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HomeMy WebLinkAbout94-05511 I I \ . -7 \ ~ \ i j 'i / I ; { i ! , I . j ~ J - - to tn I -=t, o a-,/ ~ ~ Iii .' .. !' ~ ~ ~I . ~-~.~.*~-~_.~_.~.~~..~.~.~.~.~. ~ ~--~ -------- --, -- - .- ~ "-.. . - ~ ,. ,. . .:+: :. <+:. <<<- .:c- .:... .:c. .:c. .:c. .:co ... ~ ~- -;- . '-'-'~-'18 l~ l~ l!I ~ ~ ~ 8 8 ~ 8 ~ 8 8 8 M I~ ~ .. ~ IN THE COURT OF COMMON PLEAS M' ./ ~i '. ( wi M' .1 ./ liI' ~I ~l ~ .. ~ COUNTY OF CUMBERLAND STATE OF ~ PENNA. BEHNAOEITE CASSEL, Plalnt1ff, ;\; (). .94"S5.11ClvlLTerm. 1994 M ~l ~I ., :, ., I ~ ~ MI '1 ~l I . \\;I'.";ll'; ~ R:liSS CASSEL, Defendant. DECREE IN DIVORCE - AND NOW, . . . .m~ -T. .3 . . .... . .. . . . '. 19'(J.>... it is ordered and decreed that.. .B~r:na<1~ne. .<;"s1'a1........................... plaintiff. and .Ron"I\!. RoGS. CUl'l!.l.... ............................... defendant, are divorced from the bonds of matrimony. .', ~ ~ ~ ~ ~ ~ The court retains jurisdiction of the following claims which have been raised of record in this action for which a final order has not yet been entered; none. The Post Nuptial Agreemant of the Parties dated April 13, 1995 and attached herato as Exhibit oAo Is hel:eby. .I.ncorporated by reference .her.~ln. a.nd. s.hal1. .hav~. .t.i!. .1'.a."1e force and effect as If It had been originally entered as an Order oJ. .the. Court. .provlded, .bowever,.tbat. .tbe. .sald. .AgreemBnt. .shal.I.. not mer e with this Order but shall retain Its contractual valua. ~ ~ ~ !Iv The.UL;~ oL.!, ....tt..t: .I,'-6..':<.(U /.~).b' ~.~ ~ ~ ~-~ ......' ~(;'C"~.... .4<r-r~~,~ L'j .. ~~4;" " ./" ->2e:h ,/ .r'--' P I .-' /7~(...~ rollonotary ~ .~..*~.~.~..~..*.~._~..~~..~:.,~.~..~..~..~..~.~.~. 8 8 8 ~ !~ I~ I: '~ I~ L:. i~ )~ 1'.- I,;, I~ . l~ , . )~ I' ~ ~ I~ ~ ~ ~ ~ ~ ~ L I .5'.491' &e:f tf,/1;'~~ i7J ~-<... 5' . " . 7;- 71,-/ ' ,,1, + ~L/. r...-c~ M~ C# .~ ' . . .. .. . , .n II') > ~ ~ ...l . . 0.< ... .. ... 0. ... II ... i ",on ig - .. ... ~,t'. t"l t~ ... '0 ~ ... ~ ~~ - II . II - 0 - .- ...l II U :5~ ~; :- ...l .. . W... oe . = U::J - lol- .. VI II '" ~ M =-:~-r: 0 U VIa. :- VlQ ...l ... Q C( ... t'f <-- CIoU VI < oe ;j ;..~ai~ OQ - oe U .. - .... U ... ... Ul,,"l t~ ... VI 0. .. ~ ~~~ll ... lol VI :;) a. 8cl I t ~ z < .. ~ ~ - u UW ... ... ~~ ~ Q (I) .. ~ .~ ...l ~ '0 ' u... .. ~ < II "L- I-<U . ~ .. ': i lol ~ Z III .... . 1 ... ., . ).. ... ... ... .' '. 1 _,' . . .. , , ".\1<1 \1. 1111.111111\1 \ I, ,I, I I \" . . , . . . POST-NUPTIAL AGREEMENT AGDEMENT made this I~' day of lJr~ 0 , 1995, by and between RONALD ROSS CASSEL (hereina fter called "Husband") and BERNADETTE CASSEL (hereina fter called "Wife"). WIT N E SSE T HI WHEREAS, the Parties hereto are Husband and Wife, having been married on February 13, 1988, in Enola, Cumberland County, Pennsylvania. WHEREAS, the Parties are the parents of one child, Justin Robert Cassel born on March 20, 1988; WHEREAS, diverse and differences, disputes unhappy difficulties have arisen between the Parties and it is the intention of Husband and Wife to live separate and apart for the rest of their natural lives, and the Parties hereto are desirous of settling fully and finally the respective financial and property rights and obligations as between each other, including without limitation: 1. The settling of all matters between them relating to ownership and equi table dist r ibution of real and personal property; 2. The settling of all matters between them relating to past, present and future spousal support, alimony and/or maintenance of Husband by Wife or wife by Husband; . . . 3. The settling of all matters between them relating to custody of the child; and 4. In general, the settling of any and all claims and possible clainls by one against the other or against their respective estates. RON THEREFORE, in consideration of the premises and of the mutual promises, covenants and undertakings hereinafter set forth and for other good and valuable consideration, receipt of which is hereby acknowledged by each of the Parties hereto, Husband and Wife, each intending to be legally bound hereby, covenant and agree as follows: 1. EFFECT OF A DIVORCE DECREE: A decree in divorce, entered by a court of competent jurisdiction to either Party, shall not suspend, supersede or affect the terms of this Agreement. Both parties agree to enter a Consent Order or Orders concerning the provisions of this Agreement in the Court of Common pleas of Cumberland County, Pennsylvania, or any other court of competent jurisdiction, as a part of a resolution of any divorce action filed or to be filed. This Agreement, and the terms and conditions herein, as well as the enforcement of said terms and conditions, shall not be contingent upon the granting of a Divorce Decree to either Party by the Court of Common Pleas of Cumberland County, Pennsylvania, or any other court of competent jurisdiction. Furthermore, both Parties hsreto agree to timely execute the appropriate affidavits and consents to secure a No-Fault Divorce as may be required by the Divorce Code of 1980, as amended. . .. . -. . . . Husband and Wife acknowledge that Wife has instituted a No- Fault Divorce Action docketed No. 94-5511 Civil 1994 in the Court of Common Pleas of Cumberland County, Pennsylvania, pursuant to Section 3301 (c) of the Pennsylvania Divorce Code, Act 26 of 1980, as may be amended (hereinafter referred to as the "Code"). 2. AGREEMENT TO BE INCORPORATED INTO DIVORCE DECREE: The Parties agree that the terms of this Agreement shall be incorporated but not merged into any Divorce Decree which may be entered with respect to th~m except for any provisions contained herein regarding child support which shall merge with said Divorce Decree. 3. ADVICE OF COUNSEL: Wife has been independent.ly represented by Attorney Karl M. Ledebohm, and Husband, cognizant of his right to legal representation, and having had full opportunity to obtain legal counsel, declare that it is his express, voluntary and knowing intention not to avail himself of independent counsel and chooses instead to represent himself with respect to the preparation and execution of this Agreement. 4. WAIVER OF APPRAISAL: The Parties acknowledge and agree that they have each had an opportunity to value or have appraised any and all marital property, and they do hereby waive a formal appraisal and inventory of same, and no statement or representation by either party as to value shall be deemed a misstatement or misrepresentation to the other or be deemed fraudulent. 5. MUTUAL RELEASE: Husband and wife each do hereby mutually remise, release, quit claim, and forever discharge the other in the estate of such other, for all time to come, and for all purposes . . whatsoever, of and from any and all rights, titles and interests, or claims in or against the estate of such other, of whatever nature and whatsoever situate, which he or she now has or at any time hereafter may have against such other, 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 cutesy, or widows or widowers rights, family exemptions 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 spouss's estate, whether arising under the laws of Pennsylvania, any state, commonwealth or territory of the united States, or any other country, or any right which wife may have or at any time hereafter have for past, present or future support or maintenance, alimony, alimony pendente lite, counsel fees, costs or expenses, whether arising as a result of the marital relation or otherwise, except, and only except, all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement, the support order entered on March 7, 1995, to case number 1114 Support 1992, a copy of which is attached hereto and incorporated herein as Exhibit "CO or for the breach of any part thereof. It is the intention of Husband and Wife to give each other, by the execution of this Agreement, a full, complete and general release with respect to any and all property of any kind or nature, real, personal or mixed, which the other now owns or may hereafter acquire, except and only except all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or the above stated support order or for the breach of any provision thereof. 6. PENSIONS: Each Party shall retain as his or her own separate property any pension, stock, savings, retirement or other plan through his or her respective places of employment either vested or non-vested, and both Husband and wife specifically waive any right that either may have in the said pension, stock, savings, retirement or other plan of tha other that Husband and wife may have acquired thereto by their marriage to each other. Each Party shall be and remain the sole owner of any other asset in his or her control not specifically covered by this Agreement. 7. PERSONAL PROPERTY; Husband and wife do hereby acknowledge that they will divide the marital property as of the date of this Agreement, including, but without limitation, jewelry, clothes, furniture and other personalty and hereafter Husband agrees that all the property in the possession of wife on the dats of this Agreement, including any bank accounts in her name alone, shall be the sole, separate property of the Wife; and wife agrees that all of the property in the possession of the Husband on the date of this Agreement, including any bank accounts in his name only, shall be the sole, separate property of the Husband; irrespective of the foregoing provisions, Husband hereby agrees to set over, transfer and assign all of his right, title and interest to those personal effects and items of personalty that are more fully described in Schedule "A", which has been annexed hereto and made a part hereof and which shall become the sole property of Wife with the right to remove same from the marital premlses or from wherever located, and Wife hereby agrees to set over, transfer and assign all of her right, title and interest to those personal effects and items of personalty that are more fully described in Schedule "B", which has been annexed hereto and made a part hereof and which shall become the sole property of Husband. By these presents, each of the Parties does hereby sped f ically waive, release, renounce and forever abandon whatever claiMs he or she may havs with respect to any of the above-items which are the sole and Reparate property of the other from the date of execution hereof. 8. AFTER-ACOUIRED PERSONAL PROPERTY; Each of the Parties shall hereinafter own and enjoy, independently of any claim or right of the other, all items of personal property, tangible or intangible, acquired by him or her after the date of this Agreement, with full power in him or her to dispose of the same as fully and effectively, in all respects and for all purposes, as though he or she were unmarried. 9. LIABILITIES; During the course of the marriage, wife and Husband have incurred certain bills and obligations and have amassed a variety of debts, and it is hereby agreed, without the necessity of ascertaining for what purpose and to who's use each of the bills were incurred, that the parties shall be responsible for the debts that each has separately incurred prior to or after the date hereof, except that Husband agrees to assume and pay a loan in the amount of approximately $680.DO to Members First Federal Credit Union and to indemnify and hold Wife harmless for same. Husband and wife acknowledge that they owe a debt to the Internal Revenue Service in the total amount of approximately $4,710.81 plus interest and penalties for tax period ending December 31, 1992. Husband and Wife agree that each shall pay one-half (1/2) of the said IRS debt and Husband shall indemnify and hold wife harmless for Husband's one-half (1/2) share and Wife shall indemnify and hold Husband harmless for her one-half (l/2) share. 10. WARRANTY AS TO EXISTING OBLIGATIONS: Each Party represents that they have not heretofore incurred or contracted for any debt or liability or obligation for which the estate of the other Party may be responsible or liable except as may be provided for in this Agreement. Each Party agrees to indemnify or hold the other Party harmless from and against any and all such debts, liabilities or obligations of every kind which may have heretofore been incurred by them, including those for necessities, except for the obligations arising out of this Agreement. 11. WARRANTY AS TO FUTURE OBLIGATIONS: Husband and Wife each covenant, warrant, represent and agree that each will now and at all times hereafter save harmless and keep the other indemnified from all debts, charges and liabilities incurred by the other after the date of this Agreement, except as may be otherwise specif~cally provided for by the terms of this Agreement and that neither of them shall hereafter incur any liability whatsoever of which the estate of the other may be liable. 12. WAIVER OF ALIMONY. SUPPORT AND MAINTENANCE: Husband and Wife both agree that they have been respectively advised and are aware of the contents of the provisions of the Pennsylvania Divorce Code of 1980, as amended, wherein considerations are set forth in determining an appropriate amount, if any, to be paid in the form of alimony. After being fully advised of the contents of the Divorce Code of 1980, as amended, both Parties voluntarily anrl intelligently waive and relinquish any right to seek from the other payment for spousal support, alimony and maintenance. It shall be from the date of this Agreement the sole responsibility of each of the respective parties to sustain themselves without seeking any support from the other party. Parties hersby acknowledge that by this Agreement each has respectfully secured and maintained a substantial and adequate fund with which to provided themselves sufficient financial resources to provide for their comfort, maintenance and support in the station of life to which they are accustomed. 13. CUSTODY: Husband and wife agreed as follows: a. Husband and wife shall share joint legal custody of the child. b. Wife shall have primaIY physical custody of the child. c. Husband shall have partial physical custody of the child, as follows: (1) Every other weekend from Saturday at 9:00 am until Sunday at 7:00 pm. Husband shall give wife notice by 6:00 pm on the Wednesday preceding the weekend of his partial custody rights as to whether he will exercise those partial custody rights that weekend. If Husband does not give said notice, he shall not have the right to exercise partial custody rights on said weekend. (2) Two weeks of vacation in the summer. Husband shAll give wife notice by May 1st of his two weeks of vacation in the summer months. (3) Husband and Wife shall alternate custody rights to the child on the following holidays: New Year's Day, Easter, Memorial Day, Fourth of July, Labor Day and Thanksgiving. (4) Husband shall have partial custody of the child from 2:00 pm to 8:00 pm each and every Christmas Day with Wife to have custody for the balance of Christmas Day. The above holiday schedule shall supersede the weekend schedule. (5) The. child shall be exchanged between the Parties at a neutral location mutually agreeable to the Parties. (6) Unless otherwise provided herein, Husband shall give Wife 48 hours notice of his intention to exercise the above rights to custody or visitation. If Husband does not give said notice, he shall not have the right to exercise partial custody as set forth above. d. Neither Party shall remove the said child from the Commonwealth of Pennsylvania for the purpose of relocating without first having obtained the written consent of the other Party. Both Parties agree to promptly inform the other of any change in telephone number of either Party. e. Husband understands and agrees that this Agreement shall in no way affect the contempt proceeding for non-payment of support obligations currently pending before the Cumberland County Court of Common Pleas docketed to case No. 1114 Support 1992. 14. CHILD SUPPORT: The Parties agree that the support order . . entered by the Court on March 7, 1995, a copy of which is attached hereto and incorporated by reference herein as Exhibit "C", shall remain in full force and effect subject to the review and modification of same from time to time by the Court or by application by the Parties to the Court for such modification. 15. TAX EXEMPTIONS; Wife shall be entitled to take any income tax exemptions and/or deductions allowable for the said child for federal income tax purposes and under any applicable state or local tax provisions. If in any tax year Husband violates this Agreement by claiming an exemption for the said child as a dspendent for such year, and if the Internal Revenue Service refuses to allow the dependency exemption for the said child for such year to Wife, then Husband shall pay to Wife the amount of Wife's additional tax liability penalties, fineS and costs. 16. ATTORNEY' S FEES: Husband and Wife hereby agree that they shall be responsible for payment of their own attorney's fees in connection with the preparation and execution of this Agreement and that neither shall be liable for payment of the other party's attorney's fees for same. 17. OTHER DOCUMENTATION: Wife and Husband covenant and agree that they will forthwith (and within at least thirty (30) days for demand therefore) execute any and all written instruments, assignments, releases, satisfactions, deeds, notes or other such writings as may be necessary or desirable for the proper effectuation of this Agreement in order to carr.y out fully and effectively the terms of this Agreement. 18. SUIT F~REACH; If either party breaches any provision of this Agreement, the other Party shall have the right, at his or her election, to sue for damages for such breach. The Party breaching this Agreement. shall be responsible for the payment of reasonable legal fees and costs incurred by the other in enforcing his or her rights under this Agreement or seeking such other remedy or relief as may be available to him or her. 19. FULL DISCLOSURE: Wife and Husband hereby represent that they have fully and completely disclosed to the other Party all property owned or possessed by them and all debts for which they are now or may in the future be liable, at the time this action was commenced, at the time one month prior to the signing of this Agreement, and that they have also disclosed to the other party all property transferred by them within the preceding three (3) years. 20. ENTIRE AGRl!:EMENT: This Agreement contains the entire understanding between the Parties. There are no representations, warranties, covenants or undertakings other than as expressly set forth herein. 21. WAIVER OR MODIFICATION TO BE IN WRITING: No modification nor waiver of any of the terms hereof shall be valid unless in writing and signed by both Parties and no waiver of any breach hereof or dllfaul t hereunder shall be deemed a waiver of any subsequent default of the same or similar nature. 22. LAW OF PENNSYLVANIA APPLICABLE: This Agreement shall be construed in accordance with the laws of the Commonweal th of Pennsylvania. 23. MREEMENT BINDING ON HEIRS: This Agreement shall be binding and shall inure to the benefit of the Parties hereto and ~ . . , ~- -. . their respective heirs, executors, administrators, successors and assigns. 24. SEVERABILITY: If any term, condition, clause or provision of this Agreement shall be determined or declared to be void or invalid in 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 exception of the satisfaction of the conditions precedent, shall in no way void or alter the remaining obligations of the Parties. 25. HEADINGS NOT PART OF AGREEMENT: Any headings preceding the text of the several paragraphs and subparagraphs hereof are inserted solely for the convenience of reference and shall not constitute a part of this Agreement nor shall they effect its meaning, construction or effect. 26. The provisions of this Agreement are fully understood by both Parties, and each Party acknowledges that this Agreement is fair and equitable, that it is being entered into voluntarily and that it is not the result of any duress or any undue influence. . . . IN WITNESS WHEREOF, the Parties hereto have set their hands and seals the day and year first above written. WI~:1r /f~4IU}L-- Ronald q COMMONWEALTH OF PENNSYLVANIA .. J SS. COUNTY OF ~&Y\.J~ On this, the 13fi'- day of {}nlkJ , 1995, before me, a Notary Public in and for said ~~nwealth and County, personally appeared Bernadette Cassel, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Agreement, and acknowledged that she executed same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. d~O- nt .~~L.v Notary publ c M Commission Expires: ,/-/to/9r Nobw1aI SMI Usa M. L8debchm. Nola,., PutlIo FaI......w l'wJ>.. Vonc County My Comml..lon e'pire. July 20, 1991l MomIor, .l6yI.aroaA&a<ollondNolMoe COMMONWEALTH OF PENNSYLVANIA U . I. S8. COUNTY OF O~ On this, the /1-fh day of h4 , 1995, before me, a Notary Public in and for said Commonwealth and County, personally appeared Ronald Ross Cassel, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Agreement, and acknowledged that he executed same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. n!~o.Jftr:t~J..nJ Notary Publ~c .L M Commission Expires: l/1-/J(Yt Notarial Sell U.a M. Ledebohm, Nota,., PubGc Fahview Twp., Yorl< County My CommiSSion Expires Jvly 20. 1991l Menilet. f'&mtyNarillAsalaaiia1 d Nol.>ioe , . . SCHEDULE "A" Wife's Personal Property Burial Plots Pontiac TIOOO Furniture . . . .. . . SCHEDULE "B" Husband's Personal Property 1972 Dodge Pick-Up Truck Musical Equipment Band Equipment ., jl ...,...,..,~,.. - ___ I . ~--- .. . . . . . .- . . " . DR 20,702 : IN TIm COURT OF coMMON PLEAS OF BERNI\DETI'E M. Cl\SSEI. ,pLAINTIFF: CUMBBRLAND COUNTY , PENNSYLVANIA VS : DOMF~'lTIC REI.ATIONS SECTION : CIVIL ACTION. Sm'I'ORT OONA(,D R. Cl\SSEL ,DEFENDANT: NO..1..u.L SUPPORT 19-2L ORDER OF COtJRT AND NOW, (his 7 th dAY of _Milrc:\1 . 19..9.5-. tlftSCd upon the Court'. dc<ennlnatlon (hat rlaintlO'. monthly net incomc/c.unlng cftpllcily Is S _l. 105.00. And o.:fendanr. monthly net incomdc.uning ClIf'IlCity is S 1,248.00 . it is hatby ordeml tlutllhe Dcl'endant pay \0 Ihe Domestic Rclationl Section. Court of Common r1c:aJ. Dollm(S 325.00 )amon1hpaY8ble(WEEKLY~ ~lISfollows: $75.00/Week ArteansdatS 2,299.41 o.~of 3-7-95 arc due in full IMMEDrA TELY. Conlcmp( pl'Occcdings. rn:dil bU!l:&lI reporting and laX refund offsel certIllcadon will not be initiated and judgment will not be entered. as long as IJCfcndanl pays S 10.00011 am:an each payment dale. Failure \0 make ClIch payment OIl lime and in full will cause all arrears to become subject (0 immediate collection by nl1 of the means listed above. . Forthesllwortor. his wife and child, Justin R. Cassel. born 3-20-86___ This order is mads retroactive to 10-25-94 due to the defendant' s failure to an IRS debt as ordered on 10-25-94. This order takee. ~a~8e'Y P&'\hn?~ ~Jlf ~PtIi~'i511ffi~cau8M~dnitlf.' 'b'\'A7 n~W'r.r is* . Payments must be made by cash, checL: or money order. ea.s11S payment must be made in penon. All cbecks and money ooIen must be made payable \0 Domestic Relations Section nnd delivered or mailed to Domestic Relations Section. 13 North H8I1OVl:\' street. Carlisle. Pennsylvania 17013. rl&Ch payment must bear your Domestic Re\fttiOll5 nllmber in order to be processed, Unrcimburscd medical eXJlCllSO:S arc to be paid 50 % by Defendant and 'in" by plaintiff. (PL.AJNTIFFfJlll:}lIIPJIII'WU/DOlXJ',!fDl) (0 provide medical insum1a: coverage. Within 30 days after the enlly oflhis order, the (p1.AIN11FF~ 51l81lrubmit 10 the penon having custody of the child(rcn) wrilten proof that medical Insurance coverage has been made. Proof of coverage shall consist. at a minimum. of: (I) the name oCthe health care coYCtfttlC providet(s); (2) any Ippliable identifiCAtion numbcts; (3) Ilny cards evidencing rovctage; (4) the address to whlch claims should be made; (5) tI description of any rcstrlctlOllS OIl usage, such as a prior Ijlpl'Ova! fllf hospital admissions. and the manner of obtaining approvlt; (6) a copy of !he benefit bookld or coverage contract; (7) ft description of all deductibles and ro-paymenls; and (8) five cOjlic.s of any chum fonns. IMPORTANT LEGAL NOTICE PARTIES MUST WITIIIN SEVEN DAYS INFORM TIlE DOMESTIC RELATIONS SECTION AND TIlE OTIIER PARTIES, IN WRrIlNG. OF ANY MATERIAL CHANOE IN CIRCUMSTANCES REI.EVANT TO 11 IE LEVEL OF SUPPORT OR TIlE ADMINlSTRATION OF TIlE SUPPORT ORDER.INCLl'DING.lllJT NOT LIMITED TO. *allocated S75.00/week child Rupport and SO.OO/week RpouRCll. .t':: ~4~ .Ju ,.H' . .: 1"t'" 1 '.. '. ~r "', . . , ~'" .....~..I.. -~........,\ 'r:'~ .,~ DRO" 515 .. "J" -.. ... '.'. J 'I .. . LOSS OR Cl/ANOE OF INCOME OR EMPLOYMENT AND CJlANOE OF pr>RSONAL ADDRESS OR CHANOE OF ADDRESS OF ANY ClfilD RECETVINO SUI'I'ORT. A PARTY WHO\Y1LLFUlJ,Y FAILS TO REPORT A MATERIAL CHANOE IN CIRCUMSTANCE MAY DF. ADnnXlED IN CONTEMPT OF COURT. AND MAYDE FINED OR IMPRISONED. PENNSYLVANIA lAW PROVIDES TIIAT ALL SUPPORT ORDERS SIIALL BE REvIEwED AT LF.AST ONCE EVERY TIIREE (3) YF-ARS IF SUCIl A REVIEW IS REQUESTED BY ONE OF nm PARTIES. IF YOU WISH TO REQUEST A REVIEW AND ADJUSTMENT OF YOUR ORDER. YOU MUST 00 TIm fOLLOWlNO: AN UNREPRESENTED PERSON WHO WANTS TO MODIFY (ADJUST) A SUPPORT ORDER SHOUlD fU..E A PETITION FOR MODIFICATION. FORMS ARE A VAILARLE AT TIm DOMESTIC REIA TIONS OFFICE. A MANDATORY INCOME ATIACIIMENT WILL ISSUE UNLESS TIlE DEFENDANT IS NOT IN ARREARS IN PAYMENT IN AN AMOUNT EQUAL TO OR ORFATER 1lIAN ONE MONTIl'S SUPPORT ODLlOA TION AND (I) TIlE COURT FINDS TI IA T 1lIERE IS 0000 CAUSE NOT TO REQUIRE IMMEDIATE INCOME wmnrowlNo; OR (2) A WIUTTEN AOREEMENT IS RFACIIED BElWEEN THE PARTIES WlDCIl PROVIDES FORAN ALTERNATEARRANOEMENT. DELINQUENT ARRFARAOE DAlANCES MAYDE REPORTED TO CREDIT AOENCIES. ON AND AFTER TIlE DATE IT IS DUE. EACIl UNPAID SUPPORT PAYMENT SHALL CONSTITUTE A JUDOMENT AOAINST YOU. IT IS FURTIIER ORDERED thst, upon defendanrs failure 10 comply with this order, defendant may IIC anesfr.d and brought \1cfore the {'.ourt for a Contempt hearing; defendant, WIgCS. saluy, commissions, and/or InC(lme /DlIY IIC atlllchcd In accordance with the law, dds Older wUI be Increased without IUrther hcarlng 10 S 50.00 a mondl until all am:arages arc paid in full. Defendant iJ rcsponri\1lc for court com and fce3 IU dclumincd by (he Domc.1lic Rdatlons Section.. Tbls ordcc shall become final ten days aflcr the mal ling of !he notice oftlte entty oflbc order 10 !he pnrties unless citItcr plIrty files a writ<en demand with tile Domestic: RelAtions Section for a hearing de novo before the Court. Copies delivered 10 pmies on ~ BERNl\DE'ITE M. CASSEL Plaintiff KARL LEOEI3OIIM Plaintirrs Attorney R'JNALD R. CASSEL IJcfendant IJcfendanrs Allorncy BY TIlE COURT. /) , ..- ~Lt!lu ./ .If WeBley 01 ,Jr.. s. DR:> IF. Goshorn OrSfh515 II! BEil'/ADEITE CASSEL; Plaintiff. IN '!llE COJRT OF CeJ.t.1CX'J PLEAS OF C\Jo1BERLAND CCU1'lTY, PFNNSYLVANIA NO. 94-5511 CIVIL 1994 VS. IOWJ) RES CASSEL, Defendant. 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. Grounds for divorce: irretrievable breakdown under Section 3301 lc) ~) of the Divorce Code. (Strike out inapplicable section) 2. Date and rranner of service of the canplaint: nn flAIAn..t2n. :lhn.VA n=trNal'f t), certified mall, return receipt requested, and evidenced by Acceptance of Service form slanAd by ORfAnrl~nt nn April 11. lqQ~ 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 1001;, nn Ap1"'ll lA . by the defendant nn April 17, 100~ B. (1) Date of execution of the plaintiff's affidavit required by Section 3301 (d) of the Divorce Code: (2) Date of service of the plaintiff's affidavit upon the defendant: 4. Related claims pending: None. All Issues were resolved by the Post Nuptial ARreement dated Aorll 13. 1995. Incoroorated herein. 5. Indicate date and manner of service of the noti~e of intention to file praecipe to transmit record, and attach a copy of said notice under Section 3301 (d)ll)(i) of the Divorce Code II 1M tjJL Attorney for Plaintiff/~ Karl M. 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'" Z E-o ~8:;: C ~u Ul H "" = -:.;I s! ~ Ul ..: t.l 0< u ... 0 H Ul " ~ ... ll: ~ ~ z [;J~ ~ ~ 0 .. U Q ...~ :2: ~ ~ ~ Z ~R ~ 9 ::!i . .. . . , . HOIIEllT E, 'In:~s Anl,l\{'\i y 1\1 [.,-,w lul 'fl i! jo. 1~II\lJ '\1_W n \1!1I H .\'\1' .'\ ! 'lJ"J l BERNADETTE CASSEL Plaintiff , IN THE COURT OP COMMON PLEAS CU}IBJ.:RLAND COUNTY, PENNA. v. CIVIL ACTION - LAW NO. 14 -.j'SIJ IN DIVORCE CA.~~e.. J ~ I I , I RONALD ROSS CASSEL, Ue hndant, IlO'I'ICB TO DUIJID AUI CLADI IIGJIT8 YOU HAVE BEEN SUED IN COURT. If you wilh to defend againlt the elaiml eet forth in the following pagel, you mUlt take prompt action. You are warned that if you fail to do la, the case may proceed without you and a Decree of Divorce or annulment may be entered Rgalnst you by the Court. A judgment may alia be entered againat you for any other clsim Dr relief requeated in theee papera by tha Plaintiff. You may 10le money or property or othar rights important to you, including cUltody Dr visitation of your children. When the grounds of the divorce il Indignities or irretrievable breakdown of marriage, you may request marriage counselling. A lilt of marriags counaellors is available in the Office of the Prothonotsry, Carliele. Pennsylvania, 17013. IF YOU DO NOT PILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS PEES OR EXPENSES BEFORE A DIVORCE, OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY UP THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYJ.:R AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET PORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Court Administrator's Office Cumberland County Courthoule Fourth Floor One Courthouse Square Carliele, Pennsylvania 17013 (717) 240-6200 BlnNADITTI CASSIL Pll1ntlff, Y. , IN THI COURT or ClJIMON PLIAS I CUHBIRLAND COUNTY, PINNA, I I CIVIL ACTION - LAW I I NO. 94SU00719-02D I IN DIVORCI RONALD ROSS CASSIL, D. fend'llt, ~ UST!D HA SIoo DIHANDADO IN LH CORTE. Sl u.ted d..e. d.fender.. d. 1.. qu.j.. .x~u..t.. .n 1.. pig In.. .~gulente., debe tom.r .ccltn d.ntro d. v.lnte (20) di.. . partir d. 14 fach. .n qua receibio 18 d.m.nd. y el .vlao. Uated d.b. pr...nt.r comp.r.c.nci. ..crit. en p.r.on. 0 por .bogado y pre.ent.r .n 1. Cart. pro ..crito .u. d.gen... 0 .u. obJecione. . 1.. dem.nd.. en .u contr.. S. 1. .vi.. que .i no .e defiende, el calo puede proceder .in u.ted y 1. Corte pu.d. decidir .n .u contra .in mal avlao 0 notif1c.cii5n par cu.lquier dinero rachm.do en 1. dem.nda 0 por cu.1quler otr. queJa 0 compen..cioS'n r.cl.m.do. par e1 Demand.nte. USTED PUEDE PERDER DINERO, 0 PROPIEDADES U OTROS D!RlCHOS IMPORTANTES PARA USTED. LLEVE ISTA DEMANDA A UN AIl0GADO IHMEDIATAHENT!. 51 USTED NO TUN! 0 NO CONOCE UN ABOGADO, VAYA 0 LLAHI! A LA OPICINA EN LA DIRECCION !SCRITA ABAJO PARA AVERIGUAR DONDE PUEDE OBTENER ASISTENCIA L!GAL. Cumberl.nd County Court Adminiltr.tor'. Office Cumberl.nd County Courthoule rourth P100r One Courthoule Square C.rli.le, Pennlylv.ni. 17013 (717) 240- 6 200 , BERNADETTE CASSEL Plaintiff , IN THE COURT OP COMMON PLEAS CUMBERLAND COUNTY, PENNA. v. CIVIL ACTION - LAW RONALD ROSS CASSEL, Defendant. NO. 94SU00719-02D IN DIVORCI ClIO'LAIft NOW COHES, the Plaintiff by her attorney, Karl H. Ledebohm, and brinle the followinl complaint, c:omrr I I SIlC'lIOI 201(A)(6) CW TIIB DIVoac& CODE 1. Plaintiff 11 an adult individual who reeidee at 258 North Inola Drive, 2nd Floor, Enola, PA 17025. 2. Defendant 11 an adult individual who ruid.. at 222 North Second Street, Wormleyaburg, PA 17043. 3. Plaintiff and Defendant have been bonafide reaidenta in the Commonwealth of Pennaylvania for at least six (6) months immediately previous to the filing of thia Complaint. 4. The parties were lawfully Married on or about February 13, 1988 in Enola, Pennaylvanla by Miniater Bruce D. Gearhart. 5. There have been no prior actiona of divorce or for annulment between the partlea. 6. Plaintiff aver. that the ground. upon which thi. action i. ba.ed are that Defendant ha. offered .uch indignltiea to the per.on of the Plaintiff, the innoc.nt .nd Injured .pou.a, a. to render PI.lntiff'. condition intolerable and life burden'OGle. 7. Plaintiff h.. been advlaed of the availlbility of counseling .nd haa further been sdvi.ed thst Plaintiff may have the right to reque.t that the Court require the parties to psrticipate In coun.eling. WHEREFORE, the Plaintiff prays your Honorable Court to enter a Decree of Divorce, divorcing the Plaintiff from the bonds of matrimony heretofore contr.cted between the Plaintiff and the Defend,nt. COUlIr II I SBCTIOIl 330l(C) or TUB DlVOllCB CODIt 8. The allegation. AI set forth in Paragraphs 1 through 7 of thle Compallnt are incorporated herein by reference as though set forth in full. 9. The marriage is irretrievably broken. WHEREFORE, the Plaintiff prays your Honorable Court to enter a Decree of Divorce, divorcing the Plaintiff from the bonds of matrimony heretofore contracted between the Plaintiff and the Defendant. COl/HT I II , EQUITABLE DISTRIIUTIOIl 10. Paragraph a 1 through 9 of thia complaint are incorporated herain by reference aa though aet forth in full. 11. Plaintiff and Defendant have acqulred property, both real and peraonal, durlng thelr marrlage, whlch property la "marital property". 12. Plaintiff and Defendant may have owned, prlor to the marriAga, proparty whlch haa increased In value during the marrlage and/or which haa been exchanged for other property, whlch haa Increased In value during the marrlage, all of whlch property 18 "marital property". 13. Plalntiff and Defendant have been unable to agree as to an equltable dlvialon of sald property prlor to the fl1lng of this Complalnt. WHEREFORE, PlalntLff requests your Honorable Court to equltably dlvide all marltal property. COl/HT IV, ALIlfONY PEJlDBHTIl LITI, COUNSIL rBIS, COSTS AJlD UPINSIS 14. Paragraphs 1 throug~ 13 of this Complalnt are incorporated hereln by reference as though set forth In full. BERNADETTE CASSEL, Plaintiff, vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO.: 94 5511 Civil Term RONALD ROSS CASSEL, Defendant. . . IN DIVORCE ACCEPTANCE or SERVICE I, Ronald Ross Cassel, the Defendant in the above captioned matter, do hereby certify that a true and correct copy of the Complaint with attached Notice to Defend and Claim Rights and a Notice as to counselling filed in the above captioned matter has been delivered to me and that service of same is hereby accepted this 6th day of October, 1994. Witness: 4-'/7 - tJ:) tJfI(tci)~~ // ~/J 4~ e/ / ! 1/.-(>: It. A~~.../ L( .------ Ronald Ro ssel . ., . BERNADETTE CASSEL, PIll!ntiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO.; 94 5511 Civil Term vs. RONALD ROSS CASSEL, Defendant. IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 27, 1994. 2. The marriage of Plaintiff and Defendant is irretrievably broken, and ninety (90) days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of a Final Decree of Divorce. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsifications to authorities. Dated: ~-e./ A:: /Y,9~ ..~ j . ,t1 I , ! , , I j ti1 c 1 ~ - ': :- .~ -" --:> '--, j '...:::' .. ., . BERNADETTE CASSEL, Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO.: 94 5511 Civil Term vs. RONALD ROSS CASSEL, Defendant. IN DIVORCE AFFIDAVIT OF CONSINT 1. A Complaint in Divorce under Section 3301(C) of the Divorce Code was filed on September 27, 1994. 2. The marriage of Plaintiff and Defendant is irretrievably broken, and ninety (90) days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of a Final Decree of Divorce. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsifications to authorities. Dated: f-/l~ tiS .,. ~ ~:: -.- -:-i :..~ ':> '="'II - ., '"":':') ~ -....., '" 'c. -..; ,,'.. -< vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO.: 94 5511 Civil Term BERNADETTE CASSEL, Plaintiff, RONALD ROSS CASSEL, Defendant. IN DIVORCE AFFIDAVIT REGARDING COUNSELLING 1. I have been advised of the availability of marriage counselling and understand that I may request that the Court require that my spouse and I participate in counselling. 2. I understand that the Court maintains a list of marriage counsellors in the Domestic Relations Office, which list is available to me upon request. 3. Being so advised, I do not require that the Court require that my spouse and I participate in counselling prior to a divorce decree being handed down by the Court. I verify that false statements herein are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsifications to authorities. Dated: f11~ 15 i!. #/J u2 ..,~jf~. Ronald Ross. 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