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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF .. PENNA.
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SANDRA T. RICKARDS,
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GIRARD E. RICKARDS,
Defendant
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DECREE IN
DIVORCE
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AND NOW, .... ,o,d~~~ ..l.CZ"..,... 19, ~,4",. it is ordered and
decreed that "S(\N.Qij.~, :r,. ,\lI,C~~\lD.s , . , , , , , , , , , , , , , , , . , , , , , , '. plaintiff,
and, , .., " " .. ~I;~~~P ,I;:, ,,~I;9!<!'o,~ql?, " , " " .. " , , , , " " , " '. defendant,
are divorced from the bonds of matrimony.
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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;
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LAW OFFICES
SNELBAKER
a
BRENNEMAN
THIS POST-NUPTIAL AGREEMENT
MADE AND ENTERED into this ;3 (!) 1"- day of
Jv~
,
1994, by and between:
SANDRA T. RICKARDS, of 327 East Louther
Street, Borough of carlisle, Cumberland
county, Pennsylvania, party of the first
part, hereinafter called "Wife",
AND
GIRARD E. RICKARDS, of 4575 Ethel Street,
Apartment F, Harrisburg, Dauphin County,
Pennsylvania, party of the second part,
hereinafter called "Husband":
WITNESSETH:
WHEREAS, the parties were intermarried on June 6, 1981; and
WHEREAS, two (2) children were born of said marriage,
namely:
a. Elizabeth A. Rickards, born on May 15, 1982; and
b. David E. Rickards, born on September 17, 1985;
collectively hereinafter called "Minor Children"; and
WHEREAS, during said marriage, the parties accumulated
certain marital property and incurred certain liabilities;
WHEREAS, certain differences have arisen between the parties
as a consequence of which they physically separated on November
16, 1992, (which separation continues at the present time), and
now desire to enter into an agreement for the final settlement of
their property and affairs; and
WHEREAS, the parties are represented separately by legal
counsel as follows: Wife is represented by Robert C. saidis,
Esquire, of the law firm of saidis, Guido & Masland, P.C., and
Husband is represented by Richard C. Snelbaker, Esquire, of the
law firm of Snelbaker & Brenneman, P.C.; and
WHEREAS, the parties have negotiated certain terms and
conditions concerning the dissolution of their marriage,
including an orderly disposition of marital assets and
liabilities, and certain other matters arising from their
relationship of spouses and parents;
WHEREAS, both parties acknowledge that each has had full
opportunity to be advised independently as to their respective
rights and obligations arising from their married status and in
the dissolution of their marriage and in the disposition of their
assets and liabilities, and each further acknowledges that she
and he have had a full opportunity to investigate and evaluate
the assets, liabilities and all aspects of each other's property
and their jointly owned assets and liabilities; and
WHEREAS, the parties agree that their marriage is
irretrievably broken; and
WHEREAS, Husband intends to institute an action in divorce
in the Court of Common Pleas of Cumberland County, Pennsylvania
(hereinafter called "Divorce Action");
NOW, THEREFORE, in consideration of these presents and of
the mutual covenants, promises, terms and conditions hereinafter
LAW OF'ICCS
SNElDAKER
a
BRENNEMAN
set forth and to be kept and performed by each party hereto, as
well as for other good and valuable considerations, and intending
to be legally bound hereby, the parties agree as follows:
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1. BACKGROUND AND DECLARATIONS. The foregoing preamble and
paragraphs are incorporated herein by reference thereto.
2. DIVORCE. The parties agree to terminate their marriage
by mutual consent without counselling as soon after the date
hereof as reasonably possible, and each agrees to make, execute
and file the necessary affidavits and consents to procure a
consensual divorce under the mutual consent provisions of the
pennsylvania Divorce Code (23 Pa. C.S. S3301(c)), such documents
to be filed in the Divorce Action to be commenced by Husband.
Husband agrees to provide wife with a certified copy of the final
Decree in Divorce when issued, such delivery to occur as part of
the mutual exchange as provided hereinbelow.
3. INVENTORY OF MARITAL ASSETS AND LIABILITIES. The
parties acknowledge and agree that their marital property as
defined under the Pennsylvania Divorce Code consists of all those
LAW OFFICES
SNELDAKER
a
BRENNEMAN
certain items of property more fully set forth on a certain list
or schedule attached hereto marked "Exhibit A" and incorporated
herein by reference thereto. The parties severally acknowledge
and agree that each has had full opportunity to independently
determine the value of said marital property and each is aware of
such value or has consciously and intentionally waived the
opportunity to determine such value. The parties further
acknowledge and agree that they have incurred debts and
obligations as more fully identified on a certain list or
schedule attached hereto marked "Exhibit B" and incorporated
herein by reference thereto.
-3-
4. DISTRIBUTION OF MARITAL ASSETS. Subject to the
procedure for accomplishing the distribution, the parties agree
that the marital property shall be disposed of and distributed in
kind as follows (all references are to designations appearing on
Exhibi t A):
(al TO WIFE:
(1) Marital residence real estate * A(l)
(2) Household goods located at marital
residence A(2)
(3) Retirement/pension benefits via employment B(l)
(bl TO HUSBAND:
(1) 1990 Eagle Summit Automobile
(2) 1984 Ford Tempo Automobile
(3) Retirement/pension benefits via employment
(4) Household goods located at Husband's
residence
C(l)
C(2)
C(3) (a)
and (b)
C(4)
* Notwithstanding the foregoing provisions for distribution of
the marital residence real estate in kind to Wife, said
LAW O,.'ICE.
SNELDAKER
a
BRENNEMAN
distribution is conditioned and contingent upon Wife's payment in
full of the mortgage loan on said premises, being item A(l) as
shown on Exhibit B, or her obtaining from the lender/mortgagee an
unconditional release of Husband's liability on the obligation
secured by said mortgage, within six (6) months following the
entry of a decree in divorce in the action to be commenced by
Husband, time being of the essence of this agreement. If Wife
should fail or neglect to pay said obligation or obtain Husband's
unconditional release of liability therefrom within said period
of six (6) months, the parties agree to immediately sell said
real estate on the open real estate market at a mutually
agreeable price. If the parties are unable to agree upon a
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price, the price shall be fixed by taking the average of the
appraisals made by steven Barrett and Larry Foote, both of
Carlisle, PA. The costs of said appraisals to be considered
costs of sale. Wife shall be entitled to the net proceeds of the
sale of said real estate. If either party should fail or refuse
to participate in said sale, the parties agree that either party
may institute an action in equity to specifically enforce the
provisions hereof, each hereby agreeing that there is no adequate
remedy at law.
5. NATURE OF TRANSFER IN DISTRIBUTION. It is the mutual
intention of the parties to distribute the assets in accordance
with the allocation in Paragraph 4 hereinabove in such manner
that the full ownership of each asset (and all parts of each
asset) shall pass unconditionally to the designated distributee
free and clear of all liens and encumbrances except only as
expressly provided herein.
6. METHOD OF TRANSFER IN DISTRIBUTION. The in-kind
distribution of marital property shall be accomplished
immediately following the entry of the final decree of divorce in
the Divorce Action. To effect and assure such distribution, the
parties acknowledge that each has contemporaneously with the
execution hereof made, signed, acknowledged and otherwise
executed appropriate deeds, assignments, transfers, releases and
LAW OFFICES
SNELDAKER
a
BRENNEMAN
all other documents necessary to effect such distribution and
that each has deposited the same with her and his respective
attorney, to be held by them in irrevocable escrow until the
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final decree of divorce is entered, upon which event, delivery of
such instruments shall be accomplished within ten (lO) calendar
days following said entry of decree of divorce.
Individually owned property to be retained in distribution
by the present owner shall require no further present action;
however, the parties agree to make, execute, acknowledge and
deliver such instruments and take such further action as may
hereafter be determined to be requisite and necessary to effect
confirmation of such sole individual ownership.
7. DISTRIBUTION OF MARITAL LIABILITIES.
A. Wife covenants and agrees to pay all payments when due
on the first mortgage loan on the marital residence real estate
(Item A(l) on Exhibit B).
B. The parties shall pay equally all payments when due on
the second mortgage loan on the marital residence real estate
(Item A(2) on Exhibit B), by each contributing one-half the
amounts due. At such time as the first mortgage loan (Item A(l)
of Exhibit B) is paid in full or at such time as Husband is
unconditionally released from liability thereon, Husband shall
pay in a lump sum seventy per centum (70%) of the then balance
of said second mortgage loan and wife shall pay in a lump sum
thirty per centum (30%) of the then balance of said loan.
LAW OFFICES
SNELDAKER
a
BRENNEMAN
c. Wife shall pay all individual obligations set forth in
item B of Exhibit B.
D. Husband shall pay all individual obligations set forth
in item C of Exhibit B.
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E. Each party hereby agrees to indemnify the other party
and hold her or him respectively harmless of and from any and all
liability, damages, costs, expenses, claims, demands, actions,
causes of action and all other obligations of whatsoever kind or
nature suffered or imposed by either party because of such other
party's failure to pay and discharge her or his responsibility
under subparagraphs A, B, C and/or D of this Paragraph 7.
8. ALIMONY FOR WIFE. Husband covenants and agrees to pay
as alimony to Wife through the Cumberland County, Pennsylvania,
Domestic Relations Office the sum of Two Hundred Eighty-seven
($287.00) Dollars per month up to and including August 1, 1996,
at which latter time said obligation shall cease and terminate
(unless earlier terminated as provided hereinbelow), said sum to
be due and payable on the first day of each month. It is
understood that under current federal income tax law said
payments are considered income to Wife and deductible from
Husband's gross income. Said amount shall not be subject to
modification regardless of the future economic circumstances of
LAW O"'ICCS
SNELDAKER
a
BRENNEMAN
either party.
Husband's obligation to pay said alimony and Wife's right to
receive such alimony shall terminate upon (i) Husband's death,
(ii) Wife's death, (iii) Wife's subsequent marriage, or (iv)
Wife's cohabitation with a non-relative male person in a
meretricious relationship.
9. FEES. COSTS AND EXPENSES.
A. Husband agrees to be solely responsible for the filing
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fee and the costs and expenses of processing the Divorce Action
provided that said Action is resolved without contest and in
accordance with terms of paragraph 2 hereinabove.
B. Wife agrees to be solely responsible for the costs and
expenses of the transfer of the marital residence real estate.
C. Each party agrees to be solely responsible for the costs
and expenses of the transfer of any other assets to her or him
respectively.
D. Each party agrees to be solely responsible for her and
his respective counsel fees, costs and expenses in negotiating
and concluding this agreement, dissolving their marriage and
consummating all provisions of this agreement.
lO. FUTURE OBLIGATIONS. The parties agree that any and all
obligations incurred subsequent to the date of this Agreement
shall be the sole and separate liability and responsibility of
the party incurring the obligation, and each party agrees that
he/she will not incur or attempt to incur any obligation for or
on behalf of the other party.
LJlW OFFices
SNELDAKER
a
BRENNEMAN
11. ALL OTHER INDIVIDUAL PROPERTY. Except only as
specifically provided otherwise hereinabove, each party shall
retain all property, real, personal or otherwise, which is
presently titled in his or her name and ownership, whether or not
said property is or would be deemed to be marital property under
the Pennsylvania Divorce Code and whether or not included in
Exhibit A, and each party hereby expressly releases the other of
and from any and all right of equitable distribution in and to
-8-
said individually owned property of such other party.
12. RELEASE OF SUPPORT AND RIGHTS UNDER DIVORCE CODE.
Except only as specifically provided to the contrary hereinabove
in this Agreement, each party hereby waives and forever releases
the other party of and from any and all claims which either may
have against the other for spousal support and for all claims
which either may have against the other by reason of and pursuant
to the Pennsylvania Divorce Code (and the divorce law of any
other jurisdiction) including, but not limited to, alimony,
alimony pendente lite, equitable distribution of marital
property, counsel fees, costs and expenses; except that the
performance of the obligation created hereunder may be enforced
by any remedies under said Divorce Code.
13. GENERAL RELEASE. Husband relinquishes his inchoate
intestate right in the estate of Wife, and Wife relinquishes her
inchoate intestate right in the estate of Husband, and each of
the parties hereto by these presents, for himself or herself, his
or her heirs, executors, administrators or assigns, does hereby
remise, release, quit-claim and forever discharge the other party
hereto, his or her heirs, executors, administrators or assigns,
or any of them, of any and all claims, demands, damages, actions,
causes of action or suits at law or in equity of whatsoever kind
or nature, for or because of any matter or thing done, omitted or
LAW OFfiCES
SNELDAKER
a
BRENNEMAN
suffered to be done by such other party prior to the date hereof,
except that this release shall in no way exonerate or discharge
either party from the obligations and promises made and imposed
-9-
by reason of this Agreement. This Agreement shall not be
construed to affect or bar the right of either party to an
absolute divorce on legal and truthful grounds if they now exist
or may hereafter arise, this Agreement being intended to provide
a definite and orderly method of resolving the various property
and business transactions between the parties, and not being
intended as an agreement by either party not to defend against a
suit in divorce commenced by either party or in any other way to
be regarded as a waiver of any right by either party to
participate in the litigation of any such action, with the
exception of any rights, however, as previously released by this
Agreement with regard to alimony, alimony pendente lite,
equitable distribution of property, counsel fees, costs and
expenses, other than the enforcement or performance of this
Agreement which may be instituted pursuant to the remedies
available under the Pennsylvania Divorce Code.
l4. CUSTODY OF MINOR CHILDREN.
A. The parties shall share legal custody of the Minor
Children.
B. Wife shall have primary physical custody of the Minor
Children.
LAW O,.'ICC.
SNELDAKER
a
BRI::;NNEMAN
C. Husband shall have reasonable and liberal temporary
custody of the Minor Children to accommodate his working
schedule, to include generally periods of time on weekends,
holidays and vacation seasons, as the parties may agree from time
to time.
If
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'1I
D. Wife shall not remove the Minor Children from the
Commonwealth of Pennsylvania for a period of time exceeding two
(2) weeks without Husband's prior consent.
E. In the event of a dispute concerning the custody of the
Minor Children, the parties agree that the Court of Common Pleas
of Cumberland County, Pennsylvania, shall have exclusive
jurisdiction of the Minor Children, the parties and the subject
matter which shall continue for a period of six (6) months
subsequent to Wife's removal of the children from said county of
Cumberland.
l5. INCOME TAX EXEMPTIONS OF MINOR CHILDREN. For the
purpose of income tax calculation, Wife shall have the right
hereafter to claim David E. Rickards as a dependent exemption and
Husband shall have the right to claim Elizabeth A. Rickards as a
dependent exemption, said rights to claim exemptions to continue
until said Children become emancipated and no longer dependent as
required by income tax law. Neither party shall claim both
children as dependent exemptions. The parties agree to cooperate
with each other to assure the division of exemptions as provided
above by providing the taxing authorities with such documentation
or information to implement their agreement to share said
exemptions.
LAW O'FICE;S
SNELBAKER
a
BRENNEMAN
16. SURVIVAL OF AGREEMENT. It is the intention of the
parties that this Agreement shall survive any action in divorce
which may be instituted or prosecuted by either party, and no
order, judgment or decree of divorce, temporary, interlocutory,
-11-
final or permanent, shall affect or modify the terms of this
Agreement, but said Agreement may be enforced by any remedy at
law or in equity, including enforcement proceedings under the
Pennsylvania Divorce Code.
17. ENFORCEMENT AND COUNSEL FEES. In the event that any of
the provisions of this agreement are breached or violated by
either of the parties, the other party shall be entitled to
enforce this agreement by an appropriate action of law or in
equity or to take any other action to which they are lawfully
entitled to enforce this agreement or otherwise protect their
rights. In the event that such action is commenced by one of the
parties and the other party is found to have breached or violated
any of the terms and provisions of this agreement, the party
having so violated or breached the agreement shall be responsible
for and promptly pay upon demand, the reasonable attorney's fees
incurred by the other party to enforce their rights hereunder.
l8. ENTIRE AGREEMENT. This Agreement contains the entire
understanding of the parties and there are no representations,
warranties, covenants or undertakings other than those expressly
set forth herein.
19. ADDITIONAL INSTRUMENTS. Each of the parties shall from
LAW O""ICEG
SNELOAKER
a
BRENNEMAN
time to time, at the request of the other, execute, acknowledge
and deliver to the other party any and all further instruments
that may be reasonably required to give full force and effect to
this Agreement.
20. WAIVER. The waiver of any term, condition, clause or
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provision of this Agreement shall in no way be deemed or
consinered a waiver of any other term, condition, clause or
provision of this Agreement.
2l. APPLICABLE LAW. This Agreement shall be construed,
interpreted and enforced according to the laws of the
Commonwealth of Pennsylvania.
22. HEADINGS. The headings or titles of the numbered
paragraphs of this Agreement have been used only for the purposes
of convenience and shall not be resorted to for the purposes of
interpretation or construction ~f the text of this Agreement.
IN WITNESS WHEREOF, the parties have hereunto set their
respective hands and seals the day and year first above written
intending thereby to legally bind themselves and their respective
heirs, personal representatives and assigns.
WITNESSED BY:
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J \\.~I'..b,,~~y ~ ,).. \ A- (SEAL)
. ., Sandra T. ckards
~;"./ ,.
Gl.rar
(SEAL)
LAW O,.,ICES
SNELBAKER
a
BRENNEMAN
-l3-
COMMONWEALTH OF PENNSYLVANIA )
: SSe
COUNTY OF CUMBERLAND)
On this, the~ day Of~~~ ' 1994, before me,
a Notary Public in and for the commonwealth and County aforesaid,
the undersigned officer, personally appeared SANDRA T. RICKARDS,
known to me (or satisfactorily proven) to be the person whose
name is subscribed to the within instrument, and acknowledged
that she executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official
seal.
NOTARIAL SOL
JOAH E. SMITH. NOTARY PUBUC
CARUSLE BOROUGH. CUMBERLAND CO.. PA
MY COMMISSION EXPIRES MARCH 23. 1996
( "'~~1#
./ Notary Public
COMMONWEALTH OF PENNSYLVANIA )
: SSe
COUNTY OF CUMBERLAND)
On this, the 20"6/ \lay of q lUZ.L
, 1994, before me,
a Notary public in and for the commonwealth and County aforesaid,
the undersigned officer, personally appeared GIRARD E. RICKARDS,
known to me (or satisfactorily proven) to be the person whose
name is subscribed to the within instrument, and acknowledged
that he executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official
seal.
(?(it/ () .(fkke@t.
No ary Pub
LAW O""ICES
SNELDAKER
a
BRENNEMAN
NoIaIial Soal
Usa A. Qsholsl<i. NalaIY.NlIc
l.a.ot" Pax\CI11'/,p..1JalVdn COLI1IY
My 00",,1lssllln e.pres Oct 9. 1995
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EXHIBIT A
MARITAL PROPERTY OF SANDRA T. AND GIRARD E. RICKARDS
A. JOINTLY OWNED ASSETS
(l)
Marital residence real estate at 327 East Louther
Street in the Borough of Carlisle, cumberland County,
Pennsylvania.
Household goods, furniture, fixtures and appliances
located at marital residence identified above.
(2)
B. ASSETS OWNED INDIVIDUALLY BY WIFE
(1) Retirement/pension benefits via employment.
C. ASSETS OWNED INDIVIDUALLY BY HUSBAND
(l) 1990 Eagle Summit automobile.
(2) 1984 Ford Tempo automobile.
(3) Retirement/pension benefits via employment:
(a) Wix, Wenger & Weidner Profit Sharing Plan.
(b) Army National Guard.
(4) Household goods, furniture and appliances other than
specified in A(2) above, located at Husband's residence.
LAW O"'ICE;S
SNELBAKER
a
BRENNEMAN
.' ..
EXHIBIT B
MARITAL LIABILITIES OF SANDRA T. AND GIRARD E. RICKARDS
A. JOINT OBLIGATIONS OF BOTH PARTIES
(1) Mortgage loan from Loyola Federal Savings and Loan
Association as secured on marital residence (Item A(l)
on Exhibit A) having a current balance of $36,597.9l.
(2) Mortgage loan from Defense Activities Federal Credit
Union as secured on marital residence (Item A(l) on
Exhibit A) having a current balance of $2,600.02.
B. INDIVIDUAL OBLIGATIONS OF WIFE
(1) Student loans.
c. INDIVIDUAL OBLIGATIONS OF HUSBAND
(1) Student loans.
LAW O,.,.ICE8
SNELOAKER
a
BRENNEMAN
SANDRA T. RICKARDS,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,PENNSYLVANIA
NO. 94-2754 CIVIL TERM
v.
GIRARD E. RICKARDS,
Defendant
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the following
information,
to the Court for entry of a divorce decree:
1. Ground for divorce: Irretrievable breakdown under
Section 330l(c) of the Divorce Code.
2. Date and manner of service of the Complaint: Certified
and Restricted mail on May 25, 1994. Affidavit of Service
filed on June 3, 1994.
3. (Complete either paragraph (a) or (b):
(A) Date of execution of the Affidavit of Consent required
by Section 3301(c) of the Divorce Code:
By the Plaintiff:
By Defendant:
10/11/94
9/9/94.
(B)(l) Date of Execution of the Plaintiff's Affidavit
required by Section 3301(d) of the Divorce
Code:
SAlDIS, GUIDO,
SHUFF &
MASLAND
26 W. High Sl1<et
Carlisle. PA
(2) Date of Service of the Plaintiff's Affidavit upon
the Defendant:
4. Related claims pending:
.rvc
Robert C. Saidis, Esq.
Attorney for Plaintiff
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SANDRA T. RICKARDS,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. Q'-l-J7S'f ~T~
v.
GIRARD E. RICKARDS,
. Defendant
IN DIVORCE
NOTICE
You have been sued in court. If you wish to defend against
the claims set forth in the following pages, you must take prompt
action. You are warned that if you fail to do so, the case may
proceed without you and a decree of divorce or annulment may be
entered against you by the Court. A judgment may also be entered
against you for any other claim or relief requested in these
papers by the Plaintiff. You may lose money or property or other
rights important to you, including custody or visitation of your
children.
When the ground for the divorce is indignities or
irretrievable breakdown of the marriage, you may request marriage
counseling. A list of marriage counselors is available in the
Office of the Prothonotary at the Cumberland County Court House,
High and Hanover Street, Carlisle.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, 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 Court House
1 Courthouse Square
Carlisle, PA l70l3
(717) 240-6200
/~
/ \..----C
/Robert C. Saidis, Esq.
'Attorney for Plaintiff
SANDRA T. RICKARDS,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO.
GIRARD E. RICKARDS,
Defendant
: IN DIVORCE
COMPLAINT
l. Plaintiff is SANDRA T. RICKARDS, who currently resides
at 327 East Louther Street, Carlisle, Cumberland County,
Pennsylvania.
2. Defendant is GIRARD E. RICKARDS, who currently resides
at 4575 Ethel Street, Apartment F, Harrisburg, Dauphin County,
Pennsylvania.
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. The Plaintiff and Defendant were married on June 6,
1981, in Bethaney, Pennsylvania.
5. There have been no prior actions of divorce or for
annulment between the parties.
SAIDlS, GUIDO,
SHUFF &
MAS LAND
26 W. Iligh 51reel
Carlisle. PA
I
Ii marriage counseling and the Plaintiff may have the right to
'I
I'
:: request that the Court require the parties to participate in
q
'I
': counseling.
Having been so advised Plaintiff does not desire the
6.
The Plaintiff has been advised of the availability of
i'
Ii Court to order counseling.
"
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7. The marriage is irretrievably broken.
WHEREFORE, Plaintiff requests Your Honorable Court to enter
a decree in divorce.
. .
COUNT II
8. The allegations in paragraphs one through seven,
inclusive, are made a part hereof and incorporated herein by
reference.
9. The Plaintiff alleges that in violation of his marriage
vows, the Defendant has over a period of time, in Cumberland
County, and other places offered such indignities to the person
of the Plaintiff as to render her condition intolerable and life
burdensome.
10. This action in divorce is not collusive.
WHEREFORE, Plaintiff prays Your Honorable Court to enter a
decree of divorce.
COUNT I II
EOUITABLE DISTRIBUTION
1l. The allegations in Paragraphs one through ten,
inclusive, are made a part hereof and incorporated herein by
reference.
l2. Plaintiff and Defendant have acquired property, both
real and personal, during their marriage.
SAlOIS, GUIOO,
SHUFF &
MASLAND
26 W. High Street
Carli.le, PA
WHEREFORE, Plaintiff requests this Honorable Court to
I
II determine marital property and to order an equitable distribution
thereof.
I
I COUNT IV
II
il
Ii ALIMONY
II
Ii
:1 13. The allegations in Paragraphs one through twelve,
;1
Ii inclusive, are made a part hereof and incorporated herein by
il
II reference.
. .
14. Plaintiff lacks sufficient property to provide for her
reasonable needs.
lS. Plaintiff requires reasonable support to adequately
maintain herself and her family in accordance with the standard
of living established during the marriage.
l6. Defendant is financially able to provide for the
reasonable needs of the Plaintiff.
WHEREFORE, Plaintiff requests Your Honorable Court to enter
an award of alimony pendente lite until final hearing and
permanent alimony thereafter.
COUNT V
COUNSEL FEES. COSTS AND EXPENSES
l7. The allegations in Paragraphs one through sixteen,
inclusive, are made a part hereof and incorporated herein by
reference.
lB. Plaintiff has retained the services of Saidis, Guido,
Shuff & Masland and the counsel fees, costs and expenses for
representation in this action will be substantial and continuing.
19. Plaintiff is without sufficient funds, income or assets
SAIDIS, GUIDO,
SHUFF &
MASLAND
26 W, High 51"""
Carlisle. PA
, to pay such counsel fees, costs and expenses.
I
I
I certified public accountant, appraisers, and other experts with
i regard to this action.
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'I enter an award for preliminary and interinl counsel fees, costs
,
,
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II
II
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20.
Plaintiff will need to retain the services of a
WHEREFORE, Plaintiff prays that this Honorable Court
. '
and expenses and to enter a final award of counsel fees, costs
and expenses.
u ly submitted,
/ Rober C. Saidis, Esq.
. Attorney for Plaintiff
SAIDIS, GUIDO,
SHUFF &
MAS LAND
26 W. High Street
Callisl.. PA
I
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. .
SANDRA T. RICKARDS,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. C) Y - 2 Tf..'-( C. VI( f(./ZI1,....
GIRARD E. RICKARDS,
Defendant
IN DIVORCE
~DER OF COURT
AND NOW, this ~1 day of May, 1994, upon consideration of
the attached Petition, it is hereby directed and ordered that a
hearing is scheduled in Court Room No. ~ of the Cumberland
County Courthouse, Carlisle, Pennsylvania, on the I(~
~ ~t f:.J(} 11/11,
day of , 1994, to consider an interim award of
Counsel F s, Costs and Expenses and the conversion of spousal
support to Alimony Pendente Lite.
It is further ordered and directed that if there is an
appeal of the Domestic Relations Office recommendation for
spousal support and child support, that that matter shall be
consolidated with the aforementioned hearing.
J.
SAID IS, GUIDO,
SHUFF &
MASLAND
26 W. High Slreet
C",Ii.le.PA
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II SANDRA T. RICKARDS,
Plaintiff
I
IV.
I
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO.
GIRARD E. RICKARDS,
Defendant
IN DIVORCE
PETITION
l. Petitioner is SANDRA T. RICKARDS, who currently resides
at 327 East Louther Street, Carlisle, Cumberland County,
Pennsylvania.
2. Respondent is GIRARD E. RICKARDS, who currently resides
I at 4575 Ethel Street, Apartment F, Harrisburg, Dauphin County,
I Pennsylvania.
3. A divorce action was filed in the Court of Common Pleas
of Cumberland County, Pennsylvania, to the above-captioned term
and number.
4.
Your Petitioner's Complaint requested Alimony Pendente
I
I Lite, Counsel
I
I
i
Fees, Costs and Expenses.
5.
Petitioner is in need of interim Counsel Fees, Costs and
Expenses to be able to properly evaluate and litigate this
divorce action.
SAlOIS, GUIDO,
SHUFF &
MASLAND
26 W. High 51"'<'
Cnrlisle.PA
6. The Respondent is financially able to pay said expenses.
7. The Petitioner desires that her spousal support be
converted to Alimony Pendente Lite.
8. Petitioner has requested an increase in spousal support
and child support which is currently scheduled in the Domestic
Relations Office for June 15, 1994.
9. Petitioner requests a consolidated hearing on the issue
. .
of Alimony Pendente Lite, Counsel Fees, Costs and Expenses with
Spousal and Child support, if necessary.
WHEREFORE, Petitioner requests your Honorable Court to
schedule a hearing for the purposes of considering the conversion
of spousal support to Alimony Pendente Lite and to issue an
interim Order for Counsel Fees, Costs and Expenses.
Respectfully submitted,
:'~'~1J- SH'FF & MA'LAN'
By:1 '
Robert c. Saidis, Esquire
Attorney for Petitioner
26 W. High Street
Carlisle, PA 17013
SAID IS, GUIDO, II
snUFF & Ii
MASLAND
26 W. Hiah 5u..1
Cllfli.le.PA
II
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COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND :SS
I verify that the statements made in this Complaint are true
and correct. I understand that false statements herein are made
subject to the penalties of lB Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
DATED:
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SANDRA T. RICKARDS,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY PENNSYLVANIA
: NO. 94-2754 CIVIL TERM
GIRARD E. RICKARDS,
Defendant
IN DIVORCE
AFFIDAVIT OF SERVICE
I, Joan E. Smith, certify that on May 25, 1994, I served
a true and correct copy of the within Complaint in Divorce
in this matter by depositing same in the United States mail,
postage prepaid certified, restricted delivery addressed as
follows:
Girard E. Rickards
4575 Ethel St., Apt. F
Harrisburg, PA l7109
DATED: May 31, 1994
-d cd
onE. Smit
IDIS, GUIDO & MASLAND
26 West High Street
Carlisle, PA l70l3
Sworn to and subscribed
I before me this ..3/ d
day of -:>en/' ' 1994.
. ...~__."..1
SAlOIS, GUIDO,
SHUFF &
MASLAND
26 W, High Sl=l
eMUsle. PA
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 94-2754 civil Term
SANDRA T. RICKARDS,
Plaintiff
GIRARD E. RICKARDS,
Defendant
IN DIVORCE
-, ~
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AFFIDAVIT OF CONSBNT
1. 'J; A Complaint in divorce under section 3301(c) of the
Divorce~Code was filed on May 23, 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 I may lose rights concerning alimony,
division of property, lawyer's fees or expenses if I do not claim
them before a divorce is final.
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 l8 Pa.C.S.A. S4904 relating to unsworn
falsification to authorities.
Date:
&/:24,;11
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SANDRA T. RICKARDS, : IN THE COURT OF COMMON PLEAS
Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
v. . NO. 94-2754 Civil Term
.
GIRARD E. RICKARDS,
Defendant . IN DIVORCE
.
AFFIDAVIT OF CONSENT
1. A Complaint in divorce under Section 3301 (c) of the
Divorce Code was filed on May 23, 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 I may lose rights concerning alimony,
division of property, lawyer's fees or expenses if I do not claim
them before a divorce is final.
I verify that the statements made in this affidavit are true
and correct. I understand that false statements herein are made
subject to the penalties of 18 Pa.C.S.A. S4904 relating to unsworn
falsification to authorities.
Date:
0::tctJer 11, 1994
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Robert C. Saldls
Edward e. Guido
Geoffrey S, Shuff
Albert H, Masland
lohnna l. Deily
TImothy M, Ansllne
William C, Yohs
Law Offices
SAIDIS, GUIDO, SHUFF & MASLAND
A PROFESSIONAL CORPORATION
26 Wesl High Street. Post Office Box 560
Carlisle, Pennsylvania 17013
Telephone: (717) 243-6222 . Facsimile: (717) 243-6486
West Shore om..:
2109 Markel S1ICeI
Camp Hili. PA 17011
Telephone: (71'1) 737.3405
PacslmJle: (717) 737.3407
Reply 10 Carlble
July 11, 1994
Honorable George E. Hoffer
Court of Common Pleas
Cumberland County Cour~hou8e
Carlisle, PA l7013
~Mi j:i"~
/l'c~r
Re: Rickards v. Rickards
No. 94-2754 Civil Term
Dear Judge Hoffer:
This will confirm my conversation with your office on July ll,
1994 canceling the hearing on my client's Petition for Special
Relief, Counsel Fees, Costs and Expenses.
Thank you for your kind cooperation in this matter.
Very truly yours,
~ GUIDO, SHUFF
. oe
& MAS LAND
Robert C. Saidis
RCS:rlm
CC: Sandy Rickards
Richard C. Snelbaker, Esquire
--