HomeMy WebLinkAbout02-3491JONATHAN A. STEEVER,
Plaintiff,
STACI A. STEEVER,
Defendant.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: 2002 - ~ ~qlCIVIL TERM
: 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 in 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 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 17013.
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.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
717-249-3166
1-800-990-9108
AMERICANS WITH DISABILITIES
ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with the
Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable
accommodations available to disabled individuals having business before the court, please contact our
office. All arrangements must be made at least 72 hours prior to any hearing or business before the court.
You must attend the scheduled conference or heating.
JONATHAN A. STEEVE~
:INTHE COURT OF COMMON PLEAS OF
Plaintiff,
STACI A. STEEVER,
Defendant·
· CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: 2002 - ~'/~; CIVIL TERM
: IN DIVORCE
.COMPLAINT IN DIVORCE
_PURSUANT TO SECTIONS 3301(a~(6) AND 3301(c)
OF IHE DIVORCE CODE
COUNT I: Section 3301(a~(6)
AND NOW, comes the Plaintiff, Jonathan A. Steerer, by and through his attorneys,
IRWIN, McKNIGHT & HUGHES, Esquires, and files this Complaint in Divorce against the
Defendant upon the cause of action hereinafter set forth:
1. Plaintiff is Jonathan A. Steever, an adult individual who resides 243 South
Hanover Street, Carlisle, Cumberland County, Pennsylvania.
2. The Defendant is Staci A. Steerer, an adult individual residing at 779 Hamilton
Court, Carlisle, Cumberland County, Pennsylvania.
2. The Defendant and Plaintiff have resided in the Commonwealth of Pennsylvania
for at least six months previous to the filing of this action in divorce.
3. The Defendant and Plaintiff were married on or about July 18, 1992.
4. There were two children born to this marriage, namely Chloe A. Steerer, born
July 13, 1995 (age 7); and Harrison D. Steever, born May 12, 1998 (age 4).
6. Pursuant to the Divorce Code, Section 3301(a)(6), the Plaintiff avers as the
grounds upon which this action is based that the Plaintiff is thc injured spouse and that the
Defendant has offered such indignities to him as to render his condition intolerable and life
burdensome.
7. The Plaintiff avers that he has been advised of the availability of counseling and
that said party has the right to request that the court require the parties to participate in
counseling.
WHEREFORE, the Plaintiff demands judgment
a. Dissolving the marriage between the two parties;
b. Equitably distributing all property, both personal
and real, owned by the parties; and
c. for such further relief as your Honorable Court may deem
equitable and .just.
COUNT II: Section 3301(c)
8. The averments of Paragraphs One through Five are incorporated herein by
reference as though fully set forth below.
9. Plaintiff avers as the grounds upon which the Action in Divorce is based is that
the marriage of the parties is irretrievably broken.
10. The averments of Paragraph Six are incorporated herein by reference as though
fully set forth below.
WHEREFORE, the Plaintiffdemands judgment
a. Dissolving the marriage between the two parties;
b. Equitably distributing all property, both personal and real, owned by the
parties; and
for such further relief as your Honorable Court may deem
equitable and just.
Date: July ~ , 2002
Respectfully submitted,
IRWIN, Mci{NIGHT & HUGHES
tingles, Esqmre r~
~ttorney for Plaintiff M./
60 West Pomfret Street
Carlisle, Pennsylvania 17013
(717) 249-2353
Supreme Court I. D. No. 67212
VERIFICATION
The foregoing document is based upon information which has been gathered by my
counsel and myself in the preparation of this action. I have read the statements made in this
document and they are true and correct to the best of my knowledge, information and belief. I
understand that false statements herein made are subject to the penalties of 18 Pa.C.S.A. Section
4904, relating to unswom falsification to authorities.
JON.4 TH.4N /I. S TEE VER
,2002
JONATHAN A. STEEVER,
Plaintiff
Vo
STACI A. STEEVER,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: CIVIL ACTION - CUSTODY
: NO. 2002-3491 CIVIL TERM
:
: IN DIVORCE
PRAECIPE TO ENTER APPEARANCE
TO THEPROTHONOTARY:
Please enter the appearance of Thomas S. Diehl, Esquire, on behalf of Staci A. Steever,
the Defendant in the above-captioned case.
Date:
December 26, 2002
"--Th~omas S. Diehl, Esqmre
One West High Street, Suite 208
Post Office Box 1290
Carlisle, Pennsylvania 17013
(717) 240-0833
JONATHAN A. STEEVER,
: IN THE COURT OF COMMON PLEAS OF
Ve
STACI A. STEEVER,
Plaintiff,
Defendant.
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: CIVIL ACTION - LAW
: 2002 - 3491 CIVIL TERM
: IN DIVORCE
AGREEMENT AND STIPULATION
THIS STIPULATIONANDAGREEMENTenteredintothis t~&day of~.
2003, by and between Staci A. Steever, (hereinafter referred to as "Mother") and Jonathan A. Steever,
(hereinafter referred to as "Father").
WHEREAS, Father and Mother are the natural parents of Chloe A. Steever, bom 7-13-95, and
Harrison D. Steever, born 5-12-98; and
WHEREAS, Father and Mother desire to enter into a cotnprehensive Custody Stipulation and
Agreement setting forth the physical and legal custody arrangements for their minor children, to be in
effect hereafter and until altered by subsequent order of court; and
WHEREAS, Father and Mother desire to confirm their agreement relative to custody of their
minor children and execute a Stipulation and Agreement to affect the same.
NOW, THEREFORE, in consideration of the mutual covenants, promises and agreements as
hereinafter set forth and intending to be legally bound, the parties hereto agree as follows:
1. The Father and Mother shall share legal custody of their two children, Chloe A. Steever
and Harrison D. Steever.
2. Father shall have primary physical custody of the two minor children.
3. Mother shall have periods of partial physical custody of the minor children at times and
places as agreed upon between the parties.
4. The parties will keep each other advised immediately relative to any emergencies
concerning the minor children and shall, further, take any necessary steps the ensure that the health and
wellbeing of the children is protected.
5. The parties agree that there shall be reasonable telephone contact with the children during
periods when the children are not in the custody of that party.
6. Neither party shall do anything that may estrange the children from the other party, or
injure the opinion of the children as to the other party, or may hamper the free and natural development of
the children's love and affection for the other party.
7. Each party shall be entitled to complete and full :information from any doctor, dentist,
teacher or other similar authority and have copies of any reports given to them as a parent. Such
documents include, but are not limited to, medical reports, academic and school report cards, and birth
certificates.
8. Any permanent modification or waiver of the provisions of this Agreement must be in
writing and shall be affective only if made in writing and executed with the formality as this Stipulation
and Agreement.
9. The parties acknowledge that entering into this StJ[pulation and Agreement, there has
been no fraud, concealment, overreaching, coercion, or other unfair dealing on the part of either party.
10. The parties acknowledge that they have read and understood the provisions of this
Stipulation and Agreement. Each party acknowledges that the Stipulation and Agreement is fair and
equitable and that it is not the result of duress or undue influence.
IN WITNESS WItEREOF, the parties hereto intending to lxl legally bound by the terms hereof,
set forth their hands and seals the day and year first above written.
JONATHAN A. STEEVER
STATE OF PENNSYLVANIA .
COUNTY OF CUMBERLAND .
On this, the I ~----day of
· . .,~r_~..]l! ~/u ~ ,2003, before me this undersigned
officer, personally appeared STACI A.-S"i'EEV~R, known to me (or satisfactorily proven) to be
the person whose name is subscribed to the within instrument, and acknowledged that she
executed same for the purposes therein contained.
IN WITNESS WItEREOF, I hereunl ;et my ha~ and qf6e~al. ~/~
Membei, Pe~msy.~an a ~oclationotNotaries
STATE OF PENNSYLVANIA .
COtJnT¥ OF CtJM E [LAND .
personally appeared JONATi-iAN~A.~$TEE~R. known to mc (or satisfactorily proven)
teh;ecP2~s~on__w_hos~e rt.,al'ne lS slJbscr.lbed to the within instrument, ~,d acknowle to be
· ~u same for me purposes therein contained, dged that he
IN WITNESS WHEREOF, I hereun
let my h~d and ,~fffi~ seal. .
JONATHAN A. STEEVER,
Plaintiff,
V.
STACI A. STEEVER,
Defendant.
ORDER OF COURT
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION'- LAW
: 2002 - 3491 CIVIL TERM
: IN DIVORCE
AND NOW, this J 3' day of r*x ~ ,2003, upon consideration of the attached
Stipulation and Agreement, the terms and conditions contained in the attached Stipulation and Agreement
are hereby made an Order of Court.
By the Court:
Jo
JONATHAN A. STEEVER,
Plaintiff
STACI A. STEEVER,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION .. LAW
No. 2002 - 3491 CML TERM
IN DIVORCE
MARRIA GE gE TTLEM£NT A GREEMENT
ay of ~, ; 2003, by and between
STACI A. STEEVER, (hereinafter referred to as "WIFE") and JONATHAN A. STEEVER,
(hereinafter referred to as "HUSBAND").
WITNESSETH:
WHEREAS, HUSBAND and WIFE were lawfully marr:ied on July 18, 1992; and
WHEREAS, diverse, unhappy differences, disputes and difficulties have arisen between
the parties, and the parties hereto are desirous of settling fully and finally their respective
financial and property, rights and obligations as between each other, including, but not limited to
the settling of all matters between them relating to the ownership and equitable distribution of
real and personal property, the settling of all claims and possible claims by one against the other
or against their respective estates, and the equitable distribution of property and alimony for each
party.
The parties hereto agree and covenant as follows:
It is the intent and purpose of this Agreement to set forth the respective rights and duties
of the parties while they continue to live apart from each other.
The parties have attempted to divide their matrimonial property in a manner which
Conforms to ajm and right S~andard, With due regard t° the rights Of ea~h p~i'It is the intent
of the parties that such division shall be final and shrill forever .determine their respective rights.
The division of existing marital property is not intended by the parties to constitute in any way a
sale or exchange of assets.
Further, the parties agree to continue living separately and apart from the other at any
place or places that he or she may select as they have heretofore been doing. Neither party shall
molest, harass, annoy, injure, threaten or interfere with the other party in any matter whatsoever.
Each party may carry on and engage in any employment, profession, business or other activity as
he or she may deem advisable for his or her sole use and benefit. Neither party shall interfere
with the uses, ownership, enjoyment or disposition of any property now owned and not specified
herein or property hereafter acquired by the other.
The consideration for this contract and agreement is the mutual benefit to be obtained by
both of the parties hereto and the covenants and agreements of each of the parties to the other.
The adequacy of the consideration for all agreements herein contained is stipulated, confessed,
and admitted by the parties, and the parties intend to be legally bound hereby.
Each party to the Agreement acknowledges and declares that he or she,
respectively:
. (1) Is represented by counsel of his or her own ch0os_ing, or if not represented by
counsel, understands that he or she has the right to counsel: HUSBAND is
represented by Rebecca R. Hughes, Esquire of Irwin, McKnight & Hughes; WIFE
is represented by Thomas Diehl, Esquire;
(2) Is. fully and completely informed of the facts relating to the subject matter of
this Agreement and of the rights and liabilities of the parties;
(3) Is entering into this .Agreement voluntarily after receiving the advice of
counsel or after choosing not to consult an attorney;
(4) Has given careful and mature thought to the making of this Agreement;
(5) Has carefully read each provision of this Agreement; and
(6) Fully and completely understands each provision of this Agreement, both as
to the subject matter and legal effect of each provision.
This Agreement shall become effective immediately as of the date of execution.
o
It is the purpose and intent of this Agreement to settle forever and completely the interest
and obligations of the parties in all property that they own separately, and all property that would
qualify as marital property under the Pennsylvania Divorce Code, Title 23, Section 401(e), and
that is referred to in this Agreement as "Marital Property", as between themselves, their heirs and
assigns. The parties have attempted to divide their Marital Property in a manner that conforms to
a just and fair standard, with due regard to the rights of each party. The division of existing
Marital Property is not intended by the parties to constitute ha any way a sale or exchange of
assets, and the division is being effected without the introduction of outside funds or other
property not constituting a part of the marital estate.
It is the further purpose of this Agreement to settle forew~r and completely any obligation
under the Pennsylvania Divorce Code relating to spousal_ support or alimony.
o
EaCh party represents and warrants that he or she has made a full and fair disclosure to the
other of all of his or her property interests of any nature, inclmting any mortgage, pledge,' lien,
charge, security interest, encumbrance, or restriction to which any property is subject. Each
party further represents that he or she has. made a full and fair disclosure of all debts and
obligations of any nature for which he or she is currently liable or may become liable. Each
further represents and warrants that he or she has not made any gifts or transfers for inadequate
consideration of Marital Property without the prior consent of the other.
Each Party acknowledges that, to the extent desired, he or she has had access to all joint
and separate State and Federal Tax Returns filed by or on behalf of either or both Parties during
marriage.
REAL ESTATE: WIFE agrees to transfer all right, title and interest which she may
have in that marital property located at 243 South Hanover Street, Carlisle, Cumberland County,
Pennsylvania, and any improvements thereon to HUSBAND .and releases all claims which she
may have regarding said real estate in accordance with this paragraph. HUSBAND agrees to pay
any outstanding payments on any mortgages on said property, as well as all real estate taxes,
insurance, and any maintenance and repair costs, and hold WIFE harmless fi.om any obligations
on said payments and indemnify him if any claim is made against him.
PERSONAL PROPERTY: The parties agree that the personal property has been
divided to the parties' mutual satisfaction. ~FE hereby waives all fight, title and interest which
she may have in any personal property of the HUSBAND. HUSBAND likewise waives any
right, title and interest which he has in the personal property of WIFE. Henceforth, each of the
parties shall own, have and enjoy independently of any claim or right of the other party, all items
of personal property of every kind, nature and description and wherever situated, which are then
owned or held by or which may hereafter belong to HUSBAND or WIFE with full power to
HUSBAND or WIFE to dispose of the same as fully and effectually, in all respects and. for all
purposes as if he or she were unmarried.
AUTOMOBILES: WIFE hereby waives all right, title and interest in any vehicle that
HUSBAND eun'ently owns or may own in the future, and agrees to execute all documents
necessary to transfer title of any jointly titled vehicles that HUSBAND may own within thirty
(30) days of this Agreement. HUSBAND shall hold WIFE harmless for any and all liability
associated with the use and purchase of any vehicle he may own, and shall be solely responsible
for all insurance and other financial responsibility associated with said vehicle. HUSBAND
hereby waives all right, title and interest in any vehicle that WIFE currently owns or may own in
the future, and agrees to execute all documents necessary to transfer title of any jointly titled
vehicles that WIFE may own. WIFE shall hold HUSBAND harmless for any and all liability
associated with the use and purchase of any vehicle she may own, and shall be solely responsible
for all insurance and other financial responsibility associated with said vehicle.
10.
MARITAL DEBTS: It is mutually agreed by and between the parties that WIFE shall
assume all liability for and pay and indemnify the HUSBAND against all debts incurred by
WIFE after the date of separation. WIFE represents and warrants to HUSBAND that since the
parties' marital separation she has n6t contracted or incurred any debt or liability for which
HUSBAND or his estate might be responsible and WIFE ftuther represents and warrants to
HUSBAND that she will not contract or incur any debt or liability after the execution of this
Agreement, for which HUSBAND or his estate might be responsible. WIFE shall indemnify
and save HUSBAND harmless fi.om any and all claims or demands made against him by reason
of debts or obligatiOns incurred by her.
HUSBAND shall assume all liability for and pay and indemnify the WIFE
against all debts incurred by HUSBAND after the date of separation. HUSBAND represents and
wan'ants to WIFE that since the parties' marital separation he has not contracted or incurred any
debt or liability for which WIFE or her estate might be responsible and HUSBAND further
represents and warrants to WIFE that he will not contract or incur any debt or liability after the
execution of this Agreement, for which WIFE or her estate might be responsible. HUSBAND
shall indemnify and save WIFE harmless fi.om any and all claims or demands made against her
by reason of debts or obligations incun'ed by him.
6
11.
.INSURANCE and EMPLOYEE BENEFIT8 Both parties agree to waive any right,
title or interest in the other's employee benefit, retirement fund, pension fund or other benefit
that either party may have. Both parties agree to execute any ,document necessary to effectuate
this waiver of interest.
12.
STOCK AND BANK ACCOUNTS WIFE agrees to waive all right, title and interest
which she may have in any other savings or checking or any other bank accounts of HusBAND
and likewise HUSBAND agrees to waive all right, title and interest which he may have in the
savings or checking or any other bank accounts of WIFE.
13.
ALIMONY and DIVORCE The parties both agree to cooperate with each other in
obtaining a final divorce of the marriage. Any party who fails 1~o cooperate with obtaining the
Divorce shall pay all the costs and legal fees of the party who is seeking the divorce.
The parties both agree to waive all rights to alimony, alimony pendente lite, spousal
support, or any other support for the person.
14.
BREACH: If either party breaches any provisions o:f this Agreement, the other party
shall have the right, at his or her election, to sue for damages fbr such breach or seek such other
remedies or relief as may be available to him or her, and the party breaching this contract shall be
responsible for payment of legal fees and costs incurred by the other in enforcing their rights
under this Agreement.
15.
ADDITIONAL INSTRUMENTS: Each of the parties shall from 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 the provisions of this
Agreement.
16.
VOLUNTARY EXECUTION: The provisions of this Agreement and their legal effect
have been fully explained to the parties by their respective counsel, are fully understood by both
parties, and each party acknowledges that the Agreement is fair and equitable, that it is being
entered into voluntarily, and that it is not the result of any duress or undue influence. It is the
parties' intent that this Agreement does not merge with the D:ivoree Decree, but rather shall
continue to have independent contractual significance. Each party maintains his or her
contractual remedies or any other remedies provided by law or statute. Those remedies shall
include, but not be limited to, damages resulting fi.om breach of this Agreement, specific
enforcement of this Agreement and remedies pertaining to failt~re to comply with an order of
court or agreement pertaining to equitable distribution, alimony, .alimony pendente lite, counsel
fees and costs as set forth in the Pennsylvania Divorce Code, or other similar statutes now in
effect and as amended or hereafter enacted.
17.
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.
..APPLICABLE LAW: This Agreement shall be construed under the Laws of the
Commonwealth of Pennsylvania.
19.
PRIOR AGREEMENTS: It is understood and agreed that any and all property
settlement agreements which may or have been executed pric.r to the date and time of this
Agreement are null and void and of no effect.
20.
WAIVER OF CLAIMS AGAINST ESTATES: Except as herein otherwise provided,
each party may dispose of his or her property in any way, and each party hereby waives and
relinquishes any and all rights he or she may now have or hereafter acquire, under the present or
future laws of any jurisdiction, to share in the property or the estate of the other as a result of the
marital relationship, including without limitation, dower, courtesy, statutory allowance, widow's
allowance, right to take in intestacy, right to take against the Will of the other, and right to act as
administrator or executor of the other's estate, and each will, at the request of the other, execute,
acknowledge and deliver any and all instruments which may be necessary or advisable to carry
into effect this mutual waiver and relinquishment of all such interests, rights and claims.
IN WITNESS WHEREOF, the parties hereunto have set their hands and seals the day
and year first above written.
WITNESSES:
~EAL)~ STACI A. STEEVER
JONATHAN A. STEEVER
(SEAL)
lO
COMMONWEALTH OF PENNSYLVANIA
: SS:
COUNTY OF CUMBERLAND :
PERSONALLY APPEARED BEFORE ME, this./~'~day of~~ ,
2003, a Notary Public, in and for the Commonwealth of Pennsylvania and County of
Cumberland, STACI A. STEEVER, known to me (or satisfactorily proven) to be the person
whose name is subscribed to the within Marriage Settlement Agreement, and acknowledges that
she executed the same for the purposes therein contained.
- IN WITNESS WHEREOF, I have hereunto set my hand'X-4nd OffiCial seal~
/' V.' ' ' i ' I./ ea,
~' V ] Jacqu'Eline L Drawbaugh No Pubhc
COMMONWEALTH OF PENNSYLVAN~ X, : I Carlisle ~oro Cnm~i'i-., ~ta~_ _ '
· hu~u ~OUlln'y
[ · ~_. ~ My Commission Expiras Aug. 14, 2003
· 58.
COUNTY OF CUMBERLAND : Member, PennsylvanlaAssoclatlonofNota~s
PERSONALLY APPEARED BEFORE ME, this ~day of ,]~.~~ ,
2003, a Notary Public, in and for the Commonwealth of Pennsylvania and County of
Cumberland, JONATHAN A. STEEVER, known to me (or satisfactorily proven) to be the
person whose name is subscribed to the within Marriage Settlement Agreement, and
acknowledges that he executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I have hereunt(
Notarial Seal
Jacqueline L. Drawbaugh, Notary Public
Carlisle Boro, Cumberland County
My Commission Expires Aug. 14, 2003
Member, Pennsylvania Association ot Notaries
11
JONATHAN A. STEEVER,
Plaintiff,
Ve
STACI A. STEEVER,
Defendant.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: CIVIL ACTION - LAW
: 2002 - 3491 CIVIL TERM
: IN DIVORCE
AFFIDAVIT OF SERVICE OF COMPLAINT
COMMONWEALTH OF PENNSYLVANIA :
: SS:
COUNTY OF CUMBERLAND :
NOW, Rebecca R. Hughes, Esquire, being duly swom according to law, does depose and
state:
1. That she is a competent adult and attomey for the Plaintiff in the captioned action.
That a certified copy of the Complaint was served upon the Defendant, Staci A.
Steever on July 25, 2002 by certified mail, return receipt requested, addressed to 779
Hamilton Court, Carlisle, Pennsylvania 17013, with return receipt number 7001
2510 0009 2828 4838.
That the said receipt for certified mail is signed and attached hereto and made a part
hereof.
I verify that the statements made in this affidavit are tree and con'ect. I understand that false
statements herein made are subject to the penalties of 18 Pa.C.S. Section 4904, relating to unswom
falsification to authorities.
IRWIN, McKNIGHT & HUGHES
Rcbe-~a R. Hugh~s, E~uire(~
Supreme Court Id # 67212
60 West Pomfi~et Street
Carlisle, PA 17013
(717) 249-2353
Attorney for Plaintiff
Jonathan A. Steever
· Complete items 1, 2, and 3. Also complete
item 4 if Restricted Delivery is desired.
Pri.n.t y.our~ame and address on the reverse
so that ~ can return the card to you.
~A.tt_a_ch.~t~t~s card...to the back of the mallpiece,
u, u~ tr[le ri'on! n space permits.
1. Article Addressed to:
STACI A STKEFI~
779 HAMILTON COURT
CARLISLE PA 17013
[] Agent
Is deliver item 17 I'lyes
If YES, enter delivery address below: I-I No I
3. Service Type
~ Certified Mail [] Express Mail
Registered ~]~ Return Receipt for Merchandise
2. Article Number 7001 2510 0009 2828 4838
(Transfer from service label)
PS Form 3811, March 2001 Domestic Return Receipt
102595-01~M-1424
Postage
Certified Fee
Return Receipt Fee
(Endorsement Required)
Restricted Deliver~ Fee
(Endorsement Required)
Total Poetage & Fees
Sent To
Po.,;tmark
Here
.... .S. TACI A STEERER
s~;~'~; ~'~'. '~.'; ...........................................................................
or ~ ~MILTON COURT
JONATHAN A. STEEVER,
Plaintiff,
V.
STACI A. STEEVER,
Defendant.
IN ~ COURT OF COMMON PLEAS OF
CUMBERLAND, COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
2002 - 3491 CIVIL TERM
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301(c) OF THE DIVORCE CODE
1. I consent to the entry of a final Decree of Divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorc, e decree is entered by the Court
and that a copy of the decree will be sent to me immediately aft:er it is filed with the
Prothonotary.
I verify that the statements made in this affidavit are tree and correct. I understand that
false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
Date: T, / Iq ,2003
JONATHAN A. STEEVER, Plaintiff
JONATHAN A. STEEVER,
Plaintiff,
STACI A. STEEVER,
Defendant.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: 2002 - 3491 CIVIL TERM
: 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 fmal Decree of Divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by the Court
and that a copy of the decree will be sent to me immediately after it is filed with the
Prothonotary.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
Date: --~- i § '-O..} ,2003
~'"TAC-I ~. gTE~-'~R,~)efe-ndan~ ~
JONATHAN A. SIEEVER,
Plaintiff,
V.
STACI A. STEEVER,
Defendant.
: IN TIlE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: CIVIL ACTION - LAW
: 2002 - 3491 CIVIL TERM
: IN DIVORCE
DEFENDANT'S AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on July
23, 2002.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have
elapsed from the date of the filing of the complaint.
3. I consent to the entry of a final decree in divorce.
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 made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to
unsworn falsification to authorities.
Date:
,2003
STACI A. STEEVER
JONATHAN A. STEEVER,
: IN THE COURT OF COMMON PLEAS OF
STACI A. STEEVER,
Plaintiff,
Defendant.
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: 2002 - 3491 CIVIL TERM
: IN DIVORCE
PLAINTIFF'S AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on July
23, 2002.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have
elapsed fi.om the date of the filing of the complaint.
3. I consent to the entry of a final decree in 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 tree and correct. I understand that
false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to
unsworn falsification to authorities.
Date: .>/19 ,2003
JONATHAN A. STEEVER
JONATHAN A. SIEEVER,
Plaintiff,
V.
STACI A. STEEVER,
Defendant.
: IN ~ COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: CIVIL ACTION - LAW
: 2002 - 3491 CIVIL TERM
: IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the following information, to the court for entry of a
divorce decree:
1. Ground for Divorce: irretrievable breakdown under Section 3301(c) of the Divorce
Code.
2. Date and manner of service of complaint: A certified copy of the Complaint in
Divorce was served upon the defendant, Staci A. Steever by certified mail, restricted delivery, on
or about July 25, 2002. The Affidavit of Service was filed with. the Prothontoary on or about
March 19, 2003, 2003.
3. Complete' either paragraph (a) or (b).
(a) Date of execution of the affidavit of consent required by Section 3301(c)
of the Divorce Code: by plaintiff.' March 19,2003; by defendant: March 19, 2003.
(b)(1) Date of execution of the affidavit required by Section 3301 (d) of the
Divorce Code:
(b)(2) Date of filing and service of the plaintitTs affidavit upon the defendant:
4. Related claims pending: NONE.
5. Complete either (a) or (b).
(a) Date and manner of service of the Notice of Intention to file Praeeipe to
Transmit Record, a copy of which is attached:
(b) Date plaintiffs Waiver of Notice in Section 3301(c) Divorce was filed
with the Prothonotary: March 19, 2003.
Date defendant's Waiver of Notice in Section 3301 (c) Divorce was filed
with the Prothonotary: March 19, 2003.
Date: March 19, 2003
Rebecca R. Hughes, Est
Attorney for Defendant
IN THE COURT OF COMiVION PLEAS
OF CUMBERLAND COUNTY
STATE Of ~~~ PENNA.
~ ~'r~
JONATHAN A. STEEVER,
Plaintiff
VERSUS
Defendant
STACI A.
NO. 2002-3491
Decree IN
DIVORCE
AND NOW,
/~~ ~ ~ ' , ~ , It IS ORDERED AND
DECREED That
Jonathan A. Steever
, PLAINTIFF,
AND Staci A. Steerer
, DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
THE COURT RETAINS JURISDICTION Of THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED Of RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED;
The ~arria§e Settlement Agreement dated ~arch 19, 2003, and signed by
the parties is hereby incorporated into this Decree but not merged.
BY THE COURT: /
ATT E ST/ -- J.
PROTHONOTARY