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HomeMy WebLinkAbout00-01486 -w." .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. - -- "~- " ," .. " .. .... .. .. .. .. .. .. .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. MARTIN J. NAGY, Plaintiff No. 2000 - 1486 CIVIL VERSUS' DOROTHY J. NAGY, Defendant DECREE IN DIVORCE AND NOW, 1c-.. , 2000 , IT IS ORDERED AND t..$'" DECREED THAT MARTIN J. NAGY , PLAINTIFF, AND DOROTHY J, NAGY , 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 BEE':N ENTERED; The Marriage Settlement Agrement dated March 8, 2000 is hereby incorporated inti this Decree in Divorce. By THE COURT: ArrmjJ&h~ J, PROTHONOTARY .. :t::t: :t: :t: Of. .. .. .. .. .. - ~ ., ~ .~. , -:,~I " " ,-- -~,- ...... .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. IIIiiIII1IMIir.J. . '1IlIilM1 .~~ I" ~,~~~_ -~l!il"""'~"' - ~ ;;)(/'.(}O (p , cZl.a::J ~~~~"__~, ,,~, c", e ~ ,M' . .',' . ..' ..... ". .1 -""""',-,,- .. , ;'."~ ':. ;:~ ' ~~, " {}p/o ~ /IA~( ~ 4 ~ 7lRW ~ -?j; 1fI'- ~ ". - -, -,~ , "-~ ~ ~ - . MARRIAGE SETTLEMENT AGREEMENT THIS AGREEMENT made this 1 day of f'Yl1lt'Ze.h r 2000 r by and between Martin J. NagYr (hereinafter referred to as "Husband") and Dorothy J. Nagy, (hereinafter referred to as "Wife"). WITNESSETH: WHEREAS, the Husband and Wife were lawfully married on May 28, 1983; and WHEREAS, differences have arisen between Husband and Wife in consequence of which they intend to live apart from each other; and WHEREAS, two children were born of this marriage, Kirsten June Nagy, born on March 19r 1987 and Ke1si Jo NagYr born December 11r 1989; and WHEREAS, Husband and Wife desire to settle and determine their rights and obligations; and NOW, THEREFORE, the parties intending to be legally bound hereby do covenant 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 party at such place or places as he or she may from time to time choose or deem fit. The foregoing provisions shall not be taken as an admission on the part of either party as to the lawfulness or unlawfulness of the causes leading to their living apart. 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 maybe necessary to carry out the provisions of the agreement. Neither party shall molest the other nor attempt to endeavor to molest the other, nor compel the other to cohabit with the other, or in any way harass or malign the otherr nor in any way interfere with the peaceful existence, separate and apart from the otherr and each party hereto completely understand and agree that neither shall do nor say anything to the children of the parties at any time which might in any way influence the children adversely against the other party, 1 "1ilI'!1lI '~ ,'", , ." -<" ~" . ,-1'" . , ---, , 3. DIVISION OF PERSONAL PROPERTY The parties have agreed to divide between them and already have divided between them to their mutual satisfaction the personal affects, household furniture and furnishings and all other articles of personal property which heretofore have been used by them in common. Neither party will make any claim to any such items which are now in the possession or under the control of the other, 4 . AUTOMOBILES The Wife is the driver of a leased Chevrolet Blazer, The Blazer lease expires on January 1, 2002. The lease shall remain in the name of Husband and Wife with Wife listed as the primary driver. Husband shall make the monthly lease payments and pay the insurance premium in leu of any child support obligation. Wife shall be responsible for all maintenance and repairs related to the Blazer. Wife shall be responsible for any balloon or charges at the end of the lease. If Wife elects to terminate the lease prior to January 1, 2002, Husband shall have no further duty to make any payments related to Wife's Blazer or any other vehicle, Wife agrees to indemnify and hold Husband harmless for all liability and expenses related to the Blazer except the lease payment and vehicle insurance. Husband shall be responsible for all costs, insurancer fees, liens and other expenses related to any vehicle he owns. Husband shall indemnify and hold Wife harmless for all liability and expenses related to his vehicle. 5. DIVISION OF REAL PROPERTY The real estate owned by the parties as tenants by the entireties situated at 437 Virginia Road, Mechanicsburg, Cumberland County, Pennsylvania shall be conveyed in fee simple to the Husband. Husband shall assume full responsibility for all maintenancer taxes and the payment of the existing mortgages and notes. Husband shall indemnify and save Wife harmless from any liability on the accompanying mortgages, notes or other expenses related the former marital home. In the event the house is sold within seven (7) years, Wife shall receive 50% of any proceeds from the sale of the house. If sold after seven (7) yearsr Wife shall receive 33% of the net proceeds of the sale of the former marital residence, Wife shall not be liable for any deficiency related to the sale of the home. From time to time Husband shall make a good faith effort to refinance the former marital home so as to remove Wife's name from the mortgages and notes. 2 ""","l <.-: ,,~~, . ,4--, y,~~ ,_ -'""~;:" "" -'~ , J . 6. PENSION/RETIREMENT Husband and Wife shall maintain their separate pension and/or retirement accounts, if any. Husband relinquishes any and all rights he may have in Wife's pension or retirement accounts and Wife relinquishes any and all rights she may have in Husband's pension or retirement accounts. 7 . MARITAL DEBTS Husband and Wife accumulated joint marital debt during their marriage. Husband shall be responsible for all marital debts solely in his name and Wife shall be responsible for all marital debts solely in her name. Husband agrees to be responsible for the Blazer lease payments and mortgages on the marital home. The joint debts have been equitably divided between the parties such that Husband shall be responsible for the PNC Vehicle Leasing, First USA VISA, First Card VISA, MBNA MASTERCARD and Beneficial debts, Wife shall be responsible for the Discover, CitiBank VISA, providian MASTERCARD and CitiBank MASTERCARD debts. Each party agrees to indemnify and hold the other harmless for their debts pursuant this agreement. Each party shall make reasonable efforts to transfer the joint accounts into an individual account. Neither party shall attempt to discharge a marital debt through bankruptcy. Neither party shall incur new debt on joint accounts, 8. SHARED CUSTODY The parties agree that they shall share legal custody of the children, This means that the parties shall consult with each other regarding the major parenting decisions affecting the children's health, education and welfare. Physical Custody shall be shared contingent upon the work schedule of the parties. 9. CHILD EXPENSES Husband agrees to pay for the children's school and dance expenses. Other major expenses shall be discussed before commitment and the cost shall be shared equally. Wife agrees that Husband shall claim the children as his dependants for tax purposes. Husband agrees to continue to cover the children on his medical insurance so long as it remains available through his employer at a reasonable cost. Husband has the right to change coverage provided the children's primary physician does not change. Husband and Wife agree to equally share the cost of any of the children's medical expenses that are not covered by either parent's insurance. 3 ~~ ,. . 'o,~ c . , ~ .-" 10. SUPPORT/ALIMONY/ALIMONY PENDENTE LITE The parties hereby waive, release, discharge and give up any rights either may have against the other to receive spousal support, alimony pendente lite or alimony. 11. JOINT FILING OF IRS RETURN Husband and Wife agree to file a joint tax return for tax year 1999 and separately in all subsequent years. 12. DIVORCE The parties agree to cooperate with each other in obtaining a final divorce of the marriage under section 3301(c) or(d) of the Divorce code. 13. SUBSEQUENT DIVORCE Nothing herein contained shall be deemed to prevent either of the parties from maintaining a suit for absolute divorce against the other in any jurisdiction based upon any past or future conduct of the other, nor to bar the other from defending any such suit, In the event any such action is instituted or concluded, the parties shall be bound by all of the terms of this agreement. 14 . INCORPORATION INTO DIVORCE DECREE This agreement is to be incorporated into any subsequent Decree in Divorce, 15. CONTINUED COOPERATION The parties agree that they will within fifteen days after the execution of this agreement execute any and all written instruments assignmentsr releases, titles, deeds or notes or other such writings as may be necessary or desirable for the proper effectuation of this agreement. 16. BREACH If either party breaches any provision of this agreement, the other party shall have the right, at his or her election, to sue for damages for such breach, and the party breaching this contract shall be responsible for the payment of legal fees and costs incurred by the other in enforcing their rights under this agreement or for seeking such other remedies or relief as may be available to him or her. 4 . ~'::'?",,"~" <h .,>. .-. "-' "..- ~'. 17 . VOLUNTARY AGREEMENT The provisions of this agreement are fully understood by both parties and each party acknowledges that the agreement is fair and equitable, that it is being entered into voluntarily, and that it is not the result of any duress or undue influence, Each party has had the opportunity to review this agreement and consult with an attorney of their choice. 18 . WAIVER OF CLAIMS AGAINST ESTATES Except as herein otherwise provided, 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, widows allowance, right to take in intestacYr right to take against the will of the other and the right to act as administrator or executor of the other 's estate. 19. BINDING AFFECT This agreement shall be binding upon the parties' heirsr successors and assigns. 20. MODIFICATION AND WAIVER Any modification or waiver of any of the provisions of this agreement shall be effective only if made in writing and executed with the same formalities as this agreement. The failure of either party to insist upon strict performance of any of the provisions of this agreement shall not be construed as a waiver of any subsequent default of the same or similar nature. 21. PRIOR AGREEMENTS It is understood and agreed that any and all prior agreements which may have been made or executed or verbally discussed prior to the date and time of this agreement are null and void and of no affect. 22 . ENTIRE AGREEMENT This agreement contains the entire understanding of the parties and there are no representations, warranties, covenants or undertakings other than those expressly set forth herein. 5 '-,,~ ,..~ ~ ,'-'"'"'_.,,,, "'_"_'",,.' ? ,~_ " _",T<''''''..' ,,~ - -1- 23, DESCRIPTIVE HEADINGS The descriptive headings used herein are for convenience only, They shall not have any binding affect whatsoever in determining the rights or obligations of the parties. 24 . APPLICABLE LAW This agreement shall be construed under the laws of the Commonwealth of Pennsylvania. IN WITNESS WHEREOF, the parties ~~q~ 3/&~()(JO Witness 'Ddte ::~' . Witness set their hands and seals 1l~~.~ Marti J. Na 2-o'Jooo Date _DVlo~J.~ Dor thy J. gy 6 -",'If "--"'. ,. _,,, ,~,_,r' '''_h' , ;1 Commonwealth of Pennsylvania: County of C\t"",b~f<.IIl,.;J ss PERSONALLY APPEARED BEFORE ME, this 'f/ day of this tV! I'frtc..h , 2000, a notary publicr in and for the Commonwealth of Pennsylvania, Martin J, Nagy, known to me (or satisfactorily proven to be) the person whose name is subscribed to the within agreement and acknowledged that he executed the same for the purposes herein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal, ~.",l7A {j, rY/(lAA do':" Nary Public Notarial Seal C Judlth A. Mundis. Notary Public amp Hili Boro. Cumbertand CC'Unty My Commission expires May 10; ~003 Member, Pennsylvanle AHWletlOIl 0/ NOtal1es Commonwealth of Pennsylvania: County of e...""\,4,<.(,q",d ss PERSONALLY APPEARED BEFORE ME, this ~ day of this h7"Jr(cl-, , 2000r a notary publicr in and for the Commonwealth of Pennsylvania, Dorothy J. Nagy, known to me (or satisfactorily proven to be) the person whose name is subscribed to the within agreement and acknowledged that she executed the same for the purposes herein contained, ~~a m{~', Nary Public Notarial Seal eaJUdlth A. Mundis, Notary Public mp HlI/lloro. Cumberland County My Commission Expires May 10,2003 Member, PennsylVania Association of Notaries 7 :-lftlffilill '<,_ ,,,,",!i""""'7", , ~ ,-- " '.' ,~,~ ""; . ~ H ~ " , " - (') c:. 'i? c 0 " <] ~:. iT, ,-- n ) !-+~ , .--, , ~ (~: ' " "'~) '-'I CO L_',' '--=, [-. '.' . ' _.~--) .' ( " )> " " ,'li , ,~ , , .<. "" . '-j :!1 -' n -";" 01 -< , ,',' i:i, ',,1 , - "_ "!.JlIIII".lu.m~ ~~~<_~ ~ ,."! J~lPI4 ~ ~~~I~"~M;!Wtl~~,,~~~~",~~~ [Ji'i~"'~ MARTIN J. NAGY r PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000 -1486 CIVIL TERM DOROTHY J. NAGYr DEFENDANT IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the Court for the 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 March 16, by Acceptance of Service by Defendant. 3, Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: By Plaintiff, June 20, 2000; By Defendant, June 21, 2000. 4. Related claims pending: None 5. Date Plaintiff's Waiver of Notice in ~ 3301(c) divorce was filed with the Prothonotary on June 23, 2000. Date Defendant's Waiver of Notice in ~ 3301(c) divorce was filed with the Prothonotary on June 23r 2000. /h:-l2>. ~_ Thomas D. Gould, Esquire Attorney For Plaintiff .'-gl, "-~ ~-"" -"- T ",",_"",__r~ UUq,~ ","_>' _,~~'" (') <;: 1[" Jf.~ j-;::C:' 3i" ::;j .';? '-..) r "-~ ,",' ,\} c'-"~ ~? "'0'0 (1''1 '0'-1 -~~~~~~I'.1!_IMIIJ{~ '~} ~, _~~~_ < v, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO, 2000 - 1'-1- 8~ CIVIL TERM MARTIN J. NAGY r PLAINTIFF DOROTHY J, NAGY r DEFENDANT 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 pagesr 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 is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Court Administrator 1 s Office, Fourth floorr Cumberland County Courthouse, Hanover and High Streets, Carlisle, Pennsylvania. 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. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 '':~"'Hl ~,' , ._,0,". ~" . . MARTIN J. NAGY, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000 -NPh CIVIL TERM DOROTHY J. NAGY, DEFENDANT IN DIVORCE COMPLAINT UNDER SECTION 3301(0) OR 3301 (d) OF THE DIVORCE CODE IN DIVORCE 1. The Plaintiff is Martin J. Nagy who resides at 437 Virginia Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. The Defendant is Dorothy J. Nagy who resides at 4810 Charles Road, apartment #1, Mechanicsburg, Cumberland County, pennsylvania 17055. 3, The Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint, 4. The Plaintiff and Defendant were married on May 28, 1983 in Cambria County, Pennsylvania. 5, There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7, The Defendant is not a member of the Armed Services of the United States or any of its Allies. ",,,-~. ~ ~ - - r ., - - - ,~, ., .. . 8. The Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 9, Plaintiff requests the court to enter a decree of divorce. tL,,_ 'b. ~ Thomas D. Gould Attorney for Plaintiff LD, if 36508 2 East Main Street Shiremanstown, PA 17011 (717) 731-1461 VERIFICATION I verify that the statements made in this Complaint 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. Date: ,-5 /1~/ :2OtJO / . 7l1~ fl n Martin tt Nag~ 0<""""'1, . ~ ._~__ " ~__ ,'_' ~'., Il, " MARTIN J. NAGY, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000 -1486 CIVIL TERM POROTHY J. NAGY, DEFENDANT IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on March 14, 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 of Divorce after service of notice of intention to request entry of the decree. I acknowledge that pursuant to Rule 1920.42(e) I have waived the requirement that I receive notice of intention to request entry of the decree. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: u~ J.(1~ Doroth J. Na ~.r, "."., .""_'~ r. - ',' "'--_r,"-" ," . ,..,.....~ _^__~=l>t o ~ ,~ ;~ l!f; -~... , , ..c.-:-c-", ;;:::f-:':'-' V~'_.::- rs'i~~' .-'-, j:?l.. ~S~-; ~.-! -< "",,!'Il')!'-".~ :'il\I'j~!fII!\I!~~WI'JI!l!!~~Il'P"'" .;.~- ~.:) :>7 (J] o a L.. C: ;;;:;: o -r; .~j !'-.,) c) ::_~:I --~ ,,.'.,, . , MARTIN J. NAGY, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000 -1486 CIVIL TERM DOROTHY J. NAGY, DEFENDANT IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on March 14,2000. 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 of Divorce after service of notice of intention to request entry of the decree. I acknowledge that pursuant to Rule 1920,42(e) I have waived the requirement that I receive notice of intention to request entry of the decree. I verify that the statements made in this Affidavit are true and correct, I understand that false statements herein are subject to the penalties of 18 Pa. C.S, Section 4904 relating to unsworn falsification to authorities. DATED: r; /o<(} Ie/ON) / / ~~47Z~. ,~IU, .. ,.0 r'r ~"T "~', o. "'. ., """.~.; ,. "'!f!!!I!II~_. ri'i ;~'~-: :;:".'TC 7"'; ta- r::: ~\.; o c ;::::.:.. c::> c ...... "",; o .- .,.:.... r"0 (~ "'Cl C":J :.11 {Ii ~ ~ .. 1~I!O!il!!!II!II!!!! , 0 ~TIN J, NAGY r PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000 -1486 CIVIL TERM DOROTHY J. NAGY, DEFENDANT IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(0) OF THE DIVORCE CODE 1. I consent to the entry of a final decree 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 subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: !JJ )? t1 ktld / / mA~O- n~ Martin JPNagy ;~,~. - " .~ I'" 1'<' l~. . ~~-, ~'"";-'~ 1"""'" 1Il-..~ !II~!II!IIillliflJ o c -otE: p'!rT: :;::~~~ ~:~~. r:::c: ~~~ -y :::4 -<'. C) o , -- o Tl ....( ,.~ -v c...) .'Ti --;."/ (....., ":,:i :D -< ':..n (Y'. _~.~~II1~IJltl!I~~flIim1l!ll~ . . . MARTIN J. NAGY, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v, NO. 2000 -1486 CIVIL TERM DOROTHY J. NAGY, DEFENDANT IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(0) OF THE DIVORCE CODE 1. I consent to the entry of a final decree 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 subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: ::J l.vf\ g ~ l. II 000 , (1n~ J.~ Doroth. J. Na ''lJ~ _ . , , ",I" _$fIo;,~fflt!!llllilJillll! ,_~,1 WJ.I~~WIi~ ~~~ , ' " ""'~'f]1 /lllIl'!IIl~,1iI'J!P'1W'1Q!llI!I~~ -gee 1l1i';"; 2::.-.:.: 6),S~: ....-'''"':,. ~~,' ~~;' ~l , "->c Z =< o C ~: ,~ "~::.~ N (,.;, -.,. -i;. c,,) ?.:i --L--"-' :0 ~; ;:fi en ":11' ~~..$l!!!I!!:!III~~!~'I1!~f'lli~~m ~1!.$; . - J MARTIN J. NAGY, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000 -1486 CIVIL TERM DOROTHY J. NAGY, DEFENDANT IN DIVORCE AFFIDAVIT OF SERVICE I, Thomas D. Gould, attorney for Plaintiff, in the above captioned action for divorcer hereby certify that a conformed and certified copy of the Complaint in Divorce was served upon the Defendant by depositing the same in the United States mail on March 14r 2000 pursuant to Rule 1920,4 of the Amendments to the Pennsylvania Rules of Civil Procedure relating to the Divorce Code, As indicated by the signed Acceptance of Service attached hereto, the Complaint was received by the Defendant on March 16, 2000. 7h-QA D. ~~ Thomas D. Gould ID # 36508 Attorney At Law 2 East Main Street Shiremanstown, PA 17011 (717) 731-1461 !~ ," ~. 111I' ~, ( - . .'" .."."c "_,~,,,.,JII_<"J" .,,"'_ P( UH~~I!!IiIUlMi"'!~ - (") c- oo:::: SS B~~ t~~~ -' " i~, )>~~ .Jrt;~ c::) t~-"" C) "'-1 , ~ ~"".;.. ''0 ~-,) ~'O 1IIIIl... '.-.-""., " .meA,., ,'.. "" . - , MARTIN J. NAGY, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v, NO, 2000 -1486 CIVIL TERM DOROTHY J, NAGY r DEFENDANT IN DIVORCE ACCEPTANCE OF SERVICE I, Dorothy J, Nagy, accept service of the Complaint In Divorce in the above captioned matter. Dated: J1jOr.( ~ f~, ~O()() , l1~ Jf) Dorothy ~, Na::T/ 4810 Charles Road Apt #1 Mechanicsburg, PA 17055 DEFENDANT '0" ~~..,.." ", " " I' _ ~, . , --'...._A. ,,,,,!,,,,, -'~ """'l';',,~tcc q _"'''',,'''~,. -~ ~'~"h 0 Q :;:~ c: a :? ~" :=: ~ [~., n""'j C;,: ::--;:: :z '- ,- " ;.....,) (/) ':C ce:;-. -- r:" "-."" ;t: "'1;'.1 CJ ....::. C) )> ;;.>) ";, ',-- ;?-i ....-- 'j Ul 5:1 -.... (J , -< g~ -" ,,,.,,.,,,,,...,)11I,,,,