Loading...
HomeMy WebLinkAbout00-02773 " . .. .. .. . . . . :+::F.1ti"';t;1ti~lf. . . . . . . . . . . . . . . . . . . . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY . . STATE OF . . David Andrew Lawrence . . . VERSUS -ramie Leah Lawrence . . . . AND NOW, DECREED THAT . AND . . . PENNA. NO. 2000- 07.77"> DECREE IN DIVORCE 1(7 . "i lit. ~ , 2002 ' IT IS ORDERED AND D.1=Iv; n Annrj::ll.7 T ~wt'An,...a , PLAINTIFF, Jamie Leah Lawrence , 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 By THE COURT: An"S ~ ~~ PROTHONOTARY .. ... ""Inli '" . . . . . . . . '" :F. '" '" ",'Ii . . . , ~, .'" " ~ '" ~- >'- . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J, . . . . . . . . . . !111lHw ~ li.W~~'Il~III_t:ii;iIlt.'IIi!llUll' -~--U~~l$ll!Ioll'~' , k~rz~~ A.p~:r;E ~. 4v n ~ " '. -,,~~,-,,~ , . 'c"_ P,_,~ ~, . , -~ - ,,',~ ~ - J"~ , ~'f/,/ C'?r/"1/,j ._,,_0 , ; J' ". ~'"~ t. ~ .- - ~. ~ ~. ,c~,~", >,;.". .;" "Iij;< , SEPARATION AGREEMENT MADE this ~ day of November 2001, by and between David Andrew Lawrence, of Pennsylvania, hereinafter referred to as "Husband"; and Jamie Leah Lawrence, of Shippensburg, Pennsylvania, hereinafter referred to as "Wife". WHEREASS, the parties hereto are Husband and Wife having been married on August 16, 1996; and , _ WHEREAS, the parties live separate and apart, and Husband has filed for divorce; and WHEREAS, the parties hereto have accumulated certain property throughout their marriage and wish to make a disposition thereof; and WI;IEREAS, each of the parties herein have been advised by independent legal counselor have that right to be advised by independent legal counsel as to the nature and effect of a separation agreement and with said advice have determined that the following agreement is fair and reasonable and enter into the same with full knowledge of the extent of the estate of the other and their respective rights. NOW THEREFORE, WITNESSETH, in consideration of the promise and mutual undertakings herein contained, intending to be legally bound hereby, the parties do mutually agree as follows: 1. SEPARATION: The parties may live apart for the rest of their lives. Each shall be free from interference, direct or indirect, by the other as fully as though unmarried. Each may for his or her separate benefit; engage in any employment, business or profession he or she may chose. 2. MUTUAL ESTATE WAIVER: It is the intention of the parties hereto that from and after the date of this agreement, neither shall have any spouse's rights in the property or estate of the other, and to that end, both waive, relinquish and forebear their rights of dower or courtesy, rights to inherit, rights to claim or take a husband or wife's or family exemption or allowance, to be vested with letters of administration or testamentary, and to take against any will of the other. The parties further agree that they may and can hereafter, as though unmarried, without any joinder by him or her, sell, convey, transfer and/or encumber or hereafter own or possess, real or personal property and further agree that the recording of this agreement shall be conclusive ......~ '"' '1;' ,~ evidence to all of his or her right to do so. And the said Husband and Wife do hereby irrevocably grant, each to the other should the exercise of this power hereby given become necessary, the right and power to appoint one or more times, any person or persons, whom Husband and Wife shall designate, to be the Attorney-in-Fact for the other, in their name and in their stead, to execute and acknowledge any deed or deeds, releases, quitclaims or satisfactions, under seal or otherwise, to enable either party to alienate his or her real or personal property, but without any power to impose personal liability for breach of warranty or otherwise. Each of the parties hereto further waive any right of election contained in Chapter 22 of the Pennsylvania Probate, Estates and Fiduciaries Code, or such right in this of any other jurisdiction. 3. DIVORCE: At such time as the parties are ready, Husband and Wife shall complete a divorce and shall each bear all expenses connected therewith. 4. ATTORNEY'S FEES: Both of the parties shall bear their own attorney's fees in this matter, and both and each of the parties waive any claim against the other for any attorney's fees in this matter. 5. ALIMONY, ALIMONY PENDENTE LITE, SPOUSAL SUPPORT, COSTS, AND EXPENSES: The parties, for and in consideration of this agreement, do hereby waive, one from the other and one to the other, any and all rights they may have to alimony, alimony pendente lite, costs, expenses and support for each other. This does not include any obligation to repay any past support nor shall this include any obligation to make reimbursement for any medical bills in the amount and percentage as set forth in the order of court attachep hereto and made a part hereof as fully as if set forth at length. 6. PERSONAL PROPERTY: Each party has in their possession the personal property that he or she claims an interest in, including but not limited to automobiles and each party, one to the other, waives any and all future interest in the personal property of the other and agrees to complete any and all documents or titles necessary to assure ownership. -v I "'~I"~I::U "h, .. 7. PENSION RIGHTS: Each of the parties waive any claims to any pensions that either may have through his or her employment or otherwise, excepting to the extent that pension rights have been transferred to fulfill an alimony duty. 8, EQUITABLE DISTRIBUTION OF PROPERlY: By this agreement, the parties have intended to effect an equitable distribution of their marital property. The parties have determined that an equitable distribution of such property conforms to a just and right standard with due regard to the rights of Husband and Wife. The distribution of existing marital property is not intended by the parties to constitute, in any way, a sale or exchange of assets, and the distribution is being effected without the introduction of outside funds or other property not constituting a part of the marital estate. 9. DEFAULT: If either party fails in due performance of his or her obligations hereunder, the other party shall have the right, at his or her election, to sue for damages for a breach of this agreement, or to rescind the same and seek such legal remedies as may be available to him or her. Nothing herein contained shall be construed to restrict or impair either party's rights to exercise this election. 10. APPLICABLE LAW: This agreement shall be governed by the laws of the Commonwealth of Pennsylvania. 11. MODIFICATION AND WAIVER: No modification or waiver of any of the terms hereof shall be valid unless in writing and signed by both of the parties. No waiver of any breach hereof or default hereunder shall be deemed a waiver of any subsequent breach or default of the same or similar nature. 12. RECONCILIATION: The parties shall only effect a legal reconciliation which supersedes this agreement by a signed agreement containing a specific statement that they have reconciled and that this agreement shall be null and void; otherwise, this agreement shall remain in full force and effect. Further, the parties may attempt a reconciliation which action if not consummated by the aforesaid agreement, shall not affect in any way the legal effect of this property and separation agreement or cause any new marital rights or obligations to accrue. 13. ENFORCEABILITY AND CONSIDERATION: This Agreement shall survive any action for divorce and decree of divorce and shall forever ,,'4"~~ _.~" .~ l ~~ ,..... ~w,., . . be binding and conclusive on the parties. An independent legal action may be brought to enforce the terms of this agreement by either Husband or Wife until it shall have been fully satisfied and performed. Consideration for this contract and agreement is to be found in this mutual benefit to be obtained by both parties hereto and the covenants and agreements of each of the parties to the other. The adequacy of the consideration for the mutual undertakings herein set forth is stipulated, confessed and admitted by the parties intended to be legally bound hereby. 14. WHOLE AGREEMENT: This agreement constitutes the entire understanding of the parties. It supersedes any and all prior agreements between them. There are not representations or warranties other than those expressly herein set forth. AND further the parties hereto covenant and agree that this agreement shall extend to and be binding upon their heirs, devises, executors, administrators and assigns. AND the parties hereto state that he or she, in the procurement and execution of this agreement, has not been subjected to any fraud, concealment, overreaching, imposition, coercion, or other unfair dealing on the part of the other, or on the part of the other's counsel. IN WITNESS WHEREOF, the parties hereto have hereunto set their hands and seals the day and year first above written. Witness: ~"~ ~\~ cf mJ<< ~JJ\.1 DnO a J (SEAL) = \\~~--., J}~ ~ ~~SEAL) ~. - . . . ~ ACKNOWLEDGEMENT COMMONWEALTH OF PENNSYLVANIA: :SS COUNTY OF CUMBERLAND On this /V7'day of A.JOI..k~16A- , 2001, before me, a notary public, the uncre;;gned officer~, personally appeared, Jamie Leah Lawrence, known to me, (or satisfaction proven), to be the person whose name is subscribed to the within instrument, and acknowledged the foregoing Agreement to be his act and deed and desired the same to be recorded as such. IN WITNESS WHEREOF, I hereunto set my official hand and seal. Notarial Seal Ha~rd S. Irwin 1/1, Notary Public CarlIsle Boro, Cumberland County My Commission Expires Sept. 23, 2002 Member, Pennsylvama Association ot Notaries Notary Public My Commission ACKNOWLEDGEMENT COMMONWEALTH OF PENNSYLVANIA: :SS COUNTY OF CUMBERLAND On this /Cf"1 day of7Jmm./Jf ( , 2001, before me, a notary public, the undersigned officer, personally appeared, David Andrew Lawrence, known to me, (or satisfaction proven), to be the person whose name is subscribed to the within instrument, and acknowledged the foregoing Agreement to be her act and deed and desired the same to be recorded as such. IN WITNESS WHEREOF, I hereunto set my official hand and seal. lk/;;tr'Wuj~ 'Notary Public My Commission Expires: I~"~~ ,Notarial Seal 1 .Dawn Mane Shoop Notary Publ", i Sh'PPeoenSbUrg Bora, Cumberland Co",;",",'" I ~~_ mmlsSlon _ Expires Feb. 5, ::?~":J j I -"-"~-~',-,- . -,,~, "-'~'.! '.'., " . "" '. ] k: l . '# In the Court of Common Pleas of FRANKLIN County, Pennsylvania DOMESTIC RELATIONS SECTION JAMIE L. LAWRENCE ) Docket Number DRS1998 00671 Plaintiff ) vs. ) PACSES Case Number 477100130 DAVID A. LAWRENCE ) Defendant ) Other State ID Number CONSENT ORDER AND NOW, to wit, on this 9TH DAY OF NOVEMBER, 2001 IT IS HEREBY ORDERED that the support order in this case be 0 Vacated or OSuspended or (i)Terminated without prejudice or 0 Terminated and Vacated, effective NOVEMBER 9, 2001 , due to: THE PARTIES ARE AGREEABLE TO TERMINATE THE SPOUSAL SUPPORT AS OF NOVEMBER 9, 2001; IT IS FURTHER ORDERED THAT THE DEFENDANT IS TO PAY THE REMAINING ARREARS OF $538.15 AND THE REMAINING FEES OF $26.00 WITHIN TWENTY DAYS; IT APPEARING FURTHER THAT THE PARTIES ARE IN AGREEMENT THAT PENDING ANY OUTSTANDING MEDICAL BILLS THAT ARE NOT PAID BY THE DEFENDANT'S MEDICAL INSURANCE WILL BE SPLIT NINETY PERCENT BY THE DEFENDANT AND TEN PERCENT BY THE PLAINTIFF. Co~erned: a~n ~ ~~, (1 Pia tiff. I ~~/;-e- Defendant BY THE COURT: JUDGE Date Service Type M Form OE-503 Worker ID 28202 i~~Ili!irldl"j-i4ilirl~~_~!~tI&i!lU~,*iliM!.!l''';'''I;-_''ji','I''fij.l<I1'''~~P-' . ~ ", _~, .1 '^ ~~~, "" ~" ~itlifl: JrL~~"-~ ~~.' '''''llJi~IIi"''''" .lor" -'~.... .,- C) c: ? -.- --"'- ,iI-,-, O)fi\ ~i~S,-' ,,', v..,..-. ~ES -2>,-., z(~' ~---' .Pc: 2: =< - ." ~~ Cl r",J o ""I", -~~ - "'"'1"- -," -0 -):'Y "T,,' ~iC) "T' -T" g~~ b! :0 -< N c- r" J , ~.-'" ., '~, ,-~,_ L . - D_~, ^ , ---,"". '-';,.--- " ", " IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA David Andrew Lawrence, Plaintiff : No. 2000-02773 : Civil Action - Law vs. : In Divorce Jamie Leah Lawrence, Defendant 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 3301(d)(1) of the Divorce Code. 2. Date and manner of service of the complaint: The complaint was served by certified mail return receipt requested on May 5, 2000 and was received on May 9,2000. An affidavit of service was filed on May 26, 2000. An amended complaint was served by certified mail return receipt requested on June 2, 2000 and was received on June 5, 2000. An affidavit of service was filed on June 8, 2000. 3. Date of execution of the Affidavit required by Section 3301(d) of the Divorce Code; by the Plaintiff, September 23, 2000. The affidavit was filed in the Office of the Prothonotary on September 29, 2000. The Affidavit of Plaintiff was served upon Defendant by first class mail, postage prepaid, on or about September 29, 2000. A counter-affidavit was filed by the Defendant on October 25, 2000. 4. Related claims pending: None. Defendant had filed a claim for economic relief on October 25, 2000 which has been resolved by '-.' "'-' -'''-,' ',-',",i,'-, I I I , I , I I I I i I , i' i , I I I fi ! I I I.' I I Ii I l ---L ~ ~ ",'-- -. -,,", . ' ",'-','----",---',"- , ~_ _> ~- :.'_,,;____;,;.- ~_'r. -.'.,." ''':~f ;e' ~' I ! ) .... agreement. A copy of which is attached hereto and made a part hereof. 5. Defendant signed a waiver of notice on November 19,2001 which is filed herewith. ~ 'H. Anthony Adams, Esquire Attorney for Plaintiff 128 E. King Street Shippensburg, PA 17257 (717)-532-3270 liiilllililill.i !L.. ~,," . -II"" ."~~ ,-;. '~'''-;':l "",,' ,> e'~v,._, ,~ _" t. ,~- ,.,,'./..;- ~= 1.- "--.',.;:, <,-:c..,.' ,-" ii' >Vi' ~"iN".~ ~ ,'V"" "~,, "" \. (") C) :;;. C..) f_ ~1:) ~t ';~ m -~,... ~ i~ ~\') _.-... f>? " )>~; ~ 3. ",... .];7 -< ~ - - - "--~ ,. ... J. " .-c:","~' ,-. -~I" '-' - - "." ~-, , ,- -, " " _." __ ~___ .;,.:,_ '_, -l-. __._, -.0.'_ To-' ~2.~" ~".'=""_ ;"'-;',,-<-_~- -" "" I ~. r I~ , I , I \, ~? \',: I I' 1\' 'i!- I: V' r;! r;-: ~~ . . " IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA David Andrew Lawrence, Plaintiff CI'Ut(t~ : No. 00 - ;), '7'2..3 : Civil Action - Law vs. : In Divorce Jamie Lee Lawrence, Defendant r ri NOTICE TO DEFEND AND CLAIM RIGHTS I ~; ii , i" " ~ 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 in divorce Or annulment may be 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 the custody or visitation rights of your children. ! ~' ~ ! , ! ~ ~ fI ~ I,. 1I ~ r,1 .~ When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Courthouse, Carlisle, Pennsylvania. 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 (717)-249-3166 1_: " "---._"'~ ",_'n "_ ~"',"" ~ ' ,,' .'_ "~_, .,1-.'," _ oj-, i _ _ r ~~,_ "',-" ._-n " ".,' , " ... IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA David Andrew Lawrence, Plaintiff /'- A tu.<- : No. P-tJ- il 'T.'lj ~ : Civil Action - Law vs. : In Divorce Jamie Lee Lawrence, Defendant COMPLAINT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. Plaintiff is David Andrew Lawrence, who currently resides at 44 Rustic Drive, Shippensburg, Cumberland County, Pennsylvania, since April 10, 1998. 2. Defendant is Jamie Lee Lawrence, who currently resides at 143 Park Place East, Shippensburg, Franklin County, Pennsylvania, since April 10, 1998. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this complaint. 4. The Plaintiff and Defendant were married on August 18, 1996, in Shippensburg, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. '~ . [:1 , ;1 \j I} i-j (' il ~l 'I 'I Ij l I [I , il ~ ~ il II II q ~ ='" .-,,--"'--.- . "', _-"_""I,,",,,d'~f;'<';".~_ -.:;',,: ~ ---, - '.'. , - -" -. -, '" - ~--' .0--" -n '.' ,~~. 0 0_ ,-;, ,_ , .. i' ;?~--I ..' . , 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. Respectfully submitted. ~Ch, H. Anthony ams, Esquire Attorney for Plaintiff 128 E. King Street Shippensburg, PA 17257 (717)-532-3270 "' -"-- ~- " " '., - '., ~-..' ~.....". -- I"" .', ""h"c_ -'.:; ': '-:;; "",~',,; 0"' "-',," " , " . , 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. Section 4904 relating to unsworn falsification to authorities. Date: ~2..~~t:C-> f4v:..~ ~ -/ ~ David Andrew Lawrence "-""L' -, ,~:-"- " ,,;-.: '.--'-1 .' ~" ~............, ~- ~.~ . "~ ~ . $<a~i":': IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA David Andrew Lawrence, Plaintiff : No. O{)-J,113 ~ : Civil Action - Law vs. : In Divorce Jamie Leah Lawrence, Defendant NOTICE If you wish to deny any of the statements set forth in this affidavit, you must file a counter-affidavit within twenty (20) days after this affidavit has been served on you or the statements will be admitted. AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on April 10, 1998 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 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. 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. Section 4904 relating to unsworn falsification to authorities. ~~L David Andrew Lawrence, Plaintiff Date: 7~3-(JO ~ 11!!Ilimii1~UlE~j~t<2ltli"'t__-A;"'i;ib~.!1"",[;&",'~''i!''Ji;j,i&h.:''iL<1'""1~'_;~-Hb "'",,,"i,'''i'! ~'I""EA:)..&!iclJ;o,y,",,,&!~g~' -, ~~jili"~~iMI~~~_1lll!--'~ (') c:: ;::~ "1)0.::' q)r:t:'; .&._ ::I.. 21;- (/),'.-. -:: ~< r:;O "" ~C Zr-< >c z ~ -< - ~~ f~ c) (/) ;"1 -0 -, ' [--- r-...:J '.0 \,..' -; - .,('; -,"" -'--, (1~5, -,-1 55 '-< C:1 "-"I N a-l - ~~- ,-' ,- -- --, '''k'B , """:'.'\ . ~- ;-'. . '^ ;J;,'. , " IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA David Andrew Lawrence, Plaintiff : No. 2000-02773 : Civil Action - Law vs. : In Divorce Jamie Leah Lawrence, Defendant COUNTER-AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): -A- a. I do not oppose the entry of a divorce decree. b. I do oppose the entry of a divorce decree because (Check (i), (Ii) Or both); , (i) The parties to this action have not lived separate and apart for a period of at least two years. / , (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): (a) Ido not wish to make any claims for economic relief. I understand that I may lose rights concerning alimony, division of propery, laWYJr's fees or expenses if I do not claim them before a divorce is granted. -A- (b) I wish to claim ecc;,;omir relief v~hiu, may include alimony, diviSion of property, lawyer's fees or expenses or other important rights. I understand thatin addition to checking (b) above, I must also file all of my economic relief claims with the Prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further delay. '- "-.<" L~ , -.~:", ,~. , ,-' .C'~ _"' '< .' " 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. Section 4904 relating to unsworn falsification to authorities. Date:12/Jd4-OO- ~ ~ ~ll}L J ie Leah Lawrence, Defendant NOTICE: IF YOU DO NOT OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECOMONIC RELIEF, YOU SHOULD NOT FILE THIS COUNTER-AFFIDAVIT. IRWIN By: o ~ Baranski, Jr., Esquire Attorney for Defendant Supreme Court ID No. 82585 35 East High Street, Suite 202 Carlisle, PA 17013 . " '~"' ~,-, _ '1_ - -, ,.,';'.- "'~_"__ "<_ {".,-".-,('-'-'U'__' ;__'.:.,-c;,. CERTIFICATE OF SERVICE I hereby certify that I have served a copy of defendant's Counter Affidavit Under Section 3301 (D) of the Divorce Code upon counsel for plaintiff by placing same in the United States Mail at Carlisle, Pennsylvania, Regular Mail date below written and addressed as follows: H. ANTHONY ADAMS, ESQUIRE 128 EAST KING STREET, SUITE A CARLISLE, PA 17013 Octobe!:23,2000 By: Joh aranski, Jr., Esquire Attorney 1.0. No. 82585 35 East High Street, Suite 202 Carlisle, PA 17013 Attorney for Defendant " '. ,. "~,,~~--, -,"-, -'1. ' ~- - -'" '-----_"_'."_-__;,.i'- - - .-"-;'.--- '-""-'j , "'~k !~ Ii!] 'f~ 11 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA i.i:' i~ it ';1 ~\: , :!i, I,< ,j; David Andrew Lawrence, Plaintiff : No. 2000-2773 r: 1J: ,i: I~; I ihi : Civil Action - Law vs. Jamie Leah Lawrence, Defendant : In Divorce i: I' I'~'; -" ~ , '1, WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(d) OF THE DIVORCE CODE ~!: i~ ~:I rn ;:' 111 r, !g IDJ ii ~i Iii r: ,~ 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. Date: I ~~-- David Andrew Lawrence Plaintiff 1:1 Hi Gi 1:: 1;1 ~. 1; ~i ii I ,I j; 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. Section 4904 relating to unsworn falsification to authorities. jili-< '~ ,,'; p,,, ' ~, ,'~ /~- ---'-;;it:",:ii~j.:,) >'~~"'" - ~ ~~"-'- , , c -~- .~ ~.I.- _," _r-';,;,. """ -~ o C~ ~ .ut.i. rnCi': -7"'(; ~- :ZC~ en "'~: --/ L" r::C,; "-- -", zO ,=CI be 'z -<! h,_ >,c",-,~ ., co f'J () ,) c__ '~ :2: .., r' , ~'; -J C:J :~ -->. ~~) ,..' -:--\ ~0~ ~~ ~ c> :u -< ~ l.~,,:" l::- f'> t~ '~ , - l_. - _ ~_",- -- ., .-- . ~" -0. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA David Andrew Lawrence, Plaintiff : No. 2000-2773 : Civil Action - Law vs. Jamie Leah Lawrence, Defendant : In Divorce WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date:.1(nv IQ I~\ ~ 1,)\ II ~Q(\ Yijtw'r1Dn(l 0 Ja ie Leah Lawrenc Defendant ~ :""..<". '. ,-- ,,' , ~~ -, ."~- -,. . 'L<. ~: fii t " 1:: , 1, ~_: r ~'I L ;" r f': .-,; >,: t: i" q ri n r' Ii I' ii I; ~ <:, ili -''c-,;;;-':;<i o C :? ~~f.~ ----:;""'''', ~7;':' (r:;1,.~ -<: _c_, ~(~_:: J-" r- :;;::: ~'-< >~:; ~-::~; :< L C:::.l f"'j o -n c_ ~~ -0 \ --~~ 'c..::r2 :.~; I - ~l ~IJ -< .~,~ (-,,3 s:- f0 ~ ~ ,. ~ ~'"h '"'" -,'..""-.-;.". ,. - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA David Andrew Lawrence, Plaintiff : No. 2000-02773 : Civil Action - Law vs. : In Divorce Jamie Leah Lawrence, Defendant AFFIDAVIT OF SERVICE H. Anthony Adams, Esquire being duly sworn according to law deposes and states that an amended complaint in divorce was mailed to Jamie Leah Lawrence of 143 Park Place East, Shippensburg, Pennsylvania 17257, certified mail, return receipt requested, on June 2, 2000 and was accepted on delivery by Jamie Leah Lawrence on June 5, 2000 as shown by the attached receipt. H. Anthony Adam, Esquire Attorney for Plain iff 128 E. King Street Shippensburg, PA 17257 (717)-532-3270 Notarial Seal Dawn Marie Shoop, Nol8!Y PublIc S!1lppensbu!ll Bora CUmbeJlind ~ My Commlfi8lon expIres Feb. S, 2004 Sworn to and subscribed this 6~ day of June,2000. ~~~ <;; SENDER: Notary Public , ~ My Commission Expires: ~ ~ ~ ~ = ~ o 'C * is. E o " CI Complete items 1 ancllor 2 for additional services. Complete items 3, 4a, and 4b. CI Print your name and address on the reverse of this form so that we can return this card to you. [J Attach this form to the front of the mailpiece, or on the back if space does not permit CI Write "Return Receipt Requested" on the mailpiece below the article number. CI The Return Receipt will show to whom the article was delivered and the date delivered. 3. Article Addressed to: Jamie Leah Lawrence 143 Park Place East Shippensburg, PA 17257 I also wish to receive the follow~ ing services (for an extra fee): 7. Date of Delivery b - 5.00 I I , ] ~ ~ a:' g'! -] !t'1 l;t' "t' ~ ~ !b ,"" 1. D Addressee's Address 2. KI Restricted Delivery 4a. Article Number 4b. Service Type D Registered jEl Certified D Express Mail D Insured D Return Receipt for Merchandise D COD 8. Addressee's Address (Only if requested and fee is paid) PS Form 3811, December 1994 102595-99-6-0223 Domestic Return Receipt 0 t:? n C) .....-,' c " -~ ~ - -O(}} c:: ~, rr1p\ .-~ ~ z:~c .~ I ---, n1 zc :~-~~ ~~ ~.2:~:_: ('J) ~c' ''''0 '~'i ~n :a:.:: i_O~~Z; ~l.) 1",-":rn c: ~) -~l ~ "" ~J:;.>' ;:Q '< i':i,:Ulli i'i' L~~d:-~ 3~~. ,",,0_"_'_ ,.c-',I,-,' ",--- ,.""",-",,",,,,,^,-_, , ~ ,. JOHN J. BARANSKI, JR. ESQUIRE ATTORNEY ID NO. 112585 35 EAST HIGH STREET CARLISLE PA 17013 (717) 243..6090 ATTORNEY FOR DEFENDANT DAVID ANDREW LAWRENCE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 00 - 2773 CIVIL TERM .JAMIE LEAH LAWRENCE, Defendant CIVIL ACTION - DIVORCE DEFENDANT'S CLAIM FOR ECONOMIC RELIEF NOW, comes the defendant, Jamie Leah Lawrence, by her attorney, John J. Baranski, Jr., Esquire, and makes the following claims for economic relief: 1. During the marriage of the parties, they accumulated various assets and liabilities subject to equitable distribution. 2. Pursuant to a Franklin County Order of Court Dated July 1, 1998, to PACSES # 477100130, plaintiff was ordered to pay 90% of all unreimbursed medical expenses. To date, plaintiff has not done so and medical bills remain outstanding. 3. Defendant requests your Honorable Court allow her alimony as it deems just and reasonable pursuant to Section 3701 of the Pennsylvania Divorce Code. 4. Defendant requests your Honorable Court to allow her alimony pendente lite, reasonable counsel fees, and expenses as it deems just and reasonable pursuant to Section 3702 of the Pennsylvania Divorce Code. 5. Defendant requests your Honorable Court to order plaintiff to continue to provide coverage for defendant on plaintiffs health insurance plan ,'-. ~ - ^,-< --- ,., < <.,"-~' -,,~-,~--<-, " , t'i , . . WHEREFORE, the defendant requests the Court to enter a Decree: a.) Dissolving the marriage between the parties; b.) Equitably distributing all assets and liabilities of the marriage; c.) Awarding alimony as the Court deems just and reasonable; d.) Ordering payment of alimony pendente lite, counsel fees and expenses as the Court deems just and reasonable; e.) Ordering plaintiff to maintain health insurance coverage on defendant; and f.) For such further relief as the Court may deem equitable and just. I verify that the facts contained herein are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. October 4L-, 2000 ~ ~ i(llij1illLLL JA IE LEAH L RENCE IRWIN LAW OFFICE ~ ~ By: < _____ JO J. BARANSKI, JR. Attorney for Defendant Supreme Court ID No. 82585 35 East High Street, Suite 202 Carlisle, PA 17013 , ' ~ , C" ,_ "'~' V~ '~~ , CERTIFICATE OF SERVICE ;i Ii :ij ij " Ii Ii Ii 11 Ii II I hereby certify that I have served a copy of defendant's Claim for Economic Relief upon counsel for plaintiff by placing same in the United States Mail at Carlisle, Pennsylvania, Regular Mail date below written and addressed as follows: H. ANTHONY ADAMS, ESQUIRE 128 EAST KING STREET, SUITE A CARLISLE, PA 17013 October /} 2000 By: Joh . Baranski, Jr., Esquire Attorney to. No. 82585 35 East High Street, Suite 202 Carlisle, PA 17013 Attorney for Defendant j~^'" r~ l., ~ " !J ' " ~ '" ~ , . ~ ,-,' -'"' .- -~- ~ if -" -~ , w.., , -"l~" ~~_",-< 1_ <,'" I ," -, ,-~ ,>,.' ":'-" '--":;'.- ...c o ,- u~.~ nli.::' ;,:_,:"'_' i~t~1 ~ j:;: ;_7C-' ~~~~; ("5 c) CJ ::--, --; r~..) (r, -, ';";' ~ ;'"\.~) (:J -< '"--i ,~~' ;--.> ~'-,! -'-" ~-:) -< ~ "'.. l>" 2 rIr ~ ~ ~ ~ r ~J. ~ " , .. . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA David Andrew Lawrence, Plaintiff : No. 2000-02773 : Civil Action - Law vs. : In Divorce Jamie Leah Lawrence, Defendant 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 in divorce or annulment may be 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 the custody or visitation rights of your children. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Courthouse, Carlisle, Pennsylvania. 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 ONE1 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 (717)-249-3166 .. , , .. . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA David Andrew Lawrence, Plaintiff : No. 2000-02773 : Civil Action - Law vs. : In Divorce Jamie Leah Lawrence, Defendant AMENDED COMPLAINT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. Plaintiff is David Andrew Lawrence, who currently resides at 44 Rustic Drive, Shippensburg, Cumberland County, Pennsylvania, since April 19, 1998. 2. Defendant is Jamie Leah Lawrence, who currently resides at 143 Park Place East, Shippensburg, Franklin County, Pennsylvania, since April 19, 1998. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this complaint. 4. The Plaintiff and Defendant were married on August 16, 1996, in Shippensburg, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. I., ___ <'_. _,"' .." '" " -- ~ > '""'" -"'.",. '_ "k~ '" .,- ~_ .. 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. Respectfully submitted. ~~C"J~ H. Anthony Adams, Esquire Attorney for Plaintiff 128 E. King Street Shippensburg, PA 17257 (717)-532-3270 -_ 0'''.' ~ .- .< " , --' ~, ~ , - ,,,-,,:,,- ,~', -,' "- . ....' 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. Section 4904 relating to unsworn falsification to authorities. 17~hk.l L, e David Andrew Lawrence Date: ~-,};}..oo o~ "< - ;'. ,'~ I ,,' ~' ~-' ;. - - ;'".-" 0 ' '0'._\' _,:'< IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNiY - PENNSYLVANIA David Andrew Lawrence, Plaintiff : No. 2000-02773 : Civil Action - Law vs. : In Divorce Jamie Lee Lawrence, Defendant AFFIDAVIT OF SERVICE H. Anthony Adams, Esquire being duly sworn according to law deposes and states that a complaint in divorce was mailed to Jamie Lee Lawrence of 143 Park Place East, Shippensburg, Pennsylvania 17257, certified mail, return receipt requested, on May 5, 2000 and was accepted on delivery by Jamie Leah Lawrence on May 9,2000 as shown by the attached receipt. ~~~, H. Anthony Adams, Esquire Attorney for Plaintiff 128 E. King Street Shippensburg, PA 17257 (717)-532-3270 Sworn to and subscribed this ~th~ay of Ma:, 2000. ~^~AQ~ENDER: ~ , Notary Public CIl D Complete 1.lems 1 and/or 2 for additional services. :g C~mplete Ilems 3, 4a, and 4b. My Com mission Expi res: ~ 0 ~~r~ foo~~~,ame and address on the reverse of this form $0 that we can return this e 0 Attac~ thiS form 10 the front of the mailpiece, or On the back if space does not QI permit. S 0 Write "Return Re~eipt. Requested' on the mailpiece below the article number. c 0 The Return Receipt wIll show 10 whom the article was delivered and the date o delivered. "g 3. Article Addressed to: 4a. Article Number IJ~.&~~ ~ N5 PwCk {JLa& ~ ~ ~ 7'/9S7 z a: ~ 5. w a: I also wish to receive the fd,'qW- ing services (for an extra fee): 4b. ~rvice Type t:9'fiegistered o Express Mail o Return Receipt for Merchandise o Certified o Insured DeOD ~ .. "S; Iii III 'li. 1ii .. .. a: c !; 'Q; a: '" c "; " ~ .2 " o ... '" c .. .c .... 1. 0 Addressee's Address t 2. ~ricted Delivery 7. Date of Delivery .:! 0..)" 8. Addressee's Address (Only if requested and fee is paid) j 102595-99-6-0223 Domestic Return Receipt 1M ~,I" \ \ . ',- ~,,,",,... ,'-", -',.--,,,,' ~ ,"-i. ^^ ~ g g 0 "n ""O~ '~ :::l j:>' ~:\l?J ~ "! ~ i~ rv -::i:J:\ 0" ;-",'1:: ~6 ':;'~o -0 ._. -ft _~; -1;'\ %8 :J' s~6 r.a ,,-.-fii ';Pc g 7:, l'o> ~ ':2 V\ "