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lYOV 1 'i 1997
MARK D, ANDERSON,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO, 3717 - 1995
vs.
CIVIL ACTION-LAW
ANNA MARIE ANDERSON
Defendant
IN DIVORCE
aM pjECOInu
AND NOW, this ~ day of , 1997, upon considefation of the Plaintiffs
Motion fOf Entry of Domestic Relations Ofdef and the auached Stipulation fOf the Entry of
"Domestic Relations Ofdef", it is hefeby ORDERED and DECREED that the terms of said
Stipulation afe hefeby incorpofated and made a paft hefeof as if set fonh at length.
By the COUrI,
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COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, I'ENNSYL VANIA
Mafk D. Anderson
PlaintilT
: FAMILY DIVISION
: NO. 3717 - 1995
VS,
Anna Mafie Andefson
Defendant
: IN DIVORCE
MOTION FOR ENTRY OF DOMESTIC RELATIONS ORDER
AND NOW, comes the PlaintilTby his allomeys, Purcell, Krug & Hallef, who moves fOf
the entry of a Domestic Relations Ofdef in the ubove captioned mallef, and in SUPPOrl thefeof
avers the following:
I. A Divofce DeCfee was entefed by the COUrl on Novembef 15, 1996 in the above
captioned mallef. The terms of the Sepuration und Properly Selllement Agreement between the
parties was incorporated thefein,
2. By the terms of the Separation and Pfoperly Selllement Agfeement dated Septembef
23, 1996, the parties agfeed that a Qualified Domestic Relations Order would be entered by the
COUrl concurrent with Of subsequent to the cntry of the Decfce in Divorce,
3. The parlies huve stipulated to the entry of such an Ordef, the ofiginal which is attached
to this Motion, duly signcd by both parlies,
WHEREFORE. thc Pluintill'fcqucsls this Honorublc Courlto conlirll1thc Stipulation of
the parlics and cntcf thc Domcstic Relations Ofdcr inthc Ihml ullachcd hcrcto,
Respectfully submillcd,
PURCELL, KRUG & HALLER
BY
o n W. PUfccll, Jr.
. 29955
1719 North Ffont Stfeet
Harrisbufg, PA 17102
717 234-'1178
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COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Mark D. Anderson
Plaintiff
FAMILY DIVISION
NO, 3 7/ 7 - I ? 'i'..r
vs.
Anna Maria Anderson
Defendant
IN DIVORCE
STIPULATION FOR THE ENTRY OF "DOMESTIC RELATIONS ORDER"
AND NOW, this (, day of JVOllt...{,,'tf.... , 19 97 , the parties, Mark D.
Anderson, Plaintiff, and Anna Maria Anderson, Defendant, do hereby Agree and Stipulate as
follows:
1. The Defendant, Anna Maria Anderson (hereinafter referred to as "Member") is a
member of the Commonwealth of Pennsylvania, State Employes' Retirement System
(hereinafter referred to as "SERS").
2. SERS, as a creature of statute, is controlled by the State Employes' Retirement
Code, 71 Pa. C,S. ~~5101-5956 ("Retirement Code"),
3. Member's date of birth is April 29, 1959, and her Social Security number is
177-54-0459,
4. The Plaintiff, Mark D. Anderson (hereinafter referred to as "Alternate Payee") is the
former spouse of Member. Alternate Payee's date of birth is October 8, 1954, and his Social
Security number is 195-46-2555,
5, Membor's last known moiling address is:
102 Hillcrest Road
Camp Hill, PA 17011
6. Alternate Payee's current mailing address is:
3812 Hearthstone Road
Camp Hill, PA 17011
It is the responsibility of Alternate Payee to keep a current mailing address on file
with SERS at all times,
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DRO
Page 2
7, (a) The marital property component of Member's retirement benefit equals the
Member's retirement benefit accrued on December 31, 1994 (based upon the Member's final
average salary on December 31, 1994, and based upon the Member's service under SERS on
December 31, 1994) multiplied by a reduction factor if payments commence to Member before
her superannuation age multiplied by the number of months the Member was employed by the
Commonwealth of Pennsylvania from October 20, 1984, through December 31, 1994, divided by
the total number of months the Member was employed by the Commonwealth of Pennsylvania
as of December 31, 1994.
(b) Fifty percent (50%) of the marital property component of Member's retirement
benefit is to be allocated to the Alternate Payee os his equitable distribution portion of this
marital asset.
8. Member's retirement benefit is defined as all monies paid to or on behalf of Member
by SERS, including any lump sum withdrawals or scheduled or ad hoc increases, but
excluding the disability portion of any disability annuities paid to Member by SERS or any
deferred compensation benefits paid to Member by SERS. The equitable distribution portion of
the marital property component of Member's retirement benefit, as set forth in Paragraph
Seven (7) shall be payable to Alternate Payee and shall commence as soon as administratively
feasible on or about the date the Member actually enters pay status and SERS approves a
Domestic Relations Order incorporating this Stipulation and Agreement, whichever is later,
9, The term and amounts of Member's retirement benefits payable to the Alternate
Payee after SERS approves a Domestic Relations Order incorporating this Stipulation and
Agreement is dependent upon which option(s) is (are) selected by Member upon retirement,
Member and Alternate Payee expressly agree that, at the time that the Member files a
retirement application with SERS, the Member may select any retirement option offered by
SERS under the Retirement Code at the time Member files an application for retirement with
SERS.
If the Member elects to receive 011 or 0 portion of her accumulated deductions, the
Alternate Payee is entitled to a portion of such deductions, The portion the Alternate Payee is
entitled to is determined by dividing the amount of the accumulated deductions the Member
elects to receive by the total amount of her accumulated deductions and multiplying this ratio
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DRO
Page 3
by 50% of the Member's accumulated deductions on December 31, 1994, accumulated with
intereut at the rate of 4% per year compounded annually since December 31, 1994, The
Alternate Payee Is also entitled to 50% of the balance of the marital component of Member's
retirement benefit, such balance is the marital component of Member's retirement benefit as
defined in Paragraph 7(a) less any refund of accumulated deductions to which the Alternate
Payee is entitled under this Paragraph 9.
10. Alternate Payee may not exercise any right, privilege or option offered by SERS.
SERS shall issue individual tax forms to Member and Alternate Payee for amounts paid to
each.
11. In the event of the death of Alternate Payee prior to receipt of all of his payments
payable to him from SERS under this Order, any post-retirement death benefit or any
retirement benefit payable to Alternate Payee by SERS shall revert to the Member.
12. Member hereby nominates Alternate Payee as an irrevocable beneficiary to the
extent of Alternate Payee's equitable distribution portion of Member's retirement benefit for
any post-retirement death benefits payable by SERS. This nomination shall become effective
upon approval by the Secretory of the Retirement Board, or his authorized representative, of
any Domestic Relations Order incorporating this Stipulation and Agreement. The balance of
any post-retirement death benefit remaining after the allocation of Alternate Payee's equitable
distribution portion ("Balance") shall be paid to the beneficiaries named by Member on the last
Nomination of Beneficiaries Form filed with the Retirement Board prior to Member's death.
(a) If the last Nomination of Beneficiaries Form filed by Member prior to Member's
death (a) predates any approved Domestic Relations Order incorporating this Stipulation and
Agreement, and (b) names Alternate Payee as a beneficiary, then: (1) the terms of the Domestic
Relations Order shall alone govern Alternate Payee's share of any post-retirement death
benefit, and (2) for purposes of paying the Balance via the last Nomination of Beneficiaries
Form filed with the Retirement Board prior to Member's death, Alternate Payee shall be
treated as if Alternate Payee predeceased Member, No portion of the Balance shall be payable
to Alternate Payee's estate,
(b) In addition, Member sholl execute and deliver to Alternate Payee an
authorization, in a form acceptable to SERS, which will authorize SERS to release to Alternate
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DRO
Page 4
payee all relevant information concerning Member's retirement account. Alternate Payee
shall deliver the authorization to SERS which will allow the Alternate Payee to check that he
has been and continues to be proporly nominated under this paragraph,
13. In no evont shall Alternate Payee have greater benefits or rights other than those
which are available to Member. Alternate Payeo is not entitled to any benefit not otherwise
provided by SERS. The Alternate Payee is only entitled to the specific benefits offered by SERS
as provided in this Order. All other rights, privileges and options offered by SERS not granted
to Alternate Payee by this Order are pfeserved for Member.
14. It is specifically intended and agreed by the parties hereto that this Order:
(a) Does not require SERS to provide any type or form of benefit, or any option not
otherwise provided under the Rotirement Code;
(b) Does not require SERS to provide increased benefits (determined on the basis of
actuarial value) unless increased benefits are paid to Member based upon cost of living or
increases based on other than actuarial values,
15. The parties intend and agree that the terms of this Stipulation and Agreement shall
be approved, adopted and entefed as a Domestic Relations Order.
16. The Court of Common Please of Cumberland County, Pennsylvania, shall retain
jurisdiction to amend any Domestic Relations Order incorporating this Stipulation and
Agreement, but only for the purpose of establishing it or maintaining it as a Domestic
Relations Order; provided, however, that no such amendment shall require SERS to provide
any type or form of benefit, or any option not otherwise provided by SERS, and further provided
that no such amendment or right of the Court to so amend will invalidate this existing Order.
17, Upon entry as a Domestic Relations Order, n certified copy of the Domestic
Relations Order and this Stipulation and Agreement and any attendant documents shall be
served upon SERS immediately. The Domestic Relations Order shall take effect immediately
upon SERS approval and SERS approval of any attendant documents and then shall remain in
effect until further Order of the Court,
. . .
DRO
Page 5
WHEREFORE, the parties, intending to be legally bound by the terms of this Stipulation
and Agreement, do hereunto place their hands and seals.
BY THE COURT
Plaintiff/Alternate Payee
i()"l.-hol ,(}~U.'tl. a./<dL./..\UYo.../
DefendantlMernber
~Ltu,~~
~ttorney for Defend tlMernber
Attorney for Plaintiff/Alternate Payee
. ,
DRO
Page 5
WHEREFORE, the pafties, intending to be legally bound by the terms of this Stipulation
and Agreement, do hereunto place their hands and seals,
BY THE COURT
~~J ~pJ
PI'; itTIAI..m,'C2
Atto e for Plaintiff/Alternate Pa ee
DefendanVMember
Attorney for DefendanVMember
CERTIFICATE OF SERVICE
I. John W. Purcell. Jf., Attorney fOf the Plaintiff, hefeby ceftify that a true and correct
copy of the fOfegoing was sefved on the Defendant by sending said copy to her attorney of recofd,
by fifst class U.S. mail on November 10, 1997:
Sandfa L. Meilton, Esquife
Hepfofd, swaftz & MOfgan
111 North Ffont Stfeet
P.O. Box 889
Harrisbufg, PA 17108-4121
W. PURCELL, JR,
, NO, 29955
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ANNA MARIA ANDERSON
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DECREE IN
IVORCE;t 3:o&fJA.
.. .. , .. .. .. . .l..>-, 1996..... it is ordered and
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d d h Mark D. Anderson I' 'ff
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and, . , ,. " ., , , , , ,. ,~~~~ ,~~~~~ ,~~~~~~~~, . " ., , , " , , , , .' , , , ..., 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;
The terms of the Separation and Property Settlement Agreement between the
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but shall not merge in the final Divorce Decree between the parties.
.", ,Any.existing,spousal,support,order,shall,hereinafter,be, deemed, an' order for
alimony pendente lite if any economic claims remain pending.
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SEPARATION AND PROPERTY SETI'LEMENT AGREEMENT
THIS AGREEMENT, made tWs .JJ!!day of S r (,"",-, 1996, by and between
Mark D. Anderson, hereinafter referred to as "Husband", and Anna Maria Anderson,
"
hereinafter referred to as "Wife",
WITNESSETH:
WHEREAS, Husband and Wife were lawfully married on October 20, 1984; and
WHEREAS, no cWldren were born of tWs marriage; and
WHEREAS, certain differences have arisen between the parties as a result of wWch
they separated on December 31, 1994 and now live separate and apart from one another, and
are desirous, therefore, of entering into an Agreement wWch will distribute their marital
property in a manner wWch is considered to be an equitable division of all joint property, and
will provide for the mutual responsibilities and rights growing out of the marriage
relationsWp; and
WHEREAS, there has been a complete disclosure of the earnings and property of
each party, and each understands Wslher rights under the Divorce Code of the
Commonwealth ,of Pennsylvania; and
WHEREAS, the parties hereto, after being properly advised by their respective
counsel, Husband by Ws attorney, John W. Purcell, Jr. and Wife by her attorney, Sandra L.
Meilton have come to the agreement, wWch follows:
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, covenant, promise and agree as follows:
Separation and Property Settlement Agreement. M81'k D. AnderBon/Anna Merle AnderBon
Page 2
1. Sepamtlon. It shall be lawful for each party at all times hereafter to live separate
and apart from the other party at such place that he or she may from time to time choose or
deem fit. The foregoing provision shall not be taken as an admission on the part of either
party of the lawfulness of the causes leading to their living apart.
2. Intederence. Each party shall be free from interference, authority and contact by
the other, as fully as if he or she were single and unmarried, except as may be necessary to
carry out the provisions of tWs Agreement. Neither party shall molest the other nor attempt
to endeavor to molest the other, nor compel the other to cohabit with the other, nor in any way
harass or malign the other, nor in any way interfere with the peaceful existence, separate and
apart from the other.
3. Wife's Debts. Wife represents and warrants to Husband that since the separation
she has not and in the future she will not contract or incur any debt or liability for wWch
Husband or Ws estate might be responsible and shall indemnify and save Husband harmless
from any' and all claims or demands made against Wm by reason of debts or obligations
incurred by her.
4. Husband's Debts. Husband represents and warrants to Wife that since the
separation he has not and in the future he will not contract or incur any debt or liability for
wWch Wife or her estate might be responsible and shall indemnify and save Wife harmless
from any and all claims or demands made against her by reason of debts or obligations
incurred by WID.
5. Outstanding Joint Debts. The parties acknowledge and agree that they have no
outstanding debts and obligations incurred prior to the signing of tWs Agreement, except as
follows: (a) Home Mortgage
(b) Home Equity Loan
(c) PSECU Visa
(d) Fulton Bank Mastercard
(e) Credit Cards consisting of:
(1) American Express # 378248412161001
(2) Texaco # 708795196347001
(3) Builders Square # 713841775404598
.
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Se 81'atlon and Pro ert Settlement A eement . M81'k D. AnderBon/ Anna Marie AnderBon
Pa e3
(4) Hechts # 136619490
(5) Boscov's # 003009084
(6) BonTon # 052194636060
(7) JC Penney's # 01964097341
(8) Sears # 5484095753530
(9) Montgomery Wards # 115242024
(10) Express # 331928861
(11) VISA # 4121340000204871
(f) Members First Visa
(g) Nissan Car Loan
Wife agrees to assume full responsibility for payment and ultimate satisfaction of the
debts above listed letters (a) through (e), and Husband agrees to assume full responsibility
for payment and ultimate satisfaction of the remaining debts (f) and (g), and each party shall
indemnify, defend and hold the other party harmless on account of each such obligation
assumed by the other, such indemnification to include actual attorney's fees.
In the event that either party contracted or incurred any debts since the date of
separation, the party who incurred said debt shall be responsible for the payment thereof,
regardless of the name in wWch the account may have been charged, and such party shall
indemnify, defend and hold the other party harmless from any claim or demand made against
that party by reason of such debt.
6. Equitable Distribution of Marital Property. The parties have attempted to
distribute their marital property in a manner wWch conforms to the criteria set forth in g3501
et. seq. of the Pennsylvania Divorce Code and taking into account the following
considerations: the length of marriage; the fact that it is the first marriage for Husband and
Wife; the age, health, station, amount and sources of income, vocational skills, employability,
estate, liabilities and needs of each of the parties; the contribution of each party to the
education, training or increased earning power of the other party; the opportunity of each
party for future acquisitions of capital assets and income; the sources of income of both
parties, including but not limited to medical, retirement, insurance or other benefits; the
contribution or dissipation of each party in the acquisition, preservation, depreciation or
.'
Separation and Property Settlement Agreement. Mark D. AnderBOn/Anna Marie AnderBOn
Page 4
appreciation of the marital property, including the contribution of each spouse as a
homemaker; the value of the property set apart to each party; the standard of living of the
parties established during the marriage; and the economic circumstances of each party at the
time the division of property is to become effective,
The division of existing marital property is not intended by the parties to constitute
in any way a sale or exchange of assets, and the division of being effected without the
introduction of outside funds or other property not constituting marital property. The division
of property under tWs Agreement shall be in full satisfaction of all marital rights of the parties.
A. Distribution of Personal Property.
The parties hereto mutually agree that they have effected a satisfactory division of
the furniture, household fumisWngs, appliances, and other household personal property
between them, and they mutually agree that each party shall from and after the date hereof
be the sole and separate owner of all such tangible personal property presently in Ws or her
possession, except as set forth in Exhibit A attached hereto, wWch items shall be distributed
in accordance with Exhibit A, and tWs Agreement shall have the effect of an assignment or
bill of sale from each party to the other for such property as may be in the individual
possession of each of the parties hereto and as set forth in Exhibit A.
The parties hereto have divided between themselves, to their mutual satisfaction,
all items of tangible and intangible marital property. Neither party shall make any claim to
any such items of marital property, or of the separate personal property of either party, wWch
are now in the possession and/or under the control of the other, or wWch property will be
distributed in accordance with Exhibit A attached hereto. It is understood that any property
located in the marital residence shall become the sole and exclusive property of Wife unless
an item is specifically listed as Husband's on the attached ExWbit A. Should it become
necessary, the parties each agree to sign, upon request, any titles or documents necessary
to give effect to tWs paragraph. Property shall be deemed to be in the possession or under the
control of either party if, in the case of tangible personal property, the item is physically in the
possession or control of the party at the time of the signing of tWs Agreement and, in the case
of intangible personal property, if any physical or written evidence of ownersWp, such as
passbook, checkbook, poliCY or certificate of insurance or other similar writing is in the
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Sep81'etlon and Property Settlement AlJI'eement. M81'k D. AnderBOn/Anna Merle AnderBon
Pego 6
possession or control of the party. Except as set forth herein, Husband and Wife shall each
be deemed to be in the possession and control of their own individual pension or other
employee benefit plans or retirement benefits of any nature to wWch either party may have
a vested or contingent right or interest at the time of the signing of tWs Agreement, and
neither will make any claim against the other for any interest in such benefits, except as
stated herein.
From and after the date of the signing of tWs Agreement, both parties shall have
complete freedom of disposition as to their separate property and any property wWch is in
their possession or control, pursuant to tWs Agreement, and may mortgage, sell, grant,
convey, or otherwise encumber or dispose of such property, whether real or personal, whether
such property was acquired before, during or after marriage, and neither Husband nor Wife
need join in, consent to, or acknowledge any deed, mortgage, or other instrument of the other
pertaining to such disposition of property.
B. Distribution of Real Estate.
Husband shall transfer to Wife concurrent with the payment made in Paragraph 6(c)
below, all of his interest in and title to their jointly owned real estate at 102 Hillcrest Road,
Camp Hill, Pennsylvania 17011, in exchange for wWch Wife agrees to refinance the mortgage
obligation to Source One and to make all Payments on any subsequent mortgage, as well as
for the payment of all taxes, insurance and utillty bills incurred after August 31, 1996, relative
to said real estate. Wife covenants and agrees to pay and discharge said obligations on said
premises, and agrees to indemnify Husband from any loss by reason of her default in the
payment thereof, and agrees to save Husband harmless from any future liability with regard
thereto (provided Husband's interest in the real estate is transferred pursuant to this
paragraph), including the cost of defense and actual counsel fees incurred to defend against
an action brought against WID by virtue of her default.
Husband shall vacate the premises on or before August 31,1996.
C. Cash Distribution.
In consideration for the transfer of the above referenced real estate, Wife shall pay
to Husband the sum of $25,509.50 on or before October 15, 1996 or the date of Husband's
settlement on the purchase of a new home, wWchever shall last occur.
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Sep81'atlon and Property Settlement AlJI'eement. M81'k D. AnderBon/Anna Merle AnderBOn
Page 6
.
D. Income Tax Deduction. Husband shall be entitled to claim one-half ('I.) of the first
eight mortgage interest payments as a deduction on Ws 1996 Income Tax Return. Wife shall
be entitled to claim one-half ('I.) of the first eight mortgage interest payments and the total
mortgage interest payments for the last four mortgage payments as a deduction on her 1996
Income Tax Return.
7. Vehicles. Notwithstanding Paragraph 6 of tWs Agreement, Husband shall retain
possession and ownersWp of the 1973 MGB and 1993 Nissan presently in Ws possession. Wife
hereby transfers all of her right, title and interest in said veWcle to Husband. In consideration
thereof, Husband shall assume full responsibility for payment and eventual satisfaction of any
and all liens presently encumbering the veWcle, and to indemnify, defend and hold Wife
harmless for the same. Wife hereby agrees to sign any title or other documents necessary to
transfer ownersWp of said veWcle at any time, upon demand, and further shall indemnify
Husb~d for any costs, including actual counsel fees, incurred by Husband to enforce this ~
provisi~n. Husband shall effectuate the transfer of title as soon as is practical. As long as * --171..oCl '
Notwithstanding Paragraph 6 oftWs Agreement, Wife shall retain possession and
ownersWp of the 1987 Toyota Carnry presently in her possession. Husband hereby transfers
all of his right, title and interest in said veWcle to Wife. In consideration thereof, Wife shall
assume full responsibility for payment and eventual satisfaction of any and all liens presently
encumbering the veWcle, and to indemnify, defend and hold Husband harmless for the same.
Husband hereby agrees to sign any title or other documents necessary to transfer ownership
of said vehicle prior to September 1, 1996 (provided wife provides the same by that date), and
further shall indemnify Wife for any costs, including actual counsel fees, incurred by Wife to
enforce this provision.
9. Retirement. Wife is the owner of a certain interest in a pension plan through her
employer, Commonwealth of Pennsylvania under the State Employees' Retirement System.
The parties agree that a Retirement Benefit Distribution Order or Qua1ified Domestic Relations
Order shall be entered concurrent with or subsequent to the entry of a Decree in Divorce,
wWch Order shall require the payment of one-half of Wife's interest in said pension plan
accrued to the parties' date of separation, payable at the time of Wife's retirement. The
* Wife's narre remains on said vehicle title, Husband shall provide her with verifiCi!tion
that the vehicle is currently insured.
Sep81'atlon and Property Settlement Agreement - M81'k D. Andenlon/Anna Marla AnderBOn
Pago 7
amount of Husband's portion of Wife's retirement benefit shall be in accordance with the
following formula:
Number of months employed by the Commonwealth of Pennsylvania from
dale of marriage Ihrough the date of separation divided by the lolal number
of months of employment with Ihe Commonwealth of Pennsylvania as of the
parties' date of separation, multiplied by the amount of monthly benefit
accrued as of the date of separation (based upon years of service as of the
dale of separation and based upon final average salary as of the date of
separation), multiplied by a reduction factor if payments commence 10 wife
prior 10 her superannuation age, multiplied by 50 percent.
Both parties shall retain the services of Harry Leister, and shall share the cost
of the same, who shall prepare the proposed Retirement Benefit Distribution Order or
Qualified Domestic Relations Order, and after approval by the State Employees' Retirement
System, Husband shall cause the Order to be submitted to the Court for approval.
Both parties further waive any interest in any other retirement benefits of the
other not expressly set forth herein.
8. Alimony. Both parties acknowledge and agree that the provisions of this
Agreement providing for equitable distribution of marital property are fair, adequate and
satisfactory to them, and are accepted by them in lieu of and in full and final settlement and
satisfaction of any claims or demands that either may now or hereafter have against the other
for support, maintenance or alimony. Husband and Wife further, voluntarily and intelligently,
waive and relinquish any right to seek from the other any payment for support or alirnony.
Each party shall indemnify, defend and hold the other harmless against any future action for
either support or alirnony brought by or on behalf of the other, such indemnity to include the
actual counsel fees of the defendant in any such future action.
9. Alimony Pendente Lite, Counsel Fees and Expenses. Husband and Wife
acknowledge and agree that the provisions of tWs Agreement providing for the equitable
distribution of marital property of the parties is fair, adequate and satisfactory to them. Both
parties shall accept the provisions set forth in tWs Agreement in lieu of and in full and final
settlement and satisfaction of all claims and demands that either may now or hereafter have
against the other for alimony pendente lite, counsel fees or expenses, or any other provision
for their support and maintenance before, during and after the commencement of any
Sep81'Btlon and Property Settlement AlJI'eement - Mark D. AnderBon/Anna Marie AnderBon
Page B
proceedings for divorce or annulment between the parties. Each party shall be responsible
for Ws or her own counsel fees, and each agrees to indemnify, defend and save the other
harmless from any action commenced against the other for alimony pendente lite, counsel fees
and/or expenses.
10. Divorce. A Complaint in Divorce has been filed to No. 1995-3717 in the Court of
Common Pleas of Cumberland County, Pennsylvania, and either party shall be free to proceed
without further delay to secure the divorce. Both parties shall sign an Affidavit evidencing
their consent to the divorce, pursuant to g3301(c) of the Divorce Code. In the event, for
whatever reason, either party falls or refuses to execute such affidavit upon the other party's
timely request, that party shall indemnify, defend and hold the other harmless from any and
all additional expenses, including actual counsel fees resulting from any action brought to
compel the refusing party to consent. Each party hereby agrees that a legal or equitable action
may be brought to compel WID or her to execute a Consent form and that, absent some breach
of tWs Agreement by the proceeding party, there shall be no defense to such action asserted.
11. Time of Distribution. Except as otherwise stated herein, the assets and
interests to be transferred under and pursuant to tWs Agreement shall be conveyed and
transferred to the respective parties immediately upon the execution of tWs Agreement. All
spousal support and other such obligations, including alimony, shall immediately terminate.
The parties shall cooperate by executing whatever documents are necessary to effectuate a
divorce under g3301(c) or g3301(d) of the Pennsylvania Divorce Code, and tWs Agreement to
cooperate shall be enforceable by an assumpsit action for specific performance. However,
upon refusal to consent, all distributed property shall be returned to the party originally in
possession, until the time of final Decree.
12. Release. Subject to the provisions of tWs Agreement, each party has released
and discharged, and by this Agreement does for himself or herself, and Ws or her heirs, legal
representatives, executors, administrators and assigns, release, indemnify (including actual
legal fees) and discharge the other of and from all causes of action, claims, rights, or demands,
resulting from the parties marriage, including equitable distribution, spousal support, alimony,
counsel fees, alimony pendente lite, and expenses which either of the parties against the other
ever had, now has, or may in the future have against the other under the Pennsylvania Divorce
Code, as amended, or under any other statutory or common law, except any and all causes of
action for divorce and all causes of action for breach of any provisions of tWs Agreement. Each
party also waives Ws or her right to request marital counseling, pursuant to g3302 of the
Divorce Code.
13. Waivers of Claims Against Estates. Except as herein otherwise provided, each
party may dispose of Ws or her property in any way, and each party hereby waives and
relinquishes any and all rights he or she may now have or hereafter acquire under the present
or future laws of any jurisdiction, to share in the property or the estate of the other as a result
of the marital relationsWp, including without 1irnitation, dower, curtesy, statutory allowance,
widow's allowance, right to take in intestacy, right to take against the Will of the other, and
right to act as administrator or executor of the other's estate, and any right existing now or in
the future under the Pennsylvania Divorce Code, as amended from time to time, and each will,
at the request of the other, execute, acknowledge and deliver any and all instruments wWch
may be necessary or advisable to carry into effect tWs mutual waiver and relinquishment of
all such interests, rights and claims.
14. Rights on Execution. Immediately upon the execution of tWs Agreement, the
rights of each party against the other, despite their continuing marital status, shall terminate
and be as if they were never married.
15. Breach. In the event of breach of any of the terms of tWs Agreement, the
nonbreacWng party shall be paid, as part of any award or judgment against the breacWng
party, all costs, including actual counsel fees paid to Ws or her attorney.
16. Incorpomtion in Final Divorce. The terms of tWs Agreement shall be
incorporated but shall not merge In the final divorce decree between the parties. This
Agreement shall survive in its entirety resolving the spousal support, allmony, property and
other interests and rights of the parties under and pursuant to the Divorce Code of the
Commonwealth of Pennsylvania. This Agreement may be enforced independently of any
support order, divorce decree or judgment and its terms shall take precedence over same,
remaining the primary Obligation of each party. This Agreement shall remain in full force and
effect regardless of any change in the marital status of the parties. It is warranted,
covenanted and represented by Husband and Wife, each to the other, that tWs Agreement
Page 9
Sep81'atlon and Property Suttlemant AlJI'uement . Mark D. AnderBOn/ Anna Marie AnderBon
Sell81'atlon and Property Settlement Agreement - Merk D. Anderaon/ Anna Merle AnderBOn
Pago 10
is lawful and enforceable and tWs warranty, covenant and representation Is made for the
specific purpose of inducing the parties to execute the Agreement.
17. Additional Instruments. Each of the parties shall from time to time, at the
request of the other, execute, acknowledge and deliver to the other party, any and all further
instruments that may be reasonably required to give full force and effect to the prOvisions of
tWs Agreement.
18. Separability. In case any provision of tWs Agreement should be held to be
contrary to, or invalid under, the law of any country, state or other jurisdiction, such illegallty
and invalidity shall not in any way affect the other provisions hereof, all of wWch shall
continue, nevertheless, in full force and effect, and each paragraph herein shall be deemed to
be a separate and undisputed covenant and agreement.
19. Entire Agreement. TWs Agreement contains the entire understanding of the
parties and there are no representations, warranties, covenants and undertakings other than
those expressly set forth herein. Husband and Wife acknowledge and agree that the
provisions of tWs 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 wWch have been taken into consideration by the parties.
Both parties hereby accept the provisions of tWs Agreement with respect to the division of
property in lieu of and in full and final settlement and satisfaction of all 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 Section 3502 of the Divorce code
or any other laws. Husband and wife each voluntarily and intelligently waive and relinquiSh
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 tWs Agreement.
20. ModIfIcation and Waiver. A modification or waiver of any of the provisions of
tWs Agreement shall be effective oniy if made in writing and executed with the same forrnallty
as tWs Agreement. The fallure of either party to insist upon strict perforrnance of the
provisions of tWs Agreement shall not be constrUed as a waiver of any subsequent default of
the same or similar nature.
Sep81'atlon and Property Settlement AlJI'eement - Mark D. AnderBon/Anna Morie AnderBon
Pago 11
21. Intent. It is the intent of the parties by this Agreement to fully and finally
foreclose any resort to the Courts for relief on the basis of any statute or case law presently
existing or wWch may exist at some time in the future witWn the Commonwealth of
Pennsylvania, relating to rights and obligations arising from their marriage including but not
limited to equitable distribution, alimony and other relief under the Pennsylvania Divorce
Code, as amended. This Agreement has been drafted and accepted on the basis that such
resort would constitute a breach under tWs Agreement, entitling the nonbreacWng party to
reimbursement for actual counsel fees. Other than as provided by the terms of tWs
instrument, it is intended that the Court shall treat the parties as if they had never entered
into a marital relationship. This Agreement shall be interpreted and governed by the laws of
the Commonwealth of Pennsylvania and, where such law is inconsistent, the terms of this
iustrument shall govem.
22. Voluntary Execution. The provisions of tWs 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, 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 the financial affairs of the other which has been requested by each of
them or by their respective counsel.
23. Descriptive Headings.
convenience oniy. They shall have no
obligat.ions of the parties.
24. Agreement Binding on Heirs. This Agreement shall be binding and shall inure
to the benefit of the parties hereto, and their respective heirs, executors, administrators,
successors and assigns.
25. Reconciliation. Notwithstanding a reconciliation between the parties, tWs
Agreement shall continue to remain in full force and effect absent a writing signed by the
parties stating that tWs Agreement is null and void.
26. Terrninatlon of Agreement. It is understood by both parties that Husband has
entered into an agreement to purchase another home, and needs to apply for mortgage
The descriptive headings used herein are for
effect whatsoever in deterrnining the rights or
>",.-
Sep81'atlon and Proparty Settlament AlJI'eement - Mark D. AnderBon/Anna Marie And:3rBon
Pege 12
financing. If Ws mortgage application is denied, or he Is otherwise unable to settle on the
purchase of said home, as a result of the failure of Wife to execute tWs agreement witWn
sufficient time to allow Husband to make a mortgage application, or settle on the purchase
of the home witWn the time limits set forth in Ws existing agreement of sale, Husband shall
have the discretion to declare tWs agreement null and void, as if it had never been entered
into and executed by the parties herein.
IN WITNESS WHEREOF, the parties hereto have hereunto set their hands and seals
the day and year first above written.
~~
~
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~.d~
D. ANDERSON
anm.a., !i1a-ua an~
ANNA MARIA ANDERSON
", ( :..
"" ...., . v
ANDERSON PERSONAL PROPERTY APPRAISAl. DISTRIBUTION
MARK'S LIST
FRENCH DOORS
TABLE LAMP
OAK WASH STAND
OAK PLANT STAND
MARBLE TOP PLANT STAND
WHITE SOFA
LIVING RM END TABLE
PAIR BARREL BACK CHAIRS
SINGER TREADLE SEWING MACHINE
CRYSTAL CHANDELIER
LOVESEAT
LADIES SLANT FRONT DESK
GLASS TOP TABLE (DEN)
SANSUI STEREO
END TABLE WI 4-DRAWERS
TABLE IN BOX
PLANT STAND
YAMAHA STEREO WI DUAL CASSETTE
& 5 DISK CD PLAYER
ENTERTAINMENT CTR.
GAS GRILL
HONDA MOWER
HONDA SNOW BLOWER
ROTO TILLER
MISC. GARDEN TOOLS
MISC. POTS, PANS, DISHES
CHERRY CURIO CABINET
LENOX VASE
STEMWARE - BLOWN GLASS
WALL CLOCK
PENTA X 35MM. CAMERA WITH ZOOM
UPRIGHT FROST FREE FREEZER
BATHROOM MIRROR
CEDAR CHEST
OAK BUREAU & MIRROR
LEADED GLASS TRANSOM
GLASS TOP END TABLE (FAM. RM.)
S 750
25
200
75
50
400
125
400
50
600
350
200
30
o
225
50
25
600
500
50
200
400
90
40
50
325
50
55
300
90
100
35
17S
200
250
25
[;/I1;b:r II
..
, '.'
MNIE'S LIST
ANDERSON PEHSONAL I'1l0PERTY APl'R^ISAL DISTRInUTION
FIREPL^CE MANTEL
LIBRARY TABLE & CHAIR
9X12 CHINESE RUG (PINK)
LIVING RM CONSOLE TABLE
LIVING Rid MIRROR
NEEDLEPOINT PICTURE
MAGAZINE BASKET
ETHAN ALLEN SOFA
T. V. TRAYS
HOOVER VAC
OAK TABERETTE
HASSOCK/OTTOMAN (FAMILY RM)
LAWN FURNITURE
POTS. PANS AND DISHES
PFALTZCRAFT - SVC OF 8
PAIR OF BAR STOOLS
SMALL APPLIANCES
NORITAKE CHINA - SVC FOR 8
MILK GLASS PITCHER
DINING ROOId MIRROR
STEMWARE- CRYSTAL D
DINING RM PICTURE
8X9 BLUE RUG
WHIRLPOOL WASHER AND DRYER
BASSETT BEDROOM SUITE
2X3 CHINESE RUG
2X5 CHINESE RUG
FAMILY ROOM COFFEE TABLE
600
490
I,SOO
85
110
80
25
600
45
o
65
60
195
o
75
50
45
450
40
150
55
50
150
225
1,800
45
75
NOT APPRAISED
f)!h.',r ~
.
I ._ .
68/12/1996 69:22 717-761-7267
HAMPDEN TOWNSHIP
PAGE 62
LIST OF UNAPPRAISED PERSONAL PROPERTY DIVISION
MARK'S LIST
Gram's Christmas China
Table Cloths from St. Thomas
Sliver Dollars
Leaf Blower
Pair of Brass Outdoor Lights
AlC Window Unit in Mark's Room
(2) Masonry-Look Plant Stands
(2) Pink Upholstery Chairs
Mattress and Box Spring (almost new)
Eureka Vacuum Cleaner
Mark's Plants
Refrigerator - Pre-marital
Toaster Oven - Pre-marital
Stoneware Dishes (New Set of 45 pes.)
Misc. Pots and Pans, Glasses and Cups
Dining room Suit - Pre-marital
Oak Plant stand -Dining room - Pre-marital
Crystal Wine Decanters and Water Pitcher
Crystal Candy Dish and Misc. Glassware
Bake~r~
<Z r.w.JaI'imtique upholstery chairs In Family Room
Brass Um Planter Pot
Mark's Bedroom Items, except the phone and answering machine
One of the sewing machines
Miscellaneous Pictures and Frames /11I /tJIl/Lk IS bM~Qo""
Iron and Mini Ironing Board
7 sets of mini blinds - brand new
Christmas Items - new and used In attic
Pre-marital Items in attic
All Queen-sized Sheets and all bath towels
American Tourlster Luggage -Gift from Brother
Imitation Indian Rug - Pre-marital,'" 'iT'll. b!J/loON\
Queen-sized Mattress and Box Spring - Pre-marital
Green Upholstered Chair in 4th Bedroom
Electric Sander, Circular Saw, Levels, and Misc. Tools in 4th Bdroom
Needlepoint Picture In Hall
Second Set of French Doors -taken from basement after DOS
2-Antlque Tables and 2-cane-seated oak chairs in basement (sI/fUS Mr: NM'IT;9/..)
3 Ice cream parlor chairs in basement - pre-marital'
tools and extra insulation in basement
fj."';~" A
.
,
~9/12~1996 09:22 717-761-7267
HAMPDEN TOWNSH1P
PAGE 03
LIST OF UNAPPRAISED PERSONAL PROPERTY DIVISION
MARK'S LIST lcont'd)
,
Half of the planter pots and baskets in basement
One (1) floor fan
Two (2) upholstered chairs in basement
Two (2) floor lights In basement
Bicycle - pre-marital
Outdoor cushions and Umbrella
large Cooler
Copper pots and pans, and anything else in the boxes in the basement
Small appliances in basement, i.e., kabob-it, can opener, toaster
One metal ladder and two wooden ladders
Utility Broom and Misc. Tools in Garage
One Snow Shovel and misc. Garden shovels
One (1) lightening Glider Sled
Heavy-Duty Circular Saw in Garage
Iron lawn Furniture in Garage
One (1) Sand Chair and folding lounge chair
One (1) brown trash can wI wheels
Riding mower
Your plants and pots
Misc. tools in garage
Tablecloths
Half of Kitchen Stainless Steel and Cooking Utensils
Wooden Bed Tray - Gift from Godmother
Copper Cannister Set
Hand Mixer
Kitchen Clock
Refrtgerator .Pre-marital
Oak Rocker - Pre-marital
Brass Coat Rack - Pre-marital
Two (2) Brass lamps
Brass Fireplace Set. Pre-marital
Brass Chandelier wI Glass Globes in dining room (part pre-marital removed after
DOS)
~ .
Large Cement Outside Urn
Hose and Hose Caddy
Any Roses planted along driveway
New blueberry bushes
Raspbeny Vines
f';(hlb:r ~
,,"~.' --,.'. ~._"~-~
~~-.:,. ~\....,-
.~/12~1996 69:22 717-761-7267
HAMPDEN TOWNSHIP
PAGE 64
LIST OF UNAPPRAISED PERSONAL PROPERTY DIVISION
ANNIE'S LIST
Miscellaneous Tablecloths
VCR
Tupperware (Mark Ii~B\jld lalll.tJlllluw wh..ll,g betl!lR~)
Family Room Coffee Table
All Window Treatments and Household Flxtures(L1ghts, etc. affixed to house)
Wall Hanging over door in Dining Room
My Plants and Pots
Toaster and Coffee Maker (Gifts from My Family)
Kitchen Pots and Pans and Gadgets - Pre-marital
Some glasses and coffee cups
Ceramic Angels and Jesus, Mary and Joseph statue
Decorative Items in Living Room
Baskets in Living Room
Magazine Rack (Pre-marital)
Basket In Den
My Bedroom Items
Air Conditioner In My Room
Portable PhoneS.'Post DOS (,J.)
Answering Machine (Gift from My Sister)
Glass Top Table in Mark's Room (Pre-marital)
Dressing Table and bench in 3rd Bedroom
One of the Sewing Machines
Christmas Items,.. 31l~ hJtDO"'l
Pre-marital Items In attic
Cabinets and Fixtures purchased for 4th Bedroom
Extra Carpet for Hall and Family Room
Building Supplies In 4th Bedroom and Garage
Luggage Cart and Luggage Purchased after 7/12/95 (DOS)
Hoover upright vacuum - Pre-marital
Orange Upholstery Chair - Gift from Gram
Bookcase and Books In Hall
Small Table and Candle Decoration in Hall
Dehumidifier rD~'" .DOS
One (1) floor fan
Glass tables in basement . Pre-marital
j;.+-~ I ~,1" A.
~/12/1996 09:22
HAMPDEN TOWNSHIP
717-761-7267
LIST OF UNAPPRAISED PERSONAL PROPERTY DIVISION
ANNIE'S LIST (cont'd)
Stair treads. purchased after DOS
Hoses - purchased after DOS
Extra floor tile in basement
Door to house In basement
Cat's stuff
Terrarium
Extra Paint for House
Shutters In Garage for House
Extra Building Supplies and Vinyl Siding for House
Hedge Trimmers
Two (2) lightning Glider Sleds - Pre-marital
One (1) Brown Trash Can w/wheels
Bicycle -Pre-marital
Small cement outside urn
My outside planter pots - post DOS
Window blinds on Garage windows and artificial grass carpet (pre-marital)
One (1) snow shovel- post DOS
Small garden tools and lawn edger
One (1) Sand Chair and folding lounge
Poles and accessories to the outdoor awning
Half of Kitchen Stainless Steel and Cooking Utensils
Marble Turn Table In Kitchen
Exercise Bike - from Grandfather
All landscaping remains intact except for plants listed above.
E.r (,1 ~:r I}-
PAGE 65
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MARK D. ANDERSON,
Plaintiff
vs.
ANNA MARIA ANDERSON,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 1995-3717
: CIVIL ACTION-LAW
: IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
THE PROTHONOTARY:
Transmit the record, together with the following information, to the Court for entry of a Divorce
Decree:
1. Ground for divorce: Irretrievable breakdown under Section (x) 3301(c) () 3301(d)(l) of the
Divorce Code.
2. Date and manner of service of the Complaint: Certified Mail on July 15, 1996
3. (Complete either paragraphs (a) or (b).
(a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce
Code: by Plaintiff: November I, 1996
by Defendant: October 25, 1996
(b) (I) Date of execution of the Plaintiffs Affidavit required by Section 3301(d) of the Divorce
Code:
(2) date of service of the Plaintiffs Affidavit upon the Defendant:
4. Related claims pending: None.
5. Date and manner of service of the notice of intention to tile Praecipe to transmit record. a
copy of which is auached, if the decree is to be entered under section 330l(d)(l) of the Divorce
Code. N/A
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.
MARK D. ANDERSON,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 1/)' 3 7/"7 n t' ~~ t ']l 1-.1'--
VS.
ANNA MARIA ANDERSON,
Defendant
CIVIL ACTION-LAW
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 the divorce Is indignities or irretrievable breakdown of the
marriage, you may request marriage counseling. A list of marriage counselors is
available In the Office of the Court Administrator, Cumberland County Courthouse,
Hanover Street, Carlisle, PA.
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 Administrator
Cumberland County Courthouse, Fourth Floor
1 Courthouse Square
Carlisle, PA 17013 3387
(717) 240-6200
,
\
-.-;....-y-..
MARK D. ANDERSON,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. qr. .1717 (l;,1.J -r .u....
VS.
ANNA MARIA ANDERSON,
Defendant
CIVIL ACTION-LAW
IN DIVORCE
COMPLAINT
1. The Plaintiff is Mark D. Anderson who resides at 102 Hillcrest Road, Camp Hill,
Cumberland County, Pennsylvania 17011.
2. The Defendant is Anna Maria Anderson who resides at 102 Hillcrest Road,
Camp Hill, Cumberland County, Pennsylvania 17011.
3. The Plaintiff and Defendant have been bonafide residents in the
Commonwealth of Pennsylvania for at least six months immediately prior to the filing of
this Complaint.
4. The Plaintiff and Defendant were married on October 20, 1984, in Harrisburg,
Pennsylvania.
5. There have been no prior actions of divorce or annulment between the parties.
6. Neither of the parties in this action is presently a member of the Armed Forces.
7. The Plaintiff and Defendant are both citizens of the United States.
8. The Plaintiff has been advised of the availability of marriage counseling and
that he may have the right to request the court to require the parties to participate In such
counseling. Being so advised, Plaintiff does not request that the court require the parties
to participate in counseling prior to a divorce decree being handed down by the court.
9. The Plaintiff avers the ground on which the action is based is that the marriage
is Irretrievably broken.
WHEREFORE, the Plaintiff requests the court to enter a decree of divorce.
Respectfully submitted,
Purcell, Krug & Haller
BY
~
Jcihn W. Purcell, Jr.
:1.0. 29955
\
17 9 North Front Street
Harrisburg, PA 17102
(717) 234-4178
I
VERIFICATION
I verify that the statements made in the foregoing
Complaint
in Divorce
are true and correct.
I understand that false statements herein are made subject to the penalties
of 18 Pa. C.S. 94904 relating to unsworn falsification to authorities.
Date: July 5. 1995
V)'};/&4 ~, ~pJ
Mark D. Anderson
MARK D. ANDERSON,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY , PENNSYLVANIA
NO. 1995.3717
CIVIL ACTION-LAW
IN DIVORCE
vs.
ANNA MARIA ANDERSON,
Defendant
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA:
) ss:
COUNTY OF DAUPHIN
I, JOHN W. PURCELL, JR., Allorney for the Plaintiff in the above action, hereby swear and
affirm that on the 12th day of July, 1995. I sent. by certified mail, return receipt requested,
deliver to addressee only, a certified copy of the Complaint in Divorce, containing Notice to
Defend and Claim Rights to Anna Maria Anderson, the Defendant in the above action. The return
receipt, duly signed by the Defendant is allached hereto and made a part hereof as Exhibit "A".
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MARK D. ANDERSON,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PA
: NO. 1995 - 3717
: CIVIL ACTION-LAW
: IN DIVORCE
vs.
ANNA MARIA ANDERSON,
Defendant
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301 (c) of the divorce Code
was filed on July 12, 1995.
2. The marriage of Plaintiff and Defendant is irretrievably broken and
ninety days have elapsed from the date of filing the Complaint.
3. I consent to the entry of a final decree of divorce after service of
notice of intention to request entry of the decree
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
!i3301(c) OF THE DIVORCE CODE
1. I consent to the entry of a finel 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 thet 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. !i 4904 relating to unsworn falsification to authorities.
Date:
"1l1a) J ~W/V
MARK D. ANDERSON
11 /01/96
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: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PA
: NO. 1995 - 3717
: CIVIL ACTION-LAW
: IN DIVORCE
MARK D. ANDERSON,
Plaintiff
ANNA MARIA ANDERSON,
Defendant
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301 (c) of the divorce Code
was filed on July 12, 1995.
2. The marriage of Plaintiff and Defendant is irretrievably broken and
ninety days have elapsed from the date of filing the Complaint.
3. I consent to the entry of a final decree of divorce after service of
notice of intention to request entry of the decree
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
g3301(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 divorcad 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.
understand that false statements herein are made subject to the penalties of 18 Pa,
C.S. g 4904 relating to unsworn falsification to authorities.
Date:
/O-;;JJ". (((:.
alUICi lY)ct/ua a'nd.l'Lu~
ANNA MARIA ANDERSON