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Home My WebLink About00-00364 ~ ~.~ ~ ~.~ ~ ~.~ ~ N ~ ~ ~ ~ ~":~ ~ 14 f..~ ~ ~ v' ~ ~.~ ~.~ ~ n * ~~ ~ ~.~ ~ ~":~ A ~ ~.~ ~ ~..,; t~ ~ ."< ~~~ ~ , . ":' "C" c', " ,'. .f:"'",-",,,,-,' I,.,.,. j., ~, o. ".',< , "'" !d ~/ ii ~.~ .", ~~ ,:~::+;<}::+:.:;: ::.::+::.':: :::.::.::;<:;~::+::~< )::+:~:. ::'.::+::".' ::'.::.::~':: :;.::+::< :':.::+;.:; ,,;i'- r . ,. /7:C;';:}>>};:;:::!::+X:::~:c;::::~>>};:>::.;{)':..>r>.~:~!";2:!>>;Kx.n~:C~::~~~~)::<<(:~~:CK~~3~K::;(C~a::~:.XJ~:C~~::~!>>~~$~t!:C<')'::~~:~'3.}g*:Ct;~~~"{.E:*>>>~:J:<+};;?xa>lt ~ I ~ i .,:; It' ; ~ N IN THE COURT OF COMMON PLEAS ~! ~ ~ "'." ~ ~.~ k~ ~ a A ~.~ ~ ~ ~ ~.~ ~~ ~ " ~ k~ ~ ~ J~ ~ . ~ I J~X:i_'".:__!,::":.>>::.;, OF CUMBERLAND COUNTY STATE OF PENNA. DAVID ALAN DREESE N o. ...?o..0.9,::-}~.4 .................. 19 Versus CRYSTAL WALKPEN DREESE DECREE IN D I V 0 R C E a. 3 ~ z,~ 814. · AND NOW, ....... ..... ~ . . . . . .. .(~. 2.QOO, it is ordered and decreed that.. .. ?~ . . .~~~~..~~~~~.~.. . .. .. .. . .. .. .... .. .. . ., plaintiff, and. . . . . . .c:~~s:r.~~. ~~~~J?~~ P~~.E.~~. . . . . . . . . . . . . . . . . . . . . . . " defendant, 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; AND IT IS FURTHER ORDERED, that the terms, conditions and covenants set fq~tA.~~.~4~.w~~tt~A.4q~~~~~At.~ade.and.entered., into'by'the'parties on May 3, 2000, are incorporated into this D6!G:ree . b . .:r:;6!fe.peFlce. .t:.he;ret:.0'" .blit. not. merged' 'into .this' 'Decree;' . UUp.UJ: Prothonotary ~ ~ 1;( ',:<....~;, .::.>>,;:, ':-.:c.;:: "::0>>:.:;: :::o:c(.::.>>::( :::O:C( :':.:+:>.; ):+::~< '::~:+;.::, .::.:+;.:: '~~.:+::o;,: '.:.::+;.'-' :'.:.~'" ;~~ ~ ~.~ ~ ~~~ ~ ~.s * j ~.~ I ~ ~;;~ ~ a ~.~ ~ ; ~.; ~ Ili ,", ~.'~ ~ ..~ i ~s ~ ~~~ ~ ~ ~ ,;" a ~.<! l'o ~.~ ~ t~ W ~.~ ';.,' ~ ~.~ '.;", i ~.J; i ~.~ ',.,,' j, ~.~ ~ ~.~ ~ ~.~ ~ ~.~ ~ ',.- ~ ~.~ f..~ ~ ;'~ ~ ~ '.' , " '" , ~ ". "OIl' ..T '- . ~ .. .' . ",~ "'~" '.....llI '.. '\ S'3/-CJO tV ~~ ~4~ S:3/~t7 7l~ ~ ~ 4 ~ .. , , "~ ",r " ."~ " , ,~ '- ,~. "''e " fl '",.,>" '11 ",__,_ ,,:,':""'" ,.,,~ ",0' , t' AGREEMENT ~d ,/Y) THIS AGREEMENT, Made this 3 day of 1/ ! <t 'L.. , 2000, by and between David Alan Dreese, hereinafter referred to as "l-dl3'sband", and Crystal Walkden Dreese, hereinafter referred to as "Wife". WITNESSETH: WHEREAS, Husband and Wife were lawfully married on April 29, 1995 and separated on December 25, 1995; and WHEREAS, no children were born to the marriage; and WHEREAS, certain differences have arisen between the parties as a result of which they have separated and now live separate and apart from one another, and are desirous of settling 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 past, present and future support and/or maintenance of Wife by Husband or of Husband by Wife; and in general the settling of any and all claims and possible claims by one against the other or against their respective estates for equitable distribution of all marital property; and a resolution of all mutual responsibilities and rights growing out of the marriage relationship; and WHEREAS, the parties hereto, after being properly advised by their respective counsel, Husband by his attorney, Dennis R. Sheaffer, and Wife by her attorney, Kevin E. Hobbs, have come to the following agreement. NOW THEREFORE, in consideration of the above recitals and the following covenants and promises mutually made and mutually to be kept, the parties heretofore, intending to be legally bound and to legally bind their heirs, successors and assigns thereby, covenant, promise and agree as follows: 1. SEPARATION: It shall be lawful for each party at all times hereafter to live separate and apart from the other at such place or places as he or she may from time to time choose or deem fit. 2. INTERFERENCE: Each party shall be free from interference, authority and contact by the other, as fully as if he or she were single and unmarried, except as may be necessary to carry out the provisions of this Agreement. Neither party shall molest , , the other nor attempt to endeavor to molest the other, nor compel the other to cohabit with the other, nor in any way harass or malign the other, nor in any way interfere with the peaceful existence, separate and apart from the other in all respects as if he or she were single and unmarried. 3. WIFE'S DEBTS: Wife represents and warrants to Husband that since their separation on December 25, 1995, she has not, and in the future she will not, contract or incur any debt or liability for which Husband or his estate might be responsible and shall indemnify and save Husband harmless from any and all claims or demands made against him by reason of debts or obligations incurred by her. 4. HUSBAND'S DEBTS: Husband represents and warrants to Wife that since their separation on December 25, 1995, he has not, and in the future he will not, contract or incur any debt or liability for which Wife or her estate might be responsible and shall indemnify and save Wife harmless from any and all claims or demands made against her by reason of debts or obligations incurred by him. 5. OUTSTANDING JOINT DEBTS: Husband and Wife acknowledge and agree that they have no outstanding debts and obligations of the Husband and Wife incurred prior to the signing of this Agreement. In the event that either party contracted or incurred any debts since the date of separation on December 25, 1995, the party who incurred said debt shall be responsible for the payment thereof regardless of the name in which the account may have been charged and shall indemnify and safe harmless the other from any and all claims and demands made against either of them by reason of such debt or obligation. 6. MUTUAL RELEASE: Subject to the provisions of this Agreement, each party waives his or her right to alimony and any further distribution of property inasmuch as the parties hereto agree that this Agreement provides for an equitable distribution of their " 2 - '__C". .'_' ,s--~ -, ' 'xi,'.,.. " ,~_.",-.,c', --'," '^ ~~ "'''~'\.: '" . . . ,j'" '.,1 ; ;~"--';""',;, ""'i'j, ( marital property in accordance with the Divorce Code of 1980. Subject to the provisions of this Agreement, each party has released and discharged, and by this Agreement does for himself or herself, and his or her heirs, legal representatives, executors, administrators and assigns, release and discharge the other of and from all causes of action, claims, rights or demands whatsoever arising out of their marriage, except any or all cause or causes of action for divorce and except in any or all causes of action for breach of any provisions of this Agreement. Each party also waives his or her right to request marital counseling pursuant to 23 Pa.C.S.A.Section 3302. 7. DIVISION OF PERSONAL PROPERTY: The parties hereto mutually agree that they have effected a satisfactory division of the furniture, household furnishings, appliances, 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 tangible personal property presently in his or her possession, and 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 each of the parties hereto. The parties hereto have divided between themselves, to their mutual satisfaction, all items of tangible and intangible marital property. Neither party shall make any claim to any such items of marital property, or of the separate personal property of either party, which are now in the possession and/or under the control of the other. Should it become necessary, the parties each agree to sign, upon request, any titles or documents necessary to give effect to this paragraph. Property shall be deemed to be in the possession or under the control of either party if, in the case of tangible personal property, the item is physically in the possession or control of the party at the time of the signing of this Agreement and, in the case of intangible personal property, if any physical or written evidence of ownership, such as passbook, checkbook, policy or certificate of insurance or other similar writing is in the possession or control of the party. Husband and Wife shall each be deemed to be in the possession and control of their own individual pension or other employee benefit plans or retirement benefits of any nature to which either party may have a vested or contingent right or interest at the time of the signing of this Agreement, and neither will make any claim against the other for any interest in such benefits. From and after the date of the signing of this Agreement both parties shall have complete freedom of disposition as to their separate property and any property which is in his/her possession or control pursuant to this Agreement and may mortgage, sell, grant, convey, or otherwise encumber or dispose of such property, whether real or personal, whether such property was acquired before, during or after marriage, and neither Husband nor Wife need join in, consent to, or " 3 " acknowledge any deed, mortgage, or other instrument of the other pertaining to such disposition of property. 8. WAIVERS OF CLAIMS AGAINST ESTATES: Each party may dispose of his or her property in any way, and each party hereby waives and relinquishes any and all rights he or she may now have or hereafter acquire, under the present or future laws of any jurisdiction, to share in the property or the estate of the other as a result of the marital relationship, including without limitation, dower, curtesy, statutory allowance, widow's allowance, right to take in intestacy, right to take against the will of the other, and right to act as administrator or executor of the other's estate. Each will, at the request of the other, execute, acknowledge and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interests, rights and claims. 9. SUBSEQUENT DIVORCE: It is contemplated that Husband will proceed with a no-fault complaint in divorce against Wife in the near future. Husband and Wife each agree to sign an affidavit of consent and (an affidavit waiving counseling) to be filed in said divorce action. The parties further agree that each of them shall be responsible for their own attorney's fees. It is the intention of the parties that the Agreement shall survive any action for divorce which may be instituted or prosecuted by either party and no order, judgment or decree of divorce, temporary, final or permanent, shall affect or modify the financial terms of this Agreement. This Agreement shall be incorporated in but shall not merge into any such judgment or decree of final divorce, but shall be incorporated for the purposes of enforcement only. 1 O. VOLUNTARY EXECUTION: The provisions of this Agreement and their legal effect have been fully explained to the parties by their respective counsel, and each party acknowledges that the Agreement is fair and equitable, that it is being entered into voluntarily, with full knowledge of the assets of both parties, and that it is not the result of any duress or undue influence. The parties acknowledge that they have been furnished with all information relating to the financial affairs of the other which has been requested by each of them or by their respective counsel. " 4 - 11. APPLICABLE LAW: This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania. 12. AGREEMENT BINDING ON HEIRS: This Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective heirs, executors, administrators, successors, and assigns. IN WITNESS WHEREOF, the parties hereto have set their Hands and Seals the day and year first above written. ~~ J1: ~ g~ Q.g~~~ David Alan Dreese (SEAL) ~d- ~c/ ~OOcJ (I~ U-Ju~MA~ Cry tal Walkden Dreese " 5 " ~. < ~'" " '~"',~.L,,-,~'''''~''~.''';."'''F" ,",,",w ,~,.,~,,~~"".~'''''''''''-~ ..",,,,,~', C-'".", ~ ". COMMONWEALTH OF PENNSYLVANIA COUNTY OF JJilli.ph ;n ) ( ) SS: On this, the I~ day of , 2000, before me, a Notary Public, the undersigned officer, personall appeared David Alan Dreese, known to me (or satisfactorily proven) to be the person whose name is subscribed to the foregoing Agreement and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. NoIarlalSeaJ M~.~ MvCommlsllVn=July2,2CJ01 Member, ~jl_ i ...,_..... ~ It). <.0 AO/JCCL Notary Pu I c -J (SEAL) STATE OF IOWA 4IL SS: COUNTY OF ::;?,ed On this, the J day of , 2000, before me, a Notary Public, the undersigned officer, pers lIy appeared Crystal Walkden Dreese, known to me (or satisfactorily proven) to be the person whose name is subscribed to the foregoing Agreement and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. ~.!-o~ (SEAL) 28209.1 iJ" Ii 'l' . . o. DEBRA s. CARMODY MY COMMISSION EXPIRES January27,2lIOl - 6 - ~ >- ~ lJ.,Q 96 G: ....' ~,.;:- ~;~) fr.:~:i ~:: lL.. p ('") >- I- :z: ::)<( <::)~" ().....~ ~i... .~~~ ..)2 cr: :7 L~lU {2!CL. .2: ':'J U .-k~~ Q. r-. >- ",,' ~ C) o N !i2 ~ ~ ~ ~f-I ~ <:Ilffi " cl/;l~ :; C"'",'7 ~f-t~~M ~~><:~1' ~!l::O",;1; ~~~ffi~ ;S !;: p.; "'. E <~ ~ ~- '" ~~ ~ ~ .. .. A/6 ~ ;)O()D, - 3foy ai / "T"":'I , ~~ DAVID ALAN DREESE, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000-364 CIVIL CIVIL ACTION - LAW IN DIVORCE CRYSTAL WAlKDEN DREESE, Defendant 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: certified mail, January 28, 2000. 3. Date of execution of the affidavit of consent and waiver required by Section 3301 (c) of the Divorce Code: by plaintiff: by defendant: May 16, 2000 May 3, 2000 4. Related claims pending: None Dated:;:; -/6 -(/D 0/{;& ~ Dennis R. S~affer n Attorney for Plaintiff 28724.1 (") ~ ~J~' n"Iq-~ :s~:U "r- e15 ;p;. rs,"?:,' ~~"--' -~ :;:C) $0 c: ? ~ w o a ::r )::::tt -< o " :;:1 Ni]J B~m o .-~.! :r: -rt 0- -;''7(') Om ~ -:; .~ -u 3; ,. ., 0' . ~,"-- '"""'''~"",'','. ".=",',','""," '0". _'~."'.""~~"~I",,--;' 1"'-",".,,''',;' -1 ~o-,,_', DAVID ALAN DREESE, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. rAhro- 3t;L/ ~ CRYSTAL W AUillEN DREESE, Defendant : CIVIL ACTION - LAW : IN DIVORCE 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, 1 Courthouse Square, Carlisle, Pennsylvania 17013. '-.,. ;.) IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A 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 TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Lawyer Referral Service c/o COURT ADMINISTRATOR th 4 Floor, Cumberland County Courthouse One Courthouse Square Carlisle, P A 17013 By: Dated: /__)?_ od Dennis R. eaffer / Attorney LD. #39182 111 North Front Street Harrisburg, P A 17108-0889 (717) 234-4121 Attorney for Plaintiff >->, v" " '..J:.O , ., ",'.j.'O ',~ ,;""~~'""'!'" ,,~" i:, ;;1\, ,.;;' ",,;, , ',"",^J;';' " .-' ,')" -<, <~. '.__ DAVID ALAN DREESE, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ; NO. clJ-o-tJ - 3{,,'f ~ I~ CRYSTAL WAI..KDENDREESE, Defendant : CIVIL ACTION - LAW : IN DIVORCE COUNT I COMPLAINT UNDER SECTION 3301 (e) OR 3301 (d) OF THE DIVORCE CODE 1. Plaintiff is David Alan Dreese, an adult individual who is sui juris and resides at 61 Sharon Road, Enola, Cumberland County, Pennsylvania. 2. Defendant is Crystal Walkden Dreese, an adult individual who is sui juris and resides at 2337 Heatherwood Drive, West Des Moines, Iowa. 3. Plaintiff has been a bona fide resident in the Commonwealth of Pennsylvania for at least six (6) months inunediately previous to the filing of this Complaint. Defendant has resided in West Des Moines, Towa, since September 1995. 4. Virginia. The Plaintiff and Defendant were married on April 29, 1995, in Winchester, 5. The parties have no children from their marriage. 6. There have been no prior actions of divorce or for annulment between the parties. 7. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. 8. its Allies. The Defendant is not a member of the Armed Services of the United States or any of if 9. The Plaintiff avers that the marriage is irretrievably broken. 10. After ninety (90) days have elapsed from the date of the filing of this Complaint, Plaintiff intends to file an Affidavit consenting to a divorce. Plaintiff believes that Defendant will also file such an Affidavit. 11. The parties separated on December 25,1995. They have continuously maintained separate homes since that time, said time being in excess of two (2) years. COUNT II CLAIM FOR EOIDTABLE DISTRIBUTION OF MARITAL PROPERTY UNDER THE DIVORCE CODE 12. Plaintiff and Defendant are the owners of various items of personal property, furniture and household furnishings which may be subject to equitable distribution by this Court. 13. Plaintiff and Defendant are the owners of various motor vehicles, bank accounts, investments, insurance policies and retirement benefits which may be subject to equitable distribution by this Court. WHEREFORE, Plaintiff requests the Court to enter a Decree: a. Dissolving the marriage between Plaintiff and Defendant; b. Equitably distribution all property owned by the parties hereto; c. In the event that a written Separation Agreement is reached between the parties hereto prior to the time of hearing on this Complaint, Plaintiff respectfully requests that pursuant to ~304(a)(l) and (4) and ~401(b) ofthe Dated: 22748.1 ". - ~ ., ~,' ". . , . >: ,',.' '. ".,;;,' ~'~~""",;, _ .."",IJ.,," ',;,,";. , Divorce Code the Court approve and incorporate, but not merge such Agreement in the Final Divorce Decree. d. For such further relief as the Court may determine equitable and just. Respectfully submitted, TUCKER ARENSBERG & SWARTZ By: Q)f~ Dennis R. Saffer Attorney LD. #39182 111 North Front Street P.O. Box 889 lIarrisburg,PJ\ 17108-0889 (717) 234-4121 J~)?oV Attorney for Plaintiff ~._, , _. " ,"'. .. J' "-,'~,C~";':,, "."- '" "'c. ',,' -"L<< ,~.. VERIFICATION I, the undersigned, DAVID ALAN DREESE, do hereby certify that I am the Plaintiff in the foregoing action, and that the statements made in the foregoing COMPLAINT IN DIVORCE are true and correct to the best of my knowledge, information and belief. I understand that any false statements made to this verification are subject to the penalties of 18 Pa. C.S.A. g4904, relating to unsworn falsification to authorities. DATE: - L, - 00 Q~~q~ DAVID ALAN DREESE .~ ~~ "'10!i,lli7REV,&al) ~OFPENNSYlI,lll.NIA ~OFHEoIIn< . mALf\EOOROS RECORD OF DIVORCE OR ANNULMENT (XI (CHECK ONE) 0 STATE AlE HUMBER COUNTY \ CUMBERLAND STATE FIlE DATE 1. NAME (FI<sQ DAVID HUSBAND IMiddle) ALAN DREESE City. Boro, or lWp. County Enola Cumberland (WQ (Month) (Day) MIa, (SIa"",;:'..,,,,,,,",' "'49 PA 2 6. RACE WHITE l!l BLACK o 2. DATE 'OF BIRTH 8 4. PlACE OF... BIRTH 7. USUAL OCCUPA.TlON StaIB 3. RESIDENCE 61 St'"' or R.D. Sharon Rd. PA 5. NUMBER OF THIS MARRIAGE: OlliER(Soeclfy! o WIFE Clerk II 8. MAIDEN NAME (FInQ IMiddfo) (W1J 9, DAll' (M<<I'h) (Day) "'., MARIE WALKDEN Of 10 24 60 CRYSTAL BIRTH ,.. RESIDENCE StrHI CK R.D, Clty.8oto.Oflllp. County SI<'a 11. PUCE (StaIB or ForeIgn Counlry) 2337 Heatherwood Dr. West Des 'Moines IOWA Of PA BIRlli ... NUMBER 6. RACE 1.. USUAl ocCuPA'l'1ON OfllilS 1 WHITE BlACK OlliEl1_ MARRIAGE IlD 0 0 Secretary 15. PlACE Of (Cormty) (Stale CK Foreign CountfyJ '6. DATE Of (I.lOl1/h) (Day) trea~ lIilS Virginia -rnlS 4 29 95 MARRIAGE MARRIAGE 11..... ttlltmERot= 116, NUtmER,OF OEPENOENT 16. PWII11ff 19, 0E<:l\EE GlWfTEO l\) CHILDREN THIS CHILD~EN UNDER 18 HUSBAND WIFE OTHEA(SpecIfy) HllSBAND WIFE OTHER (Specify) MAAAlAGE 0 0 l2J (2] l2J O! 0 0 20, NUMBER OF HUSBAND WIFE SPLIT CUSlOOV OlliER(Soeclfy! 21. LEGAL GROUNDS FOR CHIlDREN l\) [Q] Ul \[] 0 DM)f\CE OR ANNULMENT CUSlOOV OF 3301(c) - 3301(d) 22. O,6,TE OF DECREE (MOlIth) (Day) (\IIa~ TOO' DATE REPORT SENT I-'h) (Day) (Year; 10 VfTAL RECORDS 2.(, SIGNATURE OF TRANSCRIBING CLERK \..- - 1,~L>i , . uti ' , " > '''" ~ ~ s~ n en '" C . ~ ~ ~ ~;,,~~ . V J~9 Z N tl:l;ll'" t~~ogJ . ~~gg~::c "'",0 ::; ;p.o ::; >-1'" '" ~ 6 '" '" '" ~ ~~~ ~ ~ ~ tN< -- xN 6, \ ~ ~ G., ~ ~ ~ J :1\\ ~ ~J\4 ? ~ ~ (") 0 0 C 0 5.: 1'1 <.- -0 Cr' :';t;~ rnhl ~~ :.TI Z::;:) ..,,,- r..' ZS;- N ~'l~?) (f) "'. 0 -=<,.:,::., ~O -0 ~O =c=1=i ::;: 95 J;2 r:-: (sm ~ =-' 0 ~ Q '". "," . "".~, " .--,,"' . .7" ,',',~'" .~'~ " , "'''',-" . It . ~ DAVID ALAN DREESE, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA v. NO. 2000 - 364 Civil CRYSTAL W ALKDEN DREESE,: Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) ) SS: COUNTY OF DAUPHIN ) +i.. AND NOW, this :2.::; day of Hhl€ Ct/f~ 7 ,2000, personally appeared before me, a Notary Public in and for the aforesaid Commonwealth and County, Paula 1. Beiter, legal secretary to Dennis R. Sheaffer, who being duly sworn according to law, deposes and says that on January 25, 2000, she mailed a certified copy of a Complaint in Divorce, by certified mail no. Z 398 269 613, restricted delivery, return receipt requested, to Crystal Walkden Dreese, 2337 Heatherwood Drive, West Des Moines, IA 50265, and the same was received by her on January 28, 2000 as indicated by the return receipt card which is attached hereto. r?~ cr. 13~ Paula 1. Beiter rl Sworn to and sublSri,b/d be~is .i!in:::day of f ,2000. ~)-, KL Notary Public NoIari8I Seal C8lhleen A. Kohr, NolafY Public Hanlsburg, Dauphin County My OommlsslOf1 Expires Feb. 7, 2004 MImbBr. FennsyIV8I1Ia A8SClCIaIIDn 01 NotIIiIa (SEAL) , , T Z 3 "HI 269 613 US Postal Service Receipt for Certified Mail No Insurance COverage Provided Do not use for International Mail (See reverse) ~ntto Crystal W. Dreese s. ~reet & Number 337 Heatherwood Dr. Post OIIice, State~ ZIP Code IA 502 W. Des oines, . $ Postage .55 Certified Fee 1. 40 Special Delivery Fee Restricted Delivery Fee 2.75 '" '" Return Receipt Showing to 1. 25 '" ~ Whom & Dale Delivered ~ R,Ium ReceiptSholling"IWlam, Date,&Addr,"""sAddress 0 TOTAL Postage & Fees $ 5.75 0 CO .., Postmark or Date E 0 01/25/00 11. Ul Q. " , " ~ SE':: ' ,. ~' -~ "0 . C6*it. ,",~ms 1 pl!lle'r.2 ror aaeltional services. -: : ~~~='=: ~:~~&n the revers~ 6fthiS form so that we can return this e carcj.to,you. 1: . Attach this forl1),to.,tt;tE}.Jront of the mailpiece, or on the back if space does not G) permit. ... . Write "Return Receipt Requested" on the mailpiece ,lWlOw the article number. . The Return Receipt will show to whom the article was 'delivered and the date delivered. - 3. Article Addressed to: co' ,~.' , 5 1 also wish to receive the following servIces (for an extra fee): 1. 0 Addressee's Address 2.1iII.RestriCled Delivery Consult postmaster for fee. 4a. Article Number Z 398-269-613 " .c ~ t: o ." S t MS. CR1;"STAL WALKDEN DRRES ~ 2337 HRATHERWOOD DRIVE WEST DES M9INES, IA 5026 , 4b. Service Type o Registered o Express Mail Ql!iRetorn Rsceipl f 7. Date of Delivery -;2 8. Addressee's Address and fee is paid) ~ ';' J , 0: ~ ::l g, "!Q'-- 6, 8~ature: (. dr "'111 ' ,i " ^i' . PEl Fofm , Deo:ember 19M - ()I: Certified o Insured , OCaD ',. <T 0" ,_..,,/, ",.,.",,',; ~"."",d<-L, -u n"l 7.: &1 ~::: ~-.. l>,<.. ~~, . ?~r' j;:(~ , -< ,,',;" ",C, .~ t.) o --.j'! -" :t"q ~:::"J !~'. -'1"1 r....' \.D ''=J "T) N '~.) (,:;:> iiIf. - C' "<"" '.""-".', ..'c' :..", " 1 ~ l , i , ~ cI ! " 8 ! , , .; rI ~ '. .. ;J -. DAVID ALAN DREESE, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000-364 CIVIL CRYSTAL WALKDEN DREESE, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on January 20, 2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a final Decree in Divorce. 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 verify that the statements made in this affidavit are true and correct. understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 94904 relating to unsworn falsification to authorities. Date:5-tC,- 00 gJ Q .Q9~~ David Alan Dreese, Plaintiff . S.S. No. ~\O - y D-Yl.t.J,(,p i"" '-',~~, ~ .,=,,~"--, " ">,,,;,', '" .. ~,"~ __ ,-,"'0 '~- ,~, " ,: . , " -- . . . (') c <.? vcr rn fT; 2::0 ~;;;: -s~, f___"-._: ~Q >"c 2: ---j -< ." " ~ o o 3: "'" -< o -'"' '-I ..l-~ i;~lp "nm t56 ~.::1, ...; -:!J ;;:0 orn 'c;! ::n -< -.J L1 w '~',.,,' ~, " '",,;, ,;;"' -I , "-. i. ., ~ 11 .;t DAVID ALAN DREESE, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000-364 CIVIL v. CRYSTAL WALKDEN DREESE, Defendant CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 (c) OF 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. Section 4904 relating to unsworn falsification to authorities. Date: 5 -{c,- ()O 9.-1. ~g(lOt--.l David Alan Dreese, Plaintiff ,,'..' ""j,j I I , I I I ,'"-,'"" ...." L .. ,'-L .. , . C) ~- ~ "1:'J([] fTlrn ~~ GO ''-. S:C) ~O Pc z: =2 a co :,1': 'l~ ::.:: o -n ::::1 ;~il?J '''om "'D i,'},J., ---'~ ::.c -rl 0- 2:0 Om :;j ~ -.J -u -:i. w ,'. "'., "",:, .~,. "[', '. ,~' ,,--" -.". - , j 0, ".. . . "9 , DAVID ALAN DREESE, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY , PENNSYLVANIA NO. 2000-364 CIVIL CRYSTAL WALKDEN DREESE, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on January 20, 2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a final Decree in Divorce. 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 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. 94904 relating to unsworn falsification to authorities. Date: ~d 3/ dccc) ~~f!tMY~/ IJ~ Crys a Walkden Dreese, Defendant S.S. No. (,/7"1- 90 -Oi<3lc9o ,ti .. 6: . 11. ~ Q <- -065 ITlr-,--; Z:n ~~:: ~C ,';;-"'; ~ 7. C ""-0 >c z ~ -< <::> o ::l!: > -< o -n '-i ~T~ :n "'f- .o,:;rn '.q ~~(:, "'~~ Ii- ~):u ''==Y() Om j;! Xl -< -.J -u ::u: (..,:! -.'--' ,,' , ,-. '-" ..~. 1.:..'__ ' "C' " ".' ~'" --" ~.," '_:1 v, . . ~ " ..- ~ .# DAVID ALAN DREESE, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000-364 CIVIL CRYSTAL WALKDEN DREESE, Defendant CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF 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. Section 4904 relating to unsworn falsification to authorities. Date: ~ 3{ dOOO ~JJ [eJdJY~tY~ Crystal Walkden Dreese, Defendant 4. .. . " e,_ ",~ Q , , "" ""= ", ,'" ,""~r~ ~,P,'_"" ~.,~ .. ~ "" .. ~-~ .'" ~ . ,. 0 0 0 c 0 " ~:: :x :.::i uce :0- c'i,::rJ fTlfT? -< L. f- ?: :n :',Q8 Zr S? ~~~: .-J ;') I "-10 ~o v c-r, r..) :u ~C) -~ 20 ::"==C) Qm Pc .. ~ Z -l -< eN -<