HomeMy WebLinkAbout95-05145
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: IN THE COURT OF COMMON PLEAS :
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BRENDA J. SHEARER, II
: ',.,'", Plaintiff Nil, ,~~-::,5,~~~.Ci':'~,1...,':r.~If1) :
EI V"I'SIIS ~
~ GARY L, SHEARER, SR., $
~ Defendant: ~
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: DECREE IN ~
e DIVORCE $
~ AND NOW, .. .. ,;r. W'1,c,...?,~.. , .. .. ...., 19 ,1,~.., It Is ordered and ~
~ decreed that ...... ~~~~~..~".. ~~,~~~~~ .. .. . .. .. .... .. .... .. " plaintiff, :
~ and.......,. ...... ,~~~~..~'.. ~~,~~~~,~'.. ~~:.. .... .. ........... defendant, ~
~ are divorced from the bonds of matrimony. ~,:1
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~ The court retains iurlsdlctlon of the following claims which have ~
~ been raised of record In this action for which a final order has not yet $
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SEPARATION AND PROPERTY
SETTLEMENT AGREEMENT
THIS AGREEMENT made this J () day o~( (ft1~- , 1996, by
betwesn Gary L. Shearer, ot 440 samp1eb~e Road, Enola,
and
Pennsylvania, (hereinafter referred to as "Husband"), and Brenda
J. Shearer, of 1354 Zimmerman Road, Carlisle, pennsylvania
(hereinafter referred to as "Wife").
WITNESSETH:
WHEREAS, Husband and Wife were lawfully married on November
18, 1972, in churchtown, pennsylvania.
WHEREAS, differences have arisen between Husband and Wife in
consequence of which they have chosen to live separate and apart
from each other; and
WHEREAS, Husband has discussed with his attorney, Anne M,
Shepard, Esquire, and Wife has discussed with her attorney, Carol
J. Lindsay, Esquire, their assets and liabilities as of the date
of this Agreement, and both having been advised by their
attorneys of their rights and desires to the provisions
hereinafter set forth.
NOW, THEREFORE, the parties hereto intending to be legally
bound hereby do covenant and agree:
1. seDaration I
It shall be lawful for each party at all
times hereafter to live separate and apart from the other party
at such place as 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 or unlawfulness of
the causes leading to their living apart,
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2.
Interference:
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 this Agreement.
3. }'life's Debts: Wife agrees to be solely liable for her
student loan and for the Discover card account. wife represents
and warrants to Husband that she will not contract or incur any
debts or liabilities for which Husband or his estate might be
responsible and shall indemnify and save harmless Husband from
any and all claims or demands made against him by reason of debts
or obligations incurred by her.
4. Husband's Debts Husband agrees to be solely liable for
the Lowe's credit account and the Sears credit account. Husband
represents and warrants to Wife that he will not contract or
incur any debt or liability for which Wife or her estate might be
responsible and shall indemnify and save harmless Wife from any
and all claims or demands made against her by reason of debts or
obligations incurred by him.
5.
outstandina Joint Debts:
Each party confirms to the
other that they have not incurred any additional joint debt upon
which the other would have liability. The parties further agree
that neither will incur any more debts for which the other party
may be held liable and :- f either party incurs a debt for which
the other will be liable, that party incurring such debt will
hold the other harmless from any and all liabilities thereof.
. ,
6. Mutual Release: subject to the provisions of this
Agreement, each party has released and discharged, and by this
Agreement does for himself or herself, and his or her heirs,
legal representatives, executors, admiilistrators, and assigns,
release and discharge the other of and from all causes of action,
claims, rights or demands, whatsoever in law or equity, which
either of the parties ever had or now has against the other,
except any or all cause or causes of action for divorce or any
action to enforce this Agreement.
7. Alimonv. Alimonv Pendente Lite. Soousal Suooort and
Maintenance: In consideration of the mutual agreement of the
parties voluntarily living separate and apart and the provisions
contained herein for the respective benefit of the parties, Wife
and Husband agree to waive any and all claims of any alimony or
alimony pendente lite either may have against the other.
8. niY.ision of Personal Prooertv: The parties have agreed
to divide their personal property to their mutual satisfaction.
With the exception of that property set out specificallY below,
all property, tangible and intangible shall be the sole and
separate property of the party in whose possession it is as of
the date of this Agreement.
The parties further agree that the 1991 Chevrolet Van shall
be the sole and separate property of the Husband 1 Husband will
pay the balance of the loan for the purchase of said vehicle to
Harrisburg Belco Federal Credit Union, and will indemnify and
hold Wife harmless on, account of any loss as a result of said
loanr the 1993 Chevrolet Blazer S-10 shall be the sole and
separate property of the Wife. Both parties agree to refinance
said vehicles wi thin sixty (60) days of the date of this
aqreement.
The parties aqree to properly execute such title
documents or other written instruments as may be required to
transfer title of these vehicles to the respective parties. The
parties further agree to each assume all liability for insurance
and upkeep on their respective vehicles.
Husband and Wife agree to distribute to the other party one
half of the amount listed as the financial institution account
balances as of September 12, 1995, as follows:
To Husband
To Wife
PNC BANK
Wife & Husband's
Account #50-7003-1147
$
93.38
HARRISBURG BELCO
FEDERAL CREDIT UNION
Wife's Account #638900
5.89
YORK FEDERAL SAVINGS
LOAN ASSOCIATION
Husband's Account #090-852171
$
99.27
$ 660.05
660.05
All items of personal effects such as, but not limited to,
jewelry, luggage, sports equipment, hobby collections and books,
but not includinq any property, personal or otherwise
specifically disposed of pursuant to this agreement, shall become
the absolute and sole property of the party who has had the
principle use thereof or to whom the property was qiven or from
whom it was purchased, and each party hereby surrend';'rs any
interest he or she may have in such tangible personal property of
the other,
9. Division of Real Prooertv: The parties agree that the
real property located at 1354 Zimmerman Road, Carlisle,
Cumberland county, pennsylvania is to sold. Wife shall receive
SIXTY (60'> PERCENT of the net sales proceeds (sales price less
taxes, real estate commissions, mortgage payment and the usual
and customary seller's expenses) after settlement costs have been
paid. Husband shall receive FORTY (40%> PER CENT of the net
sales proceeds after settlement coats have been paid. Both
partiss agree to execute any and all future documents reasonably
related to the transfer of title to the marital home.
10. Insurance and other Benefits: The parties acknowledge
that neither of them have any c~aim whatsoever to any insurance
benefits, retirement benefits, or similar benefits due or
occurring to the other party of any nature whatsoever.
11. waiver of Claims Aaainst Estates: Except as herein
otherwise provided, each party may dispose of his or her property
in any way, and each party hereby waives and relinquishes any and
all rights he or she may 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
relationship, including without limitation, 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
each will, at the request of the other, execute, acknowledge, and
deliver any and all instruments which may be necessary or
advisable to carry into effect this mutual waiver and
relinquishment of all such interests, rights, and claims. This
paragraph shall not affect either party's right or power to
expressly include the other party in any will or other document,
whether written in the past or in the future.
12. Retirement Benefits: wife waives and relinquishes any
rights or interest she may have in Husband's rstirement benefits.
similarly, in the event that Wife has any retirement funds
of any nature whatsoever that are payable to her now or would be
distributed to her in the future, Husband waives and relinquishes
any rights or interest he has in those retirement benefits.
13. Enforceabilitv and consideration: This Agreement shall
survive any action for divorce and decree of divorce and shall
forever be binding and conclusive on the parties1 and any
independent action may be brought, either at law or in equity, to
enforce the terms of this Agreement by either Husband or Wife
until it shall have been fully satisfied and performed. The
consideration of this contract and agrsement is a mutual benefit
to be obtained by both of the parties hereto and the covenants
and agreements of each of the parties to ~he other. The adequacy
of the consideration for all agreements herein contained is
stipUlated, confessed and admitted by the parties, and the
parties intend to be legally bound hereby. In the event either
party breaches the aforesaid Agreemsnt and it is determined
through appropriate legal action that the alleged party has so
breached the Agreement, the breaching party shall be responsible
for any and all reasonable attorney's fees, as well as costs and
expenses associated with litigation incurred by the non-breaching
party to enforce this Agreement against the breaching party.
14. Counsel FeSSI The parties have been fully informed of
and acknowledge their right to make a claim for reasonable
counsel fees in the presently pending divorce proceedings, but
hereby make a full, complete and voluntary waiver of that right.
15.
Enforcement:
The parties acknowledge that an action
for divorce has been filed by Wife to Docket No. 95-5145 in the
Court of Common Pleas of cumberland county , Pennsylvania. The
parties acknowledge their intention and agreement to proceed in
said action to obtain a final decree in divorce by mutual consent
on the grounds that their marriage is irretrievably broken, and
to settle amicably and fully hereby all claims raised by either
party in the divorce action. The parties acknowledge they will
execute the necessary Affidavits of Consent and Waiver of Notice
for the entry of a final divorce decree in any future divorce
action,
IN WITNESS WHEREOF, the parties hereunto set their hand and
seals the day and year first mentioned above.
WITNESSES:
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B~ENDA J': ' HEARER"
COMMONWEALTH OF PENNSYLVANIA )
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COUNTY OF CUMBERLAND )
On this the c? O~ day of "--f1~
undersigned officer, personally appek~ed
, 1996, before me, the
Brenda J, Shearer, known
to me (or satiSfactorilY proven) 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 hereunto set my hand and official
seal.
COMMONWEALTH OF PENNSYLVANIA )
)
COUNTY OF CUMBERLAND )
, On this the Ole/I!. day oH /(a...-y , 1996, before me, the
undersigned officer, personally appedted Gary L. Shearer, known
to me (or satisfactorily proven) 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 hereunto set my hand and official
seal.
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BRENDA J, SHEARER,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plalntlfl
v.
NO. 95-5145 CIVIL TERM
GARY L, SHEARER, SR.,
Defendant
PRAECIPE TO TRANSMIT RECORD
To Ihe 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 (3301(c)) (3301(d)(1))
of the Divorce Code, (Strike out Inapplicable section).
2. Date and manner of service of the complaint: Certified Mail, Return Receipt
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Reauested, dated October 21, 1995
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! ~, 3. (Complete either paragraph (a) or (b)),
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(a) Date of execution of the affidavit of consent required by Section
3301(c) of the Divorce Code: by the Plaintiff Mav 20, 1996
by the Defendant Mav 20, 1996
(b) (1) Date of execution of the Plaintiff's affidavit required by
Section 3301 (d) of the Divorce Code:
(2) Date of service of the Plaintiff's affidavit upon the Defendant: -
4. Related claims pending: none
5, Indicate date and manner of service of the notice of Intention to file praecipe to
transmit record, and attach a copy of said notice under section 3301 (d)(1 )(i) of the Divorce Code,
(
Carol J, Un say, Esquire
Attorney for Plaintiff
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Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION. DIVORCE
BRENDA J. SHEARER,
VB.
NO. 96. .5 "IK
CIVIL TERM
GARY L. SHEARER, Sr.,
Defendant
IN DIVORCE
BRENDA J, SHEARER, Plaintiff, by her attorneys, FLOWER, MORGENTHAL, FLOWER &
LINDSAY, P,C,. respectfully represents:
1. The Plaintiff Is Brenda J. Shearer, who currently resides at 1354 Zimmerman Road,
Carlisle, Cumberland County, Pennsylvanlo, whore she has resided since 1987.
2. The Defendant Is Gary L. Shearer, Sr., whose current address Is P. O. Box 268,
Duncannon, Perry Counly, Pennsylvania, where he hes been since September 12, 1995.
3. The Plolntlff and Defendant both have been bona fide residents In the Commonwealth
of Pennsylvania for at least six months Immedletely prior 10 Ihe filing of this Complaint.
4, The Plaintiff and Defendant were married on November 18, 1972, at Churchtown,
Pennsylvania,
5. That there have been no prior actions of divorce or for annulment between Ihe parties
In this or In any other jurisdiction,
6. The Plaintiff avers that she Is entltlod to a divorce on the ground that Ihe marriage Is
Irretrievably broken and Plaintiff Is proceeding under Sections 3301 (c) and/or (d) of Ihe Divorce
Code,
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ElRENDA J. SHEARER,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION. DIVORCE
Plaintiff
va.
GARY L, SHEARER, Sr.,
NO. 95. 5145 CIVIL TERM
Defendant
IN DIVORCE
Brsnda J. Sheerer, Plaintiff. being duly sworn according to law. deposes and says:
1. Thst s Complaint In Divorce under Ssctlon 3301(c) of tha Divorcs Cods was filsd on
Septsmbsr 27, 1995,
2. That my marriaga with Gary L. Shearer. Sr.. Defendant, is irretrievabIY,broken.
3. That I consent to the entry of a Decree in Divorce on the grounds that the marrlags Is
Irrstrievably broksn,
4. That I understand that I may lose rights concerning alimony. division of property, counseling
fess or sxpensss if I do not claim them bafore a divorce if' granted,
I verity thst the statements made in this Affidavit ars true and correct to the best of my
knowlsdgs, information and belisf. I understand that falss statements hersin ere mads subject to the
psnaltiss of 18 Pa.C,S, 4904 relating to unsworn falsification to authorities.
WAIVER OF NOTICE OF INTENTION
TO REQUEST ENTRY OF A DIVORCE DECREE
UNDER ~330"cl OF THE DIVORCE CQQg
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 sxpenses 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 ths Decree will be sent to me immediately after it is filed with the Prothonotary.
I verity that the statement made in this Affidavit are true and correct, I understand thet false
statements hersin are made subject to the penalties of 18 Pa, C,S, ~4904 relating to unsworn
falsification to authorities,
Date: ,~/4:/'7/.,
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GARY L, SHEARER. Sr.,
Delendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY. PENNSYLVANIA
CIVIL ACTION. DIVORCE
NO. 95, 5145 CIVIL TERM
IN DIVORCE
BRENDA J, SHEARER,
Plaintiff
VB.
F IDAVIT 0
Gary L. Shearer, Sr., Defendant. being duly sworn according to law. deposes end says:
1, That a Complaint in Divorce under Section 3301 (c) of the Divorce Cads was filed on
September 27, 1996,
2. That my marriage with Brenda J, Shearer, Plaintiff, is irretrievably broken,
3, That I consent to the entry of a Decree in Divorce on the grounds that the marriage is
Irretrievably broken,
4. That I understand that I may lose rights concerning alimony, division of property. counseling
fses or sxpenses if I do not claim them before a divorce is granted,
I verify that the statements made in this Affidavit are true and correct to the best of my
knowledgs, information and belief. I understand that false statements herein are made subject to ths
penalties of 18 Pa,C,S. 4904 relating to unsworn falsification to authorities.
WAIVER OF NOTICE OF INTENTION
TO REOUEST ENTRY OF A DIVOHCE DECREE
UNDER ~3301Ic) 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 sxpenses 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 statement 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, ~4904 relating to unsworn
falsification to authorities,
Date: ~(/ -A FJ - y{-;
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BRENDA J, SHEARER,
Plaintiff/Petitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION . DIVORCE
vs.
NO. 95.
CIVIL TERM
GARY L, SHEARER, Sr"
Defendant/Respondent :
IN DIVORCE
f
NOW comes BRENDA J. SHEARER, by and through her attorneys, FLOWER,
MORGENTHAL, FLOWER & LINDSAY, P.C., and petitions this Honorable Court as
follows:
1 . The parties are husband and wife, having been Joined In marriage on
November 18, 1972.
2. Petitioner, hereinafter WIFE, flied a Complaint for Divorce on September 26,
1995.
3. Prlorto filing the Complaint for Divorce, Respondent, hereinafter HUSBAND,
threatened on several occasions to sell portions of the marital estate, to which his
business, his tools, and his vehicles.
Aside from these items of marital property, the only significant marital asset
Is the parties' home.
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4. Petitioner has no objection to the sale of tools or other personalty so long
as the fair market value for those Items be obtained, and that the sale take place to
disinterested third parties.
WHEREFORE, Petitioner prays this Honorable Court to order the parties not to
dissipate any marital asset without the written agreement of the other.
FLOWER, MORGENTHAL FLOWER & LINDSAY, P.C,
Attorneys for Plaintiff
By:
Carol J
ID '" 4
11 East High Street
Carlisle, PA 17013
(717) 243.5513
2
BRENDA J. SHEARER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
v.
.
.
GARY L. SHEARER, SR.,
Defendant
NO. 95-5145 CIVIL TERM
IN REI PLAINTIFF'S PETITION FOR SPECIAL RELIEF
ORDER OF COURT
this loiday of January, 1996, upon consideration of
AND NOW,
the attached letter from Carol J. Lindsay, Esq., attorney for
Plaintiff, the hearing previously scheduled for January 29, 1996,
is CANCELLED and the temporary oruer dated October 16, 1995, shall
remain in full force and effect until a signed stipulation and
order are filed.
BY THE COURT,
J.
Carol J. Lindsay, Esq.
11 East High Str.eet
Carlisle, PA 17013
Attorney for plaintiff
Anne H. Shephard, Esq.
200 North lIanover Street
Carlisle, PA 17013
Attorney for Defendant
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95 ,l'1:130 Pii 3: 29
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BRENDA J. SHEARER, . IN THE COURT OF COMMON PLEAS OF
.
Plalntltr . CUMBERLAND COUNlY, PENNSYLVANIA
.
.
.
va, . CML AcnON - DIVORCE
.
.
.
. NO. 85 - 5145 CMLTERM
.
GARY L SHEARER, Sr., .
.
Defendant . IN DNORCE
.
1. The parties hereto are husband and wife, having been Joined In marriage on
November 18, 1972.
2. Brenda J. Shearer, hereInafter WIFE, filed a Complaint for Divorce on September 26,
1995, seeking Inter alia equltabla distribution.
3, On October 3, 1995, WIFE filed a Petition for Special Relief seeking a Court Order
that neither party dissipate marital assets.
4. The parties hereto agree that, pending equitable distribution, neither shall dispose
of, alienate, or dissipate any Items of personal property without the written consent of the other,
and that this agreement be made an Order of Court.
WITNESS:
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Gary L Shearer, Sr,. Husband
Date: / // ~ / Y'(,,..
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Date: J_\_L'\("
BRENDA J, SHEARER,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION. DIVORCE
Plaintiff
vs,
NO, 95 - 5145 CIVIL TERM
GARY L. SHEARER, Sr..
Defendant
IN DIVORCE
NQII.CJ: OF....lNTENTION TO RESUME....eflIOR..NAMf
NOTICE IS HEREBY GIVE that BRENDA J, SHEARER, the Plaintiff In the above matter,
having been granted a Final Decree of Divorce on June 26, 1996, hereby Intends to resume and
hereafter use the previous name of BRENDA J, LUCAS, and give this written notice avowing her
Intention In accordance with the provisions of the Act of April 2, 1980, P.L., 23 P,S, 702, effective
July 1, 1980.
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\~~~ BRE~~ SH~~RER: petluoner
TO BE KNOWN AS:
-~""'''B~E;;)j~~CA~ ~
COMMONWEALTH OF PENNSYLVANIA
ss,
COUNTY OF CUMBERLAND
On IhlS,lhe (\\k day of ,\,-,,--\..,,-~ ,1996, bofore me, a Nolary Public, personally
appeared BRENDA J. SHEARER 10 be known as BRENtlGo J. LUCAS, known 10 me or sallsfaclorlly proven 10 be tho
person whose name Is subscribed 10 Ihe within document a!ld acknowledged Ihal she executed the same lor Ihe
purposes Ihereln contalnod,
IN WITNESS WHEREOF, I hereunto set my hand and official seal,
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