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Home My WebLink About00-03320 -'<' 'U ," 'r_.' "'~. ' ., ""j.. . < ~:.<<~~::~*:.c~:;'-::*:'+::!;:::::*~':)3::{;'~~)(:::!:'+:::~:)";:'XC.(:::*:'+>~)3C('X*~}::C()3};;:::::!:'*~:;XC!;::::*3";:::::!::C(:::!::+::i(,::~:'C!;Y~*W~i)~~;*:.c!f~>>::,;:~~!::+::!n*:.c!a:!:.+>a:*:.c:~[, ~ I v _. ~ ~ ~ I ~ I IN THE COURT OF COMMON PLEAS l:~ ~ '",,' a ~:~ ~ a ~.~ ~.'~ ~ ".,; ~.~ ~ ?~~ ~ ~ J~ ~~~ ~ i. ..~ I .. ..;...>:;:>.~-,.:::.:+::( -'~<+::.,-: ':-.:+>:: ':~- I ~ I ~.~ ~ ~ ~.~ h ~ ~.; ~ ~.~ ~ ~.;; * ".", . ~ ~i S 'd j;.~<i ~ V~ t~ ~ ~.s e ~.; ~ ~.~ ~ ~ ~ I ~+:~ ~ ~~~ ~ I' ~~ ~.~ . ~ a ~.~ a ~.\! ~ ~.~ ;.~ ~ ,,~ ~~ ::~::.::.::: )::.::<:: ~::.::.:: )::+::{ :::.::+::.,::>;::+;.:, :.,.::.::.< ::'.::.::~:'.>::+::"': X.::~;' OF CUMBERLAND COUNTY STATE OF PENNA. nI;~""p~.uG~, Plaintiff N o. ..z.~~.o.-::~.3.~~.. CI.\T~~...~~.~ VerSilS CIVIL ACTION - LAW ..~lJSMl..I:l...g"~, Defendant IN DIVORCE DECREE IN DIVORCE AND NOW, . . . S.:.tc.'":'>.Lc). . :4-1. .. . .. . , decreed that.. . .. .. . . ~~!'!'.~:. ~:\~. ... . . . . . . . . .. .. .. .. .. .. . " plaintiff, and.................. P!~~ .~'. .~~......................., defendant, are divorced from the bonds of matrimony. 2000 .... ..... it is ordered and 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; .. .~~~.~~~~~~~~.~~~~~~~~~~.~~~~~~~~;.~~;~~.~~P;~~~~~.~?,.?999.~~~.~~g~~~.PY the partie~.~~.q~r~~y'.~~~q~pq,~~~g.~~~q.~~~~.~~~.~~,.P~t.~9t.~~rg~~....... .......... . uuofur. . B '0h;;1:,.~m Auem:n'uuun,d" mn c - __n__ J. Vn, C';'", ~~:,. )3::~:: ':.::C!::: ).:+::{'::<C~::: >'>>::~;'_ )::.;~:,: >;::+:>'; ::'.::+::< ':,~"::~;.: >;::.::~;:_ --'.::+::< -':.3::~-,: ':'.::.::.'" i.~~ ~ i ~.~ . ~ I i ~.~ ~.; ., ~.S ~ i ~ ,,+,,, ~ ~.~ ~.s ~ ~ ~ ~,.~ ~~~ ~ ;;i ~ ~.~ ~.~ ~ ~ ~.~ t1 i ~.~ N . ~)~ ~ ~ M ~.~ ~ ~.~ ~ ~.,; ~ ~.~ ~ :"., i ~.~ ~ ~.~ '",' ~ ~.~ ~ ~.~ ~ "l ~ ." $ . L. !'<".." "_ A"",...,,,," ." ,~., ~, "" -;'.. - '" 1",'"' :-;2~ '&0 M. ~ ~~ -?Z a.f ~ tfdS.C't:J :n'~' ~ z ~(/. , , '.. .,Ii.",l. ',.,"_;.'T. :^ _=n,,,,,,^,e. "'~~ ., -~ "~'" '"'''',~-.-''' -," .. ^~ , ' ,,-~- e""""""" n~' .' ,~ '-,-,,';~,'~"'( . '.,~ :.'0""""__ "..3','" ".~"~"<",...'_!-,~""~ _C," , '--""".-';'~i;-~ ",;;.0".".;":1,,, ~~,.1 MARRIAGE SETTLEMENT AGREEMENT THIS AGREEMENT made this )9 'l4.day of Sept em bet, 2000, by and between SUSAN M. GARMAN, (hereinafter referred to as "WIFE") and LINN P. GARMAN, (hereinafter referred to as "HUSBAND"). WITNESSETH: WHEREAS, HUSBAND and WIFE were lawfully married on November 13, 1993, in Enola, Pennsylvania. The parties hereto agree and covenant as follows: 1. The parties intend to maintain separate and permanent domiciles and to live apart from each other. It is the intent and purpose of this Agreement to set forth the respective rights and duties of the parties while they continue to live apart from each other. 2. The parties have attempted to divide their matrimonial property in a manner which conforms to a just and right standard, with due tegard to the rights of each party. It is the intent of the parties that such division shall be fmal and shall forever determine their respective rights. The division of existing marital property is not intended by the parties to constitute in any way a sale or exchange of assets. , "<'",-".,-' "',- '"'._'~,~ -.,-' i''';;''~-'';;'-'_;>_';', .,.'. 1 '.-' _ ,'. c _ ~ -c ,. - "-- '~ .; -; .. . -..",-- " ,,_ '__' _'_~,'_'_,,: ,_ _:+"_ _,_ _;. ., __ n_,_,', ',' ,_,_,,', _, " --..' '0._ ;". ;-",--";;><-~>-,,~-"<"-, ~--- "-;;,,-'---~':.,";~ '.';d;' ,-,- ,,^,,, ~", .,' -, ',~,' ,~- i (3) enters into this Agreement voluntarily after receiving the advice of counsel; (4) has given careful and mature thought to the making ofthis Agreement; (5) has carefully read each provision of this Agreement; and (6) fully and completely understands each provision of this Agreement, both as to the subject matter and legal effect. This Agreement shall become effective immediately as of the date of execution. 5. It is the purpose and intent of this Agreement to settle forever and completely the interest and obligations of the parties in all property that they own separately, and all property that would qualifY as marital property under the Pennsylvania Divorce Code, Title 23, Section 401(e), and that is referred to in this Agreement as "Marital Property", as between themselves, their heirs and assigns. The parties have attempted to divide their Marital Property in a manner that conforms to a just and fair standard, with due regard to the tights of each Party. The division of existing Marital Property is not intended by the parties to constitute in any way a sale or exchange of assets, and the division is being effected without the introduction of outside funds or other property not constituting a part of the marital estate. It is the further purpose of this Agreement to settle forever and completely any obligation under the Pennsylvania Divorce Code relating to spousal support or alimony. 3 .',.'_ ,-,'"_,,'..... -'OM ->. n, .~,'_ - '"_~,'--__\,c~','._.._'_'.. ;"..c."- R. .'--'--'i--<""b'" '.' :.,.-, "',- ->--. -~. ~;'-. -"~~-;:~:~:..;<';;"- ;~:~~~: "' - -,;-;'~" "."':<,--" ,- '"..'j 6. Each party represents and warrants that he or she has made a full and fait disclosure to the other of all of his or her property interests of any nature, including any mortgage, pledge, lien, charge, security interest, encumbrance, or restriction to which any property is subject. Each party further represents that he or she has made a full and fait disclosure of all debts and obligations of any nature for which he or she is currently liable or may become liable. Each further represents and warrants that he or she has not made any gifts or transfers for inadequate consideration of Marital Property without the prior consent of the other. Each Party acknowledges that, to the extent desired, he or she has had access to all joint and separate State and Federal Tax Returns filed by or on behalf of either or both Parties during marriage. 7. mEAL ESTATE: HUSBAND hereby agrees to transfer to WIFE exclusive possession of the marital residence at 19 Lancaster Avenue, Enola, Cumberland County, Pennsylvania, and will waive all right, title and interest in the property if WIFE chooses to sell said ptoperty. HUSBAND agrees to execute a deed within thirty (30) days from the date of the execution of this Agreement transferring said property into WIFE'S name individually, and WIFE agrees to assume all liability for and indemnify HUSBAND against the mortgages currently against said residence, and agrees to be solely responsible for the payments associated with said mortgages. WIFE further agrees to have HUSBAND'S name removed from the marital mortgages within six (6) months from the date of the execution of this Agreement. The removal of HUSBAND'S name from the mortgages shall occur either by refmancing or assumption of the current ~Y:;' " 4 _ ,-,_,_ '-'_F' ",_',,_,c'_, <- - "',' -; _'''''__'-,~i,' '_,,",,--;-- - , - _ ,.', _ ~,__~ ._ ._, __" _' , .- ,-_ -'_'" ',----_ .'~;; -:,,-,.,;;,",,~~':,,;, - '~"""-""~'; ,-, ,;"-<,,,_;,' ..~";-'.oc,__~'".' ~ mortgages by WIFE. The Deed executed by HUSBAND shall be held in escrow with HUSBAND'S attorney until his name is removed from the mortgage. HUSBAND shall maintain exclusive possession of the mobile garage which is on the property of the marital residence. HUSBAND shall have at least one year from the date of signing this agreement to move said mobile garage from the marital residence. The parties by mutual agreement may agree to extend the time period for removal of the mobile garage. 8. SUPPORT: It is the mutual desire of the parties that HUSBAND will not be required to pay support to the WIFE. WIFE will not provide any fmancial support to the HUSBAND. The parties also waive any right they have to receive alimony payments from the other following the entry of the Divorce Decree in this matter. 9. PERSONAL PROPERTY: The parties agree that the personal property has been divided to the parties' mutual satisfaction. The WIFE hereby waives all right and title which she may have in any personal property of the HUSBAND. HUSBAND likewise waives any interest which he has in the personal property of the WIFE. Henceforth, each of the parties shall own, have and enjoy independently of any claim or tight of the other party, all items of personal property of every kind, nature and description and wherever situated, which are then owned or held by or which may hereafter belong to the HUSBAND or WIFE with full power to the HUSBAND or the WIFE to dispose of same as fully and effectually, in all respects and for all purposes as if he or she were unmarried. 5 y~'~',,'.',.' ,"'.._ "-,:," .' _., _,_ ", ,," ,,--te-,,,--'",,,'d--"""c,-,--~, ,"~'L'_ ~-;__-""o .',. ~ - ~,--,- - ,,,,-.: . "'I - '<-, ,~~~;; ,,~'-- -~,;o,,, ;,-. ,- ;,d.;;~i:,c - !'-'__;n';;h':';_;""._. __. ., 'o___n-,' :"._,' 10. AUTOMOBILES: The parties hereby agree that WIFE shall retain the 1995 Ford Escort or any other vehicles which are currently in her possession. HUSBAND hereby waives all right, title and intetest in the vehicles which are currently in possession of WIFE. WIFE shall hold HUSBAND harmless for any and all liability associated with the use and purchase of the cars and any vehicle she may now or in the future own, and shall be solely responsible for all insurance and other fmancial responsibility associated with said vehicle. The parties hereby agree that HUSBAND shall retain the 1992 Ford F-150, the 1972 Ford Mustang and the 1967 Chevy Chevelle or any other vehicles which are currently in his possession. WIFE hereby agrees to transfer and waive all right, title and interest in the vehicles which are currently in possession of HUSBAND. HUSBAND shall hold WIFE harmless fot any and all liability associated with the use and purchase of the cars and any vehicle he may now or in the future own, and shall be solely responsible for all insurance and other financial responsibility associated with said vehicle. 11. MARITAL DEBTS: It is mutually agreed by and between the parties that WIFE shall assume all liability for and pay and indemnify the HUSBAND against all debts incurred by WIFE after the date of separation. WIFE tepresents and warrants to HUSBAND that since the parties' marital separation she has not contracted or incurred any debt or liability for which HUSBAND or his estate might be responsible and WIFE further represents and warrants to HUSBAND that she will not contract or incur any debt or liability after the execution of this Agreement, for which HUSBAND or his estate might be responsible. WIFE 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. :-'-",'" 6 -.', ~~c-_ ...." _"_"-,,.:'~ ~",,',. "'-"-;,-",",0\.;"," '---~-,'6-"'; _. "__ '4 - ~ -':, _V<~',~<;.;';; ,-- -, F -:;,:-;;,-:;,;:~i.~:;;,;' :,",'-, ~'<'"'""" ,.- .', HUSBAND shall assume all liability for and pay and indemnify the WIFE against all debts incurred by HUSBAND after the date of separation. HUSBAND represents and warrants to WIFE that since the parties' marital separation he has not contracted or incurred any debt or liability for which WIFE or her estate might be responsible and HUSBAND further represents and warrants to WIFE that he will not contract or incur any debt or liability after the execution of this Agreement, for which WIFE or her estate might be responsible. HUSBAND 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. WIFE agrees to pay and remain solely responsible for the balances on the following credit cards: 1. Visa; 2. Texaco; HUSBAND agrees to pay and remain solely responsible for the balances on the following credit cards: I. Mastercard; Each party shall indemnify and hold harmless the other with respect to any of the obligations stated above for which the other party is not responsible. 7 ^ "'-, '_o-~ _ :i',o. -'. ~-, ' - ,__~-__,~ ';,-0;", '_oe~' 'i :'., .'.- ,,'-,"::: -:..."",';,' '., ,:: '-.::' ,__''0.-,,-,' ""'r,I', .-:,"_-,,",~;".,~ :-_:'-'~'~~.;',";::-:~,S::~~-~~'::;-2:';'-':l:;~,;2{L~_:,~:; ',' - - ,_~ - --~ " ,j' 12. CUSTODY: The parties hereto, being the natural parents of Jesse T. Garman, born April 3, 1997, age 3 years, and desiring to set forth the rights and obligations relating to the custody of said child, hereby agree as follows: A. The parties shall enjoy shared legal custody of the minor child; B. The parties shall enjoy shared physical custody of the minor child; C. The parties shall enjoy periods of physical custody with the minor child subject to the following schedule: 1. WlFEIMOTHER will have child on Sunday, Monday and Wednesday to include the entire day and overnight. WIFEIMOTHER will also have child on alternating Fridays. HUSBANDIFATHER will have child on Tuesday, Thursday and Saturday to include the entire day and overnight. HUSBAND/FATHER will also have child on alternating Fridays. 2. The parties hereto agree that holiday and vacation schedules will be decided mutually between the parties. 3. The parties hereto agree that if either party would like to have the children for both Saturday and Sunday on any particular weekend the consent of both parties in advance of that weekend is required. 4. The parties hereto agree that if a change in the days of custody is to be made it will be made in advance with the consent of both parties. 5. The parties hereto agree to equally share transportation for the applicable transfers of custody as outlined herein. 8 0',. "'-_ _,~-., - ),,,,:,,","-""'-.;;~-,-c,,-,:. ,'",.;-,' ,..'" ','- " "_^,,,' ,;.' ~.. ,- ," '---~ ",->"'fl"""'-'" : "i.:,,', ~_ ,,,- : ;;:;"'J:.,~';d;.~;:'~'-k:.~ " _ " 13. INSURANCE AND EMPLOYEE BENEFITS: The parties agree that any life insurance policies on the life of HUSBAND or WIFE or any other employee benefits, including but not limited to tetirement, profit sharing or medical benefits of either party, shall be their own. WIFE waives all right, title and claim to HUSBAND'S employee benefits, and HUSBAND waives all right, title, and claim to any of WIFE'S employee benefits. 14. BENEFITS AND BANK ACCOUNTS: WIFE agrees to waive all right, title and interest which she may have in the savings or checking or any other bank accounts of the HUSBAND. The HUSBAND agrees to waive all interest which he has in the savings or checking or any othet bank accounts of the WIFE. 15. INCOME TAX EXEMPTIONS FOR CHILDREN: The income tax exemption for the parties minor child will alternate yearly with HUSBANDIFATHER claiming the child for the year 2000 and WIFEIMOTHER claiming the child for the year 200 I and so on and so forth. 16. DllVORCE: The parties both agree to cooperate with each othet in obtaining a final divorce of the marriage. It is agreed that the parties will execute and file the consents necessary to obtain the divorce. Any party who fails to cooperate with obtaining the Divorce shall pay all the costs and legal fees of the party who is seeking the divorce. ~,'>:-t', 9 ""=; ~, '.j-" - '~" '.' .~.>~__l '~',,""'",,'-'~-,,-i;o-&. .,' - - -"'>; '''-' ,-" ~,..~ i".,-':" -,..__.,;)~'":;:,::~?t:::___-:;' -""-'e-' S:,~,;;.,~-,-/,~_ ,',;,,;..; ~-; I ,- ~---">'-'i) 17. 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 should be responsible for payment of legal fees and costs incurred by the other in enforcing their rights under this Agreement. 18. ADDITIONAL INSTRUMENTS: Each of the parties shall from time to time, at the request of the other, execute, acknowledge and deliver to the other party any and all further instruments that may be reasonably required to give full force and effect to the provisions of this Agreement. 19. VOLUNTARY EXECUTION: The provisions of this Agreement and their legal effect have been fully explained to the parties by their respective counsel, and each party acknowledges that the Agreement is fair and equitable, and that it is being entered into voluntarily, and that it is not the result of any duress or undue influence. The provisions of this Agreement are fully understood by both parties and each party acknowledges that the 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. 10 ',', _.---, " .:. ""..-:,'~~_4' ~', ",. _,,~_,,~ ,. "'> "L-_' :'__;" ",..~--:,.';;;",~,:.,'-:--; .,'-_~-_ _".T_>-""", -,~,..-..~. , i 20. 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. 21. APPLICABLE LAW: This Agreement shall be construed under the Laws of the Commonwealth of Pennsylvania. 22. PRIOR AGREEMENTS: 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. 23. PAYMENT OF COSTS: The parties agree to pay for their own costs tequired to obtain and complete the divorce. 24. WAIVER OF CLAIMS AGAINST ESTATES: Except as herein otherwise provided, 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 11 , :.' ~-,---" ,- "'~ - , ' _" :~-~&_"<,_,,._, - w ,-' ,_.~ "", _ . ,.~-~,:- -c_';:2_!~;:~~;.i;'t~;.- - -'-,,,-,,--, -,~-,;- ,-~-,;:.~~--; - " - , < ;,. ""d , , marital relationship, including without limitation, dower, curtesy, 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, at the request of the other, execute, acknowledge and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interests, rights and claims. IN WITNESS WHEREOF, the parties hereunto have set their hands and seals the day and year first above written. WITNESSES: 2~ '1YI.~ / SUSAN M. GARMAN (SEAL) ~j/~ (SEAL) LINN P. GARMAN 12 '0-' ., ,,. " ;c_'-,,_-"; '"-__,,,",,,,,.: .'~--' _.',.:, ----.,'-- .. - -'.' "--. .-.' , ,'_--'-_-,d,:_~- .- ,'C',' ',G-_,'; "'h';'-''-'" ". __ :__ .c,:_ COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF CUMBERLAND PERSONALLY APPEARED BEFORE ME, this I =$~ay of September, 2000, a Notary Public, in and for the Commonwealth of Pennsylvania and County of Cumberland, SUSAN M. GARMAN, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Marriage Settlement Agreement, and acknowledges that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. Notarial Seal Betzl A, Morrison, Notary Public Carlisle Bor,.. Cumberlan:l County My Commlssln" Explras Dec. 15,2000 MEmber, Pennsylvania Association of ;', i..lIes COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF CUMBERLAND PERSONALLY APPEARED BEFORE ME, this J 2.. tly day of September, 2000, a Notary Public, in and for the Commonwealth of Pennsylvania and County of Cumberland, LINN P. GARMAN, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Marriage Settlement Agreement, and acknowledges that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. ~~:P.'-{~ Notarial Seal Martha l. Noel, Notary Public Carlisle. Bom, Cumberland County My Commission Expires Sept. 18 2003 '!iamber, pe~~ ASSOcIation at ~otarjes 13 '" ;'>., " , ~ """".~~" ^ . ,,~-~ . .;"~_",,,__ ". .,u ,~ ,~, . "ii; '"-~, '. ; ,-, ~ (") ~::) 0 C c:,; ....n $;: U) ':1:j., rRm ,." ,'.,:t'!-j 'U nJ~ ~:tJ "'"CIrri ~.;;;; ~ ~"? D( ~t~ "~ 5!t~/ -",.. Q~ ~O :if 7~ '5>0 ."'2l .l.Y. c: :;;' ~ => .;:0 m -< ,. ~~, . =", '"",- ~ .> ... .. " . .. ... " Ie' ;:n__ --"^,,-,.o~, .. ~-; . . , LINN P. GARMAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW 2000-3320 CIVIL TERM SUSAN M. GARMAN, Defendant 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 3301(c) of the Divorce Code. 2. Date and manner of service of complaint: A certified copy of the Complaint in Divorce was served upon the defendant, Susan M. Garman, on June 8, 2000, by certified, restricted delivery mail, addressed to her at 19 Lancaster Avenue, Bnola, Pennsylvania 17025, with Return Receipt Number Z 013 345 839. 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by plaintiff: September 12,2000; by defendant: September 13, 2000. (b)(I) Date of execution of the affidavit required by Section 3301(d) of the Divorce Code: (b )(2) Date of filing and service of the plaintitl's affidavit upon the defendant: 4. Related claims pending: NONE. 5. Complete either (a) or (b). (a) Date and manner of service of the Notice of Intention to file Praecipe to Transmit Record, a copy of which is attached: (b) Date plaintitl's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: September 14, 2000. Date defendant's Waiver of Notice in Section Prothonotary: September 14, 2000. D. SC ARTZ, ESQUIRE Attorney for Plaintiff I I I. " ",0.''000..... " >"...~- - - ALfb.C'l~'lr-r: O,~ '1..:- "M_,"y, n""- '.- ,J." '1'-' "'O""tJy -- , "" - i 1\,fV' it-li-, 00 Sfp 14 Pi1 3: OS CUMBfhllWD COUNTy . PENNSYLVANIA . , -, -~ '"-":"," ", ,,'--'~ ~ .',o~ . ''V. '-j___ - ---~ " LINN P. GARMAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW 2000-~CIVIL TERM SUSAN M. GARMAN, Defendant IN DIVORCE NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree in divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request 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, 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 ALA WYER 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, Pennsylvania 17013 717-249-3166 1-800-990-9108 ""."' "" ~--d"'-' ""__"__~r<' .",~-- '_'e' -"~-,,, f_i'-~-' -.-~"-" '""",~ -","-'''-,"~.,"v - -"-';;' ~ ~ "--;"-'~:<l j r , AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. .- . ^_ d~_ <'C-''''.;:''''''''' "'S""',""",,,._, LINN P. GARMAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW 2ooo-33Jo CIVIL TERM SUSAN M. GARMAN, Defendant IN DIVORCE COMPLAINT IN DIVORCE PURSUANT TO SECTION 3301(c) OF THE DIVORCE CODE NOW comes the plaintiff, Linn P. Garman, by his attorney, Mark D. Schwartz, Esquire, and files this complaint in divorce against the defendant, Susan M. Garman, representing as follows: 1. The plaintiff is Linn P. Garman, an adult individual residing at 3825 Elmerton Avenue, Harrisburg, Pennsylvania 17011. 2. The defendant is Susan M. Garman, an adult individual residing at 19 Lancaster Avenue, Enola, Pennsylvania 17025. 3. The defendant has been a resident of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The plaintiff and the defendant were married on November 13, 1993 in Enola, Pennsylvania, and separated on January 7,2000. 5. There have been no prior actions of divorce or for annulment between the parties. 6. There was one (I) child born to this marriage; namely Jesse T. Garman, born April 3, 1997, age three (3) years. 7. Pursuant to the Divorce Code, Section 3301(c), the plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. 8. The plaintiff avers that he has been advised of the availability of counseling and that said party has the right to request that the court require the parties to participate in counseling. WHEREFORE, the plaintiff demands judgment dissolving the marriage between the two parties. Respectfully submitted, By: It Mark D. Schwartz, Esquire Attorney for Plaintiff West Pomfret Professional Building 60 West Pomfret Street Carlisle, Pennsylvania 17013-3222 (717) 249-2353 Supreme Court I.D. No. 70216 Date: May 30th ,2000 " ~. "."."." "".'."'."" ""'j , , I I I I I I I ; I VERIFICATION The foregoing Complaint in Divorce is based upon information which has been gathered by my counsel and me in the preparation of this action. I have read the statements made in this Complaint and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. .::Z.. .. # ......,Gf..'v .",. .- LINN P. GARMAN Date: May 30th ,2000 . ~ ;::-:- I.JJ\'" (,);~ ~p:: r:) 5t:' &5 ~-c:.~ cr,~~ ~. ''-- o ~~ .~ ~- - ~ \0 c.~ ..:; ~ c C>) >- i? fS ?i :5 C?i ("~ :2!-' ~C ..J;J (c.-o. I.lJ(t; !j?Q;: El ._-..~-~."-'- ." 'y-~ ._~>d_', ""'-,- ~ ~,~."-- - '_-~~"~-~''''''"'~.'' "-<<---I~"""-c"_I: " LINN P. GARMAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW 2000-3320 CIVIL TERM SUSAN M. GARMAN, Defendant IN DIVORCE AFFIDAVIT OF SERVICE OF COMPLAINT PURSUANT TO PA. RC.P. RULE NO. 1920.4 (a)(1)(O COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF CUMBERLAND NOW, Mark D. Schwartz, Esquite, being duly sworn according to law, does depose and state: 1. That he is a competent adult and attorney for the plaintiff in the captioned action in divorce. 2. That a certified copy of the Complaint in Divorce was served upon the defendant, Susan M. Garman, on June 8, 2000, by certified, restricted delivery mail, addressed to her at 19 Lancaster Avenue, Enola, Pennsylvania 17025, with Return Receipt Number Z 013 345 839. 3. That the said receipt for certified mail is signed and attached hereto and made a part hereof. I verify that the statements made in this affidavit 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 """",m fuhi""",,. to """""'rim. ~~~ v D. SCHWARTZ, ESQUIRE Attorney for Plaintiff Date: September 13, 2000 , . , h,," ,'.< '__"'_l -ri.~. -- """_"_~,,,"O._ -, -~"~ ,'" + Z 013 345 839 us Postal Service Receipt for CE!~ified Mail No Insurance Covera!f3lProvided. Do not use far International Mail (See rsvetse) Sent 10 SUSAN M GARMAN Street & Number 19 LANCASTER.AVE Post Office. State. & ZIP Code ENOLA PA 17025 Postage X $ \ II Certified Fee X \,I../D Special Delivefy Fee Restricted Oellvely Fee h ),75 Return Receipt Showing to \ r~ ~ Whom & Date Delivered X II.' Ret\Jm Recei~ 5IIowil\gto Whom. . Oale,& Addressoe's Address TOTAL Postage & Fees x$ /;, i7 PostmaJk or Date MARK 05-30-00 GARMAN - SERVE DIV. COMP. 1-..-.- ill '" - 'E ~ o o ... C'l E o "- en 0. -'- -'", .- ~ -- - --.. - - . Complete items 1.~ 2, and 3. Also complete item 4 if RestrictEkl Delivery is desired. . Print your name and address on the reverse 50 that we can return the card to you. . Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: SUSAN M GAllMAN 19 LANCASTER AVE ENOLA PA 17025 :/1,'; x o Agent o Addressee DYes i!!i No D. Is delivery address different from item 1? If YES, enter delivery address below: 3. SelViee Type iXi Certified Mail o Registered o Insured Mail . estrieted. Delivery? o Express Mail o Return Receipt for Merchandise o C.O.D. Fee) III Yes 2. Article !\lumber (flapy from service label) . :/:. 013 345 8:}9 PS Form 3811, JulY 1999 Domestic Return Receipt 102595-99-M-1769 "' ~ '_oj - ~ -~~' I I i I I I I , ! I I I '""" . < ,.f '. ,"" ~__ ~ ~" ~I,_- ~ ~ r" ". 'r -lil '.--'~ - --'.. ~" , " f'f- .", :.-. ;-,.",-,,~ jOO 'Jil;ci~( !fJ "'"'l,} ,} .5; . :;$-4.- ~o , ~8 :3 c..; ~ .. 0 N ~ - ~- " ~- - -.~ ...~ - . ->>',,",'. .>C'-, ," .--,. - "' -" LINN P. GARMAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW 2000-3320 CIVIL TERM SUSAN M. GARMAN, Defendant IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A complaint in divotce under Section 3301(c) of the Divorce Code was filed on May 30, 2000. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the complaint. 3. I consent to the entry of a fmal decree in divorce. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! do not claim them before a divorce is granted. I verify that the statements made in this affidavit 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. Date: September ,,,'\1\ ,2000 ;z:;- fl ~ LlNNP.GARMAN ',--k-"" " ~ 0 0 0 -q ~ '-'1 ~W ;;it~ rn ''0 :;r:: "{.liS 2(: .r:- Ctj~ :lJ.1 ...'-} ;::siC; ':-::-.rO 10 " 7: ::R ::?K .',:>- . ~o ~ '::.-' O-f'r1 ':;:. ~ I\} -< . . - ~ --'"~.~--,- . ~ - -'~-' " <- -,",,' ""' ,,-<,->' h.' " ~""~ ~'" ~~-"-,:-"-,-,,,,,,,,,\:;';'-,i'h,,i<,,~",;,ckc,,_.'" _ "'_, LINN P. GARMAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW 2000-3320 CIVIL TERM SUSAN M. GARMAN, Defendant IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on May 30, 2000. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the complaint. 3. I consent to the entry of a final dectee in divotce. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! do not claim them before a divorce is granted. I verifY that the statements made in this affidavit 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. Date: September ~, 2000 ;'''Q L'1 1Yl"'..tlu fY\O../l SUSAN M. GARMAN "lIIlIIilill~'- 1-"""- ~ -- 'L . '~'''--~".''''~111(' ~ ."''''~~_ J',..,,~ " r-,' (") <=I 0 ~ 0 -q CI) ---j '"- rRffl i""1 :;;~-i1d <, -0 ~i!! -urn .t:. -~'.o ~e 01.. -" t;1 -0 -r: _" 3Eo ~ c~-- 2:0 5>8 :~ om ~ 0 ~ t.) -< '" " LINN P. GARMAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW 2000-3320 CIVIL TERM SUSAN M. GARMAN, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE I. 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 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 made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsifIcation to authorities. Date: September \1 'tI- , 2000 ~~~ LINNP.GARMAN Plaintiff -, .,-, ,_~ w.?-_ ~" ~ , -......~".d'T " ~ ..""- " ., n' "In''''''' ,- .~. ~-~,- ..--. " e 0 0 0 'n <::: en ~-:-j ~fb fTl J-;'k_;~ .9') -0 -T"-fTl Zr;:: .c- >j,) 0 ~:?: I..~)(-S ~C -1::1 c;:J-.., ~-n :;;::: St- io - (") 2 ~ _~,m '-' ~ => ~ <.J" -< (;) . . . "-."-~",-", .-.-<. "''''<~'-^''~'-'- ",'",'-;- ~'-;';""''''''''''/'AL.iYL;,-~; <',. .',,"" --;.," ',>> " " LINN P. GARMAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW 2000-3320 CIVIL TERM SUSAN M. GARMAN, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) oF'THE DIVORCE CODE 1. I consent to the entry of a fmal Decree of Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the dectee 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 made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: September \ 3 , 2000 AL(laY/ /Y). 1I~ / SUSAN M. GARMAN Defendant ',:: ;,~, ,_~,~_"~';._J" ",- --'''. ",},-"~,-- ..... ... ~.. , 117- .. '-'1I.'<IP'~'''''''''' ~~_"IIi_' '-". - ,.....j~-' " ~ 8 Sf: U) ;:;1~:!: ~ m "'0 :,,:;~n ..,- ,'J r' ~;z 8<":; :<:;0 v ~~ ~8 :x >c: Sl' om ~ <::) ~ of:" -< _ ,;'1;' ""0",';; -,"J_ r -', 0'. '~j "._,,~.,;;,~ , ',' ,,', '_',r,'"_~"'~','o .\;S,' "c~~_;"''-''';''><,,,,<,...,);_";_ << ';:;,".~':::>;-Ji:ii;>~';..,~ --"'''1 n.; . LINN P. GARMAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW 2000-3320 CIVIL TERM SUSAN M. GARMAN, Defendant IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, being duly sworn according to law, deposes and says: I. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Prothonotary's 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. I verifY that the statements made in this affidavit 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. ~" Date: September \'4 , 2000 ,;z::; . - #~ LINN P. GARMAN ~ - " 8 0 0 0 -n ~ (/) ---! , !:d ;';OJ''if9 :!~f9 ~e .r:- 0- C{.,:S ~ ""I;) .~"';J ::.r-. ~o -'-"11 :r ~(~ :i>8 ~ om ~ 0 ~ .;:- -< .~ Cd" '"C"'C."', "h~"~" ,~4.;; .." O",~*~,,;, ,_-~~ ,;..,..- '~ "_~ ./,;.__, , ,-_,_,,-__ d--^ci -,~..",- --'---'.o-.~L'--';;";- ,,":-:'_';:-_:/i~~'-:-,~(' ,-.-. __ -',,-"',.;"~d' ' ~ ,;1 ", LINN P. GARMAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CML ACTION - LAW 2000-3320 CML TERM SUSAN M. GARMAN, Defendant IN DIVORCE DEFENDANT'S MARRIAGE COUNSELING AFFIDAVIT The defendant, being duly sworn according to law, deposes and says: I. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Prothonotary's 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. I verify that the statements made in this affidavit 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. Date: September \.3 , 2000 1",.1) an '177 -1/((/1 /JMUA- /. SUSAN M. GARMAN -<- -,. -L -', _\i- 'l-~- ~--:!;;,:: '''"''''--;~ ~-( .1__"'I--'~'''' -;;;^-"-~!'>~ "-'...... ,-+ '" ,-, g--.g s:: en ~'OJ. . -, J:I"f... _ z9:l ..." mS? ;: ~:;a; Is ~ ~ ,;=. -< .r:- o -n .--'4 ;~'tl~ '~~'IT! ~r:1Q ;-.... '! ~f..-J :T:.=H O'~-: ",,0 5m :'Pi ~ " = ~, ~~- SOCIAL SECURITY INFORMATION SHEET PURSUANT TO 23 Pa.C.S.A. SECTION 4304.1 (a) (3) ALL DIVORCES MUST INCLUDE THE PARTIES SOCIAL SECURITY NUMBER PLEASE FILL IN THE APPROPRIATE INFORMATION AND RETURN TO THE PROTHONOTARY'S OFFICE DATE: September 13, 2000 DOCKET NUMBER: 2000-3320 CIVIL TERM PLAINTIFF~SS# 196-48-2607 NAME: LINN P. GARMAN DEFENDANT~ SS # 197-68-4762 NAME: SUSAN M. GARMAN