. Admitted in part and denied in part. It is admitted that on June 4, 2006, the bank statements state that Wife withdrew $5,000.00. Defendant is without sufficient knowledge to affirm or deny for what purpose this money was withdrawn. 12. Admitted in part and denied in part. It is admitted that on June 19,2006, the bank statements state that Wife transferred $5,000.00 to her personal account. It is denied that said withdrawals constituted $65,000.00 as additional amounts have also been withdrawn since the separation date. Specifically, it is believed that between January 2006 and July 2006 Wife has withdrawn sums exceeding $121,000.00 from Husband and Wife's MFFCU accounts. 13. Denied. Wife has withdrawn amounts in excess of$65,000.00, the amount of her personal loan. 14. Admitted in part and denied in part. Husband admits to withdrawing a total of $26,854.64 from the joint checking account upon learning that Wife had removed funds. It is specifically denied that Husband had knowledge that Wife was removing the funds for her personal loan as monies in excess of $70,000.00 had been withdrawn by Wife. 15. Admitted in part and denied in part. It is admitted that Husband did not remove $4, 750.00 from the joint money management accounts, as Mrs. Chronister withdrew said amount on June 26,2006, as well as $5,000.00 on May 14, 2006, and $840.00 on July 3, 2006, from the joint money management accounts. 16. Admitted in part and denied in part. It is admitted that Husband made a deposit on June 29, 2006 and July 3,2006, totaling $13,055.00. However, it is believed that Husband thus retained $13,799.64 of the joint marital funds. 17. Denied. It is denied that Wife withdrew $12,000.00 from the joint marital funds. On July 3,2006, Wife withdrew $13,800.00 from the parties' joint checking account. By way of further response, Defendant is without sufficient knowledge to affirm or deny why Wife withdrew said funds or where the funds were directed. 18. Admitted. 19. Admitted. 20. Denied. The allegation set forth in paragraph 20 is a legal conclusion to which no response is required. By way of further response, it is denied that Husband knew at all times that the $70,000.00 deposited in January was money borrowed only by his Wife after their separation, and as such, did not constitute marital property. 21. Denied. Wife has withdrawn over $121,000.00 from marital funds while Husband has only withdrawn $26,854.64 and upon Wife's request, Husband deposited $13,055.00 of that amount back into the parties' joint account making the balance of Husband's withdrawals only $13,799.64. 22. Admitted. 23. Denied. It is denied that Husband has indicated that he is seeking this relief to exact revenge, as Husband is simply concerned about the dissipation of marital assets. By way of further response, Husband is only seeking this relief because Wife was the primary bookkeeper and the accounts were the only accounts that Husband and Wife held together and paid monthly bills from. Husband noticed that the funds were being depleted and Husband was unaware of where the funds were being directed. WHEREFORE, Defendant and his counsel request that Wife be required to deposit $37,000.00 into an interest-bearing account. Respectfully submitted, Zt: -^^ Elizabeth 1. Saylor, Esquire I.D. No. 200139 The Law Offices of Peter J. Russo, P.c. 3800 Market Street Camp Hill, P A 17050 717-591-1755 Attorney for Defendant, Todd A. Chronister MELISSA L. CHRONISTER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 06-4038 TODD A. CHRONISTER, Defendant CIVIL ACTION - LAW VERIFICA nON I, Todd A. Chronister, verify that the statements made in the foregoing document( s) are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. S 4904 relating to unsworn falsification to authorities. ~) - -" . J/- (I' ',_ k; "'......- " r~ k ~/ ^2_,,";';::, Date:...... :,,;.;i/?"" -e:"'2~..-.._~ ,/~'-'.. -<~...., ^^ .~~ ... ~,.,.",....~..^. 6....". ..-?~ ,-"'~ ..-.~ --......-. . .," ~-,~ Todd A. Chronister MELISSA L. CHRONISTER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. NO. TODD A. CHRONISTER, Defendant CIVIL ACTION - LAW CERTIFICATE OF SERVICE I, Janet E. Bush, hereby certify that I am on this day serving a copy ofthe Defendant's Answer to Plaintiffs Motion for Reconsideration of Order for Special Relief upon the person(s) and in the manner indicated below: US Mail and addressed as follows: Leslie Beam, Esquire The Law Offices of Shane B. Kope 4660 Trindle Road Suite 201 Camp Hill, P A 17011 Date: '8 - 3 i - d to r U1 ;,") C) .-< "'" C.:,) '~ . :. ~'\ r,--,: I --.J ~. (") ~ .." MELISSA CHRONISTER,: Plaintiff v. TODD CHRONISTER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW NO. 06-4038 CIVIL TERM IN RE: DEFENDANT'S PETITION FOR SPECIAL RELIEF FOR THE PROTECTION OF MARITAL FUNDS ORDER OF COURT AND NOW, this 6th day of October, 2006, upon consideration of the attached letter from Elizabeth 1. Saylor, attorney for Defendant, the hearing previously scheduled in the above matter for October 9,2006, is cancelled. ~lie Beam, Esq. Kope and Associates, LLC 4660 Trindle Road Suite 201 Camp Hill, PA l7011 Attorney for Plaintiff /~~lizabeth Saylor, Esq. Law Office of Peter J. Russo 3800 Market Street Camp Hill, PA 17011 Attorney for Defendant :rc BY THE COURT, ~ , 6 rj : I l,,!d 9- J.80 900l Ab'Vl.O:'.!C; UDtJd 3H1 :10 38J.::,i.:~,()-031t::J From:AMERICAN SETTLEMENT SERVICES 7179205238 10/06/2006 09:40 #082 P.002/004 \ "'-..4fa .. LAW OmCES OF PETER J. Russo, p.e. ATTORNEYS AT LAW 3800 Marlcet Sb'eet Camp Hill, PA 17011 Peter J. Russo, Esquire lohn N. Papautsis. Esquire Scott A. Stein. Esquire Elizabeth J. Saylor. Bsquite Wednesdav. October 4. 2006 Cumberland County Courthouse Attn: The Honorable Judge Oler's Chambers 1 Courthouse Square Carlisle, PA 17013 VIA FACSIMILE ONLY 717 -240-8462 RE: Chronister v. Chronister, NO. 06-4038 Civil Term Dear Judge Oler: The parties in the above referenced matter have reached an agreement. Therefore, I have filed the attached Praecipe to Withdraw my Petition for Special Relief for the Protection of Marital Funds filed on July 27, 2006, and respectfully request that the hearing scheduled for October 9, 2006, be cancelled. Elizabeth J. Saylor. Esquire 1.0. No. 200139 The Law Offices of Peter J. Russo. P.C. 3800 Market Street Camp Hill, PA 17050 717-591-1755 Enclosu res/attach ments cc: Leslie Beam. Esquire (Plaintiff's Counsel) 4660 Trindle Road Suite 201 Camp Hill. PA 17011 Fax: 717-761-7572 (VIA FACSIMILE ONLY) PHONE: (717) 591-1755 THE CHELSEA Bun.DJNO FAX: (717) 591.1756 LAW OFFICES OF PETER J. RUSSO, P.C. 3800 Market Street Camp Hill, PA 17011 (717) 591-1755 MELISSA L. CHRONISTER, Plaintiff Attomeys for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 06-4038 Civil Term TODD A. CHRONISTER, Defendant CIVIL ACTION - LAW : JUDGE J. WESLEY OLER, JR Praecipe to Withdraw Defendant's Petition for Special Relief for the Protection of Marital Funds To the Prothonotary: Kindly withdraw Defendant's Petition for Special ReHat for the Protection of Marital Funds, which I filed on July 27,2006. Date: /(j-~ -Ob Respectfully submitted, ~_.~./ Elizabeth J. Saylor, Esquire 1.0. No. 200139 The Law Offices of Peter J. Russo, P.C. 3800 Market Street Camp Hill, PA 17050 717-591-1755 (") ~ 0 (? C c:.::-;. "''11 c:r~ C) c; \ CJ' ~;: ~... co -'C c o~ LAW OFFICES OF PETER J. RUSSO, P.C. 3800 Market Street Camp Hill, PA 17011 (717) 591-1755 MELISSA L. CHRONISTER, Plaintiff Attomeys for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 06-4038 Civil Term TODD A. CHRONISTER, Defendant CIVIL ACTION - LAW : JUDGE J. WESLEY OLER, JR CERTIFICATE OF SERVICE I, Janet E. Bush, hereby certify that I am on this day serving a copy of the Praecipe to Withdraw Defendant's Petition for Special Relief for the Protection of Marital Funds upon the person(s) and in the manner indicated below: US Mail and addressed as follows: Leslie Beam, Esquire (Plaintiff's Counsel) 4660 Trindle Road Suite 201 Camp Hill, PA 17011 Facsimile to: Leslie Beam, Esquire #717-761-7572 Date: I() - It; -()l.9 o C "".:.-- r-.) ~:::::) ~ C:,... o .~ o -1'1 ~11 flIp \ l_"~ \>-.' i w en N . ' \ , KOPE & ASSOCIATES BY: LESLEY J. BEAM, ESQ. ATTORNEY 1.0. 91175 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 Ibeam@kopelaw.com Attorney for Plaintiff vs. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PA : NO. 06-4038 MELISSA CHRONISTER, Plaintiff, TODD CHRONISTER, Defendant. : CIVIL ACTION - LAW : IN DIVORCE MARITAL SEPARATION AGREEMENT 1. INTRODUCTORY PROVISION This Agreement is made by and between Melissa Chronister of Cumberland County, Pennsylvania ("Wife") and Todd Chronister of Cumberland County, Pennsylvania ("H usband"). 2. WHEREAS CLAUSES WHEREAS, the parties hereto are Husband and Wife, having been married on November 29, 2003, in Mechanicsburg, Pennsylvania; WHEREAS, certain differences exist between the parties and they have decided to permanently live separate and apart from each other and they intend by this Agreement to fully and finally settle all of their respective rights and obligations as between each other, including, but not necessarily limited to the settling of all interests, rights and/or obligations between them or their estates, whether arising out of their marriage, including, but not limited to: a) the past, present and future support, alimony pendente lite, alimony or maintenance of either party by the other party; and (b) the ownership of all assets of whatever nature, including assets acquired by either party prior to or subsequent to the date of execution. of this Agreement; 1 , , 3. CONSIDERATION NOW, THEREFORE, in consideration of the premises and of the mutual promises, covenants and undertakings set forth in this Agreement and for other good and valuable consideration, the receipt and adequacy of which is hereby acknowledged by each of the parties hereto, Wife and Husband, intending to be legally bound hereby, covenant and agree as follows: SECTION I GENERAL PROVISIONS 4. INCORPORATION OF PREAMBLE The recitals set forth in the Preamble of this Agreement are incorporated herein and made a part hereof as if fully set forth in the body of the Agreement. 5. DEFINITIONS 5.01. Divorce Code. The phrase "Divorce Code" shall be defined as Pennsvlvania C.S.A.. Title 23, Section 101 et seq. (effective March 19, 1991). 5.02. Date of Execution of This Agreement. The phrase "date of execution", "execution date" or "date of this Agreement" shall be defined as the date that the last party signs this Agreement. 5.03. Date of Distribution. Except as defined in Paragraph 8.5 of this Agreement, the phrase "date of distribution" of this Agreement shall be defined as the earlier of the date of: (1) death of one of the parties; or (2) the thirty-first day subsequent to the date on which an initial divorce decree is entered without an appeal having been taken, or, if such an appeal has been taken, on the date of receipt of notice of final confirmation of the initial divorce decree by the appellate courts. If the distribution date falls on a date when the court which entered the decree in divorce or to which appeal was taken is closed for official business, then the distribution date shall be the next day on which that court is open for official business. 5.04. Internal Revenue Code. The phrase "Internal Revenue Code" or "I.R.C." shall be defined as the Internal Revenue Code of 1986, as amended, or any successor statute thereto. References to sections of the Internal Revenue Code shall refer to sections of the Internal Revenue Code as of the date of execution of this Agreement. 5.05. Asset. The word "Asset" shall be defined as anything of value, including, but not limited to, real and/or personal, tangible and/or intangible property and all financial interests however held. 5.06. Effective Date of Agreement. This Agreement shall become effective and binding upon both parties on the execution date of this Agreement. 2 6. DIVORCE DECREE 6.01. The parties acknowledge that their marriage is irretrievably broken and that they will secure a mutual consent, no-fault Divorce Decree in the above captioned divorce action. Wife previously filed a divorce action in the Court of Common Pleas of Cumberland County, Pennsylvania, Civil Term, 2006, No. 06-4038, seeking a divorce decree pursuant to, among other provisions, Section 3301 (c) of the Domestic Relations Code. Husband filed a counterclaim in Divorce in the Court of Common Pleas of Cumberland County, Pennsylvania, Civil Term, 2006, No. 06-4038. The parties shall promptly file the affidavits required to obtain a divorce pursuant to Section 3301 (c) of the Domestic Relation Code. As defined in the Domestic Relations Code, the parties' marriage is irretrievably broken and they do not desire marital counseling. The parties shall also take all legal steps (including, but not limited to, the timely and prompt submission of all documents and the execution of appropriate waivers of the right to file exceptions and of the right to file an appeal) necessary to ensure that a divorce pursuant to Section 3301 (c) of the Domestic Relations Code is entered as soon as possible/within one (1) month~), but in any event not later than three (3) months from the date of execution of this Agreement. 6.02. Responsibility for Proceeding With Divorce. Wife shall be responsible for the prompt filing of the Praecipe to Transmit the Record and the related required documents. Should Husband want a certified copy of the final divorce decree, Husband shall pay the required fee to secure that document. 6.03. Withdrawal of Other Actions. The parties further shall take all legal steps necessary to ensure that all pending petitions and actions between the parties (including, but not limited to counterclaims or petitions for economic relief), except for the divorce action referred to in this Paragraph (to the extent necessary to obtain the divorce), are dismissed with prejudice as soon as possible and that no similar actions are instituted, except to the extent necessary to enforce the terms of this Agreement. 6.04. Penalty for Delay. Notwithstanding the foregoing, if, after the execution of this Agreement, either party unreasonably delays or contests the obtaining of a final, unappealed divorce decree, that party shall exonerate and indemnify the other party against and hold the other party harmless from any liability and/or expense, including reasonable counsel fees, incurred as a result of such delay or contest in obtaining the decree. 3 7. EFFECT OF NO DIVORCE Except as otherwise provided for in this Agreement, this Agreement shall remain in full force and effect even if no final decree in divorce is entered. 8. EFFECT OF DIVORCE DECREE. INCORPORATION AND MERGER This Agreement shall continue in full force and effect after a final decree in divorce is entered in any jurisdiction, it shall survive and not merge into any such divorce, and its provisions shall not be affected by the entry of such a decree, surviving any such decree and remaining independent of any such decree. The terms of this Agreement shall be incorporated for enforcement purposes only, but not merged into the divorce decree. The Court entering the decree shall have all of the powers of enforcement, which, at the discretion of the nonbreaching party, shall include, but not necessarily be limited to, all of the following: for breach of contract, under theories of equity, and under the Divorce Code, including under Section 3105 (which includes contempt). The provisions of this Agreement shall not be modifiable for any reason. 9. ADVICE OF COUNSEL Wife has been represented by Lesley J. Beam, Esquire of Kope & Associates, LLC. Husband has been represented by Elizabeth J. Saylor, Esquire of the Law Offices of Peter J. Russo, P.C. Each party represents that he or she understands that, in the absence of this Agreement and as a matter of law: (1) as a surviving spouse, he or she might be entitled to a greater share in the decedent's estate than is provided for in this Agreement; and (2) as a separated and/or divorced spouse, he or she might be entitled to greater support, maintenance, alimony pendente lite, counsel fees, costs, alimony, distribution of property, or other financial benefits arising from the marital relationship than is provided for in this Agreement. Notwithstanding the foregoing, the parties shall be bound by the terms of this Agreement. Each of the parties further acknowledges and agrees that, with such knowledge, and after having read this Agreement carefully and fully, this Agreement is fair, reasonable and equitable, that it is being entered into freely, voluntarily, and in good faith, and that its execution is not the result of any duress, undue influence, coercion, collusion and/or improper or illegal agreement. 10. FINANCIAL DISCLOSURE The parties confirm that each has relied on the substantial accuracy of the financial disclosure of the other as an inducement to the execution of this Agreement, and each party acknowledges that there has been disclosure of the parties' marital assets and debts and the parties' respective incomes. The parties agree to waive any 4 further disclosure and proceed with a settlement of all financial assets and/or debts. 11. DISCLOSURE AND WAIVER OF PROCEDURAL RIGHTS Each party understands that he or she has the right: (1) to obtain from the other party a complete inventory or list of all of the property that either or both parties own at this time or owned as of the date of separation; (2) to have all such property valued by means of appraisals or otherwise; (3) to compulsory discovery to assist in the discovery and verification of facts relevant to their respective rights and obligations, including the right to question the other party under oath; and (4) to have a Court hold hearings and make decisions on the matters covered by this Agreement, which Court decision concerning the parties' respective rights and obligations might be different from the provisions of this Agreement. Given said understanding and acknowledgment, both parties hereby waive the foregoing procedural rights. 12. BANKRUPTCY The parties hereby agree that the provIsions of this Agreement shall not be dischargeable in bankruptcy and expressly agree to reaffirm any and all obligations contained herein. In the event a party files such bankruptcy and pursuant thereto obtains a discharge of any obligations assumed hereunder, the other party shall have the right to declare this Agreement to be null and void and to terminate this Agreement in which event the division of the parties' marital assets and all other rights determined by this Agreement shall be subject to Court determination the same as if this Agreement had never been executed by the parties. 13. MUTUAL RELEASES Except as otherwise expressly provided in this Agreement, Wife and Husband each do hereby mutually remise, release, quitclaim and forever discharge the other and the estate of such other, for all time to come, and for all purposes whatsoever, of and from the following: A. Claims Aaainst Property or Estate: Any and all right, title, interest and/or claims in or against the other party, the property (including income and gain from property hereafter accruing) of the other or against the estate of such other, of whatever nature and wheresoever situated, which he or she now has or at any time hereafter may have against such other party, the estate of such other party or the property of the other party or any part thereof, whether arising out of any former acts, contracts, engagements or liabilities of such other. 5 B. Life Time Conveyances: The right to treat a lifetime conveyance by the other as testamentary, or all other rights of a surviving spouse to participate in a deceased spouse's estate, whether arising under the laws of (i) the Commonwealth of Pennsylvania, (ii) State, Commonwealth or Territory of the United States, or (iii) any other country; C. Marital Riahts: Any rights which either party may have or at any time hereafter have for past, present or future support or maintenance, alimony, alimony pendente lite, counsel fees, equitable distribution, costs or expenses, whether arising as a result of the marital relation or otherwise. D. Breach Exception: The foregoing shall not apply to all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provision thereof. It is the intention of Husband and Wife to give to each other by the execution of this Agreement a full, complete and general release with respect to any and all property of any kind or nature, real, personal or mixed, which the other now owns or may hereafter acquire, except and only except, all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provisions thereof. 14. WAIVER OR MODIFICATION No modification or waiver of any of the terms hereof shall be valid unless in writing and signed by both parties and no waiver of any breach hereof or default hereunder shall be deemed a waiver of any subsequent default of the same or similar nature. 15. MUTUAL COOPERATION Each party shall, at any time, and from time to time hereafter, and within five (5) business days of request, take any and all steps and execute, acknowledge and deliver to the other party, any and all further instruments and/or documents that the other party may reasonably require for the purpose of giving full force and effect to the provisions of this Agreement. 16. AGREEMENT BINDING ON HEIRS This Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective heirs, executors, administrators, successors and assigns. 17. INTEGRATION This Agreement constitutes the entire understanding of the parties and supersedes 6 any and all prior agreements and negotiations between them. There are no representations or warranties other than those expressly set forth herein. 18. BREACH If for any reason either Husband or Wife fails to perform his or her obligations owed to or for the benefit of the other party and/or otherwise breaches the terms of this Agreement, then the other party shall have the following rights and remedies: A. Divorce Code Remedies: The right to all remedies set forth in Section 3502(e) of the Pennsylvania Divorce Code, 23 PA. C.S.A. 3502(e), and any additional rights and remedies that may hereafter be enacted by virtue of the amendment of said statute or replacement thereof by any other similar laws. B. Damaaes: The right to damages arising out of breach of the terms of this Agreement, which damages shall include reimbursement of all reasonable attorney's fees and costs incurred as the result of the breach and in bringing the damage action. C. Other Remedies: Any other remedies provided for in law or in equity. D. Consideration for Reasonable Attorneys Fees: Any award of "reasonable attorney's fees" as used in this paragraph shall be based on consideration of (1) the hourly rate charged; (2) the services rendered; and (3) the necessity of the services rendered. Determination of reasonableness shall not take into consideration the amount or nature of the obligation sought to be enforced or any possibility of settlement for less than the obligation sought to be enforced by the non-breaching party. E. Breach Notice: In the event of an alleged breach of any term of this Agreement, the aggrieved party shall provide written notice to the breaching party and his or her counsel of his or her intent to take action to enforce his or her rights under the Agreement and to remedy such breach. The breaching party shall have a period of fifteen (15) days from the mailing of such notice to cure the alleged breach prior to the institution of any proceedings of any nature for enforcement of this Agreement. 19. INCOME TAX MATTERS With respect to income tax matters regarding the parties the following shall apply: A. Prior Returns: The parties have heretofore filed joint federal and state returns. Both parties agree that in the event any deficiency in federal, state or local income tax is proposed, or any assessment of any such tax is made against either of them arising out of such joint filing, each will be responsible for payment of half of such tax and any interest, penalty or other expense arising 7 therefrom and shall indemnify and hold harmless the other from and against any loss or liability as a result thereof. B. Current Returns: The parties shall file individual tax returns for the current tax year and for every tax year hereafter. C. Preservation of Records: Each party will keep and preserve for a period of three (3) years from the date of their divorce all financial records relating to the marital estate, and each party will allow the other party access to those records as may be reasonably necessary from time to time. 20. EFFECT OF RECONCILIATION This Agreement shall remain in full force and effect even if the parties reconcile, cohabit as Husband and Wife or otherwise, or attempt a reconciliation. This Agreement shall continue in full force and effect and there shall be no modification or waiver of any of the terms hereof unless the parties, in writing, signed by both parties, execute a statement declaring this Agreement or any term of this Agreement to be null and void. SECTION II EQUITABLE DISTRIBUTION OF PROPERTY 21. FINAL EQUITABLE DISTRIBUTION OF PROPERTY The parties agree that the division of all property and debts set forth in this Agreement is equitable and in the event an action in divorce has been or is hereafter commenced, both parties waive and relinquish the right to divide and distribute their assets and debts in any manner not consistent with the terms set forth herein and further waive and relinquish the right to have the Court equitably divide and distribute their marital assets and debts. It is further the intent, understanding and agreement of the parties that this Agreement is a full, final, complete and equitable property division. 22. DISTRIBUTION OF PROPERTY AND DEBTS The parties' marital assets and debts shall be divided and distributed as follows: A. Personal Property: The parties' tangible personal property including, but without limitation with specific reference to, jewelry, clothes, furniture, furnishings, rugs, carpets, household equipment and appliances, tools, pictures, books, works of art and other personal property ("the Personal Property") shall be divided and distributed by agreement of the parties. Should there be disagreement as to this property, said property will be divided and distributed 8 as follows: 1. To Wife: All items of personal property currently in the possession of Wife, not otherwise distributed to Husband herein. 2. To Husband: All items of personal property currently in the possession of Husband, not otherwise distributed to Wife herein. B. Vehicle(s)and Vehicle Loan(s}: The parties' vehicles, boats, snowmobiles, motorcycles, trailers, campers and the like owned by one or both of the parties, or the trade in value thereof if the vehicles have been sold or traded in prior to the date of this Agreement, and loans associated therewith, shall be divided and distributed as follows: 1. To Wife: All vehicles currently in possession of Wife, specifically a 1995 Ford Windstar. 2. To Husband: All vehicles currently in possession of Husband, specifically a Toyota Corolla. C. Monetary Distributions: All funds in joint and separate accounts, including but not limited to savings, checking, and money market accounts, should be distributed as follows: 1. To Husband: (a) Thirteen thousand, seven hundred and ninety nine dollars and sixty-four cents ($13,799.64), said amount being already withdrawn from the parties' joint accounts and in Husband's possession as of July of 2006. (b) Any and all funds currently held in Husband's business accounts and/or any other accounts held solely in his name. 2. To Wife: (a) The remainder of any funds held in parties' joint accounts. (b) Any and all funds currently held in any accounts held solely in Wife's name. Husband agrees that he will remove his name from the joint checking account to which Wife's personal loan is tied. Husband will take all necessary steps to remove his name from said account within one (1) month of the date of execution of this agreement. D. Investments: The parties' shares of stock, brokerage accounts and other investments (the "Investments") shall be divided and distributed as follows: 1. To Wife: Any shares currently in her possession or name. 9 2. To Husband: Any shares currently in his possession or name. E. Life Insurance: The parties' life insurance policies and the cash value of said policies shall remain in the possession of the party under whose name the policy is held. Neither party is entitled to the value or a portion of the value of the life insurance policy of his/her current spouse. F. Retirement Plans: The parties' Pension Plan, Retirement Plan, IRA Account, Profit Sharing Plan, 401-K Plan, Keogh Plan, Stock Plan, Deferred Savings Plan, any employee benefit plan and/or any other retirement type plans (the "Retirement Plans") shall be divided and distributed as follows: 1. To Wife: Any plans currently held under her name. 2. To Husband: Any plans currently held under his name. G. Debts: The parties' marital debts, loans, credit cards and other obligations, not otherwise divided and distributed herein, shall be divided and distributed as follows: 1. To Wife: Wife shall be solely liable for and shall timely pay the following debts: A. Any credit cards, loans, debts and liabilities incurred in Wife's individual name. 2. To Husband: Husband shall be solely liable for and shall timely pay the following debts: A. Any credit cards, loans, debts and liabilities incurred in Husband's individual name. H. Title Transfer: The vehicles owned by the parties respectively should be owned in full by whatever party with whom custody of the vehicle currently lies. Title for said vehicles should be in the name of the party with whom has custody of the vehicle at this time. Should transfer of the title of any vehicle be necessary to comply with this Paragraph and Paragraph 228., title transfer of said vehicle will be made in accordance with the law within thirty (30) days of the signing of this Agreement. All costs of the title transfer will be the responsibility of the party assigning title. 23. MEDICAL. DENTAL. VISION. PSYCHOLOGICAL AND PSYCHIATRIC CARE AND PRESCRIPTIONS FOR WIFE AND HUSBAND. 23.1. Insurance. Wife represents that she presently is carrying health insurance coverage for the benefit of Husband. 10 Husband agrees that after the divorce is finalized or within one (1) month of the date of this agreement, whichever comes first, he will pay for and secure health insurance coverage for himself. No party shall be responsible for the costs of health care coverage of the other party after this time. 24. MISCELLANEOUS DISTRIBUTION PROVISIONS: The following miscellaneous provision shall apply to the distribution of the parties' marital assets and debts: A. Final Equitable Distribution of Property: The division and distribution of all property and debts set forth in this Agreement is equitable and in the event an action in divorce has been or is hereafter commenced, both parties waive and relinquish the right to divide and distribute their assets and debts in any manner not consistent with the terms set forth herein and further waive and relinquish the right to have the Court equitably divide and distribute their marital assets and debts. It is further the intent, understanding and agreement of the parties that this Agreement is a full, final, complete and equitable property division. B. As Is Condition: Except as otherwise specifically herein provided, and with respect to the transfer of any tangible assets provided for in this Marital Agreement, the parties acknowledge that he or she have had the opportunity to inspect and view the assets that he or she is to receive as his or her sole and separate property and he or she is fully aware of the condition of such tangible asset and is receiving those assets in "as is" physical condition, without warranty or representation by or from the other party. C. Personalty Transfer: if either party is entitled to any items of personal property in the possession of the other party as of the date of this Agreement, the parties shall promptly make arrangements so as to permit that party to remove the items of property from the other party's possession no later than fifteen (15) days from the date of this Agreement. D. Waiver. Each of the parties specifically waives, releases, renounces and forever abandons whatever right, title and interest they may have in any property that is to become the sole and separate property of the other party pursuant to the terms of this Agreement. E. Liens: In the event any asset is subject to a lien or encumbrance the party receiving the asset as his or her property shall take it subject to said lien and/or encumbrance and shall be solely responsible and liable therefore. F. Debt Balances and Prior Payments: Any debt herein described shall be deemed to include the current balance owed on the debt. Unless otherwise herein specifically provided, there shall be no adjustment in the distribution provisions for the payment of any portion of the marital debts prior to the execution of this Marital Agreement, whether or not that debt or the prior payment thereof is specifically referenced in this Paragraph, said payment 11 . . having been taken into consideration in determining the distribution of marital assets and debts herein provided. G. Indemnification: Any party assuming an obligation pursuant to the terms of this Agreement shall indemnify, protect and hold the other party harmless from and against all any and all liability thereunder, including, but not limited to, any attorney's fees and costs incurred by the other party as the result of defending against the obligation and/or enforcing the provisions of this indemnification. H. Cancellation of Joint Debts: Any joint debt shall be cancelled so that neither party can make any further charges thereunder, and if said charges are made in violation of this Agreement, then the party incurring said charge shall immediately repay the same. I. Non-Disclosed Liability: Any liability not disclosed in this Agreement shall be the sole responsibility of the party who has incurred or may hereafter incur it, and the party incurring or having incurred said debt shall pay it as it becomes due and payable. J. No Further Joint Debt: From the date of this Agreement, each party shall only use those credit accounts or incur such further obligations for which that party is individually and solely liable and the parties shall cooperate in closing any remaining accounts which provide for joint liability. K. No Additional Debt: Each party represents and warrants to the other party that since the separation he or she has not, and in the future he or she will not, contract or incur any debt or liability for which the other party or the other party or the other party's estate might be responsible. SECTION III CLOSING PROVISIONS AND EXECUTION 25. COUNTERPARTS. This Agreement may be executed in counterparts, each of which shall be deemed to be an original, but all of which shall constitute one and the same agreement. 26. FACSIMILE SIGNATURE. Each party agrees to accept and be bound by facsimile signatures hereto. 27. BINDING EFFECT. By signing this agreement, each party acknowledges having read and understood the entire agreement, and each party acknowledges that the provisions of this agreement shall be binding upon the parties as if they were ordered by the Court after a full hearing. 12 IN WITNESS WHEREOF, the parties hereto, intending to be legally bound hereby, have signed sealed and acknowledged this Agreement the day and year below written, which Agreement has been executed in various counterparts, each of which shall constitute an original. WITNESS: c41i.c~ [k.c~fi \..JIJ()<;;dCA~ i H~ (SEAL) Melissa C' ister Date: (0 ~rf{)t~y 2fi)b (SEAL) Todd Chronister /' <5 -.2>(, - 0 <c. 13 COMMONWEALTH OF PENNSYLVANIA ) ) SS: COUNTY OF CUMBERLAND ) ( t\)...,_0 On this, the ~ day of~, 2006, before me, a Notary Public, the undersigned officer, personally appeared Melissa Chronister, known to me (or satisfactorily proven) to be the person whose name is subscribed to the foregoing Marital Settlement Agreement and acknowledged that she executed the same for the purposes therein contained. IN WITNESS THEREOF, I hereunto set my hand and official seal. COMMONW~~ QI.J.'r.h:~;.~\:~,*L:;'::':l G.us~~rDJltm ~:1N.. \ Camp I-IHI Bora, C~~~bl~rlar:'li9. \ .~ \ Mv COl11rr!~SIO!1 [xp.. €. " .;.', I ") Notary Publi~ COUNTY OF CUMBERLAND ) ) SS: ) COMMONWEAL TH OF PENNSYLVANIA On this, the db day of aCt- ,2006, before me, a Notary Public, the undersigned officer, personally appeared Todd Chronister, known to me (or satisfactorily proven) to be the person whose name is subscribed to the foregoing Marital Settlement Agreement and acknowledged that she executed the same for the purposes therein contained. NWEALTH OF PENNSYLVANIA NolarIaI Seal 0\1Itopher L PIt, NoCary PubIc HIlt..,... QlIlberlBnd CaI1ly My 0ai.1.1iIIIclI, &pies Sept. 3, 'llIJ7 Member. Pennlytvante Assoctatlon Of NoIlIrIee IN WITNESS THEREOF, I hereunto set my hand and official seal. NotaryPUbli~a . 14 r:--) ----\ ,) -':1 t,,) ~'- KOPE & ASSOCIATES BY: LESLEY J. BEAM, ESQ. ATTORNEY 1.0. 91175 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 Ibeam@kopelaw.com Attorney for Plaintiff vs. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PA : NO. 06-4038 MELISSA CHRONISTER, Plaintiff, TODD CHRONISTER, Defendant. : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301 (c) of the Divorce Code was filed on July 17, 2006. 2. The Complaint was served by Certified Mail signed by Todd Chronister on July 21,2006. 3. The marriage of plaintiff and defendant is irretrievably broken and at least ninety (90) days have elapsed from the date of filing and service of the complaint. 4. 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 this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pac C. S. Section 4904 relating to unsworn falsification to authorities. Date: 10(210/0/0 --B4.q~ - CScrs-=t Social Security Number t-:> ,~ ~F o "Tl :r -t] lnp- ~ C) I N ~: (3 r""......") (.P KOPE & ASSOCIATES BY: LESLEY J. BEAM, ESQ. ATTORNEY 1.0.91175 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 Ibeam@kopelaw.com Attorney for Plaintiff vs. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PA : NO. 06-4038 MELISSA CHRONISTER, Plaintiff, TODD CHRONISTER, Defendant. : CIVIL ACTION - LAW : 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 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 this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. Date: J.Qj 2.10 I uk:> J 1J~C IMt\U'&1J:: '--Melissa.' nister 114 . 4~) ..~~ '~~ c'ST Social Security Number 0 1"-.) 0 ,~ C c.:.""::) 'Tl 0"" ;::~ --l (-~1 :r: .., ot:,f"':: ,n F rr~ I CJ N C.l ~ '-1-\ ~"1/; -r, -:;;;.... ;:. (~; ~l n 0 \.~~../ .._~! J> f"-,' .::D U', .< KOPE & ASSOCIATES BY: LESLEY J. BEAM, ESQ. ATTORNEY I.D. 91175 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 Ibeam@kopelaw.com Attorney for Plaintiff vs. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PA : NO. 06-4038 MELISSA CHRONISTER, Plaintiff, TODD CHRONISTER, Defendant. : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301 (c) of the Divorce Code was filed on July 17, 2006. 2. The Complaint was served by Certified Mail signed by Todd Chronister on July 21, 2006. 3. The marriage of plaintiff and defendant is irretrievably broken and at least ninety (90) days have elapsed from the date of filing and service of the complaint. 4. 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 this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. Date: /0 - Z?:;-- ok:> /....."./" .. /~ ~ ~~-=------ ~ -- Todd Chronister /2;:]- ~.2-7{;, n- Social Security Number r-:> = c:.:." C7' I N ~ 23 \,0 KOPE & ASSOCIATES BY: LESLEY J. BEAM, ESQ. ATTORNEY 1.0. 91175 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 Ibeam@kopelaw.com Attorney for Plaintiff vs. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PA : NO. 06-4038 MELISSA CHRONISTER, Plaintiff, TODD CHRONISTER, Defendant. : CIVIL ACTION - LAW : 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 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 this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. Date: /0- ?G-c6 ~---~ Todd Chronister /G :J r- s-;t -- /.6 <g7S- Social Security Number 1"'-':> C.? ,,::;> 0-'" -,t.::... ~~ I N ..,..." ~. s' f'-' ~,::a IN THE COURT OF COMMON PLEAS MELISSA CHRONISTER VS. CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION TODD CHRONISTER NO. 06-4038 CIVIL TERM 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 93301 (c) i~<<>t1Q)gt~~WR~~K (Strike out inapplicable section). 2. Date and manner of service of the complaint: Certified Mail Restricted siqn by Defendant on July 21, 2006 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by 93301 (c) of the Divorce Code: by plaintiff 1 0/26 /06 ; by defendant 1 0 /26 /06 (b) (1) Date of execution of the affidavit required by 93301 (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 93301 (c) Divorce was filed with the Prothonotary: 11 /2/2006 Date defendant's Waiver of Notice in 93301 (c) Divorce was filed with the Prothonotary: (") ~ l"-.:l C.::::). C'-:') G-~ ,--., ::.~) .. ,<--..l- ei I 1...0 :"2 c.n "'''' '" 143 '" :Ii :Ii "'<ti:li<ti :Ii:li fIi '" "''''''':Ii IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA. MELISSA CHRONISTER No. 06-4038 VERSUS TODD CHRONISTER DECREE IN DIVORCE AND NOW, fJ 0 'u ~,~ L.,(,} 2 ') MELISSA CHRONISTER , PLAINTIFF, , ~r>'- IT IS ORDERED AND DECREED THAT AND TODD CHRONISTER , 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; NONE ATT '" Ef. ~"'l43~~l43~~ ~~~~~ ~~~~ ~ r+lr+l~ ~ ~~r+lfF.~ ~~l43 ~r+l~~ ~:f.~ r+l r+l :f. ;+: J. .h ? ~ ~lL, '$' h' c! ~ r '-? ~ ~l or; 'Jf' /" .' el i # '. '. \ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ~. \l.S,SQ c1v(/'l\.~ Plaintiff Vs File No. 06 - 4{)3~ IN DIVORCE I'CYLi l~y{[N~ Defendant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff I defendant in the above matter, [select op.e by marking "x"] _ prior to the entry of a Final Decree in Divorce, . . or ...A- after the entry of a Final Decree in Divorce dated -ill 1.- '2- l'() b hereby elects to resume the prio.r surname of . As.lL4 . , and gives thi~ written notice avowing his I her intention pursuant to the provisions of 54 P .S. 704. Date:~. , ~~C1.vrMet-9JI.-- ature COMM:ONWEH-TH OF PENNSYLVANIA ) COUNTY OF r..:Jvl~ On the~ day of t~ ' 200~ before me, the Prothonotary or the notary public, personally appeared the above affiant mown to me to be the person whose name is subscribed to the within document and acknowledged that he I she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereWlto set my hand hereunto set my hand and official seal. NOTARIAL SEAL PROTHONOTARY, IIOTARY PI8.IC CARlISLE CUMBERLAND COUtf1Y COURTHOUSE MY COMMlSSIOll EXPIRES JANUARY 4. 2010 . 74 4c' ~ I ?s? ~ J'i , ~, ~ ~ '\j ~ \) ~ 'D ~ , ~ ~ o ~; ~ = --' -r'1 rJ c...; ~ t . "'1 _~4 - - .. ,;\;';; 77~;T:';i: . I "'.~ "'Y.i1l';JHTOA't IIl't.,! "'lJ\!!q\lh:','U":' . ""iW':) lnj"':H~. oil. .~',. .,'1 .fJJ t;'''\!.1j .' ,:', ""0 '1M l "''l^t''':..t''!1:)'I( I." . "'J 1",,,,-,,,,,,, . ~.," "'::s.):~~'~'\~.t\.e~;L....;:.,.:::.:: "', ,~_. I N ~ :?--;') filE:. -(1 \..'..J -;.1 ......" (-~:; ~:.;-:), "-~ -"~'.-, ?h\ ) :-:-~t -0 ::;. - 1'0 .. o 0" ~