Loading...
HomeMy WebLinkAbout96-05433 t:. \. \l ~ ;.. to) ~ ~ \. ~ 0-... ~ ~ ~ ...... . I I I \ ~ :;t.. ~/ ~t ~ " " .:.:. ::~:~ ::.::,"':~:",':~:' ~:~:~.~. ,':!~'~.:!:'.."~:' .::~:~, ':~:~_,':~~_':~;~....:~~::~,:~' ~.~:: ':~:', .~:~ ::~.:~ ',:.:' _'~~~,~~:' ':~;:.'::!::~~::.:~.::.:'_ ~~::___-:~:. ',f ~ !~ (' '.', I~ " ! , PLEAS 'li (' lii, I~ If. J~ ~ ~' ~, -"! ~ ~ ~,.' ~. ~' ~I ','] .'.: ~' ~i '," , ' li.' , . .'.> ~; ~ ~~ li ',or li. ... ~. ~ ~ ",,' .... . , . Nt , , ~i ~. ~. .." ~, ~i 'i ~l "1 , !ii . , , Ml ~: I! ~ ~ " ~ . IN THE COURT OF COMMON OF CUMBERLAND COUNTY STATE OF ~ '~~~ PENNA. Kimberly Ann Metzger, Plaintiff 96-5433 l'\ 0, II) \"('1'';:\1.'': It:lrr is Henry Met.2.ger, Jr., Defendant DECREE IN DIVORCE AND NOW, . ..... f",.i, ,-; ;-, , ..., . -:-.\.'-.. . ~. , it is ordered and 197 'I decreed that Klmberly Ann Metzger . ., plaintiff. defendant. andlt:lrrJS Henry Metzger, Jr. are divorced from the bonds of matrimony, The court retains jurisdiction of the following claims which have been raised of record in this action for which a final order has not yet been entered; Property Settl€'fl'('nt Aqteenent dated August 12, 1997 is Incorporated herein. -. ~ .. J. .' . _ 1 . .: ~ ~ I: \ T t, t" t' II 'It t / i ."... . i' , ." ... " . \ 1_ . .J,.f '- '''-.. " l ,\U.,I: i c..,. ,.'_ r(/ \",;.,.. ,'-, J t' ..,,,,,,-1.$''C.1' --'w.i<~..~ ,,,.,.;.t- __~"'.u.... \ I " " .7 .' -r:.-fll''''~ .r _~' (t. ."-tP..-. /" .J ,,/ 1"r._hHn~ll ,n \ ~ S ,;, ~ 1~ ).. l~ lM ) , !? ," , i~ } ~. J.", \~ ".' , :~ .~ .~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ Ii ~ ~ " ~ . KIMBERLY ANN METZGER, P1aIntifJ', : IN THE COURl' OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. . . : NO. 116-11433 CIVIL TERM MORRIS HENRY METZGER, JR., Deeendant . : CIVIL ACTION : IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: 'l'raDImit the reeord, together with the CoIIowiDg iDf'ormatIon to the court Cor entry of a cIiYorce deeree: 1. GI'OUIld Cor di~~..e: 3301(c) of the Dmlrce Code. 2. Date lIDd _ of Rrrice of the ""'"'IpI_lnt; Certified mall OIl October 2, 1996. a. Date of nec:utian of the AfIidarit of ('~ required by330l(c) of the Divwee Code: 4. By PWntifI: AJIIUIIl12, 1991 !Wo'ed c:Ialma petldinI; By De(-tanf: AJIIUIIl12, 1991 N_. 6. Date PIaintIO"I WaIwer of Notb In 13301(c) Dmlrce _ IIJed with the Protlliocrilry: Aupt 12, 1991 Date Dee___'. Waiftr ofNotb In ta3Ol(c) ~ _1IJed with the Protlliocrilry: AJIIUIIllI, 1991 ~ .~.-',#"~ . ~\J14- -,-.. ...... ~ ttl ~ N ..,. .. :.}..,. ~9 ('oJ l'"):;.;J tj~ c' .- ....;j ~? 0.. " ::~G ',' 0'\ I.... ....--" c .'2 ~i! ~ l';~ u... ;i .,:1 f. :3 u, ,.. L1 cr U SEPARATION AGREEMENT AND PROPERTY SETI'LEMENT ThiaAgreement,madeandenteredlntothil 1;( It- dzI10f Ilufl'l' ,1997, between KImberly Ann Metzger, of Cumberland County, Pel1ll8y1vania, hereinafter referred to as "Wife", and Morris Henry Metzger, Jr" of Cumberland County, Pel1ll8ylvania, hereinafter referred to as "Husband", WHEREAS, the parties hereto are now Wife and Husband, having been lawfully married to each other on February 24, 1995 In Cumberland County, Pennsylvania; WHEREAS, there have been no children born of this IIIlIrriage between Husband and Wife; WHEREAS, the parties hereto are now living aeperate and apart and desire to enter into an Ap-eement respecting their JlI openy rilhts, reprdIesa of the actualleplll'8tion or other character thereof and their other rilhts, including the Wife', rilht to support and maintenance; WHEREAS. both and each of the parties hereto have been advised of their lepl rilhta and the implatioal of this Acreement lUId the lepl CODBeq\leIICft that may and will ensue from the execution hereof. lUId each has had the opportunity to c:onauIt with his 01' her own competent IegaJ counsel independent of each other; WHEREAS. each party warrants, .. pert of the c:onaideratioo of this Ap- etment, that each has fully and coo.pIeteIy .\;- \..'Wd all infOl'lll8tioa of a IlnImci8I nature requetted by the other, and that no infonnliion of auch nature has been aubject to diatortion or In U\J _ belIlI mlaftpreeenled; and WHEREAS. other than .. set forth herein, Wife dealree fInIIIIy and f_ to reIinquiah all of ~r rf&bla to be IIIpIlOI'ted by the HUIbend and all of her riIbt 01 dower, rf&bla.. heir Ill' IIlInivIna ~ or otbI.I...,&l:tual, ~~"'c.1lI' '""'-te.lnand to the _and ~1.....aI p1opdtyofthe Huaband. now owned by him Ill' wbida in the lUture may be owned by him, and aD r!Pu to aIiaaonJ. Nimony ~ lite. ~ fftS, or ftpeIIIH and other thin AI set Cwth herein, HUIbend Iibwiw .w- to reIiftqulab all bioi riIbta of Nrteq. riIbta .. heir . 11II .l"~ .,... Ill' otJooIt ...... IdUlll and CWT\'t\tl"v ...... ....-.., in and to the _ and ,M1ClNlI etUle of tM Wife, ~ owned by her tV' "l\irh .. -.:r ..Ill the lUture: NOW. THERUOR!, the pII'ti1l!t hereto InttndIIlI to be"" bound "'"'" do Iwreby mutually ... as followa: 1, Separation, Husband and Wife do hereby mutually agree and consent to live separale and apart and do further agree that it shall be lawful for the Husband and Wife at all times hereafter to live separate and apart from each other, and to reside, from time to time, at such place or places 88 they respectfully shall deem fit, free from any control or restraint or interference, direct or indirect, by each other, 2, No Molestation, HaraAment or Interference, Neither party shall molest, har888 or interfere with the other or compel or endeavor to compel the other to cohabit or dwell with him or her by any me8ll8 whatsoever, 3, Mutual Property and Estate Waiver, Except 88 otherwise expressly set forth herein, in which event such express provision shall take precedence over this paragraph. the parties hereto intend that from and after the date of this Agreement, neither shall have any spouse's rights in the property or estate of the other, and to that end both partie8 waive, relinquish, and forbear the rights of dower or curtesy, Mehts to inherit, Mehts to claim or take the Husband or Wlfe's or family exemption or allowance. to be vested with letters of administration or letters testamentary, or to take against any will of the other. and each agrees with the other if either should die intestate. his or her share shall descend to vest in hi, or her heirs at law, personal representativn, and next of kin, excluding the other 88 thoU&h he or she had died a widow or widower, And each further agrees that ahould the other die testate. his or her property shall descend to and vest in ~ persons let forth in the other's lAst Will and THtamfllt 8.' though thp spouse so designated .. beneficiary had predeceued the testator. The partieI further agree that they may and can hereal\er, as thouch WUDIII'I'ied, without any joinder by him or her, sell. con~. transfer or encumber any and all rftl estate and penona1 property which either of them now or ~er own or pouetI and further agree that the rerotding oC this Aar-nmt shal1 be conclusive nidmce to all of hi- or her Meht to do so. The IlIIid Husband and Wife do hereby irftyocab\y &f8IIt, MCh to tM other, should the exercise of lhis power ~by ai'lt'll be ~, the riaht and the power to llJlIlOUIt on<, or nl<>ft> times any pel'l101\ or penons whom the llwoband or Wife shal1 designate to be the Iluorney-in-flllrt f,... IIIP othH. in their name and in t.heir 1Itnd. t<l u<<ute and III'luIow~ any de<ed or dffds, "'~.., qlUt daulU, or lllltiofaetitlna. und<'r -' (If' othff~. to f'llIIbIf. eitllf<r party ~Io 10 ~Mte hill Of t...r ",,,I or personal property, but without any power to impose personal liability for breach of warranty or otherwise, Each of the parties hereto further waives any right of election contained in Chapter 22 of the Pennsylvania Probate Estates and Fiduciaries Code, and any right to seek or have an equitable distrihution of married property ordered by the Court subsequent to Section 3502 of the Divorce Code, ElICh of the parties hereto further agrees that neither shaI1 herea/ler be under any legal obligations to support the other, pay any expenses for maintenances, funeral, burial. or otherwise for the other, and to that encl..nrh of the parties hereto does hereby waive any right to receive support, alimony, alimony pend"nl.. lilt'. counsel fees, expenses, or any type of flll8l1Cial8S8istance whatsoever from the other, except as otherwi!lf' expressly provided for herein. 4, Division of Pel'8Onal Property. a. The parties agree that the gas grill. hand saw, cow haIJoween costume. Locusl Point coITee mugs, and Locust Point huggies shaI1 be the exclusive property of the Husband, All other personal property located in the mobile home shaI1 be the exclusive property of the Wife. Henceforth, each of the parties shall own, have and eqjoy, indepeoo..lltly of any claim of righl "f the other party, aD items of personal property of every kind, nature and description and wheresoever situated which are now owned or held by or which may hereinafter belong to the Husband or Wife respectively, with full power to the Husband or Wile to dispose of lhe llIUIl" ItS fully and efrectual1y in aD respects and for aD ptII'p08eS as if he 01' she were unmarried. b. The parties agree that the 1986 Ford Branco shaI1 be the IOIe and RpArnI.. property of the Huabend, Huabend wiII_ the underI7inc obIiption for this automobiJ<o und he willli&n aD documentll necuMl')' to obtain rm- of the Wife from said obIiption, c. ~ efrft'U. AD items of pl'nDlUII efrect such as but not limited to joo.....Iry, 1IItIPc'P. sporU fqWipmenl, hobby colImioM III1d books but not incIudinr I'umitW'f' or any tltlwr propmy. pl'nDlUII or otherwise ~ <lIsp-.J of pun\Wlt to this ...._nt .tWI bl'l't\ll\t. the abeoIuu! III1d sole prupeMy oftbP part, who has hIld the prirDpBI.... th-ftoI' or to ",'hOlm II... ","",,"y - ~ or form whom it -I'W"'~ and _h party hrn-by s~ any mle""1 ho' Of .,'" IMY haw III ...'h WlgIhl<- r<""'>Ml P"'t""'Y' of lho' tltho'f ~ ~~.......-' ~.,~ ~--- ~ Ii, Property, The parties are owners of a camper and mobile home, The Husband ha.. previously destroyed the title to the camper, He hereby agrees to go to BoUenberger's and sign whatever paperwork is necessary and pay whatever fees are necell8lll'Y to obtain a duplicate title to said camper, The Husband further agrees to convey to the Wife all right, title and interest in the mobile home WId the camper to the Wife 88 her sole and exclusive property, 6, Debtll, a. Husband, The Husband shall be solely responsible for the loan with Farmer's ,.~T ~ Trust on the 1986 Ford Bronco and sha11 remoJe the Wife's name from said loan within 15 day. .. of the signing of this Agreement. The Husband shall be responsible for any debts incurred in his name alone, b, Wife, The Wife shall 888ume the joint marital debt at Preis Consumer Discount Company and ~~~~e 'tsband'S name from said Io8n within 15 days of the removal or her name from the Farmer's Trust Io8n mentioned in paragraph 6A above, The Wife shall be responsible for any debts incurred in her name a1one, 7, Future Debtll, The parties further agree that neither wiD incur any more further debts for lil'1Ueh the other may be held liable, and if either party incurs a debt for IiI'hich the other wiD be liable, that party incurring such debt wiD hold the other harmless from any and all liability tbereof, 8. Waiver ot A1lmony, In consideratioo of the mutual agreement of the parties volWlwil}' to live separate and apart and the provisions contained herein for the respective benefit or the partiea and other good and valuable consideration, the parties agree to waive any and all daima for any alimony. 9. PeIl.IIon, Both parties agree to waive any daillll they may have to lII\Y ""muon or ftllPIoyment benefits or any kind. t!8I"Md during the~. by the other party, 10, ('n"_1 F_ and Court CaetlI. The parties agree to be r"pon8i~ ror their own l'OUlIaf'\ tfft and court C08l8. 11. Dl\o._, The parties lIcluIowledp that an 8l'tion for ~ btt_ Uwm bas bo..-tl m.-J by \We and is prnently pendinc ~ bet_ thml in the C~ or Common Ptr.u 0( Cum~t County to the caption lWnt..rty Ann Mt'tJl!l'r v MOI'N IIfl11'y Mt'trrr, Jr. OO-M3.1 ('1\'\1 T..rm '11", parties acknowtedge their intention and agreement to proceed in said action to obtain a fmal decree in divorce by mutual consent on the groundll 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 have executed simultaneously herewith the necessary Affidavits of Consent for the entry of a fmal divorce decree in that action, 12, Breach, In the event that either party breaches any provision of this Separation and Property Settlement Agreement, he or she shaI1 be responsible for any and all costa incurred to enforce the terms hereof. including, but not limited to, court costa and reasonable counsel fees of the other party, In the event of breach, the other party shaI1 have the right, at his or her election, to sue for damages f"r such breach or to seek such other and additional remedies as may be available to him or her, 13, Enloreement, The parties agree that this marital settlement agreement or any part or parts hereof may be enforced in any court of competent jurisdiction, 14. ApplIcable Law and Execution, The parties hereto lIgI'ee that this marital settlement agreement ahaII be construed under the laws of the Commonwealth of Pennsylvania UId shaI1 bind the parties hereto and their respective heirs, executors UId uaiens- This document ahaII be ellecuted lIll original UId multiple copies, 15, The Entire Agreement. The parties acknowledge UId lIgI'ee that this marital settlement agreement tolltainl the entire undentandinc of the parties and aupenedel any prior lIgI'eeIDl!nt betw~n them. There are 110 other repreeenlationa, warranllee, promises, covenants or underatandinp bfotw....n the parties other than thoee ellpresaq set forth herein. 16. lDcorpontIon and Judplent for D1wGlCle, In the _t that either busband or wlf.. at any tD hereal\er obtain a divorce in the adion for divorce presently pendina betWf'f'll th..m, or otherwiIe. this lIpfttIIeIIl and aD of ita JlI'CWWona IlIaD be inc<<porated into any lIlICh ~t for dirorcf', either direct.b or by reffftllCt'. The c-t. on enttJ of j...Jcment far divorce. IlIaD retain the richt '0 fftfaree the prlMaions and tHma of this .ntal setlJealent .Uimenl. ~ PI i':: "" " ..' r\.' : 1..- fUr: i , (-\ r . F{' . . (-"- . -j ,.'t.-, a. ~; l..;.._ . CI ! . I ~: I. ..... ,-, <J' . , . KIMBERLY ANN METZGER, Plaintiff, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO, 96-5433 CML TERM : CML ACTION : IN DIVORCE v, MORRIS HENRY METZGER, JR., Defendant AMENDED COMPLAINT IN DIVORCE 1, Plaintiff is Kimberly Ann Metzger, an adult individual, currently residing at 1328 Pine Road, Lot #6, Carlisle, Cumberland County, Pennsylvania. 2, Defendant is Morris Henry Metzger, Jr., an adult individual, currently residing at 65 West Church Avenue, Carlisle, Cumberland County. Pennsylvania. 3, Plaintiff and Defendant are bollllt'1de resident! of the Commonwealth of Pennsylvania and have been so for at least six months immediately previous to the riling of this Complaint, 4, Plaintiff and Defendant were married on February 24. 1995 in Cumberland County, I I Pennsylvania. II II II II " j i I , i I the Court require the parties to participate in CIlUIIIIdin&, Knowing uu., the Plaintiff II.- not d8ire that iI il 'I I, H ;,1 ;; n i, 5, There have been no prior actions for divoree or annulment between the parties, 6. Tbe Defendant is not a member of the Armed Forces of the United Slates of America, or it! Allies. 7, The Plaintiff has been adviaed oCtM a-ilAhi1ity of eounaeline and the right to request that the Court require the parties to participate in counseling, 8. Plaintiff and Defendallt are ciliullII of the United States of AmerillL 9, The parties have Ped seplII'tle and ~ ~ Marth 15. II1l16 and continue to 1M ~ and ~ as of th., date of this Cmlpkoint. 10. PlaintifT desirM . ~ .... upon: ... The tact that DPfftldant baa oft'ert'd IUd\ indicIlities to the pencil of the PWntiff. the innol:'I!m and injunod fIlOUlII!. .. to mdff bet' ~-- iIltoIrrablf< and Iif.. bw J. __. lUl<t tl\i!o llAl<lft is Mt ~ elf, in the llIt,matM>. b, It is believed that Defendant will aIler ninety (90) days from the date of the filing of this Complaint, consent to this divorce, WHEREFORE, Plaintiff requests your Honorable Court to enter a decree in divorce. COUNTn EQUITABLE DISTRIBUTION 11, PlII'IIgr&pha 1 through 10 are incorporated herein by reference sa If set forth in their full text. 12. Plaintiff and Defendant are joint owners of various items of personal property, furniture, and houaehold furniahinp acquired during their IIllIITiaae which are subject to equitable distribution. 13, Plaintiff and Defendant have incurred debts and obligations during their marriage which are subject to equitable distribution. WHEREFORE. Plaintiff requests your Honorable Court to enter a decree equitably dividini the parties' propertl and equitably apportioning the debts incurred by the parties, Respectfully Submitted, THE LAW OFFICES OF RON 111RO 4s7f7 Date ~~~. 32 South Ord Street CarJille. PA 17013 (717) 2u.Gll88 Attorney for Plaintiff , ,I i! !i ii :1 ;i n . i ~ ;! ii w . . VERIFICATION I YerIf1 that the at8lementa IIIlIde In the Coreaolnlr Divorce ('''''''pI.hot are true and correct. I understand that Calle at8tementa herein IIIlIde are auiject to the penalties of PL c.s. SectIon 4904 relating to IIIIIWOI'II r.lai,.....tlOll to authorltiee. ~yy97 -,d~ -,... ':::t~ -J 'ti rt~ ~rt 3 " 1O~ ~11 ~~ ?l Vt_ ,~f) E. ." . f'. it: C' L: In ~i ~ .,... e ;:: 11' :~ .-. -, :1: .?~ .~ )~-!2 ::~ , '.'f,] l" -:iu.: -) u \) \) ~ ~ \. - - KIMBERLY ANN METZGER, Plaintill', : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO,(l6. '.)-" 3.3 CIVIL TERM : CML ACTION : IN DIVORCE v. MORRIS HENRY METZGER, JR.. Defendant COMPLAINT IN DIVORCE 1. Plaintill'is Kimberly Ann Metzger, an adult individual, aJJTent.l,y reelcIine at 1328 Pine Road, Lot #6, Carliale, Cumberland County, Pennsylvania. II 2. Del'endant is Morris Hemy Metzger. Jr ~ an adult individual, c:urrentIy residiDc at 66 West Ii.' Church AYeDUe. Carlisle, Cumberland County, Pennsylvania. 3. Plaintill' and Defendant are bonarlde rnidenta 01 the Ownftt(JQwee!th 01 PennsyMmja and II 'II bII'fe been 10 for at least IIix monthllmmediatel;y preyioua to the fiIinc 01 this C.na>pLoln\. I 4. PIaintif1' and Del'eDdant wen! IIlIUTied 01\ February 24. 1~ in Cumberland County, I !I " " Pennsylvania. Ii !! II Go There ba'lt! been no prior actiona for di-forte or annu1ment between the partlea. I' II 6. The Del'endant is not . member 01 the Armed F_ 01 the United Slate8 01 America, or Ii Ita AIIiet. 11 7. The PlaintilJ'baa been ad-.i8ed 01 the 8fti1abi1ity ol~-" and the ~ to reqIR8t that ;, II the Court req...... the paniea to participate in~, Knowlnc uu.. the Plaintllf doea not deMt that I :: the Court requft the partiet to participate In --1iIl&- II. PIaintilJ' and Del'endant are citbaII 01 the United &atea 01 America. 8. Tbe paniea bII'fe Ihed Mparate and BfW'l1lila Mardl 15, 1M and ........... to .... ~ and..-n .. 01 the date 01 thiI ~. III PWmiIr dnins. ~ '-d upon: .. Tbe r.t that lW....... baa arr.n.d IUdI II""..'. jooo to the petal 01 the I'taintiIt the InnoceGt and ~ ..,..- .. to rftlder her ~vuditiun lilt 111111* .... .... ~ dt-.--.. and thiI .-tion is nat cUIIIIive or. 1ft the aItematlft. . .vy..j;. 1". J ~ t:. ~ " Go .... '", l' c: ...... ..... g ~ ~: \(. t . u,.,~ , ..-c ( ,. fC.": .. " :1 0 J L: 'i .) .. ,- , 1-0,. , ,- e '1 '- - . L. , '-' ~ KIMBERLY ANN METZGER, PlalntilT, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY. PENNSYLVANIA v. . . : NO. 96-6433 CIVIL TERM MORRIS HENRY METZGER, JR., Defendant . : CIVIL ACTION : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Diwn:e under Sec:tion 3301(c) of the Diwn:e Code was filed on October 2,1996. 2. The IIl8I1'ia&e of PlalntilT and Defendant is irretrievabI.y broken and ninety (90) ~ have eIapeed f'rom the cIate of the flIina of the C'.oIDpLolnt 3. I CUIIeJIt to the entry of the fiDaI Decree of Divorce 8fter eervice of IIOtice of intention to requat entry of the decree, I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECl'. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECl' TO THE PENALTIES OF 18 P..... c.s, SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORmES. , I Ii ,. !J 'I' >- ,n u: c: , \:. .. u'" ~:!:; : \.l-' t.,.;... \ ~- C.i. , ' ::,,~I 0 u c: ~' , 1;_ , - , I' ..... " '--' c"\ 0 '- '--L-' to.' c:. , \~ (~-' : ,,- I " , , ',.' n L.~ L: ! - ..... 1>_ .... , G .,:.. ~~ , , , II ~ I , KIMBERLY ANN METZGER, PlaintilT, . , v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO, 96-5433 CML TERM : CML ACTION : IN DIVORCE MORRIS HENRY METZGER, JR., Defendant WAIVER OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 330Ile) OF THE DIVORCE CODE 1, I c:onsent to the entry of a lina1 decree of cIivorce without notice. 2. I understand that I may lose rights c:onceming alimony, division of property, lawyer's rees 01' expenses if I do not claim them before a cIivorce is jp'lIDted. 3, I understand that I will not be diYorced 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 fi1ed with the prothonotary, I VERIFYTHATTHE STATEMENTS MADE INTlDSAFFlDAVlT ARE TRUE AND CORRECT. 1 UNDERSTAND THAT FAUlESTATEMENTS HEREIN ARE MADE SUBJECl'TOTHE PENALTIES OF 18 PA. C.s. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. ~fi-?/~;> Date ~/~4r ti;.r- Morris Henry Me ger, Jr. , -. KIMBERLY ANN METZGER, . IN THE COURT OF COMMON PLEAS OF Plaintiff . . CUMBERLAND COUNTY, PENNSYLVANIA . . . . CIVIL ACTION - LAW . . . 96-5433 vs. : NO. CIVIL 19 MORRIS HENRY METZGER, JR. , . . Defendant . IN DIVORCE . STATUS SHEET DATE: ACTIVITIES: . 4/29/97 Counsel are to get back to the Divorce Master's Office with some su ested dates in Au ust for an indi nities hearing. '?f!";~/.J ~.- ;1] , "f I"'. "./ ,~- _~",I ,'I ;... I. _ ~ H -~ 1 , J. , i ., -J -~ '.f.. I '" ' f ! .. ',~ . ,t,...., . { .. "I'.f (.xt ." ~ .:', -" , ! r1.. . ~ ~'.,' fJJ1 kNI~~ ~CWG. ~.lt ~~/IM!:*rtLr ~itl'-~\ lit. -r'A ,li~' I 'N) . . KIMBERLY ANN METZGER, . IN THE COURT OF COMMON PLEAS OF . Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . vs. CIVIL ACTION - LAW NO. 96-5433 CIVIL 19 MORRIS HENRY METZGER, JR, , . . Defendant . IN DIVORCE . ORDER AND NOTICE SETTING HEARING To: Kimberly Ann Metzger Robert J. Mulderig Morris Henry Metzger, Jr. John H. Broujos , Plaintiff , Counsel for Plaintiff , Defendant , Counsel for Defendant You are directed to appear for a hearing to take testimony on the grounds for divorce of indignities to the 9arson at the Office of the Divorce Master, 9 North Ha~over Street Carlisle, Pennsylvania, on the 12th day of August ,1997, at 9:00 a.m. at which place and time you will be given the opportunity to present witnesses and exhibito in support of your case. By the Court. ~a"~1t 1 ~== . Harold E. Sheely, .Judg" Date of Order and Not ice: 5/8/97 By: Divorce Haster H YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELON TO FIND OUT WHERE YOU CAN GET LEGAL HELP. court Administrator Fourth Floor, E.st Wing CUmberland County CourthQu5~ carlisle, PA 17013 Telephone (7\11 240-6200 ~"...., ~:"':'t'r. \ \.!:.\J"" .'-.... ,-.r" _' ,,' ,,' ,J,\ r:: - - ''\1 ," c,',?j ., \.; 1 \, r1 .,' .10 ," " ", \.'.' \'~'l-," ,~,i~' ...~..\ ..... c. t,- h l~ ! t~l i,.. .:1 I ~,. , " ,) I- " "- I -, '. .... , , "'. \.,,) KIMBERLY ANN METZGER, . IN THE COURT OF COMMON PLEAS OF . Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . . . vs. . NO. 96 - 5433 CIVIL . : MORRIS HENRY METZGER, JR., . . Defendant . IN DIVORCE . AND NOW, ORDER OF COURT this ~ day of ~t) L)/-' , 1997, the economic claims raised in the proceedings having been resolved in accordance with a separation agreement and property settlement dated August 12, 1997, the appointment of the Master is vacated and counsel can file a praecipe transmitting the record to the Court roquesting a final decree in divorce. BY THE COURT. y, P.J. ee: Robert J. MulderilJ Attorney for plaintiff - ....""-""~..h..""l..' ....R~ John H. Broujos Attorney for Defendant . "",~.\ th."'... 'I "l'n ~.j': "" 't ,- '. 'r. ;, .. .',,.. -. .. '~"" ':::f.' ':t. . 4' ,~ :;- ..J ~ c-; c: .",- \. .. ~ ~ hJC - p. - ":.1.,. \J.... ,,- '-.:. ~ Q: 0 0' ~.'? L.. . ~ 0 r~'''' , (L ':;1 U. - ~ u' to- , v: t' rY.. 0 r- U ~ cr.