HomeMy WebLinkAbout00-02394
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF
PENNA.
.
KATHLEEN A. MASLAND,
Plaintiff
NO.
00-2394
VERSUS
DAVID S. MASLAND, JR.,
Defendant
DECREE IN
DIVORCE
AND NOW,
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DECREED THAT
Kathleen A. Masland
PLAINTIFF,
AND
David S. Masland, Jr.
, DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED; None
The attached Property Settlement Agreement is hereby incorporated, but
not merged, into this Decree in Divorce.
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PROTHONOTARY
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PROPERTY SETTLEMENT AGREEMENT
THIS AGREEMENT, made this /&J day of J/dJJ-fJ€Jr...J , 2001, by and
between DAVID S. MASLAND, JR., hereinafter called "Husband", and KATHLEEN A.
MASLAND, hereinafter called "Wife".
WITNESSETH:
WHEREAS, Husband and Wife were legally married on June 14, 1997;
WHEREAS, differences have arisen between Husband and Wife in consequence of which
they desire to live separate and apart from each other; and
WHEREAS, Husband and Wife desire to settle and determine their rights and obligations.
NOW THEREFORE, in consideration of the premises and covenants contained herein, it is
agreed by and between the parties hereto that:
1. flF-PARATION.
It shall be lawful for each party at all times hereafter to live separate and apart from each
other at such place as he or she from time to time shall choose or deem fit. The foregoing provision
shall not be taken as an admission on the part of either party of the lawfulness or unlawfulness of
the causes leading to their living apart.
2. INTERFERENCES.
Each party shall be free from interference, authority and control 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 or attempt to endeavor to molest the other, or in any way
harass or malign the other, nor in any other way interfere with the peaceful existence, separate and
apart from the other.
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3. DMSION OF REAL PROPERTY.
The real estate owned by Husband located at 72 Zion Road, Carlisle, Cumberland County,
Pennsylvania shall remain his sole and separate property. Wife acknowledges that she has no
claim, right, interest, or title whatsoever in said property and agrees never to assert any claim to said
property in the future.
4. DMSTON OF PERSONAL PROPERTY.
The parties have divided between them to their mutual satisfaction, personal effects,
household goods and furnishings and all other articles of personal property which have heretofore
been used in common by them, and neither party will make any claim to any such items which are
now in the possession or under the control of the other with the exception of the following:
A. Wife shall retain as her sole and separate property, two Browning 425 Shotguns, serial
numbers 07766NTK13 and 02898NTK13, and the Sandpiper Print.
B. Husband shall retain as his sole and separate property, the Golf Cart Trailer. Wife will
execute title to the trailer at the time of the execution of this Agreement.
Should it become necessary, each party agrees to sign any title or documents necessary to
give effect to this paragraph, upon request.
Upon delivery to Wife of the Browning shotguns referred to in subparagraph A hereof,
Wife shall be solely responsible for the guns and shall forever release Husband of any responsibility
related thereto and shall indemnify and hold Husband harmless relating to the saidguns in the
future.
5. APPLICABILITY OF TAX LAW TO PROPRRV TRANSFERS.
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
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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.
6. BREACH.
If either party breaches any provision of this Agreement, the other party shall have the right,
at his or her election, to sue for damages for such breach. The party breaching this contract shall be
responsible for the payment of legal fees and costs incurred by the other in enforcing his or her
rights under this Agreement, or seeking such other remedy or relief as may be available to him or
her. The parties specifically acknowledge that they are entitled to utilize the remedies as set forth in
the Divorce Code of 1980, as amended.
7. FULL DISCLOSURE.
Husband and Wife each represent and warrant to the other that he or she has made a full and
complete disclosure to the other of all assets of any nature whatsoever, and of all other facts relating
to the subject matter of this Agreement to which such party may reasonably require to make an
informed decision regarding this Agreement.
8. ADDITIONAL INSTRUMENT.
Each of the parties shall on demand execute and deliver to the other any deeds, bills of sale,
assignment, consents to change of beneficiary on insurance policies, tax returns and other
documents and do or caused to be done any other act or thing that may be necessary or desirable to
the provisions and purposes of this Agreement. If either party fails on demand to comply with this
provision, that party shall pay to the other all attorneys' fees, costs and other expenses reasonable
incurred as a result of such failure.
9. WIFE'S DEBTS.
Wife represents and warrants to Husband that since the parties' 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.
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10. HUSBAND'S DEBTS.
Husband represents and warrants to Wife that since the parties' 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.
11. WAIVERS OF CLAIMS AGAINST ESTATES.
Except as otherwise provided herein, 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, curtsy,
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, and each will, to the
request of the other, execute, acknowledge, and deliver any and all instrwnents which may be
necessary or advisable to carry into effect this mutual waiver and relinquishment of all such
interests, rights and claims.
12. REPRESENTATION.
It is recognized by the parties hereto that Husband is represented by John J. Connelly, Jr.,
Esquire, and Wife is represented by Gail Guida Souders, Esquire. It is fully understood and agreed
that by the signing of this Agreement, each party nnderstands the legal impact of this Agreement
and further acknowledges that the Agreement is fair and reasonable and each party intends to be
legally bound by the terms hereof.
13. V!>LUNTARY EXECUTION.
The provisions of this Agreement are fully understood by both parties and each party
acknowledges that this Agreement is fair and equitable, that it is being entered into voluntarily and
that it is not the result of any duress or undue influence.
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14. 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.
15. PRlOR AGRERMENT.
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.
16. MODIFICATION AND WAIVER.
Any modification or waiver of any provision 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.
17. GOVERNING LAW.
This Agreement shall be governed by and shall be construed in accordance with the laws of
the Commonwealth of Pennsylvania.
18. INDEPENDENT SEP ARA TE COVENANTS.
It is specifically understood and agreed by and between the parties hereto that each
paragraph hereof shall be deemed to be a separate and independent covenant and agreement.
19. vom CLAUSES.
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.
20. ENTRY AS PART OF DECREE.
It is the intention of the parties that this Agreement shall survive any action for divorce
which may be instituted or prosecuted by either party and no order, judgement or decree of divorce,
temporary, :final or permanent, shall affect or modify the financial terms of this Agreement. This
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Agreement shall be made a part of, but shall not merge with, any such judgment or decree of final
divorce.
21. DIVORCE ACTION.
The parties shall, at the time of the execution of the Agreement, execute documents
necessary to finalize the divorce action including, but not limited to, the withdrawal of any claims
pending under said action, indexed to number 00-2394 Civil Term, in the Court ofConnnon Pleas,
Cumberland County, Pennsylvania, as well as Affidavits of Consent and Waivers of Counseling
and Waivers of Notice of Intention to Request Entry of a Divorce Decree.
22. DOMESTIC RELA nONS CODE OF THE COMMONWEALTH OF
PENNSYLVANIA.
Except as specifically provided in this Agreement, each party waives any claim they may
have against the other under the Domestic Relations Code of the Connnonwealth of Pennsylvania
including, but not limited to, alimony, alimony pendente lite, counsel fees, costs and equitable
distribution of marital property.
IN WITNESS WHEREOF, the parties hereto, intending to be legally bound hereby, have
hereunto set their hands and seals the day and year first above written.
WITNESS:
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COMMONWEALTH OF PENNSYLVANIA
COUNTYOF ~
ss.
On this, the /1J-l day of Jurh JYx.he JU , 2001, before me, a Notary Public,
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personally appeared David S. Masland, Jr., known to me to be the person whose name is subscribed
to the within Property Settlement Agreement and acknowledged that he executed the same for the
purposes therein contained.
IN WIlNESS WHEREOF, I hereunto set my hand and official seal.
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~OT P IC
COMMONWEALTH OF PENNSYLVANIA
COUNTYOF JJflLlPlIl1J
NOTARIAL SEAL
Jean L, Kosier, Notary Public
City of Hummelstown,County of Dauphin
My Oommission Expires Feb. 9, 2004
: ss.
On this, the It ftU day of ~
.
,2001, before me, a Notary Public,
personally appeared Kathleen A. Masland, known to me to be the person whose name is subscribed
to the within Property Settlement Agreement and acknowledged that she executed the same for the
purposes therein contained.
IN WIlNESS WHEREOF, I herennto set my hand and official seal.
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NOTARY PUBLIC
NolIUtaI seal
LJnda L. FeII8Ihoff. No\lIIY Public
Deny 1\Ilp.. [)aIjphIn CountY""""
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KATHLEEN A. MASLAND,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYL V ANlA
v.
: NO. 00-2394
DAVID S. MASLAND, JR.,
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 (XX) 3301(c) ()
3301(d) of the Divorce Code.
2. Date and marmer of service of the Complaint: April 27, 2000 by Certified,
Restricted Mail No. Z 332 878 312.
3. Complete either paragraph (a) or (b).
(a) Date of execution of the Affidavit of Consent and Waiver of Counseling
required by Section 3301(c) of the Divorce Code: by Plaintiff: December 13,2001; by Defendant:
December 13,2001.
(b) (1) Date of execution of the Plaintiffs Affidavit required by Section 3301(d) of
the Divorce Code:
(2) Date of service of the Plaintiffs Affidavit upon the Defendant:
4. Related claims pending: All claims of record have been resolved and settled pursuant to
a Property Settlement Agreement dated October 18, 2001.
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5. Date and manner of service of the Notice of Intention to file Praecipe to Transmit
Record, a copy of which is attached, if the decree is to be entered under Section 3301(d) of the
Divorce Code:
6. Date and marmer of service of Notice of Intention to file Praecipe to
Transmit Record, a copy of which is attached, if the decree is to be entered under Section 3301(d)
of the Divorce Code:
or, date of execution of Waiver of Notice oflntention to Request Entry of a Divorce Decree
under Section 3301(c) of the Divorce Code: by Plaintiff: December 13,2001; by Defendant:
December 13,2001.
and, date of filing of the Waiver of Notice oflntention to Request Entry of a Divorce
Decree: Both Waivers are being filed simultaneously with this Praecipe.
JAMES, SMITH, D
& CONNELLY LLP
Date: /J., -/~-Oj
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KATHLEEN A. MASLAND
Plaintiff
v.
: IN mE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
~ NO. 00- ~q~ML TERM
DAVID S. MASLAND, JR.
Defendant
: IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in court. If you wish to defend against the claims set
forth in the following 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, Cumberland County
Courthouse, Carlisle, PennsylVania 17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DMSION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNillMENT 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
CARlJSLE, PA 17013
(717) 249.3166
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KATHLEEN A. MASLAND : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERlAND COUNTY, PENNSYLVANIA
v.
.
: NO. oo-..?31YCML TERM
DAVID S. MASLAND, JR.
Defendant
: IN DIVORCE
COMPLAINT UNDER SECTION 3301(c) OR 3301(d)
OF THE DIVORCE CODE
Count I - Divorce
1. Plaintiff is Kathleen A. Masland, who resides at 415 North Progress Avenue,
Harrisburg, Dauphin County, Pennsylvania, 17109.
2. Defendant is David S. Masland, Jr., who resides at 72 Zion Road, Carlisle,
Cumberland County, Pennsylvania, 17013.
3. Plaintiff has been a bona fide resident in the Commonwealth for at least siX
months immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on June 14, 1997, in Carlisle,
Cumberland County, Pennsylvania.
5. A prior action of divorce was filed by Defendant in Cumberland County on
January 26, 2000, Docket Number 2000-496 which action was withdrawn on March 23,
2000 by Defendant. There have been no other actions for divorce or annulment
between the parties.
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. Neither Plaintiff or Defendant is a member of the Armed Forces of the
United States.
9. Plaintiff requests the Court to enter a decree of divorce.
Count II - Equitable Distribution
10. Plaintiff incorporates herein the prior paragraphs by reference.
11. The parties are the owners of property subject to equitable distribution
between them as marital property.
12. The Plaintiff requests the Court to equitably divide such items of marital
property between them.
Count m - Counsel Fees, Costs and Expenses
13. Plaintiff incorporates herein the prior paragraphs by reference.
14.Plaintiff is not in a financial position to meet the costs and expenses of
prosecuting this action and to pay reasonable counsel fees to her attorney.
IS.Defendant has resources and income available to him which make him well
able to pay his own and plaintiff's costs and expenses and counsel fees in this matter.
WHEREFORE, Plaintiff requests this Court to:
a. Enter a final Decree of Divorce divorcing the Plaintiff from the Defendant;
b. Grant equitable distribution of the marital property of the parties;
c. Award Plaintiff reasonable counsel fees, expenses and costs of suit in this
matter; and
d. Grant such further relief as it shall deem proper and just.
Respectfully submitted,
Me
BY: Andrea obsen, Esq.
JACOBSEN & MILKES
52 East High Street
Carlisle, PA 17013
(717) 249-6427
Attorney No. 20952
I hereby verify that the statements made in the foregoing 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.
Dated: 4-/2-0C)
4Dog~,t
KAlHLEEN A. MAS D
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KATHLEEN A. MASLAND
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 00-2394
CIVIL TERM
DAVID S. MASLAND, JR.
Defendant
: IN DIVORCE
I:RR'T'Tli'TCA'T'w' nF ~w'l?'\nl:w'
I, Dana A. Dunkle, hereby certify that a true and correct certified copy of the
Compltiint Under Section 3301(c) or 3301(d) of the Divorce Code in the above
captioned matter was duly served upon David S. Masland, Jr., Defendant, by
depositing it in the U.s. Mail, certified, restricted delivery, return receipt requested
on April 20, 2000, addressed as follows:
David S. Masland, Jr.
72 Zion Road
Carlisle, PA 17013
I hereby verify that the statements made in the foregoing are true and correct.
I understand that false statements herein are made subject to the penalties of 18
Pa.C.S. Section 4904, relating to unsworn falsification to authorities.
Dated: \f\~ ~l ~tJOO
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na A. Dunkle
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following services (for an
extra fee):
not 1. CJ Addressee's Address
2~ ResttlclEld Delivery
consull postmester for fee.
4a. Ar1IcIe Number
Z 332 878 312
1 andfQr,2 for~ services.
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. The,RetLIm Recelpt'will Show to whO"
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3. Article Addressed to:
D7aZvid S. Mas1and, Jr.
, Zion Rd.
Carlis1e,PA 17013
4b. SaMce Type
CJ Registered
CJ Express Mall
CJ Rslum Receipt for Ue""'andloe
7. O"te of Dellvel}'
GlCertlfled
CJ Insured
CJ COO
8. Addressee's Address (Only" reques/sd
and lee Is paid)
Receipt
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Z 332 1.\711 312
US Postal Service
Receipt for Certified Mail
No Insurance Coverage Provided.
Do not ,use for Intemational Mail See reverse
smIo'd
Vl S. Mas1and, Jr.
StmElf. & Number
IZ Zion Rd.
Post Officel State, & ZIP Code
Car1ls1e PA 17013
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KATHLEEN A. MASLAND,
Plaintiff
v.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYL VANIA
: NO. 00-2394
DAVID S. MASLAND, JR.,
Defendant
: CML ACTION - LAW
: IN DIVORCE
PLAINTIFF'S AFFIDAVIT OF CONSENT
AND W AIVRR OF COUNSELING
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
ApriI14,2000.
2. The marriage of the Plaintiff and Defendant is irretrievably broken, and ninety days
have elapsed from the date of both the filing and service of the Complaint.
3. I consent to the entry of a final de9ree of divorce after service of Notice ofIntention
to request entry of the Decree.
4. 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. I further
understand that the Court maintains a list of marriage counselors in the Prothonotary's Office,
which list is available to me upon request. Being so advised, I do not request that the Court require
that my spouse and I participate in counseling prior to a divorce decree being handed down by the
Court.
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 IS Pa. C.SA Section 4904, relating to
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KATHLEEN A. MASLAND,
Plaintiff
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: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYL VANIA
: NO. 00-2394
DAVID S. MASLAND, JR.,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
W AJVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE
DECREE tJNDER ~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 in 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.A. Section 4904, relating to
unsworn falsification to authorities.
Date: / tl,- /?r 01
4d~k.d
thleen A. Masland, Plaintiff
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KATHLEEN A. MASLAND,
Plaintiff
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: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 00-2394
DAVID S. MASLAND, JR.,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
DEFENDANT'S AFFIDAVIT OF CONSENT
AND W AIVRR OF COUNSELING
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
April 14, 2000.
2. The marriage of the Plaintiff and Defendant is irretrievably broken, and ninety days
have elapsed from the date of both the filing and service of the Complaint.
3. I consent to the entry of a final decree of divorce after service of Notice of Intention
to request entry of the Decree.
4. 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. I further
understand that the Court maintains a list of marriage counselors in the Prothonotary's Office,
which list is available to me upon request. Being so advised, I do not request that the Court require
that my spouse and I participate in counseling prior to a divorce decree being handed down by the
Court.
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.A. Section 4904, relating to
Date: /J.- r6-o/
unsworn falsification to authorities.
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KATHLEEN A. MASLAND,
Plaintiff
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: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYL V ANlA
: NO. 00-2394
DAVID S. MASLAND, JR.,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE
DECREE UNDER ~3301W 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 ifI 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 innnediately 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.A. Section 4904, relating to
unsworn falsification to authorities.
Date: 1:;'-/8 -() (
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KATHLEEN A. MASLAND,
Plaintiff
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: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 00-2394
DAVID S. MASLAND, JR.,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
PRAECIPE FOR ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Please enter the appearance of John J. Connelly, Jr., Esquire on behalf of the Defendant,
David S. Masland, Jr., in the above-captioned action.
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KATHLEEN A. MASLAND
Plaintiff
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DAVID S. MASLAND, JR.
Defendant
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Kathleen A. Masland, Plaintiff herein, hereby states and certifies as follows:
1. I have been advised of the availability of marriage counseling and
understand that I may request that the Court require that my spouse and I
participate in counseling.
2. I understand that the Court maintains a list of marriage counselors in
the Domestic Relations Office, which list is available to me upon request.
3. Being so advised, I do not request that the Court require that my spouse
and I participate in counseling prior to a divorce decree being handed down 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 falsific 'on to authorities.
Dated: -1- / 2. -r::b _
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
~ NO. 00- ~IVIL TERM
WAIVER OF COUNSELING
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KATHLEEN A. MASLAND
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
VS
No. 00-2394 CIVIL TERM
DAVID S. MASLAND, JR.
Defendant
IN DIVORCE
To Clerk of Courts:
I, the undersigned, hereby enter my appearance as attorney on
behalf of Kathleen A. Masland, the Plaintiff in the above-
captioned case.
Date: December 14, 2001
/1A I{ r;;t2
Attorney for the Plaintiff
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
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f\lJ.A-SLAA I~
Plaintiff
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File No.
2.000- 2. 30, L{
vs.
:
IN DIVORCE
DflvI't--. S. 1Y1f\~UAu'" 3!?-
Defendant
NOTICE TO RESUME PRIOR SURNAME
Notice is hereby given that the Plaintiff/Defendant in the
above matter, having been granted a Final Decree in Divorce on the
DATE:
ztp day of ~ECFHe,E./2.... 20::::>\ ,hereby elects to resume the
prior surname of KA\<....~u:x:) \.((-\n\L...!C€:d AL\~O~ ,and gives
this written notice pursuant to the provisions of 54 P.S. S 704.
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COMMONWEALTH OF PENNSYLVANIA:
: 55.
COUNTY OF CUMBERLAND
On the lyL day of 0 J..V'\J.... 02o~, before me, a
Notary Public, personally appea ed 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.
CJ~&~ q, '/31~baJl;/
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NbTARIAfSEAL'
CLAUDIA A, BR~WBAKER, No-:fARVPUBlIC
Carlisle Bora, CUniberlandC!iunly
My Commission Expires April 4, 2005
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PRAECIPE
KATHLEEN A. MASLAND
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
VS
No. 00-2394 CIVIL TERM
DAVID S. MASLAND, JR.
Defendant
IN DIVORCE
To Prothonotary:
Please WITHDRAW Equitable Distribution, and Counsel Fees, Costs
and Expenses in the above-mentioned case.
Date: December 14, 2001
Respectfully submitted,
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Gail Guida Souders
Guida Law Offices
503 North Front Street
Harrisburq, PA 17101
717-236-6440
Identification #68740
Attorney for Plaintiff
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