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HomeMy WebLinkAbout00-01963 ~ ,,'" f. i -:(,; >::.~(:::~::.~~;:,:::!::.X)3E~::::~::+::-~~:'::,.3t{X+:::(:::!~t:'::!::+>::-:~::+>;1::~::.::>:C~~:)>>~~;;: :,:~::C(:::~3E~;:':~~::.~:;:)::C~~':c:!::+~~;2:::~::+~~:';XC!$*;:{C<*::~:~}$~::C~!~~::+);W!::+~{:~~:+):;::~:<6"">.-::_~~. ii - -~ ~.~ ~ .1 ~~ I] ~.~ I ,~~ ~.~ ~ i ~.~ fA ~~~ ~ ~,.i ~ ~ ;.~~ ~ ~-r~ ~~~ . ~ ,,~ ~~~ ~ ,", N ~ ~~~ . :;'.:~ j '<-.~ ~.'~ ~ ~ k; I ~~; ~ ~.~ ~ ~~; ~ M~ a l".~ h .;'., ~~; . ~:'< ~.~ ~ ~ ~.~ H ~ ?": ~ ,,~ ~ ~ ~ ~ ::~::+::~;: >:+;<::.::+;.'..>::.::( :::-::+;.,;: >::+;~;. )::.::~;,: ::'::+::';::>::+::'..: }::+::~:' ~"': ~ IN THE COURT OF COMMON PLEAS t ~~~ OF CUMBERLAND COUNTY ~.:, ~ ;,,) ~ ;''',; ~~ ~ ~-;; ~.' .' ;:",' PENNA. STATE OF / a p ~ CHRISTOPHER LEE .............u,u..,.,.",,,..,.,,,..,.' I II N o. ,,,..??~,~?~,~ """'''u'''''' 19 ~ ~ Versus ELAINIL,LE,E."....., ,.~ ~ ~.~ ~ ~t ~ ~.~ i ~.~ IN '",,' ~ N i ~.~ DECREE D I V 0 R C E ex ~: ~o f' #I. AND NOW, . .. .~ .~ .~. . .. ., xl 19 i!.o.QQ., it is ordered and decreed that..... .~l!~~!'.~<?~!l~.~ .~~~.........................., plaintiff, and............. ..EJ:.AWE. .~E;E.............................., defendant, are divorced from the bonds of matrimony. . l>l X ~.~ ~ a ~.~ ~~ w n ~ ~ ~.f ~ ,", 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 9<?y.e.~~p:t.s. .l?~:t. .~9~:t.~ .:J.P. .t;i?-<;!. Y'.x::j.t:t~.1'! .~:r.~P.e:";-:tY. .1?~:t.qe:"I,TI~.I'!t:.~5J.:r::e;~I,TI~nt made and entered into by the parties on August 15, 2000 are ' incoL"li>0;rat.ed. .int0. .this. -Dec;:ree .by. .L"efer.ElRce. .thereto,. but. n.ot.... merged into this Decree. h ~ ~ ~~ ;..; ~ ~.~ ~ ~.~ ~ ~.,' t:'<l ~ '.'" ~.~ ~ '" ~.~ ~ a ...~ If M i I Pi ~-(::~.>.,,:::_,:.'.:.... Attest: u~u ~ .' -:+:C{. -::O:C{ :::-::+::( ""::+::':.- .::.::+;~;,: ":.::+:>;,: .::.::+::< )::+::.:: ::~.:.::.:;. ""::.;';;: X.;~'" ):'.::.": ~ .. . ;-~" '. , ~ - ,~" -~- .,-. ',;,,' ~ ~~ i ~ ~.~ ~.~ ~ -,,''; ~ ... ;.~ ~ ~ ~l J. '. ~ \.~ ~ ~.~ ;.~ ~ ~ ... ~ .- . ~ , ;~;;;'~""",i~.' " , .1".......~...~rii.........,_~~.---.,IiIllIiIit~~~. 1iiiiIiiIi.....;.~~ ~~ -~ ~, ,~ _'M,,^",_ ; I...J <~ -'~;..;.. ~ "'.. ~'. "t\!':IIA! :Jh )L,L.JL:!IH .!1l~ " . .IL~...I,.".,.. 9 0?5- Cl? 1'06"-00 - ^.". ~~, - --"." -......'- ., , ~ , ~ ~ ';.; .\... .... u.~~z4 ~ 71~ /U~ ~ ~ ,()~ 1, \ III - . I .., .. . , .....i CHRISTOPHER LEE, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00-1936 CIVIL TERM : CIVIL ACTION - LAW : IN DIVORCE ELAINE LEE, Defendant PROPERTY SETTLEMENT AGREEMENT .'..,..,.. ,,-<- ,-- -~ . I . t "- ' :.. ~< PROPERTY SETTLEMENT AGREEMENT AGREEMENT, Made this IS-- day of , 2000, by and between CHRISTOPHER LEE, hereinafter as "Husband", and ELAINE NISSLEY LEE, hereinafter referred to as WITNESSETH: WHEREAS, Husband and Wife were lawfully married on July 16, 1988; and WHEREAS, no children were born of this 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, fully understand and agree that Husband is represented by Sandra L. Meilton, Esquire and that Wife is represented by Mary A. Etter Dissinger. 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. ~~..."., - .'. ',".~,"""~~~,3~~".'~,"~ ''__"" -"__,_"~,.:,"~",~_,~,,,,_,, .,' ~"~.~"' __~ ~_, ,>>_ ,,__ m, .==' M.~~ " ".. -< - '- . , < <. --...,: 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 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 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, except as follows: Descriotion of Debt Resoonsible Partv Mortgage on 1778 North Meadow Drive, Mechanicsburg, PA 17055 held by York Federal Wife - 2 - I:" -:','> ~ 7 -~" . " '''-,~,?,,,;;,,,r'''f_'O.;'t~om'r', .-,.."'t"!i-~'" . --.- -'-:s'!i'f'~'T~,> ,-",o'~,~,~_":.."m_~_~ :""t'-,',".,_"" 6"-~'-_"_~_ ,,,",,',""'''','''>'''_',', """"_._, ,. "po .!. _~,,....,_"..'.__~.. '._"1'. "",,_, "~-"""",' """ "~""-'M"!_'" _~ _' _ _~_"'~_~"., ",~,"",,_~""'u " , .. ': ----; Personal Loan to Wife's Mother, Ruth Nissley Wife Loan on 1994 Buick Park Avenue held by Belco Husband Husband's credit card debts Husband Belco Visa GM Mastercard Exxon Texaco Sears J.C. Penny's Bon Ton Belco line of credit Belco car loan Wife's credit card debts Wife Member's First Visa Member's Line of Credit Platinum One Visa Boscov's J.C. Penny's Hechts Sears Bon Ton Each party agrees to pay the above referenced debts as indicated and agrees to indemnify and save harmless the other from any and all claims and demands made against either of them by reason of such debts or obligations. In the event that either party contracted or incurred any debts since the date of separation, 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. 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 marital property in accordance with the Divorce Code of 1980. Subject to the - 3 '" , ..,.', ,,'p.' ,'., ... .,d ,,~,",'."n,.... ". '''h''''.. ,.~._ .. ......._,,, ..."., .."n". ....'~, .., ...q"..". ... ..,."' ..... ,'.._. 'n. . ,,-- ~--,_. . <.. '. 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. EQUITABLE DISTRIBUTION OF MARITAL PROPERTY: The parties have attempted to distribute their marital property in a manner which conforms to the criteria set forth in 23 Pa.C.S.A. Section 3501 et. sea., and taking into account the following considerations: the length of the marriage; the fact that it is the first marriage for Husband and the second marriage for Wife, the age, health, station, amount and sources of income, vocational skills, employability, estate, liabilities and needs of each of the parties; the contribution of each party to the education, training or increased earning power of the other party; the opportunity of each party for future acquisitions of capital assets and income; the sources of income of both parties, including but not limited to medical, retirement, insurance or other benefits; the contribution or dissipation of each party in the acquisition, preservation, depreciation or appreciation of the marital property, including the contribution of each spouse as a homemaker; the value of the property set apart to each party; the standard of living of the parties established during the marriage; and the economic circumstances of each party at the time the division of property is to become effective. The division of existing marital property is not intended by the parties to constitute in any way a sale or exchange of assets, and the division is being effected without the introduction of outside funds or other property not constituting marital property. The division of property under this Agreement shall be in full satisfaction of all marital rights of the parties. A. DISTRIBUTION OF PERSONAL PROPERTY: Except as may be otherwise provided herein, 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, except as set forth in Exhibit "A" attached hereto, which items shall be distributed in accordance with Exhibit "A", and this Agreement shall have the - 4 - :.~~- - c __,,_" ~'''''', ,".'"-,""-:,,-'~"f",,,.",,, ,,_~~,;- '. -''''"/,.,,_",, .~ ,>",,<<_, C"_>,.",,<'C .-'. ,. _ ~"_"'''l''''I''__=, ,.. . _"",. _, "" ,',L _G'_' ,",'_"'" ,. ~,_,_ __ 0,,'_" _ ,~"~,, ._, ~_ =_ '0 . ~"- '" 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 (and as set forth in Exhibit "A". 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, or which property will be distributed in accordance with Exhibit "A" attached hereto. 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. Except as may be otherwise provided herein, Husband and Wife shall each be deemed to be in the possession and control of his or her own individual pension or other employee benefit plans or retirement benefits of any nature with the exception of Social Security benefits 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 his/her separate property and any property which is in their 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 acknowledge any deed, mortgage, or other instrument of the other pertaining to such disposition of property. B. DISTRIBUTION OF REAL ESTATE: The parties agree as follows with respect to the marital residence: (1) Husband agrees to transfer to Wife immediately upon the signing of this Agreement, all of his interest in and title to their jointly-owned real estate at 1778 North Meadow Drive, Mechanicsburg, Cumberland County, Pennsylvania, subject to the mortgage given to York Federal in exchange for which - 5 - -_1. ,., c ,~_ .""",",,,,, _.~,,,_c(_><. -"-,"",' _~_",""'.C"~'___"~'"'''"'''_N'_~''''' ~_ ~_"'~ ", ~ _~ _~ "',' ~"-=,~ , (, Wife agrees to be solely responsible for the payment of all future mortgage payments, taxes, insurance and utility bills relative to said real estate. Wife covenants and agrees to pay and discharge the existing mortgage obligation on said premises in accordance with its terms, and agrees to indemnify Husband from any loss by reason of her default in the payment thereof and agrees to save Husband harmless from any future liability with regard thereto. (2) The parties agree that the house shall be listed for sale within three months of the signing of this Agreement and shall remain actively on the market until sold. Wife shall control the sale of the real estate including, but not limited to, the selection of the realtor, the list price and the sale price. Upon the sale of the real estate, Wife shall retain the net proceeds from the sale. Net proceeds shall be defined as the balance remaining of the sale price, less all outstanding mortgages and liens, the debt owed to Ruth Nissley, taxes, realtor's commissions and costs incident to sale. In the event that there are insufficient proceeds from the sale of the marital residence to satisfy the mortgage, the Ruth Nissley debt, and all other expenses owing on the house, Wife shall be responsible for said deficiency and agrees to indemnify Husband from any loss by reason of her default in the payment thereof and agrees to save Husband harmless from any future liability with regard thereto. (3) Until sold, Wife shall have the right to the exclusive use and possession of the marital residence. In return for her right to exclusive possession of the home, she shall be solely responsible for the payment of all debts and obligations noted in paragraphs (1) and (2) above. Wife further covenants and agrees indemnify Husband from any loss by reason of her default in the payment thereof and agrees to save Husband harmless from any future liability with regard thereto. (4) In the event that the marital residence is not sold by July 1, 2002 Wife shall refinance the house to remove Husband's name and in the event of her failure to do so by July 1, 2002 title to the home shall be transferred to Husband. (5) Prior to July 1, 2002 Husband may, at his discretion, require that the house be refinanced on ninety (90) days notice. Upon Husband's request, Wife shall refinance the house. - 6 - -. . ."\",',,..,"';~'~~. ~.~--- - _'''''''~'_''~'_~_~__' .c_"_",_ _.,,_~_.___ _ ,_~ ,_ " ., ~ ",_ _ ,,-,< . . ....= ,,_u ,__~. .=~. ., - --~~ ~--~ "- " C. DEBT TO RUTH NISSLEY: The parties acknowledge that they borrowed money from Wife's mother, Ruth Nissley, and utilized the funds toward the building of the marital residence at 1778 North Meadow Drive, Mechanicsburg, PA. Wife agrees to be solely responsible for the outstanding balance on said debt. Wife covenants and agrees to pay and discharge the obligation to Ruth Nissley in accordance with its terms and agrees to indemnify Husband from any loss by reason of her default in the payment thereof and agrees to save Husband harmless from any future liability thereto. In the event the demand note is called, Wife shall pay the note in full upon demand. D. STOCKS: The parties acknowledge that each have stocks registered in their own name. Each shall retain as his or her separate property the stocks registered in each party's individual name. All joint stocks which were purchased during the marriage have been transferred to the individual name of Husband and/or Wife. Each party shall retain the stocks transferred into their individual name and the other party waives all right, title and interest in said stock. E. TAX LIABILITY: The parties hereby agree and express their intent that any transfer of property pursuant to this Agreement shall be within the scope and applicability of the Deficit Reduction Act of 1984 (hereinafter the "Act"), specifically, the provisions of said Act pertaining to the transfers of property between spouses and former spouses. The parties agree to sign and cause to be filed any elections or other documents required by the Internal Revenue Service to render the Act applicable to the transfers set forth in this Agreement without recognition of gain on such transfer and subject to the carry-over basis provisions of the said Act. 8. PENSION AND RETIREMENT PLAN: The parties acknowledge and agree that each party has a 401 K and IRA (Roth and regular) accounts. As a result of her employment with Capital Blue Cross and Highmark, Wife has a defined benefit plan. - 7 - .'_ ">":;""""._,~_,~c.,,,,!,,,,,>.,,,,,,,~,~,-',,, '. ..0-' <)"'_ ,-,'_,'n.', _,.~ ~o,.~.",x___,~ . _~ _ _ __ "'__,___~ __ ,o~.~_ _ h_~ _~.~_~ -"~ " Husband shall retain his 401 K (Roth and regular) and IRA accounts, and Wife agrees to waive all of her right, title and interest to Husband's 401 K plans and IRA accounts and any other retirement type funds Husband has and to sign any and all documents necessary to enforce this provision. Wife shall retain her 401 K and IRA (Roth and regular) accounts and, her defined benefit plan with her employer, Highmark, and her retirement benefits with Capital Blue Cross. Husband agrees to waive all of his right, title and interest to Wife's pension and any other retirement type funds Wife has and to sign any and all documents necessary to enforce this provision. 9. MOTOR VEHICLES: With respect to the motor vehicles owned by one or both of the parties, they agree as follows: (a) the 1995 Chevrolet mini van shall become the sole and exclusive property of Wife free and clear of all liens and encumbrances; (b) the 1994 Buick Park Avenue shall become the sole and exclusive property of Husband subject to a lien held by Belco. and (c) the titles to the said motor vehicles shall be executed by the parties, if appropriate for effecting transfer as herein provided, on the date of execution of this Agreement and the said executed title shall be delivered to the proper parties on the distribution date. 10. ALIMONY: Both parties acknowledge and agree that the provisions of this Agreement providing for equitable distribution of marital property are fair, adequate and satisfactory to them and are accepted by them in lieu of and in full and final settlement and satisfaction of any claims or demands that either may now or hereafter have against the other for support, maintenance or alimony. Husband and Wife further, voluntarily and intelligently waive and relinquish any right to seek from the other any payment for support or alimony. - 8 - /', '--'~~'''~~'' _. ''''''''';'-'c'-' ,,' 'C'._. --. _".,,~"1 _'~_ .'f,~' '"..."" ,~"",",., .'. '0,' ',..eL ",_'.'.". ."'co,, ,.. .. .0 , ., <- " 11. ALIMONY PENDENTE LITE. COUNSEL FEES. AND EXPENSES: Husband and Wife acknowledge and agree that the provisions of this Agreement providing for the equitable distribution of marital property of the parties are fair, adequate and satisfactory to them. Both parties agree to accept the provisions set forth in this Agreement in lieu of and in full and final settlement and satisfaction of all claims and demands that either may now or hereafter have against the other for alimony pendente lite, counsel fees or expenses or any other provision for their support and maintenance before, during and after the commencement of any proceedings for divorce or annulment between the parties. 12. INCOME TAX PRIOR RETURNS: The parties have heretofore filed joint federal and state tax returns, Both parties agree that in the event any deficiency in federal, state or local income tax is proposed, or any assessment of any such tax is made against either of them, each will indemnify and hold harmless the other from and against any loss or liability for any such tax deficiency or assessment and any interest, penalty and expense incurred in connection therewith. Such tax, interest, penalty or expense shall be paid solely and entirely by the individual who is finally determined to be the cause of the misrepresentations or failures to disclose the nature and extent of his or her separate income on the aforesaid joint returns. 13. YEAR 2000 INCOME TAX RETURNS: The parties shall file separate Federal returns for the year 2000 and thereafter. In the year 2000, Husband shall be entitled to claim the first six month interest paid on the York Federal mortgage on the marital residence. 14. WAIVERS 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, 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 - 9 - or" , ,~"".~,,,'''~--~ ,.-,""'",.,,-.'.-,- "-~,,,,-,"~-,,,,,'-P_'~"-"""--"-~"~' __,_ ~__~_, ~,~- .. - . . " . 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. 15. SUBSEQUENT DIVORCE: Husband has filed a mutual consent no fault divorce pursuant to the terms of 3301 (c) of the divorce code of the Commonwealth of Pennsylvania, and this agreement is contingent upon Husband proceeding with said divorce and Husband filing his affidavit of consent and waiver of notice of intention to request entry of a divorce decree thereto upon the expiration of the waiting period. Said affidavit and waiver shall be promptly transmitted to counsel for the Plaintiff who will immediately file a praecipe to transmit the record, the vital statistics forms and any other documents necessary to precipitate a prompt entry of decree of divorce. A further condition of this Agreement is that Wife shall, upon execution of the Agreement, sign and deliver her consent and waiver to counsel for Husband. H !.-I 11 'I I! !i 'I !i ~I' I, Ii Ii " 16. BREACH AND ENFORCEMENT: 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, or seek such other remedies or relief as may be available to him or her, and the party breaching this Agreement shall be responsible for payment of legal fees and costs incurred by the other in enforcing his or her rights under this Agreement. i' " Ii " i-i LI " i-I :1 17. THIRD PARTY BENEFICIARIES: I I: I,~ i I' Husband and Wife agree that it is not their intention in this Agreement that any other individuals, including their minor children, be third party beneficiaries of this Agreement at this time or at any time in the future. I~ I'. 18. OPPORTUNITY TO OBTAIN ADVICE OF INDEPENDENT TAX COUNSEL OR ACCOUNTANT: " i' , !1 " Both parties acknowledge and agree that they have had the opportunity to retain tax attorneys, accountants, tax advisors, or certified public accountants with reference to the tax implications of this Agreement. 'I :1 - 10 - '~',,"'''' ,~>>"',',' I' "'~, "'.. ..,>, ""'''',~r,.'' 'I' '. ,.", .... ,_" '"_,.,, _' .,.'., - ~-" . 19. 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. 20. 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. Husband and Wife acknowledge and agree that the provisions of this Agreement with respect to the distribution and division of marital and separate property are fair, equitable and satisfactory to them based on the length of their marriage and other relevant factors which have been taken into consideration by the parties. Both parties hereby accept the provisions of this Agreement with respect to the division of property in lieu of and in full and final settlement and satisfaction of all claims and demands that they may now have or hereafter have against the other for equitable distribution of their property by any court of competent jurisdiction pursuant to 23 Pa.C.S.A. Section 3501 et. sea. or any other laws. Husband and Wife each voluntarily and intelligently waive and relinquish any right to seek a court ordered determination and distribution of marital property, but nothing herein contained shall constitute a waiver by either party of any rights to seek the relief of any court for the purpose of enforcing the provisions of this Agreement. 21. DISCLOSURE: Each of the parties hereto acknowledges that he or she is aware of his or her right to seek discovery, including but not limited to, written interrogatories, motions for production of documents, the taking of oral depositions, the filing of inventories, and all other means of discovery permitted under the Pennsylvania Divorce Code or the Pennsylvania Rules of Civil Procedure. Each of the parties further acknowledges that he or she is aware of his or her right to have the real andlor personal property, estate and assets, earnings and income of the other assessed or evaluated by the Courts of this Commonwealth or any other Court of competent jurisdiction. The respective parties do hereby acknowledge, recognize and accept that there has been full and fair disclosure to the other of his or her assets and - 11 - .,j , , >'~~"",-~,~~- > .'~.,. ,,~, ~u.T .d _ __ , "",,,, _,~. '~'~Q'~"="_" ., .." .,.,.." ~ w__,_ , liabilities, and each party agrees that any right to further disclosure, valuation, enumeration or statement hereof in this Agreement is hereby specifically waived, and the parties do not wish to make or append hereto any further enumeration or statement. The parties hereby acknowledge and agree that the division of the marital assets as set forth in this Agreement is fair, reasonable and equitable, and is satisfactory to them. 22. MODIFICATION AND WAIVER: A modification or waiver of any of the provIsions of this Agreement shall be effective only if made in writing and executed with the same formality 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. 23. PRIOR AGREEMENT: It is understood and agreed that any and all property settlement agreements which mayor have been executed prior to the date and time of this Agreement are null and void and of no effect. 24. DESCRIPTIVE HEADINGS: The descriptive headings used herein are for convenience only. They shall have no effect whatsoever in determining the rights or obligations of the parties. :, , " -ii il 'I ,I 25. APPLICABLE LAW: This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania. ;; ! ..! i i :1 i - 12 - -'~=''''~o> ,_,,".~~_~_~ ,,~. _,=.r.,', ~_" ,_~__", " !?',,~< '--~'H"_'o~"",_" 07__",_. ,.V. ,_",",_ .. ~M _ _' ~ _~___~,",' ".~,. _ _ _~ ."" =~. _ . , . 26. 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. dd~~ )k~ ~7- '-tSEALl Christopher Lee '/J14~.~. -;-~ ~~J~ (SEAL) ,; - 13 - "o"~"",,^o ~_~_~'O;-_'"~_~_' ,--,~.~o _'_~_"',~,,''''"~_'-.., . _'-~~_"___?'",<,''"'''''_''''~_,__'''~~,'''1r"'~'''_'' '___~', ","",-"_C',"' ~-,e_ ,,~, .~, -- -" - -- .~, .,===.-"..-" ~~- =- ~ . COMMONWEALTH OF PENNSYLVANIA COUNTY OF Daufh:t"\ On this, the /5" day of SS: O'Y Notary Public, the undersigned officer, personally appeared , 2000, before me, a Christopher Lee, known to me (or satisfactorily proven) to be the person whose name is subscribed to the foregoing Property Settlement Agreement and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. -~~~ Notary Public Notarial Seal Pauline ~lli Thomas, Notary Public Harnsburg, Dauphin County My Commission Expires Mar, 24, 2003 Member, Pennsylvania ASsOciation ot Notanes "\." ,~- .' ,"".__"_~"' ~ ~_, m __ .~- ",~,.,<,., ~"_" "'.'. c.--l'>tz:fC,;"__-">;"___","""'M"=,'''.'~" "",,-,-"__"" ,",.,- - .- ,,,, "" ,_ ___, ;,,", eo.,,'''''.' _~^~,~, "._,1^,""", ,__~,=,q.~~". ~'-~'7''''_-_ "" - =-,-' -~-"-- ',.'- - - , , , COMMONWEALTH OF PENNSYLVANIA COUNTY OF Oh~Lf.l~ ) ( ) SS: ~7JM+ me, a Notary Public, the undersigned officer, personally appeared Elaine Nissley Lee, On this, the J:!L cJ3 day of , 2000, before :j ~ j ~ ;; 1 11 J known to me (or satisfactorily proven) to be the person whose name is subscribed to the foregoing Property Settlement Agreement and acknowledged that she executed the same for the purposes therein contained. d 1 , " ') 'J ;.1 '1 I IN WITNESS WHEREOF, I hereunto set my hand and official seal. ~ Public NOTARIAlS MARTHA Pi. BOOTH, Nolal)/ Publro Camp Hill &ro, Cumllalllllld Cooniy My COmmission ExpJres July 12, 2004 1 ,e' . ':; i '. ,') ;'! , 'i " ~:! i I : :,1 d .- \- ~ 'r' ., _", _'_"''''_'~.,~_,_=r.'_'l-"''-' ,-_..-'f''';'''~-~:'_''''' ,<_7 "Y::";_ ,10"_"'-". '_'__ ='_~-""'__'_ ;0"",-','.":,_ -~- "'''"~- """~",-..,-.,,,,-,,,,<,-' ", -~',-- , . EXHIBIT "A" Husband shall retain the following items of personal property: All items in the workshop Aluminum ladder in the garage Husband's clothing, records, CDs, posters, books, laptop computer, cameras, photographs Items owned by Husband prior to marriage (1) Telephone and radio/alarm clock in the bedroom (2) Black walnut stereo cabinets Furniture Husband made with the exception of the quilt rack, jewelry display case and the oak trestle table for the computer Smaller oak computer table Oak chest of drawers Glass top coffee table and matching end table Cherry TV table Oak toy chest Oak and cherry lumber Television set and VCR in the family room An assortment of gardening tools and cooking utensils The storage chest for Husband's sweaters Snowblower ; 'J ;1 :J 28406.1 " :",," - c' "-, """'~-F"""f-""~W~;:-""'<l(';:",,~,_ ,~- , . -, h_~ ,~, ,,~~_" ,:_~"-_",, ~~ 'i;..- ,_" _ ""',' ",;>__. "",' _~_'""_ ""'__"~_o_O k "'Y""'" ""'. _, ""_H ,_n. ", ;; P,,<k,~_ : '" ", ,.' ","~"" ,~,,,-,'W,,,,,",,,,y"'"' ,A_, ,',~, ,,,,,--,,,-"-,"'.", _."V_~' n n c ;!;;: -U OJ ~1rr.,." ::D r cn~: ~4~ !<:O ~8 ~c: ~ -, "_~,_, ,__,"~7'_ o C> . V> ,.., -0 ,/-';"-,'jc,'"",' <Jl Q .'-1 :r;:'J ~ ; ; ,.....- -h'rn ~:'IO C:;:j i ",U 2~ c-' ');! ~ -u -,- ~ ~ U> ---;- - ,'f:-'_"'''<S-~'' " v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ,qt.? NO. 00-1986 CIVIL TERM CHRISTOPHER LEE, Plaintiff ELAINE LEE, Defendant : CIVIL ACTION - LAW : IN DIVORCE 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. Aoril 8. 2000 3. Date of execution of the affidavit of consent and waiver required by Section 3301 (c) ofthe Divorce Code: by plaintiff: by defendant: August 31, 2000 August 23, 2000 4. Related claims pending: None Dated: cr..... {4~o(;;> LAMtf~/~J Sandra L. Meilton Attorney for Plaintiff 32182,1 ',- M,,_, <" -~ Ill! - , ",.,. ,,,-. '0 " .. '-'0'" ~!J~ ~ ~P'<lnl1" . C) fE ~' .~ :2:; ~o ~,8 :li>" ~ ,,~ "~IlII:!1U, . "_'~,,-~_~ ""~ "-_~;""_M_ o o en rTl -C o "'" ,,-t ;;s~ , :~ F.9 c"" i ~O -r: It ;--C;...-.n i;g ~ -< <.n -0 :x f'<) (T\ .^- 1!'ll1l'W'l"!'11!!.1ItI~,_"", ~_ ^,_~A"_~'''''''''' " v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 00 - /9W CU.)~(~"1 CBRISTOPHER LEE, Plaintiff ELAINE LEE, Defendant CIVIL ACTION - LAW IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGBTS 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 Courthouse, 1 Courthouse Square, Carlisle, PA 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 ~OT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. The Cumberland County Lawyer Referral Service 1 Courthouse Square Carlisle, PA 17013 TUCKER ARENSBERG & SWARTZ By: ~f!:1eA/-~-, / Sandra L. Mei ton Attorney I.D. #32551 111 North Front Street P. O. Box 889 Harrisburg, PA 17108-0889 (717) 234-4121 Dated: 3- ;)..7-00 ATTORNEYS FOR PLAINTIFF ij-, ,--, ~ ~"~ "< ^' v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. ()!J-J9t.:, ~ ~ CHRISTOPHER LEE, Plaintiff ELAINE LEE, Defendant CIVIL ACTION - LAW IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Christopher Lee, an adult individual who is sui juris and resides at 8 Oak Ridge Road, Carlisle, Cumberland County, Pennsylvania, 17013. 2. Defendant is Elaine Lee, an adult individual who is sui juris and resides at 1778 N. Meadow Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17013. The present whereabouts of the Defendant, Elaine Lee, to the knowledge of the Plaintiff, is the same. 3. Both Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on July 16, 1988, in Hershey, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. 7. The Defendant is not a member of the Armed Services of the 2 71, .~ - --I ,u ,- > United States or any of its Allies. 8. The Plaintiff avers that the grounds on which the action is based is that the marriage is irretrievably broken. WHEREFORE, Plaintiff requests the Court to enter a Decree: a. Dissolving the marriage between Plaintiff and Defendant; and b. For such further relief as the Court may determine equitable and just. TUCKER ARENS BERG & SWARTZ ~~~~~re III North Front Street P.O. Box 889 Harrisburg, PA 17108-0889 (717) 234-4121 ATTORNEYS FOR PLAINTIFF 26321.1 3 -q,.1,_ ~~-~- --, ~~~. ,,0 . VERIFICATION I, Christopher Lee, acknowledge that the facts stated in the within document are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. A/-'i ;? "7 ~'_. Christopher Lee DATED: ~fC. i 3, .2€MO ;~~_n" ~ . CHRISTOPHER LEE, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 00-1963 ELAINE LEE, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF DAUPHIN AND NOW, this (3A day of April, 2000, personally appeared before me, a Notary Public in and for the aforesaid Commonwealth and County, Gloria M. Rine, legal assistant to Sandra L. Meilton, who being duly sworn according to law, deposes and says that on April 6, 2000, she mailed a certified copy of a Complaint in Divorce, by certified mail no. Z 398 269 783, restricted delivery, return receipt requested, to Elaine Lee, 1778 N. Meadow Drive, Mechanicsburg, PA 17055, and the same was received by her on April 8, 2000 as indicated by the return receipt card which is attached hereto. ~~4-L Gloria M. Rine SWQrn to and subsc~ibed before me this 15 day of April, 2000. ~~ (SEAL) Notarial 6eal , Pauline !'alti Thomas. Notary Public Hamsburg. Dauphin County ~y Commission Expires Mar. 24. 2003 Vl&flJDsr, Pennsylvania Association ot Notanes 11365.1 , ;:r~ 'c" '.,,~" .~-, 't- . -'-_~ ,. ."_-,~__"~,_,"h'-'_'_'"__ ~-- - - --'~'.',. ,_",_"~'_"::,,,,_,_,_., _ ". ,'''.' """'"'^' or, ,< ,. _.,' - ,'~ . - .. T Z 3'l8 269 783 US Postal Service Receipt for Certified Mail No Insurance Coverage ProVidea. .- Do not use for International Mail See reverse Senllo r PA 17055 Postage Certified Fee Special Delivery Fee Restricted Delivery Fee Ul m Return Receipt Showing to ..- Whom & Date Delivered '&. Retum RecoptShowinglo Whom, <t' Date, & Addressee's Address r::i o 11lTALP~~e&~ $ ~ PostmlllkorOate 4/6/00 o u. le + <', 'OJ " 'ij OJ l! OJ ~ ~ OJ :5 c o " 3. Article ~ is. ~ " Ul Ul w II: C C C Z ~ 5. Received By: (Print Name) II: ; ,!ii, ;~. Signatu,e:;d{Jtt!1;SI11J :;e::1 ":. -: ,:-':: "--!" X" -: :"i._,,.: . .~ . , .. . - . ',' . ,~ .., .' - f>s Fomi3IWI,-Dece SEN'I;FI: -eompJElte-ltems-1 amuor2for'addltlonal services. _eornpl_ete itE!ms ~ 48..and 4b. . Print your. name ',and address on the reverse of this form so that we can return this carcUo you. ." -Attach this ~orm to th9 front of the m8ilpiece, or on the back if space does not permit. -Write.Rstum RSC8;/pt-Requested- on the mallplece below: the article number. -The Return R~ipt will show to whom the article was delivered and the date dBliver'ed. _ ,J; ressed to: :' 16r:":1C' ~.~7I. Tl\;:T:'ti' LEE ,.""".~"", 1778 N" ME:1IDO\'J DRIVE l<lECl1A'!li[CSBURG, PA n I also ,wish to reseive the folloWIng se!Vices (10, en extra fee): 1. 0 Add,essee's Address .! $ 2, QiI Restrtcted DeUvery q Consult postmaste. 10' fee, 1 1 48. Article Number G a , , f a , ;1 ! z 398 269 783 4b. Service Type Registe'ed IllI Certified Express Mall 0 Insured Return Receipt fo, Merchandise 0 COD Date of DeUvery ~ ~ ~ . .. . 8. Addresse~'s 'Add,ess (Only if requested and fes is paid) '1: Return Receipt .'1:"; :y:- ~ ,-." __,,~,"","._,__"',,~~,-~F(="._,."~," _~,~, ,."",.,-'d" _~;'?,.,,_~" '"'.' ,.,~_,.~, _n .~ . "'," "-... "',__..~"',"~"__ "__,_^,.,,"._.eu, ~:"-~'~.:;; ~ . .-" .~-". j""" 0> - . '?':'_'-'J',,-~,,-,, .' - " ~, ,_, 'f!" "jI 0 (? t.-:J C I:;) .'n <-- -;:= -n c,;::] -0 , nl ~;~: cO -"~ ;0:: . :--n z c (~:J CP .... C< ,,~. "', l) '2 C') ~'-C' 2~\ ,~-~ (~ C) ---,' .<:- 0 .c:'_._ n'l )::> C ,0 ~~~ ,"- "r:;:. __1 5:J -< ,(:"' -< .1 ,'"' >:;-- .'- ." .H~U . . .' CHRISTOPHER LEE, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 00-1963 Civil Tel:m ELAINE LEE, 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 March 30, 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 after service of 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 made subj ect to the penal ties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. Date: fj'3 J JDe ~;L Christopher Lee, Plaintiff SS# :2.. 6 3. fll - II ~ R' ^< ,,~ .,- ~~ ,~ ""^ '. ~ 0 0 0 ., tI) '~ ~~ !:ci "1'- nl~ , ~.'~ I I CJ:!~ (.n I ~b -q ~ 3: Q6 "-'m - 0 .. i ~ N U> -< :1 ',j :1 'I ';: ';, ,'i",!:),', 1;1 " ','I :i iI' :';;, ~~~ ",:,",'1 -iY i~! ".,"1, " :1 ":",',,':,,,1 ,I; I ,~ ~ -, -. ~"f" -_ r~. ",~"C" ~~o,_, ,~~J1UJ;"'~~,", iii! ,," - J.'1l!l '7' ~.~ ~, -r"","""""',. I ..'. II ( . v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA 00-1963 civil TeJ:m CHRISTOPHER LEE, Plaintiff NO. ELAINE LEE, 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 subj ect to the penal ties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. Date: ;/3/100 ~'o(. Christopher Lee, Plaintiff --=?i ..'. ~o, ' ". 0.' . . (') 0 ?, ~ 0 ~ en ;,;:j l'Tl -0 rh :!1 CO!;:; t.r! 8t? ~e ~ -0 -,,0 ::It: ~'~T=R $8 ~5_(~ ~ - om I .. I'> ~ 0"\ :0 -< "', r, ,',".~".",,' " i ] ~ ~",i, '; II ,;,1;) , o,~ ~ ~,'~ ;1, ,'~ '1) ", ~~]I9!IJmn_ _ ,-. "'-"!_ .""';c"f' .',~ - 1IHJiIII!IIfj=~ ,F""m111!1'IMll!"'mt~~....~,,,,.,,, _~ ".~,!ln:j~," t'""~o,~_":_5Jh_' II lor" .. I CHRISTOPHER LEE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. ELAINE NISSLEY-LEE, Defendant CIVIL ACTION - LAW NO. 00-1963 IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce under s 3301(c) of the Divorce Code was filed on March 30, 2000 and served on April 6, 2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of the 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 made subject to the penalties of 18 Pa. C.S. s4904 relating to unsworn falsification to authorities. Date: A~ .2.3; 'Go" c) I I, [I 11 " :\ 'I I) " ,1 Ij i_' IJ 1 I ,I 11 " J ;j , I' . - _'''~,~_~_=~,!~~~~, 9'1' ,,' .. ,.. n 0> 0 € c> '-n ~ .-.~l i'im :J::'-n ,"liF' z~ ~'O(1'1 '~'" <.J) t~~, ~ -0 c-,'" -rl :Jl: OPn '". ~n - ~ .. N '?is t:f\ :;;<; ~-'1' _ ~ ,}11!M!!f~'lW~~1ri!U"J''''''~llMi~~IMIl~~__~- r~"",~~~~!f. ... ...,.'. - " l CHRISTOPHER LEE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. ELAINE NISSLEY-LEE, Defendant CIVIL ACTION - LAW NO. 00-1963 IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 53301 (C) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree in Divorce without notice. 2. I understand that I may lose rights concerning alimony, alimony pendente lite, marital property or counsel fees 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. s4904 relating to unsworn falsification to authorities. Date: ;4~ -<-~ I L.OOU z~J1d "t; 1~ Elaine NissQey-Leo/r Defendant I I' - " -'i-~ S' , "'.JoI .... I' I I (;) 0 0 c:: 0 -n ;;;;:: ~ .--{ I tee irflFl ~ -0 "'an"1 ~~ (,]1 ::)9 1 "~~O ;,:::;0 -0 ,-' '1 T,:),::'I"1 i~ :x s,?(') - om I ,-I ~ N ~ i ll1' I I I I I 1 J , 1 l 'I 1 I 'l_ "-~JI'~~~ .," '._,~ l ~",.....!ffIVq~_'l$~~ll1if4i<j1*~-!;>~~IiIfIi~~~~~I!l;lI!l' ,.' . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW .' : CHRISTOPHER LEE Plaintiff : : File No. 00-1963 vs. IN DIVORCE : ELAINE NISSLEY-LEE Defendant : NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the ~Defendant in the above matter, having been granted a Final Decree in Divorce on the / 9\f1-- day of s.,,-k-r/\ b.x- , i:9--~ou "', hereby elects to resume the , NISSLEY prior surname of , and gives this written notice pursuant to the provisions of 54 P.S. S 704. DATE: Or:. t ?.-.) 0 CiO ~ (t~ -;1~ Signature ;(~ < .1 Signature of name being ~ resume COMMONWEALTH OF PENNSYLVANIA: : 55. COUNTY OF CUMBERLAND On ,the .211 d day of 0<:-1 _ , Hzooo, before me, a Notary Public, personally appeared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he/she executed the foregoing for the purpose therein contained. In witness Whereof, I have hereunto set my hand and official seal. ~~ //. 2:ilfl~___ Notary Putllic c , " NOTARIAL SEAl.. :, MARTHA A. BOOTH, Newly P_ Camp Hill Boro, Cumllelland eoulltw' . My COmmission Expns July 12, 2004 . ''T. J .~ ." =~ I'""" - , , ,1 1,1 ,~- ~ . -: """' ~1lII 0 0 C 0 9 ~ C) n ~ ~ ~ ;:gm n ..-( zrn -f -'il'1 z:J:) tt.. B mS; I r- "TtlTl -:n::c ;::5"" .f-~. :80 ~ ~ <1...) 'J,~ ~r, ;J> ---i'-,_' ~ Z"'.' 3: ~)~ :B --- S;;;C ';.0 ~ = c 9? OITl Z ~ ~ -t- =< W ';;! -< f'.;l 5:J -< Q \j i .,c. , ,'"'' ;',' .. , f;._,,"~~~I;!".........~, """,~.l!lIUIIU:lllIII._ . ,~" '" ",~r""- . _j ,)1'"