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HomeMy WebLinkAbout07-0337i? ti TAMMY L. LAUGHMAN, Plaintiff V. GARY L. LAUGHMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007 - .33 7 CIVIL TERM CIVIL ACTION-LAW NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 9 TAMMY L. LAUGHMAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2007 - CIVIL TERM GARY L. LAUGHMAN, CIVIL ACTION-LAW Defendant DIVORCE COMPLAINT 1. Plaintiff is Tammy L. Laughman, an adult individual who currently resides at 566 Middle Road, Newville, Cumberland County, Pennsylvania 17241. 2. Defendant is Gary L. Laughman, an adult individual who currently resides at 566 Middle Road, Newville, Cumberland County, Pennsylvania 17241. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on January 1, 1977 in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. The Plaintiff has been advised of the availability of counseling and that she may have the right to request that the court require the parties to participate in Counseling. 8. The Defendant engaged in an adulterous relationship during the marriage which resulted in the birth of his daughter, Cheyenne Sanbower. WHEREFORE, the Plaintiff requests the court to enter a decree of divorce in favor of the Plaintiff and against the Defendant on the grounds of adultry or in the alternative because the marriage is irretrievably broken. COUNT II -EQUITABLE DISTRIBUTION 9. Plaintiff hereby incorporates by reference paragraphs 1 through 8. 10. The parties have acquired real estate, personal property, including automobiles, bank accounts and other items of miscellaneous property during the course of their marriage, some of which is marital property. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a decree which effects an equitable distribution of marital property. Respectfully submitted, Date: 1 b , 2007 O'BRIEN, BARIC & SCHERER Michael A. Scherer, Esquire I.D.# 61974 19 West South Street Carlisle, PA 17013 (717) 249-6873 Attorney for Plaintiff mas.dir/domestic/laughman/divorce.comp VERIFICATION I verify that the statements made in this Divorce Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. § 4904, relating to unsworn falsification to authorities. Date: / - r ` c ? , 2007 mm ` L : ghman (? N 1U C-- C= 'r 1 r T', _ q r' r *M,,, tea:: y TAMMY L. LAUGHMAN, Plaintiff V. GARY L. LAUGHMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007 - 337 CIVIL TERM CIVIL ACTION-LAW PRAECIPE TO REINSTATE TO THE PROTHONOTARY: Please reinstate the Complaint filed in the above-captioned matter on January 18, 2007. Respectfully Submitted, O'BRIEN, BARIC & SCHERER AA c Michael A. Scherer, Esquire I.D. # 61974 19 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 mas.dir/domestic/iaughman/reinstate.pra ?_ ?? t?, ,.5 ,- ^+? ??{q ? ,i c w? j'?i? i ?? ? '? }.;. t" - r,:1 f t'•' . ?-G . !; ter' TAMMY L. LAUGHMAN, Plaintiff V. GARY L. LAUGHMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007 - 337 CIVIL TERM CIVIL ACTION-LAW MARITAL SETTLEMENT AGREEMENT THIS AGREEMENT is made this 14th day of March, 2008, BY and BETWEEN Tammy L. Laughman, of 18 Hosfelt Road, Carlisle, Cumberland County, Pennsylvania, hereinafter referred to as "Wife", A N D Gary L. Laughman, of 566 Middle Road, Newville, Cumberland County, Pennsylvania, hereinafter referred to as "Husband". RECITALS R.1: The Parties hereto are Wife and Husband, having been joined in marriage on January 1, 1997 in Cumberland County, Pennsylvania and the parties agree that the date of separation is October 17, 2006; and, R.2: There are no minor children from the marriage; and, R.3: Differences have arisen between the parties, in consequence of which the parties intend to separate in the near future; and, RA: The Parties have resolved that it is not possible to continue the marital relationship between them for reasons known to them, in consequence of which they are living separate and apart; and, Page 1 of 10 R.5: Wife filed a Complaint for Divorce in the Court of Common Pleas of Cumberland County in the Commonwealth of Pennsylvania, to above-captioned docket number; and, R.6: It is the desire and intention of the parties, to amicably adjust, compromise and settle all property rights, and all rights in, to or against the property or estate of the other, including property heretofore or subsequently acquired by either party, and to settle all disputes existing between them, including any claims or rights that they may have under the provisions of the Pennsylvania Divorce Code, as amended; and, R.7: Wife and Husband declare that each has had a full and fair opportunity to obtain independent legal advice of counsel of their selection; that Wife has been independently represented by Michael A. Scherer, Esquire and that Husband has been independently represented by Ruby D. Weeks, Esquire. NOW THEREFORE, with the aforementioned recitals being hereinafter incorporated by reference and deemed an essential part hereof and in consideration of the covenants and promises hereinafter to be mutually kept and performed by each party, as well as for other good and valuable consideration, receipt of which is hereby acknowledged, and the parties, intending to be legally bound, hereby agree as follows: (1) SEPARATION: It shall be lawful for each party at all times hereafter to live separate and apart from the other party at such place or places as he or she from time to time may choose or deem fit, free from any control, restraint or interference from the other. Neither party shall disparage or discredit the other in any way, nor in any way injure his or her reputation; nor shall either of them act or permit anyone else to act in any way which might tend to create any disaffection or disloyalty or disrespect between the members of the family of either party. Page 2 of 10 (2) DIVORCE: The parties acknowledge that the marriage is irretrievably broken and that they will secure a mutual consent no-fault divorce decree in the above- captioned divorce action. Simultaneous with the execution of this Agreement, the parties shall execute the Affidavits of Consent and Waiver of Notice Forms necessary to finalize said divorce. Said Affidavits and Waivers shall be immediately filed with the Prothonotary's Office. If either party fails or refuses to execute and file the foregoing documents, said failure or refusal shall be considered a material breach of this Agreement and shall entitle the other party at his or her option to terminate this Agreement. (3) REAL PROPERTY: The parties are the joint owners of certain real property located at 566 Middle Road, Newville, Cumberland County, Pennsylvania (hereinafter "Marital Residence"). The marital residence is under contract to be sold and settlement is scheduled for March 17, 2008. The parties shall share equally in the payment of the customary settlement charges and any liens of record on the marital residence. The liens are a first mortgage to WellsFargo totaling aproximately $145,000.00 and a second mortgage to Commerce Bank totaling approximately $10,500. In addition, the parties shall pay off a credit card from FIA Card Services which is in joint names which totals approximately $17,500.00. The first three thousand dollars of the remaining proceeds shall be paid to Wife because Husband had made more charges on the joint credit card than Wife. The remaining proceeds after payment of $3,000.00 to wife shall be split equally between the parties. The parties waive their interest in any proceeds from the sale of the marital residence awarded to the other party by virtue of this paragraph. Page 3 of 10 (4) DEBT: A. MARITAL DEBT: The parties are using the proceeds of the sale of the marital residence to pay off all marital debt. Each party hereby warrants that there is no additional outstanding marital debt which will remain unpaid after the application of the proceeds of the sale of the marital residence to the marital debt as listed in paragraph three (3) above. B: POST SEPARATION DEBT: Except as otherwise herein provided, in the event that either party contracted or incurred any debt since the date of separation, the party who incurred said debt shall be responsible for the payment thereof regardless of the name in which the debt may have been incurred. C: FUTURE DEBT: Except as otherwise herein provided, from the date of this agreement neither party shall contract or incur any debt or liability for which the other party or his or her property or estate might be responsible and shall indemnify and save the other party harmless from any and all claims or demands made against him or her by reason of debts or obligations incurred by the other party. (5) MOTOR VEHICLES: The parties are the owners of various motor vehicles. Wife shall become the sole owner of the 2001 Chevrolet Monte Carlo which is in joint 1 q93 ?L names and which has no lien against it, along with the 2001 Dodge Intrepid which is in joint names with no lien. Husband shall become the sole owner of the 2001 Dodge Intrepid and the 1996 Dodge 1500 pickup truck, neither of which have liens against them. Each party shall sign whatever documents are necessary to retitle the vehicles as set forth above. (6) TANGIBLE PERSONAL PROPERTY: Except as otherwise herein provided, the parties hereto mutually agree that they have effected a satisfactory division of the furniture, household furnishings, appliances, tools and other household personal property between them, and they mutually agree that each party shall from and after the date hereof be the sole and separate owner of all such property presently in his or her Page 4 of 10 possession whether said property was heretofore owned jointly or individually by the parties. This Agreement shall have the effect of an assignment or bill of sale from each party to the other for such property as may be in the individual possession of the parties hereto. (7) INTANGIBLE PERSONAL PROPERTY: The parties are the owners of a Franklin Templeton Investment Account, number xxxx0792 with a balance of approximately $6,700.00. Husband shall convey his interest in this investment account to Wife and Wife shall become the sole owner of this account by virtue of this Agreement. Except as otherwise provided herein, each party hereto hereby relinquishes any right, title or interest he or she may have in or to any intangible personal property currently titled in the name of or in the possession of the other party, including, but not limited to, stocks, bonds, insurance, bank accounts, individual retirement accounts, employment benefits, including retirement accounts, savings plans, pension plans, stock plans, 401 K plans, and the like. (8) WAIVER of ALIMONY: The Parties acknowledge that each has income and assets satisfactory to meet his and her own reasonable needs. Each Party waives any claim he or she may have, one against the other, for alimony, spousal support or alimony pendente lite. (9) DIVISION OF BANK ACCOUNTS: The parties acknowledge that all joint bank accounts have been closed or divided to their mutual satisfaction prior to the execution of this Agreement. The parties hereto further acknowledge and agree that any bank accounts established individually by the parties shall become the sole and separate property of that party simultaneous with the execution of this Agreement. Page 5 of 10 (10) AFTER-ACQUIRED PROPERTY: Each of the parties shall own and enjoy, independently of any claims or rights of the other all real property and all items of personal property, tangible or intangible, hereafter acquired, with full power to dispose of the same as fully and effectively as though he or she were unmarried. Any property so acquired shall be owned solely by that party and the other party shall have no claim to that property. Husband intends to purchase real estate with his share of the proceeds of the sale of the marital residence and wife waives any interest in she may have in the real estate to be purchased by husband which interest may arise from the marital status of the parties. (11) RETIREMENT ACCOUNTS: Husband has been employed with the SuperValue Company for nearly thirty years, and wife has been employed with the Beistle Company for nearly twenty five years. Each party has earned an interest in defined contribution retirement plan and the parties have exchanged account statements to disclose the values of these accounts to one another. Husband shall keep as his separate property his 401 k Account with his employer, free from any claims to that account by Wife. Wife shall keep as her separate property the stock ownership/profit sharing plan with her employer, free from any claims to that account by husband. (12) ATTORNEY'S FEES: Except as otherwise herein provided, each of the parties waives the right to receive a payment for counsel fees from the other, and each shall be responsible for his or her own counsel fees, costs and expenses, if such fees or expenses are incurred. Page 6 of 10 (13) ADDITIONAL INSTRUMENTS: Except as otherwise herein provided, each of the parties shall from time to time, at the request of the other, execute, acknowledge and deliver to the other party, within ten (10) days of any request to do so, any and all further instruments that may be reasonably required to give full force and effect to the provisions of this Agreement. (14) BANKRUPTCY: The parties hereby agree that the provisions of this Agreement shall not be dischargeable in Bankruptcy and expressly agree to reaffirm any and all obligations contained herein. (15) COMPLETE DISCLOSURE: Each of the Parties hereto acknowledges that he or she is aware of his or her right to seek discovery including, but not limited to, written interrogatories, motions for production of documents, the taking of oral depositions, the filing of inventories and all other means of discovery permitted under the Pennsylvania Divorce Code or the Pennsylvania Rules of Civil Procedure. Each Party further acknowledges that he or she has had the opportunity to discuss with counsel, if desired, the concept of marital property under Pennsylvania law and each is aware of his or her right to have the real and/or personal property, estate and assets, earnings and income of the other assessed or evaluated by the courts of this Commonwealth or any other court of competent jurisdiction. The Parties do hereby acknowledge that there has been full and fair disclosure to the other of his or her respective income, assets and liabilities, whether such are held jointly, in the name of one party alone or in the name of one of the parties and another individual or individuals. Each party agrees that any right to further disclosure, valuation, appraisal or enumeration or statement thereof in this Agreement is hereby specifically waived, and other than provided herein, the parties do not wish to make or append hereto any further enumeration or statement. The Parties hereby Page 7 of 10 acknowledge and agree that the division of assets as set forth in this Agreement is fair, reasonable and equitable, and is satisfactory to them. Each of the Parties hereto further covenants and agrees for himself and herself and his or her heirs, executors, administrators or assigns, that he or she will never at any time hereafter sue the other Party or his or her heirs, executors, administrators or assigns in any action of contention, direct or indirect, and allege therein that there was a denial of any rights to full disclosure, or that there was any fraud, duress, undue influence or that there was a failure to have available to him or her full, proper and independent representation by legal counsel. (16) WAIVER OF APPRAISALS: The parties acknowledge that they are aware of their respective rights pursuant to the Pennsylvania Divorce Code to obtain formal valuations or appraisals of the real estate, the personal property, the vehicles, and 401 K's and IRA's, some or all of which were acquired during the marriage and therefore constitute marital property. However, the Parties have determined that they will not undertake the expense to have these items appraised and/or valuated, and that the division of property as set forth in this agreement, represents a fair and equitable distribution. (17) RELEASE of ALL CLAIMS: Except as otherwise provided herein, each Party releases and discharges completely and forever the other from any and all right, title, interest or claim of past, present or future support, division of property, including income of gain from property hereafter accruing, right of dower or curtesy, the right to act as administrator or executor of the estate of the other, the right to a distributive share of the other's estate, any right of exemption in the estate of the other, or any other property rights, benefits or privileges accruing to either party by virtue of their marriage relationship, or otherwise, whether the same are conferred by statutory or common law of Page 8 of 10 the Commonwealth of Pennsylvania, or any other state, or of the statutory or common law of the United States of America. Except as provided herein, the Parties specifically waive any and all rights that they may have to equitable distribution of marital property and/or alimony and counsel fees, except those counsel fees sought in the event of a breach of this Agreement, or any other marital rights as provided in the Pennsylvania Divorce Code, Act 26 of 1980 or any amendment thereto. Each party further releases the other from any and all claims or demands up to the date of execution hereof and any other claims either party could raise which arise from the marriage, contract or otherwise. (18) SEPARABILITY of PROVISIONS: If any term, condition, clause or provision of this agreement shall be determined or declared to be void or invalid in law or otherwise, then only that term, condition, clause or provision shall be stricken from this Agreement and in all other respects this agreement shall continue in full force, effect and operation. (19) GOVERNING LAW: All matters affecting the interpretation of this Agreement and the rights of the Parties hereto shall be governed by the laws of the Commonwealth of Pennsylvania. (20) INCORPORATION into DIVORCE DECREE: The Parties agree that this Agreement shall continue in full force and effect after such time as a final Decree in Divorce may be entered with respect to the parties. Upon entry of the Decree, the provisions of this Agreement may be incorporated by reference or in substance, but they shall not be deemed merged into such Decree. The Agreement shall survive any such Decree in Divorce, shall be independent thereof, and the Parties intend that all obligations Page 9 of 10 contained in this Agreement shall retain their contractual nature in any enforcement proceedings, whether enforcement is sought in an action on the contact itself at law or in equity, or in any enforcement action filed in a Divorce action. (21) BREACH: It is expressly stipulated that in the event that either party breaches any provision of this Agreement, he or she shall be responsible for any and all costs incurred to enforce the Agreement, including, but not limited to, court cost and counsel fees of the other party. In the event of breach, the other party shall have the right, at his or her election; to sue for damages for such breach or to seek such other and additional remedies as may be available to him or her. (22) ENTIRE UNDERSTANDING: This Agreement constitutes the entire understanding between the parties and there are no covenants, conditions, representations, or agreements, oral or written, of any nature whatsoever, other than those herein contained. (23) AGREEMENT BINDING on PARTIES and HEIRS: It is understood and agreed that not only the Parties hereto, but also their heirs, administrators, executors and assigns, shall be bound by all the terms, conditions and clauses of this Agreement. IN WITNESS WHEREOF, the parties hereto, intending to be legally bound hereby, have hereunto set their hands and seals to this Agreement the day and year first above written. WITNESS: Y'z li?'L MMicffidl A. Scherer, Esquire Ta Laugh Ruby Weeks, Esquire aryL. La ghman Page 10 of 10 fi--i ? ? C_ ? ' Ti c xa -rr-` ?' ---I ?,? _ Ct ;` ---, ???. '?- ? { =:? i r"5 ?? ?? .. . a _i ' ,? r,_ --< TAMMY L. LAUGHMAN, Plaintiff V. GARY L. LAUGHMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007 - 337 CIVIL TERM CIVIL ACTION-LAW AFFIDAVIT OF SERVICE I hereby certify that on February 10, 2007, the United States Postal Service served upon the defendant, Gary L. Laughman, the Divorce Complaint by Certified Mail as indicated by the Certified Mail Domestic Return Receipt attached hereto as "Exhibit A'$. Date: March 17, 2008 6ki / Michael A. Schere , Esquire O'Brien, Baric & Scherer 19 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 Attorney for Plaintiff .r'' , „ ¦ Items 1, 2, and 3. Also complete Ion 4 If Restricted Delivery is desired. Pft your name and address on the reverse ¦ that we can roMm the card to you. ¦ h this card to the back of the mailpiece, 1. Article Addressed to: A. SWtah" or on the front 0 space permits. 13 AC Ac B. Received WtPHr Alame) I C. Date of D. Is delivery address drama, from item 1? fU MW If YES, enter delivery address below: 0 No GARY L LAUGHMAN I 566 MIDDLE RD _ NEWV ILLE PA 17241 3. Servlos type ja owli d Mall 0 Bpess Mail Q O Return Receipt for March 4 0 Insured Moil 0 C.O.D. 1 4. Restricted Del MY? (P ft Fes) 0 Yes 2. fjdcle Number 7006 0810 0000 7876 0525 Monsfer from aarvks label) PS Form 3811, February 2004 Domestic Return Receipt 102595-02-WIMO Exhibit "A" „"' C? C? ?' ?? -:-? cr ??> ? '? ` i`?? x? ?.., i?' s= ? _? ? ;c t?? ?, ?t ( , .=? ?? ? . ? 7 i%.. -? f?.r ?- ,.z..! ? TAMMY L. LAUGHMAN, Plaintiff V. GARY L. LAUGHMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007 - 337 CIVIL TERM CIVIL ACTION-LAW PLAINTIFF'S AFFIDAVIT OF CONSENT 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 18, 2008. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 3. 1 consent to the entry of a final decree in divorce without notice. 4. 1 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. 1 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. 1 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: 3. lti • o 6 i ^-? c:? {'? n? ?? ?, TAMMY L. LAUGHMAN, Plaintiff V. GARY L. LAUGHMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007 - 337 CIVIL TERM CIVIL ACTION-LAW 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 18, 2007. 2. Defendant acknowledges receipt and accepted service of the Complaint on 110-67 3. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 4. 1 consent to the entry of a final decree of divorce without notice. 5. 1 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. 1 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. 1 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. 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: 3v .?`a,.AI Gary L. Laughman C3 cY CD 77, f GJ :T TAMMY L. LAUGHMAN, Plaintiff V. GARY L. LAUGHMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007 - 337 CIVIL TERM CIVIL ACTION-LAW 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) of the Divorce Code. 2. Date and manner of service of the Complaint: Defendant signed a certified mailing return receipt card on February 10, 2007. 3. (complete either paragraph (a) or (b).) A. Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by Plaintiff on March 14, 2008; and Defendant on March 14, 2008. B. (1) date of execution of the Plaintiffs Affidavit required by Section 3301(d) of the Divorce Code: N/A (2) date of service of the Plaintiffs Affidavit upon the Defendant: N/A 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: The parties signed Waivers of Notice of Intent to Request Entry of Divorce Decree. Respectfully submitted, O'BRIEN, BARIC & SCHERER InAAA__ Michael A. Scherer, Esquire 19 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 ? ? -r'9 ?_. ? .-.? "'.??: ?.F 'j y l ?.i? M',.j .?' ?/ ??l IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. TAMMY L. LAUGHMAN. Plaintiff VERSUS GARY L. LAUGHMAN Defendant NO. 2007-337 DECREE IN DIVORCE Civil AND NOW, My (-? 2-6t , Z06E, IT IS ORDERED AND DECREED THAT TAMMY L. LAUGHMAN AND GARY L. LAUGHMAN ARE DIVORCED FROM THE BONDS OF MATRIMONY. , PLAINTIFF, ,DEFENDANT, 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 nar Marital Settlement A,g-r_eempnt daf-AA Marsh 14, 7nnR is incorporated but slot _merged herein as a final order-of Court. BY THE COURT: I/'/'- ?Ll- 71 ATT T: D J. PROTHONOTARY ??, ? ??