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HomeMy WebLinkAbout96-00339 ~ 1 ~1 o ' ~. (/) j L ~ "?' .f \I) I $ r ~ J ~ (Y)' I I ! ~ I 0-1 I ~~ *--~~~~~~~~---~---~~-~~;~--~-~~~:~ ~ -- ----- ~ $ 8 8 ~ 8 . . S 8 ~ W '.' IN THE COURT OF COMMON PLEAS ~ ..:., ~ OF CUMBERLAND COUNTY STATE OF '* PENNA. " " w ... ,~~ ~ s ,', ~ MARTHA K. SHOVER, :1 N Il. .~,?:::~,~,~....... ,~,~,y..~~.. i ',' w '.' Plaintiff ~ ... VCI'SUS MAC E. SHOVER, ~ '.' . . " . . ! ~ '.' Defendant ~ ',' $ w ',' DECREE IN DIVORCE W ',' Wl ',' ~ ~ ',' AND NOW, .., ..&.1;':") "~9... '., .. .. ,... 19 ,cr,~... it is ordered and decreed that..", "" ",~!\.R,~~~, .K,., , ~~,q'{~~., ",." "'""..., plaintiff, and, ,. " " " ., , , , , . , , , , , ~~9, ,E,', , ~~?,~~~" , , " , , , , , , .. , , , , ". defendant, are divorced from the bonds of matrimony. ~ ~ 8 ~ ... 8 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 PARTIES MARITAL SETTLEMENT AGREEMENT DATED FEBRUARY 9, 1996 8 ~ 0;' ..:.. ~ ~ .. ...... ......... ... ...... ....... ......... .... ..... ......... ............... IS INCORPORATED HEREIN AS AN ORDER OF COURT. ~ ...... ............ . ........ ..... ..... ...... ............ .... ............... ~ .,' 1{i Dy The Court: Alle~..,r ~ '~.g,. .// ~ J. .......... rlC< ?()~""<;., ,~7",..11.'~et:r -L';;L-1'l:1 K ~..& W / / r..70thonotnry ~ ,,' ~ ,~ ~ ~ ~ ~ ~ r! 1': ,-: - -;:- ; ;. ";". , .1t..' '4f:. ':'..' .~... .~.. . ..' "... ~.~..~--~"".,"-. ,. ~ ~*-~~-----------*---~-~. ~ " " 8 8 ~ ~ ~~ ,', ~ ~ 8 ~ ..:., ~ w ~.' .', ~ ~ ',' ~ ',' ~ 8 l~ ~ (~ I~ I;' J~ /''- :* , . .~ . ' ~ ".' "~ , ' I.'. i~ , . ~ J 1't: tJ"i ~jJj ,:H~Ji? ~ a:lf ~w., t '5 It '71~-, f/f~;':.tb '7j, c~' .. . ... , I I I ~ MARTHA K. SHOVER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 96-339 CIVIL TERM CIVIL ACTION-LAW IN DIVORCE v. MAC E. SHOVER, Defendant AND NOW, this ORDER 01" COURT 1.0 ~ day of , 1996, vt1 ' " . this Qualified Domestic Relations Order is hereby ordered and directed. 1. The parties are as follows: Martha K. Shover 16 Spring Garden Estates Carlisle, PA 17013 Plaintiff in divorce action Mac E. Shover 341 Fairview Street Carlisle, PA 17013 Defendant in divorce action Employee of Keystone Railway, Inc. S.S. . 206-32-1115 S.S. . 161-34-1314 2. The parties intend for this Order to constitute a "Qualified Domestic Relations Order" as defined in Section 414(p) of the Internal Revenue Code of 1986, as amended. 3. This Order applies to the following Qualified Retirement Plan: The Keystone Railway 401K Plan, "Plan." 4. Mac E. Shover, 161-34-1314, hereinafter referred to as "participant" is a participant in the plan, presently a defendant in the divorce action. 5. Martha K. Shover, 206-32-1115, hereinafter referred to as "alternate payee," is the participant's spouse, presently a plaintiff in the divorce action. ,. , , . , 6. Participant's current and last known mailing address is: 341 Fairview Street, Carlisle, Pennsylvania, 17013. 7. Alternate payee's date of birth is January 2, 1941. Alternate payee's current and last known mailing address is: 16 Spring Garden Estates, Carlisle, Pennsylvania, 17013. 8. A portion of the participant's account in the plan is marital property and subject to distribution by this court. Following receipt of this QDRO by Keystone Railway, Inc., the alternate payee shall receive fifty (50%) percent of the total value of the plan using the balance on January 23, 1996, the day on which the Complaint in Divorce was filed. This sum is to be withdrawn from participant's account in the plan and distributed directly to alternate payee or her designated qualified tax plan which shall receive this rolled over amount. Alternate payee shall be solely responsible for any required federal tax withholding or payment required as a result of this transfer. 9. The non-taxable portion of the Alternatp Payee's distribution shall be paid directly to the Alternate Payee. 10. Alternate payee select one (1) initial choice: (A) The taxable portion of the Alternate Payee's distribution shall be paid directly to Alternate Payee. The Alternate Payee is aware of the rollover option and understands that the Plan Administrator will withhold 20% taxable portion of her distribution for federal taxes. 13. Any reasonable cost incurred by the Plan Administrator to effectuate the terms and provisions of this order may be assessed against that party requiring the services of the Plan Administrator. In the event both parties require services or the Plan Administrator, then such expenses shall be divided equally between them. 14. The parties shall promptly notify the Plan Administrator of any changes in their address from those set forth above in this Order. 15. The parties shall promptly submit this Order to the Plan Administrator for determination of its status as a Qualified Domestic Relations Order. IT IS INTENDED that this Order shall qualify as a Qualified Domestic Relations Order as such is defined under Section 414(p) of the Internal Revenue Code of 1986, as amended. The Court retains jurisdiction to amend this Order as might be necessary to establish or maintain its status as a Qualified Domestic Relations Order. BY THE COURT, cc: Michael A. Scherer, Attorney for Plaintiff 'l'dp; /Ita:'&' &/3;;;" Mac E. Shover, Defendant - &ILl, ",;,~ t../JI.;/ Keystone Railways, Inc. r1 ~ - SEPARATION AND MARITAL SETILEMENT AGREEMENT THIS AGREEMENT, made this '11 day of Feb(tl~t''J ' 1996, by and between MARTHA K. SHOVER, hereinafter referred to as "Wife", and MAC E. SHOVER, hereinafter referred to as "Husband". WITNESSETH: WHEREAS, the parties are Husband and Wife who were married on November IS, 1985, and continue to reside together in the marital residence but intend to establish separate residences within one month; and, WHEREAS, the Wife has instituted divorce proceedings in the Court of Common Pleas of Cumberland County to No. 96.339 Civil Term by Complaint filed on January 23, 1996; and, WHEREAS, the parties desire to settle fully and finally their respective financial and property rights and obligations as between each other, including without limitation by specification: the settling of all matters between them relating to the ownership in equitable distribution of real and personal property and related economic claims including but not limited to spousal support, alimony and alimony pendente lite; and in general the settling of any and all claims or possible claims of one against the other or against their respective estates; and, WHEREAS, Wife is represented by her separate legal counsel and has been advised of her respective rights, privileges, duties and obligations relative to the parties' property rights and interests under the Divorce Code and regarding alimony and spousal support, and 1 !"'"-,,._,.' ~ Hushand has volunlurlly chosen to he unrellresellled In Ihls maller, hut has heen advised and continues to understand that he hils Ihe right to he represented hy his own separate legal counsel who could advise him regllrlllng his respective property rights, privileges, duties and obligations relative lOthe parties' properly rights und Interests under the Divorce Code und regurdlng ulimony und spnusal support; allll, WHElmAS, euch purty Is fully familiar with the marltul property und both parties now desire to sellle and determine his and her property rights and claims under the Divorce Code, Including ull clulms regarding equltahle dlstrlhutlon of murital property, alimony, spousal support and reluted eeonCllllle c1l1lms. NOW, THEREFOIm, the parties herelll helnglegully hound hereby, do covenant and agree as follows: I. l11e purtles IIgree to the entry of a Decree In Divorce pursuanl to Section 3301(C) of the Divorce Code. Olllh partics shall execute und file the requisite Consents with the Court as soon as the luw permits the pending divorce uction to be concluded, and Wife's allorney shall thereafter file the I'ruecipe III Trunsmit the record and obtain a Decree in Divorce withoat delay. Should either party do anything to delay or deny the entry of such a Decree, or fail to do anything required to ohtain the Divorce Decree in breach of this Agreement, the other party mllY, at his or her option, declure this Agreement null and void, ab Initio. 2. This Agreement and all wllrranlies and representations contained herein shall survive the Divorce Decree amI shall continue to be enforceable in accordance with its 2 < " ....."..c."...,.,_.... _I.. terms. No Court may change the terms of this Agreement, and it shall be binding and inclusive upon the parties. The Court, however, shall retain jurisdiction of this matter following the divorce for the purpose of modifying the Qualified Domestic Relations Order, if necessary to effectuate the distribution of Husband's pension. An action may be brought at law, in equity or pursuant to the provisions of the Divorce Code to enforce this Agreement by either Husband or Wife. In the event of a reconciliation, attempted reconciliation or other cohabitation of the parties hereto after the date of this Agreement, this Agreement shall remain in full force and effect in the absence of a written agreement signed by the parties expressly stating that this Agreement has been revoked or modified. 3. The parties are joint owners of real estate situate at 341 Fairview Street, South Middleton Township, Carlisle, Pennsylvania. Husband shall refinance this real estate by obtaining a loan which he will be solely responsible to repay. After satisfying the current mortgage to Farmers Trust Company, Husband shall pay Wife the sum of $14,000.00 at the time of disbursement of the new loan, representing Wife's marital share of her interest in this property. Upon receipt of the $14,000.00, Wife shall deliver to Husband a Quitclaim Deed conveying all her ownership interest in this real estate to Husband. 4. The parties agree that Husband shall become the sole and separate owner of the following personal property, presently located in the real estate at 341 Fairview Street, Carlisle: lawn and garden tractor, snow blower, woodworking tools, meat processing equipment, his bed, the camcorder, a refrigerator and television. Except for the forgoing, Wife will become the sole owner of all other personal effects, household furniture and 3 , furnishings In the relll eMllle loclllelllll 341 Flllrview Streel. Carlisle, and she may remove these items from the IIIlIrlllll residence III her convenience. Wife will become the sole owner of the 19HH I'IYllloulh Sundllnce, IInd IlushlllllJ shall become the sole owner of the 1994 Chevy S.1O Truck. Elich pllrly will hcrellfter he responsible for any loans outstanding on these lIutml10hlles liS well liS olher ClIStS including registration and maintenance. Neither Jlllrty will herellfler IIIlIke II Cllllrl1 fur IIny such items which have been designated as property of the olher pursullnt ICl Ihls pllrllgruph. Each party will execute any and all documents necessary 10 effectullle the lrunsfer of ownership of any items of personal property titled in hoth nllllles. 5. '111e pllrlles IIgree 111IIt Wife shall become the sole owner of the Financial Trust Corp, slIvinlls IIccounl. heing IIccounl number 007.306150. with a balance of $1,696.59. HusblllllJ shllll hecml1e the sole owner of a $10,000,00 inheritance which he received in Janullry. 19%, in connecllon with Ihe death of his mother. The parties will divide equally the United SIllIes SlIvlngs Bonds which are currently in the possession of the parties. The parties shlllllllso divide equlllly Hushand's pension plan in connection with his employment lit Keystone J{lIl1wIlY. helng ul'rudential Mutual Fund Services pension, Plan Number 4620. Account NUlllher 161.34.1314, vuuled as of December 31,1995 at $26.368.93. The valuation dute fur division purpnses shall he Junuary 23, 1996. the date of the filing of the Divorce Cml1plullll. Wife shull he permilled to immediately withdraw her one half sbare of this pension plun liS soon us permilled by the pension plan administrator. The parties agree to cooperute In Ihe preparation of a Qualified Domestic Relations Order which will effectuate 4 !, ~ ....., ........' ,.. ~ .. o Wife's withdraw of her share of the pension from the pension plan. Aside from the matters above, the parties have divided between them to their mutual satisfaction all other intangible personal property such as cash, bank accounts, annuities, securities, and insurance policies. The parties hereby agree that all such intangible property presently in the possession of or titled in the name of Husband shall be his sole and separate property, and intangible property presently in the possession or titled in the name of the Wife shall be her sole and separate property. 6. Except as herein otherwise provided, each party represents that she and he have not heretofore incurred or contracted any debt or liability or obligation for which the other may be held responsible or liable. Each party agrees to indemnify and save and hold harmless the other from and against all such debts, liabilities or obligations of any kind which may have heretofore been incurred between them, except the obligations arising out of this Agreement. 7. Both parties covenant, warrant, represent and agree that each will now and at all times hereafter save and keep each other indemnified against all debts, charges, or liabilities incurred by the other after the execution of this Agreement, except as may be otherwise specifically provided for by the terms of this Agreement and neither of them shall hereafter incur any liability whatsoever for which the Estate of the other may be liable. Each party further agrees to indemnify and save and hold harmless the other from any and all liabilities he or she may incur upon the obligations of or assumed by the other, which indemnification as to all provisions of this Agreement shall include the right to recover out 5 " -..A. I of pocket expenses and reasonable attorney's fees actually incurred. 8. Both parties agree that the hereinabove set forth Agreement constitutes an equitable distribution of their marital property and equitable resolution of all other economic claims pursuant to tbe provisions of the Divorce Code and each party irrevocably waives, releases, and remises any claim to ownership of or interest in any property designated as the property of the other by virtue of the provisions of this Agreement except as otherwise may be provided pursuant to the provisions of this Agreement. 9. Husband does hereby release, remise, quitclaim and forever discharge Wife and the estate of the Wife from any and all claims he has now, ever may have or can at any time have against the Wife or her estate or any part thereof, whether arising out of formal contracts, engagements or liabilities of the Wife, arising by way of widower's right or under the Intestate Law arising by any right to take against the Wife's will, arising out of the Divorce Code, Act No. 26 of 1980, as amended, including, alimony, alimony pendente lite, counsel fees and expenses, arising as a right to spousal support or arising by any nature whatsoever, excepting only those rights accorded to the Husband under this Agreement. 10. Wife does hereby release, remise, quitclaim and forever discharge the Husband and the Estate of the Husband from any and all claims she has now, ever may have or can at any time have against the Husband or his estate or any part thereof, whether arising out of formal contracts, engagements or liabilities of the Husband, arising by way of the widower's right or under the Intestate law, arising by way of any right to take against the Husband's Will, arising under the Divorce Code, Act No. 26 of 1980, as amended, including, 6 - alimony, alimony pendente lite, counsel fees and expenses, arising as a right to spousal support arising by any nature whatsoever, excepting only those rights accorded to the Wife under this Agreement. 11. If either party to this Agreement resorts to a lawsuit or other legal action pursuant to the provisions of the Divorce Code or otherwise shall enforce the provisions of this Agreement, the successful party shall be entitled to recover his or her reasonable attorney fees, actually incurred, from the other as party of the judgment entered in such legal action, whether in law, in equity. pursuant to the provisions of the Divorce Code or otherwise as the same shall be determined by the Court. 12. The parties do herehy warrant, represent and declare and do acknowledge and agree that each is and has been fully and completely informed of and is familiar with and is cognizant of the wealth, real and/or personal property, estate and assets, earnings and income of the other and that each has made a full and complete disclosure to the other of his or her entire assets and liabilities and any further enumeration or statement thereof in this Agreement is specifically waived. 13. This Agreement constitutes the entire understanding of the parties. There are no covenants, conditions, representations or agreements. written or oral, of any nature whatsoever, other than those herein contained. 14. This Agreement is subject to modification only hy a subsequent legal writing signed by both parties. It shall he construed according to the laws of the Commonwealth of Pennsylvania. 7 ., , . 15. Husband and Wife acknowledge that each of them has read and understands his and her rights and responsibilities under this Agreement, that he and she have executed this Agreement under no compulsion to do so but as a voluntary act. 16. This Agreement shall hind and inure to the benefit of the parties hereto and their respective heirs, executors, administrators, successors and assigns. IN WITNESS WHEREOF, the parties hereto intending to be legally bound, have set their hands and seals the day and year first above written. WITNESS: ~U" 'tYJ ~ K j}~ (SEAL) MARTHA K. SHOVER -, (' / n </ "J i dj.J(( '/J1rLe" C ~~L,... (SEAL) MAC E. SHOVER domcatlC'/diYol't'C/ihoycr.lgr 8 - STATE OF Pennsylvania COUNTY OF Cumberland . . : SSe AND NOW, this 9'!/j day of Ckh- . ,1996, before me, the undersigned officer, personally appeared MARTHA K. SHOVER, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. 1noi1 r ~ uJwuw Notarial Seal Jennlfor S, Calaman, Nolary Publlo Cartlslo Born, Cumbertand CounlIi My Commission EXpires Nov. 29, Idgg MrmbPr. Pennsylv,n,. AssoelaNon of Nolartes STATE OF Pennsyh'anla SS. COUNTY OF Cumberland AND NOW, this 9ct.n day of 5/-e1r. ,1996, before me, the undersigned officer, personally appeared MAC E. SHOVER, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he executed same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. r letm'a! Seal .Ir.nnilnr S. C;11::tm:m, NolnfY. Pub1Io C;lIIL-,\.~ PO.\). GllmberlandOctmtY ~ '.'v C0i11rr,i:"'.i1:l Explm~ Nov 29. '999 [' ' .!",,',.,.r"..ti..,!i.1nofUntar1~S \~:-Ll,tJ,'1 t :i:: . '. ~ - . 4. Related claims pending NONE MARTHA K. SHOVER, Plaintiff V. IN THE COURT OF COMMON' PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 96-339 CIVIL TERM MAC E. SHOVER, Defendant CIVIL ACTION-LAW IN DIVORCE PRAECIPE TO TRANSMIT RECORD To 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 3301(c) . 2. Date and manner of service of the complaint DEFENDANT SIGNED AN ACCEPTANCE OF SERVICE ON JANUARY 27. 1996 3. (Complete either paragraph (a) or (b).) (a) Date of execution of the affidavit of consent required under Section 201(C) of the divorce code: by the plaintiff MAY 13. 1996 ; by the defendant MAY 11. 1996 (b) (1) Date of execution of the plaintiff's affidavit required by Section 201(d) of the divorce code N/A (2) Date of service of the plaintiff's affidavit upon the defendant N/A 5. Indicate the manner of service the notice of intention to file praecipe to transmit record, and attach a copy of said notice under section 201(d)(1)(i) of the Divorce Code N/A ~j~ MICHAEL . SCHERER Attorney for the Plaintiff - :.) '. . ;j ) ,; i'i: In ?:: ..~ N .' .. .' UJ~:1 N :i~ ( ).:. U ~ -- [l;~-' :r: u~:: ~;_:, <.:.. . -,~, j '-I;' r., . '~ "J -1 , fL.... :=-: ..' I,',i . r...; -, ~',..L_ " 10 ~ Cl -' C"' U ~ Ul ..: w ~ "" . >- ZE-t OZ :C6..: :c <J.... o Z uc::a< "'Z> O<~ ~>- E-tO::Ul o::WZ OalZ O:Cw uO"" U w'" ::Co E-t Z .... . 0:: W > 0..... ::c..... Ul.... ..... C t<:.... <Ill ::c.... E-t"" 0:: ;j 1 ~ . \'" ~ ~~\ \ \. \) ~ ~ N. \..: ~ \.. ........ ~, \. ~ ~ ~ " ""- . > 0:: W >.... oc ::Clll Ul'O C 'QJ t>l..... QJ uc::a < :c . .. . "'~ \::I, ::::--. ~~ t "'-.l W U 0:: ~ 0 < " > ~ ~ c .... I ... c::a Z t ~ 0 ~ ~ Ii ~ Z .... :;; ~ .... IDE-t E ~ OlU ~ ~ E-t Ol< ~ ~ z.... ~ ~ .... ~ ~ . < .... 5 e ~ ~ > "" .... 113 ~ ~ :c U 0 0 u . " .. . . v. 96- 3 3:7 CML 'mRM " . MAR'lllA K. SHOVER, Plaintiff IN 'mE CXXJRT OF ~ PLEAS OF CUMBERLAND OXJNTY, PENNSYLVANIA MAC E. SHOVER, : Defendant CIVIL ACl'I<:N-LAW IN DIVORCE oorlCE '10 DEFEND AND CLAIM RIGtn'S You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take pratpt 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 judgnent 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 inportant to you, including custody or visitation of your children . When the ground for the divorce is indignities or irretrievable breakdown of the rrarriage, you may request rrarriage counseling. A list of rrarriage counselors is available in the Office of the Prothonotary at the CUnberland County Court House, Carlisle, Pennsylvania. IF 'YOO DO oor FIlE A ClAIM FUR AL:IM:!ff, MARITAL PROPERTY, CXXJNSEL FEES OR EXPENSES BEFORE 'mE FINAL DECREE OF DIVORCE OR ANNUrnENT IS GRAN'mD, 'YOO MAY LOSE 'mE RIGHT '10 ClAIM ANY OF 1lfE1of. 'YOO SHOOID TAKE '!HIS PAPER '10 YOOR ATIORNEY AT <:NCE. IF 'YOO DO oor HAVE AN ATIORNEY OR CANl'Dl' AFFORD OOE, 00 '10 OR 'lELEPHOOE 'mE OFFICE SET FOR'm !3E:I1M '10 FIND oor WHERE YOO CAN GET ux;AL HELP. Court lIdministrator CUntlerland County Court House Fourth Floor Carlisle, PA 17013 Telephone: (717) 240-6200 - . . MARIHA K. SHOVER, , Plaintiff IN THE CXXlRT OF a::MI:N PIEAS OF 0JMBERLl\ND ClXMl'Y, PENNSYLVANIA v. 96- CIVIL 'mRM MAC E. SHOVER, Defendant CIVIL AC'l'ICN-UIW IN DIVORCE CDoIPLAINl' UNDER SECl'ICNS 33011C\ AND 330110\ OF THE DIVORCE ())[)E 1. Plaintiff is MARTHA K. SHOVER, an adult individual who currently resides at 341 Fairview Street, Carlisle, CUrrberland County, Pennsylvania . 2. Defendant is MAC E. SHOVER, an adult individual who currently resides at 341 Fairview Street, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents in the Carm:mwealth of Pennsylvania for at least six JI'Onths imnediately previous to the filing of this Carplaint. 4. The Plaintiff and Defendant were lll'3rried on Noventler 15, 1985, in Plainfield, CUmberland County, Pennsylvania. CXXJNT I - DIVORCE 5. Plaintiff hereby incorporates by reference paragraphs 1 through 4 above. 6. There have been no prior actions of divorce or for annulment between the parties as to their current marriage. 7. Neither Plaintiff nor Defendant is in the Armed Forces of the United states. 8. Plaintiff avers that the marriage between the parties is irretrievably broken. .. . " . , , 9. The Plaintiff has been advised of the availability of counseling and that she IMY have the right to request that the court require the parties to participate in counseling. WHEREFORE, Plaintiff respectfully requests this Honorable court to enter a decree in divorce. CXXJNT II - DIVISlOO OF PROPERTY 10. Plaintiff hereby incorporates by reference paragraphs 1 through 9 above. 11. The parties have acquired personal property, including autarobiles, bank accounts and other items of miscellaneous property during the course of their marriage, sane of which is marital property. WHEREFORE, Plaintiff respectfully requests this Honorable court to enter a decree which effects an equitable distri.bution of marital property. Respectfully subnitted, Date: 1.2~.q(, ~~A Ct ~~ ~chaelA. Scherer, E~ire J.D. #61974 17 West South Street Carlisle, pennsylvania 17013 (717) 249-6873 Attorney for Plaintiff darestic/divorce/Bhover. can , . .' . . ,I . " VERIFIClTICIf I verify that the statements IMde in this Carplaint are true and correct. I understand that false statements herein are JMde subject to the penalties of 18 Pa. C.S. S 4904, relating to unsworn falsification to authorities. '-()) ~ I( ~ Ml\R'llfA K. SHOVER Date: 1- ~""- q lP , , "_. .,,____l _ . , . . I . MARTHA K. SHOVER, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 96-339 CIVIL TERM CIVIL ACTION-LAW IN DIVORCE MAC E. SHOVER, Defendant AFFIDAVIT OF CONSENT, ACCEPTANCE OF SERVICE AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. A complaint in divorce under Section 3301(C) of the Divorce Code was filed on January 23, 1996. 2. Defendant acknowledges receipt and accepts eervice of the Complaint on January 27, 1996. 3. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 4. I consent to the entry of a final decree in divorce without notice. 5. 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. 6. 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. 7. I have been advised of the availability of marriage counseling and understand that I may request that the court require counseling. I do not request that the court require counseling. I verify that the stateme~ts 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. Section 4904 relating to unsworn falsification to authorities. Date: o/'l" /f'J. "JJ?rLt'. ~ .dL-i.. Mac E. Shover i' f!'; { .. 1'4' {. .'- , , ;.1 '. " ,,", .J ~ , o . . . . < -.' . .' . . I' , MARTHA K. SHOVER, plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 96-339 CIVIL TERM CIVIL ACTION-LAW IN DIVORCE v. MAC E. SHOVER, Defendant DEFENDANT'S AFFIDAVIT OF CONSENT, ACCEPTANCE OF SERVICE AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. A complaint in divorce under Section 3301(C) of the Divorce Code was filed on January 23, 1996. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complalnt. 3. I consent to the entry of a final decree in divorce without notice. 4. 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. 5. 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. 6. I have been advised of the availability of marriage counseling and understand that I may request that the court require counseling. I do not request that the court require counseling. 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. Section 4904 relating to unsworn falsification to authorities. Date: .'i -/J' 9b yn J.! ,'d It a: .~_ ^ ,>/- r-r.lI ,~ Martha K. Shover ~ j..;, ",{~' ,'. ,- f..! r ~ 1_,. f'" "- ..- '.,.~ j ') ( , L , 'J . . . . . , . . . . Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 96-339 CIVIL TERM CIVIL ACTION-LAW IN DIVORCE MARTHA K. SHOVER, Plaintiff v. MAC E. SHOVER, ACCEPTANCE OF SERVICE AND NOW, this (;t~9q? day of January, 1996, I, MAC E. SHOVER, Defendant above, hereby accept service of the Complaint filed in the above case pursuant to Pa. R.C.P. 1920.4(e) and acknowledge receipt of a true and attested copy of said Complaint. 'mae e MAC E. )/;J ~i:./f,;'i!/'G SHOVER domestic/divorce/shover.acc '1/. foJ' ,e;:: ~ C , , (: i... I. e , i ,~ : ..:.: ( ") ',. ,} , . . . . . . .