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HomeMy WebLinkAbout00-00569 " . .. . . ... . . ; 0- "';,l,,. " I iF. ;F.'" ;F. ;F. Of. '" . ... :f.;F. ;F.;!iif.:f. ;F. ;F. if. if. Of. Of. ;ti;ti;F.;F. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY . . STATE OF . . nORIS J. NEGLEY, . . Plaintiff . . . VERSUS GARY C. NEGLEY, . Defendant . . . PENNA. No. 00-569 CIVIL TERM DECREE IN DIVORCE . . . . . ,t(: ~;p~~ ~ . . AND NOW, JUNE jJ) 2000 , iT is ORDERED AND . . . DECREED THAT DORIS J. NEGLEY , PLAINTiFF, AND GARY C. NEGLEY , 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; . . . . NONE. . . . . . . . . . . . a. . J. < ~~ROTHONOTARY . . ;F.;F. "''''Of. "'iF. iF. iF. iF. :f.:f. iF. . . . ff. :f.:f.;F.;F.w."" . . " . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ~ '01 ' " , , " , lIi~ ~~. .' , ~'/.2-aJ M-~ ~ -$4 ~ v'/<2z:P~ ~ ~ ~~- - '""-, "" - -~ ~ -- ._~ ~-' ,'''-''"~ ,~,~,~--,~ '"", ^- ,_,__>:_,.MJltlI ,j . , C'-CUe,,",,<" ."" . " . "','''- _c__; -,',-- ~:'O"" "~I" "'~-:'"""- ",- !&W' HAROLD S. IRWIN, III SUPREME COURT ID NO 29920 35 EAST HIGH STREET, SUITE 201/202 CARLISLE PA 17013 (717) 243.6090 DORIS .I. NEGLEY, Plaintiff = IN THE COURT OF COMMON PLEAS OF = CUMBERLAND COUNTY, PENNSYLVANIA v. = CIVIL ACTION. LAW = NO. 00 - 0569 CIVIL TERM GARY C. NEGLEY, . . Defendant = IN DIVORCE PRAECIPE TO TRANSMIT RECORD Please 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: On or about February 5, 2000 defendant was served by certified mail, restricted delivery, with a copy of the divorce complaint. See Affidavit of Service filed by plaintiffs counsel. 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 the plaintiff: May.22., 2000 By the defendant: May ~'Z/,2000 (b)(1) Date of execution of the affidavit required by Section 3301 (d) of the Divorce Code: N/A ; and (2) Date of filing and service of the plaintiffs affidavit upon the defendant: N/A 4. Related claims pending: None. 5. Complete either (a) or (b): (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: N/A (b) Date plainti1f.~ VVaiver of Notice in Section 3301 (c) Divorce was filed with the Prothonotary: ~ 2000 Date defenda~er of Notice in Section 3301 (c) Divorce was filed with the Prothonotary: _"'2.;-2000 .14--2- ~_, 2000 HAROLD S. IRWIN, I ,ESQU RE Attorney for Plaintiff n <:;) 0 c: 0 ., "U~ 1::: ,.::J ffirn ;;Z i-!1;::: Z:tl 2'C- I ;Ef r;9 ~-'" 1'0 Z '::::::;.() ~t;, -0 6l""'J". -'- -1'1 ~o ~ ~.o >0 - ''',en '0 ~ " ~ 'W <D ---:-"""~- _~~-~~-'~':V ---~----~------~-~----- -- --- - --- -_..._--.."._.,=--~~~~~ --""'= ,.c..~_----....~~~:~~........~~~~~~~~~~:;:-~~==---~=::="t.=-~7:~O-=~'f[~~_t~~f~ :1_ j",. 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',".';"tC - , ~ .- '~ ~~~~- ~ fJ ~::l..~c ;~ Q -1- P< ~~~-:~---=:: ~--~ ~ ~- a- _ un = S!< - :-:: I Ii: '~-"" : Q!', ;,,' . tS'~'-~~c:-- ~ ::;:--- ... .. ..--..lir. ....'''. 9> .._};!~=c:: ~..... R;,.-. .'...."l!. .... ........'.~'..c.......l.... ~..ILti.i ~_~.tJ. ... ~..~cc.~ ~. . - '" .,. "". .... C '" "l ur un ~~~-illl-__ ;:;$" -- <<t ....' 4 f? .:.;.:...::.. ~ ~ .~--t~-~l-- . . ~.-.-=- ------ --i>1,-. ----'....~ - --- ----- -~ -'~~ -~Rl;1l_,JJ-~ .--~ TRWINIlI "-,,, ,,' " ':, "~ ", ;""",^-~~ .-'~ ~'--, ""'_"';~'l__'~'';;~': -- '-' "-~t '~,.- ,."-,, !'Z..I HAROLD S. IRWIN, III, ESQUIRE ATTORNEY ID NO. 29920 35 EAST HIGH STREET CARLISLE PA 17013 (717) 243-6090 ATTORNEY FOR PLAINTIFF DORIS .J. NEGLEY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION. LAW : NO. 00. Sc.. <; CIVIL TERM GARY C. NEGLEY, : Defendant : IN DIVORCE NOTICE 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 in 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 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, Cumberland County Courthouse, 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 Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 ".-_ ,-.1'- ",__..",_,o_~"" ",-<","-,~c." ~__, ~~+ :-- ~ 'it,:; DORIS .J. NEGLEY, Plaintiff ; IN THE COURT OF COMMON PLEAS OF ; CUMBERLAND COUNTY, PENNSYLVANIA v. ; CIVIL ACTION. LAW ; NO. 00 - St. '1 CIVIL TERM GARY C. NEGLEY, Defendant ; IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301~ OF THE DIVORCE CODE NOW, comes the plaintiff, by her attorney, Harold S. Irwin, III, Esquire, and files this complaint in divorce against the defendant, representing as follows: 1. The plaintiff is Doris J. Negley, an adult individual residing at 7 North high Street, Newville, Cumberland County, Pennsylvania 17241. 2. The defendant is Gary C. Negley, an adult individual residing at 7 North High Street, Newville, Cumberland County, Pennsylvania 17013. 3. The parties have been residents of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The plaintiff and the defendant were married on July 31, 1971, in Shippensburg, Pennsylvania. ~--" 'L.. '. '^-~ ",. ' , "~~c'HJ~'" "--1-'-,:- ,""I 5. Pursuant to the Divorce Code, Section 3301 (c), the plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. 6. The plaintiff avers that he has been advised of the availability of counseling and that she has the right to request that the court require the parties to participate in counseling. WHEREFORE, the plaintiff demands judgment dissolving the marriage between the two parties. I verify that the facts contained herein are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. February 1, 2000 })cndl ~ ~~/y DORIS J. NE LEY, PI . tiff HAROLD S. IRWIN, III Attorney for Plaintiff 35 East High Street Carlisle, Pennsylvania 17013 (717) 243-6090 Supreme Court ID No. 29920 ~' -'~ -- --"~-,"~ -,-----"~ '-",', ,,".' .--, -'-."',- "I """""oiJ!;.' DORIS .J. NEGLEY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : NO. 00 - 6'G, 9 CIVIL TERM GARY C. NEGLEY, Defendant : IN DIVORCE PLAINTIFF"S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. February 1, 2000 flC/1J~#c ?l~~ DORIS J. GLEY ain' FlLED-vICFJCE OF THe r'~CTJ'CNG7ARY DO FES - I /iN 9: 24 G'i' "'''''''''') ", "ITY UI'/'-'.>-:r-';"L,I "I ~ \[ I!.;'; I \liL,....,j .'0-,:.. ,--'V, 1\';, PENI\!SYLV,4NJA , ~ ~, '^ ..,Pc . """":" ," ",' ,~" ~~ -, J "<':""',y '..' "0'" _ _. _ '"ro"" ,.,. ~._~ . '<'".,..,.,____c. ',,-',",," ',-,. -,; o---.f--.,-"'~,_ \."4-"-';; .0<-.-.' .,oE'- ',-','"~ _"_ ><=i'-'- 0_ ~,' .; . .,c,.::".,,,,,,,,,,,,.?, ,. ~:\! ~i ~ ;:: I: !f.: r If: , c I: , I; DORIS d. NEGLEY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA rt' ~, ,I, ~. I, I" " I: I: 1;; I' ~' ~: , ~i " ii I II v. : CIVIL ACTION. LAW : NO. 00 . 0569 CIVIL TERM GARY C. NEGLEY, Defendant : IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301 (c) of the Divorce Code was filed in this matter on or about February 1, 2000 and served upon the defendant on or about February 5, 2000. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the service of the complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the divorce. I verify that the statements made in this affidavit are true and correct. understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. May Zs:'2000 /)01~~ ~f77 DORIS J. NEG EY -4 , ~ ", _0. 1iIiIIAI"""~'" " ,-"~, ~ -" " (") f [Ro:; z9J <::C' cn.!2 ;:$< ~~ 2',.; ::!? :i> 0 ~. C - ::z:; " ~ "-> 00 ""<<, g ~ I N e '" :r (11l!J ::prn _o~ C)y c:;o!O -c.~ 0- :<;0 Orn ?i """ t - < -. , - '0',,"',",. - ,- ~ ' J!ll:i..[l\;;,J r::::::, - "{ . . -' -',' -.r.... -,. ~.-. '. '- . H I, n lr=:-' '. ~ \;8/ u DORIS .J. NEGLEY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : NO. 00 - 0569 CIVIL TERM GARY C. NEGLEY, Defendant : IN DIVORCE DEFENDANT"S AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301 (c) of the Divorce Code was filed in this matter on or about February 1, 2000 and served upon defendant by certified mail on February 5, 2000. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the service of the complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the divorce. I verify that the statements made in this affidavit are true and correct. understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. May 1.. z--; 2000 ~~c_~ GARY C. GLEY -~ "n~ '" 'H "'- '",,-,- :iL-i.> .. ,,,,, ~ ~ (') <::> 0 ~ (::) -n f= ::1 :"lJm t"1i;;g ~gj :;z: 25; I -urn ~/ N ag 0 ;,;:: -0 -~1'i Jg -. 9;;; - (5m .. ~ ~ W CO -< ,.. , .. -- ~.c ~",-~,'v"-",~",-",, "'.' ,',;", "-~-'~"., ,_ .' ,I" , .,kj DORIS .I. NEGLEY, Plaintiff ; IN THE COURT OF COMMON PLEAS OF ; CUMBERLAND COUNTY, PENNSYLVANIA v. ; CIVIL ACTION - LAW ; NO. 00 - 0569 CIVIL TERM GARY C. NEGLEY, Defendant ; IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE JJNDER SECTION 3301 lID OF T"HE DIVOR~E CODj; , 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. May 2.S, 2000 ~/7~ ~ ~ DORIS J. NEGL Y , a :.,,'b--'"-' ~- ~, "Co'_. .',-<" ""--'-'-~,--. ,.. . '0<,'"'"''' u . - [} g 9, :J:J{E ~ !PSJ .~ ::if ~J-' ~. f-ii:J1 ~ I I'-" I'\) '-:P:fJ:l 1"-'0 ~~:J Is ~ S\5 -.:1...... ~!.-:B A!;;' -. SiC') ~ " gf'li t.J Cl:> ~ " , " . IlliIiiiliIIiIii' --.i&h;,'i, ~ -',. --,. - 1 ' \. I' f-"', ~.,,\. el, ,'~. Jj ," " !I~--"'~ I 'I ~~ ~. ". -' "'-'..... ~ DORIS ], NEGLEY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION. LAW : CUSTODYNISITATION GARY C. NEGLEY , Defendant : NO, 00-0569 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 3301(c) OF THE DIVORCE CODE I. 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! 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. ~4904, relating to unsworn falsification to authorities. ....00 Date: ! - 2,..1-- iii l'-~~.!~~~'" "~~, :aIIiiill~''''''''"~ .'l~~. t - ,. ".~~ ''-'''~ \:~7 91 CO) ~ ! 8 0 0 s:: 0 -n ."UOJ C- ..... ~..rn c:: ~r; t1 :::0 Z !11p:= co 5; I -"m N ~u9 .~~ O~ 0 ~. -0 ::to 28 ::r;: cj:D 20 Pc: Om Z ~ =< w CD -< f ,,,,_,, _,. ~,_-~-,-- ~",,_,~, n."_~ ,~ '~",,_ _ ",-' N_ '~,,,.. '-"I ' -',--", Iii!!i!~ DORIS.J. NEGLEY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : NO. 00 - 0569 CIVIL TERM GARY C. NEGLEY, Defendant : IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT The Plaintiff, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage ,counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down. 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. May ~OOO :D~ ~ ~,P ~; DORIS J. NE LEY -' ~"'" c", . ~ - -_t_ 'T_ " C) C) 0 c: <::> -n s: <:... '~ ;j?r.o c:: r-t'i(1l zSf <l:: ;;>'~. I ~Drn (1.;- N :!Jg ;:$0 c-_, ',... , _.-J ~,; <::: -0 ~""'. Po :J<: \:3:n 20 -;....() j;;. 0;11 ~ W ~ :0 OJ -< , ~"', " " " r.___c --=,. , ~ --~. "' , '. '!iIW " ~.: n -, ."..,-/ q , r-'. .~.~ ~~; "' \J '''''''-~~ L. " " DORIS d. NEGLEY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : NO. 00 - 0569 CIVIL TERM GARY C. NEGLEY, Defendant : IN DIVORCE DEFENDANT"S MARRIAGE COUNSELING AFFIDAVIT The defendant, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the \ Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are true and correct. understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. May ~, 2000 ~~EyL ~ Ii '"->~ ~" " ,,",-, (') 0 0 ~ 0 -n :-Offi ?:: ":=j 5grTi :;;e: .-~ir:: ::u :zs; I ~B-? (I;j - N ~"'" Uo :;:::CJ -0 -"f___, ~8 ::JZ ??ii1 Sc: - 0'" ~ " ~ w {l:l -< r: -- ~., , --I~ -~ HAROLD S. IRWIN, III ESQ. ATTORNEY ID NO. 82585 35 EAST HIGH STREET CARLISLE PA 17013 (717) 243-6090 ATTORNEY FOR PLAINTIFF DORIS J. NEGLEY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION. LAW : NO. 00 - 0569 CIVIL TERM GARY C. NEGLEY, Defendant : IN DIVORCE AFFIDAVIT OF SERVICE OF COMPLAINT PURSUANT TO PA. R.C.P. RULE NO. 1920.4 C!ill1lill NOW, Harold S. Irwin, III, Esquire, being duly sworn according to law, does depose and state: 1. That he is a competent adult and attorney for the plaintiff in the above captioned action in divorce. 2. That a certified copy of the complaint in divorce was served upon the defendant on or about February 5, 2000, by certified mail "restricted delivery", addressed to the defendant at 7 North High Street, Newville, PA 17241 (Certified Mail Receipt No. Z 339 062 182). 3. That a copy of the sender's receipt and signed receipt for certified mail is attached hereto. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904, relating to unsworn falsification t authorities. Harold S. Irwi III Attorney for pia February 8, 2000 o Complete items 1 and/or 2 for additional servicli!s. Complete items 3, 4a, and 4b. o Print your name and address on the reveTS9 of this form so thai we can return fhis card .10 you. o Attach this form to the front of the mailpiEiN:e, or on thll back if space does not permit ',' o Write -RetUrn Receipt Requested. on the mailpiec:e below the artlcle number. [j The Return Receipt Will show to whom the article was delivered and the date delivered. 3. Article Addressed to: ~. .. '0 Ui .. .. ~ .. .. .. S ~ \1 g SENDER: I also wish to receive the follow. ing services (for an extra fee): 1. 0 Addressee's Address 2)iCRestriGted Delivery 4a. Article Number 'Z- 3~ q O(o;;l 4b. Service Type ., h-aegislered o Express Mail etum ReceIpt for Merchandise I S;;;2.., )lE:;ertified o Insured DeDD 7. Date of Delivery- -OQ B. Addressee's Address (Only if requested and fee is paid) 102Sgs..ge:,.llI-D223 Domestic Return Receipt PS Form 3800, April 1995 d' ~ U~~ I. .g> n ~ . 3, ~ ~ p.,3 ~ 3 [ .. ~ ~ fI~f ~ .. 0 i!' ~. ~ 0 .. N 0 !!-f~~ ~ ~' .. D j' -< m l,JJ ~ .. f<!' ~~ ;!' ;!' 0" a~' i!' ~ w m f ~D .JI is CJ <:I> II'" 'ru '" '" ru ~'-"-' 'dC'" ,', i t ! " I II: '" .5 ill S '" ~ I .. i_ <<"" -~~~= ~" . ~ ' .' i- ~, o C :.2' -oe6 rnrT1 z::n ~~ ~~ 1:25 J:':n r, " , -'~" CJ o ..." r> o:l \ 0:> -< '~- ,,'0',,",'" ~ -'> -~H .--;;~() ~,ln .::4 ~ :< r"':' 1% ~:.I'_"'m-. .:~~ " , ",: -~-----'- <-"C__ '" ~ ,-'" ~_~. __ ........~.3.::...Ii;; ~..::....~--=:;.::-=.::c.';=,,=~:::~_~.~c!l~,i . :5 . >' \:I '" "'? 3.:: VJ ~ :;:'.:>; ~. !t.C4 ~ tQ ~ ~ . .~. l: '<tlU- 1::: "'-J 'II:( UJ-.I e::: :g. !!l ..~ -~. - -:--. ~- ~. q :>< 1"I<!4 .H<H ..,,-,!~~. . ",' __!'ill! .' tJ..!r. .. ttJi . ..~,. -...~~...." "-~---, ~~-.~d- .._~:.,CcH'" ,< _~r-i . . '(j'i~rr. -;,;;~ o - _n - - - ~ - --~=-~ ---="~- -----=--- ~""~--- -- - -- - --- -- - - -- ~---~---~~~- . --~~-- - _ _ _ _,-,_~'''''~~fE_'"<_7".__:'~'~,",~~~;~~';~~;--; ~~---::-=-~ - """""o~~,;;.__;;~~--~ ~~-- --..;::;<~:--.= -...-- =', ^ ,"---, -.... __ - '''"-~''',k''"'I~--~--' ' - ""--~~j . ' ~---..." O~ll'r ~ - HAROLD S. IRWIN, III, ESQUIRE ATTORNEY ID NO. 29920 35 EAST HIGH STREET CARLISLE PA 17013 (717) 243-6090 ATTORNEY FOR PLAINTIFF DORIS J. NEGLEY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION. LAW : NO. 00. 5t.1 CIVIL TERM GARY C. NEGLEY, Defendant : IN DIVORCE ORDER OF COURT AND NOW, this '3" day of r:JAYJ ' I , , 2000, upon presentation and consideration of the attached stipulation and agreement and upon agreement of the parties, it is hereby ordered and decreed that the attached agreement is made an Order of Court. BY THE COURT, ./ld J. ~ 00 Jt V\~;.OJ ''C. , ~ ",- F!LFD-Or-:-FiCE G,.. "H- ""n]'1 "", '.~,n RY .x :t-:"': i'"';'U .-L.,'i'-j',JI/1i ao ~PR - 3 Ml II: n 7 CUMBErlAND COUNTY PENNSYLVANIA ~,' , 7',._ ~,_ '-'__ . ~ ",-. --,- ,_.I '-. -,--", ''^c , ",,,,,,,,", ""l" '0,:::_" 0'1'_ '~'~,~',;b'~I~"'-'-"" .",. _c",., -~, ^'y _;';"1 DORIS J. NEGLEY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : NO. 00. .s~{..", CIVIL TERM GARY C. NEGLEY, Defendant : IN DIVORCE STIPULATION AND AGREEMENT THIS onpULA TION AND AGREEMENT enterod '''''' lh.~ day of ~f!!!~~ eI' 2000, by and between GARY C. NEGLEY (hereinafter referred to as "Father") and DORIS J. NEGLEY (hereinafter referred to as "Mother"). NOW THIS AGREEMENT WITNESSETH THAT: WHEREAS, the Father and Mother are the natural parents of one (1) minor child, namely, Kevin L. Negley (born October 15, 1987); and WHEREAS, the parties wish to enter into an agreement relative to the custody and partial custody of the child. , ""'.-" ,,-" ,".i_~" ^" -', __ > "'-,,',,,,~,,-~. .'. . 'i>,'.{,.-, ';:-;_,k,.' ~, iiI -- . . ... NOW, THEREFORE, in consideration of the mutual covenants, promises and agreements as hereinafter set forth and intending to be legally bound, the parties hereto agree as follows: 1. The parties shall have joint legal custody of the child. 2. The Mother shall have primary physical custody of the child, subject, however, to the Father's rights of visitation and temporary physical custody at such times as the parties may mutually agree, with the Mother agreeing not to unreasonably withhold her consent to such reasonable, temporary physical custody. 3. The parties agree to cooperate fully to coordinate these temporary physical custody times as well as to share holiday time and vacation time, and to consider the schedule and other activities of the child. 4. The parties will keep each other advised immediately relative to any emergencies concerning the child and shall further take any necessary steps to ensure that the health, welfare and weUbeing.of the child is protected. 5. The parties shall do nothing that may estrange the child from the other parent or injure the opinion of the child as to the other parent or which may hamper the free and natural development of the child's love or affection for the other parent. 6. Any modification or waiver of any of the provisions of this agreement shall be effective only if made in writing and only if executed with the same formality of this agreement. ..J """-- ,,- --~- , ,"'- .'" .', ,,~, ,-~~ .,"-.-'1'",..;--," ,'.:c~ '-. ~ ,"" ~~'!iBl " ~ . -','" 7. The parties agree that in making this agreement there has been no fraud, concealment, overreaching, coercion or other unfair dealing on the part of the other. 8. The parties desire that this agreement be made an order of Court through the Court of Common Pleas of Cumberland County, and further acknowledge that the Court of Common Pleas of Cumberland County has jurisdiction over the issue of custody of the parties' minor child and shall retain such jurisdiction should circumstances change and either party desire further or require further modification of said Order. IN WITNESS WHEREOF, the parties hereto, intending to be legally bound by the terms hereof, set their hands and seals the day and year herein set forth. i~~~ Date:3/3/ (X) ---H~ C r ~(SEAL) GARY C. NEGLEY Date: 3/Zf!{)() U ' 8E~j DO~. GLEY U) (SEAL) " ,- ~, ,,"-' .<~--" .-"_. " , '-q)~ -"-,-,'-0,0-, ".:.Jj ! ",.' ...,...... "' COMMONWEALTH OF PENNSYLVANIA :SS: COUNTY OF CUMBERLAND PERSONALLY APPEARED BEFORE ME, a notary public for Cumberland County, Pennsylvania, this M day of ~, 2000, GARY S. NEGLEY, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within agreement, and acknowledge. that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. Nowial Seal Heather L. Smith, Notary Public Carlisle Bora, Cumberland County My Commission Expires Apr, 7, 2003 em er, Pennsylvan a ssoc a ion of Notaries ~x.~ Notary Public COMMONWEALTH OF PENNSYLVANIA :SS: COUNTY OF CUMBERLAND PERSONALLY APPEARED BEFORE ME, a notary public for Cumberland ~~. County, Pennsylvania, this ?{f 7" day of F: , 2000, DORIS J. NEGLEY, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within agreement, and acknowledge that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal.