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IN
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OF CUMBERLAND COUNTY
STATE OF '* PENNA.
MARION M. SEIDLE,
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PLAINTIFF
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GEORGE E. SEIDLE, JR.
DEFENDANT
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ANI) NOW, . . . ... ., .................., 19....... it is ordered and ~
MAR 0 M. SEIDLE ^
decreed that ................................................., plaintiff, ~
GEORGE E. SEIDLE, JR. ~
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The court retains iurisdiction of the following claims which hove
been raised of record in this action for which a final order has not yet
been entered;
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: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: IN DIVORCE
MARION M, SEIDLE.
Plaintiff
GEORGE E, SEIDLE. JR"
Defendant
: NO, 94-1942 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 Section 330l(c) of the
Divorce Code,
2, Date and manner of service of the complaint: served on April 22, 1994. United
States mail, certified, restricted delivery, return receipt requested. postage prepaid.
3, Date of execution of the affidavit of consent required by Section 330l(c) of the
Divorce Code: by the plaintiff, August 3) 1994; by the defendant. June 14, 1995,
4, Related claims pending: the counter-claim for equitable distribution that was filed
by the defendant on September 19, 1994, was withdrawn on June 14, 1995, at the Divorce
Master's pre-hearing conference,
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TINA' IMPSO
s_~ Alii-
THO S M, PLACE
Supervising Attorney
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
717/240-5204
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MARION M. SEIDLE,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
.
.
vs.
: NO.
1942 CIVIL 1994
GEORGE E. SEIDLE, JR.,
Defendant
.
.
IN DIVORCE
ORDER OF COURT
AND NOW, this
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day of
~vo../"'-
, 1995,
the parties and counsel having entered into an agreement and
stipulation resolving the economic issues on June 14, 1995, the
date set for a conference with counsel and the parties, 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.
BY THE COURT,
P.J.
co:
Thomas L. Peeler
Attorney for Plaintiff
Samuel L. Andes
Attorney for Defendant
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: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: DIVORCE NtJ, q if -Iq t.f2. ~ T.I./VhJ
: NO, CIVIL 1994
MARION M. SEIDLE
Plaintiff
GEORGE E. SEIDLE, Jr.
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, Cumberland County Courthouse, Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR AUMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS
GRANTED. YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM,
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE
THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL
HELP,
Court Administrator
Cumberland County Courthouse
Carlisle, PA 17013
717/240-6200
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MARION M, SEIDLE
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
DIVORCE
,
,
,
v.
GEORGE E. SEIDLE, Jr,
Defendant
NO,
CIVIL 1994
,(
COMPLAINT
The plaintiff, Marion M, Seidle, by her attorneys, The Family Law Clinic, sets forth the
following cause of action:
COUNT I.
DIVORCE UNDER 23 Pa.C.S. SECTION 3301 (el and 3301 (d)
OF THE DIVORCE CODE
1. Plaintiff is Marion M. Seidle, who currently resides at 200 South Second Street,
Wonnleysburg. PA 17043. since September, 1993,
2, Defendant is George E, Seidle, Jr" who currently resides at 813 Wertzville Road,
Enola, PA 17025, since July. 1992,
3, Plaintiff and defendant have been bona fide residents in the Commonwealth for at
least six months immediately previous to the filing of this Complaint.
4, Plaintiff and defendant were married on May 3, 1986, in Harrisburg, Pennsylvania,
5, Plaintiffand defendant have lived separate and apart since September I, 1992,
6, There have been no prior actions in divorce or for annulment between the parties,
7, The marriage is irretrievably broken,
8. Plaintiff has been advised that counseling is available and that plaintiff may have the
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right to request that the court require the parties to participate in counseling,
WHEREFORE, plaintiff requests the court to enter a decree in divorce dissolving the
marriage,
Date ~I,J/?9Y
__-If- 'L72~
PaIge Rol'ni
Student Attorney
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Thomas M, Place
Supervising Attorney
Family Law Clinic
45 North Pitt Street
Carlisle, PA 17013
(717) 240-5204
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COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND: 5S,
I verify that the statements made in this Complaint are true and correct to the best of
my personal knowledge and belief, I understand that false statements herein are made
subject to the penalties of 18 Pa.C,S, ~4904. relating to unsworn falsification to authorities,
~nn~dih
'on M, eidle
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MARION M. SEIDLE
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v,
: CIVIL ACTION - LAW
: DIVORCE
: NiJ.Qtf-I'l'l1. ~ f~
: NO, CIVIL 1994
GEORGE E. SEIDLE, Jr.
Defendant
pRDER OF COURT
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AND NOW, this () day of L\ I , 1994, on consideration of the attached
petitioner's Affidavit, leave is granted to the petitioner to proceed in forma pauperis to the extent
that she is relieved of all costs in this action,
By the Court,
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MARION M. SEIDLE
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY. PENNSYLVANIA
v,
: CIVIL ACTION - LAW
: DIVORCE
GEORGE E. SEIDLE, Jr.
Defendant
: NO,
CIVIL 1994
PETITION TO PROCEED IN FORMA PAUPERIS
Marion M, Seidle, Plaintiff in the above titled action, respectfully requests this
Honorable Court to grant her leave pursuant to Pa,R,C,P, 1920,62 to proceed in forma
pauperis to the extent that she be relieved of all costs attendant to this action,
Date ~Z t) J~"~
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Student Attorney
~~~
Thomas M, Place
Supervising Attorney
FAMILY LAW CUNIC
45 North Pitt Street
Carlisle, PA 17013
(717) 240-5204
.,
MARION M. SEIDLE
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v,
: CIVIL ACTION - LAW
: DIVORCE
GEORGE E. SEIDLE, Jr.
Defendant
: NO,
CIVIL 1994
ATfORNEY'S AFFIDAVIT SUPPORTING PETITION
FOR LEAVE TO PROCEED IN FORMA PAUPERIS
I, Paige Rosini, of the Family Law Clinic, attorney for the party petitioning to proceed
in fonna pauperis, certify that I believe petitioner is unable to pay the costs of instituting this
action and that I am providing free legal service to petitioner.
Plaintiffs Affidavit showing inability to pay the costs of litigation is attached hereto,
Date a,u:.e ~: 199,/
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'1..J1 .Af'~
Paige R ni
Student Attorney
~~~
Thomas M, Place
Supervising Attorney
FAMILY LAW CUNIC
45 North Pitt Street
Carlisle, PA 17013
(717) 240-5204
"
MARION M. SEIDLE
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: DIVORCE
v,
GEORGE E. SEIDLE, Jr.
Defendant
: NO,
CIVIL 1994
AFFIDAVIT SUPPORTING PETITION FOR LEAVE
TO PROCEED IN FORMA PAUPERIS
TO THE HONORABLE JUDGES OF SAID COURT:
1. I am the Plaintiff in the above matter and because of my fmancial condition am
unable to pay the fees and costs of prosecuting or defending the action or proceeding,
2, I am unable to obtain funds from anyone, including my family and associates, to pay
the costs of litigation,
3, I represent that the infonnation below relating to my ability to pay the fees and costs
is true and correct.
(a) Name: Marion M, Seidle
Address: 200 South Second Street, Wonnleysburg, PA 17043,
Social Security Number: 426-35-3364
(b) Employer: Premier Eye Care
Address: 2745 N, Front St., Harrisburg, PA 17110,
Salary: $840,oo/month
Type of work: Medical Assistant
(c) Other income within the past twelve months
Business or profession: None
Other self-employment: None
Interest or dividends: None
Pension and annuities: None
Social security benefits: None
Support payments: I am supposed to receive $125,oo/month, I receive a portion every
month, but very rarely do I receive $125,00,
Disability payments: None
Unemployment compensation and supplemental benefits: None
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,
Workman's compensation: None
Public Assistance: None
Other: None
(d) Other contributions to household support
Name: Douglas Wagner
Employer: Construction Consultants
Salary: Unknown
Type of work: Heating and air conditioning
Contributions from children: None
Contributions from parents: None
Other contributions: None
(e) Property owned
Cash: None
Checking account: Yes, no balance,
Savings account: None
Certificates of deposit: None
Real estate (including home): None
Motor vehicle: Pontiac, 1984, cost is unknown, amount owed is -0-
Stocks or bonds: None
Other: None
(t) Debts, obligations and expenses
Rent: $325,OO/month is my one-half of the rent payment
Childcare: $468,OO/month
Grocery: $240,OO/month
Utilities (gas, electric, water, phone): $108,OO/month is my one-half of the payment
Gasoline: $80,OO/month
Medical expenses for the children: $764,00/1993
Sports teams for the children: $75,00/1993
Automobile insurance: $285,OO/year
(g) Persons dependent upon me for support
Justin Seidle, Age 7,
Brandon Seidle, Age 3,
4, I understand that I have a continuing obligation to infonn the court of improvement
in my financial circumstances which would pennit me to pay the costs incurred herein,
5, 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, fi4904, relating to
unsworn falsification to authorities.
WHEREFORE, petitioner prays that this Honorable Court grant petitioner leave to
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proceed in fonna pauperis in the above titled action without fee or cost to the petitioner,
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MARION M. SEIDLE,
Plainitiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: IN DIVORCE
v,
GEORGE E. SEIDLE, Jr.,
Defendant
: NO, 94 - 1942 CIVIL TERM
NOTICE TO DEFENDANT
If you wish to deny any of the allegations set forth in this affidavit, you must file a
counter-affidavit within twenty days after this affidavit has been served on you or the
statements will be admitted,
PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE
I. The parties to this action separated on September I, 1992, and have continued to
live separate and apart for a period of at least two (2) years.
2, The marriage is irretrievably broken.
3, 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,
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,
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MARION M. SElDLE
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY , PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: DIVORCE
NO. 9'/- /9t/.:l. ec;vd ~v__
: NO. CIVIL 1994
GEORGE E. SElDLE, JR.
Defendant
CERTIFICATE OF SERVICE
I, Paige Rosini, Student Attorney, Family Law Clinic, hereby certify that I have served
a true and correct copy of said Divorce Complaint on George E, Seidle, Jr., residing at 813
Wertzville Road, Enola, PA 17025, by depositing a copy of the same in the United States mail,
certified, restricted delivery, return receipt requested, postage prepaid, this 20th day of April,
1994.
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Paige Rosim
Student Attorney
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MARION M. SEIDLE,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v,
: CIVIL ACTION - LAW
: DIVORCE
GEORGE E. SEIDLE, JR.,
Defendant
: NO, 94 - 1942 CIVIL TERM
CERTIFICATE OF SERVICE
I. Paige Rosini. Certified Legal Intern. Family Law Clinic. hereby certify that I have
served a tnle and correct copy of Plaintiffs Affidavit Under Section 330l(d) of the Divorce
Code on George E, Seidle, Ir,. residing at 813 Wertzville Road. Enola, PA 17025, by
depositing a copy of the same in the United States mail, first class, postage prepaid, this 13th
day of September, 1994,
/l~it- ~'rJV;L~
Paige Rosl i
Certified Legal Intern
THE FAMILY LAW CUNIC
45 North Pitt Street
Carlisle, PA 17013
(717) 240-5204
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HARION H. SEIDLE,
Plaintiff
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IN THE COURT OF COMMON
PLBAS OF CUMBBRLAND
COUNTY. PENNSYLVANIA
CIVIL ACTION - LAW
DIVORCB
NO. 1942 CIVIL 1994
VB.
GBORGB E. SEIDLE. JR,
Defendant
NOTICB
TO PLAINTIFF NAMBD HEREIN:
YOU HAVB BEEN SUBD IN COURT, IF YOU WISH TO DEFBND AGAINST THE CLAIHS SET FORTH IN
THE FOLLOWING PAGES, YOU HUST TAKE ACTION WITHIN TWENTY (20) DAYS APTER THIS COHPLAINT
AND NOTICE ARE SBRVED. BY BNTERING A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND
FILING IN WRITING WITH THB COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIHS SET FORTH
AGAINST YOU, YOU ARE WARNBD THAT IF YOU FAIL TO DO SO. THE CASB HAY PROCEBD WITHOUT
YOU, AND A JUDGMENT HAY BB ENTBRED AGAINST YOU BY THE COURT WITHOUT FURTHBR NOTICE FOR
ANY MONBY CLAIMBD IN THE COHPLAINT OR FOR ANY OTHER CLAIM OR RBLIEF REQUESTED BY THE
PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS IHPORTANT TO YOU,
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVB A LAWYER OR
CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU
CAN GET LEGAL HELP,
COURT ADHINISTRATOR
FOURTH FLOOR, CUMBERLAND COUNTY COURT HOUSE
CARLISLE, PENNSYLVANIA l7013
TELEPHONE: (717) 240-6200
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MARION M. SEIDLE,
Plaintiff
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IN THE COURT Of COMMON
PLEAS Of CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
DIVORCE
NO. 1942 CIVIL 1994
vs.
GEORGE E. SEIDLE, JR.
Defendant
ANSliIlIl AND OOUNTBRCLAIM
AND HOW, comes the above-named Defendant, by his attorneys, Andes, Vaughn & Bangs,
and makes the following answer and counterclaim to Plaintiff's Complaint:
OOUNT ! = DIVORCE
1. Admitted.
2. Admi tted.
3. Admitted.
4. Admitted.
5. Denied as stated,
6, Admitted.
7. Admitted.
8. Mmitted,
The parties separated after 1 September 1992.
WHEREFORE, Defendant prays this court not to grant a final decree in divorce until
such time as the economic issues raised in Defendant's Counterclaim have been
determined by the court.
COUNTERCLAIM
OOUNT II = EQUITABLE DISTRIBUTION
9. During the course of the marriage, the parties have acquired numerous items of
property, both real and personal, which are held in joint names and in the individual
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names of each of the parties hereto.
VRBRBPORB, Defendant prays this Honorable Court, after requiring full disclosure
by the Plaintiff, to equitably divide the property, both real and personal, owned by
the part.ies hereto as marital property,
I verify that the statements made in this Answer and Counterclaim are true and
correct. I understand that any false statements in this Answer and Counterclaim are
subject to the penalties of 18 Pa. C,S. 4904 (unsworn falsification to authorities).
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HARION H. BBIDLB, ) IN THB COURT OF COHHON
Plaintiff ) PLBAB OF CUHBBRLAND
) COUNTY, PENNSYLVANIA
vs. )
) CIVIL ACTION - LAW
) DIVORCB
GBORGB B. BBIDLB, JR. )
Defendant ) NO, 1942 CIVIL 1994
COUNTER-AFFIDAVIT UNDER SBCTION 330I(D) OF THB DIVORCB CODB
AND NOW, comes the above-named Defendant, George B, Beidle, Jr., and, being duly
sworn according to law deposes and says:
l, He is the Defendant in the above-captioned matter.
2. He and the Plaintiff separated in September of 1992 and have lived separate
and apart since that time.
3. He has economic claims which he has raised in the divorce action which he
wants the court to determine prior to the entry of any decree in divorce.
4. He is not willing to waive his right to have these economic matters decided by
the court and requests the court not to enter a final decree in divorce until all
economic issues have been addressed.
Date: ~. It I m
1Jo~ [, ~c;.IA1t J,.
GeORGB B. IDLB, JR, tJ1
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MARION M. SEIDLE
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v,
: CIVIL ACTION - LAW
: DIVORCE
GEORGE E. SEIDLE, Jr.
Defendant
: NO, 1942 CIVIL 1994
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
April IS, 1994,
2, The marriage of plaintiff and defendant is irretrievably broken and ninety days
have elapsed from the date of filing the Complaint,
3. I consent to the entry of a final decree of divorce.
4, I understand that I may lose rights concerning alimony, division of property,
lawyer's~fees or expenses if I do not claim them before a divorce is granted,
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,
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MARION M. SElDLE,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL AcrION - LAW
: DIVORCE
GEORGE E. SElDLE, JR.,
Defendant
: NO. 94 - 1942 CIVIL TERM
AFFIDAVIT OF CONSENT
I. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
April IS, 1994.
2, The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90)
days have elapsed from the date of filing the Complaint,
3, I consent to the entry of a final decree of divorce,
4. I understand that if a claim for alimony, alimony pendente lite, marital property or
counsel fees or expenses has not been filed with the Court before the entry of a final decree
in divorce, the right to claim any of them wiIl be lost,
S. I understand that I may request marriage counseling and I hereby waive any right
to marriage counseling which is afforded to me under the law,
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, I 4904, relating
to unsworn falsification to authorities.
Dale (p - ;q - 'i~-
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MARION M. SEIDLE, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs. NO. 1942 CIVIL 1994
GEORGE E. SEIDLE, JR.,
Defendant IN DIVORCE
THE MASTER: Today is Wednesday, June 14, 1995.
This is the date scheduled for a conference between counsel and
the parties in the above referenced divorce action. Present in
the conference room are the Plaintiff, Marion M. Seid1e and her
counsel Thomas L. Peeler and a student attorney, Tina Simpson.
Also present is the Defendant, George E. Seidle, Jr. and his
counsel Samuel L. Andes.
A divorce complaint was filed on April 15, 1994,
raising grounds for divorce of irretrievable breakdown of the
marriage. In response to the divorce complaint the Defendant
filed an answer and counterclaim. The counterclaim raised the
economic issue of equitable distribution.
Counsel and the parties have agreed to conclude the
divorce under Section 3301(c) of the Domestic Relations Code.
The plaintiff filed an affidavit under Section 3301(d) averring
that the parties were separated for a period of at least two
years, since September 1, 1992. The Defendant, husband, filed a
counter-affidavit indicating that he had raised economic claims
in the action and would not agree to an entry of a divorce
decree.
.
Mr. Seidle has, however, in view of the parties
having reached an agreement here today, has agreed to sign an
affidavit of consent so that the divorce can proceed under
section 3301(c) of the Domestic Relations Code. Previously on
August 3, 1994, wife filed an affidavit of consent in the
action. It is the Master's understanding that Mr. Seidle, with
counsels' concurrance, will withdraw the counter-affidavit in
the action which he filed on September 21, 1994.
As indicated, the Master has been informed that the
parties have reached an agreement as to the outstanding economic
issues relating to equitable distribution. Counsel is going to
place on the record that agreement that has been worked out here
this date and the agreement as placed on the record will be the
substantive agreement of the parties. It will not be subject to
any modification after it is placed on the record except for
correction of typographical errors which may have made during
the transcription. Inasmuch as the agreement involves limited
issues and the Master has informed the parties that the
agreement as stated on the record will be not be subject to
modification except for correction of typographical errors,
counsel have agreed to forego the Master's usual request that
the parties affirm the agreement by affixing their signatures.
We will, therefore, present the agreement to the Court as placed
on the record without having the parties affirmation by
signature with the understanding of the parties that the
f
agreement as stated is the agreement that will be binding upon
them. Mr. Andes:
MR. ANDES: The parties have agreed as follows:
1. There is currently in the wife's possession a Sears
snowblower. She will make that available to be delivered
to husband or picked up by husband at her residence
within ten (10) days of today's date and that snowblower
will be and remain the sole and separate property of
husband hereafter.
2. Otherwise, the parties agree that they have effected a
division and distribution of their marital property
specifically including the items of tangible household
furniture and similar personal property which we
have discussed and negotiated for today and each of the
parties hereby waives any claim to the property now in
the possession of the other. Further, each of the
parties also waives any further claim to the equitable
distribution or other division of any marital property
or claims to marital property that they may have.
3. Husband hereby withdraws his claim for equitable
distribution in this matter and the counter-affidavit
he filed, which was dated September 19, 1994, it being
the intention and agreement of the parties that they will
conclude a divorce by consent as promptly as can be done.
4. Each of the parties is represented by counsel, has had
ample opportunity to discuss these matters with counsel,
and accepts this agreement as the final resolution of the
economic issues raised in their divorce and waives any
further claim against the other arising out of their
marriage, with the exception of matters relating to
the custody and support of their children which are
handled in separate actions before this Court.
5. Except as herein otherwise provided, each party may
dispose of his or her property in any way and each
party hereby waives and relinquishes any and all rights
he or she may now have or hereafter acquire under the
present or future laws of any jurisdiction to share in
the property or the estate of the other as a result of
the marital relationship including without limitation,
dower, curtesy, statutory allowance, widow's allowance,
right of intestacy, right to take against the will
'1
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c.
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.
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 interests, rights, and claims.
MR. ANDES: Mr. Seid1e, you heard the agreement
that I just recited?
MR. SEIDLE: Yes.
MR. ANDES: Did you have an opportunity to review
and discuss that with me before we dictated it today?
MR. SEIDLE: Yes.
MR. ANDES: And although you may not be satisfied
with all of the terms of it; is that the agreement that you have
reached?
MR. SEIDLE: Yes.
MR. ANDES: It's accurately stated?
MR. SEIDLE: Yes.
MR. ANDES: And you're willing, at this time, to
conclude, finish, terminate, the divorce on those terms?
MR. SEIDLE: Yes, I am.
MS. SIMPSON: Marion, you have heard the agreement
today?
MS. SEIDLE: Yes.
MS. SIMPSON: And you agree with the agreement?
MS. SEIDLE: Yes.
MS. SEIDLE:
MS. SIMPSON:
with the divorce?
MS. SEIDLE:
Yes, I am.
And you are willing to go forward
.
MS. SIMPSON: Although you may not be satisfied
with the agreement, you are willing to accept the terms of the
agreement?
Yes.
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MARION M, SEIDLE,
Plaintiff
vs,
:.
GEORGE E. SEIDLE. JR,
Defendant
NO. 94-1942 CIVIL TERM.19
MOTION FOR APPOINTMENT OF MASTER
Georqe M. Seddle, Jr. (P~MtR) (Defendant).
~ master with respect to the following claims:
( ,) Divorce
( ) ,Annulment
( ) Alimony
-( ) Alimony Pendente Lite
moves the court to appoint
(X)
( )
( )
( )
Distribution of Property
Support
Counsel Fees
Costs and Expenses
and in support of the motion states:
(1) Discovery is complete as to the claims (s), for which the
appointment of a master is requested.
her (2) The defendant (has) (k~~~) appeared ~n
(by ~a a.ttorney, Ti nA ~; mpQnn. PAm; 1 y LAW ('1; n;,...
(3) The staturory ground(s) for divorce (is)
the action (R~*XX>
,Esquire),
~ll~ ~~ nl (n)
(4) Delete the inapplicable paragraph(s):
(a) The action is not contested.
(b) An agreement has been reached with respect to the
following claims:
(c) The action is contested with respect to the following
Division of household goods,
(5) The action,~x~~ (does not involve) complex issues of law
claims:
or fact.
(6) The hearing is expected
(7) Additional information,
to take 1/2 day (hours)
" :Y~g.~Q
Attorn for a~
(Defendant)
(days).
Date:
19 April 1995
ORDER APPOINTING MASTER
AND N,OW 1\ l'oR 1 L- ). G ,19..2.L, E. ROBERT ELICKER, II,
is appointed master with respect to the following claims:
Equitable distribution
Esquire,
By the'Court:
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PROPERTY IN POSSESSION OF MARION SEIDLE AS OF 0&/02/95
Microwave oven
Queen size bed
Three (3) lamps
Bed linens
Two (2) twin size beds
Two (2) dressers
Curio cabinet (gift from Marion's mother)
Coffeemaker (gift from Marion's mother)
Pots and pans (gift from Marion's parents)
Set of drinking glasses
Toaster
12" inch mOllitor
Throw rug
Two (2) telephones
Washer and Dryer
Snowblower
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Living room couch
Love Seat
Chair
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Coffee table
Two (2) end tables
Dining room table and chairs
Television Stand
Long dresser
Tall dresser
Two (2) night stands
Vacuum Cleaner
Trash can
Set of dishes
No longer in possession
No longer in possession
No longer in possession
No longer in possession
No longer in possession
No longer in possession
No longer in possession
No longer in possession
No longer in possession
No longer in possession
No longer in possession
No longer in possession
Were given back to Mr.
Seidle's grandmother
PROPERTY TA~EN BY GEORGE SEIDLE
$1600.00 from bank account
Ms. Seidle's engagement ring
Ms. Seidle's wedding ring
Antique expanding table
Drop leaf table
25" color television
VCR with remote control
CD player
Maranex receiver
Cassette tape player
Coffee maker
Kitchen utensils
Sofa bed
Recliner chair
Two (2) end tables
Two (2) living room lamps
Christmas decorations
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oil lamp
six (6) sets of drinking glasses
Serving plates
Electric frying pan
Set of dishes
Complete fish tank system with fish
six (6) blankets
Pressure cooker
Desk
Typewriter
Freezer (chest size)
Two (2) lawn mowers
Storage cabinet
Lawn equipment
Gas grill
Patio furniture
Two (2) refrigerators
stove
Pots and pans
Two (2) telephones
Two (2) throw rugs
Vacuum cleaner
Two (2) rocking chairs
Four (4) bar stools
Kerosene heater
~"""'('::".~"n. :>,'_'.~J...,..r:.....~
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ANDI~S, VAUOHN 8: BANOS
ATTOUNEYS AT LAW
~~o HonTII TWBLfTU 8TRRET
P.O. BOX IOU
LEMOYNE, PENNSYLVANIA 17043
TaLaPHON.
(717) 701.&aOI
,
...MUEL L. ANDB.
OBOROB /I.. VAUGHN, m
Mien...... L. BAWOs
J. BART D_LONB
19 April 1995
PAX
(717) 781.1435
B. Robert Elicker, II, Esquire
Office of the Haster
9 North Hanover Street
Carlisle, PA 17103
RE: Harion H. Seidle vs. George E. Seidle, Jr.
94-l943 Civil Ter.
Dear Hr. Elicker:
The above parties have now been separated for more than two years. I
represent Hr. Seidle on a conflict of interest appointment for Legal Services.
Hrs. Seidle is represented by Tina Simpson of the Family Law Clinic. There
really are no significant assets to fight about, but the parties are deadlocked
over a way to divide the household furnishings which they each claim to have
owned at the time of their separation, This is the classic case in which each
party claims the other one took all of the valuable items and neither party is
willing to admit that they bold any assets of any significant value at all.
I ask that you depart frOD your normal procedure in this matter by
allowing counsel to meet with you in a pre-trial conference, with their two
clients available in your waiting room, to discuss ways to resolve this case
without the necessity of formal pre-trial statements, inventories, and income
and expense statements. The only helpful information that would be produced by
these pre-hearing pleadings would be conflicting lists of items of household
goods, each list having greatly disparate values assigned to each ite.,
depending on allegations of possession. Rather than put counsel through that
exercise, and make you go through the tedium of reading the documents, I
suggest we simply meet with you, exchange our lists, and see how you want to
try to resolve these issues.
I have filed a motion for appointment of master and enclose a copy for
you. If you will be kind enough to allow us to address the case in this
informal manner, I hope we can save everyone a lot of unnecessary expense and
delay.
Sincerely,
Ie
ANDES, VAUGHN & BANGS
s~'i:. And~s
Enclosure
cc: Tina Simpson, Student Attorney
.
(C; (Q) fP 11
aAMueL L. AHD".
0&0801 I.. YAUOIIN. m
l4ICIIABL L.IS4NOB
".""AT paLONB
ANnl~S. VAUOHN & BANOS
^TTOIIN1~YH AT LAW
D~S NOlnll TWY.LI'TII STURt:T
1',().1I0X 100
LEMOYNE, .)ENNSYLVANIA 17043
TBLBrllONB
(11',) 701'D301
19 April 1995
PAX
17'1'1 701-14:1&
Office of the Prothonotary
Cumberland County Court House
1 Courthouse Square
Carlisle, PA l70l3
RE: Harion H. Seidle vs. George E. Seidle, Jr.
94-l942 Civil Term
Ladies:
Enclosed for filing please find a Hotion for Appointment of Haster
together with extra copies and envelopes addressed to counsel involved, If you
need anything further to process this, please let me know.
sincerely,
ANDES, VAUGHN & BANGS
Samuel L, Andes
le
Enclosures
./
co:
E. Robert Elicker, II, Esquire
Tina Simpson, Student Attorney
.
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.
MARION M. SEIDLE,
Plaintiff
vs.
:'
GEORGE E. SEIDLE. JR.
Defendant
NO. 94-1942 CIVIL TERM.19
MOTION FOR APPOIN~mNT OF MASTER
Georqe M, Seidle. Jr. (P~~iR)
a master vith respect to the folloving claims:
( ') Divorce
( ) .Annulment
( ) Alimony
,( ) Alimony Pendente Lite
(Defendant), moves the court to appoint
()() Distribution of ~roperty
( ) Support
( ) Counsel Fees
( ) Costs and Expenses
and in support of the motion states:
(1) Discovery is complete as to the cla1m:i(s), for vhich the
appointment of a master is requested.
her (2) The defendant (has) (jU~~lfWlt) appeared i.n the action (R~*k3t>
(byida attorney, Tin" !';impc:nn, F'''mily T,,,w ('1;n;(" ,Esquire).
(3) The staturory ground(s) for divorce (is) ~~)r "I"In1 (n)
(4) Delete the inapplicable paragraph(s):
(a) The action is not contested.
(b) An agreement has been reached vith respect to the
fo11oving claims:
C:,laims:
(c) The action is contested vith respect to the folloving
Division of household goods,
(5) The action.~XR~ (does not involve) complex issues of lav
or fact.
The hearing is expected to take 1/2 day (hours) (days).
Additional information, if any. re1evan~ to the motion:
)(~U}\~nQ
Atl:orn~ ~ for ~1axIldl6fX
(Defendant)
(6)
(7)
Date:
1:9 April 1995
ORDER APPOINTING MASTER
AND NPW ,19..2..2-. E. ROBERT ELICKER, II,
is appointed master v1th respect to the follov1nS claims:
Equitable distrfbution
Esquire,
By the Court:
J
MARION M. SEIOLE.
Plaintiff
. IN THE COURT OF COMMON PLEAS OF
.
.
. CUMBERLAND COUNTY, PENNSYLVANIA
.
.
: CIVIL ACTION . LAW
.
.
NO. 1942 CIVIL 1994
. IN DIVORCE
.
VS.
GEORGE E. SEIDLE. JR..
Defendant
STATUS SHEET
DATE:
-1-~27-'7S
t.
mJ-P.;~ ~t:..O\~
11g :-R~~ ~~ Wr-M->3 ~~ ,1--
G\..Jli. Q, tlc33
Q~1i ~~~P> ~ r7
83 ~tc>,lli.~~
~~'.t- .9., \ 1 o-z.s-
MARION M. SEIDLE, . IN THE COURT OF COMMON PLEAS OF
.
Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
VS. . CIVIL ACTION - LAW
.
.
.
: NO. 1942 CIVIL 1994
GEORGE E. SEIDLE, JR., .
.
Defendant . IN DIVORCE
.
CONFERENCE
WITH COUNSEL AND PARTIES
TO: Marion M. Seid1e
Tina Simpson
George E. Seidle, Jr.
Samuel L. Andes
, Plaintiff
, Counsel for Plaintiff
, Defendant
, Counsel for Defendant
A conference has been scheduled at the Office of
the Divorce Master, 9 North Hanover Street, Carlisle,
Pennsylvania, on the
14th
day of
June, 1995, at 9:00 a.m.,
with counsel and the parties to discuss the outstanding economic
issues to determine if there is a basis of settlement of claims.
If issues remain after the conference a hearing will be
scheduled at another date.
Very truly yours,
Date of Notice: 4/27/95
E. Robert Elicker, II
Divorce Master