Loading...
HomeMy WebLinkAbout94-07230 , ,', .\-,' " . , . -----~-------------~~~-------~ . --- I_ - . . . - . . . . ..Kel~nda, ,S..Ilippel1ateel. . ,.. ,.. " . . ..,DaV:lcl B.,HippeD8~~~1. I.II. "" , ., ",.. . . i . . . . . . . . . . . . . . . . . . - . ~--- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF .. PENNSYLVANIA ..Plaintiff I .." ., II N o. ,~~::~7..ZJ!L.", ".."",,,,,,,.. 19 Vcrsus , ..Defendant DECREE IN DIVORCE AND NOW. ' . . , . ~ k \. , , . ,I~, , , . . . ., 19.<::J C., it Is ordered and decreed that "..."..,., ,"~H'.'~",~,. \I~pp!,,,!,~!,!,~.. , . . . , ,., . . . .. plaintiff. and, ,. . . . , , , ., , , ' . , , DilV.id, )1,0, JUp.p.e.nS.I;l\l\l,. xu. . , , . . , . ...., ., 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. ., .. ...... . . , ."" . , ,. , . . . "., , , , . . , ,.. ,.. .". . . ..,.. . ;,~;J" .. . , .. ..... ... . ............................ ....~.]............... U/ "" , .., "./")'( r ,. ..,. ......., Alleal: ~,.ii''''''>"<!,'' f1CQ~<A,'~~" ,_ J. /.:b" ~~~t:( /" >>~.., ,',"'" y ,j' F. ot onolary _ _ --------~_ -c;- ~- ,,,-~'''''-:iV~IC-.:ac:-~_-''':-1o:.-...-.--J . . . . . - - . . . . . . t . . . . Ii '" v J ~ ~ . - - . ~ g 8 8 ~ 8 ~ 8 ~ ~ ", \, I/o~', ,P? 4-~tJ -9S- ,w '~l'f;..J" 711' q;zJ' ~ ~ INJ/ -r; .;r. t)'. ~ ;" . ,'I , , , , , " , I.', , , I'. " , " , , " I , " , ',. , , " 'II, , , , " II " . , , 'I, ,II , . . " , , " . " " , " " Ii , , l'i , " , " " " " " ,I !' Ilf , , , , 'I I I:. ....' ': " li , , , , " .' ., , I ;,1 ,I . , , " , " " ," ,,'I , ' , , ',! :.{ , " , . , . . lR !i .... 0;:> c:;) - :t"' ",t: ~.... It! ~~~JI ;.:t r .;.! :c I." J.~ l...(,.~ .~ ~ "l':'......' ~- -, l~L: .1: ../ , r-,.~ >J' :.:,j!'11 II. .:It Idl~Z '4.-'1,"11.-4 , '~t Q~ , ::;) ,SU .. . , " " i' " , ,.1 r- - " .I, I'll' '" ' ,i: ',1" , " " , ;i ~ .. IH!~! .f J I i I~ ~ S:! I ~~ . ~ I ~<!~tltl in i:! . ~I f;g I ~ I> ~ I Q l:l 3 i~ ~ f . ~<! ~~ ~~ . CIl i . I I IIll i ~ ~~ :I , , ,,' , , . ,I.. I, -I, ." ,,' 'I 1', ,/ ,,', " " , >I' Ii', , ., , , " " " ')' , , , " ., ., i'- "-i " ,"', -. J IT' II, . ,.......~. j'\/-'" ,. 1'.)1), Yf tlt/. &/1 AI~...~ ~ a"lf /J~ 1/'1~ ~5 ~, ;I(~ ~ y/ cr.. M-~r' , , . , , '. " I , '. . , , , , " '. , , , F!, , , " 'j', , '1, i'j , , " "I , . , ',' , , , , \'1 , " , , , , , , . , 01' .. . " . , , , 'I " , " :1, ! . , . , , . , : . .' , ;., , , '1'1/\ , , , , " " , , , , . Ii ,-\ i' i'l I " \.1, , , i , " l' ,~ I , , Ii' " , " . , , c, I' " '. " , " " I, . " 'II, , , '. , 'j' , ill , I It., , , , . .'1' .. " , ,'J I ,'\"1, . " .' " , , " " i" , " , \ , , i " , '. ", Ii I;; '. , . , . " , , , , '. " '-I 'II; " , " !'".\ ')/'0] :." 1'/ " " d~ ~ , , " MARITAL AGREEMENT , THIS AGREEMENT, made thisS.t't, day of ~ ,1995 by and between DAVID B. HIPPENSTEEL, Ill, hereinafter-referred-to aa Husband, of 161 C1evenburg Rosd, Shippenlburg, Cumberland County, Pennsylvania, and MELINDA S, HIPPENSTEEL, hereinafter-referred-to ss Wife, of 434 Peiper Road, Shippenlburg, Cumberland County, Pennsylvania. WITNESSETH: WHEREAS, the parties hereto are Husband and Wife, having been married on December 10, 1993, in Shippenaburg, .'rsnk1in County, l?enneylvania, with no children having been born of the marriage, WHEREAS, diverse unhappy differenceo, diaputea and difficulties have arisen between the parties and it is the intention of Wife and Husband to live separate and apart, and the parties hereto are desirous of settling aome of their reepective financial snd property rights and obligations as between each other including, without limitation by specificstion: the equitable division of marital property, and the settling of all matters between them relating to the past, present and future alimony and/or maintenance of Wife by Husband or of Husband by Wife. NOW, THEREFORE, in consideration of the premises and of the mutual promiaes, covenants and undertakings hereinafter set forth which is hereby acknowledged by each of the plirties hereto, Wife and Husband, each intending to be legally bound hereby, covenant and agree as follows: 1, AGREEMENT NOT A BAR TO DIVORCE 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 shall hereafter exiat or to such defense as may be available to either party. This Agreement is not intended to condone and shall not be deemed to be a condonation on the part of eithel party hereto of any act or acts on the part of the other party which have occasioned the disputes or unhappy differences which hsve occurred prior to or which may occur subsequent to the date hereof, The parties intend to secure a mutual consent, no-fault divorce pursuant to the terms of the Pennsylvania Divorce Code, Act No. 1990 - 206. 2. EFFECT OF DIVORCE DECREE The partiea agree that unless otherwise specifically provided herein, this Agreement shall continue in full force and effect after such time as a final decree in divorce may be entered with respect to the parties. 3, AGREEMENT TO BE INCORPORATED IN DIVORCE DECREE The parties agree that the terms of this Agreement may be incorporated into any divorce decree which may be entered with respect to them. MARK. WEIGLE AND PERKINS - Al'TORNEV!5 AT LAW - 12& EAST KINO STREET _ 5HIPPENSBURG, PA. 17:0157 .' 4. DATE OF EXECUTION The "date of execution" or "execution date" of this Agreement ehall be defined as the date upon which it is executed by the parties if they have each executed the Agreement on the same date. Otherwise, the "date of executilln" or "execution date" of this Agreement ahall be defined aa the dste of execution by the party last executing this Agreement. 5. ADVICE OF COUNSEL The provisions of this Agreement and their legal effect have been fully explained to the parties by their respective counsel, Jerry A. Weigle, Esquire, for Melinda S. Hippensteel, and H, Anthony Adams, Esquire, for David B, Hippensteel, III, The parties acknowledge that they have received independent legal advice from counsel of their selection and that they fully understand the facts and have been fully informed ae to their legal riKhts and obligations and they ecknowledKe end accept that this Agreement 18, in the e1rcumstances, fair snd equitable and that it l,s being entered into freely and voluntarily after having received such advice and with such knowledge and that execution of this Agreement is not the result of any duress or undue influence and that it is not the result of sny collusion or improper or illegal agreement or agreements, 6, PERSONAL RIGHTS Wife and Husband may and shall, at all times hereafter, live separate and apart. They shall be free from any control, restraint, interference or authority, direct or indirect, by the other in all respects as fully as if they were unmarried. They may reside at such place or places as they may select. Each msy, for his or her separate use or benefit, conduct, carryon and engage in any business, occupation, profession or employment whtch to him or her may seem advisable. Wife end Husband shall not molest, harass, disturb or malign each other or the respective families of each other nor compel or attempt to compel the other to cohabit or dwell by any means or in any manner whatsoever with him or her. 7. PERSONAL PROPERTY Husbsnd and Wife do hereby acknowledge that with the exception of the items specified in Paragraphs 7A, 7B and 7C, they have previously divided their tangible personal property, including but not necessarily limited to jewelry, clothes, furniture, furnishings, rugs, carpets, household equipment and appliances, vehicles, pictures, books, works of art and other personal property and hereafter Wife agrees that all of the property in the possession of Husband shall be the sole and aeparate property of Husband; and Husband agrees that all of the property in the pouess ion of Wife shall be the Bole and separate property of Wife. The parties do henby specifically waive, release, renounce and forever abandon whatever claims, if any, he or she may have with respect to the above items which shall become the sole and separate property of the other. A. The following items of personal property presently located in the marital residence shall be the sole and exclusive property of Wife or Wife's fsmily and MARK. WEIGI..E AND PERKINS - A r rORNEY~ AT L.AW -- 10!6 EAST KINO STHI':E r !'itllfJPl:N!'lftUHO, ",A 11.1"1 I shall be removed soley at Wife' e expense within fifteen (15) days of the execution of this marital settlement agreement! T.V. stand Air Conditioner Picnic table and chairs Bedroom suit Stereo Shelving Christmas tree skirt Pictures and knick-knacks Three piece living room suit (sofa, chair, loveseat) Coffee table Two end tables Two lamps presently located in marital residence Large rubber type planter, located in living room B. Husband agrees ($250.00) dollars for residence and belonging to pay Wife or her family the the refrigerator currently to the parents of Wife, full sum of two hundred fifty located within the marital C. Husband agrees to pay Wife the full sum of two hundred fifty ($250,00) dollars for the couple's television set, presently located within the marital residence and which is marital property, Wife agrees to pay in full any existing indebtedness on said television set and to furnish proof of final payment within fifteen (15) days of the execution of this agreement. 8. MOTOR VEHICLES With respect to the motor vehicles owned by one or both of the parties, they agree as follows: a. The 1989 Chevrolet Berreta vehicle titled in the name of Wife, shall become the sole and exclusive property of Wife with any dobt thereon to be the sole and exclusive responsibility of Wife. b, The 1987 Grand Prix vehicle titled in the name of Husband shall become the sole and exclusive property of Husband with any debt thereon to be the sole and exclusive responsibility of Husband. c, The titles to the said motor vehicles and any other necessary documents shall be executed by the parties, if appropriate for effecting transfer as herein provided, on the date of execution of this agreement and the said executed titles shall be delivered to the proper parties on the distribution date. 9. LOAN OBLIGATIONS a, The Sears and Montgomery Ward appliance and furniture loan obligations incurred prior to or during the time when the parties hereto cohabited as husband and wife, shall be the sole and exclusive responaibility of Wife. b, The home mortgsge obligation in the names of both Hu..;'and and Wife sholl be the sole and exclusive responsibility of Husband. c, Huaband and Wife agree to indemnify and hold each other harmless from sll further responsibilities and liabilities with respect to the above referenced ob1igati~ns that each is soley assuming hereunder, MARK. WEIGLE AND PERKINS- ATTORNEYS AT LAW _ 12l'j EAST "<INO STRf".ET StUPPEN'iRURG, PA. 174151 d. In the event that either party becomes a debtor in bankruptcy or financial reorganization proceedings of sny kind while any obl1Rations remain to be performed by that psrty for the benefit of the other psrty pursuant to the pI'ovisions of thie A~reement, the debtor spouse hereby welvea, releasee and relinquishes any right to claim any exemption (whether granted under atate or federe1 law) to any property remaininR in the debtor as a defense to any clelm made pursuent hereto by the creditor apouse, and the debtor spouse hereby assigna, transfera. and conveya to the credi tor apouse any interest in all of the debtor's exempt property sufficient to meet all obligations to the creditor spouse as set forth herein, including sll attorney's fees and coats incurred in the enforcement of this paragraph or any other provieion of this Agreement. No obligstion crested by this Agreement shsll be discharged or dischsrgeable, regerdlesa of federal or atate law to the contrsry, and each party waives sny and all right to assert that any obligetion hereunder is discharged or d1achargeab1e, The failure of any party to meet his or her obligations under anyone or mor.e of the peragraphe herein, with the exception of the satisfaction of conditions precedent, shsll not in any way void or alter the remaining obligationa of either of the parties. 10. REAL ESTATE The psreies hereto acknowledge and agree that they are ownere by the entiretiea of a certain home residence known as 161 Cleversburg Rosd. Shippenaburg. Southampton Township, Cumberland County, Pennsylvania. For and in consideration of the mutual covenant a and agreement s herein contained in the body of this instrument. Huaband and Wife agree that said real estate shall become the sole and exclusive property of Husband with Husband assuming sole responsibility for the payment of the current mortgage thereon with the Orrstown Bank, Orrstown, Pennsylvania. effective with the March, 1995, mortgage payment, Husband agrees to indemnify and hold Wife harmless from any further responsibilities and liabilities with respect to the above referenced mortRsge and further agrees to refinance said mortgage so as to remove W1f.e I s name from said obligation at the earliest possible time, Husband further agrees to pay Wife at such time as she executas a deed transferring her right. title and interest in and to the aforesaid real estate to Husband, the full sum of five thousand ($5,000.00) dollars. Husband shall be responsible for deed preparation and the fees and costs associated therewith, for the 1995 County and Township taxes and for all future real estate taxes thereon, 11. BANK ACCOUNTS For the mutual promises and covenants contsined in this sgreement. Husband hereby waives all right, title, claim or intarest he may have by equitable distribution or otherwise in any and all bank accounts, checking or savings, and each party waives against the other, any duty of accounting for disposition of eny jointly held funds, 12. AFTER-ACQUIRED PERSONAL PROPERTY Each of the part ies shall hereafter own and enjoy. independently of any claim or right of the other. all items of personal property. tangible or intanRib1e. hereafter acquired by him or her, with full power, in him or her to dispose of the seme as fully and effectively, in all respects and for all purpoees, as though he or she were unmarried, MARl<. WEIGI.E AND PERKINS ATTORNI,:VS AT LAW - llfi EAST" KING STREET _ SHIPPENSnURG, PA. 11J.~1 13. WARRANTY AS TO EXISTING OBLIGATIONS Each party repreaents that he or she has not heretofore incurred or contracted for sny debt or lisbility or obligation for which the IOtate of the other party may be responsible or liable except as may be provided for in this Agr.ement, Esch party agrees to indemnify or hold the other party harm1eas from and against any and all such debta, liabilitiea or obligat ions of every kind which may have heretofore been incurred by them, including those for necessities, except for the obligations arlaing out of this Agreement, 14, WARRANTY AS TO FUTURE OBLIGATIONS Wife and Husband each covenant, warrant, represent and agree that each will now and at all times hereafter save harmless and keep the other indemnified from any And all debts, charges and liabilities incurred by the other after the execution date of this Agreement, except aa may be otherwise specifically provided for by the terms of this Agreement and that neither of them shall hereafter incur any liability whstsoever for which the estate of the other may be liable, 15, LEGAL FEES Wife shall pay the cost of legal fees incurred in preparation of this marital Bgreement and all legal fees and court costs in connection with obtaining a 330l(c) No-Fault Divorce, Wife agrees to cooperate by executing the necessary consents and other documents required to effectuate said divorce, as requested by Husband's attorney, 16. MUTUAL RELEASES Husband and Wife each do hereby mutually remise, release, quitclaim and forever dl.scharge the other and the estate of each other, for all time to come, and for all purposes whatsoever, of and from any and all rights, title and interest, or claims in or egainst the property (including income and gain from property hereafter accruing) of the other or Against the estate of such other, of whatever nature and wheresoever situate, which he or she now has or at any time hereafter may have against such other, the eetate of such other or an)' part thereof, whether arising out of any formp.r acts, contrscts, engagements or liabilities of such other or by way of dower, courtltsy, or claims in the nsture of dower or courtltay or widcw's or widower's rights, family exemption or similar sllowance, 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 survivinR spouse to participate in a decease spouse's estate, whether arising under the laws of (a) Pennsylvania, (b) any State, Commonwealth or territory of the United States, or (c) any other country, except, and only except, all rights and agreement a and obligations of whatsoever nature arising or which msy arise under this Agreement or for the breach of any provision thereof. It is the intention of Husband and Wife to give to 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 for the breach of any provision thereof. MAI,HC, WLIf.jlf. AND J'UU<IN.-. ^lfO~lljlV"'l AT lAW l~" feASI K1Nf, ")THEEr ,\ttlPPf.NSBUHG, PA_ 11:1....7 , . .. 17. WAIVER OR MODIFICATION TO BE IN WRITING No modification or waiver of any of the terms hereof ahall be valid unhas in writing and signed by both parties and no wsiver of any breach hereof or default heuunder shall be deemed .. waiver of any subsequent default, of the lIame or eimilar nature . 18. DIVORCE The parties hereto agree to enter into a mutual consent divorce under Section 3301(c) of the PennsylvaniG Divorce Code, Act of 1990 ~ 206, Wife agrees to pursue the present divorce action filed to No, 94-7230 Civil, in Cumberland County, Pennsylvania, end to be the Plaintiff therdn. Husbsnd agrees to sign the neceasary documents, including the Affidavit of Consent, at ouch time Gfter the ninety (90) days of the flUng of tho Complaint and further instruments that may be reasonably required to give full force and effect to the provisions of this Agreement. 19, MUTUAL COOPERATION Each party shall, st any time and from time to time hereafter, take any and all steps and execute. acknowledge and deliver to the other part.y any and all future instrumeuts and/or documents that the other party may reasonably require for the purpose of giving full force and effect to the provisions of this Agreement. 20, This wealth of LAW OF PENNSYLVANIA APPLICABLE Agreement shall be const rued in accordence with the laws of the Pennsylvenia, CODUUon- 21. AGRIlEMENT BINDING ON HEIRS This Agreement shall be binding and ahall inure to the benefit of the parties hereto and their respective heirs, executors, administrators, successors and assigns. 22. BREACH If either party breaches any provIsion of this Agreemant, the other party shall have the right, at his or her election, to sue for damages for such breach or seek such other remedies or relief as may be available to him or her, and the party bresching this contract shall be responsible for payment of legal fees and costs incurred by t.he other in enforc1ng their rights under thie Agreemp.nt. 23, WAIVER OF ALIMONY AND OTHER RIGHTS The parties hereto have been informed of their rights or hsve been advised to seek counsel to inform them of th.dr rights under and pursuant to the Pennsylvania Divorce Coda, Act of 1990 - 206, particularly the provisions for alimony, alimony pendente lite, equitable di..tribution of marital property, counsel fees or expenses. Both parties agree that this Agreement shrill conclusively provIde for the dl.stribution of property under the said law, snd except as specifically provided for herein, hereby waive, release and relinquish sny further rights they may respectively have against the other for alimony, alimony pendente lite, equitable distribution of marital property, counsel fees or expenses, except as set forth in this Agreement, From tbe date hereof, erlch party may acquire either personal or real property in h Ls or her own name, Any property so acquired shall be owned solely by the individual and eball not be subject to any claim whatsoever by the other party, MAflK, Wf,.lnlE AND PEHKIN~ ^, IOHNf "5 ^ r LAW '111 EASY KINe, ";, Rl:oE: t 5..lIPPENSf\URG. PA 1725/ 24. FINANCIAL DISCLOSURE The partie. confirm that they have relied on the subetsntid accuracy of the financiel di.c10sure of the other as an inducement to the execution of thiB Agree- ment, 25. ENTIRE AGREEMENT This Agreement constitutell the entire underatanding of the partie. and super- sed.. any and all prior agreement a llnd negoliat iona between them, There au no repreaentations or warrantias other than those expressly set forth herein. 26. NO WAIVER OF DEFAULT This Agreement shall remain in full force and effect un1eas and until terminated under and purauant to the terms of this Agreement. The failure of either party to insist upon strict performanca of any of tha providons of thia Agreem'lnt shall in no way affect ths right of auch perty hereafter to enforce the same, 1I0r shall the waiver of allY breach of any provision hereof be construed as a waiver of a.,y subsequent default of the same or similar nature, nor shall it be conatrued as a waiver of strict performance of any other ob1igationa herein, 27, 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 proviBion 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 her or his obligations under anyone or more of the paragraphs herein, with the except ion of the satisfaction of the conditions precedent, shall in no wsy avoid or alter the remaining obligations of the parties. 28, HEADINGS NOT PART OF AGREEMENT Any head ings preceding the text of the several paragraphs and subparagraphs hereof are inserted solely for convenience of reference and shall not constitute a part of this Agreement nor shall they affect its meaning, construction or effect. 29. VOLUNTARY EXECUTION The provisions of this Agreement and their legal effect have been fully explained to the parties by their respective counsel, and each party acknowledges that the Agreement is fair and equitable, that it is being entered into voluntarily, and that it i8 not the result of any duress or undue influence. IN WITNESS WHEREOF', the parties hereto have set their hands and Beals the day and year firat above written. WITNESS: Yr J r \~t}u.~lttLta .j 1// ('/If//..,71a~{1 Melinda S. Hippensteel ' {Jr>, .;,f f3 ,~~_::f:. f:m:- David B, Hippen eel, III MARl<, WEIGLE ANO Pl:RKINS ATTORNEVS AT LAW IJ6 EAST KING STREET - S~UPPEN5nUH(j, PA 11,J~.1 -g:, .. ~. )-' I " ,'" J" ~.' ~ ' ~,(, \" ~ ~-n ';-..: ") '..J e, '"'\ Ii ~ r . :::J .~ ...., ~ ......... " - '. --{ r('l ;rl .~ , " \1 ~', ,) ,..> </,1 LJ J; ~, "~~ ~" 'V'1 -l Z~ ~ .~ r;; .~ " '--J' , \~) '.J. ,"(' of"("t r)') , . \~ '-...l , OOol , ~~ 4-l , ..:l..:! 4-l ~ p.~ 'rot d ~ -Ill ~~ d H'tl ~ -,rot Hd III S~ HQ) Z ~P< ~ 4-l t!~~ ~p. - Q) o - ~ E-t ~Q ~' i u>< en f;u ~~ H ei ;.l I Q . E-l 3@5 Qj <ia~ P< :> III E-tO Z P< ffi z z !SU H H ~~ -<'<\,l~~ D:l ~ TO ~J ~ 8i2l cj ~l~E I . H I en D:l H i:l ~ f~ ~ . ~<~~~: f ;~ III H Q = ~!l I 1 H -< 8i ~ I ~ " . ' '. " , " " .. .. .', i "".. '.' 6. Plaintiff h.. been advised that counnling is evailab1e and that Plaintiff I118Y have the right to requBllt that the court require the parti.. to pnticipate in counseling. 7. The marriage is irretrieveb1y broken. 8. The parties hav!! lived eeparate and apart sincl November 28, 1994. 9. The Plaintiff requests the court to enter a decree of divorce. COUNT II INDIGNITIES GROUNDS FOR DIVORCE 10. Paragraphe 1 through 9 of this Complaint are incorporatad hersin by reference as though set forth ill full. 11. Defendant has offered to the person of the Plaintiff, Plaintiff being the innocent and injured spoutle, such indignities aa to render Plaintiff's condition intolerable and Plaintiff's life burdensome. COUNT III EQUITABLE DISTRIBUTION 12. Paragraph a 10 and 11 of this Complaint are incorporated herein by referenca as though set forth in full. 13, Plaintiff and Defendant have legally and beneficially acquired property, both real and personal, during their marriage from December 10, 1993, until Ncvember 28, 1994, the date of their separstion, all of which property is "marital property". 14. Plaintiff and/or Defendant have acquired. prior to the marriage or subeequent thereto, "non-marital property" which hae increased in value since the date of the marriage and/or subaequent to ita acquisition during the msrriage, which incresse in value is marital property. 15. Plaintiff and Defendant have been unable to agree as to an equitable division of said property to the date of the filing of this Complaint. MARK. WEIClU: AND PERKINS ATroffNEY~ Al lAW In, f_Asr KINO STHrEI SHIPPJN'SnURG, ,~^ '-'257 " ,tA " . r-i' ., Sl r- -, .I 'I 'I . ... ;";"1' Clh~ "ft.lr, , ...,,)'-- :V~~h", "'o't; .f. '~';:e-J '~ .,'} t- " " ';";/1 . "'It, ~i ""11;;r.' . ',I, ~OI4J ~,.;t:t!~' "' ~U ',I., ,'II '\)1 , " 'I , ,. J 'I' ~ ; I ' ".,I,i' 'I I/LI "1' " , " ", " i " I d I' , , "ii' "I .. I,' 1',:\; " , ~ \. " /1' " " ,,-j, , " ,,' I'"~ " )"lj'l.i':j' "t I~__ L .; " i" ,il . " 'I'I " :.1 j' \"r, ,', /1 ., " " , I I t ",/ "-I" " if' I,'! "I .. .1" '''fi'l; , .' ',/<'," , , I: , \ I-I, j'i't ,_,,{l '. . , " " " 'I, t- J',I ih.-l.l. I'!)" I' .'d ui"'_l; 1\. ;";\ , 1-1'1'.d,!, " , I " 'J"" , I , , 1\ iI (j 1'1 /,i", /, J' , , ,'''' 'i, ':(1\ ,:,,;,,:,)1'" i ~ " . , , Ihl I, 'Ii-,'" ,', " , ,! JIll I-,J ), ~-'i-l "H I, " I,J"I,d,li . , I li!!'/IJ " " \" " " jJ\:tt n_',./, ,"I.,'1r '" , , , , 'J'_1 "I, " , 'I . , iltl "l'ir , " .' :! " , ' 'H.l ,\ ':-1 '.,' '. , 'I, JIll ;1, ',"1 , " , ", " . . '. " , . 'I' IJ, '. " " " " " , , .' .' i" " , " .'/r , " , " I, Ii , '. " iFl' ..~ )10. ~.~,I, , .., , II l' -., .., "" RT ,r' ()':or. tf: ~... !;i ~.o,:~l. :~ H. ), '')'', ~ ,.,)100..:1'....: " :~,~ ~~ ~'I . ,) l!'~~ 1- .-::I!.':b!;"11 - j. .J. "r l~ ,. ,\.) .s tr,~ , , , " '.'1 " . . , j: ,~ " , , , .. , , . , / . . " , 'i '. 1 , " , , . , .' " . " , " " , " " " , " , , '. ',I " . '. 'I , , ['i '1 ;1: ..' ,.1 " ;1 " ,,' "I, i' I,', , Ii . I' . , '.. , , -1/1,: ,I , , , , , 'I " ,; ':I! "I " " ..I:' " , ,I,'. , " " , " " . , " 'I , 'q I, ,.' " ,',J,I',' , , 'I' lR .. ~' c:) .., , r:o 1,,1 , .. i , , , " " , , .. , . , ;I, . " " "I' " I, , .' " , , '. i' >' ..lit....., ::"," I 'o./'" "', ,"-'f "'-r-~'l , "... 'I,) l. .:~ :,", . 1, ~ :'" ; . " . . , ~ .l1 o,,'J "'.'".r: ',',.,.'1, ,,'-" ~. "j, '. -"'1 r: ~- , ' o~ ~g \iol :.,J \iol ~ I~IU~ '.-I ~>< ~ -'0 tl Poolll e:: He:: ~ ~~ .'.-1 HGl ~~ H\iol H I -Gl ~ p' rolPo ~Q Eo< 8 -..:l III rol III ><.... ffi Eo< Il.. ill H Eo<:> . III I r..~.... p., :> ffi 0 I o u p., Eo< 0 .... Po E-oU = Po .... f ~Q:;: H :c ~.~! ~: rol . =: O~N U III Q I U r-- l3'. . .... ~ I ~ :3 III Il.. ~l3'.~ ~ =:~'" H lZl' Q ~~~ Q ~ H lZl ~ HU H ;:: ," " '.' " , " , '.' " , ", .' ,I ,I! "-1 'jl ;1' . " ~ , . t" '4 . , , . ~ - tt ':i . '" g r-:" ~ , d I , . :.t:; '~:'" ....... ''.I <:r,) ,- I. , , . '-JIlt- '\" ~: ~~ ~ ~ ~~ , " t........ - '... ~r ::a.: , " " ,. , I .' " ~~ , 0 ~ ... I ~ I i. I 0 ~~ ... ... .... i-< I '" ~ ... :a '~ ,,. ~ ~!~a~ . . ... H] I~ 0 0 ~3 H i~ iR :0: ~ . III !J ~ ~~ ~ I ;PI~g ~ "'~ . ... I ~~ i:!l 15 I> '" J '" ~ 15 '" '" ~ 3 Q.. I ~ ~ 0 f H ~ ~ s @l H ~ ~ ~ ~5l!i~: ~ H U H . = H 8~ ~ '" i-< I . 0 I ~ IQ :0: :~ ~ s ~ ~ ~ u , . " " ' , , , " , " " .', I:, , " " " ' , , , :' " .~ v. IN THE COURT OF COMMON PLEAS OF CUHBLERLAND COUNTY STATE OF PENNSYLVANIA CIVIL ACTION ~ LAW NO. 94-7230 CIVIL ACTION IN DIVORCE MEL INDA S. HIPPENS'rEEL, Plaintiff , DAVID B. HIPPENSTEEL, III, Defendant NOTICE OF ELECTION TO RETAKE FORMER NAME - granted a Final ~ Decree in divorce from the bonda of matrimony on matter, having ;l'.Jlt the h day of been Notice is hereby given that the Plaintiff in the above . 1995, hereby elects to retake and hereafter use her previous name of Melinde S, Pe1per. To Be Known As I '" Me1 Hippenateel: ~ ~, p~I'f\nll Melinda S. Paiper ~.JJU COMMONWEALTH OF PENNSYLVANIA SS. COUNTY OF CUMBERLAND On this. the l~ay of c~ . 1995, before me, a Notary Public in and for said County and State, the undersigned officer, personally appeared MELINDA S, HIPPENSTEEL, to be known as MELINDA S, PEIPER, known to me (or satisfactorily proven) to be the person whoae name is subacribed to the within instrument, and acknowledged that she executed the seme for the purposea therein contained, IN WITNESS WHEREOF, I hereunto set my hsnd and official seal. MIAl JIny A. WIfgIe, NalIIy PuIlIc ~. J 111:1. PA CUmlIe.llood ,.~...... Com."II']II~ 31'7. Cr _(StALl ,/"-~,\ \._-_\-' MAJlK WEI(;I.t-~ ANO Pl-HKIN". Arl(JI~Nf.Y'1 Ar lAW 1,16 fAST KINCi STREEr - !)t!IPPENSBURO, PA '7;Z~7