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HomeMy WebLinkAbout00-02011 pi . '" "'''' :f. . . . . . . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY . . PENNA, . . STATE OF DEBORAH J. DAVIS, . . No, 00-2011 CIVIL TERM Plaintiff VERSUS ROBERT H. DAVIS. JR.. Defendant . . . . DECREE IN DIVORCE . . . . . #bdL /Lv , 2001 , IT IS ORDERED AND AND NOW, . DECREED THAT DEBORAH J. DAVIS , PLAINTIFF, . . . ROBERT H. DAVIS, JR. , DEFENDANT, AND . . 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. The parties' Post-Nuptial Aqreement is incorporated. . but not merged into this . . . . . . . . . . ATTEST: . ROTHONOTARY . . ~. -- '1 ,,1 . ., - -~, -,-- . . . . . . . . . . . . . . . . . . . . J. . . . . ;;-~jlMlliJ"i.""", ,llIll!." ~fI'""~'BlliilIfiI ".""- . ~~-" , ' _......l....;"Ililiit-'"'J~- . 3d'? -t:Jf .J '';;fi -of <'-""" ~ --~ ....-- , .- .. "" II ,,'~ L .,:<." M-~~~4~~ J1~~<;?4~ _J! '" _~'__'" .,1.. ~ LAW OFFICES SNELBAKER. BRENNEMAN & SPARE . .' POST-NUPTIAL AGREEMENT ,-;-Q:l THIS AGREEMENT, made and entered into this 1'- day of ~c.\--, ,2001 by and between: DEBORAH J. DAVIS, of 34B West Locust Street, Mechanicsburg, Pennsylvania, party of the first part, (hereinafter "Wife") AND ROBERT H. DAVIS, JR., of 401 Springhouse Road, Camp Hill, Pennsylvania, party of the second part, (hereinafter "Husband") WITNESSETH: WHEREAS, Husband and Wife (collectively referred to herein as the "parties") were married to each other on August 12, 1972 in Fulton County, Georgia; and WHEREAS, the parties last resided with each other at 401 Springhouse Road, Camp Hill, Cumberland County, Pennsylvania; and WHEREAS, the parties have accumulated certain assets and incurred certain debts during their marriage; and WHEREAS,the parties separated on June 23, 2000; and WHEREAS, the parties have two children of their marriage, neither of which is a minor; and WHEREAS, certain differences have arisen between the parties, as a consequence of which they have separated and now live separate and apart from each other; and , ~ ~.. T' LAW OFFICES SNELBAKER, BRENNEMAN 8: SPARE -'1~~ '" _~ ~_ \1 II WHEREAS, on March 31, 2000 Wife initiated an action in divorce docketed to No. 2000-2011 in the Court of Common Pleas of Cumberland County, Pennsylvania (hereinafter the "Divorce Action"); and WHEREAS, the parties agree that their marriage is irretrievably broken; and WHEREAS, the parties acknowledge that each has had the full opportunity to be advised independently and represented by separate counsel concerning their respective rights, duties and . obligations arising out of their marital status and with respect to the terms and provisions of this Post-Nuptial Agreement and the meaning and legal effect thereof; Wife by Keith O. Brenneman, Esquire and Husband by Theresa Barrett Male, Esquire; and WHEREAS, the parties having a full opportunity to be so advised of their respective rights, duties and obligations arising out of their marital status, and each having a full opportunity to investigate and evaluate assets, liabilities and all other aspects of each other's property and their jointly owned assets and liabilities, have come to an agreement for the final settlement of their property and affairs, which they believe to be fair, just and equitable. NOW THEREFORE, in consideration of these presents and the mutual covenants, promises, terms and conditions hereinafter set forth and to be kept and performed by each party hereto, and intending to be legally bound hereby, the parties mutually agree as follows: , 1. INCORPORA nON OF PREAMBLE. The foregoing preamble and paragraphs are incorporated by reference herein in their entirety. 2. MUTUAL SEP ARA TION. Husband and Wife shall be free from constraint or control by the other as fully as ifhe or she were unmarried. Neither shall disturb, trouble or interfere in -2- ~ , ,_4-."" ,) LAW OFFICES SNEL8AKE~. 8RENNEMAN & SPARE ''!?\lIl!_~~~ ,...~ II I! " . II il. , , any way with the other or with any person for associating with the other. 3. DECLARATION AS TO ASSETS AND WAIVER OF EVALUATION. The parties declare and agree that they have, prior to the execution of this Post-Nuptial Agreement, voluntarily agreed to divide and have physically divided and distributed between themselves all of the parties' personal property, furnishings and furniture. Said agreement and division is noted on the personal property list attached hereto and incorporated by reference herein as "Exhibit A". All assets and property possessed by each party as a result of this final division and distribution shall be owned and possessed free of any right or claim of the other, it being understood that each party may own, possess, use and dispose offreely any property in his or her possession. Wife agrees to remove her personal property from the marital residence no later than 14 days prior to settlement on the sale of the residence or two years from the date hereof, whichever shall first occur. The parties acknowledge and agree that the division and distribution of property as set forth above has occurred whether or not said property is or would be deemed to be marital property under the Pennsylvania Divorce Code and subject to equitable distribution. The parties declare and acknowledge that they are fully aware and familiar with all assets and real property that each has brought into the marriage and that has been obtained or acquired separately or jointly by them during the course of their marriage and therefore waive any valuation thereof. Each party expressly releases the other of and from any and all right of equitable distribution or claims to assets and property of any kind or nature whatever possessed in accordance with the division that occurred prior to the execution of this Agreement and possessed as a result of this Agreement by the other party and hereby declares and acknowledges -3- " ; ~~'.... 11 LAW OFFICES SN~LBAKER:. BRE:NNEMAN 8: SPARE ~-. ~I~ II II I j' that the voluntary division by them of all property, whether marital or not, is fair and equitable. . 4. MOTOR VEHICLES. The parties agree that Husband shall retain sole possession, use and ownership of a 1987 BMW L6 Coupe. The parties further agree that Wife shall retain sole possession, use and ownership of the 1995 Audi A6 Sedan. The parties also agree that Husband shall retain sole possession, use and ownership of the 1988 Buick station wagon. Within twenty-one (21) days of the execution of this agreement, the parties agree to sign any and . all title documents necessary to transfer their title and interest in any of the vehicles noted above to effect the exclusive ownership of such vehicles as agreed to herein. 5. MARITAL RESIDENCE AT 401 SPRINGHOUSE ROAD, CAMP HILL. Husband and Wife acknowledge that they are the owners of certain real estate improved with a residential dwelling located at 401 Springhouse Road, Camp Hill, Pennsylvania (hereinafter the "marital residence"). The parties acknowteage that the marital residence is titled in the names of Husband and Wife and that it is encumbered with the following mortgage obligations: 1) Alliance Mortgage Company, loan No. 011737; 2) Harris Savings Bank Prime Line, account No. 1207003069; and 3) Harris Savings Bank Prime Line, account No. 2307025069. The parties agree that Husband shall have exclusive possession of the marital residence. Wife agrees concurrently with her execution of this agreement to execute a fee simple special warranty deed, transferring all of her right, title and interest on and to the marital residence to Husband. Husband agrees that he shall be solely liable and responsible for all expenses and utilities servicing the marital residence or property, including, but not limited to electric, telephone, cable television, sewer and trash, hazard insurance, real estate taxes and -4- ~ '-......; . ~ LAW OFFrCE~:; SNEl.8AKEft BRENNEMAN 8< $PARE II II assessments. Husband agrees that all utilities provided to the marital residence shall be placed in his name alone by the time this Agreement is executed by the parties. Husband agrees to assume and be solely responsible for the payment of the mortgage obligations noted above. Husband agrees to hold harmless and indemnify Wife of and from any and all liability, costs and expenses related to the three mortgage obligations. Husband agrees to pay Wife the sum of$17,000 within ten (10) days of the settlement on . the sale of the marital residence or by December 31, 2002, whichever occurs first. In the event Husband does not sell and settle on the sale of the marital residence by December 31, 2002, he agrees to conclude refinancing of the mortgage obligations noted above in his sole name by December 31, 2002, for purposes of releasing and removing Wife as a mortgagor or obligor of such obligations. 6. BANK ACCOUNTS. All bank accounts held by the parties up to the time of their separation have been divided by mutual agreement to their satisfaction. 7. MUTUAL DEBT AND FUTURE OBLIGATIONS. The parties acknowledge that their marital debt consists of the three mortgage obligations made reference to in Paragraph 5, supra. , The parties agree that any and all loans, debts and/or obligations incurred subsequent to the date of their separation shall be the sole and separate liability and responsibility of the party incurring the obligation and each party agrees that he/she will not incur or attempt to incur any obligations for or on behalf of the other party and will indemnifY and hold harmless the other party of and from any and all liability arising from such future obligation. Further, the parties -5- J '.--.J,~ ,l ~ LAW OFF1CE:S SNELI3AKER, BRENNEMAN & SPARE "'~f-M' hereto agree to indemnifY and hold harmless the other party of and from any and all liability arising from the loans or account balances specifically identified above, and any and all other debts incurred by each party, whether marital or not, not disclosed or identified herein. 8. RETIREMENT PLANS, PENSION, EMPLOYMENT BENEFITS AND lRAs. The parties acknowledge and agree that they are the owners, as noted below, of the following IRA and investment accounts which are agreed to be marital property in their entirety: , . ACCOUNT DESCRIPTION OWNER/TITLE 1. Fahnestock IRA Account No. A87-0900782-l27 Husband 2. Fahnestock SEP IRA Account No. 0903885-127 Husband 3. Fahnestock Putnam Voyage Fund IRA Account No. 0362741115 Wife The parties acknowledge that the Fahnestock Money Market Account No. A09-0023308- 127 has been closed after the parties' separation and the funds therein distributed pursuant to mutual agreement of the parties. 4O,;l.~{) The parties agree that Wife shall receive $48,888'from the IRA account identified by 40.1010 number 1 above. The parties further agree that Wife shall receive $7,888.88 {rom the SEP IRA account identified by number 2 above. With respect to both accounts, Wife waives any claim or right to any contributions made by Husband to said accounts, after the date of the parties' separation. The parties also agree that the IRA account identified by number 3 above, shall remain in Wife's name in its entirety without any portion thereof being transferred to Husband. -6- J ,_J.... ,'I LAW OFFICES SNEL8AKEI=i. BRENNEMAN & SPARE The parties acknowledge that Wife is eligible for a certain retirement benefit due to her former employment at Cumberland Valley School District. Husband waives and forever releases Wife of and from any and all claims against Wife's retirement benefit through Cumberland Valley School District as well as Wife's post-separation retirement benefit through her current employer, Pennsylvania Association For The Blind. The parties agree promptly to cooperate, sign all documents and pursue jointly any court approvals necessary to effect the division of the accounts noted above as soon as possible upon execution of this Agreement. In addition, neither party shall transfer, encumber or order sales or purchase upon the above accounts, or any parts or investments therein prior to the conclusion of the division as agreed to herein, To the extent a qualified domestic relations order is necessary to divide the accounts identified as numbers 1 and 2, above, said order shall be prepared by Wife's attorney for approval by Husband's attorney, which approval shall not be unreasonably withheld. 9. LIFE INSURANCE. The parties acknowledge and agree that they are the owners of the following policies of life insurance, all of which are agreed to be marital property: Policv 1. Mass Mutual Policy No. 2974857 2. MassMutual Policy No. '3348159 3. Mass Mutual Policy No. 4468225 4. Mass Mutual Policy No. 3835249 -7- ,-~,j ,If ;' LAW OFFICES SNELBAKEF~, BRENNEMAN 8: SPARE ::,{ ~!. - II ,I , I," The parties agree that ownership of the policies identified in numbers 1, 2 and 4, above, shall be transferred to or remain in ownership of Wife, whichever the case may be, and that the policy identified in number 3 above, shall be transferred to or remain in ownership of Husband, as applicable. Upon execution of this Agreement, Wife shall be responsible to pay the premiums on the policies assigned or to be transferred to Wife. The parties agree promptly to cooperate, sign all documents and pursue jointly any court approvals necessary to effect the transfer and ownership of the policies as agreed to herein. The parties further agree that either party may terminate and utilize the cash value of anyone or more policies of insurance that he or she may own after the transfer of ownership as noted above or, in the alternative, keep and maintain said policy or policies of insurance as each party in his or her sole discretion shall decide. 10. SPOUSAL SUPPORT, ALIMONY PENDENTE LITE AND ALIMONY. Beginning May 1, 2001 and by the first day of each month thereafter for a total period of thirty-six (36) months, Husband agrees to pay to Wife the sum of$1,300 each month as alimony. Beginning April 22, 2004 and on the 22nd day of April each year thereafter, Husband agrees to provide Wife with a copy of Husband's Schedule C, confirming his net profit in the prior year. Beginning May 1,2004 and each year thereafter, Husband agrees to pay monthly alimony to Wife on the first day of each month in an amount equal to one-twelfth of ten percent (10%) of Husband's prior year's net profit as established by and noted on the form Schedule C. Accordingly, by way of illustration, Husband's alimony obligation to Wife for the months of May, 2004 through April, 2005 on a monthly basis shall be determined by taking the net profit -8- - II I 'l-J.' ] '- ,I ii I; Ii I: " " I, ii Ii Ii I 'i Ii ,I I' " 'I I I' Ii [: i' i! il " i: I I' I , LAW OFFICES SNELBAKEf;~, BRENNEMAN & SPARE I i <~ noted on Husband's form Schedule C applicable to the calendar year 2003, calculating ten percent (10%) of such net profit, then dividing the ten percent (10%) amount by 12. Husband's alimony obligation described above will terminate upon the earliest of the following to occur: the first day of the month in which Husband reaches the age of65; Husband becoming disabled to the extent he is prevented from earning a living as an attorney; Husband's death; Wife's death; Wife's remarriage; or Wife cohabitating with a person ofthe opposite sex who is not a member of her family. In the event Husband no longer works as a sole practitioner in the practice of law, Husband agrees to pay to Wife ten percent (10%) of his annual W-2 gross wages or ten percent (10%) of his net profit from self-employment in the same manner as described above, subject to such obligation terminating in accordance with any of the events above described. The alimony set forth in this paragraph shall not be subject to modification under any circumstances. Except as provided herein, each party hereby relinquishes and surrenders any and all claims for support from the other, including, but not limited to, spousal support, alimony, and alimony pendente lite. It is the intention of the parties that all payments made by Husband to Wife pursuant to this paragraph, shall be periodic payments in discharge of a legal obligation, which, because of the marital or family relationship is imposed on or incurred byHusband under a written instrument incident to a divorce, all within the meaning of the Internal Revenue Code of 1986, as amended, as now in effect and of similar provisions of future laws. Such payments will be includable in Wife's gross income and will be deductible by Husband in determining their respective taxable income. -9- ! ~J'" " LAW OFFICe:S SNEL8AKER. BRENNEM)\N 8: SPARE '<; 11. COUNSEL FEES. COSTS AND EXPENSES. Husband agrees to pay to Wife the sum of One Thousand ($1,000.00) Dollars to be applied toward her attorney's fees, costs and expenses of filing for a divorce. Such payment shall be made to Wife no later than thirty days of the execution of this Agreement by the parties. Except as provided in this Paragraph, each party hereby waives and releases each other of and from all claims for attorney's fees, costs and expenses. 12. DIVORCE. The parties agree to terminate their marriage by mutual consent without counseling and each agrees, concurrently with his or her execution ofthis Agreement, to execute the necessary affidavits, waivers and consents to procure a consensual divorce under the provisions of the Pennsylvania Divorce Code, such documents to be filed in the Divorce Action. 13. GENERAL RELEASE. Husband relinquishes his inchoate intestate right in the estate of Wife, and Wife relinquishes her inchoate intestate right in the estate of Husband, and each of the parties hereto by these presents, for himself or herself, his or her heirs, executors. administrators or assigns, does hereby remise, release, quit-claim and forever discharge the other party hereto, his or her heirs, executors, administrators or assigns, or any of them, of any and all claims, demands, damages, actions, causes of action or suits at law or in equity of whatsoever kind or nature, for or because of any matter or thing done, omitted or suffered to be done by such other party prior to the date hereof, except that this release shall in no way exonerate or discharge either party from the obligations and promises made or imposed by reason of this Agreement. . 14. SURVIVAL OF AGREEMENT. It is the intention of the parties that this Post- Nuptial Agreement shall survive any action in divorce which may be instituted or prosecuted by either party, and no order, judgment or decree of divorce, temporary, interlocutory, final or permanent, shall affect or modify the terms of this Agreement, but said Agreement may be -10- ',"-' .. LAW OFFICES SNEL8AKER, BRENNEMAN 8: SPARE <,.",,^ lI/IIllIIl!lIlI ~ II 'I , I. , enforced by any remedy at law or in equity, including enforcement proceedings under the , Pennsylvania Divorce Code. The parties agree to incorporate this Agreement into a separate order of court to be entered in the Divorce Action, but this Agreemeritshall not be merged into said order or decree in divorce. 15. COOPERATION. The parties agree to cooperate with each other and to make, execute, acknowledge and deliver such instruments and take such further action as may hereafter be determined to be requisite and necessary to effect the purposes and intention of this Post- Nuptial Agreement. 16. BREACH; INDEMNIFICATION. If either party hereto breaches any provision hereof, then the nonbreaching party shall have the right, at his or her election, to sue for damages for said breach, or seek such other remedies or relief as may be available to him or her, and the defaulting party shall be responsible for payment of all reasonable legal fees and costs incurred by the other party in enforcing his or her rights under this Agreement. Each party agrees and covenants to indemnify and hold harmless the other party from any and all liability and/or claims and/or damages and/or expenses (including attorneys' fees and expenses of litigation) that the indemnitee may sustain or may become liable or answerable in any way whatsoever~or shall pay upon, or in the consequence of, the indemnitor's breach of any obligation, term or covenant of indemnitor under this Agreement, including, but not limited to, indemnitor's obligation to make any payment provided for herein. .17. VOLUNTARY EXECUTION. The parties declare and acknowledge that they have had the opportunity to have the provisions of this Post-Nuptial Agreement and their legal effect explained to them by independent counsel of their choosing and each party acknowledges that this Post-Nuptial 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 -11- ~.1.....,! t \.. LAW OFFICES SNELBAKER. BRENNEMAN & SPARE I'-.,It ~.="'" II Ii " , influence. The parties acknowledge that they have been furnished with all information relating to the financial affairs of the other to the extent same has been requested by each of them. . 18. ENTIRE AGREEMENT. This Post-Nuptial Agreement contains the entire understanding of the parties and there are no representations, warranties, covenants or undertakings other than those expressly set forth herein. The parties 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 the Pennsylvania Divorce Code or any amendments thereto. Each party voluntarily and intelligently waives and relinquishes 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. , 19. W AIVERlMODIFICA nON. The waiver of any term, condition, clause or provision I of this Agreement shall in no way be deemed or considered a waiver of any other term, condition, clause or provision ofthis Agreement. This Agreement can only be modified in writing executed by both parties hereto. 20. ENFORCEMENT AND MODIFICATION. Either party may enforce this agreement as provided in Section 3l05(a) of the Divorce Code. As provided in Section 3l05(c), provisions -12- - '.:..,J l'; LAW OFFICES SNELE3AKE]~. BRENNEM,A,N Be SPARE ~ ~: 1.'" " i " of this agreement regarding equitable distribution, alimony, alimony pendente lite, counsel fees or expenses shall not be subject to modification by the court. 21. DISCOVERY; RIGHT TO ASSESSMENT: WAIVER. Both parties have had an opportunity to discuss with counsel the concept of marital property under Pennsylvania law and the right to seek discovery under the Divorce Code and the rules of civil procedure; and the right to have the real estate, personal property, estate and assets, earnings and income of the other assessed or evaluated by the courts of this Commonwealth. Each party confirms that there has been disclosure to the other of such income, assets and liabilities. Each party waives any right to further disclosure, valuation, enumeration or statement of income, assets or liabilities. Neither party desires to make or append to this agreement any additional enumeration or statement. Neither party shall sue the other party or that party's heirs, executors, administrators or assigns, alleging denial of any right to full disclosure, or fraud, duress, undue influence or failure to have available full, proper and independent representation by legal counsel. 22. TAX IMPLICATIONS AND MATTERS. The parties have negotiated this agreement with the understanding that the property transfers described in this agreement fall within the provisions of Section 1041 of the Internal Revenue Code, and as such v;ill not result in the recognition of any gain or loss upon the transfer by the transferor. The parties will file joint federal, state and local income tax returns for 2000, and shall share equally any refunds. Husband will assume all costs for the preparation of the returns, and for payment of any taxes due. Within five (5) calendar days of either party's receipt of any deficiency notice or other correspondence form the Internal Revenue Service, the Pennsylvania Department of Revenue, or -13- - r , ......L.\. ". LAW OFFICES; SNELBAKER. BRENNEMAN & SPARE "'!li1lj-" II " " the local taxing authority, the receiving party shall provide the other with a copy of such notice and/or correspondence. 23. HUSBAND'S LAW PRACTICE. Wife waives all claims in and to the marital portion of Husband's sole practitioner law practice, including but not limited to accounts receivable and personalty. 24. APPLICABLE LAW. This Agreement shall be construed, interpreted and enforced according to the laws of the Commonwealth of Pennsylvania. 25. HEADINGS. The headings or titles of the numbered paragraphs of this Agreement have been used only for the purpose of convenience and shall not be resorted to for the purposes of interpretation or construction of the text of this Agreement. 26. EFFECTIVE DATE. This Agreement shall be dated and become effective on the date when executed by the latter of the two parties. " IN WITNESS WHEREOF, the parties have hereunto set their respective hands and seals intending to legally bind themselves and their respective heirs, personal representatives and assigns. WITNESSED BY: ~ (J~4:flLb; ~ (SEAL) Deborah J. Davis Date: nll~H 1, 2~1 ~COW!~ . (SEAL) Rooert H. avis, Jr. Date: Ju'MeftAJ..,?a{ -14- .~~" "..' " " Equitable Distribution *Deb inherited **Deb would like to take w/ Familv Room sofa antique trunk* frreplace tool set cathedral mantel clock** picture over fireplace* small framed family pictures** Bertra's painting picture of Helen's house* 5 x 8 area rug love seat wall cabinet of videos, tapes, records** checkerboard side table** 4 shelf metal bookcase assorted books, casettes, cds**(some) brass lamp 32" color tv w/remotes vcr chest w/drawer, 2 doors* basket of dog toys** Brumby style rocker apple picture** 6 wall shelves ofbooks**(some) assorted framed mirrors** WW I truck toy* small wooden shelfwlbell** red/green coverlet sofa pillows ginger jar lamp picture albums**(some) - negotiated nest of end tables end table w/shelf telephone/answering machine tv trays tv/vcr stand w/shelves for videos stereo (5 disk cd changer, tape player, tuner, speakers, remote)~* coffee urn lamp Fover . Table with bookshelfi' I 1 EXHIBIT A 'ji,-~= " . . .~II - ~" " . ......,' ~ " ,,",~,~~, , -,~ .,P Livin!! Room lOx 14 Karastan area rug books! !**(rnany) piano & bench** Plantation desk Tv stand 3 - 2.5' x 6' bookcases/books**(2) wicker rocker* whole house humidifier Framed needlework** basket w/plant** small 3 drawer chest table for computer trash can music stand piano music** brass book ends** gun rack candlestick lamp Computer, printer, speakers, monitor T orcheir lamp Office chair Rosewood loveseat & 2 chairs* Guitar Piano lamp** Ger. Christmas candle whirley gig** Office supplies Wall picture Dinin!! Room Cherry drop leaf table Pitchers & teapot* Mother/Child framed picture* Helen's picture* Boston Rocker* Cherry dining room table 4 cane seat chairs (Helen's)* cane back/seat rocker** black cane seat chair plant stand with Christmas cactus* * copper boiler** Jackson press** table linens*(Helen's)- 8 x 11 oriental rug crystal*(Helen's) copper chafmg dish** sterling, crystal, china, serving dishes*(Helen's) 8 places ettings Reed & Barton Grand Renaissance sterling flatware & serving pieces -Deb 8 place settings Autumn by Lenox china + soup bowls, fruit bowls, ramekins - Deb mahogany silverware box - Deb [her initials] 2 sets brass candlesticks** 2 ~' b . -~ . - "-,~,-~ . . .'-;-'" .'.' Bob's Bedroom King size bed Brass lamp Cedar chest* 2 bedside tables blue porcelain lamp* chest of drawers Chris's Bedroom Brass double bed bedside table Lamp chest of drawers I>esk chadr Assorted wall pictures, bulletin boards, etc. Tv Helen's Bedroom Spindle/spool double bed* Lamp Desk Bookcase wi books & stuff bedside table** chest of drawers wall posters & pictures trunk Deb's Bedroom Chest of drawers* Cedar chest* Double bed Bookcase**(books & stuff) Smalllamp** lamp desk* quilt rack boombox** Amish wall picture** Linen Closet Towels** (some) Blankets**(some) sheets**(some) vacuum cleaner 3 jW!! ~- - ...,.., ~ " . ,/(\ (\(,(y 'Vtllg\IIV IJ . .-. L '. < Laundry Room Wooden key plaque Washing machine Laundry supplies Candles**(those given to me as gifts) Picnic supplies Thermoses* House cleaning supplies Dog leashes, supplies**(all) Decorative wall broom Right Side ofthe Basement Hide-a-bed sofa MagnifYing lamp**" 3 shelf bookcase 2 3' x 6' folding banquet tables**(l) Needle arts/gardening books/magazines** Sewing machine** lron** Ironing basket w/ things to be ironed** Upholstered lounge chair Plate shelf"*(Blair made) Table fan** Small wooden sheu:',*(Blair made) '1JJ' ~^ pineapple wall omarnent clothes dryer packaging supplies flower vases**(some) ,vine, liquor lunch containers shoe care supplies**(some) laundry baskets back door mat I window valance end table quilt stand * * 1T'tv** boxes offabric/yam/craft supplies** needlework notions** 2 swing arm lamps** ironing board** clothes rack** trunk black cane bottom chair misc. baskets**(some) cork board** 4 ~. ~d'V < ~~~-- ~~-"' , . ,.1" . Kitchen Pots & pans"'*(Revereware set) White dinnerware**(half) 4 chairs stainless flatware**(all ofl pattern[of3]) microwave coffee pot food processor* * copperlbrass tea kettles* * copper cookware** refrigerator Roseville bowls** Wmsbrg. Pitchers** Cookbooks**(some) . Cutco knives WV blue pottery** Back Porch Baker's rack** Rocking chairs** Kayak paddles, suits, bags, etc, Porch swing** Assorted plant containers** Folding chairs Washtub '~i'!1!Jj_ , casserole dishes**(a few) serving dishes**(some) drinking glasses* * (halt) coffee mugs**(some) toaster oven waffle iron antique iron/trivet collection* Dad's pancake griddle* iron skillet & cornbread pan* copper & brass sugar/creamer/tray** Roseville pitchers** chestnut table with oak leaf" cooking utensils**(some) Chicago cutlery** plants** lawn mower kayak(s) 2 dogfood containers & dogfood** Shop Vac small step ladder firewood Chris's mountain bike 5 ~' " . / ~~l" , ~~."'-' II,'" ~ ~ 1 Left Side ofthe Basement 4 fans set speakers for stereo** twin bed frames - [Bob's} games Solo Flex - Chris's wall shelf**(Blair made) Boxing bag (heavy) / speed bag w / wooden mount - Chris's Christmas wreathes Christmas decorations**(some) Framed pictures**(same) wax candles** Aqwnum rollrop~~ Painting supplies fmancial records Wallpapering supplies antique wooden bakery box Glass water jar manual typewriter Helen's memorabilia Chris's memorabilia Turntableltape player/tuner** telescope Coolers upright freezer Gift wrapping supplies**(some) canning jars & equipment Camping equipment [Kelty backpack, 4 sleeping bags, Coleman stove, misc. pads, pans, dishes} Wooden cutting board** clear plastic picnic ice bubble** Toaster** 24 cup coffee pot** Copper kettle** Deb's memorabilia Assorted baskets**(some) African masks Luggage** - Deb's Law office files 6 metal shelf units manual coffee grinder** old Davis family films Box antique dolls - Helen's 2 coffee table books - Bob's Assorted kids books Box wooden play blocks - Chris's Box law school notes - Bob's Box Transformer toys, space station - Chris's 6 ;f$~V. ~I' ~""""""" '~n ,_ , ~ -' .....'.. .,,- Garage and Over the Garage Storage Large gardening tools (shovels, rakes, etc.) Small gardening hand tools** Electric tools (router, jigsaw, sander, circular saw) Small tools (screw drivers, hammers, saws, level, etc.)**(some) Robert Sr.'s toolbox life jackets Paddles & hiking sticks trash cans 3 shelf units (2) car care supplies Assorted shoes, bike helmet wooden box athletic equipment 6' ladders (2) extension cords concrete mix radio driveway sealant camping tent cement mixing trough painting drop cloth 4 all season radials (station wagon) lumber campmg canopy hiking backpack sleds ox yoke garden hoses (2) : 7 ~.~~ ,~jlii: ,~^ . ~_ "., ~ , ,~ ~ ",' '. .,. ~ !!lfTI_1IR1\II". ~~ !II, '~","'"7"''C''-."'"'I'_ _" ,..,.~ ".~ <:0 ~ ~~ ~G] fl1n1 ~~. r:::,I..J i:c) bel ;pc ~ o -- ~':'" .~:;jO ::,)J ~'M , " ", '"'~ - '" o '-r1- en -,-,- i..~.1 :=7 :si~ I:;~~,~ ~l ~, 5:- -< .-r) ::i.: :.;'? :::? .17" '!!;~~!j1'~W;:"flivm~!!Iil!~~, __. ~_.~~... . F'_l~ LAW OFFICES SNEL8AKER. BRENNEMAN & SPAR];: I ". DEBORAH J. DAVIS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00-2011 CIVIL TERM : CIVIL ACTION - LAW ROBERT H. DAVIS, Defendant : IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO: Prothonotary of Cumberland County: 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 330l(c) of the Divorce Code. 2. Date and manner of service of Complaint: by certified mail, restricted delivery on Defendant on April 4, 2000 (see Affidavit of Service filed herein). 3, Date of execution of the Affidavit of Consent required by Section 330l(c) of the Divorce Code: by the Plaintiff: March 9, 2001; by the Defendant: March 12,2001. 4. Date of execution of Waiver of Notice in Section 330l(c) Divorce: by the Plaintiff: March 9, 2001; by the Defendant: March 12, 2001. 5. Related pending claims: None. SNELBAKER, BRENNEMAN & SPARE, P. C. Date: March 16, 2001 By: Attorneys for Plaintiff ~ ., " ...." J !If_.......~ .:I!J~IlllII',]I.. ..... ~ " () 0 C 0 ~ :J:: -r-; '"DBJ f11n--; = ;;::0 =0 ;--':i21 ..e:C' :...~T8 (1)<.:':.:::: m =<, ~Cj ""U ~-?,(:) ~c' --'-r-, ~d ::E: ('''12 5>C ~/ .~~.;. C') drll 2: S;; =< 0 ., C.J'l :r:; -< ,.__:"_~<I!If4!l'~!~-fl$lO<llll'"~I!i;'~~-~-.,,,,..~!!!I!IIi:"'~ "0 iI!lIlg.~~...~411JR!i1"_~Jl I j il I " ~ ,.1 !I ;j] ! 'I! I '!I I I ~ , ,~ , LAW OFFICES SNELBAKER, BRENNEMAN & SPAHE t,'~~,. , -"-~ ,'1.-" DEBORAH J. DAVIS, Plaintiff : IN THE COURT OF COMMON PLEAS 0 : CUMBERLAND COUNTY, PENNSYL V ; NO. M -dOli CIVIL TERM CIVIL ACTION - LAW v. ROBERT H. DAVIS, JR., 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 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 divorce is indignities or irretrievable breakdown of the marriage, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce decree being handed down by the court. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, Carlisle. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from the list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DMSION 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 WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 SNELBAKER, BRENNEMAN & SPARE, P.c. By: ~~, Attorneys for Plaintiff LAW OFFICES SNELBAKER. BRENNEMAN & SPAR:E !] I: DEBORAH 1. DAVIS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VA : NO. 1>-o_,.Jf) II CIVIL TERM CIVIL ACTION - LAW v. ROBERT H. DAVIS, JR., Defendant INDNORCE COMPLAINT COUNT I - DNORCE 1. Plaintiff DEBORAH 1. DAVIS is an adult individual residing at 401 Springhouse Road, Camp Hill, Cumberland County, Pennsylvania 2. Defendant ROBERT H. DAVIS, JR. is an adult individual residing at 401 Springhouse Road, Camp Hill, Cumberland County, Pennsylvania. 3. Both the Plaintiff and the Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were lawfully joined in marriage on August 12, 1972, in Fulton County, Georgia. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction since the date of the marriage averred in Paragraph 4, above. I.AW OFFIC:ES SNELBAKER, BRENNEMAN & SPARE ,_"C' -~ ~- "-~,"'1 ^ "'0' ", : ,',. -_ '-,_., ,~_" '- - 6, Neither party is a member of the armed forces of the United States of America. 7. The Plaintiff avers as the grounds upon which this action is based is that the marriage between the parties hereto is irretrievably broken. 8. The Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 9. The Plaintiff requests this Court to enter a decree of divorce. WHEREFORE, Deborah J. Davis requests this Court to enter a Decree of Divorce, divorcing the Plaintiff from the bonds of matrimony heretofore existing between the Plaintiff and Defendant. COUNT II-EOUITABLE DISTRIBUTION 10. Paragraphs I through 9 included in this Complaint are incorporated herein by reference. II. Plaintiff and Defendant have legally and beneficially acquired various property and assets since the date of their marriage on August 12, 1972. 12. Plaintiff and Defendant have not agreed to any equitable distribution of their property and assets. WHEREFORE, Plaintiff Deborah J. Davis requests this Court to order equitable distribution of the parties' marital property. -2- LAW OFFIGES SNELBAKER, BRENNEMAN & SPAHE 1:-1. "' - -, ~, WHEREFORE, the Plaintiff requests this Court to: (a) Enter a decree of divorce divorcing the Plaintiff from the bonds of matrimony; (b) Order equitable distribution of marital property; ( c) Order such other relief as this Court deems just and reasonable. RENNEMAN & SPARE, P.C. By: Date: tlfAJ ~ ~p, Keith O. Brenneman, Esquire 44 West Main Street Mechanicsburg, PA 17055-0318 (717) 697-8528 Attomeys for Plaintiff Deborah 1. Davis -3- --. -~ ,- .,-,,-.- , I I I I I I " I I I I I I I " ~ Ii II I ;1 ! i1 " " 11 '1 f1 I I II " I' II Ii I I ,I i II I I ! ~ Ij ji II , I ! fj~~:,,!" ~, LAW OFFICES SNEL8AKER. BRENNEMAN & $PAHE -"'. - ~ II I- I ,I :' VERIFICATION I verify that the statements made in the foregoing 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. 7, (j},~~ Date: / ~i c2f 02000 , J i ! 1 ,j J ,: 11' 1, 'i ;! I \1 1.1 II .~ 'I 'II fi 11 LAW OFFICES SNEL8AKER. BRENNEMAN & SPAFtE :,1 " !i II )~ . 1/ II I: DEBORAH J. DAVIS, Plaintiff IN THE COURT OF COMMON PLEAS 0 CUMBERLAND COUNTY, PENNSYL VAN v, NO. CIVIL TERM CIVIL ACTION - LAW ROBERT H. DAVIS, JR., Defendant IN DIVORCE AFFIDAVIT DEBORAH J. DAVIS, being duly sworn according to law, deposes and says: I. 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 Office of the Prothonotary, which list is available to me upon request. 3. Being so advised, I do NOT request that the court require my spouse and I participate in counseling prior to a divorce decree being handed down by the court. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. S 4904 relating to unsworn falsification to authorities. Vlmo-lfr;@lttd Deborah J. aV1S Date: Jtue./J c1.f) j.Ot) () ~ - ~,,.,, ~ -", :c ~ . ',- '.,;" : ~,~. ~~ \, ~ ~'\ vJ ~ --J~ ....... "\) ~-'- " '" " ,~ <:\ ~~ ~ ~ ~ ~ \~ \ \ ~ ~ ~ ~ ~ . ~ ' ~ ~ " t ~ '_, __'.p.,,",,,,,,_ "'?! .",._ _ _ 1?'<'!7 ~ ,--, ; .-..- , ~,," '. "" C) :;;;; -r-)s.. ma1 ~~! ,.,;> 19E: -c /' ':.;! 'I.tif;jrr_"':-~ c:> o o ~.. -n ~ :;:. :~~ 00 (,,:) ,~ .......- ~ :...;: .;n C.' _,,","^, :,.I!'/'''v :_~ ~D1I'I!'_ -,,-,i-r; ::_'-lC') :'~~ ~:? " ~.5~~ ~:'-l :0 -< :::1 .,...,~~~;j!i ti f~ I:! [; " I, I' r~ Ii Ii [.1 " " r'j ii d I: II il Ii Ii I' " ~ 1 i'! U II H I' " ri " r.' [-j 'I fl f'1 (i I:; i.:: f1 I' l'; I, j'-': 1"1 ~ " H 1,1 ir i" 11~ "I I:, 1','1 !j; Ii; :';1 [';j " 'Ii LAW OFFU:ES SNEL8AKER. BRENNEMAN & SPARE " ~ ~ 1 I _-, ~ ., DEBORAH 1. DAVIS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO.00-20Il CIVIL TERM CIVIL ACTION - LAW ROBERT H, DAVIS, Defendant IN DIVORCE PLAINTIFF'S AFFlDA VIT OF CONSENT UNDER SECTION 3301(C) OF THE DIVORCE CODE I. A complaint in divorce under Section 330l(c) ofthe Divorce Code was filed on March 31, 2000. 2. The marriage of the Plaintiff and the Defendant is irretrievably broken and ninety (90) days have elapsed from the date ofthe 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. 4. 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. S 4904, relating to unsworn falsification to authorities. Date: March 9, 2001 Q,~FL,;) Debor . Davis (Plaintiff) :i , "'H'" _...,.?',"""',......'O"" ""'cf,',",' ','M ...., 'H if~ 0 0 0 C -'1 .". - "'"' -:'" '~ '13(0 ~~ --.,.-,', fnTT. ;:0 e,;:::-. Z::C1 -''-T' 2:C (j') ~".~~ ~? (/)-2;: -<..-:~ .~~ f<C,' -0 ~::O ....::,~ L-O C:? :.:o;SFT1 >c ~ 2: 0 :< :D .s:- -< ]~I ~ ~~. - rJII'!ll!~jj' ,j "I ;~i ., 'i 'I -,J ;:j ';1 ~~ :1 ;: <:'1 ;"1 , ,! LAW OFFICES SNEL8AKER. BRENNEMAN & SPAFIE 1 :,1 , f',~~ DEBORAH 1. DAVIS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, : NO.00-20l1 CIVIL TERM CIVIL ACTION - LAW ROBERT H. DAVIS, Defendant IN DIVORCE PLAINTIFF'S 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! 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 ofthe decree will be sent to me immediately after it is filed with the Prothonotary. 4. 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. S 4904 relating to unsworn falsification to authorities. Date: March 9, 2001 ~ /, : /~) Debo . Davis (Plaintiff) li ".' - "C,' .. " -,",'" " ". ..' . " 'IIlrnw'f o c <'" -ow rr1JT, Z::C Z'" ~?~ ~c ::-Z""(") ~o >c ~ ,. J._ """ ,.,.'.d',,' -, ~mwf'f,,,,~~ffli!![~~.. ~~=. ~!QJ~,I!'!1:ttI!JlIIl r'-~~ o ,~, ,~ -on - _t~. ~; "'_: r':--;;: cPo -26 ~~:~~ c:S~ o-l 15 -< ..t) ~~ Cf? o .;:- Theresa Barrett Male Supreme Court #46439 513 North Second Street Harrisburg, P A 1710 1 (717) 233-3220 Counsel for Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DEBORAH J. DAVIS, Plaintiff v. NO. 00-2011 Civil Term ROBERT H. DAVIS, JR., Defendant CIVIL ACTION - DIVORCE AFFIDAVIT OF CONSENT 1. 31,2000 A complaint in divorce under ~ 3301(c) of the Divorce Code was filed on March 2. The marriage of plaintiff and defendant is irretrievably broken and ninety 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 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. ~ 4904, relating to unsworn falsification to authorities. Date: March / J-- Yf{ , 2001 l-1J . , "'-f. , il ~, ...,.... ._u II -.. ". , -<~, ~,. ~, "~." 0 0 0 c: Tl s: :::!C :.::,:! -Pm ~ mm AJ -11 F~J Z"::Cr Zt;;' J:;o (f) ,.- en -<L '2fS !:<o -0 ~I;~:i ~o :OK ~-:Jo .-..:0 ~ ;o..-::;.n )>c: ~ :z => p =<! :xl .r;- -< "'~ 1!l::r.~!W~~~""111l~if fililJM'I!!I~>;'~Mml!lf!!\ll~~. !",~!Q~H( Theresa Barrett Male Supreme Court #46439 513 North Second Street Harrisburg, PA 17101 (717) 233-3220 Counsel for Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DEBORAH J. DAVIS, Plaintiff v. NO. 00.2011 Civil Term ROBERT H. DAVIS, JR., Defendant CIVIL ACTION - DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is fIled with the prothonotary . I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C,S. ~ 4904 relating to unsworn falsification to authorities. Date: March /J- , 2001 . - OL.' ,_~, ~, ., - ~~9~~ ~ '". ." ~-'"' ,~> .""", _ ,--,", ',~,;'<, ,..~~,,_~. ,.If,,=.~,,,,,,", ~" "0"' ~, .~,~,.~~~," .~. " "'" ~^ () C) 0 C -'n ~. :;Ii: "'- -elm ~ :-;-~f.A fTlm 7.1 2::G 2~ - ~--J t.") en '1", v' ,<2 ;~(=) !<,O ~1 ':;;;"- " ~8 ::t": "-?o J>c s:! <.:sin ..... 2 .,,' ..... 0 ~ -< .;;- H~~~11;lIl!IIII8I.\'1f!!~IQl!!fiI!II!IIij1l~~,"~,ij~~~_I!!ll-1$ . '. I 1 I II i I ! I 1 I , j II." j I.~ , ,~ ~ .j 11 p 11 II i LAW OFFICES SNEL8AKER, BRENNEMAN & SPAn~E , II !1 I Iii Ii I r; f'l l):'ll_"_",,._ " ~ ,_ ,,~, . DEBORAH J. DAVIS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL V ANlA v. : NO. 00-2011 CIVIL TERM CIVIL ACTION - LAW ROBERT H. DAVIS, JR., Defendant IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYL V ANlA) SS. COUNTY OF CUMBERLAND ) Keith O. Brenneman, Esquire, being duly sworn according to law deposes and says: that he is a principal in the law firm of Snelbaker, Brenneman & Spare, P. c., being the attorneys for Deborah J. Davis, Plaintiff in the above captioned action in divorce; that on April 3, 2000, he did send to Defendant Robert H Davis, Jr. certified mail, return receipt requested, restricted delivery, a duly certified copy of the Complaint in Divorce which was filed in the above captioned action as evidenced by the attached cover letter of the same date and Receipt for Certified Mail No. 7099 3400 0004 5009 3089; that both the Complaint and cover letter were duly received by Robert H Davis, Jr., the Defendant herein, as evidenced by the return receipt card for said certified mail dated April 4, 2000; that a copy of the aforementioned cover letter dated April 3, 2000 is attached hereto and incorporated by reference herein as "Exhibit A" and that the original Receipt for Certified Mail and the Domestic Return Receipt are attached hereto and incorporated by reference herein as "Exhibit B"; and that the foregoing facts are true and I ~, I I fi i I, ~ I ~ ~ ~ ~ Ii I' ii I i " ~ I, i ~ I Ii " I LAW OFFICES SNELBAKER. BRENNEMAN 8: SPARE I ~" - correct to the best of his knowledge, information and belief. ,~ Keith O. Brenneman Sworn to and subscribed before me this II f day of April, 2000. ~,~~ -(~ Notary Public Notarial Seal Susan L. Zych, Notary Public Mechanlcsburg BOlO, Cumberland County My Commission Expires Nov. 24, 2003 1\1 r, Pe"nsylvanla Associallon of Notaries SNELBAKER BRENNEMAN (1 SPARE A PROFESSIONAL CORPORATION ATTORNEYS AT LAW 44 WEST MAIN STREET MECHANICSBURC. PENNSYLVANIA 17055 RICHARD C. SNEtBAKER KEITH C). BRE}lNEMAN PHILIP H spARE P. O. BOX 318 FACSIMILE (717) 697-7681 717-697-8528 April 3, 2000 Robert H. Davis, If., Esquire 112 Walnut Street Harrisburg, PA 17101 Re: Davis v. Davis No. 00-2011, C.C.P. Cumberland County, Pennsylvania Dear Mr. Davis: I am enclosing a certified copy of the Divorce Complaint, the original of which was filed on March 31, 2000. Yours truly, Keith O. Brenneman KOB/sz Enclosure CC: Deborah 1. Davis (w/enclosure) ,~ , I By certified mail, restricted delivery, parcel No. 70993400000450093089 EXHIBIT A -~"" ,.- --." , . LAW OFFICES SNELBAKER. BRENNEMAN & SPARE I 'ilJ!:,~",,~, I' .. - .. i I I I, I I' 11 " I! Ii IT" ... I::l m IT" o I::l Ll1 Postage $ Certified Fee 1.40 1.25 2.75 $ $''15-- .;r AE!tum Raceipt Fee' Q (EndorSementR.e?-Wred) ~ Restricted Delivery Fee E::I (Endorsement Required) o Q =r fTI Name (Please Print Clearly) (to be completed by mailer) IT" Iil.QP~IC'l;mH_~_,_J;!ay.i-5_'n_,J.r:A_#mEsq'~n:mmmnm Sl,Wt, N;Jt. No.; ,or PO Box No. ' IT" J1;2 Wal,nut Street. ' ~ -en;,~StBt8,.ziP+4----"**.*__'.h.'--___----------*"--_.._._--------------,-----"-"'....--. " 'irr:ril'PJIrg, P~ 17101 ;'. Total Postage & Fees , . '. '.' '. '". ~ __,'.'" c :"". "".__'_"___.,.''"....':.,"'''''''..'''.'''---.~ . " ~e items 1, 2, arid 3. Also complete . ill"" 4 ~ Restricted Delivery is desired. . flfitat your name and address on the reverse $0 1hjt. we can return the card to you. . Attache-- this card to the back of the mail piece, ,or en the front if space pennits. 1. Micle Addressed to: ~rt H. Davis, Jr., Esq. 112 ~a1nut Street Rar~isburg, PA 17101 3. Service Type .Certified Mail o Rf:lgistered o Insured Mail o Express Mail o Return Receipt for Me~hancliSe DC.D.D. 4. Restricted Delivery? (Extra Fee) . V;" 2. Arti~[e Number (Copy from service JabeQ 7099 3400 0004 5009 :!1J1l9 PS Form 3811 , July 1999 Domestic Return Receipt , 10259S-99-M-1789 EXHIBIT B '" I~ , -'~ -~" ,~ 9,..,~,'" ~ .",.,.,.. , ~ ~ o ~ (]fZ; r,'lh-., 2:1::.: ~~: ?i~; :00j -< ~~ ,._".7 , D C:Y ~, ':"'~I "" """"':.1 :.'2..] i\) -'1 ;-'1 ,'::~ ,'r ~, ::.::' .;.. " ';:_!.:! 6:-6 ~t -< --,:1 ~v i-".) (..::J I~~ , Theresa Barrett Male Supreme Court #46439 l1S Pine Street Harrisburg, PA 17101 (717) 233-3220 Counsel for Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DEBORAH J. DAVIS, Plaintiff v. NO. 00-2011 Civil Term ROBERTH. DAVIS, JR., Defendant CML ACTION - DIVORCE PRAECIPE To the Prothonotary: Please enter the appearance of Theresa Barrett Male, Esquire on behalf of Defendant in this proceeding. L Theresa Barrett Male, Esquire Supreme Court # 46439 115 Pine Street Harrisburg, Pennsylvania 17101 (717) 233-3220 Counsel For Defendant Date: April ll, 2000 ,71!! '--',. - ""~ . H_ .~ ... " ~," ~"~F1'" n' ~,,, ''Wl''-.'''' -""']1- ~_"fY , o ~ -0["' gI ~fj Z ef) ;:0;.:00: , r ~..".., 5c] ~{-) p<,-= ~ a c:; ~ ~o ::C:J o ~1'1 " ;"- ",jl"':"1 -bc'J ~~~6 ~),~ :o:::;rn ~ ~ -< +'0 :~ ':"? ,,-, U1 ~ Fi1!1'~~~~~iI!!WI~!ll~,"'.~",'~' /f~1!"