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HomeMy WebLinkAbout96-05454 II) ~ /) l t ..) ('J" ~l I '~'< " ,j -~ :~ "~ y,; ," j .'.~~ ;~ ,"J!I "-". '?1 ;':~ MICHAEL J. KANE, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE NO. S~S~ -11411 YVETTE KANE, Defendant OUALIFIED DOMESTIC RELATIONS ORDER AND NOW, this -s:..- day of ~ ' 195f, Yvette Kane and Michael J. Kane stipulate to the following facts: 1. The parties hereto were formerly husband and wife having been divorced on November 14, 1997, by this Court pursuant to a marital settlement agreement which provides for this Court to retain jurisdiction over enforcement of the Equitable Distribution Agreement. 2. Michael J. Kane (Social Security Number 136-42-1090), is hereinafter referred to as "Plaintiff" or "Participant" 3. Yvette Kane (Social Security Number 437-88-84991, is hereinafter "Defendant" or "Alternate Payee., has raised claims for, inter alia, equitable distribution of marital property pursuant to the Pennsylvania Divorce Code. 4. The parties have agreed pursuant to an Equitable Distribution Agreement executed November 11, 1991, that the SUlll of Nine Thousand One Hundred Ninety-Four ($9.194.001 Dollars shall be paid to Defendant subject to the terl\lll and provisions of thia Order, and at Defendant's eleetion _y be paid directly to an eligible Individu41 Retirement Account. F',!.::\}..r,-:?::.: OF ,. 'jP 'jT,I'~~,Y ~.Rrr.~-:.., (" r,11 ~)~ ,-... >:-.-./ .... ., ',./.. . ~_.-... ..... ..'-, ..- 5. Plaintiff I s current and last known mailing address is 4182 Antelope Court #117, Mechanicsburg, Cumberland County, pennsylvania 17055; and 6. Defendant' s current and last known mailing addresS is 401 Huron Drive, Mechanicsburg, Cumberland county, pennsylvania 17055; and 7. The balance of the aforementioned account on March 24, 1997, was Thirty One Thousand One Hundred Seventy TWo ($31,172.43) Dollars and 43/100 Cents. IT IS ORDERED, ADJUDGED AND DECREED as follows: 1. 1\. portion of the aforementioned Cash Management Class 1\. IRA account in the name of Michael J. Kane is marital property subject to distribution by this Court. :I. The sUIII of Nine Thousand One Hundred Ninety-Four ($9,194.00) from the account is awarded to the Alternate Payee, yvette Kane and is to be segregated and paid directly to yvette Kane or, at her electiOn, to be transferred to an Individual Retirement Account in her name. The participant Michael J. Kane. is awarded the remainder. 3. The payment shall be a lump SU\'ll payment to be commenced immediately. 4. This payment shall not be subject to the premature distribution penalty as provided in I.R.C. S72(t} (2) (CI. In the event that this payment is rolled over into an Individual Retirement Account, this rollover shall not be subject to the premature distribution penalty and the rollover shall be considered a tax free rollover of the benefits/amounts distributed. 5. The Plan to which this Order applies is the American Express Cash Management Class A IRA account in the name of Michael J. Kane, bearing client #1526-8802-4-001. 6. Any reasonable costs incurred by the Plan Administrator to effectuate the terms and provisions of this Qualified Domestic Relations Order shall be assessed such that the Participant, Michael J. Kane, pays one hundred (100') percent of the costs. 7. The parties shall promptly notify the Plan Administrator of any change in their addresses from those set forth above in this Order. 8. The partiea shall promptly submit this Order to the Plan Administrator for determination of its atatus as a Qualified Domeatic Relationa Order. 9. Neither party shall encumber. transfer, pledge, or in any way dispoae of any portion of this pension plan until such time aa the Plan Administrator has qualified thia Order. after which . . DETERMINATION AS TO QUALIFICATION OF DOMESTIC RELATIONS ORDER, NOTICE TO PLAINTIFF (PARTICIPANT) AND DEFENDANT (PAYEEI AND AGREEMENT TO COMPLY WITH ORDER Pursuant to the requirements of the Retirement Equity Act of 1984, the Plan Administrator, and any successor, hereby states as follows: 1. The attached Order of the Court of Common Pleas of CUmberland County, Pennsylvania, dated 1997, is a Qualified Domestic Relations Order; and 2. The Plaintiff (Participant) and Defendant (Payee) are hereby notified as to the qualification of said Order; and 3. The undersigned will comply with all of the terms and conditions of said Order. Dated this day of , 1997. By: Plan Administrator .~~'~~~~~~~~~-~-***~*~)~:~~~---~~~~ . . . '.- ------,----~-'.........-----_......--- ._.... -" ~ ~ $ 8 8 ~ 8 * 8 8 S 8 8 ~ 8 8 ~ , ~ 81 s 8 ,;, " IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF '* PENNA. ~; :'1 ~ I ,;, " 8 Michael J, Kane, Nil. 5454 ...... 1<)96 w " Plaintiff ~ ~'! ~ v~ ..l ," \ ~' , i ~! ~.' ; \','r:,ll.~ Yvette Kane, Defendant DECREE IN DIVORCE AND NOW, .\\J~ r L1.. 19 ~tl.. it is ordered and Xi " ~) Xi '1 " M1 .1 ..' ~I . } 8l ) 8l 8i ./ !!II 8l ~i : l I!! I 8 8 M. - M! ! 8; M . . 11>:. decreed lhat .... . Michae 1. J, . Kane. and . . . . . . . . . . . Yvet.te. .K.ane. 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 nol yet been entered; ~ . the attl\cl1e<\ property seUlelllentaS\reelllent ill hereby. incorporated. ioto " the divorce decree. /' n. l'ih. c:.u;.: / ~..v...V ^tt..t:I"'~~~''''''' /, (~;;:'.~ ~~ikm: ~ ",,:,;y;. ~~ ./ ".,'" P,ntho...c.tart M '. .. 8 8 8 ~ 8 8 , i. 8 )8 ) . :~ } . I!I ~ ~ ~ Ii '" ~ ~ 'i J. ~ ~ I'i ~, .. :.; . x- .. ,-a: -,~. ..;<< -.3t;, .. .:..; .:w:. .. ~.. ...... .- ~ " MATRIMONIAL SETTLEMENT AGREEMENT THIS AGREEMENT, made this 1997, by and between Yvette Kane of 401 Huron Drive, Mechanicsburg, Cumberland County, Pennsylvania ("Wife"), and Michael J. Kane of 4182 Antelope Court N117, Mechanicsburg, Cumberland County, Pennsylvania ("Husband"). I J t/J day of Nol Recitals: A. The parties hereto, being Husband and Wife, were lawfully married on September 18, 1982. B. Differences have arisen between Husband and Wife in consequence of which they have begun to live separate and apart from each other. C. Husband and Wife acknowledge that they both have consulted their attorneys and have been advised by their attorneys of all of their rights and duties or have had the opportunity to consult independent legal counsel and have wilfully, knowingly and voluntarily waived the right to consult an attorney. NOW, THEREFORE, in consideration of the mutual promises, covenants and undertaking herein contained, the parties, each INTENDING TO BE LEGALLY BOUND, agree as follows: 1. Recitals. The Recitals set forth above are incorporated herein by reference. ~. Divorce. It Is specifically understood and a9reed by and betveen the parties, and each party does hereby warrant and represent to the other that, as defined in the Divorce Code, thelr marriaqe is irretrievably broken. Husband has filed an action in the Court of Common Pleas, Cumberland County, Pennsylvania. The parties agree to take all legal steps (including the timely and prompt submission of all documents and the taking of all actions) necessary to assure that a divorce pursuant to 23 Pa. C.S.A. ~ 3301 as amended of the Divorce Code is entered as soon as possible. This Agreement and any ancillary or supplemental agreements shall be incorporated by reference and merged into the proposed Divorce Decree presented to the Court. Husband and Wife shall at all times hereafter have the right to live separate and apart from each other and to reside from time to time at such place or places as they shall respectively deem fit, free from any control, restraint or interference wh.~.gever by ..oh gther. N.ither par~y .hall mol..t the g~h.r in any way whatsoever nor endeavor to compel the other to cohabit or dwell with him or her by any legal or other proceedings. The foregoing provision shall not be taken to be an admission on the part of either Husband or Wife of the lawfulness or unlawfulness of the causes leading to their living apart. 3. Marital ProDertv. (a) Personal ProDertv. Husband and Wife acknowledge that they shall divide the personal property acquired during their marriage as set forth on Exhibit "A". Husband hereby relinquishes all right, title and Interest in Wife's personal property and Wife hereby relinquishes all right, title and interest in Husband's personal property. (b) Retirement. Pension. 401-K Plan. Husband hereby relinquishes all right, title and interest in Wife's retirement, pension and/or 401-K Plan, if any, and Wife hereby relinquishes all right, title and interest in Husband's retirement, pension and/or 401-K Plan, if any. (c) Real Estate. Husband hereby waives and relinquishes any right, title, or interest in the home located at 401 Huron Drive., Mechanicsburg, PA, title shall rest solely in Wife's name. The parties agree to execute any deeds or instruments of conveyance necessary to accomplish the within. Wife agrees to waive and relinquish any right, title, or interest in any real property that husband may obtain by legal or eqyitable tiUe or: r:ivht and that any suoh pr:operty shall r:est solely in Husband's name. The parties agree to execute any deeds or instruments of conveyance or waivers of rights necessary to accomplish the within. (dl Division of Prooertv. Husband and Wife agree to the entry by the court of a Qualified Domestic Relations Order by which Husband agrees to pay the sum of Nine Thousand One Hundred and Ninety Four Dollars ($9,194) to Wife as a final lump sum payment regarding the equitable distribution of marital property, specifically equalizing the assets which each party has retained. Wife agrees that, in the event that the distribution pursuant to such Qualified Domestic Relations Order is deemed to be subject to a premature distribution penalty as provided in The Internal Revenue Code. wife shall pay such penalty or reimburse husband for sallie. 4. pebts and Obliaations. (a) Individual debts/obliaationS. Each of the parties shall assume all debts and obligations presently in their individual names and shall indemnify, defend and hold the other harmless from said debts and obligations, whether incurred prior to, during, or subsequent to the marriage. This shall include all personal, individual credit cards and personal individual loans by either party except as otherwise set forth herein. Each party hereby agrees to pay and hereby agrees to hold the other harmless from any and all personal debts and obligations incurred by him or her on or after the date of this Agreement. If any claim, action or proceeding is hereafter brought seeking to hold the other party lla~le on accQunt of any such debts and obl19atlons, su~h party will at his or her sole expense defend the other party against any such claim, action or proceeding, whether or not well-founded, and indemnify the other party against any loss resulting therefrom. (b) Joint debts/nbliaations. Husband and Wife represent that there are no 10int debts or other debts incurred by either of them, except the obligation encumbering the automobiles, currently outstandlng with respect to which the other party may incur any liability now or in the future. Each party otherwise hereby expressly agrees to indeanify, defend and hold hanaless the other frea any and all liability, direct or indirect, including attorneys' fees and costs, which may arise in connection with an obligation, 10int or ot.herwise, for which the party has agreed hereunder to bear sole or partial responsibility, or which the party has failed to disclose and provide for herein. 5. Leaal Fees. Each party agrees that they shall be responsible for their own legal and other fees incurred by them in connection with this domestic relations matter unless otherwise specified herein or otherwise agreed to by them. 6. Automobiles. Upon execution hereof, the parties agree that the 1993 passat GL automobile shall become the sole free and clear property of Wife, and that Wife shall insure and assume all liability for the loan encumbering said automobile therefor except as otherwise set forth herein. Husband waives any right, title or interest he may have in and to said automobile and shall promptly execute any title or transfer documents necessary to fulfill this provision. Wife agrees to waive any right, title or interest she may have in and to the 1991 Plymouth Voyager which Husband has in his possession. Wife shall promptly execute any title or transfer documents if necessary to fulfill this provision. Each party shall, after execution hereof, maintain their own automobile insurance in their separate names. 7. Other Writtnas. Each of the parties hereto agrees to promptly execute any and all documents, deeds, waivers, bills of sale, tax returns or other writings reasonably necessary to carry out the intent of this Agreement. 8. custodv/SuDoort. The parties agree that Husband and Wife shall share legal custody of the P<lrttes' two children, Madeline F. Kane and Kathleen Y. Kane. Wife shall have physical custody of botll children. Husband shall pay to Wife the amount of Eight Hundred and Seventy Five Dollars ($875.00) per month as child support on the first day of every month hereafter. Husband may deduct the sum of Ninety Dollars ($90) from the December, 1997, January 1998 and February 1998 payment to repay advances previously made by him to wife. The parties shall equally divide all extraordinary personal or medical expense, including by illustration, but not limitation, summer child care expenses, orthodontic expenses, major surgeries, psychological counseling and other such matters not covered by insurance, so long as both parties reasonably agree that the expense, procedure or treatment is reasonably necessary. Such agreement will not be unreasonably withheld. Release of claim to ExemDtion. Wife agrees to unconditionally release any claim of Federal and State income tax exemption for Madeline Francis Kane for all future years, and shall execute IRS Form 8332, Part II to accomplish same. Child Visitation. Commencing on November 7, 1997 Husband shall have visitation with the children on alternate weekends from Friday at 6:00 p.m. until Sunday at 6 p.m. and shall further have visitation on Wednesdays commencing at 6:00 p.m. until 8:30 p.m.. Husband shall have the option of keeping the children at his home overnight on such nights. Ih...h-I.d ..han pick up -~i ekll.F9ft A~ vitA'. ~~.e to at6rt said ,isit.tiQft. An~ VI'A .hall ~~~ pie" ..... "hlldu:n at: HUSDan(J'. I~.. "!."'" \';UAlpleteu. If either child shall remain overnight with Husband, he shall be responsible for transporting said child to school. Husband shall have temporary custody for one uninterrupted week during the children's summer vacation. Such temporary custody shall extend no later than seven (7) days prior to the first scheduled school day of any child. Husband shall provide notice to Wife prior to June " of each year the week in which he wishes to have temporary custody. Regardless of any provision set forth above, custody of the children shall be divided as follows: a. temporary custody shall be provided to Husband on Father's Day, and to wife on Mother's Day. b. Husband and Wife will be provided custody of the children on alternating holidays. Said holidays shall be considered as Memorial Day, Independence Day, Labor Day, Thanks,ivin" Gh~i.~.a. C~e,innin, a~ ilOO p... De8..~e~ 34\h an. extending to 10:00 a.m. December 26th), New Year's Day and Easter Sunday. Husband will be provided temporary custody on Christmas, 1997 and holidays shall alternate thereafter. c. Husband and Wife will alternate yearly birthdays of the children, Husband being provided temporary custody of the children for all birthdays occurring in 1998, and alternating yearly thereafter. 9. Further Debt. (a) Wife shall not contract or incur any debt or HabUity for which lIusband or his property or estate might be responsible and shall indeanify and save harmJes. Husband froe any and all claims or demands, Including attorneys' fees and costa, made against him by reason of debts or obligations Incurred by her. lb) ttuaband shall not contract or incur any debt or liability for which Wife or her property or estate might be responsible and shall indemnify and save harmless Wife from any and all claims or demands, including attorneys' fees and costs, made against her by reason of debts or obligations incurred by him. 10. Mutual Release. Except as otherwise provided herein and so long as this Agreement is not cancelled by subsequent agreement, the parties hereby release and discharge, absolutely and forever, each other from any and all rights, claims and demands, past, present and future, specifically from the following: alimony pendente lite; alimony; spousal support; division of property; claims or rights of dower and right to live in the House; right to act as executor or administrator in the other's estate; rights as devisee or legatee in the Last Will and Testament of the other; any claim or right as beneficiary in any life insurance policy of the other unless specifically named otherwise or as required herein; and any claim or right in the distributive share or intestate share of the other party's estate, all unless specified to the contrary herein or in a subsequent writing signed by the parties hereto. 11. Tax Return. The parties have elected to fUe separate individual income tax returns beginning with tax year 1997. Each party shall be solely liable for any tax liability from that period forward and shall indemnify, defend and hold the other haraless from and against any sueh liability. 12. Medical/Health Insurance. Upon execution hereof, each party shall be responsible for their own llIedical/health insurance and the _lntenanee thereof, if any. WU. shall maintain health Insurance for the children, providin9 covenoe equivalent to that provided to Commonwealth of Pennsylvania employees. 13. Entire Aoreement. 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. 14. Leoallv Bindino. It is the intent of the parties hereto to be legally bound hereby, and this Agreement shall bind the parties hereto and their respective heirs, executors, administrators and assigns. 15. Full Disclosure. Each party asserts that she or he has fully and completely disclosed all the real and personal property of whatsoever nature and wheresoever 10Qated belonvinv in any way to each of them; of all debts and encumbrances incurred in any manner whatsoever by each of them; of all sources and amounts of income received or receivable by each party; and of every other fact relating in any way to the subject matter of this Agreement. These disclosures are part of the consideration made by each party for entering into this Agreement. Each party further represents and warrants that there are no undisclosed debts or obligations for which the other party may be liable, and each party shall indemnify and hold haI1llless the other party from any such liabUittes, including attorneys' fees and costs. 16. Costs to Enforce. In the event that either party defaults In the performance of any duties or obligations required by the teras of this "gre_ent, and leqal proceedings are oOlfmenced to enforce such duty or obligations, the part.y found to be in default shall be liable for costs. If either party shall be found to have acted in bad faith with respect to such duty or obligation or the enforcement thereof, said party shall be liable for the other's reasonable attorneys' fees, incurred as a result of such proceedings. 17. Aoreement Voluntarv and Clearlv Understood. Each party to this Agreement acknowledges and declares that he or she respectively: (a) Is fully and completely informed as to the facts relating to the subject matter of this Agreement and as to the rights and liabilities of both parties; (b) Enters into this Agreement voluntarily after receiving the advice of independent counselor, having been advised to consult independent counsel, has knowingly and voluntarily chosen to forego such consulta tion; (cl Has given careful and mature thought to the making of this Agreement; (dl Has carefully read each proviSion of this Agreement; and (e) Fully and completely understands each provision of this Agreeaent, both as to the subject utter and legal affect. 18. All\endaent or ......ification. This Agreeaent uy be amended or .edified only by a written instrument signed by both partiea. 19. !oDUcable La". This Agreeaent ahall be governed, .. ---~ '- construed and enforced under the statute and case law of the Commonwealth of Pennsylvania. 20. Soousal Suooort. In consideration of the terms hereof, Husband and Wife mutually agree to waive any claim either may have for alimony or spousal support. 21. Counteroarts. This Agreement may be executed in separate counterparts, each counterpart deemed an original and when combined represents the legal binding intent of the parties hereto. 22. Severabilitv. If any part of this Agreement is determined to be invalid by a court of competent jurisdiction, such determination shall not invalidate the entire document but shall apply only to that phrase, sentence, paragraph or section. The remainder of the sentence, paragraph, section and Agreement shall continue in full force and effect. IN WITNESS WHEREOF, the parties hereto have executed this Agreement the day and year first above written: WITNESS: WIFE: y..,,~..~~ WITMUS: HUSBAND: ~~y~ ~ -. ~ I ..,. .. .,~ i c- o , UI~, .J I ~' " - U~ t_ (,' ~ ;;; ~:. .J;.-' .:t" ~'-:\a ,.... ~- ..J :;.. .~ U'. '.tt r- !., -. .., ~ t', r- .l 0 0' lJ ,; j : : I N TilE COUIlT O~' COHMON I'I.I;^S Nichae 1 J. Kane, : Plaintiff : CUHOERLAND COUNTY. PENNSYLVANIA . . VS. : CIVIL DIVISION . . Yvette Kane, . NO.96-5454 CIVIL TERM . Defendant : PRAECIPE TO TRANSHIT RECORD To the Prothonotary: Transmit the record, together vith the following infor.ation to the court for entry of a divorce decree: I. Ground for divorce: irretrievable breakdown under S3301(c) ~of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of tho complaint: October 31, 1996 Personally handed to Defendant who accepted service 1. Complete either paragraph (a) or (bl. (a) Date of execution of the affidavit of consent required by SllOI(c) of the Divorce Codo: by plaintiff November 11, 1997 by defendant November 11, 1997 (b)(l) Date of execution of the affidavit required by S330l(d) of the Divorce Code: : (2) Date of fi11ng and service of the plaintiff's affidavit upon tho r~spondent: 4. Related claias pending: None ~. co.pleto either (a) or (b). (a) Date and ~nner of service of the notice of intention to fUe praecipe to tran_it record. a copy of which is attached: (bt Date plaintiff's Waiver of NOtice in IJJ01(c) Divorce va. Ck led vilh the Prothonotary: :'\on'lllb.-r . \,,1(17 Date defendant's Waiver of Notice in 13J01(0) Divorce v.. rUed with the Prothonotary: Nol,,,,,,,,"'r . 14'~; . $'-"''- P" . t'! ' . ../ ..i it- " "Hotne, for lltl ......WU.( Dotfendanl) . .' In the Court of Common Pleas of Cumberland County, Pennsylvania Michael J. Kane, ) Plaintiff ) ) No. of 1996 vs. ) 91.. S"IS~I ~,~,'l Ii IZ. "/ ) Yvette Kane, ) Defendant ) COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Michael Joseph Kane, who currently resides at 4182 Antelope Court, N111, Mechanicsburg, Cumberland County Pennsylvania since September 13, 1996. 2. Defendant is Yvette Kane, who currently resides at 506 Partridge Court, Mechanicsburg, Cumberland County, Pennsylvania since August of 1991. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on September 18, 1982 at Littleton, Arapahoe County, Colorado. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the court require the parties for participate in counseling. 8. Plaintiff requests the court to enter a decree of divorce. I verify that the statements make in this Complaint are true and correct. I understand that false statements herein are made subject to penalties of 18 Pa.C.S. S 4904, relating to unsworn falsification to authorities. Date: ~ ) r ,ol1t. ~ ~ Q... ,.- ~ tv) r( c- ~"J I> - ,.- - Vj ~ ',0,' -. , -- ~ ~ ' . Q " t l? r ~ ~ ~ .:J. - ~ (j r:t.. (f) >- - c u; - - ;.:: S 1:- lUQ . )< -~7 u:. .~ _J~- (:"",. ~. ~-:: ", :...:. ~~ O(~ .3- .~ C.'){ - "'<, L:... ..~2 :--\' .:.", _ :J;."J L.. - . f=..: ,;.). - a " ,... U 0'1 .' , >- - 2:: 0; - ;s ,. tuG:: S ~~~~ ( "h "~- r...: : ;-': .;:)::~ I._} orq; "-...,.' 0, .....~ C, .::r .~"-, 1.<" - .'~ <.. "J, - ~ . ::.. :11':U ,- !:" .~?..~ - .-" a r0- B U1 . . v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE NO. MICHAEL J. KANE, Plaintiff YVETTE KANE, Defendant NO. 96-5454 WAIVER 01' NOTICE 01' INTENTION TO REQUEST ENTRY 01' A DIVORCE DECREE UNDER SECTION 3301(c) 01' THE DIVORCE CODE 1. I consent to the entry of a final Decree of Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a Divorce Decree is entered by the Court and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the 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.A. Section 4904, relating to unsworn falsification to ~uthorities. Yve,,~/:,':.~ >- ;:: c; ~ ;::, 5..,- w~. S .:.)~ -, ~J:. ,- .J< ~- .;, ~ , . "-J "., -:~ 0.;.. 9,' -3 ~ ft. rY' .~ .j;;: LV..... "7 ~ Jt. ::~ i.... ,,_ ','I~ (\:: . c;., L1": F.: :z: a u, r- a C1' In the Court of Common Pleas of Cumberland County, Pennsylvania Michael J. Kane, ) Plaintiff ) ) No. 96-5454 VB. ) Civil Term ) Yvette Kane, ) Defendant ) ACCEPTANCE OF SERVICE I accept service of the COMPLAINT UNDER SECTION 3301(c) OR 3301(dl OF THE DIVORCE CODE. I certify that I am authorized to accept service on behalf of defenda t. /O/~lly(, Date 506 Partridge Court Mechanicsburg, PA 17055-2597 '0;.'.*.'" - , ,-, ;..~:.",,' ,- ~ "I .?: -~ ("; ~ , ~ "$ :) - ).<e, - 0.- "l~ t<", ...,., ~ ~ '\j} ';." - ~~ - it.'> ~ ." Cl .J 0- r:' - .- l3 \:) '" c:t' '.".~~--'~".~"..~~,-; .- -=",',,<--~-.-.~,. ~."t'~~_ ",..";"':-~-~~~::.:- ,-'~~-'::'=:-,:,"'i,..,.._~.. ,....~; . MICHAEL J. KANE, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW IN DIVORCE NO. 96-5454 YVETTE KANE, Defendant PRAECIPB TO ENTER APPEARANCB TO THE PROTHONOTARY: . Please enter the appearance of John R. Fenstermacher, Bsquire and the Offices of Fenstermacher and Associates, on behalf of Yvette Kane in the above matter. Respectfully submitted, AND ASSOCIATES er DATED: /lINIn f:~ ;:;;. ?7. "-' :":'';; ~~j ::; :...:;.; .,.:c;:: ~~? .~./. ._~ '."" ;.iul :.::!il. $;': :.:'l U ~ ~ U J~ ~ U'. {~: ~" 0'. . . 01 ,-"C ~-l\ . t.i-..' {;: ~. ..,:,:.. t5 r- C'