The URL can be used to link to this page

Home My WebLink About00-02077 ". ,,' J' ."", ",~--,' '.'-"--.',-- "\';';1",--"- '-"\j .\....'.:" "~.~":<.;' :'~.~4!:'.;"":.~~,~,,,.~,,,,.,,,-~.,:_,,t'''.~''''~-''.''--.'~'''TP.'~'"."4~~"''--'~~""""""-,-__",,, ',......,.<,..'.....,',''''"'...--.,~.,,....--.,'''<-......,',''''','..4...,"'.'.....",'~...$,:-,;__..~..,_:.",_..~",.. , . .. .' . .,.~ i,....", ",,', ','" ... ",'.'" ".",0.'" ",-",.-','" ",,-,,,,'..., "M,-;"..._,'..'"',.._:">.,",......i,"""~~,,,."._i!",,',........i.';-','...._.., "'_0;, "._i.';-;'...._.,,:'~._i.'. ,....._" .'........i."",.':,...._"""'...__<<'~':...__~,;.~...~:It.::c:<'''::.ar~,,<~.._~~''''..<!J'.:-4_ 8 . '''' 'H' ,... '''. .", ,., 'H' " " . , . ,"". ,'. "'/"'~'."'""""" ...'" "-~"I n ~.. ~ IN THE COURT OF COMMON PLEAS ~ ~ I I ~.~ ~ ~~ I :,-':: ~.~ , ;", S t"; ~ " ,'0, ~ I ~.~ ~ i . y4&;;:.::_!,,,::~4E.,,:":.2t::.;,:\,, ~.,~ ~ .,.", W \l'.~ a \l'.~ ~ ~":~ ~ ~..'~ ~ 8 ~ ~ ",,- ~ ~.~ ~.~ I \~ ~ ~.~ ~ \l'.~ ~.,., W N ~ t ~i ~ ~'" I ~~~ ~ ~.~ I u k; ~ t.,; .,." M /'i ~~~ ~ ",,' i! ~ ~.~ ~ t.,,; OF CUMBERLAND COUNTY STATE OF PENNA. ,.!l,J;:!3J;:c:c:i\..~....Il~()~J;:~LL N o. ,JQ,Q,Q,7.~Q.v ,......,........,x~ ~~~ ~ a ~.~ ~ ; I ~.~ ~ ~ DECREE IN ~.~ ;': it) , D I V 0 R C E ~ ~ ~ SS-t't1. ~ I!t 'jct ~ d d d a AND NOW,. ,., '" ,~.......,.,' ",..., it is or ere an ~.~ w ~.; decreed that"""" ,.. .~~~~~~~,~~,~~?~~~~~"""""".., plaintiff, ~ ~.~ ~ and "", , , . , , , , , , , , , , , , , , , ,W.IJ...,L,I.A!'\ ,J, ,B.R,O.l'!N:E.\'!E,L,L, , . . , , , , , , , , , " defendant, "~oj ~ ~.~ ~.'~ ~ f"'i ~~~ ~ u".P la.in:li.i.f,L....... Versus ..W.I,~g!\l1.. J:.',Il~()~J;:~J:.J:. m..."..Def,endant.... 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; The Marital Settlement Agreement of the parties dated May 14, 2001 ................................................ .........................., filed herein is incorporated herein by reference, but not merged , , , . . , , . , , 'wifli 'fli;:.; 'decree: ' , , . , , , , , , , , , , , . . , . . . , , , , , , , , , , , . , , . , . , . , , . , , , , ,', ~ ~ ~.~ ~ ~... ~ ::.::.~~:::::-..::.x ::~::.::.-, >::.::.;: ::~::.::~ ::;.::.;':. ,:-.::.::~,,: ::.::.::~':: :~'::.::"" .::.::.:; ~~ '3C{'::.:c.;:: :'.::+::.;,. :::.:c( :':.::+>:,:':,.::<<< ':.~.::~;;::::.::.::< -".::+::':::" .:+::< :'.:.::.". ~ i ~~ i ~.~ ~ ,~ .', ~ ~ 'd j ~.~ ~.~ I ~ ~ ~.~ i ~.~ ;.~ ~ ~ ~.~ > i'.' ~ ;.~ ~ ;o~ ~ ..-' ::; .~tJl S';;,s---t:)! '1'!llllIJ!I! " ~~~ '''Il-~' !lHl8!'1JI!!1lII! o~_ ~ ~ - M~~$4~ 'YIA0 ~ ?ff 1//. """ ,~~~,~ ,_.- ~'. '" ~~~~!'iWllI!l~_=~__. " .,..,tm ~ , '" ............~ ~""...,J~" ~"~~'. '. REBECCA S. BROWNEWELL Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : NO. 2t.W- c.b7tIVIL TERM : IN DIVORCE WILLIAM 1. BROWNEWELL Defendant MARITAL SETTLEMENT AGREEMENT AGREEMENT, made this -.-r:L day of _fVl", 1r ,2001, between REBECCA S, BROWNEWELL (hereinafter called "Wife") and WILLIAM 1. BROWNEWELL (hereinafter called "Husband"), WITNESSETH: The parties hereto are Wife and Husband, having been married on October 11, 1985, at Newville, Pa, There were no children born of this marriage. Diverse unhappy differences, disputes and difficulties have arisen between the parties and it is the intention of Wife and Husband to live separate and apart for the rest oftheir natural lives, and the parties hereto desire to settle fully and finally their respective financial and property rights and obligations as between each other, including without limitation: (1) the settling of all matters between them relating to the ownership of real and personal property; (2) the settling of all matters between them relating to the past, present and future support and/or maintenance of Wife by Husband and of Husband by Wife; and (3) in general, the settling of any and all claims and possible claims by one against the other or against their respective estates, --~~=~ ',"'lL "'1"'1'''11,' ~,t.l.iW~~i~I,"~~':- ;.=i"=~ - ~ .w""-,oiI",,,,!.il '. '. NOW mEREFORE, in consideration of the premises and of the mutual promises, covenants and undertakings hereinafter set forth and for other good and valuable consideration, receipt of which is hereby acknowledged by each ofthe parties hereto, Wife and Husband, each intending to be legally bound hereby, covenant and agree as follows: 1. ADVICE OF COUNSEL Wife and Husband declare that each has had a full and fair opportunity to obtain independent legal advice of counsel of her and his selection; that Wife has been independently represented by Taylor p, Andrews, Esquire, and that Husband, aware of his right to legal representation, declares that it is his express, voluntary and knowing intention not to obtain counsel and he chooses instead to represent himself with respect to the preparation and execution of this Agreement. 2. PERSONAL RIGHTS Wife and Husband may and shall, at all times hereafter, live separate and apart. Each shall be free from all contro~ restraint, interference or authority, direct or indirect, by the other in all respects as fully as if she or he were umnarried, Each may reside at such place or places as she or he may select. Each may, for her or his separate use or benefit, conduct, carry on and engage in any business, occupation, profession or employment which to her or him may seem advisable, This provision shall not be taken, however, to be an admission on the part of either Wife or Husband of the lawfulness of the causes which led to, or resulted in, the continuation of their living apart, Wife and Husband shall not molest, harass, disturb or malign each other or the respective families of each other, nor compel or attempt to compel the other to cohabit or dwell by any means or in any manner whatsoever with her or him. ~ 1~1IiIlI_'" ~~V . ~ ,., ' u_ '0 ......"-~~ 1~l<tiil.fll;]~Mlt<d-i ., 3. PERSONAL PROPERTY The parties acknowledge that they have heretofore divided between them, at the time of their separation, all their personal property to their mutual satisfaction, except as otherwise stated. Henceforth, each of them shall own, have and enjoy independently of any claim or right of the other all items of personal property of every kind, now and hereafter owned, or held by him or her, with full power to dispose of same as fully and effectively in all respects and for all purposes as ifhe or she were unmarried. To compensate for the value of the property retained by Husband, Husband shall pay Wife Twenty thousand ($20,000) dollars at the time of settlement on the sale of 120 S, High St., Newville [Currently scheduled for May 15, 2001]. Wile explicitly hereby waives and releases any claim that she may have to the following / property of Husband: IRA at F&M Trust Bank 401 (k) at One Valley Bank 1988 Cadillac 1973 Dodge Truck 1990 Chevy Van 1977 Motorcycle 1953 Willies Classic Husband explicitly hereby waives and releases any claim that he may have to the following property of Wife: IRA at F&M Trust H&R Block business 3 - I ~ " :jci_i&ili~jlilljJ~0! ., 4, REAL PROPERTY Husband hereby agrees to convey, transfer and grant to Wife his right, title and interest in the real estate situated and located at 21-23 S, High St, Newville, Pa, free and clear of any debt for mortgage, taxes, or utilities, This transfer shall be completed within 30 days of this agreement. Husband agrees that his share of the proceeds of the sale of 120 S, High St., Newville, PA shall be held in escrow by Husband's attorney to assure the availability of the funds to enable Husband to pay off the mortgage, taxes or utilities on the property at 21-23 S. High St., Newville, PA as per this section of this agreement. The proceeds my be released from escrow and paid to Husband when Husband has paid off the balance of the mortgage, taxes, and utilities on the property at 21-23 S. High St., Newville, PA. Husband also hereby assigns to Wife all insurance claims for damage to the property at 21-23 S. High St., Newville, and Husband shall take all required action to process damage claims on the insurance, and he will endorse any insurance claim check to Wife's benefit. Wife hereby agrees to convey, transfer and grant to Husband her right, title and interest in the following real estate: Lot #2, Springview, Newville, Pa. 110 E. Main St., Newburg, Pa, 765 Grahams Woods Rd" ~e, Pa, lJewvllle f?,S!3 v / lJ - From the date ohhis Agreement, Husband agrees to assume as his sole obligation any and all mortgage payments, taxes, claims, damages or other expenses incurred in connection with said premises, and Husband agrees and covenants to hold Wife harmless from any such liability or obligation. q . ~ ._~ , ""'li~,.jj",;;;\JIi4,1 Wife shall transfer her interest in the above listed properties when Husband shall have secured Wife's release from all mortgage financing for all of the properties by way of a release from the mortgagees or by way of a refinancing, This shall occur within 90 days of the date of this agreement. If Husband shall not have secured Wife's release from all the mortgage financing referenced herein within 90 days of the date of this agreement, Husband shall list for sale with a realtor selected by Wife such properties as Husband shall select and which shall enable Husband to secure Wife's release from all the mortgage financing referenced herein within 60 days of the completion of the sale of property, Properties selected for sale shall be listed for sale at a price that shall not be greater than the most recent County tax assessment of the properties. Husband shall maintain the listing of the properties for sale until they sell, or until Husband successfully secures Wife's release from all the mortgage financing referenced above. Each party shall be responsible for the preparation of all deeds to be received by the party and all mortgages given by the party to perform this agreement. Each party shall be responsible for the recording costs of the deed that is received by the party. 5, SUPPORT AND ALIMONY Husband and Wife do hereby waive, release and give up any rights they may respectively. have against the other for alimony, support or maintenance. It shall be, from the date of this Agreement, the sole responsibility of each of the respective parties to sustain themselves without seeking any support from the other party, 5 ""- "" _~!4!,,,",ilfll,' 6. LIABILITIES Wife and Husband each covenant, warrant and represent and agree that each will now and at all times hereafter save harmless and keep the other indemnified from all debts, charges and liabilities incurred by the other prior to or after the effective date of this Agreement, except as may be otherwise provided by the terms of this Agreement. During the course of the marriage, Wife and Husband incurred certain bills and obligations and amassed a variety of debts, and it is hereby agreed, without the necessity of ascertaining for what purpose and to whose use each of the bills were incurred, that Husband shall be responsible for all bills, obligations and debts arising from the marriage which were incurred prior to November 3, 1999, Husband explicitly hereby accepts responsibility to pay the debt to Fleet [account #5491-0000-7542-2258] [approximate balance: $9,000], and to indemnify Wife and hold W1fe harmless from any expense or loss related to the debt. 7. LEGAL FEES Wife and Husband each agree to be responsible for her or his own legal fees and expenses. 8, DIVORCE Husband and Wife shall each sign an affidavit of consent and waiver of notice for the entry of a divorce decree at the same time that they shall each sign this agreement, Neither Husband nor Wife shall assert any claims for equitable distribution of marital property, costs, attorney fees, alimony, or alimony pendente lite in the above captioned action because all such claims are resolved by the terms of this agreement. This agreement shall be incorporated into the Divorce Decree between the parties, but shall not be merged with the decree. 6 I ~ _,J", -"_I...:J&hi~, 9, MUTUAL RELEASE Wife and Husband each do hereby mutually remise, release, quitclaim and forever discharge the other and the estate of such other, for all time to come, and for all purposes whatsoever, of and from any and all rights, titles and interests, or claims in or against the property (including income and gain from property hereafter accruing) of the other or against the estate of such other, of whatever nature and wheresoever situate, which she or he now has or at any time hereafter may have against the other, the estate of such other or any part thereof, whether arising out of any former acts, contracts, engagements or liabilities of such other or by way of dower or curtesy, or claims in the nature of dower or curtesy or widow's or widower's rights, family exemption or similar allowance, or under the intestate laws, or the right to take against the spouse's will; or the right to treat a lifetime conveyance by the other as testamentary, or all other rights of a surviving spouse to participate in a deceased spouse's estate, whether arising under the laws of (a) Pennsylvania, (b) any State, Commonwealth or territory of the United States, or (c) any other country, or any rights which Wife may have or at any time hereafter have for past, present or future support or maintenance, alimony, alimony pendente lite, counsel fees, costs or expenses, whether arising as a result of the marital relation or otherwise, except, and only except, all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any thereof. It is the intention of Wife and Husband to give to each other by the execution of this Agreement a full, complete and general release with respect to any and all property of any kind or nature, real, personal or mixed, which the other now owns or may hereafter acquire, except and only except all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any 7 ;1i!!J[,! thereof, subject, however, to the implementation and satisfaction of the conditions precedent as set forth herein above, 10, OTHER DOCUMENTATION Wife and Husband covenant and agree that they will forthwith (and within at least ten days after demand therefor) execute any and all written instruments, assignments, releases, satisfactions, deeds, notes or such other writings as may be necessary or desirable for the proper effectuation of this Agreement, and as their respective counsel shall mutually agree should be so executed in order to carry out fully and effectually the terms of this Agreement. 11, SUCCESSORS' RIGHTS AND LIABILITIES This Agreement shall, except as otherwise provided herein, be binding upon and inure to the benefit of the parties hereto, their respective heirs, executors, administrators, successors or assigns. 12, ENTIRE AGREEMENT Wife and Husband do hereby covenant and warrant that this Agreement contains all of the representations, promises and agreements made by either of them to the other for the purposes set forth in the preamble hereinabove; that there are no claims, promises or representations not herein contained, either oral or written, which shall or may be charged or enforced or enforceable unless reduced to writing and signed by both of the parties hereto; and the waiver of any term, condition, clause or provision of this Agreement shall in no way be deemed to be considered a waiver of any other term, condition, clause or provision of this Agreement. 8 - ' I., . , , .,-' ~ -" 1lI,'Ii'U~ 13, BINDING EFFECT OF AGREEMENT This Agreement shall remain in full force and effect unless and until terminated pursuant to the terms of 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, This agreement shall be fully enforceable at law or in equity, without limitation in accordance with Pennsylvania law. If a party must seek a remedy through Court action, such party shall be entitled to receive reasonable counsel fees as part of his or her relief if the other party is found to have breached this agreement. 14, SEPARABILITY If any term, condition, clause or provision of this Agreement shall be determined or declared to be void or invalid in law, or otherwise, then only that term, condition, clause or provision shall be stricken from this Agreement and in all other respects this Agreement shall be valid and continue in full force, effect and operation, Likewise, the failure of any party to meet her or his obligations under anyone or more of the paragraphs herein, with the exception of the satisfaction of the conditions precedent, shall in no way avoid or alter the remaining obligations of the parties, 9 ,,-~~~ - -'". , ~^ --. -~--"<' 15, NOTICE PROVISIONS (a) Notice to Husband shall be sent by regular first class mail, to 762 Grahams Woods Rd.., Newville, Pa. 17241, or such other address as Husband from time to time may designate in writing, (b) Notice to Wife shall be sent by regular first class mail, to 21 S, High St., Newville, Pa, 17241, and to Taylor P, Andrews, Esquire, at 78 W, Pomfret St" Carlisle, Pa, 17013, or such other address as Wife from time to time may designate in writing, 16, HEADINGS Any headings preceding the text of the several paragraphs and subparagraphs hereof are inserted solely for convenience of reference and shall not constitute a part of this Agreement nor shall they affect its meanings, construction or effect, 17. EFFECTIVE DATE The effective date of this Agreement shall be the date upon which it is executed; however, the transfer of the property provided for herein shall only take place upon the entry of a final decree in divorce, unless otherwise indicated. 18, CONTROLLING LAW This Agreement shall be construed in accordance with the laws ofthe Commonwealth of Pennsylvania, ID 0"",""",""""",, ~~ ~~ I Wlt,t'il IN WITNESS WHEREOF, the parties hereto have set their hands and seals the day and year first above written. This Agreement is executed in duplicate, and in counterparts, and Wife and Husband, as parties hereto, acknowledge the receipt of a duly executed copy hereof ~f3a S&(i'<J~-d/ Rebecca S, Brownewell, Wife k2~~~ ~ William J. B ownewell, Husband ""'-- COMMONWEALTH OF PENNSYLVANIA ) : SS, COUNTY OF CUMBERLAND ) On this, the I L/ day of (\'\:1: ,2001, before me, the subscriber, a Notary Public for the Common ealth ofPennsylvarua, resldmg m the County of Cumberland, personally appeared Rebecca S. Brownewell and in due form oflaw acknowledged the above Agreement to be her act and deed and NOTARIAL SEAL SHELLY SEXTON. NOTARY PUBLIC CARLISLE BORO. CUMBERLANO COUNTY MY COMMISSION EXPIRES APRIL 26, 2003 Member, Pennsylvania Association 01 Notaries Notary Public 11 j IIilll*k COMMONWEALTH OF PENNSYL VANIA ) : SS, COUNTY OF CUMBERLAND ) On this, the I Y day of _vY\6\.LI ,2001, before me, the I subscriber, a Notary Public for the Commonwealth of Pennsylvania, residing in the County of Cumberland, personally appeared William 1. Brownewell and in due form oflaw acknowledged the above Agreement to be his act and deed and desired the same to be recorded as such, NOTARIAL SEAL SHELLY SEXTON, NOTARY PUBLIC CARLISLE BORO, CUMBERLAND COUNTY MY COMMISSION EXPIRES APRIL 26, 2003 Member, Pennsylvania Association of Notaries (SEAL) 12 d:~H, - ~" - U~ J..~.III~ U"~ll!tIllll!ili!liillLfld Mol "' ,< -~~HIIIili_ '0 C ~ ...., -oCLI rnr"'1 ~::::J.:) -;7 ( ~,~C: (;2 C~ j2 ~ c:; . .....-- ~---.". ~.--<. " "" ~~ C:'" '-) " ' '-----c; -0 --~'" -:--_:;"n l.,__~ ::p: <J:J: =< r.- ,0 , _.,_~O' = ~til>-r lllli:iUi ~ "~ J""" ~~~__.~ :~ ~1,._"'" REBECCA S. BROWNEWELL Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW WILLIAM J. BROWNEWELL Defendant : NO. 2000-2077 : IN DIVORCE CIVIL TERM PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a divorce decree: I, Ground for div,orce: irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: April 7,2000 by restricted delivery, certified return receipt requested, 3, (a) Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by the Plaintiff May 14, 2001; by Defendant May 14,2001. 4, Related claims pending: None 5, Date Plaintiffs Waiver of Notice III ~3301(c) Divorce was filed with the Prothonotary: filed herewith Date Defendant's Waiver of Notice in ~3301(c) Divorce was filed with the Prothonotary: filed herewith Tay, r , An ews, Esq, 7 t Pomfret Street sle,PA 17013 (717) 243-0123 Supreme Court ID No. 15641 Date: May 16, 2001 By: iiii[lii(i ~iImiii..MlI ".""'jriil!lli.~;~ - o. .~'~MMOil 'l;L,.idi.~' " '" ' " ~ - -.~ ~- 0 a n .., C -,'r ~ :::r: (Jet' }':'" rnfT; -< --1 r':.~ Z:X) ;!, ~:~' COj '.-., :-(..::, ,j 9 ~C..: :S? ~:=2 ;!? zQ '" -..u ~nl ;Pc: ~ \:"'1 :a -<; -<; ~1fIl ~- i ~li<\-,i II i1 I II :1 il ;1 ,I " II ! REBECCA S. BROWNEWELL Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW ; NO.aoo::>- ~D77CIVIL TERM : IN DIVORCE WILLIAM J, BROWNEWELL Defendant 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 the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, High and Hanover Streets, Carlisle. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Phone: (717) 249-3166 '2;~~-' -'''-" ~- " " . i~U REBECCA S. BROWNEWELL Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, : CML ACTION - LAW WILLIAM J. BROWNEWELL Defendant : NO. tJV _.1-077 CIVIL TERM : IN DIVORCE COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Rebecca S, Brownewell, who currently resides at 332 1/2 East King Street, Shippensburg, Cumberland County, Pennsylvania, since November 3, 1999, 2. Defendant is William J. Brownewell, who currently resides at 120 South High Street, Newville, Cumberland County, Pennsylvania, since October 1991. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on October 11, 1985, at Newville, Cumberland County, Pennsylvania, 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 6, The marriage is irretrievably broken, 7. 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, 8, Plaintiff requests the Court to enter a Decree of Divorce. . =- - "~~~-~ , , -, ~-~~..i' :iw.t:IiIl!ful:fh': I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S, 94904, relating to unsworn falsification to authorities. Date: t-J /5 JotJ I I ~t!-1'1l C, &rw7'u,u",,-U Rebecca S. Brownewell, Plaintiff ANDREWS & JOHNSON By: ylor P, Andrews, Esquire ~ttorneys for Plaintiff 78 W, Pomfret Street Carlisle, PA 17013 (717) 243-0123 .~Ji.'--'~ . ""'"'".."- ~ - - ....~""--';Y~--i REBECCA S, BROWNEWELL Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW WILLIAM J. BROWNEWELL Defendant : NO, 2000-2077 : IN DIVORCE CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 330 1 (c) of the Divorce Code was filed on April 5, 2000. 2, The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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. S 4904, relating to unsworn falsification to authorities. Date: til;/o) I I ~kcca S &-w~ Rebecca S, Brownewell, Plaintiff ......,-< "~~~."-""","""",,ill""iidlilll"'-""'" ~!UIl~Il!!~~illRlilllii.ii~ "" ,= il -~ b.. - ~" .('") 1::':;\ <:-) C s: ',-, U [r-' :::r: n"fr-::': ,1::cr~ ~"'- 2:: -, ._.;: 0~:' , .~"l 0-, ...c~ r:::c:: r"-, ',--'" ,~ ::'2 " ~(~ " ,") c-') "b C__J .;> .-c "'-'0; )Ti '-' 2:: :--i =< ::'71 .;~ 0 CD -< I 2'" "" ,~ ~-" -, , - ---, ,~ -- ~ ..~''''-'- [,8 . REBECCA S. BROWNEWELL Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, : CIVIL ACTION - LAW WILLIAM J. BROWNEWELL Defendant : NO. 2000-2077 : IN DIVORCE CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 330 1 (c) of the Divorce Code was filed on April 5, 2000. 2, The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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, S 4904, relating to unsworn falsification to authorities. Date: 5- / 'f~ ~ / fhni: I~; j' ~~-.-illlilO'o-~~\ii!lilUlI~~'"""~"-"'. liiill..lslliilil~-,",~""""-'-'~""'liIIIllfjll! ~ ~w~~_ .l!IlIili!1lIl.-.w~' .~- 0 0 S c: :;;:.-'<" -U -, -~ C'-' ._i'<. ~~i :~.:." -,~ ~~-~ Chi ?(-.-- '~i Z',,' :317: 5>0 C ,~ ~ <- :,n Si :< a ::a -< , ........ T - ==,", :ililrI~' ~ REBECCA S, BROWNEWELL Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, : CIVIL ACTION - LAW WILLIAM 1. BROWNEWELL Defendant : NO, 2000-2077 : IN DIVORCE CIVIL TERM 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! 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: s:- /;/~o / ~~ ;A . ............ "- William 1. Br wnewell, Plaintiff -~; ......._'*___~iiIi;io'~ !I!IIlII hil!illlIm~P'lI1iJll<I l~_.IilIili. 'iiKl~lll RIII'~1-'''''-.~''~!lIillll'iltii'~ .......;.. -. 0 c:~ LJ c: ,--. -r'; ~ :r: -v-c,n >~-'--" rnr:-; -"":' --/'T, ~~~', G r;; C~ 4") <- -~ "'--""1 ....~ -Zt..- :~-:.; -=0 - ,-, ):> -'- --, ~'" ;S ~ :Jl -<. . ,~- -~ ~~=. -- - ~- '-"J!ijlki\-. REBECCA S, BROWNEWELL Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : CIVIL ACTION - LAW WILLIAM J. BROWNEWELL Defendant : NO. 2000-2077 : IN DIVORCE CIVIL TERM 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! 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: ~/;c//OI ~(!C1S~~ Rebecca S. Brownewell, Plaintiff ..~ ~ilIlillIiII~l!'rMI ._~~-"~ ~ M~ M"_ ,~ ..~J ,~, ~llli_~lti1!i!1!: lli~iilJl-'" " -." ~- ""~ " ~liiMI/di L "'" "",_ 'c_ o c ~~, i~ ~'O '2..c, ,~-'c' 'PC ~ -<. o - -::-~ ~, .:~.:.: .1 '~ -~ - v' -,',..) ''0 "; !----. .-~,:s '"',(, :~~~, ~ -<. "~,,- ~. So ,- rn ,._i ~~ , , .....iJJ, REBECCA S. BROWNEWELL Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, : CIVIL ACTION - LAW WILLIAM 1. BROWNEWELL Defendant : NO. 2000-2077 : IN DIVORCE CIVIL TERM AFFIDAVIT OF SERVICE COMMONWEALtH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND ) AND NOW, this A- day of May, 2001, I, Taylor p, Andrews, Esquire, attorney for Rebecca S. Brownewell, Plaintiff in the above-captioned action, hereby swear that I have served a true copy of the Complaint in Divorce, with Notice to Defend and Claim Rights, executed by the Plaintiff in the above-captioned matter, upon the Defendant at his residence at 120 South High Street, Newville, Pennsylvania, 17013, by depositing the same in the U.S. Mail, postage prepaid, certified, deliver to addressee only, return receipt requested. A copy of the return receipt card signed by the Defendant on April 7, 2000, indicating service was effected, is marked Exhibit "A", attached hereto and made a part hereof. By: lor P. Andrews orney for Plaintiff Sworn and subscribed to before me this PI <!' day of May 2001. ~"u/~ If-~ Notary Public NOTARIAL SEAL BRENDAL. BREHM, NOIaIy Public CarlisleBorougb, Cumberland Coumy My Commiuion~J811. 6, 1014 , . . ~ SENDER: " ;; .. Ie !l !! .. S I also wish to receive the fallow- ing services (for an extra fee): o Complete items 1 and{or 2 for additional services. Complete llems 3, 4a,-aflct 4b. o Print yollr name pnd aCldress on the reverse of this form so that we can relum this card to you. e Attach this form to the front of the mailpiece, or on the back if space dQes ru:rt permi::-: o Write -R91um Aecsipt Requested" on '\he mailpiece below the article number. c:. lJThe Return Receipt will show to' whom the article was delivered and the date o delivered. al 3, ArtiCllI !>.<ldressed 10: 1; a E o u 1. 0 -Addressee's Address William J. Browne.we.ll 1~ South High Stre.e.t N~ille., PA 17241 4b. Service Type D Registered D Express Mail Return Receipt for Merchandise )g Certified D Insured DeOD -~.'.'''''- ~:' .~ ~ ,. . .. 102595-99-e..o223 Domestic Return Receipt Exhibit A ',' i" ~~ .,~, ;r~ """;: .. Ul 1: .. g II: c 5 1il II: Cl c 7ii ~ .E ~ o ,.. ... c .. .r:: I- :1-; t 1'_, ,U ",j I" ,',\ I!: 11;\ li,i I!' I"~ ii , ',' ii,; ii '! 1iiI';d",~if ,- 'l?':<,,-_,. ,,,', ,.,," -~_iIlIidlii~jjllllll!li~~~,L,.'"""""""Ji!il,,"_. .'-;~ .... O~ .,,1 "~_lii.....k.~~. - -' .~I-- o c s: '"001 ~gj 2,.,-- 0.1> ~- 2' -i -< ,. - ., t:_~ 5 "; c' ,--:---,--, '0 :--':;;:'(~' r',"-:;rn -' ::i;,! 'iJ -< ~ "' ~ - I, ''"',~~ ,--- ~ .--- .~ REBECCA S, BROWNEWELL Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v, : CIVIL ACTION - LAW WILLIAM 1. BROWNEWELL Defendant : NO. 2000-2077 : IN DIVORCE CIVIL TERM NOTICE OF ELECTION TO RETAKE MAIDEN NAME Notice is hereby given that Rebecca S, Brownewell, the Plaintiff in the above matter, hereby elects to retake and hereafter use her previous name of Rebecca S, Clugston. ~cca '5 &1JJ1;~ Rebecca S. Brownewell TO BE KNOWN AS: ~45~+OyU Rebecca S, Clugsto COMMONWEALTH OF PENNSYLVANIA ) : SS. COUNTY OF CUMBERLAND ) On the 14th day of May, 2001, before me, a Notary Public, personally appeared Rebecca S. Clugston, known to me to be the person whose name is subscribed to the within document and acknowledged that she executed the foregoing for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. NOTARIAL SEAL SHELLY SEXTON, NOTARY PUBLIC CARLISLE BORO, ClIMBERLAND COUNTY MY COMMISSION EKPIRES APRIL 26, 20113 Member, Pennsylvonia Association ot Notaries 0: .1Ii~r-J :i, ''"'''''''_Iiii___Ili;UM~~4<!o'iliilIi- -'.~_lJl b'~_C I......,' .,. _iIlilIIilillll ~~ ~ ~~ E ~ "it ~ 'C ~ ~ ~ '" t .,.. ~ :! <.1\ ~ - o c: -.-. :."" -rJr"i'f QJtjj .z~' ~~~- kC-:/ ~B .... :z ~ - "~ ,~--- ~- '0 ;;; ,- -" :::::", ,-< t"'" - ' ,- :~sj '_.,.' (n., --1<,.-' -,-"-r, ::s ~r;i~ ,-, ~n (.:J - ' :J:J -<