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Home My WebLink About95-05378 Ii ~~;(~i . it;..~p..'" ..... .-~.-.-_.- .- .-.. ~"'"'-.-.-''-, ffi~,' T ': --~ r'~:;M 1~t.n ..:<<. ... ... .1IC' {<<. .:.c. .1IC' .1IC' -It- .'Ii- /lIC-.lIC' .:.:. .:.:. .1IC' .>>:. .;.:. .>>:. .1IC' .;.:. ~ .1IC' .>>:.,.:<<. .;<<. ... ... fIC' .... ....~ . ' ---~-----'_. ,--~-~._------- ..,.--- -------..---- .~_.. ~ 8 ij IN THE COURT OF COMMON PLEAS 8 , 8 8 OF CUMBERLAND COUNTY 8 8 8 8 . · . STATE OF ~'" '. .:r l PENNA, 8 8 · 8 8 GAIL D. PECK, : PI",tiff N n. .1',n7!...... I~ : Q \' w,' '=' Pl':,ll~ " 8 WARD E. PECK, . ! 8 8 Defendant 8 8 iii 8 ~ : / ~~CVR~: i ;t.L1'17 ~p.: . AND NOW'~'"'''''''''''' ..." 19....." " I. .,d.,.d "d~ _.. <to decreed that ............. 9MJ... p!. r~q<. .. .. .... .. .. .. .. .... .. .. plaintiff, ~ . ~ and . .. .. .. .. .. . .. .. . .. .. . ,F.O\~^RQ .F....P.ECK .. .. . .. . .. . .. . .. .. ... defendant, i . are divorced from the bonds of matrimony, $ . ~ . The court retains jurisdiction of the following claims which have III 8 been raised of record In this action for which a final order has not yet ~ ':'.' been entered; I'l 8 ! . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .~q~~ . . . . . . . . . . . . . . . . . . . 8 " 8 . ........................................................ ~ , 8 . ~ 8 ~ '" lie . " l") ,J/ ~.,I/ ."I J. .' _ ;/?~~,;:.';~'~JLJ,~~~7~Mr'K7 \~ . I ~'rnlh()()nlnry ! ~ .1___....... ..__.-___ _. __"._.; __ ..' .... .. .. .. .. .. .. .. .. .. .. .. ., .. .. .. J;' ~..._----_.._-_..__.._.......~_. ~...v .f'? d/.-I. tbl7' "r:~/ i- a4 "/';J.:) . p~ '1;'~t- / ;.'-t;.tfv zj. 4 . . /fIc r.l . .-#- JC.,.I)~Ht~C ~ . :..,y,".'. . . , . .. GAIL D. PECIt, I IN THE COURT OF COMMON PLBAS OF I CUMBERLAND COUNTY, PENNSYLVANIA I I CIVIL ACTION - LAW I NO. 95-5378 I I IN DIVORCB PRABCIPB Plaintiff VB. EDWARD E. PECK, Defendant TO THE PROTHONOTARY I Please file the attached separation and property Settlement, dated April 4, 1996, to the above-captioned matter. Respectfully Submitted, ARTHUR T. MCDERMOTT , ASSOCIATES ~C"..-:::. Arthur T. JlCDerllOtt, Esq. 50 Ealt Hi9h Street Carlisle, PA 17013 (717) 243-7807 CCI Scott M. Staller, Esquire Attorney for Defendant P.O. Box 264 New Bloo.field, PA l7068 ," . SBPARATION AND PROPBRTY SBTTLBMENT AGREBMENT THIS AGREBMENT Made thiB L[fh ~pr'l\ day of ..{Ie~lSar,., 1996 by and between Gail D. Peck, of Cumberland County, PennBylvania, (hereinafter referred to as Wife) and Bdward B. Peck, of Perry County, PennBylvania (hereinaftex referred to as HUBband); WITNBSSBTH. WHBRBAS, the partieB hereto . ,,,~J ,t, ,r. were married on August ., 1990, in New Bloomfield, Perry County, PennBylvania, have been and are HUlband and Wife. WHBREAS, diverBe, unhappy differenceB, diBputes and difficultiel have arilen between the parties and it iB the intention of WIPB and HUSBAND to live Beparate and apart for the relt of their natural liveB, and the partieB hereto are deBiroul of settling fully and finally their respective financial and property rightl and obligationB as between each other, including, without limitation by specification; the settling of all matters between them relating to the ownerBhip and equitable distribution of real and personal property, settling of all matters bet_en them relating to the paBt, present and future support and/or maintenance of the wife, the Bettling of any and all claims and possible claims by one against the other or againBt their relpective estate, NOW, THBRBFORE, in consideration of the premises and of the mutual promises, covenants and undertakings hereinafter Bet forth and for other good and valuable consideration, receipt of which is hereby acknowledged by each of the partieB hereto, WIn and 1 " . ,. HUSBAND, each intendinQ to be leQally bound, hereby covenant and aQree as follows. l. AGREEMENT NOT A BAR TO DIVORCE PROCEEDINGS. This AQreement shall not be considered to affect or bar the riQht of WIFB or HUSBAND to a limited or absolute divorce on lawful Qrounda as such Qrounds now exist or shall hereafter exiet or to such defense as may be available to either party. Thil AQreement is not intended to condone and shall not be deemed to be a condonation on the part of either party hereto of any act or acts on the part of the other party which have occurred prior to the date hereof. The parties intend to secure a mutual consent divorce, 2. BPPBCT or DIVORCE DECRBB. The parties aQree that unless otherwise specifically provided herein, this AQreement shall continue in full force and effect after such time as a final decree in divorce may be entered with respect to the parties. 3. AGREBMENT TO BE INCORPORATED IN DIVORCE DBCREE. The parties aQree that the terms of this AQreement shall be incorporated into any divorce decree which may be entered with respect to them. 4. SBPARATION. It shall be lawful for each party at all times hereafter to live separate and apart from the other party as euoh place as he or she may from time to time choose or deem fit. The foregoing provisions shall not be taken as an admission on the part of either party of the lawfulness or unlawfulne88 of the cause8 leading to their living apart. 2 " . . . 5. INTERFERENCE I Each party shall be free from interference, authority, and contact by the other, as fully al if he or she were sin~le and unmarried except as may be necessary to carry out the provilions of this A~reement. Neither party shall molest the other or attempt to endeavor to molest the other, nor compel the other to cohabit with the other, or in any way harass or mali~n the other, nor in any way interfere with the peaceful existence, eeparate and apart from the other. 6. WIPE'S DEBTS. WIFE represents and warrants to HUSBAND that since the separation on Kay 27, 1995 she has not and in the future ehe will not contract or incur any debt or liability for which HUSBAND or his estate mi~ht be responsible and shall indemnify and save harmle88 HUSBAND from any and all claims or duande made a~a1net him by reasons of debts or obli~ations incurred by her. 7. HUSBAND'S DEBTS I 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 which WIPE or her estate mi~ht be responsible and shall indemnify and save harmless WIPE from any and all claims or demandl made a~ainst her by reason of debts or obli9ations incurred by him. 8. MUTUAL RELEASE. subject to the provieions of th1e A9reement, each party has released and dischar~ed, and by this A9reement does for himself or herself and his or her heirs, le~al representatives, executors, administrators 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 3 . --..... " the parties ever had or now has againBt the other, except any or all cause or caUBes of action for divorce and except any or all caus.s of action from breach of any proviBionB of thiB Agreement. 9. REAL PROPBRTY. The marital home at RD '1, Box 31, New Bloomfield, PA l7068, Bhall be the property of HUBband. The rental propertieB at (1) ROil, Box 3lA, New Bloomfield, PA l7068, ~ J? rI 3(/.j C. /; (2) ROn Box 32,., New Bloomfield, PA 17068, (3) ~ 11, Box ;pII", ,'a'lfJ C-: r New Bloomfield, PA 17068, (4) Rij 12, Box~, New Bloomfield, PA ff,1 c': /.' 17068~5) ~12, Box , New Bloomfield, PA l7068; (6) RO'2, , f.. (<.r; Box , New Bloomfield, PA 17068 Bhall' be the property of Husband. In exchange for Wife'B interest in the foregoing real properties, Husband Bhall pay to Wife the Bum of Fifteen Thousand ($15,000.00) dollarB. 10. DIVISION OF PBRSONAL PROPBRTY. (a) The parties have heretofore divided their personal property to their mutual BatiBfaction. Henceforth, each of the parti.. .ha1l own, have and enjoy, independently of any claUD of right of the other party, all itemB of perBonal property of every kind, nature and deBcription and whereBoever Bituated, which are now owned or held by or which may hereafter belong to the HUSBAND or WIFB reBpectfully, with full power to the HUSBAND or the WIFB to dispoBe of Barne aB fully and effectually, in all reBpectB and for all purpoBes as if he or she were unmarried. All itemB of perBonal property shall be divided between the parties aB provided herein. (b) Pension. Wife has non-vested pension with General Signal Blectric. 4 .. . (c) Debtll The Husband shall be responsible for all existing joint debts and liabilities incurred by the parties prior to their separation except as otherwille provided herein. The Husband shall also be responsible for all existing debts and liabilities incurred in his own name prior to the separation. The Wife shall be responsible for all existing debts and liabilities incurred in her own name prior to the separation. (c) The parties further agree that neither will incur any future debts for which the other may be held liable, and if 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 liability thereon. (d) Vehicles. The parties' vehicles s~ be distributed as follows. ~A~ If/Kf' /fEr r FlEtf'lufJ/) 13Ki _ To Husband. ~ 4WD Truck, 1968 Chevelle, 1..ft.~~/!?P ~J~ I'fPA1;LSk::tf(t- '5t!"h"At M: '7/<,'''-;ZWS/I'"'?'IISiIEMy NKYf'J"'l.,ulEHI'~rS~Jt(. IJ;(,Xil..s'lI~!~lI /'lY~~ To Wife . 1989 Grand Am POX liS' tf(O.lf~ IlPfl~ ~!trA',~, 17~ If?'! '" Fh'IP~ '''~f;tJ lI"kt.c. Jlt'f1I€ ::.r/Cllfl -* C.1I~f, 11. AFTER ACQUIRED PERSONAL PROPERTY. Each of the parties li13 ~ '''KKItIllJlE Ihall hereafter own and enjoy, independently of any claims or ~~_ # Y'37. right of the other, all items of personal property, tangible or 1'177 ~ IfkSl> intangible, hereafter acquired by him or her, with full power in~~~~ him or her to dispose of the same as fully and effectively, in :J:;~.)' all respect and for all purposes, as though he or she were /llt'N{(" ~ 1~71 M1Nf;I unmarried. J.>.Kk' iIf"~ Ib/KE f"~ l2 . DIVORCE. The parties hereto agree to enter into a JII: /II&'; mutual consent divorce. WIFE agrees to pursue the divorce and to be the Plaintiff therein. HUSBAND agrees to sign the necessary 5 . ' documente, including an Affidavit of Coneent and further instrumentB that may be reaBonably required to give full force and effect to the proviBions of this Agreement. l3. WAIVER OF CLAIMSI Except aB herein otherwise providud, each party may diBpoee of hiB or her property in any way, and each party hereby waives and relinquiBhes any and all rights he or ehe shall now have or hereafter acquire, under the preBent or future lawe of any jurisdiction, to share in the property or the eltate of the other as a reBult of the marital relationBhip, including without limitation, dower, courteBY, BtatUtOry allowance, widow's allowance, right to take in inteBtacy, right to take againBt the Will of the other, and right to act aB adminiBtrator or executor of the other'B eBtate, and each will, at the requeBt of the other, execute, acknowledge and deliver any and all instruments which may be necesBary or advilable to carry into effect thiB mutual waiver and relinquiBhment of all such intereste, righte and claimB. l4. BREACH I If either party breacheB any provilion of thie Agreement, the other party Bhall have the right, at hiB or her election, to Bue for damageB for such breach or Beek Buch other remediel or relief as may be available to him or her, and the party breaching thiB contract Bhall be reBponBible for payment of legal feeB and costs incurred by the other in enforcing their rightB under thie Agreement, lS. VOID CLAUSES I If any term, condition, clauBe or proviBion of thil Agreement shall be determined or declared to be void or invalid in law or otherwiBe, then only that term, 6 condition, clause or provision shall be stricken from this Agreement and in all other respects this agreement shall be valid and continue in full force, effect and operation. l6. DESCRIPTIVE HEADINGS I The descriptive headings used herein are for convenience only. They shall have no effect whatsoever in determining the rights or obligations of the parties. l7. INDEPENDENT SEPARATE COVENANTS I It is specifically understood and agreed by and between the parties hereto that each paragraph hereof shall be deemed to be a separate and independent covenant and agreement. lB. ADDITIONAL INSTRUMENTS I 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 instrWllents that may be reasonable required to give full force and effect to the provisions of this Agreement, 19. APPLICABLE LAW I This Agre8lllent shall be construed under the laws of the Commonwealth of Pennsylvania and more specifically under the Divorce Code of 19BO. 20. AGREEMENT BINDING ON HEIRSI This Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective heirs, executors, administrators, succe.sors and a.signs. 2l. ENTIRE AGREEMENT I This Agreement contains the entire understanding of the parties and there are no representations, warranties, covenants or undertakings other than those expressly set forth herein. 7 . 22. KODIFICATION AND WAIVER I A modification or waiver of any of the provisions of this Agreement shall be effective only if made in writing and executed with the same formality as this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall not be construed as a waiver of any subsequent default of the same or similar nature. 23. WAIVER OF RIGHTS I The parties hereto have been informed of their rights or have been advised to seek counsel to inform them of their rights under and pursuant to the the Divorce Code, Act of April 2, 1980, Number 1980-26, particularly the proviBions for alimony, alimony pendente lite, equitable distribution of marital property, counsel fees or expenses, Both partiel agree that this Agreement shall conclusively provide for the distribution of property under the said law and hereby waive, release and relinquish any further rights they may respectively have against the other for alimony, alimony pendente lite, equitable distribution of marital property, counsel fees or expenles, From the date hereof, each party may acquire either personal or real property in their own name. Any property so acquired shall be owned solely by the individual and shall not be subject to any claim whatsoever by the other party. 24. EXECUTION OF DOCUMENTS I Both parties hereby agree to execute any documents required to implement this Agreement. 25. FINANCIAL DISCLOSURE I The parties confirm that they have relied on the substantial accuracy of the financial 8 .. ,"'. . , ' diBcloBure of the other as an inducement to the execution of thiB Allreement. IN WITNESS WHEREOF, the parties hereto have set their hands and Beals the date and year first above written. ~- ~<A' "" Art ur T. McDermott j;/ oJ fJ, PJ-tl. Gail D, Peck tiJ, /.... -~ ~".,-r<L" - ~. ~ Edwara E. pec 9 . . i'~ ,... '- f ~r .. }JI' ! ! , ,. ! If' " , .... . (,.' ~, ,J e {h) '! L" " L - ',' 'J . I , , , G . CI ,,, Gail 0, Pcck, l'lllintiff !"..,~,.. . . :.'V:"'A.' .:Y,".'!'~,':Ti~~'( IN 'l'HE COORT OF ~ Pt.EAS or . .... ClHlERLAND COONTY. PENNSYL~IA , . 00. 95-5378 CIVIL 19 VB. FIlward E. Pcck, Defcndant PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record. together with the following info~tion. to the court for entry of a divorce decree: l. Grounds for divorce: irretrievable breakd~n under Section 330l (c) ~~) of the Divorce Code. (Strike out inapplicable section) 2. Date and manner of service of the complaint: October 14. 1995 restricted. certified mail. rcturn receipt requested 3, Complete either paragraph A. or 8. A. Date of execution of the affidavit of consent required by Section 3301 (c) of the Divorce Cnde: by the plaintiff February 19, 1996 by the defer.dant March 25, 1996 8. (11 Date of execution of tr.e plaintiff'S affidavit required by Sec~ion 330l (d) of the Divorce Code: (2) Date of ser:ice of the plaintiff'S affidavit upon the defendant: 4. Fela~ed claL~s pending: none , 5. Indicate date and manner of se~lice of the notice of intention to file praecipe to transmit record, and attach a copy of said notice under Section 3301 (d)(l)(i) of the Divorce Code February 23, 1996 certified mail, return receipt {' ----.;<-;,?.. -' . ~ ;J- r' ( ._2<-.~ Attorney for Plaintiff/~ -" C.) . ,. ~ III ~ " I! {> " 1': '. j \.~ .I , . . :~) ,,1 c. , , , b~ . '".. :ll " 11.. .. , , " '. . ) GAIL D. PECK, I IN THE COURT OF COMMON PLEAS OF plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I VB. I CIVIL AC'rION - LAW I NO. '15 -5 :3'1 S- et ~ ;:r.. N"'" EDWARD E. PECK, I Defendant I IN DIVORCE IIO'l'ICB TO DBPBIlD MID CLAIM RIGHTS YOU HAVB 88" SUlD 1M COURT. If you wiBh to defend againBt the claiml set forth in the following pages, you mUBt take prompt action. You are warned that if you fail to do BO, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may alBo be entered against you for any other claim or relief requeBted in theBe papers by the plaintiff. You may lOBe money or property or other rights important to you, including custody or viBitation of your children. When the groundB for divorce iB indignitieB or irretrievable breakdown of the marriage, you may requeBt marriage counselling. A list of marriage counselorB iB available in the prothonotary's Office at the cumberland County Courthouse, carlisle, pennsylvania. Ir YOU DO IIO"f PILB A CLAIM FOR ALIIIOIIY, DIVISIOII or PROPIR'l'I, LAIfYIlR' S PBBS OR BKP..SIS, 8IFORB A DIWRCI OR UIItJLIIIII'f IS GRAII'RD, YOU HAY LOSB TIll RImrr TO CLAIM AllY or '1'1IIII. YOU SHOULD TUB THIS PArBR TO YOUR LA1fYBR AT OIICB. IP YOU DO IIOT HAVB A LAIfYIlR OR CAIIIIOT AfFORD 0118, GO TO OR TBLBPIlOIIB TIll OPPIel SIT FOR'l'H BBLOW TO PIlIP OUT WHBRB YOU CAlI Oft LBGAL IIBLP. Court Administrator, 4th Floor cumberland County CourthouBe CarliBle, PA 17013 (717) 240-6200 Arthur T. McDermott, Esquire ARTHUR T. MCDERMOTT' ASSOCIATES Fifty East High Street Carlisle, PA 17013 (717) 243-7807 GAIL D. PECK, , IN THE COURT OF COMMON PLEAS OF , CUMBERLAND COUNTY, PENNSYLVANIA , , CIVIL ACTION - LAW , NO, tt.5 - 5 3'18 C, ,:~(;:I~..". '- , , IN DIVORCE Plaintiff vs, EDWARD D. PECK, Defendant CQllPLAIIlT IH DIWRCB COMES NOW, plaintiff GAIL D. PECIt, through her attorney, Arthur T. McDermott, Esquire and avers as follows, comrr I - DIWRCB l. plaintiff is Gail D. peck, who currently resides at 29 South High Street, Apartment No, 2, Newville, Cumberland County, PA 17241, 2. Defendant is Bdward B. peck, who currently resides at RD '1, Box 3l, New Bloomfield, Perry County, PA, 3. plaintiff and Defendant have been bona fide residents in the commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The plaintiff and defendant were married on August lB, 1990 in Perry County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties, 6. The marriage is irretrievably broken, and the parties are proceeding under Section 3301(c) of the Divorce Code. 7. Neither plaintiff or Defendant are a member of the United States Armed Forces, i WHEREFORE, Plaintiff reque.ts the court to enter a decree of divorce. comrr II - IQUITABLI DI8TRIBU'l'10ll 8. Paragraphs 1 through 7 are included herein a. though stated in full. 9. During the marriage, the parties accumulated certain real and per.onal property which i. subject to di.tribution. WHEREFORE, Plaintiff pray. thi. Honorable Court to equitably di.tribute the marital property. Re.pectfully .ubmitted, ARTHUR T. MCDERMOTT' ASSOCIATES ~~~- Arthur T. HcDel'lDOtt, Esquire Attorney for plaintiff 50 Bast High Street Carlisle, PA l70l3 (717) 243-7807 VERIFICATION OF PLEADINGS I verify that the statements made in this document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S, Section 4904, relating to unsworn falsification to authorities. . )t (uQll.PJl~J: GAIL PICK Date, 16 ~ IO-9:j /""\ .~ ~ t . ~ . In . 0; ;. - ,r..)- . . ~I VI .;J' . <;) "'l '.') 0- ..... = ~ 0- ... = . , GAIL D. PECK, Plaintiff I I I I I I I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PBNNSYLVANIA CIVIL ACTION :;. LAW NO. C/t" - !>"3?" IN DIVORCE vs. BDWARD E. PBCK, Defendant AFPIDAVIT OP COISBII'r 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on OCtober lO, 1995. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing the COIIplaint. 3. I consent to the entry of a final decree of divorce. 4, I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim th.. before a divorce is granted. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of lB Pa. C.S. section 4904 relating to unsworn falsification to authorities. Date I () -Iq . q (; ..J1 o~jJ Q r?~(l GAIL D. PECK '('" Sworn r~r\ljh.... . to and subscribed before me , 1996. z..c~p. this day of ~~ory ~ NOTARIAL SEAl. SHELLY D. SEXTON, NOTAIlY PUBLIC CARLISLE BORO, CUMBERlANO COUNTY MY COMMISSION EXPIRES APRIL ai, tl8l Mtmbll, I'IMsytvlnll Auoclallon at NoIIrlll ?? <.0 i= l.!; 0 ;J> ~~~ 0\ . ::: ~-;: ..:.. )>-: t-- 0..: ' -. ,.0::;' ';~ (': II' ' :l<) !..,!L: ,,: \'.' rb' . ' r: .H,~J I. l.1: ,.(.tJ- 1.<. ll_ I.CI ::i w tr"l () , . Date I ~-v2 "'- 7'C, r ,~._ J:-.... -r.?/ EDWARD B. PBCK ,1stl day of GAIL D. PBCK, I IN THB COURT OF COMMON PLEAS or plaintiff I CUMBBRLAND COUNTY, PBNNSYLVANIA I va. I CIVIL ACTION - LAW I NO. q5~ 537J" BDWARD B. PBCK, I Defendant I IN DIVORCB UrIDAVIT or COIISIII'l' 1. A Complaint in divorce under Section 330l(c) of the Divorce Code waa filed on October 10, 1995. 2. The marriage of plaintiff and defendant il irretrievably broken and ninety daya have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce, 4. I understand that I may lose rights concerning aliaony, division of property, lawyer'l feel or expenles if I do not claim th.. before a divorce is granted. I verify that the Itatementl made in thil affidavit are true and correct. I underatand that falae Itatementl herein are made lubject to the penaltiel of 18 Pa, C.S. lection 4904 relating to unsworn falaification to authorities, ~~:fn to and , 1996. sublcribed before me this c.~, i: qt,1f,d~..J Notary u c -----] 11OT"~I"'L rm [JUDY F I'lllft. "".r,ll lill,,; I'I:rc fkw Q;tom'i~IJ, I err} r."/II,"j'. t A M~ {;r!l'~' ;~.tn r . " h... ~ F';l ____",. ...... ",,~,"'.-."4 ......~, ...-.. i l.~ ." , 11,1 ,-, .~ 0 (,;! . .. . ~ l!_.. ....;~ fl. X ::J ( ':';:t '.: L i U. , " i ,. d . I. "~. , ,. \ I;.' .' - GAIL D. PBCK, I IN THB COURT OF COMMON PLBAS OF Plaintiff I CUMBBRLAND COUNTY, PBNNSYLVANIA I VS. I CIVIL ACTION - LAW I NO. 95-5378 BDWARD B. PBCK, I Defendant I IN DIVORCE NOTICE OF INTBNTION TO REQUBST BNTRY OF DIVORCB DBCREB TOI Mr. Bdward B. Peck c/o Mr. Scott Staller, Esquire Cupp Office Bldq. Rt. 34, P.O. Box 264 New Bloomfield, PA 17068 GAIL D. PBCK, Plaintiff, intends to file a Praecipe to Transmit with the Court on or after March 11, 1996 reque.tinq that a final decree in divorce be entered. C:::-~~AQ ~ ~ Arthur of, McDermott, Bsq. 50 Bait Hiqh Street Carlisle, PA l70l3 (717) 243-7807 Attorney for Plaintiff Dated. February 20, 1996 " , CIRTIrICATI or SIRVICI I hereby certify that a true copy of the foregoing Notice of Intention to Requelt Entry of Divorce Decree wal lerved on the Defendants counlel, by certified mail, return receipt requelted and by placing a copy in the U.S. mail, first clan, postage prepaid, and addrelled al followsl 1Ir. Scott Staller, Isquire Cupp Office Bldg. Rt.3., P.O. Boa 2'. ... Bloaafield, PA 17068 Dated, ~~7 /~} ')1(~ I ( ---...---.- _._~---, (/------?':~(/ .~-~ ~'"/ - t .- Arthur T. McDermott, laq. 50 East High Street Carlisle, PA l7013 (717) 243-7807 l;~ In i-:: ~F <..:J ',' ii, , ; ," . '. ~ '. ~"' ... ',' , \ .s .~ ~ , ~- ,,,.e" ~t. .! ,~! U\L ' I c-J "'",....,- .t: 4V~ c- "1': " L~ .1 . :_"tJ '" ,,1,-,. " \.>. ,'.' II. I.'" :.1 u ,,' u " " . . I GAIL D. PBCK, I IN THB COURT OF COMMON PLEAS OF Plaintiff I CUMBBRLAND COUNTY, PENNSYLVANIA I vs. I CIVIL ACTION - LAW I NO. 95-5378 IDWARD E. PICK, I Defendant I IN DIVORCB WAIVER OF COUNSBLLING GAIL D. paCK, being duly sworn according to law, deposes and says I 1. I have been advised of the availability of marriage counselling and understand that I may request that the Court require that my spouse and I participate in counselling. 2. I understand that the court maintains a list of marriage counselors in the Domestic Relations Office, which list i. available to me upon requelt. 3. Baing so adviBed, I do not request that the Court require that my spouse and I participate in counselling prior to a divorce decree being handed down by the Court. I understand that false stat8lll8nts herein are made subject to the penalties of 18 Pa. C.S, section 4904 relating to unsworn falsification to authorities. BCK me thiB 26tl.. day of Sworn to and subscribed before j:t.bf\l~1 1996. ~t~ Al SEll SHEIJ.YD.5EXTON, NOTAIlYPUBUC OAllllSlE 101I0, CUMBEIllAND COUNTY MYCDMMISSION EXPIRESAPRIL 21, 11M Member, f'ennlyIVlnl. Auocl.tlOft 01...... ~ ..0 '- 0 '- j:~ 0\ J. ~: -:) .~ ~c ;' ,~~ ..'- -, ~-,"' ,.(- ~. ~.1 ;~:! ~c : 'in 1.1'-. "I ::;:; -' l1:t!. c. ,.. Il,"j I" LJ~I ; ,1l~ l._ I'. ,..("1 ~:S 0 u't (.) , , \. .. -- GAIL D. PBCIt, . IN THB COURT OF COMMON PLBAS OF plaintiff . CUMBBRLAND COUNTY, PBNNSYLVANIA . VI. . CIVIL ACTION - LAW . NO. 95-5378 BDWARD B, PBCIt, . oefendant . IN DIVORCB WAIVER OF COUNSBLLING IDIARD I. PICK, being duly eworn according to law, deposes and says. 1. I have been advieed of the availability of marriage counlel1ing and underetand that I may request that the Court require that my epoUle and I participate in counselling. 2. I underltand that the court maintains a liet of marriage counlelor. in the Domestic Relations Office, which list i. available to me upon request, 3. Being eo adviled, I do not requeat that the Court require that my lpoUle and I participate in counselling prior to a divorce decree being handed down by the Court. I understand that fa lee statements herein are made eubject to the penaltiel of 18 Pa. C.S. section 4904 relating to unsworn falsification to authorities. B~:-~~~~ W\n... n Sworn to and subscribed before me this d day of ~ 199~.-] . C_ ...t. .A;{ -f f 1 n.4.4U~e .., U Notary pubrrc- -----'J tn~'H'.tI. ~'!}L \'''''''1''''11'''''\' ,,['" ,...'OJ I 1<.,."" ~.' ," ll~1t ~,'."il.<.,:'J_1 if"\; t :,,;",1\ ~~f C :;';,,~>.m f' t'!',' " 71 ... -,,-." "'.~ -. ., -...~- ....... ~ t.~ U) j . .. .. !.s~' ~~:! ,'..-r- 1,." (I .- J: ~ .; ~'i~ l'~~ i' .. , ~J '(. 8" I::> "Ij 'u" ,1..- ..J, : ~:-:;; U::' r': J;11 1.'- 0 to:'; -'.:i- I' ,n ..) l. ", U .' -., . . . GAIL D. PECK, I IN THE COURT OF COMMON PLEAS OF Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I vs. I CIVIL ACTION - LAW I NO. 95-5378 EDWARD E. PECK, I Defendant I IN DIVORCE AFFIDAVIT or BIRVICI BY IlAIL PUR8~ ~ P.. R.C.IP. 1920..(.,(ll(iil COMMONWEALTH OF PENNSYLVANIA I I SS COUHTY OF CUMBERLAND I Arthur T. McDermott, Esquire, being duly sworn according to law, deposes and says that he is the attorney for plaintiff, GAIL D. PICK, and that he did serve a true and correct copy of the Notice of Intention to Request Entry of Divorce Decree filed in the above matter, by certified mail, return receipt requested, on the Defendants counsel, 8CO'l"I' B'rALLIR, on February 23, 1996. The receipt form is attached hereto as Exhibit "A", .~~\. ~ur T. McDermott, Esquire Sworn to and subscribed before me this ~~ day of February, 1996. &,~~~ Not b c SHEllY 0, SEXTON, NOTARY PUBlIC OARUSLE lORD, CU"'ERlAHD COUNTY MY COIAIIISION EXPIRES APRIL 21, I. MtmIIIr I'IMI1fVInII AIIoclalllll ot_. . : I .:..1_.... __...-. llllo wlIh III 110II'II'" , ~_.,... "'11I. lalIcMln8..... (lor'" 11Wil~_"'_""'_oltNI.........._..._tNI I_III): . .=::tI:"..........................,.......-.--... I. [J Addflll .'IAddfIM , I .~,....---..............:.~........ R. [J ~~lllI'lDlllvllY : .""---........-.......- .....- . I ........ ConNI ,.Get1l_fllor III. . t ~r. ~.. S+~\lU'1 Es~, , c...,t ~ 6~. , ~+:l1/, 1).0, &r z,-y Nt~ 6ItJ1,,,,.{ltl,{, fA l1tJl,r ~: II . ""H.." pIIId} '.l i J\S~S (I 0 '- -.. I ; i Ul .. , ) .~~ (~ l\l -- ,. --" I.' ...1.: " l. In ) f;. (-,J . . P" ,j L \,. ,.... lL. :"'.1 ,,' I ,;,', u , , ( , , .~ GAIL D. PECK, I IN THE COURT OF COMMON PLEAS OF plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I VB. I CIVIL ACTION - LAW I NO. 95-5378 BDWARD E. PECK, I Defendant I IN DIVORCE Al'PIDAVI'l' or SIRVICI BY MIL PURS~ TO Pa. R.C.1P. 1920..'a"l't11' COMMONWEALTH OF PBNNSYLVANIA I I SS COUNTY OP CUMBERLAND I Arthur T. McDermott, EBquire, being duly Bworn according to law, depoleB and BaYB that he iB the attorney for plaintiff, GAIL D. PIICK, and that he did Berve a true and correct copy of Plaintiff' B Complaint in D1vorce and Notice filed in the above utter, by uil certified, reBtricted delivery, return receipt requested, to the Defendant, IDMARD I. PICK, on october 14, 1995. The receipt 'form iB attached hereto aB Exhibit "A". ~ <---,. , ~r T. McDermott, Esquire Sworn to and Bublcrlbsd before lIIe this I-Pl-, day of october, 1995. . ~Pu~ NOTARIAl SEAl. 0=0, SEXTON, NOTAIlYPUBLlC MY lORD, CUMBERlAND COUNTY CDelllllSlOIl EXPIRES APRIL 28 1881 Member, ",_-.1. Aaaocla/IDn of NoIaIIIl -...- ~ r,. .. .~R.... .. I.- 1 ..- . lot -.. ........, I..... with 10 llOIIw. \fit. ' ... ..' _ t. 1M 41 . b. 'oIIowlng IIIVIcN 1101 W' . . I! ~-:::=_,,,,",,".....II""''''''''lhll''''''' '..II . .. La'. !lO\~~~IO""""'I'I""""""',....""-",,,,,, ,. ~o A......'. A4:fl ' , .._........" Ill...... ..........._IllI........I'UI'lbII. 2 ....lIlcled DIIIYIIY .. : I' "'"~"........-................_...,.......- C'. . !J~~:\'i\.X ff ~.:..v o...:"~9Ii : u...~ ~"".ffdd 1.4 '1C11/P )lJCIIllfled 0 COIl .-. I: ,,,,*,, I 0 IIqIIHt ~ 0 .... 7. Dat. of DIIIVlfY .. . I: J: I, ll~ CA....lI I i .If. otm 011.1._'-'''4 DOMIITIC.TURN MClII'1' ' , DlCtmber 1111 .,.. "'., - ".. ;~ -: , , ., u..U,-'''l ~:z:.rQ 4" ,_.i...., ..J . \....,..... lfl.t;"..'J'." i.Wn..'C.r ~JltJ' I~ :z: ..~. 't1 .-. , ~>~ ... , ;.lr ., , \ J J ... tW'J 2 q 1995 tJ.' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GAIL D, PECK, Plaintiff/Respondent : CIVIL ACTION - LAW y, : No. 95-5378 EDWARD E. PECK, Defendant/Petitioner ORDER AND NOW,thi~ Day of _~_, 1995, it is hereby ORDERED, DIRECTED AND DECREED, pursantto 23 Pa,C.S.A. 0 3302(b), Gail D. Peck and Edward E. Peck shell undergo marriage counseling for three sessions within ninety (90) days following the filing of the divorce complaint, which was filed on October 10, 1995, The Defendant, Edward E, Peck, shall choose said marriage counselor and shell be liable for any and all costs and/or fees associated with said marriage counseling, BY THE COURT: J. ': 'j,:...;t<' 'jlP ,t l. ' '; . , "I, i ~ 1 -H"~I i .~~ it ~'c. . ; SG. I"~) ''} r \ J1J . , , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GAIL D. PECK, PlaintilT/Respondent : CIVIL ACTION - LAW v. No. 95-5378 EDWARD E. PECK, Defendant/Petitioner MOTION FOR MARRIAGE COUNSELING AND NOW, comes the Petitioner, Edward E. Peck, who by and through his attorney, Scott M. Staller. Esquire, files the within motion and respectfully represents as follows: 1. On October 10, 1995, Respondent filed a Complaint in Divorce to the above captioned matter. 2. Petitioner believes that Respondent is blaming him for problems In her previous marriage. 3. Respondent is unwilling to communicate to Petitioner the problems that she perceives with the marriage in an elTort to attempt to resolve the differences between the parties. 4. Petitioner realizes that he yells too much and has a problem with alcohol, but desires to know what other problems, ifany, Respondent perceives of the marriage. 5. Petitioner believes that marriage counseling may benefit both parties in this case. , . . . . WHEREFORE, Petitioner requests thutthe court order Respondent to underllo marrialle counselinllPursuantto Title23 Pa.C.S.A. fi 3302(b). ~;jf11 J Ail/l, Scoll M. Staller, Esquire P. O. Box 264 New Bloomfield, P A 17068 Telephone: (717) 582.7574 Allorney for Petitioner I verifY that the statements I1UIde in this Motion for Marrialle Counselinll arc true and correct. I understand that false statements herein arc I1UIde subject to the penalties of 18 Pa.C.S. fi 4904 relating to unsworn falsification to authorities. Date: //-/6 .- 'i'''o- r1 a._.J <'~ /.'f:-<f" Edward E. Peck, Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA GAIL D, PECK, Plaintiff/Respondent : CIVIL ACTION - LAW v. : No. 95-5378 EDWARD E. PECK, Defendant/Petitioner CERTIFICATE OF SERVICE I hereby certify tllatl am this day serving a copy of the Motion for Marriage Counseling on the person at the address indicated below by mailing the same to the addres5 below, which service satisfies the requirements ofP.R.C.P. 440: Arthur T. McDermoll. Esquire Fifty East High Street Carlisle, PA 17013 Dated: November 17, 1995 /-=d ~ P ~Sfa er, Esquire p, O. Box 264 New Bloomfield, P A 17068 Telephone: (717) 582-7574 Allorney for Edward E. Peck, Defendant 1