HomeMy WebLinkAbout95-03689
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF .. PENNA.
PATRICIA A. MASSIE.
........................... . ............Niiiiiffff..........
VerslIs
N I). ........3.~~?........ ................. 1995
Defeiidant
DECREE IN
DIVORCE
~D.......- 1..1. 9 96' d d
AND NOW. ...~............... 1 ....... It is or ere and
decreed that....... ..\~~~~~~~ .~: .~~~~:~....................... plaintiff.
and... .. .. ........ .. . ?~~~~~.~:. ~~.S.S.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; IA...Q~
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MARITAL DISSOLUTION AGRBRMBNT
TillS AGREEMENT, made this 1J,'th day of j..L Jp!.(,{a~ ,1996,
by and between PATRICIA A. MASSIE, of Camp Hill, Cumberland County,
Pennsylvania, hereinafter referred to as "WIFE", and DENNIS A.
MASSIE of Mechanicsburg, Cumberland County, Pennsylvania, herein-
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after referred to as "HUSBAND",
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WITNESSETH:
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WHEREAS, the parties hereto are Husband and Wife,
married June 22, 1985;
and
WHEREAS, certain differences have arisen between the parties
as a result of which they have separated and now live separate and
apart from one another, and are desirous of settling fully and
finally the respective financial and property rights and obligation
as between each other, including, without limitation by specifica-
tion: The settling of all matters between them relating to the
ownership of real and personal property, the equitable distribution
of real and personal property; and in general, the settling of all
matters between them relating to any and all claims and possible
claims by one against the other or against their respective
estates.
NOW, THEREFORE, in consideration of the above recitals and the
following covenants and promises mutually made and mutually to be
kept, the parties heretofore, intending to be legally bound and to
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legally bind their heirs, successors and assigns thereby, covenant,
promise and agree as follows:
1. AGREEMENT NOT A BAR TO DIVORCE PROCEEDINGS: This Agree-
ment shall not be considered to affect or bar the right of Husband
or Wife to a limited or absolute divorce on lawful grounds as such
grounds now exist or shall hereafter exist or to such defense. as
may be available to either party. This Agreement is not intended
to condone and not shall be deemed to be a condonation on the part
of either party hereto of any act or acts on the part of the other
party which have occasioned the disputes or unhappy differences
which have occurred prior to or which may occur subsequent to the
date hereof.
2. EFFEc'r OF DIVORCE DECREE: The parties 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. It is the
intent of the parties hereto that this Agreement shall create
contractual rights and obligations entirely independent of any
Court Order and that this Agreement may be enforced by contract
remedies in addition to any other remedies which may be available
pursuant to the terms of this Agreement or otherwise under law or
equity.
3. AGREEMENT TO BE INCORPORATED IN DIVORCE DECREE: The
parties agree that the terms of this Agreement shall be incorpor-
ated, but not merged, into any divorce decree which may be entered
--. .
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with respect to them. The parties further agree that the Court of
Common Pleas which may enter such divorce decree shall retain
continuing jurisdiction over the parties and the subject matter of
the Agreement for the purpose of enforcement of any of the
provisions thereof.
4. DATE OF EXECUTION: The date of execution" or "execution
date" of this Agreement shall be defined as the date upon whicp it
is executed by the parties if they have each executed this Agree-
ment on the same date. Otherwise, the "date of execution" or
"execution date" of this Agreement shall be defined as the date of
execution by the party last executing this Agreement.
5. ADVICE OF COUNSEL: The provisions of this Agreement and
its legal effect have been fully explained to the Wife by her
attorney, L. Rex Bickley, Esquire. Husband has chosen not to
obtain legal counsel although he has been advised that he may do so
and acknowledges that he is free to do so. The provisions of this
Agreement and their legal effect have also been fully explained to
Husband. The parties acknowledge that they fully understand the
facts and have been fully informed as to their legal rights and
obligations, and they acknowledge and accept that this Agreement
is, in the circumstances, fair and equitable and that is 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 any collusion or improper or illegal agreement or
agreements. The parties further acknowledge that they have each
made to the other a full accounting of their respective assets,
estate, liabilities, and sources of income and that they waive any
specific enumeration thereof for the purpose of this Agreement.
Each party agrees that he or she shall not at any future time raise
as a defense or otherwise the lack of such disclosure in any legal
proceeding involving this Agreement with the exceptio~ of
disclosure that may have been fraudulently withheld.
6. PERSONAL RIGHTS: Wife and Husband, at all times
hereafter, may and shall 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 may, for his or her separate use or benefit, conduct,
carry on and engage in any business, occupation, profession or
employment which to him or her may seem advisable. Wife and
husband shall not molest, harass, disturb or malign each other or
the respective families of each other or compel or attempt to
compel the other to cohabit or dwell, by any means or n any manner
whatsoever, with him or her.
7. s.l1BSEOUENT RECONCILIATION: The parties agree that the
terms of this Agreement shall not be affected by their subsequent
co-habitation or resumption of marital relations, unless the
parties otherwise specifically agree in writing.
S. MUTUAL RELEASES: Husband or Wife each do hereby mutually
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remise, release, quit-claim and forever discharge the other and the
estate of such other, for all time to come, and for all purposes
whatsoever, of and from any and all rights, title and interes~, or
claims in or against the property (including income and gain from
property hereafter accruing) of the other or against the estate of
such other, of whatever nature and wheresoever situated, which he
or she now has or at any time hereafter may have against the ot~er,
the estate of such other or any part thereof, whether arising out
of any former acts, contracts, engagements or liabilities as such
other or by way of dower or courtesy, or claims in the nature of
dower or courtesy or widow's or widower's rights, family exemption
or similar allowance, or under the intestate laws, or the right to
take against the spouse's will; or the right to treat a lifetime
conveyance by the other as a testamentary, or all other rights of
a surviving spouse to participate in a deceased spouse's estate,
whether arising under the laws of (a) Pennsylvania, (b) any
State, Commonwealth or territory of the United States, or (c) any
country or any rights which either party may have or at an~' time
hereafter shall have for past, present or future support or
maintenance, alimony, pendente lite, counsel fees, property of
division, costs or expenses, whether arising as a result of the
marital relations or otherwise, except, all rights and agreement
and obligations of whatsoever nature arising or which may arise
under this Agreement or for the breach of any provision thereof.
It is the intention of Husband and Wife to give each other by the
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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. It is
further agreed that this Agreement shall be and constitute a full
and final resolution of any and all claims which each of the
parties may have against the other for equitable division of
property, alimony, counsel fees and expenses, alimony pendente lite
or any other claims pursuant to the Pennsylvania Divorce Code or
the divorce laws of any other jurisdiction.
9. PERSONAL PROPERTY: With the exception of those items set
forth in Schedule A, Husband and Wife do hereby acknowledge that
they have divided or will divide in the near future their tangible
personal property, including, but without limitation, jewelry,
clothes, furniture and furnishings, rugs, carpets, household
equipment and appliances, pictures, books, works of art and other
personal property. All such property currently in possession of
Wife shall become the sole and exclusive property of Wife. All
such property currently in possession of Husband shall become the
sole and exclusive property of Husband. The parties do hereby
specifically waive, release, renounce and forever abandon whatever
claim, if any, he or she may have with respect to the above items
which shall become the sole and separate property of the other.
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The items of personal property listed in Schedule A shall
become the property of the Husband and the Wife hereby agrees to
convey said property at a time convenient to the parties.
10. AFTER-ACOUIRED PROPERTY: Each of the parties shall
hereafter own and enjoy, independently of any claim or right of the
other, all items of property, be they real, personal or mixed,
tangible or intangible, which are hereafter acquired by him or ~er,
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.
11. REAL ESTATE: The parties are the owners of a house
located at 2920 Chestnut Street, Camp Hill, CUmberland County,
Pennsylvania. Husband shall transfer his interest in said real
estate to the Wife. Wife will be solely responsible for the mort-
gage with PNC and agrees to indemnify and hold harmless Husband
therefrom. Wife will also be solely responsible for the Dauphin
Deposit Home Equity loan and agrees to indemnify and hold harmless
Husband therefrom. Husband agrees to execute a deed to the
property upon execution of this Agreement.
12. RETIREMENT ACCOUNTS AND PENSION PLANS: Husband is the
owner of a pension with his former employer, DuPont Company, a
substantial portion of which would be deemed marital property. In
consideration of the terms and conditions contained in this Agree-
ment, Wife hereby agrees that she waives any rights which she may
have to such pension plan.
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13. AUTOMOBILES: The parties are the owners of a 1989
Chevrolet Astro Van titled in both names. The Husband hereby
agrees to transfer his interest in said vehicle to the Wife which
shall become solely her property. The Husband further agrees to
execute any documents necessary to effectuate this transfer.
14 . CURRENT I,IABILITIES: Husband and Wife have
accumulated various debts during the marriage in addition to the
PNC mortgage and Dauphin Deposit home equity loan set forth above.
All debts set forth in Exhibit B to this Agreement shall be the
sole and separate responsibility of the Husband. All debts set
forth in Exhibit C of this Agreement shall be the sole and separate
responsibility of the Wife.
15. WAIVER OF PAYMENT OF LEGAL FEES: Wife shall be
responsible for payment of her legal fees. Husband shall be
responsible for payment of his legal fees.
16. ALIMONY AND ALIMONY PENDENTE LITE: Husband and Wife do
hereby waive, release and give up any other rights they may
respectfully have against the other for any alimony, support or
maintenance. It shall be, from the execution of this Agreement, the
sole responsibility of each of the respective parties to sustain
themselves without seeking any additional support from the other
party, except as provided herein.
17. MUTUAL CONSENT DIVORCE: The parties agree and
acknowledge that their marriage is irretrievably broken, that they
do not desire marital counseling, and they both consent to the
8
entry of a decree in divorce pursuant to ~3301(c) of the Pennsyl-
vania Divorce Code, Act 26 of 1980, as may be amended (herein
referred to as the Code). Accordingly, both parties agree to
execute such consents, affidavits, or other documents and to direct
their respective attorneys to file such consents, affidavits, or
other documents as may be necessary to promptly proceed to obtain
a divorce pursuant to said ~3301(c) of the Code. Upon request.. to
the extent permitted by the law and the applicable Rules of Civil
Procedure, the named defendant in such divorce action shall execute
any waivers of notice or other waivers necessary to expedite such
divorce.
18. 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 indemnity and hold the
other party harmless for 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.
19. WARRANTY AS TO FUTURE OBLIGATIONS: Husband and wife
covenant, warrant, represent and agree that with the exception of
obligations set forth in this Agreement, neither of them shall
hereafter incur any liability whatsoever for which the estate of
the other may be liable. Each party shall indemnify and hold
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harmless the other party for and against any and all debts, charges
and liabilities incurred by the other after the execution date of
this Agreement, except as may be otherwise specifically provided
for by the terms of this Agreement.
20. WAIVER OR MODIFICATION TO BE IN WRITING: No modification
or 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 default hereunder shall be deemed a waiver of any
subsequent default of the same or similar nature.
21. MUTUAL COOPERATION: Each party shall, at any time and
from time to time hereafter, take any and all steps and execute,
acknowledge and deliver to the other party any and all further
instruments 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.
22. APPLICABLE LAW: This Agreement shall be construed
under in accordance with the laws of the Commonwealth of
Pennsylvania which are in effect as of the date of execution of
this Agreement.
23. AGREEMENT BINDING ON HEIRS: This Agreement shall be
binding and shall inure to the benefit of the parties hereto and
their respective heirs, executors, adminiatrators, successors and
assigns.
24. OTHER DOCUMENTATION: Wife and Husband covenant and
agree that they will forthwith (and within at least ten (10) days
10
after demand therefor) execute any and all written instruments,
assignments, releases, satisfactions, deeds, notes or such other
writings as may be necessary or desirable for the proper
effectuation of this Agreement.
25. NO WAIVER OF DEFAULT: This Agreement shall remain in
full force and effect unless and until terminated under and
pursuant to the terms of this Agreement. The failure of either
party to insist upon strict performance of any of the provisions of
this Agreement shall in no way affect the right of such party
hereafter to enforce the same, nor shall the waiver of any default
or breach of any provision hereof be construed as a waiver of any
subsequent default or breach of the same or similar nature, nor
shall it be construed as a waiver of strict performance of any.
other obligations herein.
26. ENFORCEMENT OF AGREEMENT: If either party breaches
any provision of this Agreement, the other party shall have the
right, at his or her selection, to sue for damages for such breach
or to require specific performance. The party breaching this
Agreement shall be responsible for payment of legal fees and costs
incurred by the other party in enforcing their rights under this
Agreement or for seeking such other remedies of relief as may be
available to him or her.
27. SEVERABILITY: If any term, condition, clause or
provision of this Agreement shall be determined or declared to be
void or invalid in law otherwise, then only that term, condition,
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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 her or his 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.
28. HEADINGS NOT PART OF AGREEMENT:
Any headings 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.
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PATRICIA A. MASSIE
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C/J-.A At
DENNIS A. MASSIE
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Drums
Camera equipment
Navajo Dancer Suite (4)
Navy uniform
Tools
Stereo equipment, records, tapes, etc. (to be divided amicably)
Fishing equipment
Marine battery
Boat motor
Battery charger
pictures
Baseball glove
Books
Clothes
Jewelry box
Kitchen items (to be divided amicably)
TV
All other property to be divided by agreement of the parties.
EXHIBIT A
Sears Card
Bank One
CitiBank
Mellon Bank
IRS Obligation
Husband's Debts
1,000.00
$200-300.00
1,000.00
941. 09
527.95
EXHIBIT B
Wife's Debts
CitiBank
Choice
visa
Visa
IRS Obligation
900.00-1,000.00
4,700.00
400-500.00
900.00
800.00
SCHEDULE C
COMMONWEALTH OF PENNSYLVANIA
SS:
COUNTYOF !J"',"~
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On this, the " day of February, 1996, before me, a Notary
Public in and for said Commonwealth and County, personally appeared
patricia A. Massie known to me to be the person whose name is
subscribed to the within Agreement and acknowledged that she
executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and official
seal.
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Notary Public (SEAL)
My Commission Expires:
M01ARIAl SeAL
L Rell BIC~LE" ~ola~ I'ubflc
My c~~~r~s~~~'~:p~~:~nApg,~~ 1999
,.
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF de.,"-
SS:
On this, the I..... day of February, 1996, before me, a Notary
Public in and for said Commonwealth and County, personally appeared
Dennis A. Massie known to me to be the person whose name is
subscribed to the within Agreement and acknowledged that he
executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and official
seal.
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Notary Public (SEAL)
My Commission Expires:
NOTARI~L SEAL
L. REX BICKLEY r:utary pubnc
Harrr.bulg. Oaunn:n COl'nly
My Commission Elplles April 10. 1999
PATRICIA A. MASSIE,
plaintiff
No. 95-3689
Prothonotary
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS
Action in Divorce
DENNIS A. MASSIE,
Defendant
PRAECIPE TO TRANSMIT RECORD
1. Ground for divorce: irretrievable breakdown under Section
(33011cl) (3301 (d) (1)) of the Divorce Code.
2. Date and manner of service of the Complaint: First Class
Mail. Restricted Delivery. Certified Mail -- August 1. 1995
3.
required
February
(a) Date of execution of the Affidavit of Consent
by Section 3301(c) of the Divorce Code: by Plaintiff
12. 1996; by Defendant February 12. 1996
(b) Date of execution of the Plaintiff's Affidavit required
by Section 3301(d) of the Divorce Code:
(c) Date of execution of Waiver of Notice of Intention to
Request Entry of A Divorce Decree Under ~3301(c) of the Divorce
Code: By Plaintiff: 2/12/96; By Defendant: 2/21/96
and, date of service of the Plaintiff's Affidavit upon the
Defendant:
4. Related claims pending:
pendinq.
5. Date and manner of service of notice of intention to file
praecipe to transmit the record, a copy of which is attached, if
the decree is to be entered under Section 3301 (d) (1) (i) of the
Divorce Code.
There are no related claims
(plaintiff)
ckley
PATRICIA A. MASSIB,
Plaintiff
vs.
IN THB COURT OF COMMON PLEAS OF
CUMBBRLAND COUNTY, PENNSYLVANIA
NO. 95-3689
CIVIL ACTION - LAW
IN DIVORCE
DENNIS A. MASSIE,
Defendant
Waiver of Notice of Intention to Request
Entry of a Divorce Decree Under
~3301(c) of the Divorce Code
1. I consent to the entry of a final decree of divorce
without notice.
2. I understand that I may lose rights concerning alimony,
division of property, lawyer's fees or expenses if I do not claim
them before a divorce is granted.
3. I understand that I will not be divorced until a divorce
decree is entered by the Court and that a copy of the decree will
be sent to me immediately after it is filed with the prothonotary.
I verify that the statements made in this affidavit are true
and correct. I understand that false statements herein are made
subject to the penalties of 18 Pa. C.S.A. ~4904 relating to unsworn
falsification to authorities.
Date:
j/u Jq(,
I I
~~G .17itVJ~
Patricia A. Massie, Plaintiff
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PATRICIA A. MASSIB,
Plaintiff
IN THB COURT OF COMMON PLEAS OF
CUMBBRLAND COUNTY, PENNSYLVANIA
NO. 95-3689
vs.
DENNIS A. MASSIE,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
Waiver of Notice of Intention to Request
Entry of a Divorce Decree Under
~3301(c) of the Divorce Code
1. I consent to the entry of a final decree of divorce
without notice.
2. I understand that I may lose rights concerning alimony,
division of property, lawyer's fees or expenses if I do not claim
them before a divorce is granted.
3. I understand that I will not be divorced until a divorce
decree is entered by the Court and that a copy of the decree will
be sent to me immediately after it is filed with the prothonotary.
I verify that the statements made in this affidavit are true
and correct. I understand that false statements herein are made
subject to the penalties of 18 Pa. C.S.A. ~4904 relating to unsworn
falsification to authorities.
Date:
~~9C.
(7).- ~ A!~
ennis/A. "Massie, Defendant
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PATRICIA A. MASSIE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. q~'- 3ft-a? (I.t.~
CIVIL ACTION - LAW
IN DIVORCE
vs.
DENNIS A. MASSIE,
Defendant
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 this 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 the divorce is indignities or
irretrievable breakdown of the marriage, you may request marriage
counselling. A list of marriage counsellors is available in the
Office of the Court Administrator, CUmberland County Courthouse,
Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER \ S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED,
YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
COURT ADMINSTRATOR
Fourth Floor
CUmberland County Court House
1 Court House Square
Carlisle, Pennsylvania 17013
(717) 240-6200
AVISO PARA DEFENDER Y RECLAMAR DERECHOS
USTBD HA SIDO DEMANDADO EN LA CORTE. Si desea defenderse de
las quejas expuestas en las paginas siguientes, debe tomar accion
con prontitud. Se le avisa que si no se defiende, el caso puede
proceder sin used y decreto de divorcio 0 anulamiento puede ser
emitido en su contra por la Corte. Una decision puede tambien ser
emitida en su contra por cualquier otra queja 0 compensacion
reclamados por el demandante. Used puede perder dinero, 0
propiedades u otros derechos importantes para usted.
CUando la base para el divorcio es indignidades 0 rompimiento
irreparable del matrimonio, used puede solicitar consejo
matrimonial. Una lista de consejeros matrimoniales esta disponible
en la oficina del Court Administrator, CUmberland County
Courthouse, Carlisle, Pennsylvania.
SI USBD NO RBCLAMA PENSION ALIMBNTICIA, PROPIBDAD MARITAL,
HONORARIOS DE ABOGADO U OTROS GASTOS ANTES DE QUE EL DECRBTO FINAL
DB DIVORCIO 0 ANULAMIBNTO SEA EMITIDO, USED PUEDB PBRDBR EL DBRECHO
A RBCLAMAR CUALQUIBRA DE ELLOS.
USTED DBBE LLEVAR BSTB PAPBL A UN ABOGADO DE INMBDIATO. SI NO
TIBNE 0 NO PUEDB PAGAR UN ABOGADO, VAYA 0 LLAME A LA OFICINA
INDICADA ABAJO PARA AVBRIGUAR DONDE PUEDE OBTENBR ASISTBNCIA LBGAL.
COURT ADMINSTRATOR
Fourth Floor
CUmberland County Court House
1 Court House Square
Carlisle, Pennsylvania 17013
(717) 240-6200
, .
.
PATRICIA A. MASSIE,
plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 1:[ :If., i'l c.~..<-rr;<.....
CIVIL ACTION - LAW
IN DIVORCE
vs.
DENNIS A. MASSIE,
Defendant
COMPLAINT IN DIVORCE
AND NOW, comes the Plaintiff, patricia A. Massie, through her
attorney, L. Rex Bickley, Esquire, who hereby files the following
Complaint in Divorce:
1. The plaintiff, patricia A. Massie, is an adult individual
who presently resides at 2920 Chestnut Street, Camp Hill,
Cumberland County, Pennsylvania 17011.
2. The Defendant, Dennis A. Massie, is an adult individual
whose residence is 2920 Chestnut Street, Camp Hill, Cumberland
County, Pennsylvania 17011.
3. The parties were married on June 22, 1985, in Harrisburg,
Dauphin County, Pennsylvania.
4. There have been no prior actions of divorce or annulment
between the parties.
5. The Plaintiff has been advised of the availability of
counselling and the right to request that the Court require the
parties to participate in counselling.
6. The Defendant is not a member of the Armed Services of the
United States or any of its allies.
7. The marriage is irretrievably broken.
,
.
8. The plaintiff avers that the grounds on which the action
are as follows:
A. Defendant has committed' adultery. (3301(a))
B. Defendant has offered such indignities to the innocent
and injured spouse as to render her condition intolerable
and life burdensome. (3301(a))
C. The marriage is irretrievably broken. (3301(C))
COUNT ~l
Eqpitable Distribution
9. Paragraphs 1 through 8 hereof are incorporated herein as
set forth by reference.
10. The Plaintiff and Defendant are the owners of marital
property and the Plaintiff requests that the Court equitably divide
the marital property.
WHERBFORE, Plaintiff requests this Court to:
(A) Enter a decree in divorce between the parties.
(B) Equitably divide the marital property.
(C) For such other relief as deemed appropriate and
equitable.
Respectfully submitted,
ey
17101
.
VERIFICATION
I, patricia A. Massie, verify that the statements made in this
Divorce Complaint are true and correct to the best of my
information, knowledge and belief. I further understand that false
statements made herein are subject to the penalties of 18 Pa.
C.S.A. ~4904 relating to unsworn falsification to authorities.
Date: z/,o/~ J
Jl~ C. \:]1\ nJ.1A.J
PATRICIA A. MASSIE
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PATRICIA A. MASSIB,
Plaintiff
IN THB COURT OF COMMON PLEAS OF
CUMBBRLAND COUNTY, PENNSYLVANIA
NO. 95-3689
CIVIL ACTION - LAW
IN DIVORCE
VB.
DENNIS A. MASSIE,
Defendant
AFFIDAVIT OF CONSENT
1. A Complaint in divorce under Section 3301(c) of the
Divorce Code was filed on June 11, 1995.
2. The marriage of plaintiff and defendant is irretrievably
broken and ninety (90) days have elapsed from the date of filing
the Complaint.
3. I consent to the entry of a final decree of divorce after
service of notice of intention to request entry of the divorce.
I verify that the statements made in this affidavit are true
and correct. I understand that false statements herein are made
subject to the penalties of 18 Pa. C.S.A. ~4904 relating to unsworn
falsification to authorities.
Date:
dA /;:11 ti r,
~~nis~,~ssie, Defendant
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PATRICIA A. MASSIB,
Plaintiff
vs.
IN THB COURT OF COMMON PLEAS OF
CUMBBRLAND COUNTY, PENNSYLVANIA
NO. 95-3689
CIVIL ACTION - LAW
IN DIVORCB
DENNIS A. MASSIB,
Defendant
AFFIDAVIT OF CONSENT
1. A Complaint in divorce under Section 3301(c) of the
Divorce Code was filed on June 11, 1995.
2. The marriage of plaintiff and defendant is irretrievably
broken and ninety (90) days have elapsed from the date of filing
the Complaint.
3. I consent to the entry of a final decree of divorce after
service of notice of intention to request entry of the divorce.
I verify that the statements made in this affidavit are true
and correct. I understand that false statements herein are made
subject to the penalties of 18 Pa. C.S.A. ~4904 relating to unsworn
falsification to authorities.
Date:
~/I;}'/9('
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Patricia A. Massie, Pla~ntiff
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PATRICIA A. MASSIE,
plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 95-3689
DENNIS A. MASSIE,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
CERTIFICATE OF SERVICE
I, L. Rex Bickley, hereby certify that on the August 1, 1995,
I served a copy of the above captioned Divorce Complaint by
depositing the same in the United States Mail, Restricted Delivery,
Certified Mail, Return Receipt Requested, at the Defendant's
address at c/o Arthur Buckwalter, 933-A Nixon Drive, Mechanicsburg,
Cumberland County, pennsylvania, a copy of the return receipt of
which is attached hereto.
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L. ReX~ley
121 So Street
Harrisburg, PA 17101'
(717) 234-0577
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IN THE COURT OF cmNON PLEAS 01' r:UfllllmLAlIll COUNTY. PENNSYL'/ANIA
CIVIL ACTION - LAW
PATRICIA A. MASSIE.
Plaintiff
~:O.
3689 CIVIL 1995
VB.
DENNIS A. MASSIE,
Defendant
ACTION [~ DIVORCE
:lOTlCE OF ZLECTlm: TO RETA::r. FOIC.fER :m1E
Notice is hereby given that th.. Plaintiff in the ablJ'Ie IlI3tter. havinll been
granted a Final Decree in divorce from :he bonds of matrimony on the 26th
day of Fp-hrllArv
. 1996 . hereby elects to retake and hereafter use
her previous name of Pntrfrfn Ann
Afrirn
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P ricia Afric Massie
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Patricia Ann Africs
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To Be Known As:
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF 0.., ~. ,
55.
On the ? $' 7' day of ,...,( t, . 1936 . before me. a Notary
Public, personally appeared t'. 1,,<., .. 11-(".. ( ... . known to me to be the
person whose name is subscribed to the within document. and acknowled~ed that she
executed the foregoing for the purpose therein contained.
IN WITNESS WHEREOF. I have hereunto set my h:1Od and ~lotari31 Seal.
---;i~TARIM. SE~L
L "tX oICKLEY. NOlal! ('ubUC
Harrtsburg, Dauphin C".'nly 999
My Commission ~res April 10, 1
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NOTARY PU3.~
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