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Home My WebLink About94-05450 I !. j ", 1 ! , \ ~ IV -:r- E ;' . IIJ 7 " If) ~ [ J J s:? -::t Ln , 5-/ <~;'_::~;:_.~:~;~~.::~;:_,-:~' ';4 iX I~ I:' /~ *.~,~.~*~*~~..~.~.*.~.~..~.~..~.~..~..:~. .:.;. -:.;', .:.;. ,;.;. ~, -~~-_..-- ,."_.~-,.~.-..",, ,.-....,-_....-,.. ~ ~ ~ ., ~ ~ ~ ~ ., ~ ~ ~ ~ ~ ~ ~I ~I ~I 7'_ __, '~;. .~:. .:. ~. ~ ~ ~, , , ~) '.1 ,',) 1.1 , i ,,; . \ ~! "', :1 ~i ~I ~I ".1 ", .:.1 ~l ~I ~ " ~I :/ ~': " ,I ,,) : I ~l ~ .. ~ ~ ., ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND STATE OF ?.~~. \.~~~~ COUNTY PENNA. ALLISON L. MYERS Plaintiff l\: I) ..94"5450"1994,,,,....,..,. I I) Vt'I","Il.'i DONALD K. MYERS Defendant DECREE IN DIVORCE -, AND NOW, . , , .. .. . . . . r:j.~,,, i. .. . A, , .. '. 19,9,5.,... it is ordered and decreed that .,. ?-.1l,i,s.on, '~" .M.Y.~r:~ . , . . . . . , . . . . . , . . . . . . . . . .. . . . '. plaintiff, and.".... "'" ,Donald.K, ,Myers"." ,...,.,...,..,..., ....... defendant, are divorced from the bonds of mutrimony. 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: AND IT IS FURTHER ORDERED, ADJUDGED AND DECREED, that the terms, provisions and condltlons,Of,p,cartaln, property sett~ement ~gr.egment .between.the.parties.dated and attached hereto, and hereby incorporated in this Decree and Order by reference' '6S' fully' as' though the same were set 'forth 'herein 'at 'length. "Said agreement shall not merge with, but shall survive this Decree and Order. /Iv 1j;1hC,"7uurt ~ ,/ 0' /1.A1-- Attest: "'"/ ~ ,1' 1,_/< _ J. . .~,3: J~ 'fC.' OJ /uv.:i1./ .:?;;0,u'~ /i / X<,/;"'''--) It L, -':-:.e'/t. ..l-JiJ. ,,{/" ~ Prbthol1olary :~ -:t;. .:.;. .;.:- .:.;. .:.;. .:+:. -:.:- .:.:. .:+;. <eo> -:.;. .;.;. .:.;. .:.;. .;.:. -:.;. ~ ~ ., x .' ~ ,;, " ,;, " ,;, " ~ ., ~ M .' ~ ~ ~ i, ~ ,;, " ~ !~ i~ ~ ~ ., ~ ~ ~ (~ ('"0 ~~ (' \~ i: ~ s ~ ~ ,* ~ ~ :~ ,~ -I' 195 c:d {t7-'l />.J>hd/ ;(. .J'f '&/"'" ~ .1;/7//1' >;;.ft::,l /)"j// ~ <eif /:/...fr<< \'1 NOW THEREFORE, in consideration, of these premises and of the mutual promises, covenants and undertakings hereinafter set forth and for other good and valuable consideration, receipt of whlch is hereby acknowledg~d by each of the parties hereto, Husband and Wife, each intending to be legally bound hereby, covenant and agree as follows: 1. AGREEMENT NOT PREDICATED UPON DIVORCE It is specifically understood by and between the parties hereto, and each of the said parties does hereby warrant and represent to the other, that the execution and delivery of this agreement is not predicated upon, nor made subject to any agreement for the institution, prosecutivn, defense or for the non-prosecution or nondefense of any action for divorce; provided, however, that nothing contained in this agreement shall prevent or preclude either of the parties hereto from commencing, instituting or prosecuting any action or actions for divorce, either absolute or otherwise, upon just legal and proper grounds, nor to prevent either party from defending any such action which may. has been, or shall be instituted by the other party or from making any just or proper defense thereto. 2. PERSONA~ RIGHTS Husband and Wife may and shall, at all times hereafter, live separate and apart. Each shall be free from all control, restraint, interference or authority, direct or indirect, by the other 1n all respects as fully as if he or she were unmarried. Ea(:tl may reSIde at sue}l place or places as he or she may select. -~- Each may, fo. his 0. he. sepa.ate use 0. benefit, conduct, carry on and engage in any business, occupation. profession or employment which to him or he. may seem advisable. This provislon shall not be taken, however, to be an admission on the part of eithe. Husband 0. Wife of the lawfulness of the causes which led to, or resulted in, the continuation of their living apart. Husband and Wife shall not molest, harass, disturb, malign each other or make derogatory statements about the respective families of each other, nor compel 0. attempt to compel the other to cohabit or dwell by any means or in any manner whatsoever with him or her. 3 . IlEtlI.<;r.tES Husband and Wife agree that Wife, is and shall remain, the sole owner of the 1978 Coneko Mobile Home situate at 17 Lois Lane, Mechanicsbu.g, PA 17055. 4. rERSQNl\kupROPERTX Husband and Wife do hereby acknowledge that they have heretofore divided the marital personal property including, but without limitation, jewelry, bank accounts, clothes, furniture, household furnishings and other personalty, and further, mutually agree that all such personal property in the possession of Wife shall be the sole and separate property of Wife and that all such personal property in the possession of Husband shall be the sole and separate property of Husband. Husband and Wife mutually waive, release, renounce, quitclaim and fo.eve. abandon whatever claims. if any, he or she may have with respect to any of the -3- above items which are the sole and separate property of each other. 5. SEPAllATe: PROPERTY Each party shall retain. have and enjoy, independently of any claim. right or demand of the other party. all property of every k1nJ. nature and description and wherever situated which 1S now owned or held or is hereafter acquired by him or her, or stands in his or her name. 6. ~rOU~ft(,..RUfPQrrl' M/!lilI..JMOJ'!Y Husband agrees to pay to Wife the sum of Twenty Dollars ($20.00) per month as spousal support, and further agrees to the entry of an order by the Domestic Relations Section of the cumberland County Court of Common pleas in the agreed amount, to be enforced by income attachment as provided by Law. Upon the entry of a Final Decree in Divorce, Husband agrees to continue the payment of Twenty Dollars ($20.00) per month to Wife as permanent alimony, to be enforced through appropriate Orders of the Domestic Relations Section of the cumberland County Court of Common Pleas. The alimony payment herein provided shall terminate upon the death of either Husband or Wife. or the remarriage of Wife. 7 . I..IAB t (. J.TIES Husband agrees to repay one-half the total indebted~ess to Glenn and Lois Jourdan on a loan secured by the 1978 Coneko Mobile Home. at the rate of Thlrty-seven Dollars ($37,00) per month. -4- 8. I..EGAL FEES AND EXPENSES Husband and W de hereby lOut ua II y agree to wa i ve any right to alimony pendente lite, expenses, cost::; of litigation, and each party agrees to be solely responsible for hls or her own legal fees and expenses. 9. NO BAR TO FURTHER PROCEEDINGS This agreement shall not be considered to affect or bar the right of Wife or Husband to a limited or absolute divorce on lawful grounds if such grounds now exist or snail hereafter exist or to such defense as may be available. Husband and Wife mutually understand that Wife has commenced action in divorce and for uther relief filed in the Court of Common pleas of cumberland County, Pennsylvania to No. 94-5450, and that Husband has not filed an Answer thereto denying the relief ~equested in Wife's Complaint. Husband and Wife agree that a copy of this Agreement may be filed with the Court as resolving and settling issues of Equitable Distribution, Alimony and Alimony Pendente Lite, Attorney's Fee::;, Costs and Expenses, contained in Plaintiff's Complaint. Husband agrees to execute and deliver to Wife's lttorney the necessary affidavits and/or consent forms to enable Wrfe to obtain a decree in divorce pursuant to the provlsions contained in Section 3301 lc) of the Pennsylvania Divorce Code. It 1S agreed that th1S Agreement shall not be impaired by any such divorce decree which may be granted and that this Agreement shall be 1ncorporated into any divorce decree which may be -5- granted. but shall not be deemed to be a condonation on the part of any party hereto of any actions on the part of the other party which have occasioned the disputes or unh~ppy differences which have occurred prior to or which may occur subsequent to the date hereof. 10. MUTUAL RELEASE Husband and Wife each do hereby mutually remise, release, quitclaim and forever discharge the other and the estate of such other, for all time to come, and for all purposes whatsoever, and from any and all rights, titles and interests or claims in or against the property (including income and gain from property hereafter accruing) of the other or against the estate of such other or any part thereof, whether arising out of any former acts, contracts, engagements or liabilities of such other or by way of dower or curtesy, or claims in the nature of dower or curtesy or widow's or widower's rights, family exemption or similar allowance, or under the intestate laws, or the right to take against the spouse's Will; or the right to treat a lifetime conveyance by the other as testamentary, or all other rights of a surviving spouse to participate in a deceased spouse's estate, whether arising from the laws of (a) Pennsylvania, (b) any state, Commonwealth or Territor'y of the United states, or (c) any other country. It is the intention of Husband and Wife to give to each other, by the execution of the Agreement, a full, complete and general release with respect to any and all property of any kind -6- or nature, real, personal or m1xed, which the other QOW owns or may hereafter acquire. except, and only except, all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any thereof, subject, however, to the implementation and satisfaction of any conditions precedent set forth herein. 11. Q'l'HJ;:R DOCUMENTATION Husband and Wife covenant and agree that they will forthwith execute any and all written instruments, assignments, releases, satisfactions, deeds, notes or such other writings as may be necessary or desirable for the proper effectuation of this Agreement, and as their respective counsel shall mutually agree should be so executed in order to carry out fully and effectively the terms of this Agreement. 12 . .QJJQgK~.QQR'_!LI{ I Q!!T_L1HU>J, H\J;1 I LIT I ES This Agreement shall, except as otherwise provided herein, be binding upon and inure to the benefit of the parties hereto, their respective heirs, executors, administrators, successors or assigns. 13. f;N'l'JJiJ;;_J\CmgE:M,E_NT Husband and Wife do hereby covenant and warrant that this Agreement contains all of the representations, promises and agreements made by either of them to the other for the purposes set forth 1n the preamble hereinabove; that there are no claims, promises or representations not herein contained, either oral or -7- written, which shall or may be charged or enforced or enforceable unless reduced to writing and signed by both of the parties hereto; and the waiver of any term, condition, clause or provision of this Agreement shall in no way be deemed to be considered a waiver of any other terms, conditions, clauses or provisions of this Agreement. 14. ~lNDlNG EFFECT OF AGREEMENT This Agreement shall remain in full force and effect unless and until terminated under and pursuant to the terms of this Agreement. The failur~ of Bither party to insist upon strict performance of any of the provisions of this Agreement shall not be construed aB a waiver of any subsequent default of the same or similar nature. 15. SEPARABl4IT~ If any term, condition, clause or provision of this Agreement shall be determined or declared to be void or invalid at law or otherwise, then only that term, condition, clause or provision shall be stricken from this Agreement and in all other respects this Agreement shall be valid and continue in full force, effect and operation. Likewise. the failure of any party to meet his or her obligations under anyone or more of the paragraphs herein, with the execeptlon of the satisfaction of the conditions precedent, shall in no way avoid or alter the remaining obligations of the parties. - 8 - 16. HEAl)J,tl,Q? Any headings preceding the texts of the several paragraphs and subparagraphs hereof 1re inserted solely for the convenience of reference and ~h~li not constitute a ~art ot this Agrc~mcnt nor shall they effect Its meaning, construction or effect. 17. ~F.i'~.~T I V]';. ll}\1'E The effective da\0 01 this Agreement ~hall ba the date upon which it IS executed. 18. CON~ROLLINO LAW This Agreement shall be construed in accordance with the laws of the Commonw>nlLh of Pennsylvania. IN WITNESS WHEREOF, the parties hereto have set their hands and seals the date and year first above written. WITNESS: - -_.~. ( '~'-;> --- /C7.A ./ ,__:.~~ -- ~r?~ ~'8-I~ ALLISON L. MYERS D.n1IAv L/ 9<. 111 ~ ""'Q... DONALD K. MYERS -9- COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND On this, the /'JI day of )}( a. L . , ,'--" , 1995, before me, the underslgned, personally appeared ALLISON L. MYERS, known to me (or satisfactorily proven) to be the person whose name is subscribed to the wlthln lnstrument, 3nd acknowledged that she executed same for the purposes thereln contained. IN WITNESS WHEREOF, I hereunto set my name and official seal. ., ? l(}<l 0._ . -!/ Nota y Public ./ -/ -' ,{ '0 '1 , ~ COMMONWEALTH OF PENNSYLVANIA N()l:1r~'".I ~.,ml ShnHnH It" ,r, ~:""l\I P11N1o jl.f"'''',~ ' ", 1\m, \ ;\l.... ,t ~If",..{f(~m r' .. ...,,' ,~..\:',.jitl''' 1'1..1\11& ss. COUNTY OF CUMBERLAND <..-.... , ~_ ~~ c:::---- On this, the d,:~ .,Co'-d3Y of \-"\:-,\',.Jlc,~~,A, , 1995, . ...) before me, the undersigned, personally appeared DONALD K. MYERS, known to me (or satlsfactorlly proven) t~ be the person whose name is subscribed to the within instrument, and acknowledged that he executed same for the purposes thereln contained. IN WITNESS WHEREGF'. i heroi!unto set my name and officlal seal. ~L~~ '~. ~N\~\/t:;:'--. Notary PlIhli c._.. \ l tL'3rol5oal Dp~y,..,;1-J E kQoJy. f'.:,' I'Y Pl..IJIC '. r', . "-r):'lr~rQ.P(;' ' "N L,", ',_",':,nbplo~~ ,,_ '.._ "-,(J7 -... ~ -10- ..r> en " ~ c.,_ -, 'J -:'J \",..1 , ,..j :'1~ ..: H :<: CIl=2 0 ..:~ ... I' W-, ;.0: 0 -'''' w .... I' Q.,U'l ffi 0: z t.J < zz w J f;j ow '" C) ~ .. N ~Q., " 0 '" ci ~ ..: ~ e III ~ .. Z 0 . .... ... '" . u i:~::.: .... <: :;j N > Q j ~ CIl.... <11 '" ~ ~ '" :.'.0\..-( '" ... CIl'1:l .... Z ~ a: 0 =:J"'~ W <: '" <: ... .... ~ W ~ 0- I <:: .... w OJ Q., 0: 0 .. m ~ ... U I ;.0: ,. <11 <::.... ;:> t.J 5 ~ :f - '" 00 H CIl ~ OJ :? III ... :J ;:> ,,"'.... w . Q., ;:. " 0 ~~t; u -' ,.; ... .J U u '" CIl -< ~ -' I < 0 Z 0 w "'~ ;:. 0 " Q., '" w",-, .... CIl ';;j Z ... '" .... " .... .... :;.- -' ;.0: ;.0: !:3o_ '" ';;j 0 .... U:?U H " .., ~ - -- =-= "'- o o N ,."' '" ''-oJ CJ: ., :r= ALL 1 SON I.. MY ERS , Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA '/ '/ '-'1 ,',' I.'.,;.. I ~L f+-- NO. ' .," '---<--< VS. UONALU K. MYERS, Defendant CIVIL ACTION - LAW IN DIVORCE r:cIlcE '1'(: Ul'FI,:::, M:r> CL,\r~l 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 ur relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custudy 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 Court Administrator at: Cumberland County Courthouse 4th Floor Carlisle, PA 17013 (717) 240-6200 IF YOU DO ~OT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES DEFOrE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAP! ,\::'1 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 JFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GBT LEGAL HELP. Court AJmir\istr3tor Cumberland County courthouse 4th Floor Carlisle, PA 17013 (717) 240-6200 ALLISON L. MYERS plaintiff I I I I I I I IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. '1'/- J,-'/~-') C,,:.( -ri<~~ VS. DONALD K. MYERS Defendant CIVIL ACTION - LAW COMPLAINT COUNT ONE 1. The Plaintiff is ALLISON L. MYERS, an adult individual residing at 17 Lois Lane, Mechanicsburg, Cumberland county, pennsylvania 17055, since March, 1992. 2. The Defendant is DONALD K. MYERS, an adult individual residing at 17 Lois Lane, Mechanicsburg, Cumberland County, Pennsylvania 17055, since March, 1992. 3. The Plaintiff and Defendant have been bona fide residents of the Commonwealth of pennsylvania for a least six (6) months immediately prior to the filing of this Complaint, having residp.d in Pennsylvania since 1990. 4. The Plaintiff and Defendant were married on September S, 1990 in Mechanicsburg, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties. 6. The marriage between the Plaintiff and the Defendant is irretrievably broken. 7. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. WHEREFORE, Plaintiff requests your Honorable Court to enter a decree of divorce. COUNT TWO 6. Paragraphs one through seven hereinabove are restated and incorporated herein by reference thereto. 9. The Defendant has offered such indignities to the Plaintiff, the innocent and injured spouse, as to render her condition intolerable and life burdensome. WHEREFORE, plaintiff requests you Honorable Court to enter a decree of divorce. COUNT THREE 10. Paragraphs one through nine hereinabove are restated and incorporated herein by reference thereto. 11. Plaintiff and Defendant have acquired property during their marriage from September 6, 1990 to the date of their separation. 12. Plaintiff and Defendant have been unable to agree as to an equitable division of said property. WHEREFORE, plaintiff requests your HonQrable Court to equitably divide all marital property. COUNT FOUR 13. paragraphs one through twelve hereinabove are restated and incorporated herein by reference thereto. 14. Plaintiff laCKS sufficient property and/or income to provide for her reasonable needs and is unable to support herself through appropriate employment. -2- 15. Plaintiff requires reasonable support to adequatelY maintain herself in accordance with the standard of living established during the marriage. WHEREFORE Plaintiff requests your Honorable Court to enter an award of alimony in her favor. COUNT FIVE 16. Paragraphs one through fifteen hereinabove are restated and incorporated herein by reference thereto. 17. Plaintiff has employed counsel but is unable to pay the necessary and reasonable attorney's fees for said counsel. lB. Plaintiff is unable to sustain herself during the course of the litigation. WHEREFORE, Plaintiff requests your Honorable Court to enter an award of Alimony Pendente Lite, interim counsel fees, costs and expenses until final hearing and thereupon award such additional counsel fees, costs and expenses as deemed appropriate. ~~ ~. /'i'v.v.v ALLISON L. MYERS -3- " I verify that the statements In this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 10 PA. C.S. 14904, relating to unsworn falsification to authorities. Date: c:;.-'n/~~ .:'.,l...1..i.;V)-<J11..- 1 Jhltl/) ,',2/ (SEAL) Allison L. Myers ~,"'--::f ,,/7 /' // y~/) 5::::::: :/.:/-'(~~~~, Albert Z. Bogert,'Esquire Attorney for Plaintiff 317 Third Street New Cumberland, PA 17070 (717) 774-1972 - . -,,, . . . .. __"__ _ t , ' " '. , '" , I"~. " '- , . c_ , ,) ~ > , " ", 'J '" " " ,) .' ., , , , " ., ~ '", '.:) ,l '. ,}. ,'\ '. '\ ... ~ J ~J .~ ": 'l- 'I:) lJ '. , '" I I I ,,,- '~ , 'i~ , '.... '"' .". ''I ''\ !\,.~ ..... '" ... c" ,"" 1\ ..; ... '" '" < 0 ~ 0- ,.J S ,.J '" 1- 0.- '" " 2 ffi - % 7- '" ~ ~ ~ C '" U Cl N 2j 0.- 0:: c 0 ~ W ~ ~. 0 . ci ~ 0 . 0- m I- ~ Z u '" .... ... ... C ~ ... "'... " '" N ,. a :5 ~ ... % 0:: .... '" I1l '" $ 0: ~ 0 '" '" ... 0::"" Z 1- z 0 :r. " '" " H 0: ~ W ~ II: 0 ... u . .... (:: .. ~ ~ m ~ '" I1l . ~. ... H W _ :E . ::> '" . H '" .. ;.-. m ~ :J 0 7. ,.Jo.- ... .", H .J U u < ~ ..; ,.J :? ,.J c( ~ OJ '" 0 '" ~ '" OJ '" :;! ... '" H 0 Z :>: ,.J z u z '" ,.J 0 H U ..; '" SHERIFF'S RE'I'URN cct-lMONWf',AUIl1 OF PENNSYLVANIA. COUNI'Y OF CLMBERIAND In the Court of Common Pleas of Cumberland County, Pennsylvania No. 94-5450 Civil Term Complaint in Divorce and Notice to Defend and Claim Rights Allison L. Myers VS Donald K. Myers Harry Kina , lShex.kfi6<lDK Deputy Sheriff of Cunberland County, Pennsylvania, who being duly sworn according to law, says, that he served the within Complaint in Divorce and Notice to Defend and Claim Rights upon Donald K. Myers . , the defendant, at 7:35 0' clock A .M. ~1i'RxI EDST, on the 28th day of September , 19~-at Frv Communications - W. Church Rd., Mechanicsburg, Cunberland County, Pennsylvania, by handing to Donald K. Myers Complaint in Divorce and Notice to Defend a true and attested copy of the and Claim Riqhts and at the sarre time directing attention to the contents thereof and his the "Notice to Plead" endorsed thereon. Sheriff's Costs. Docketing Service Affidavit Surcharge So answers. . / .'::' , ..~. b-' ~;/. "r. " . (' //~--t? ..--~--;.. ';;"'-~;:;.A'>":':'~_'-::"~ /. .-~~- 1 ,.-.., R. Thanas Kline, Sheriff 14.00 5.60 2.00 21.60 Pd. by Atty. 9-28-94 by ~ ',- Sworn and subscril:,ed to before lID this /'1 f!- day of fl,-lll1~ 19_~ A.D. _ ':'c'f0=-O /ll,ih_ tJ'J,7, " . ProttlOnotary VS. IN THE COURT OF COMMON PLEAS I CUMBERLAND COUNTY, PENNSYLVANIA I I NO. 94-5450- 1994 I CIVIL ACTION - LAW IN DIVORCE ALLISON L. MYERS Plaintiff DONALD K. MYERS Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 23, 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 loose rights concerning division of marital property, alimony, alimony pendente lite, lawyer's fees or expenses if I do not claim them before a divorce is granted. 5. I have been advised of the availability of marriage counseling, and I understand that the Court maintains a list of marriage counselors and that I may request the Court require my spouse and I to participate in counseling and, being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to the entry of a final Decree of Divorce. 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. /1- Date: ~ /11'1 ~~,~ Allison L. Myers ---- ~, ALLISON L. MYERS plaintiff IN THE COURT OF COMMON PLEAS CUMBE\UJ\ND COUNTY, PENNSYLVANIA VS. NQ. 94-5450 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE DONALD K. MYERS Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under section 3301(c) of the Divorce Code w~s filed on September 23, 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 loose rights concerning division of marital property, alimony, alimony pendente lite, lawyer's fees or expenses if I do not claim them before a divorce is granted. 5. I have been advised of the availability of marriage counseling, and I understand that the Court maintains a list of marriage counRelors and that I may request the Court require my spouse and I to participate in counseling and, being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to the entry of a final Decree of Divorce. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~4904 relating to unsworn falsification to authorities. Date: :J/l./..~( rffNl/',tJ, k ~~".(~ Donald K. Myers un> GW'l\ -... " :s:: ~ <:> Q ('oJ ,--, ,.... = - '":! -- - .~. ~ -~~- . ' .-. ALLISON L. MYERS Plaintiff IN THE COURT OF COMMON PLE.\S CUMBERLAND COUNTY. PENNSYLVANIA VS. : NO. 94-5450 : : : 1. Plaintiff files the folLowing inventory of all property owned or possessed by either party at the time this action was commenced and all property transferred within the preceding three years. DONALD K. MYERS Defendant CIVIL ACTION - LAW IN DIVORCE 2. Plaintiff verifies that the statements made in this inventory are true and correct. Plaintiff understands that false statements herein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 3. Plaintiff identifies the following assets as applicable to the case at bar. INVENTORY OF ALLISON L. MYERS, PLAINTIFF 1. Real Property: 2. Motor Vehicles: 1978 Coneko Mobile Home 3. Stocks, bonds and securities: 4. Certificates of deposit: 5. Checking Account: Commerce Bank - Checking Account Mellon Bank - Checking Account - Account closed 9-94 - held joint with father, Glenn L. Jourdan 6. Savings account, money ma::-ket and savings certificates: 7. Contents of safe deposit boxes: 8. Trusts: 9. Life insurance policies: 10. Annuities: 11. Gifts: 12. Inheritances: 13. Patents, copyrights. inventions, royalties: 14. Personal property outside the home: 15. Business: 16. Employment termination benefits - severance pay worker's compensation Claim/award: 17. Profit sharing plans: 18. Pension plans: 19. Retirement plans, Individual Retirement Accounts: None $8,000.00 None None $ 198.00 None None None None None None None None None None None None None None 20. Disability payments Social Security Disability Benefits: Food Stamps: 21. Litigation claims: 22. Military/V.A. benefits: 23. Education benefits: 24. Debts due, inclUding loans, mortgages held: 25. Household furnishings and personalty - Basic wardrobe and basic household furniture and furnishings: 26 , Other: $ 498.00 per month $ 112.00 per month None None None None $ 500.00 None MARITAL PROPERTY Plaintiff lists all marital property in which either or both spouses have a legal or equitable interest individually or with any other person as of the date this action was commenced: Item Number Property Description owners 25 Household furniture and furnishings Husband and Wife NON-MARITAL PROPERTY Item Number Property Description owners 2 5 20 Mobile home Commerce Bank Checking Account Social Security Benefits Wife Wife Wife PROPERTY TRANSFERRED NONE LIABILITIES Item Number Property Description Creditors Debtors 2 Mobile home Glenn & Lois Jourdan Husband and Wife Balance due on loan from creditors is $10,000.00 which is secured by lien on title to mobile home. -2- ... VERIFICATION I, Allison L. Myers, verify that the statements made in this Inventory and Appraisement are true and correct upon my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 10 PA. C.S. 14904, relating to unsworn falsification to authorities. Date: I:~ / t; / ';/../ mi",~<J7,- i .,; (vIJ)jAV (SEAL) Allison L. Myers --,., ':> , ~, "C-. /~, _ C ______ /' -- G -,:;:------ Albert Z. Bogert, Esquire Attorney for Plaintiff 317 Third Street New Cumberland, PA 17070 (717) 774-1972 < H '" Ul=i 0 <:- ... W", ... 0 ...;.- ... <l.Ul n: - z IJJ <C z '" ~ I;; 0 W Cl ~ .. N O'i <l. 0 ~ ci ~ ~ ~ -, m ~ ~ z 0 . :< "" ... ~ ~ ~ ui:; < .... " N > 0 :5 ~ ... Ul ..... " 0 ~ ~ ~ ""1< :>: .. "''tl ... Z It: 0:.> I W " :>: " ~: ... ~ j: W ~ 0 i::: ..... w " W n: 0 m ~ ...u ;r..o: ... " C"" ~ IJJ ~ t: ::E . '" 0 0 ..... '" ... " m < M :l :.J:::l "' H W p.. ::> '" H 0;'-: '" ... U ... ..J U U:': "' U '" :..: <( ~ ... I < 0 Z W~ '" :- 0 ~ :IlW "'... H '" Z ...'" H :::l H (. .:- ... z z ;.J OH '" ... 0 H U r:U H <: '" ~ , . , . : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 94-5450 : : CIVIL ACTION - < , ALLISON L. MYERS Plaintiff VS. DONALD K. MYERS INCOME AND EXPENSE STATEMENT OF ALLISON L. ~YERS INCOME: Plaintiff is receiving: Social Security Benefits: Food Stamps TOTAL INCOME EXPENSES: (Average Monthly) Lot Rent Maintenance on mobile home Electric Heat - propane gas Telephone Taxes Real Estate - per capita Insurance Home Loan Payment Food Clothing Taxi Fare TOTAL EXPENSES $498.00 per month $112.00 per month $610.00 per month $255.00 40.00 80.00 90.00 30.00 30.00 17.00 170.00 200.00 30.00 30.00 $972.00 tI'l -<. w H tI'l Z " .. U1 ~ W 0 <5 ;.. e, ... ... 0 ... ,.. [J ... ... p.. U1 n: - z el IJJ <C '" z ~ I;; 0 w =i Cl ~ .. N O'i O. 0 '" ci ~ ~ ~ ~ -, m ~ ~ z 0 . :. 'H ... < ~ ~ u i:: -<. "" " 0 N > 0 :5 ~ ... i2'~ '" u '" !!: ~ "" r: '11 'tJ '" z It: 0 ;.J I W ~ :>: ~ H ... ~ J: W ~ 0 to:: ..... W " n: ~ ~ m ~ ... U 0 '" -, " L-::t,.. "" IJJ ~ " . '" ," 0 ..... ~ ...~ Q,I 0 m < M :l '-' ~ -1 ..... ~l .p.. r:> 0 ," ... U ... . 8 ..J U u =i I U rG :..: <( ~ ... -t --:: 0 '" ~l '" '" ;.. 0 ::J ~ w '" w .-' H III Z ... l<\ H '" H .( ... ?~ . :..;.~ ... z <( " .-, G: H .. ... :3 ... .. .' H U U H .( U1 - - i -:r 1}.. () (Xl rl ~ 8 .:) .J r:-' ~t1 -jj:. rfJ ~ ~ -.l cJ In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION 13 N. HANOVER ST, P.O. BOX 320, CARLISLE, PA. 17013 Defendant Name: DONALD K. MYERS Member ID Number: 3015000032 Please note: All correspondence must include the Member ID Number. ORDER OF ATTACHMENT OF UNEMPLOYMENT COMPENSATION BENEFITS Plaintiff Name ALLISON L. JOURDAN Financial Break Down of Multiple Cases on Attachment PACSES Docket Case Number Number 376000064 94-5450 CIVIL Attachment Amount/Fr en 20.00 /..N1�Q}ITHrrt r /rn /PO GI /<c TOTAL. ATTACHMENT AMOUNT: $ 20.00 tom? N) Now, by Order of this Court, the Department of Labor and Industry, Office of Unemployment Compensation Benefits (OUCB), is hereby directed to attach the lesser of $ 4.60 per week, or 50%, of the Unemployment Compensation benefits otherwise payable to the Defendant, DONALD K. MYERS Social Security Number XXX -XX -5664, Member ID Number 3015000032. OUCB is ordered to remit the amount attached to the Department of Public Welfare (DPW). DPW shall forward the amount received from OUCB to the Domestic Relations Section of this Court for support and/or support arrearages. If the Defendant's Unemployment Compensation benefits are attached by another Court or Courts for support and/or support arrearages, DPW may reduce the amount attached under this Order so that the total amount attached does not exceed the maximum amount subject to garnishment pursuant to 15 U.S.C. § 1673 (b)(2) and 23 Pa. C.S.A. § 4348 (g). This Order shall be effective upon receipt of the notice of the Order by the OUCB and shall remain in effect until the Defendant's entitlement to Unemployment Compensation benefits, under the Application for Benefits dated AUGUST 10, 2014 is exhausted, expired or deferred. OUCB shall comply with this Order, unless it is amended or vacated by subsequent Order of this Court. All questions, challenges or obligations to this Order shall be directed to the Domestic Relations Section of this Court. Date of Order: AUG 2 6 201. Service Type M BY THE COURT Edward E. Guido , JUDGE Form EN -530 Worker ID $IATT