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Home My WebLink About95-04129 11 ' , , i -I " " ,d ' , 0 [ " I ~ ~ J 'r,' . c;- ns - :r .. , -:.:- :. <c. .:.}. ':.:. -:~. -:.. .:<<, .:c, .;e .. " . .. . .. . " .,. ".... . 8 8 8 ~ 8 . 8. . 8 8 ~ 8 8 8 8 I, '8 8 I. 8 18 I. 8 8 Iii , . i~ ~ 8 8 ~ ~ 8 ,;, " ~ l! ~;, .:.;. -:+:- .~.;. -:.:. .~.;. .:.:. .~.:. .~.:. .~..:. ->>;. ':.:. .~:. .:.:. 'c<<' ~._--*~*,~~..~.~~.,~~,~~:~.':~.~ ~ ..-...._- ~.-............. ........ -' .-.. . ~ "" ' , . . ~ ~ I N ',' ~: ~" . , r;! , ,'" " ',' ~ :~ ~ ~ ~ ;;:1 '.' ~! ~) :.1 ~I :!: " :~ ' ~; ~ ',' THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY 1Jt.~ ':P:~"~~ 1/.",f1"jI, " l " ~ II .. J'..j, ~~." ;. \ PENNA. STATE OF CALVIN A. MCCAUSLIN, Nt), .4.lZ.9. It) 95 Plaintiff VI'I':,II'; KATHY S. MCCAUSLIN, De f endan t DECREE IN DIVORCE ~ . ~ ~ ~ ~ ~ 8 8 ~ 8 8 . - . 8 ~ . . t-_._~... . d ./,!',-,'. "'Plf~..,., ~c,., . . 19.95. , it is ordered and AND NOW, '.",'.' decreed that ,.." Ca 1 V~!1, 1\... M~cau,s.LI!1, Kathy S. McCauslIn , , , '. plaintiff. , ", defendant, and.,..,.""",.,.. ' 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; .., ,NQo\',. .Th".~tt~ch~d Post-Nuptial A~r"ement is inc?rporat"d., b~t. ~1?~.... ." .,?~~~~d ~nto. thisD.'cr"". " ,,,,,.,, fly Th. C,,"rt,' II -/(... /J J::Iz- / ~ ^th!~t: "", J. ".'Vn,(!(' t ,(~&,tI~ f4'-~71"~ 4~".1 .i::'. ~k, t ).A~ f' "7it,thonot.,ry ~ ~ ~ ~ CALVIN A. MCCAUSLIN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA l/'; NO. 9~4129 CIVIL TERM v. KATHY S. MCCAUSLIN, Defendant IN DIVORCE PRAECIPE TO TRANSMIT R~CORD TO: Prothonotary of Cumberland County: Please transmit the record, tagether with the fOllowing informatian, to the Court for entry .of a divorce decree: 1. Ground for divarce: irretrievable breakdown under sectian 3301(c) of the Divarce Code. 2. Date arid manner .of service .of Complaint: servi.ce via certified mail, restricted delivery, return receipt requested an September 13, 1995. (See Affidavit .of service filed herein.) 3. Date of execution of the Affidavit of Consent required by Sectian 3301(c) .of the Divorce Cade: By the Plaintiff: November 6, 1995; by the Defendant: November 6, 1995. 4. Related pending claims: None. SNELBAKER , BRENNEMAN, P.C. L-AW O""ICI'IPS SNELIJAKIU't lit BRENNEMAN By ~~~ Keith O. Brenneman Attorneys for Plaintiff Dated: November 8, 1995 , I,.AW OIf"CI. SNII..IIAKIR a SIUI'INIMAN CALVIN A. MCCAUSLIN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 95-'t /.>.1 CIVIL TERM vs. KATHY S. MCCAUSLIN, Defendant IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in caurt. If yau wish to defend against the claims set farth in the follawing pages, you must take prompt actian. Yau are warned that if yau fail to da sa, the case may proceed withaut you and a decree .of divorce .or annulment may be entered against yau by the Court. A judgment may also be entered against you far any other claim .or relief requested in these papers by the Plaintiff. You may lose money or praperty or ather rights impart ant ta you, including custody .or visitatian of yaur children. When the ground far divorce is indignities .or irretrievable breakdown .of the marriage, you may request that the court require yau and your spouse to attend marriage counseling prior to a divarce decree being handed dawn by the caurt. A list .of marriage caunselars is available in the Office .of the Prathanatary at the Cumberland Caunty Caurt Hause, Carlisle. You are advised that this list is kept as a canvenience to yau and you are nat baund to choose a caunselor from the list. All necessary arrangements and the cost .of counseling sessions are to be barne by you and your spouse. IF ~OU 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 h LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW WHERE YOU CAN GET LEGAL HELP. Court Administratar One Caurthouse Square Carlisle, Pennsylvania 17013-3387 (717) 240-6285 By ~=:-.C. Attorneys for Pia ntiff CALVIN A. MCCAUSLIN, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 95- '-41 J.e, CIVIL TERM KATHY S. MCCAUSLIN, Defendant IN DIVORCE ~PLAINT COUNT I - DIVORCE 1. Plaintiff CALVIN A. MCCAUSLIN is an adult individual residing at 6 Lacust Lane, Mechanicsburg, CumbQrland County, Pennsylvania. 2. Defendant KATHY S. MCCAUSLIN is an adult individual residing at 117 N. 17th Street, HarriSburg, Dauphin Caunty, Pennsylvania. 3. Both the Plaintiff and Defendant have been bona fide residents .of the Cammonwealth of Pennsylvania far at least six (6) manths immediately previous ta the filing of this Complaint. 4. The Plaintiff and Defendant were lawfully jained in marriage on October 23, 1987 in Mechanicsburg, Pennsylvania. 5. There have been na prior actions of divorce .or for annulment between the parties hereta in this .or any other jurisdiction since the date of the marriage averred in Paragraph LAW O'.IC.. 8NIl.BAKEIlI . B"IENN~MAN 4, above. LAW O"'It:U 8NIL8AICE.. . e"INNEMAN 6. Neither 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 braken. 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 ta participate in counseling. 9. The Plaintiff requests this Court ta enter a decree .of divorce. COUNT II - EOUITABLE DIVISION OF PROPERTY 10. The Plaintiff and Defendant have legally and beneficially acquired praperty both real and persanal during their marriage from October 23, 1987. 11. The Plaintiff requests this Court to equitably divide all marital praperty pursuant to section 3502 of the Pennsylvania Divorce Code. WHEREFORE, the Plaintiff prays this Honorable Caurt ta: (al enter a decree of divorce, divarcing the Plaintiff from the bands of matrimony heretafore existing between the Plaintiff and the Defendant; (bl order equitable distribution of marital property; and -2- (c) Qrder such other relief as the Court deems just and reasonable. SNELBAKER & BRENNEMAN, P.C. Date: J~'ly 26, 1995 By: Keith O. Brenneman, Esquire 44 West Main street Mechanicsburg, PA 17055-0318 Telephone: 717-697-8528 Attorneys for Plaintiff Calvin A. McCauslin ....'" 0"11:1. 8NII",AICIPI . B'UNNIMAN -3- ,'hl ,'I 'I" :Ql '1'IIE caJl~ CI' CQoIoDl PUAS OF CltlllllRLN:lD COON1'Y, pfHlSYLW\NIA tI>. 9S- 41;).'f nvn. TEllM INOIVaO: @) " ;l{.l: ,11,. ,;;(~::'r;,~,~' " ,\:' IJt\t iL"/, :ll~ ,;:. {.,Ii" ;"\ ~J;'.'.:: ,:,\::"), ':: !,i,\H ';';*1\>(;':" lI,il,J'l\..JII..,':,:. I,V;,!I :::~~,\)":,'~,\i, '", ""Ij,f" I,', "j',:'" " ;;,(, i'".,J(" "'\!;'\ ,in:" ~'~P";iZ\" '". ,,' , \'I~';",l'<,\ ' ,; :,,':1 :Mji;',:: ~ \il:\~:,~';\:'\':;>:' iJ'\'\ltJ i;'r' il. ,':', ~( ~IL~,::,r",'ti,lf~~!rj,,<~'.1" ,I ";, ,,,' ,\1, I' {, .~~ ~',,," I , .I', .' ' . 'JJ..~ /.~n, ,I'"" i"J. 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'.~~',;~,,:'.':~,I' ' ,;' :;'. t\11;li~,';, '"c,,:.., ::. ,1~',II.trL \ ': ":i.""; "~~f,;\,~I:,~\.~.. \ i~ ',: ':',~li' r;/N',,' ;':',i.'I\ 't't' -," I' ".I.~""\\''''''' " f' I~'ltl~ '.J~ . \ , ','" ,', "" iIl'l ,~ I"'.", ,S',. ',/\i I' I :~\I;.':' I' ',I 'jI c.' ~"~I"'~" ,(U",:,!: """,' ',' '. ,.f" i"\'$J ,..t" ',I \L' rJ I.\:.f.... / ' 1 'I: ~irf JI'lI11,.f' Ir' ' 11' . ,."'.... '1. \11 11~~II\\\II,. ,<Ill' jjL' ~ '~''<.'''''\, 1 ", ".' \~('~! 'J; I l", IT \ ': , I; r, ,~~ I" \~' \ lIt: /, :11 ;;\,~,~},,:.t~i~,!':'!,':,:'::"i; ;:il~'~\I.i',I:~..:{' ;.,'1';, 1,< ~~i:~~r!,.I~~' ,;." ItJ~lj"(,.\'ll,!" ': l i;J::~"';~:~,;,:r C.'ALVIN A. MX:1IlJSl.IN, , .\ "i (, L j '. ~ t. ",1/'1 '95 .: 24 Plaintiff v. (iT 1'1" " lCA'1HY a. KCIWSLIN, Defendant " $/ '10 5", SO - P,f. ~j " - CXIHAIN1' ............ :.....~9.............# '1'..~ ?j~~. ~~;~mL ~. PROTHONOTARV , I, , ';. ,.\' " ,. " ',' ,I , ' :' I :" 1:"1," ,,\' 1'1" '\,. I, "I '.'," 'J' ~l-iI!LIW<.~Jl & BRENN~MNJ A; N.OfISNOHM CPUOMTION ^nO"NIn At ~W "I - "iI, , , " " .. ~11 ""^'" S'nllf MlCHAWlC.S.UJ.~ PENN$YLVANI^ 170&.l " 0 eox 31. " "( I", I' ',,' I., '1.,1. ~ .. "" ~. . ('\\"1 ,. c.D :.vJO\ ",J..'f " I?"', :J:',. \ ~.. ,.-.., .' . I r,;) ~.' I - .., c. ,. "!) '"' ",:'1' ., ,,, . ,., .:...:.. ~j' .' IT . 1.: :.< ~ CALVIN A. MCCAUSLIN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ./:) NO. ~~-4129 CIVIL TERM vs. KATHY S. MCCAUSLIN, Defendant IN DIVORCE AFFIDAVIT KATHY S. MCCAUSLIN, being duly sworn according ta law, depases 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 spause and I participate in caunseling. 2. I understand that the court maintains a list .of marriage counselars in the Office .of the Prathanotary, which list is available to me upon request. 3. Being so advised, I do NQr request that the caurt require my spause and I participate in counseling priar to a divarce decree being handed dawn by the caurt. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. S 4904 relating ta unswarn falsification to authorities. L.AW O""ICI8 SNl[LElAI(E~ a BIUNNI:MO\N (kr~ fit l-I . ~ ) J(ej~,,';~ JKathy S. McCaUB n (Defendant) Date: ~lvcmber 6, 1995 CALVIN A. MCCAUSLIN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VB. NO. 95-4129 CIVIL TERM KATHY S. MCCAUSLIN, Defendant : HI DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA) SS. COUNTY OF CUMBERLAND) Keith O. Brenneman, Esquire, being duly sworn according to law deposes and says: that he is a principal in the law firm of Snelbaker & Brenneman, P. C., being the attorneys far Calvin A. MCCauslin, the Plaintiff in the abave captianed action in divorce; that on September 13, 1995, he did send to Defendant Kathy S. McCauslin by certified mail, return receipt requested, restricted delivery, a duly certified and reissued copy .of the Complaint in Divorce which was filed in the abave captioned action as evidenced by the attached cover letter .of the same date and Receipt far certified Mail No. Z.115 697 405; that bath the Complaint and caver letter were duly received by Kathy s. McCauslin, the Defendant herein, as evidenced by the return receipt card f?r said certified mail dated September 15, 1995; that a capy of the aforementianed cover letter dated September 13, 1995 is attached hereto and incorporated by reference herein ......w O"ICI. SNIL.8AICI,. . BRENNlMAN a8 "Exhibit A" and that th41 original Receipt far Certified Mail I, >l..,,, ," I' .., ,-.) , r"7') (.,I..' .-' " -.., ::J,: ,.'.'. . ''':"'', ~ POST-NUPTIAL AGREEMENT THIS AGREEMENT lIIade and entered into this :"'-S-7fJ day of ...l)p"Mr!I\ , 1995 by and between: !: CALVIN A. MCCAUSLIN, of 349 Maple Lane, Carlisle, Cumberland County, Pennsylvania, party of the first part, (hereinafter "Husband") , AND KATHY S. MCCAUSLIN, of 1207 B Rose Hill Avenue, Hagerstown, Maryland, party of the second part, (hereinafter "Wife") WITNESSETH: WHEREAS, Husband and Wife (collectively referred to herein as "the parties") were married to each other on October 23, 1987 and last resided with each other at 6 Locust Lane, Mechanicsburg, Pennsylvania; and WHEREAS, the parties hereto have accumulated certain assets and property during their marriage; WHEREAS, the parties hereto have had no children of their marriage and have not adopted any children; and ....w o"rcII INEl.8AKlft II ."INNUtAN WHEREAS, certain differences have arisen between the parties, as a consequence of which they have heretotore separated and now live separate and apart trom each other; and LAW O"'ICU SNIL.IAI<I" a ."INNIMAN WHEREAS, on August 2, 1995 Husband cammenced an action in Divorce docketed ta No. 95-4129 civil Term, in the Court of Common Pleas of Cumberland County, Pennsylvania (hereinafter the "Divorce Action"); and WHEREAS, the parties agree that their marriage is irretrievably broken; and WHEREAS, the parties acknowledge that each has had the full opportunity to be advised independently and represented by separate counsel concerning their respective rights, duties and abligatians arising out of their marital status; and WHEREAS, the parties having a full opportunity to be so advi3ed .of their respective rights, duties and obligations arising out of their marital status, and each having a full opportunity to investigate and evaluate assQts, liabilities and all other asp~cts of each other's property and their jointly awned assets and liabilities, have come to an agreement for the final settlement of their property and affairs. NOW THEREFORE, in consideration of these presents and the mutual covenants, promises, terms and conditions hereinafter set forth and to be kept and performed by each party hereto, and intending to be legally baund hereby, the parties mutually agree as follows: -2- .....w O"ICU SNIL.AICIPI 81 8P1ENNIMAN 1. INCORPORATION OF PREAMBLE. The toregoing preamble and paragraphs are incorporated by reterence herein in their .ntirety. 2. DECLARATION AS TO ASSETS ANp WAIVER OF EVALUATION. The parties declare and agree that they have, prior to the .xecution ot this Post-Nuptial Agreement, voluntarily agreed to divide and have physically divided and distributed between themselves all assets which they acquired during their marriage, whether or not said property is or would be deemed to be marital property under Pennsylvania Divorce Code and subject to equitable distribution. The parties turther declare and agree that prior to the execution hereat, they have voluntarily distributed between themselves all assets and property which each brought with them into their marriage. The parties declare and acknowledge that they are tully aware and tamiliar with all assets and property that each has braught into the marriage and that has been obtained or acquired separately or jaintly by them during the course of their marriage and atter separation and therefore waive any evaluation thereot. Each party expressly releases the other of and from any and aU right of equitable distribution or claim. to assets and praperty of any kind or nature whatev.r po......d by the oth.r party. Wite agrees to transfer any interest .h. has in the one motor vehicle jaintly titled in the partie.' names to Husband by executing the title and any oth.r document. -3- necessary tor said transter. Wite shall sign such documents, it not already signed by her, within thirty days at the date of this Agreement. 3. DIVISION OF LIABILITIES. The parties declare and agree that they have divided and allocated between themselves all debts and liabilities, whether or not incurred by them during the course ot their marriage. 4. FUTURE OBLIGATIONS. The parties agree that any and all obligatians incurred subsequent ta the date ot their separation, May 15, 1995, shall be the sole and separate liability and responsibility at the party incurring the obligation and each party agrees that he/she will not incur or attempt to incur any obligatians tor or on behalf ot the other party and will indemnify and hold harmless the other party of and from any and all liability arising trom such tuture Obligation. 5. COUNSEL FEES. Each party to this Post-Nuptial Agreement shall be responsible tor paying his or her own counsel tees and related costs associated with the processing ot the Divorce Action and the negotiation, execution and consummation of the pravisions ot this Post-Nuptial Agreement. 6. RELEASE OF SUPPORT AND RIGHTS UNDER DIVORCE CODE. Each party waive. and torever releases the other party of and trom any and all claims which either may have against the LAW oWle.s 'NIL.IAKI" a ."INNIMAN -4- t"AW a"'e.. 8NI1..AKUI II ."INNIMAN other for spousal support and for 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 any obligation created hereunder may be entorced by any remedies under the penn.ylvania Divorce Code. 7. DIVORCE. The parties agree ta terminate their marriage by mutual consent without counselling and each agrees to execute the necessary atfidavits and consents to procure a consensual divorce under the provisians of the Pennsylvania Divorce Code, such documents to be filed in the Divorce Action. 8. GENERAL RELEASE. Husband relinquishes his inchoate intestate right in the estate of Wite, and Wife relinquishes her inchoate intestate right in the estate of Husband, and each of the parties hereto by the.e presents, for himself or her.elf, his or her heirs, executors, administrators or a..igns, does hereby remise, release, quit-claim and forever discharge the other party hereto, his or her heirs, executors, admini.trator. or assigns, or any of them, of any and all claim., demand., damages, actions, causes of action or suits at law or in equity of whatsoever kind or nature, for or because of any matter or -5- 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 or imposed by reason of this Agreement. 9. SURVIVAL OF AvREEMENT. It is the intention of the parties that this Post-Nuptial Agreement shall survive any action in divorce which may be instituted or prosecuted by either party, and no order, judgment or decree of divorce, temparary, 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 enfarcement praceedings under the Pennsylvania Divorce Code. The parties agree ta incorporate this Agreement into a separate order of court to be entered in the Divorce Action, but this Agreement shall not be merged into said order or decree in divorce. 10. COOPERATIO~. The parties agree to cooperate with each other and to make, execute, acknowledge and deliver such instruments and take such further action as may h~reafter be determined to be requisite and necessary to effect the purposes and intention of this Post-Nuptial Agreement. LAW o",ICII SNU...ItK.I.. a ...IINN.MAN 11. VOLUNTARY EXECUTION. The parties declare and acknowledge tnat they have had the opportunity to have the -6- ....w O~~IC" SNII.IA.KI.. a ."INNIMAN provisions of this Post-Nuptial Agreement and their legal ottect tully explained to them by independent counsel ot their choosing and each party acknowledges that this Post-Nuptial Agreement is tair and equitable, that it is being entered into voluntarily, with tull knowledge of the assets ot both parties, and that it is not the result ot any duress or undue intluence. The parties acknowledge that they have been furnished with all intormation relating to the financial attairs of the other to th~ extent same has been requested by each ot them. 12. ENTIRE AGREEMENT. This Post-Nuptial Agreement contains the entire understanding ot the parties and there are no representations, warranties, covenants or undertakings other than those expressly set torth herein. The parties acknowledge and agree that the provisions ot this Agreement with respect to the distribution and division ot marital and leparate property are tair, equitable and satistactory to them based on the length ot their marriage and other relevant tactors which have been taken into consideration by the parties. Both parties hereby accept the provisions of this Agreement with respect to the division ot property in lieu of and in tull and tinal settlement and satistaction ot all claims and demands that they may now have or hereatter have against the other tor equitable distribution ot their property by any court ot competent jurisdiction pursuant to the Pennlylvania Divorce Code or any -7- LAW O""C" SNII.IIAKI" a '..INNIMAN amendments thereto. Each party voluntarily and intelligently waives and relinquishes any right to seek a court ordered determination and distribution ot marital property, but nothing herein contained shall constitute a waiver by either party ot any rights to seek the reliet ot any court tor the purpose ot entorcing the provisions ot this Agreement. 13. WAIVER. The waiver ot any term, condition, clause or provision ot this Agreement shall in no way be deemed or considered a waiver ot any other term, condition, clause or provision ot this Agreement. 14. APPLICABLE LAW. This Agreement shall be construed, interpreted and entorced according to the laws ot the Commonwealth ot Pennsylvania. 15. HEADINGS. The headings or titles ot the numbered paragraphs of this Agreement have been used only tor the purpose ot convenience and shall not be resorted to tor the purposes ot interpretation or construction of the text of this Agreement. 16. EFFECTIVE DATE. This Agreement shall be dated and become effective on the date when executed by the latter of the two parties. IN WITNESS WHEREOF, the parties have hereunto set their respectiv8 hands and seals the day and year tirst above written -8- I I I,M\'IN l\. H,','l\\I:a,IN. I' 1,1 lilt III VB, IN '1'lIt: ClIl/WI' 01' r;OMMOII !'1.EAIl ()f' ('lJMBEIII.ANI> COlJll'I"l, "EIIIIIl'Il.'lAII IA NO, .",- '111'1 CIVil, Tf:RM KATHY S. MCCAUSLIN, 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 tollowing pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without YOlA and a decree of divorce or ailnuln,ent "lay be entered agalnst: you r;,y \.he ~oUlt. A judgmen\; JIIo1Y 01180 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 ot 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 Oft ice 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 trom the list. All necessary arrangoments 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 NO'!' hAVt; A LAWYER Ok \.MNu!" AiFOi\tJ ONE, GO Tv ui< TELEPHONE THE OFFICE SET FORTH BELOW WHERE YOU CAN GET LEGAL HELP. Court Administrator One Courthouse Square Carlisle, Pennsylvania 17013-3387 (717) 240-6285 ~w 0'''<:1. 8NII.IAKIN . ."INNIMAN TRUE COpy FROM RECORD 'Til'l;U:oony whereof, I herl unto set my hind ,:,; lhe seal of said Court at cartttII. PI.. By ni$ S~day, 01 I \~ 1'1_~' BRENNEMAN, P.C. CALVIN A. MCCAUSLIN, Plaintitt IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 95- YO..'} CIVIL TERM vs. KATHY S. MCCAUSLIN, Detendant IN DIVORCE COMPLAINT COUNT I - DIVORCE 1. Plaintiff ChLViN A. M~CAUSLIN is an adul~ individual residing at 6 Locust Lane, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant KATHY S. MCCAUSLIN is an adult individual residing at 117 N. 17th Street, Harrisburg, Dauphin cQunty, Pennsylvania. 3. Both the Plaintift and Oetendant have been bona fide residents of the Commonwealth of Pennsylvania tor at least six (6) months immediately previous to the tiling ot this Complaint. 4. The Plaintiff and Defendant were lawfully joined in marriage on October 23, 1987 in Mechanicsburg, Pennsylvania. 5. There have been no prior actions ot divorce or tor annulment between the parties hereto in this or any other jurisdiction since the date ot the marriage averred in Paragraph LAW o'",c:.. .NII..,AICI" . ...INNIMAN 4, above. W'W O~~ICI. INIL._AKI" . .flINNIMAN 6. Neither party is a member of the armed torces 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 Plaintifl' mlY have the right to rtiquest that the Court require the parties to participate in counseling. 9. The Plaintiff requests this Court to enter a decree ot divorce. COUNT II - EOUITABLE DIVISION OF PROPERTY 10. The Plaintiff and Defendant have legally and beneticially acquired property both real and personal during their marriage trom October 23, 1987, 11. The Plaintiff requests this Court to equitably divide all marital property pursuant to Section 3502 ot the Pennsylvania Divorce Code. WHEREFORE, the Plaintiff prays this Honorable Court to: (a) enter a decree of divorce, divorcing the Plaintitt trom the bonds of matrimony heretofore existing betwe.n the Plaintitf and the Defendant; (b) order equitable distribution of marital property; and -2- (c) order such other relief 8S the Court deems just and reasonable. SNELBAKER , BRENNEMAN, P.C. Date: July 26, 1995 By: Keith O. Brenneman, Esquire 44 West Main Street M_chanicsburg, PA 17055-0318 Telephone: 717-697-8528 Attorneys for Plaintitt Calvin A. McCduslin l.AW O,."CII 8NII..IAICIII . ."INNIMAN , -3- CALVIN A. MCCAUSLIN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 95- CIVIL TERM i' II I. KATHY S. MCCAUSLIN, Defendant IN DIVORCE AFFIDAVIT CALVIN A. MCCAUSLIN, being duly sworn according to law, deposes and says: 1. I ~~ve been ad,ised c: the av~ilabllity 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 HQ1 request that the court require my spouse and I participate in counseling prior to a divorce decree being handed down by the court. i L \ 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. 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