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HomeMy WebLinkAbout95-00762 w ~.' ~ r.' ~ .'; ~ ,,- i '.' ~ .' ~_~~*~*~~~~~*ro~*.~~*~~'):'~~~~:~~~.-_'_ro:.~:~ " ..- -............-------....... ...........-..-...---- '.' !tt ~ ~ Y, ~,' '"" w ~,- IN THE COURT OF COMMON PLEAS ~ ~.. ~ OF CUMBERLAND COUNTY ~ STATE OF PENNA, ~ ~ '.' w ,,. ~ ',' ~ ',' 'I , , N,), ..??::}~.2,.....(;lvrk:m.~1, l\X} ~ .CARLI'!; J, ..EI~ENIIOWER. ~ '.' Plaintiff ~ ~,' ~ Vel'StlS TIIADIJ!'US G, EISENIIOW.ER. ,', ~ ~ '.' Defendant ," ~ ',' ,', ~ ri ',' DECREE IN DIVORCE AND NOW, ',-~1Y~, " :?f\, " '. 19 qr it is ordered and decreed that." ..., ,~t\~I~1\1\ ,J,', ,I\I,S,I\~I!q\o!I\~,.", " " , ,"" ".,,'. plaintiff, and"" , ., " "" " ,,:~~??~~~,?:, ~~~~~~I~~~~"""" "" ,',' , " defendant. are divorced from the bonds of matrimony, ~ ... ~ ,; ,', ~ ~ ~.~ ,', ~ ~ ~.~ .' ~ r.i ~.' The court retains judsdlclion of the following claims which have been raised of record in this action for which a final order has not yet been entered; -rJ.-a- ~?~p, ,~~. r?~~f?~?; F~.t~F~. ~~.F~~~~:n:~.t-, ~!7".t~.L, r;. . .:-: ~~ P.o.s,t.-,N.u,P.t.i.l1,l. .^.&.r.c,cmcnt dated Nay 14. 1995. 1<o1Uo.l. _'.. "l is made a port of these proceedings by ..., ........ ...... ........,..., ....,. .., ... ........ .............. ......... separate Order of even date herewith but is not merged herein), n, Th~ c~ /~/ ^"e~l' _}"-:' / ",\ / ~ 14.-././-,L J. "",,(7.i''f~ 1(<!..~ c: c (.:~i"'.,;~ //'c'~;V:h..<-r/ L-~,mz. ):'. ~k AJZ / .. ~ T7Prolhollolnry ~ ~ ? I.l ~ :;( ---- :''''':' ~:. .... ,~ .~:;:~::.:. .. ~.:: ~:~:." .:.;. ".:.::- .:.;. .:.:. .:.:- .:.:. .:.:. .:.:. .:.:. .:.:. .:+:. .:,,:. .:.:. .:.:, .:.:, .:.:. .:.:. .:.;.' ,,~ ~ ~ <:, ~ ~ ~ '.~ ,', ~ ~ ',' ,', ~ ,', ~ ~ ,,. ,', ~ ~ ~.' ,', ~ ,', ... !~ ~ ~ , .~ ~ '.- ~ ~.' ,:" :, ,', ~ ~.~ ~ ',- " ,'. ~ ~ ~.' ~ ~ ',' $ ~ ',' l~ )~ ',' ., ~ .. !'. l~ i-.- I.., '. {." '~ :-,' , . !~ !~ , /'~ y~ . (}d. (0/7 /;:;Ji/~ <-4 d,dt{.4 /3 ,9ft 71v'~ 11t~ ~ .:'~, i' I II I I I i I I , .' CARLEE J. EISENHOWER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSVLVANIA CIVIL ACTION - LAW vs. THADDEUS G, EISENHOWER, Defendant NO, 95-762 CIVIL TERM IN DIVORCE ORDER OF COURT AND NOW, this -;2.fA. day of r~^ I ..l.)~ ' 1995 , a divorce decree having been entered in the above captioned proceeding, it is further ordered and directed that the attached Post-Nuptial Agreement between the parties dated May 14, 1995, is incorporated in this proceeding as an Order of this Court. It is further ordered that said Post-Nuptial Agreement shall not merge with said Decree of Divorce or this order, but shall retain its contractual significance. By , ) LAW ornc[a SutLnM:ER 8< BnCNNtMAU , I . , . -// .." / /.3 'it;: Ii", ((7:;,'/ /1'. ,,, t;W ..~ "rp ''5J:d!';':t'.) ,. k, '/.. '/ . ~.?' I' - . I . ; I ..J ,t. l,c" (f,' ,I/iI, t,:,:'/ ;( ,'1r.. J, POST-NUPTIAL AGREEMENT THIS AGREEMENT made and entered into this /f day of May , 1994, by and between: CARLEE J. EISENHOWER, of 409 Deerfield Road, Camp Hill (Lower Allen Township), Cumberland County, Pennsylvania, party of the first part, hereinafter called "Wife", AND THADDEUS G, EISENHOWER, of 502 Bridge street, New Cumberland, Cumberland County, Pennsylvania, party of the second part, hereinafter called "Husband": WITNESSETH: WHEREAS, the parties herein were married to each other on April 4, 1992, and last resided together on July 5, 1993; and WHEREAS, the parties accumulated various assets and incurred various liabilities; and WHEREAS, the parties have one child born of their marriage, namely, JACOB T, WILLIAM EISENHOWER, born on September 25, 1992, hereinafter called "Minor Child"; and WHEREAS, the parties agree that their marriage is irretrievably broken; and WHEREAS, Wife intends to commence an action in divorce in the Court of Common Pleas of Cumberland County, Pennsylvania, hereinafter called "Divorce Action"; and u.w orfU;a:a SNELDAKER . BRErmEMAN WHEREAS, the parties desire and intend to amicably dissolve their relationship and provide for an orderly resolution of various matters arising therefrom; and IIHEREAS, the parties acknowledge that they have personally negotiated the terms of this agreement and that neither Richard c. Snelbaker, Esquire, nor the law firm of Sne1baker & Brenneman, P.C" has participated in their bargaining, but that this document has been drafted by said attorney in the capacity as scrivener only; and LAW O"ICLI SNELDAKtn . 8RtWltMAU WHEREAS, Wife is independently represented by Richard C. Snelbaker, Esquire, of the law firm of Snelbaker & Brenneman, P,C" and Husband, being aware of his right to legal counsel and representation, is not represented by legal counsel; and WHEREAS, the parties, having a full opportunity to be advised as to their respective rights, duties and obligations growing out of their marital status, and each having had a full opportunity to investigate and evaluate the assets, liabilities and all other aspects of each other's property and their jointly held assets and liabilities, have come to an agreement as to each and all of their said matters of property and relations; NOW, THEREFORE, in consideration of these presents and of the mutual covenants, promises, terms and conditions hereinafter set forth and to be kept and performed by each party hereto, as well as for other good and valuable considerations, and intending to be legally bound hereby, the parties agree as follows: 1. The foregoing preamble and paragraphs are incorporated herein by reference thereto, 2, The parties acknowledge that their marital property consists only of certain household goods and personal property -2- and Wife's individually owned motor vehicle. They agree to distribute and divide said marital property as follows: a, wife shall keep, retain and own the motor vehicle as her sole and separate property and she shall be solely liable for the payment of the balance of the purchase price encumbering the title thereof. b. The parties shall each keep, retain and own the household goods and other personal property now in their respective individual possessions as his and her sole and separate property, except that Husband shall deliver to Wife within ten (10) days from the date hereof the items of personalty set forth on a certain list or schedule attached hereto marked "Exhibit A" and incorporated herein by reference thereto, which items the par~ies agree are and shall be the sole and separate property of Wife. c, The parties shall continue to be the co-owners of the camcorder, Said camcorder shall be kept in the possession of Wife; however, Husband shall have the right to borrow it temporarily for his personal use from time to time, particularly with the Minor child, The parties agree to equally pay the balance of the purchase price of the camcorder owing to Sears, Roebuck LAw OftICL. SNELDAKER a DntUI'IEMA.N & Co, 3, The parties individually agree to pay and discharge the following additional marital liabilities: -3- a. Wife shall pay the current balance of the charge account incurred with Boscov's. b. Husband shall pay the balance of the King's LAW Ol""ctu SNELDAKER a BRENNEMAU Jewelry account. c, Each party agrees to pay one-half of the actual balance of the account payable to Polyclinic Medical Center in the approximate amount of $794.00. Each party agrees to indemnify and hold the other party harmless of and from any and all liability which may be imposed or sought to be imposed by reason of the failure or neglect of the party to pay the obligation assumed and agreed to be paid as aforesaid. 4. Wife shall have primary physical custody of the Minor Child. The parties shall share legal custody of the Minor Child. The terms "physical custOdy" and "legal custOdy" shall have the meanings as stated in 23 Pa. C.S, 55302. Husband shall have reasonable rights of visitation with and temporary custody of the Minor child from time to time as the parties may agree. 5. Husband covenants and agrees to pay to Wife for the support of the Minor Child (a) the sum of Three Hundred ($300.00) Dollars per month, and (b) the entire and full tuition, fee or other charge of day care for said Minor Child in a licensed day care facility. Said monthly amount shall be paid to Wife no later than the first day of each and every calendar month commencing as of the first day of February, 1994. Said day care amount shall be paid as of the due date established by the day care facility. -4- Husband agrees to obtain, keep and maintain hospitalization and medical insurance on the Minor child equivalent to the basic dependent coverage as available from time to time through Capital Blue Cross and Pennsylvania Blue Shield at his sole cost and expense, The parties agree to share equally the hospitalization, medical, dental and orthodontic costs and expenses of the Minor Child not covered by insurance, 6. Husband covenants and agrees to pay for and provide a college or other post-highschool education for Minor Child, not to exceed four years of study, Husband's obligation shall include, but not be limited to, tuition, books, supplies, room, board and transportation, The extent of Husband's obligation shall be based upon his financial circumstances at the time of enforcement. LAW O,.,ICI:U SNELDAKER a BRENNeMAN 7, Husband covenants and agrees to pay to Wife the sum of Seven Hundred Fifty ($750.00) Dollars on account of her counsel fees and costs in the Divorce Action, said sum to be paid contemporaneously with the execution hereof. 8, The parties agree that any and all obligations incurred subsequent to the date of this agreement shall be the sole and separate liability and responsibility of the party incurring the obligation, and each party agrees that he/she will not incur or attempt to incur any obligation for or on behalf of the other party, and will indemnify and hold harmless the other party of and from any and all liability arising from any such future -s- obligation, 9. The parties agree to terminate their marriage by mutual consent without counseling and each agrees to make and execute the necessary affidavits and consents to procure a consensual divorce under the provisions of the Pennsylvania Divorce Code, such documents to be filed in the Divorce Action aforesaid, This agreement and the terms and conditions herein, as well as the enforcement of said terms, shall be and is/are contingent upon the issuance of a final decree of divorce in the Divorce Action. 10. Except only as specifically provided to the contrary hereinabove in this agreement, each party hereby waives and forever releases the other party of and from any and all claims which either may have against the other by reason of and pursuant to the pennsylvania Divorce Code (and the divorce law of any other jurisdiction) including, but not limited to, alimony, alimony pendente lite, equitable distribution of marital property, counsel fees, costs and expenses; except that the performance of the obligations hereunder may be enforced by any remedies under said Divorce Code, LAW or..cu SNELDAKEn . BRENNEMAN 11. Except only as may be provided specifically to the contrary hereinabove, each party shall retain all property, real, personal or otherwise, which is presently titled in her or his name and ownership, whether or not said property is or would be deemed to be marital property under the Pennsylvania Divorce Code, and each party hereby expressly releases the other of and from any and all right of equitable distribution in and to said -6- LAW O,.,ICta SNELDAKEft . BRENNEMAN individually owned property of such other party, including, but not limited to, the respective pension rights and plans of the parties. 12, Husband relinquishes his inchoate intestate right in the estate of Wife, and Wife relinquishes her inchoate intestate right in the estate of Husband, and each of the parties hereto by these presents, for himself or herself, his or her heirs, executors, administrators or assigns, does hereby remise, release, quit-claim and forever discharge the other party hereto, his or her heirs, executors, administrators or assigns, or any of them, of any and all claims, demands, damages, actions, causes of action or suits at law or in equity of whatsoever kind or nature, for or because of any matter or thing done, omitted or suffered to be done by such other party prior to the date hereof, except that this release shall in no way exonerate or discharge either party from the obligations and promises made and imposed by reason of this agreement. This agreement shall not be construed to affect or bar the right of either party to an absolute divorce on legal and truthful grounds if they now exist or may hereafter arise, this agreement being intended to provide a definite and orderly method of resolving the various property and business transactions between the parties, and not being intended as an agreement by either party not to defend against a suit in divorce commenced by either party or in any other way to be regarded as a waiver of any right by either party to participate in the litigation of any such action, with the exception of any rights, -7- however, as previously released by this agreement with regard to alimony, alimony pendente lite, equitable distribution of property, counsel fees, costs and expenses, other than the enforcement or performance of this agreement which may be instituted pursuant to the remedies available under the Pennsylvania Divorce Code. 13, It is the intention of the parties that this agreement shall survive any action in divorce which may be instituted or prosecuted by either party, and no order, judgment or decree of divorce, temporary, interlocutory, final or permanent, shall affect or modify the terms of this agreement, but said agreement may be enforced by any remedy at law or in equity, including enforcement proceedings under the Pennsylvania Divorce Code. The parties agree to incorporate this agreement into a separate order of court to be entered in the Divorce Action, but shall not be merged into said Order or the decree in divorce. 14, The parties agree to cooperate with each other and to make, execute, acknowledge and deliver such instruments and take LAW OFf/eta SNELDAKER a BRENNCMAU such further action as may hereafter be determined to be requisite and necessary to effect the purposes and intention of this agreement. lS, Each party acknowledges that the agreement is fair and equitable, that it is being entered into voluntarily, with full knowledge of the assets of both parties, and that it is not the result of any duress or undue influence, The parties acknowledge that they have been furnished with all information relating to -8- the financial affairs of the other which has been requested by each of them or by their respective counsel. 16, This agreement contains the entire understanding of the parties and there are no representations, warranties, covenants or undertakings other than those expressly set forth herein, The parties acknowledge and agree that the provisions of this agreement with respect to the distribution and division of marital and separate property are fair, equitable and satisfactory to them based on the length of their marriage and other relevant factors which have been taken into consideration by the parties, Both parties hereby accept the provisions of this agreement with respect to the division of property in lieu of and in full and final settlement and satisfaction of all LAW O'fICtS SNtLUAKEn . BRErWEMAN claims and demands that they may now have or hereafter have against the other for equitable distribution of their property by any court of competent jurisdiction pursuant to the Divorce Code or any amendments thereto, Each party voluntarily and intelligently waives and relinquishes any right to seek a court ordered determination and distribution of marital property, but nothing herein contained shall constitute a waiver by either party of any rights to seek the relief of any court for the purpose of enforcing the provisions of this agreement. 17. The waiver of any term, condition, clause or provision of this agreement shall in no way be deemed or considered a waiver of any other term, condition, clause or provision of this agreement. -9- 18, This agreement shall be construed, interpreted and enforced according to the laws of the commonwealth of Pennsylvania. IN WITNESS WHEREOF, the parties have hereunto set their respective hands and seals the day and year first above written intending, thereby to legally bind themselves, their heirs, personal representatives and assigns, VJ)OA/f);(;(1' ,71ft, Kg:.~ I' /2 :/ ....- ~~ t C C~Q, Thaddeu (SEAL) WITNESSED BY: C' l/})'1AW/u/(. iflt,,! i:4'7 , - (SEAL) LAW OH\CU SNCLDAKEtt . DnENNEM"" -10- COMMONWEALTH OF PENNSYLVANIA ) , , COUNTY OF CUMBERLAND) SS, On this, the N day of May , 1994, before me, a Notary Public in and for said Commonwealth and County, the undersigned officer, personally appeared CARLEE J. EISENHOWER, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Post-Nuptial Agreement, and known as "Wife" therein, and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official sea 1. " I.~." " '. '-frJ();)JOItAfJ . tl/i{::-r I Notary Publ c MN.lf..,t~.....;: "V'.~J; I'lj;., C..iIl,"IIU1'.:)<'U CU:lt.j....,I~W:.;.,'t.~ ,.lyC,)lm'.!::'...ldF.'fil......O.t'11.(: j PO'\ )1'1, 'lllr:i;r;:.jA:.~;~:r;-:-t-: On this, the /"/ day of May , 1994, COMMONWEALTH OF PENNSYLVANIA ) , , COUNTY OF CUMBERLAND) SS. LAw on/eLl SNELUAKER . BRErlNI:MAN before me, a Notary Public in and for said Commonwealth and county, the undersigned officer, personally appeared THADDEUS G. EISENHOWER, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Post-Nuptial Agreement, and known as "Husband" therein, and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal, [-.--.... . ! ,.a,' ~ . 4' .. 1,1'0\".. "",.. "1-11.,1.''''. I....J".'III..l-..J,/'_d'.i.,. .;l.".u~ r:: ,"'.. ....'" \l 'I_ '" . j, J l , ,"'~ rr::"l:.; (,;,;.;:, ~' ,'.. ' l-/ ') b'/lti'I!//t' Flit I~) I Notary Publ c EXHIBIT "A" The following items of household goods and furnishings are and shall be the sole and separate property of Wife to be delivered to Wife by Husband in accordance with paragraph 2b. of the attached Agreement: 1. oriental rug 2, Gold mirror 3 , Wooden men 4, Antique wooden horses 5, 3 horse pictures 6, 1 flower picture 7. 3 oriental ceramic pieces (1 plate; 2 vases) 8. Black lamp shades 9. Photography light 10. Wall sconces 11. Baker's rack 12. All knick-knacks and vases ,on baker's rack except one clear circular vase given to parties by Husband's mother and a cream-colored Lenox vase. 13. All Wife's clothing and personal effects LAW O"'IC:':. SNELDAl-:ER A BnE"NEMAN ... In r.=. Ir. - ~ N ~~1 ~~~ w~ if~ ...... t..'''' - . a: ..~.~ ~r-: (~ ~-! <:) rol .. 'I" n: ;:.~ ~.-; u. N W i_.... -"lU t:.I\'J i~ lLi l~U.. c:> :3 ... 10 0 "'... U , >- tr.l ':- 0; L~ ~ C'J :".J..~ . 0 tJ--:~ ~~~ Ll: (.);;T ~~ CI~:J .";.. n N ;.....V; i"r. LLI u.. C~ .._1..... .Jj;i: a:"J W I!. !.'~I FE Lt.l LJU... ~) ....: "-. 11_ In S 0 C'l U LAW OffiCI:_ SNELDAKER a BRENNEMAN CARLEE J, EISENHOWER, . IN THE COURT OF COMMON PLEAS OF . Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW THADDEUS G, EISENHOWER, NO, 95- 7~J.. CIVIL TERM Defendant : IN DIVORCE NOTICE TO DEFEND AND CLAIM 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 or relief requested in these papers by the plaintiff, You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce decree being handed down by the court. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, Carlisle. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from the list, All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW WHERE YOU CAN GET LEGAL HELP. Court Administrator One Courthouse square Carlisle, pennsylvania 17013-3387 (717) 240-6200 By orneys for Pla nt ff CARLEE J. EISENHOWER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW vs. THADDEUS G, EISENHOWER, Defendant NO. 95- IN DIVORCE CIVIL TERM COMPLAINT 1. The Plaintiff in this action is CARLEE J. EISENHOWER, an adult individual, who resides at 409 Deerfield Road, camp Hill, (Lower Allen Township), Cumberland County, Pennsylvania 17011. 2. The Defendant in this action is THADDEUS G, EISENHOWER, an adult individual, who resides at 106 Wilson Street, Bellefonte, Centre County, pennsylvania 16823. 3. Both the Plaintiff and the Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this complaint. 4. LAW 0'1"11:1:. SNELDAKER . BRENNEMAN The Plaintiff and Defendant were lawfully joined in marriage on April 4, 1992, at Lower Allen Township, Cumberland County, Pennsylvania, 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 6, Noither party is a member of the armed forces of the united states of America, 7, The Plaintiff avers as the grounds upon Which this action is based is that the marriage between the parties hereto is irretrievably broken. 8. The 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. 9. The Plaintiff requests the court to enter a decree of divorce, LAW nuna.. DNU.bAKtlt . Dntrmr.MAN WHEREFORE, Plaintiff, CARLEE J. EISENHOWER, prays your Honorable Court to enter a decree of divorce, divorcing the Plaintiff from the bonds of matrimony heretofore existing between the Plaintiff and the Defendant, -2- I verify that the statements made in the foregoing Complaint are true and correct, I understand that false statements herein are made sUbject to the penalties of 18 Pa. C,S, S 4904 relating to unsworn falsification to authorities, /" ,- /7 . /7 .~Zt,tC<- r(~L- v Carlee J, Eisenhower Plaintiff Date: February (0 , 1995 By ard C. Snelbaker 44 West Main street Mechanicsburg, PA 17055-0318 (717) 697-8528 Attorneys for Plaintiff LAW O"ICES SNElDAkER a BRENNEMAN -3- CARLEE J, EISENHOWER, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW THADDEUS G, EISENHOWER, Defendant NO. 95- IN DIVORCE CIVIL TERM AFFIDAVIT CAR LEE J. EISENHOWER, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Office of the Prothonotary, which list is available to me upon request, 3, Being so advised, I do NOT request that the court require my spouse and I participate in counseling prior to a divorce decree being handed down by the court. I understand that false statements herein are made subject to the penalties of 18 Pa. C,S, S 4904 relating to unsworn falsification to authorities, (U~~~ &L Carlee J. Eisenhower (Plaintiff) LAw O"ICt. SNELDAKER " BntNNEMAN Date: February /0 , 1995 . ~.~, .:',',~"':'.,~~.; .':. ~l,;-~~'I."':..' . . . ' . , ' " ,I, . 0 '. : ~ . o. ,. '\.'-' ';. :~ ',. ..~. . ot- 0'_"";(': oJ. i:'..t' '''tt;''"l . .,' ". '- . r, ..t,1 ...:.'....:' ...,.,',:,,\'- , ~ ........_--_:.-. -...........-- .1 C-, 1;- " '-.1 I,jJ:dJ'...' :".1""1 ..~_: ~ , f- a- UJ (" < ...f- "f- . c( (: 0 :r-;l,IZ 'l.Il' . r :Z:":O ::;.:_~":I: r'~ W jjf- :0:;.-=.0 . ,.;-' a: d-~.-;'lL 1j~1 \,.;::,,: c...?,: : r.~): : -:0 i : : U--'- : . " , .' . :: ,..) ~~ I \- I '" 'i1 --:J ..:., w'\ .- \ \.n '), ......... L;:"' "" -- --- \! 1 ~p ,.]j '-.:> r-... ~.~ f'\,\ ~ ",-., "-....9 'b"- l"- . .-l (......" '>L -- '. \:.) ~~\ ~. - ~ ~..: 0.... 1Il~ '.. ;5::- .... w I ...:: 'N t: :0- w " ,n I'< III P! t: '1:l . 'n ~?; '" 'M t: U a ci:i !-' ,. 'J ,~ !:: .... . .... ~d ~I'< ... . I'< '" ." ..~:l ~ ,. .... ~ '" '" o ...~..... '" :::: f-. z ~ 0 z Uj;j::: - Q ffi~~ ~ ::; Ul '- .. :<: :I: o. w ~~ U ;; > .., .... ..J w ~ o ~ u :.5 " 01 W lfl z".g ~ ~ . ~U~ III .... n. z~o Z ;; .. w u .... '" ~, I 7- 7- ::> 0 '" Q gj~? a 3 UJ ~ o~~ w . u o. . u;5U U ..,Pl6 'I. . , t:l .. 15 0 ",,,,":18 ., ~- o! . III c::: 0 a I) " ~ ~ :uw....JlI"'\.... '" ::; ~f ~ . ::> ....=HO'\I-'l '" '" :J '" _. c: ...l '" .. f rJ 'B"" . :? HO~ '" ~ "" ( ......uuz....= tJ ~~ Z !-' i u UJ :::; , ' " , ' . (Ai'! ~ ," If.' I' ,I.~ ~ .. u vs, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CARLEE J. EISENHOWER, Plaintiff THADDEUS G, EISENHOWER, Defendant NO, 95-762 CIVIL TERM IN DIVORCE PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Please reinstate the Complaint filed in the above matter February 13, 1995. SNELBAKER & BRENNEMAN, p, C. ~~ By: R chard C, Snelbaker, Esqu re Keith O. Brenneman, Esquire 44 West Main Street Mechanicsburg, PA 17055 (717) 697-8528 Attorneys for Plaintiff Car lee J, Eisenhower Date: July 7, 1995 LAw O"'lCU SNELDAKER 6 8nENNEM^N i I I I 1 LJ") c:T> -"., I - .r :-~ - ., s:. ,. @ B', I ..... e>..:.... M :.,' " j j r-- ,. j i ..... I => ~~l '-. , --, i , CARLEE J, EISENHOWER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs, CIVIL ACTION - LAW THADDEUS G, EISENHOWER, Defendant , . NO. 95-762 IN DIVORCE CIVIL TERM AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) . SS, . COUNTY OF CUMBERLAND ) William M. Thomas, being duly sworn according to law deposes and says: that I am an adult individual employed by the law firm of Snelbaker & Brenneman, P.C,; that on July 13, 1995 at 3:05 P,M, I did personally serve upon Thaddeus G, Eisenhower, defendant in the above captioned action, a duly certified copy of a complaint in divorce issued in the above case (said complaint having been reinstated on July 7, 1995) ~y handing the same to him and making known unto him the nature of the document, all at 44 West Main Street, Mechanicsburg, PA 17055; and that the foregoing facts are true and correct to the best of my knowledge, information and belief. WAt'u f( .'1-Z::"d,( Will1am M, Thomas ' LAW O"ICU 6NELOAKER 6 BREUUCMAN Sworn to and subscribed before me this /7t./. day of JUly, 1995, G7d<U'A~~) 9, ;:j;hL4~JL/ b-- tJfll,tt1dj Su:,1 PalnCln J ftlOrm;oll, NOliUY PubliC Mldlllrllr.!ibur~ UO(O. (uml)iHlnm1 cnuntr My l:flmnllr,l);on E.l~flj~ Dtj'. 31, 1-J'J1 Mo..;-;;;-; f"lnfryfillfilfl.::n:t:rtit...l (J t~.f;1(W\5 [:;;S ",:<j iJ> ~>l P<'" Si ~~ !:l alP< ~. ~ 8 ciS ~ [:;S,u o ~u5 o~S~ici!j u U",p:: "l <10 ll:: ~~e; E-<f9H Q z~e;ciz ....UUZH .' If, ~-:;.) "'- ,- (Jj ,;)) Q') ::: -. , ..... ..... '... U " . '... ~ ~ o ffi '" H "l , .., W W ~ & , Ul ;> u " .. . 't:l el " ~ ~ o <;J ffi Q '" H W ~~ p..~. ~~O ~ t; ~~.J :! ~~~ ~ ; ~i E I ~ :~~ ~ ~ ~~~ ~ 3 ml>l:< ~~ CIl , t:l '" ::> J w U H :>- el '" ~ o f-< H :>- Zi H ~ . " . . .. . \~;;i:':~::~~~:~'~"'~fb.~;;_;,t'~ 1.: ( 1Il 1Il g :S z ~ ~ " ~ ;;; OJ ~ .. .. g 0 :;:I ~. V .~ u OJ ::i . . . . .' . , ' , vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CARLEE J. EISENHOWER, Plaintiff THADDEUS G. EISENHOWER, Defendant NO. 95-762 CIVIL TERM AFFIDAVIT OF CONSENT 1. A complaint in Divorce under section 3301(c) of the Divorce Code was filed on February 13, 1995, and reinstated on July 7, 1995. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of 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. S 4904 relating to unsworn falsification to authorities, Date: December A, 1995 ~~ Thaddeus G. Eisenhower (Defendant) LAW OF....Cta SNELDAKt:R Il< BRCNNEMAN I , I, " ii >- In .... ;€ E::: ...:. I- ., -, .. WQ N ?'5 ~", [fb ::t: 6=::~ -.- ".~ 0- Cl~:j ~8 .. -' ".- N :-"(,") ,');,-: u. N .:.;;:;.:: ff!Jj '-' lUlU ~ Lt.f l.fJC=- 0 ...; U. In ::> 0 ell U . , . . . vs, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CARLEE J, EISENHOWER, Plaintiff THADDEUS G. EISENHOWER, Defendant NO, 95-762 CIVIL TERM AFFIDAVIT OF CONSENT 1. A complaint in Divorce under section 3301(c) of the Divorce Code was filed on February 13, 1995, and reinstated on July 7, 1995. 2, The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of 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. S 4904 relating to unsworn falsification to authorities. Date: December Iq , 1995 ~(~ Carlee J, E senhQwQr (Plaintiff) LAW Of FICCO 5NELD~KEA II BRENNCMAN [r, Ir) [; - "" ~ [:) N :::>.- ~-,. (.)r:': O.~'I ffCi c:: . ~. ~?j n..i ''''''_w (f': N ~;?' c,') u. N ..:! ~,..; to.) l.l......._ 'W tIJII..) Lt,l O)u.. t::J " . & ,t') ::i In U f . . .. . . . CARLEE J, EISENHOWER, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW THADDEUS G. EISENHOWER, Defendant NO. 95-762 CIVIL TERM AFFIDAVIT THADDEUS G, EISENHOWER, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2, I understand that the court maintains a list of marriage counselors in the Office of the Prothonotary, which list is available to me upon request, 3. Being so advised, I do NOT request that the court require my spouse and I participate in counseling prior to a divorce decree being handed down by the court. I understand that false statements herein are made subject to the penalties of 18 Pa, C,S. falsification to authorities, LAW O',IC[S SNELUAKER a BftENNE:M"N Date: December fer- ' 1995 ~ In ..... !"l; ~ b N :'~) .-~ ~I-~ (),;~ (.2c.5 ..- ()~::: Efr:i: 0- a.' c,...! () : ~-: ~.: 61'0: oN ,- '.. u.J u- N .~.I,/: I .W i.J~ ..; iL~ ~ II U t.; :~ ~ lJ.. tJ. In ::; 0 u' <.J " . .. . . . . . .