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HomeMy WebLinkAbout00-02743 . . 1 ~:'''8~~:::~::C~::::!::.:}::j.>>X:::~::.:::{>::C{:::.>>};:-)::C!f.:::<C<:::~::.;(:~~::C!:: :::!::C{}3};::)::.::!~::)::C!;~:::!::.::()>>X );::C!;,:>~::.::!::::::!::C!:;j>~~{C:!::..>n!::..>:t~*:}r~:~::.:}tt:~~~X:!~!;:::~~::.::!::;~B:X:!:+Nt-!~1 ~.~ ~ ~.~ t:: ~ i ~~ ~ ~ ~ 'v' W ~.~ ~-:~ ~ '-,,' ~ ~.~ S ,"- ~ ~.~ 8 ~~~ * ~'s ~ ~ ;.~ ;, ;.";; ~ ~-:~ ~ ~ ~ ~.~ ~ ~'S ~ "-,< ,,'~ ~l . ~.~ ;.; a ~.~ ~ I ~.~ ~ ~'s ~ I ~.~ ~'S ~ '".,- ~ ~.~ ~f ~ to,; .1 , .",..,- :"".'-':-; ~ ." CJ."'_ _n'__, ,_O_'n __._....,_. " --;j ., I , I I ! .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. mm:r<ENNE1?lI..~~mSOBE~... .......... ....ml'l!l:i,I11::!..:u.. N o. ...O'O'::-.2.7..4.3.....Ci:v:i.~...1?".r.m Versus LORRAINE SOBER. Defendant DECREE IN D I V 0 R C E I' ~ 3 A./t\ . AND NOW, .......<f~.~.?.,~.~} i~ ordered and decreed that......... .~I'fflW.t'I!.:r,j..SQ~EE.,......................, plaintiff, and. . . . . . . . . . . . . . . . . . . LORRAINE. SOBER. . . . . . . . . . . . . . . . . . . . . . . " 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 . . :r.h.i.s. .af!,.r.e.e1ll.ep.t. .a.f. . .Au.gl\s.t. in... .2.0.0.0. .1,s. .l!",r:"'Qy' .i.I\C;o.r:P.o.r:,-t;E1<\.:i:f\t;Q.1;4El .J;l.I\il~ t ~.~ ~.~ ~ ~~~ ~ i l-, ~ ~ i ~i - to,;. kI E I . '4I>~>,.')(e..:. .,:...;,:.::_~; ~~;:. -:.:c~:,.).:c~;::':~::.::<'::.:.::0::.:c{-:-.::e~:,.>:.::~-_"':'~;'<::-'30::(-):::~::.::"" .,.::.::..,:':.::.::.... Divorce Decree. ............. . ............................ ............................... ~ ~~ ,~.::.::.( }::+x ::.::+::. >:::.::.:: )::+::--:::::.::+::':, ,'.::.::',,' ::.::..::.,::::..::.::.... :--~::.::~-' ._u J. Allest: H~H' othonotary ~ ~.' I I ',-- , . . . --_c~,o-- -. _ ., -- -, - ~ -, .'.'- " -,~ " - ~-'I~'~V~ . "". "'~- ~~ ,~ ~'" ~' ''I .. 1.; lit Y:/1"&C w-t"'o/ ~ ~ 4-a#; tJ-f{(.&e) J1~ ~z, 4 ~ . . "'"'1""- ~ - .~tl .". ,-,-""."'-!-~~! -,.,- '." '" -~- . 'i' THIS AGREEMENT, AGREEMENT S., made this 31 day of A u~ lJ S -+-, 2000 by and between KENNETH N. SOBER of Cumberland County, Pennsylvania (hereinafter referred to as HUSBAND), and LORRAINE GRIBBIN-SOBER of Cumberland County , Pennsylvania (hereinafter referred to as WIFE), WHEREAS, HUSBAND and WIFE were lawfully married on December 25, 1996 in Cumberland County, Pennsylvania, and; WHEREAS, no children born of this marriage; WHEREAS, 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 of their natural lives, and the parties hereto are desirous of settling fully and finally their respective financial and property rights and obligations as between each other, including without limitation by specification: the settling of all matters between them relating to the ownership and equitable distribution of real and personal property; settling of all matters between them relating to the past, present and future support, and alimony; and in general, the settling of any and all claims by one against the other or against their respective estates. NOW, THEREFORE, in consideration the premises and of the mutual promises, covenants and undertakings hereinafter set forth hereby acknowledged by each of the parties hereto, WIFE and HUSBAND, each intending to be legally bound, hereby covenant and " ~ ,~'~-. -\',1 . . agree as follows: 1. SEPARATION: It shall be lawful for each party at all times hereafter to live separate and apart from the other party at such place as he or she may from time to time chose or deem fit. The foregoing provisions 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. INTERFERENCE: Each party shall be free from interference, authority, and contact by the other, as fully as if he or she were single and unmarried, except as may be necessary to carry out the provisions of this Agreement. Neither party shall molest the other or attempt to endeavor to molest the other, nor compel the other to cohabit with the other, or in any way harass or malign the other, nor in any way interfere with their peaceful existence, separate and apart. 3. SUBSEQUENT DIVORCE: The parties hereby acknowledge that HUSBAND has filed a Complaint in Divorce in Cumberland County to docket number 00-2743 claiming that the marriage is irretrievably broken under the no-fault mutual consent provision of Section 3301 (cl of the Pennsylvania Divorce Code. WIFE hereby expresses her agreement that the marriage is irretrievably broken and expresses ~er intent to execute any and all affidavits or other documents necessary for the parties to obtain an absolute divorce pursuant to Section (cl of the Divorce Code at the same time as she executes this agreement. The parties hereby waive all rights to request Court-ordered counseling under the Divorce Code. It is 2 '0 "- .,",- ;l,.', . further specifically understood and agreed by the parties that the provisions of this Agreement as to equitable distribution of property of the parties are accepted by each party as a final settlement for all purposes whatsoever, as contemplated by the Pennsylvania Divorce Code. Should a decree, judgment or order of separation or divorce be obtained by either of the parties in this or any other state, country or jurisdiction, each of the parties hereby consents and agrees that this Agreement and all of its covenants shall be not affected in any way by any such separation or divorce; and that nothing in any such decree, judgment, order or further modification or revision thereof shall alter, amend or vary any terms of this Agreement, whether or not either or both of the parties shall remarry. It is specifically agreed, that a copy of this Agreement or the subs~ance of the provisions thereof, may be incorporated by reference but not merged into any divorce, judgment or decree. It is the specific intent of the parties to permit this Agreement to survive any judgment and to be forever binding and conclusive upon the parties. 4. DATE OF EXECUTION: The "date of execution" or "execution datei. of this agreement shall be defined as the date upon which it is executed by the parties if they have each executed the agreement on the same date. Otherwise the "date of execution" or "execution date" of this agreement shall be defined as the date of execution by the party last executing this agreement. 5. DISTRIBUTION DATE: The transfer of property, funds 3 ',..--. ','-' j,-- and/or documents provided for herein, shall only take place on the "distribution date" which shall be defined as specified herein. 6 . MUTUAL RELEASE: HUSBAND and WIFE 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, title 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 situation, which he or she 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, Corrnnonwealth or territory of the United States, or (c) any country, or any rights which either party may have or at any time hereafter shall have for past, present or future support or maintenance, alimony, alimony pendente lite, counsel fees, property division, costs or expenses, whether arising as a result of the marital relations or otherwise, except, all rights and agreements and obligations of whatsoever 4 'j-, -- -.V^\ naCure arising or which may arise under this Agreement or for the breach of any provisions thereof. It is the intention of HUSBAND and WIFE 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 provision thereof. It is further agreed that this Agreement shall be and constitute a full and final resolution of any and all claims which each of the parties may have against the other for equitable division of property, alimony, counsel fees and expenses, alimony pendente lite or any other claims pursuant to the Pennsylvania Divorce Code or the divorce laws of any other jurisdiction. 7. ADVICE OF COUNSEL: The provisions of this Agreement and their legal effect have been fully explained to the parties by JUDITH A. CALKIN, ESQUIRE, counsel for HUSBAND and SUSAN KAY CANDIELLO ESQUIRE, counsel for WIFE. HUSBAND and WIFE accept that this Agreement is, in the circumstances, fair and equitable and that it is being entered into freely and voluntarily and that execution of this Agreement is not the result of any duress or undue influence and that it is not the result of any collusion or improper or illegal agreement or agreements. The parties further acknowledge that they have each made to the other a full accounting of their respective assets, estate, liabilities, and sources of income and that they waive any 5 . ~ W&,,' specific enumeration thereof for the purpose of this Agreement. Each party agrees that he and she shall not at any future time raise as a defense or otherwise the lack of such disclosure in any legal proceeding, involving this Agreement, with the exception of disclosure that may have been fraudulently withheld. 8. WARRANTY AS TO EXISTING OBLIGATIONS: Each party represents that they have not heretofore incurred or contracted for any debt or liability or obligation for which the estate of the other party may be responsible or liable except as may be provided for in this Agreement. Each party agrees to indemnify and hold the other party hannless for and against any and all such debts, liabilities or obligations of every kind which may have heretofore been incurred by them, including those for necessities, except for the obligations arising out of this Agreement. 9. WARRANTY AS TO FUTURE OBLIGATIONS: WIFE and HUSBAND each covenant, warrant, represent and agree that with the exception of obligations set forth in this Agreement, neither of them shall hereafter incur any liability whatsoever for which the estate of the other may be liable. Each party shall indemnify and hold hannless the other party for and against any and all debts, charges and liabilities incurred by the other after the execution date of this Agreement, except as may be otherwise specifically provided for by the tenns of this Agreement. 10. PERSONAL PROPERTY: The parties hereto have divided between themselves, to their mutual satisfaction, all items of tangible and intangible marital property. Neither party shall make 6 - .1 .',,",>l " -~~""~-:;I any claim to any other such items of marital property, or to the separate personal property of either party, which are now in the possession and/or under the control of the other. Should it become necessary, the parties each agree to sign, upon request, any titles or documents necessary to give effect to this paragraph. property shall be deemed to be in the possession or under the control of either party if, in the case of tangible personal property, the item is physically in the possession or control of the party at the time of the signing of this Agreement, and in the case of intangible personal property, if any physical or written evidence of ownership, such as passbook, checkbook, policy or certificate of insurance or other similar writing is in the possession or control of the party. HUSBAND and WIFE shall be deemed to be solely and individually in the possession, control and ownership of any pension or other employee benefit plans or other employee benefits of any nature to which either party may have a vested or contingent right or interest, apart from the provisions of the Divorce Code, at the time of the signing of this Agreement. 11. MOTOR VEHICLES: The parties agree that HUSBAND shall become the sole and exclusive owner of 2000 F-350 Ford Truck. WIFE shall become the sole and exclusive owner of the 2000 Jetta. HUSBAND will be solely liable for the payment of the balance of the lien on the Jetta and the balance of the lien on the Ford. 12. BOAT, MOTORCYCLE, SNOWMOBILE: HUSBAND shall be the \ sole and separate owner of the 2000 Bayliner Trophy Model 2002 boat, the antique Harley motorcycle and the 1986 Polaris Trail Indy 7 n.,'"'' Tf( snowmobile. 13. DOG: The Labrador dog, Haley, shall be the sole and separate property of WIFE. 14. BUSINESSES: HUSBAND owned a landscaping business, Sober CUstom Landscaping, prior to the marriage which he continues to operate. HUSBAND shall be the sole and separate owner of this business, including, but not limited to, the equipment used in this business. HUSBAND shall be solely liable for all expenses of said business, including, but not limited to, any liens against any of the equipment used by the business. HUSBAND and his brother own a Christmas Tree Business called Sober Trees. WIFE waives any right or interest in said business which shall remain the sole and separate property of HUSBAND . 15. REAL ESTATE: The parties own a home located at 1492 Letchworth Road, Camp Hill, Pennsylvania. HUSBAND agrees to transfer to WIFE all of his right, title and interest in said home. WIFE agrees to be solely liable for the payment of all of the expenses on said home, including, but not limited to the payment of the mortgage. WIFE agrees to refinance the existing mortgage into a mortgage in her name alone within sixty (60) days of the date of execution of this agreement. HUSBAND, purchased, during the marriage an eight (8) acre piece of property on Still House Lane in Etters, York County, Pennsylvania. WIFE waives any or interest in said property she may have as a result of the marriage and she agrees it will remain 8 .. .,-' - <'"'" "" ",._,,- the sole and separate property of HUSBAND. HUSBAND agrees to be solely liable for the payment of any expenses on said property including, but not limited to, the payment of the mortgage. HUSBAND owns, with his father, a rental property located at 707 Hummel Avenue, Lemoyne, Pennsylvania. This property was purchased before the marriage. WIFE waives any interest in the increased value in said property as a result of the marriage, she may have, and she agrees it will remain the sole and separate proper~y of HUSBAND. In considera~ion for the above transfers, HUSBAND agrees to pay WIFE the sum of Twenty-five thousand ($25,000.00) Dollars. 16. AFTER ACQUIRED PERSONAL PROPERTY: Each of the parties shall hereafter own and enjoy, independently of any claims or right of the other, all items of personal property, tangible or intangible, hereafter acquired by him or her, with full power in him or her to dispose of the same as fully and effectively, in all respects and for all purposes, as though he or she were unmarried. 17. APPLICABILITY OF TAX LAW TO PROPERTY 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 (herein in "Act"), specifically, the provisions of said Act pertaining to transfers of property between spouses or fonner spouses. The parties agree to sign and cause to be filed any elections or other documents required by the Internal Revenue Service to render the Act applicable to the transfers set forth in this Agreement without 9 ---,:;" "'----- II, .~ > ,-,,/. ::,.-,. recognition of gain on such transfer and subject to the carry-over basis provisions of said Act. 18. LEGAL FEES: HUSBAND agrees to pay WIFE'S legal fees in the amount of $2000.00. 19. FULL DISCLOSURE: Each party asserts that she or he has made a full and complete disclosure of all the real and personal property of whatsoever nature and wheresoever located belonging in any way to each of them, of all debts and encumbrances incurred in any manner whatsoever by each of them, of all sources and amounts of income received or receivable by each of parties, and of every other fact relating in any way to the subject matter of this Agreement. These disclosures are part of the consideration made by each party for entering into this Agreement. 20. WAIVER OF ALIMONY: The parties herein acknowledge that by this Agreement they have respectively secured and maintained a substantial and adequate fund with which to provide for themselves sufficient financial resources to provide for their comfort, maintenance and support, in the station of life to which they are accustomed. WIFE and HUSBAND do hereby waive, release and give up any rights they may respectively have against the other for alimony, spousal support or maintenance. It shall be from the execution of this Agreement the sole responsibility of each of the respective parties to sustain themselves without seeking any support from the other party. 21. BANKRUPTCY OR REORGANIZATION PROCEEDINGS: In the event that either party becomes a debtor in any bankruptcy or 10 ~ ".-' --" ". .I'" .' financial reorganization proceedings of any kind while any obligations remain to be performed by that party for the benefit of the other party pursuant to the provisions of this Agreement, the debtor spouse hereby waives, releases and relinquishes any right to claim any exemption (whether granted under State or Federal law) to any property remaining in the debtor as a defense to any claim made pursuant hereto by the creditor-spouse as set forth herein, including all attorney fees and costs incurred in the enforcement of this paragraph or any other provisions of this Agreement. No obligation created by this Agreement shall be discharged or dischargeable, regardless of Federal or State law to the contrary, and each party waives any and all right to assert that obligation hereunder is discharged or dischargeable. The parties mutually agree that in the event of bankruptcy or financial reorganization proceedings by either party in the future, any monies to be paid to the other party, or to a third party, pursuant to the terms of this Agreement shall constitute support and maintenance and shall not be discharged in bankruptcy. 22. INCOME TAX PRIOR RETURNS: The parties have heretofore filed joint federal and state tax returns. Both parties agree that in the event any deficiency in federal, state or local income tax is proposed, or any assessment of any such tax is made against either of them, each will indemnify and hold harmless the other from and against any loss or liability for any such tax deficiency or assessment and any interest, penalty and expense 11 ~ -"- ,-~- - . "" .d !il!ri-;;j .' incurred in connection therewith. Such tax, interest, penalty or expense shall be paid solely and entirely by the individual who is finally determined to be the cause of the misrepresentations or failures to disclose the nature and extent of his or her separate income on the aforesaid joint returns. 23. WAIVER OR MODIFICATION TO BE IN WRITING: No modification or waiver of any of the terms hereof shall be valid unless in writing and signed by both parties and no waiver of any breach hereof or default hereunder shall be deemed a waiver of any subsequent default of the same or similar nature. 24. MUTUAL COOPERATION: Each party shall, at any time and from time to time hereafter, take any and all steps and execute, acknowledge and deliver to the other party any and all further instruments and/or documents that the other party may reasonably require for the purpose of giving full force and effect to the provisions of this Agreement. 25. APPLICABLE LAW: This Agreement shall be construed in accordance with the laws of the Commonwealth of Pennsylvania which are in effect as of the date of execution of this Agreement. 26. AGREEMENT BINDING ON HEIRS: This Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective heirs, executors, administrators, successors and assigns. 27. INTEGRATION: This Agreement constitutes the entire understanding of the parties and supersedes any and all prior agreements and negotiations between them. There are no 12 .'."j - : .' representations or warranties other than those expressly set forth herein. 28. OTHER DOCUMENTATION: WIFE and HUSBAND covenant and agree that they will forthwith 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. 29. NO WAIVER ON DEFAULT: This Agreement shall remain in full force and effect unless and until terminated under and 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 in no way affect the right of such party hereafter to enforce the same, nor shall the waiver of any default or breach of any provisions hereof be construed as a waiver of any subsequent default or breach of the same or similar nature, nor shall it be construed as a waiver of strict performance of any other obligations herein. 30. SEVERABILITY: 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 obligation 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. 13 , <" ,-,- -"~'i I i .. , 31. BREACH: If either party breaches any provisions of this Agreement, the other party shall have the right, at his or her election, to sue for damages for such breach or seek such other remedies or relief as may be available to him or her, and the party breaching this contract shall be responsible for payment of reasonable legal fees and costs incurred by the other in enforcing their rights under this agreement. 32. HEADINGS NOT PART OF AGREEMENT: Any heading preceding the text of the several paragraphs and subparagraphs hereof are inserted solely for convenience of reference and shall not affect its meaning, construction or effect. IN WITNESS WHEREOF, the parties hereto have set their hands and seals this day and year Witness Sober '.{3/1-d fUn/ ~ o?~ ~/dV Lorraine Gribbin-Sober 14 " . "l1i1il.': : KENNETH N. SOBER, : IN THE COURT OF COKHON PLEAS Defendant : : CUMBERLAND COUNTY, PENNSYLVANIA . . VS. : CIVIL DIVISION : LORRAINE SOBER, : NO. 00-2743 CIVIL TERH Plaintiff : 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 SJ301(cl ~l) of the Divorce Code. (Strike out inapplicable s.ectionl. 2. Date and manner of service of the complaint: Certified restricted delivery May 6, 2000 3. Complete either paragraph (al or (bl. (a) Date of execution of the affidavit of consent required by S3301(c) of the Divorce COde: by plaintiff 8/31/00 by defendant 8/31/00 (b)(l) Date of execution of the affidavit required by : (2) Date of filing S3301(dl and of the Divorce Code: service of the plaintiff's affidavit upon the r~spondent: 4. Related claims pending: NONE 5. Complete either (a) or (bl. (a) Date and manner of service of tbe notice of intention to ~ile praecipe to transmit record. a copy of which is attached: (b) Date plaintiff's filed with the PrOthonotary: Date defendant's filed with the Prothonotary: Waiver of No~ice in 53301(c) Divorce was 8/31/00 Waiver of Notice in 53301(0) Divorce was 8/31/00 ~ (Plaintiff)~~ ~j~1ft~~~oliWl...,;;o{,<&;j~"~,jljlil1lfilliffili;,lj,M!b~N~flk!:l!W",!,*",,!L<"iiI''''''''''i.)~Wl:"''i,,~,"'I!li,,",'~~_w""'~ I.. ~ L. ~ :IiiIl,~~:rffi.l;ji!iUI'lt ~ -~<~ sj J . ~-'--!'m-!l 0 C':1 ;,~) C C' -n s: to -0 en "1'1 m if! "1) Z :.Jj ZC ~:~;-~ --,: ~Ci --0 ~C) ~Q '-j '-- Z i'.) ::::; =< -,-, r-0 ~-, -< - "': . , -" ~~ ", ~ " &' 1 'ffi:&,. vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 00 - .l1~ Ci(.)~'(/~ : IN DIVORCE KENNETH N. SOBER, Plaintiff LORRAINE SOBER, Defendant NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN the claims set forth action. SUED IN COURT. If you wish to defend against in the following pages, you must take prompt 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 Court Administrator's Office, Cumberland County Courthouse, Carlisle, PA. DO NOT OFFICE IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. PROPERTY, GRANTED, "~ Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 - .'" ,n KENNETH N. SOBER, Plaintiff VB. XN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANXA NO. tJiJ,;l7<13CWJ T~ LORRAXNE SOBER, Defendant XN DXVORCE : COMPLAXNT XN DXVORCE 3301 (c) 1. Plaintiff is KENNETH N. SOBER, who resides at 1492 Letchworth Road, Camp Hill, CUmberland County, Pennsylvania. Plaintiff's social security number is # 165-54-9721. 2. Defendant is LORRAXNE SOBER, who resides at 1492 Letchworth Road, Camp Hill, Cumberland County, Pennsylvania. Defendant's social security number is unknown. 3. Plaintiff has been a bona fide resident in the Connnonwealth for at least six months innnediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on December 25, 1996 in Cumberland County, Pennsylvania. 5. There has been no prior action for divorce or for annulment between the parties. 6. The Defendant is not a member of the Armed Forces. 7. The marriage is irretrievably broken. 8. Plaintiff has been advised of the availability of marriage counseling and that he may have the right to request the Court to require the parties to participate in such counseling. Being so advised, Plaintiff does not request that the Court := ,-< "k:: require the parties to participate in counseling prior to a Divorce Decree being handed down by the Court. WHEREFORE, the plaintiff prays your Honorable Court to enter a Decree in Divorce from the bonds of matrimony. Respectfully submitted: { dith A. Calkin, Esquire ttorney for Plaintiff ~ 2201 North Second Street Harrisburg, PA 17110 (717) 238-2312 --I ,". C'. ~i$:' AFFIDAVIT I verify that the statements made in this 3301 (cl Divorce Complaint 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 ~4C-- Kenneth N. Sober authorities. Date: Sworn and Subscribed rl- before me this I day of tn 19'1 ,2000. {(/ lvw/ ~ NOtary Public ~ I~OTARIAL SEAL - -" ' ELLEN ROSENBLOOM, Notary Public City 01 Ha' , Dauphin CounlY IvCo 'ssion 'res Ma 8. 2003 ~ '-'"-4.' CERTIFICATE OF SERVICE I, Judith A. Calkin, Esquire do hereby certify that a true and correct copy of the 3301 (c) Divorce Complaint has been sent by United States Mail, postage pre-paid, certified-restricted delivery to the following person: Kenneth Sober 1492 Letchworth Road Camp Hill, PA 17011 Date: . 1 '\". tilll.e.Jiilff.,' KENNTH N. SOBER, Plaintiff vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-2743 Civil Term LORRAINE SOBER, Defendant IN DIVORCE AJ<'}'wA VIT OF SERVICE I, Judith A. Calkin, Esquire, deposes and says: 1. That she is an adult individual residing in Dauphin County, Pennsylvania. 2. That on May 5, 2000 she sent by certified-restricted mail, return receipt requesting from Harrisburg, Pennsylvania (No. Z273 825 759) the 3301(C) Divorce Compaint in the above captioned case to: Lorraine Sober 1492 Letchworth Road Camp Hill, PA 17011 3. That on May 6, 2000. Lorraine Sober signed the receipt (No. Z273 825 759) which is attached to this affidavit. I in, Esquire Plaintiff e 2201 North Second Street Harrisburg, PA 17110 (717) 238-2312 .' " '...... iii e"Iilp1<'!te'JIGrnS t 2, anctS:Aiiio oomplete ' "item '4 if Restricted De\ivel)f is desired. . Print your name and address on the reverse' so that we can return the card to you. . Attach this card to the back of the mailpisc8, or on the front if space permits. 1. Article Addressed to: . Is delivery address differen rom item 1? If YES, enter delivery address below: Lorraine Sober 1492 Letchworth Road Camp Hill, PA 17011 3. Service Type 10 Certified Mail 0 Express Mail D Registered 0 Return Receipt for Merchandise o Insured Mail 0 C.O.D. :1. Restricted Delivery? (Extra Fee) [j Yes 2. Article Number (Copy from service labeQ 273 8~5 759 ." PS Form 3811, July 1999 Do~c Return Receipt 102595-99-M-1789 Z 273 825 759 US Postal Service Receipt t,,: Certified Mail No Insurance Coverage Provided. Do not use for International Mail See reverse Sent to Postage Certified Fee Special Delivery Fee Restricted Delivery Fee '" '" '" ~ ."i~ " ~" ," "~I!:"""". ~~ - "','I j-~'" " '.J ~ l:Ilil!~lid"'" '- c:; i-'::'::: f" U-ll....-.i.-.,;-"lOi;!l~ltilii!llllU "u'",'c,'''c'c' "I ". >- r- Z .:::>", "~;~ _J ~::::: i~~l ~0 ~~ o C'__ ;-~ C.. Lc.,,: (.f'; C::J Cl ',,,,:; i_ '~ , ~ ,'," "';'..J."~~ , " KENNETH N. SOBER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 00-2743 Civil Term LORRAINE SOBER, Defendant IN DIVORCE AJ.....mA VIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on May 3, 2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a Final Decree in Divorce after service of notice of intention to request entry of the decree. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Date: ~/oll ~~/n Lorraine Sober SS# No. /7'1-(.,;1-1753 .ti.:'"-~ ,:;" ~" , ~ II....<--..;Ir.' "" "-~-11~' ~~ ~~" ~~-~~,~" ,,<'. L......~ .-" (') C <" uci:": rn..---,-- ~K ~~ =s --< ''V t'V ,. , c:; o U) '" -0 I ~_1 .. "~ -'I ,~ --'0 ,. . '0 ' "'. '0' "~" JJ ~ ...,. KENNETH N. SOBER, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-2743 Civil Term LORRAINE SOBER, Defendant IN DIVORCE WAIVER 01" NOTICE 01" INTENTION TO REQUEST ENTRY 01" A DIVORCE DECREE UNDER SECTION 3301 (0) 01" THE DIVORCE CODE 1. I consent to 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 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. 4. I verify that the statement made in this Waiver 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. DATE: ~IITO ~. .?}/p() Lorraine Sober w i~"""" . -1iIiI!I~~ ~~~~ ~"""""""1.t'.bll'iil- ikumilllilf..iilll1 _ L'lfIjli!IM.J8itLDI ~, (') ~ < uf].1 (TIr,; ~~=:r~ ~~: <-0 ~c_, :;;g z :;! 11 /. '\ C.> c:, :/) ,-rj n"1J I --.! () -n v '.:0 ~ - - f"~ ~2(-=s ~O::<,rn ~ :$ -<. ="' N f\:l 0[_1__ " - <d''lke i". " . . KENNETH N. SOBER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 00-2743 Civil Term LORRAINE SOBER, Defendant IN DIVORCE M<lfmA VIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on May 3, 2000. 2. The marriage of Plaintiff and Defendant is irretrievably" broken ,and . ninety" (90). days.have elapsed. from. the date of the filing and service of the Complaint. 3. I consent to the entry of a Final Decree in Divorce after service of notice of intention to request entry of the decree. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Date: g-13 t1cl.o Kenneth . Sober SS# No. /~.r'~~?z.( :'j"H',_ ,.J.,. ,-.'," ... llIiiii"'........ ~. '~-1 ..' . l,~A~~"'" ~ ~~Ilii!lti c. ,,_ - (') c $: -ncr' mrT. Z~:' 2:(. Cf)",~:.. ;:s<' r-c -,--,' ;';1: Z~C (-' ..=..." >c 2: =< C:j c:) C/) ,-,., '-0 C, "~fi "_,J -0 ''0 r,) , ."'- II 11 II II ! I, , ~ "' '.- ,.. .,'. .,- ,;. ~ . -1 -. i', , . . KENNETH N. SOBER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 00-2743 Civil Term LORRAINE SOBER, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 (c) OF THE DIVORCE CODE 1. I consent to 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 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. 4. I verify that the statement made in this Waiver 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 DATE: ~31'o.C autborit~ . Kenneth N. Sober 16'.J'=Frr- 972../ , ~lIIf'~ ~ 41.......iol!tlOJ]i~ .:...="" . ~~ o ~ ~ V;'J;~ rTlr< 2 "}'-j 2:r (/).;----.. ;S::';:.' KG :1?C) <;~Ci -"'C 2: ~ !'V r" c:> a V') i-" " I ~~ -, :J~ ",..... 11 ::1 .] :i j , , j n iil ili " ! I ii i ! I l I I 8 1'J --,~~ i-:-; 'I' ~~ ::;~';;2 C)' ,; ':'::::1 :'5 -< :;i'{~ ~ _ _ .C t ,,, "e . KENNETH N. SOBER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 00-2743 Civil Term LORRAINE SOBER, Defendant : IN DIVORCE PRAECIPE FOR ENTRY OF APPEARANCE Please enter my appearance on behalf of the Defendant, LORRAINE SOBER. Respectfully submitted, GATES & ASSOCIATES, P.C. Dated: June ~ 2000 Susan Kay Can . Counsel for De n PA I.D. # 64998 1013 Mumma Road, Suite 100 Lemoyne, PA 17043 (717) 731-9600 ~.- ',.'.' ,-,-";j, " .........w- . ~ ~:1.;..;:Jl'" "',.'..... . _ .ojj ...... .~ - --',,';'1lliw~l:lilitj"'" ..-....".~'"l . () 0 0 C 0 ~n ;;;: '- .-.< ."" '"Om c:: "i1~ mrn z Z:n -ni'T1 65s;:. -' ',"')1 oe' -<..t.__ ~~:8 ~o "'0 ~() :JI: ~C-) ~,-o '>: orll Pc ~ ~ Ul :- -< -t" 'i 'I II I i: Ii