The URL can be used to link to this page

Home My WebLink About00-04693 - '~~'" - . . .. . . ... . .. . . . . IN THE COURT OF COMMON PLEAS . OF CUMBERLAND COUNTY . PENNA. . STATE OF . . . \JiQj(; K;mme.l f2..o..me..~ 'V\Qi f\ +; ~s;. No. dOoo - lj.(P'i'"3 . . . . . VERSUS . . . \)(11 e RG.'t Q.O--'f'(\e~ t <:- ~"dot\ -\-- . . . . . . . DECREE IN DIVORCE it ~~ (<f@ M. ~, IT IS ORDERED AND . . . e . . AND NOW, . eo.m-e. ~ , PLAINTIFF, . DECREED THAT . . AND \Jo-.\-e- Qo..j KO-mej , 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; . . /JO~L . . . . . . . . . . . . . .. :t: :t::t: :t::t::t: ~~, . . I . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . i~ ,"~Jlc.I.,~_...",""ll:" -~....,j,~ilrlDiiIIl""-' ~~~.~~-W~ "-'~..-'" ......... , ,-,":,: ,. ',>, .'-,' > !C~ '~ 1'13.t2J /. /3.tJ3 ~---.~ " .- - . 1llIIII...'~'- , . .' . .' tv.Iaw!"'~' # ~ ~.~~9' ~ ,'" ~ _... "'-." \)ic...t,' 1<: ""me.-( l2o.me.~ --:P\~; 1\.+ ~ H vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Do..le.. R. Q 1 Q(V'0e ~ \:)€. ~e", dO-Y"\ + PRAECIPE TO TRANSMIT RECORD CIVIL DIVISION NO. d,OOO - Lf 10 q ~ CIVIL TERM 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 93301 (c) 3:391(9)(1) af tRe DivgrM I"'nrl'). (Strike out inapplicable section). 2. Date and manner of service of the complaint: ('/~9/oo r;/eJ. d:\iooc.~ of the Divorce Code: (2) Date of filing and service of the plaintiff's affidavit upon the respondent: 4. Related claims pending: All A , 5. Complete either (a) or ~ (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 of plaintiff's Waiver of Notice in 93301 (c) Divorce was filed with the Prothonotary: ll{ '1/ 0 ~ Date defendant's Waiver of Notice in 93301 (c) Divorce was filed with Ihe Prothonotary: II It I 0 ~ L:'('){I:J( ~~~ Attorney for Plaintiff I fendan! ",~, ~- , I ,'~ " ~", ~,~' .. , r~ , ~ .' ~~J.,"" ~~l.~ 1 ,~-"-" - ,',~' ~" ,-",-"k:'i, ,~"" ",/' ~,'~'d,:' ,,- ' ~"'-"9';" ,~,'~ '" ,<- ~,.., ......".. 0 0 ~, ',-~ c.: w -.. S- C_ -0(,0 ;;:-flO ;~\ ~ ;p, f';'in; -. Z5: ..,.- -,-;l'J: I ZC N ".~-~~~ (D ",,,:~; ~.L-- r:::C; '-0 -,,"_ ~r~ "" """{';.. ~'2~9 "C ~ ;Z6 r;::> O.d~\ )>c: -' Z :".) :;p :<! ro ~ ~ ,!!"'"" -~ _r __,,:~~'W~~rnlIWflI~~"'~"_~ ,~~~".~ , " VICKI KIMMEL RAMEY, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v. ; NO. 00 - 4(,9;3 Co..(T~ DALE RAY RAMEY, Defendant : CIVIL ACTION - LAW : COMPLAINTINDIVORCE NOTICE TO: Dale Ray Ramey 14 Carter Place Carlisle,PA 17013 YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for 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, 1 Courthouse Square, 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 TillS PAPER TO YOUR LA WYERAT 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 Lawyer Rtlferral Service 2 Liberty Avenue' Carlisle, PA 17013 (717) 249-3166 , Document #: 177876.1 -j,. ..,,"" . "'r~' r VICKI KIMMEL RAMEY, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL V ANlA v. : NO. DALE RAY RAMEY, Defendant : CIVILACTION-LAW : COMPLAlNTIN DIVORCE NOTICIA TO: Dale Ray Ramey 14 Carter Place Carlisle, P A 17013 I USTED HA SIDO DEMANDADO/ A EN CORTEt Si usted desea defenderse de las demandas que se presentanmas adelante en las siquientes paginas, debe tOffiar accion dentro de los proximos veinte (20) dias despues de la notificacion de esd Demanda y A viso radicando personalmente 0 por medio de un abogado una comparecenciaescrita y radicando en la Corte por escrito sus defensas de, y objecciones a, las demandas pres~ntadas aqui en contra suya. Se Ie advierte de que si usted falla de tomar accion como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda 0 cualquier otra reclamacionor remedio solicitado por el demandante puede ser dictado en contra suya por la Corte sin mas aviso adicional. Usted puede perder dinero 0 propiedad u otros derechos importantes para usted. ' USTED DEBE LLEV ARESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTEDNO TIENE UN ABOGADOO NO PUEDEPAGARLEA UNO, LLAME 0 VA YAA LA SIGUIENTE OFICINAPARA A VERIGUARDONDEPUEDE ENCONTRAR ASISTENClA LEGAL. Cumberland County Lawyer Referral Service 2 Liberty Avenue Carlisle, PA 1701:3 (717) 249-3166 Document #: 177876.1 ,'> ',', ~ . -'[ ,..- v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL V ANlA ~ NO. 0tJ-<f(.73 ~ f.;..- VICKI KIMMEL RAMEY, Plaintiff DALE RAY RAMEY, Defendant : CIVIL ACTION - LAW : COMPLAINTINDIVORCE COMPLAINT IN DIVORCE 1. The Plaintiff is Vicki Kimmel Ramey, an adult individual currently residing at 39 Broad Street, Newville, Cumberland County, Pennsylvania 17241. 2. The Defendant is Dale Ray Ramey an adult individual residing at 14 Carter Place, Carlisle, Cumberland County, Pennsylvania 17013. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on February 26, 1997 in North Carolina. 5. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Rights Act of the Congress of 1940 and its amendments. 6. Plaintiffs social security number is 171-46-3893 and Defendant's social security number is 165-62-1855. 7. There have been no prior actions of divorce or for annulment between the parties. Document #: 177876.1 '''='_'lI' , ~ , '~r 8. Plaintiffhas 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. 9. There are no children born of the marriage. COUNT! Divorce 10. The averments of paragraphs 1-9 hereof are incorporated herein by reference. 11. The marriage is irretrievably broken. 12. Defendanthas offered such indignities to Plaintiff, the innocent and injured spouse, as to render Plaintiff's condition intolerable and life burdensome. 13. Plaintiff requests the Court to enter a Decree in Divorce divorcing Plaintiff and Defendant. COUNT II Equitable Distribution 14. The averments of paragraph 1-13 are incorporated herein by reference. 15. During the marriage the parties acquired marital property, assets, and debts which Plaintiff requests the Court equitably distribute and assign. Document #: 177876.1 ~'''.~I>Il'l-, ~...., . WHEREFORE, Plaintiff requests that this Court enter a Decree in Divorce, enter an order equitably distributing marital property and enter such other orders as are appropriate and just. METZGER, WICKERSHAM, KNAUSS & ERE By ?iI~w+ Heather L. Harbaugh, Esquire Attorney I.D. 83997 3211 North Front Street PO Box 5300 Harrisburg,PA 17110-0300 Attorney for Plaintiff Date: Co/~T(OO Docwnent#:J778761 , <'~ ,:"",[" 1r,r':~C"T"~ , VERIFICATION I, Vicki Kimmel Ramey, hereby certify that the facts set forth in the foregoing Complaint Under Section 3301(c) or 3301(d) of the Divorce Code are true and correct to the best of my knowledge, information and belief, and that false statements herein are made subject to the penalties of 18 Pa. C.S.A. g4904 relating to unsworn falsification to authorities. Date: -k)if,)Ob Document #: 177876.1 Form 133.08-1 Acceptance of Service By Defendant Or Authorized Agent- Official Form Cpa.R.C.P. NoA02(b) I accept service of the Divorce complaint. 7/17/00 (date) lfo-le..l? ~ (defendant) j We..':> t p,''f)e 5t. fYlt. 4v1/y ~pr; riftS 1 (mailing address) ~ " ~,,- Aft. I Po.. J7D0S II II ,; !1 :-1 !? ,I : ~ i: __"~~~!'llI!llfM~!IJ!~.,,"",,~ ,- -.....,- ", -., '>V ._. "~ () 0 0 c: (..,-) s: ~1 '-- ---=---t -0 OJ "'" rnrn z ,=r 2::1:' ,. 7r" I "-Ti71 (7j ~~ r-) J ~~:; ~2 " l ~~~ "." ;,: :~~ ~i~ ::r.:: ~.::("5 pO N :::1 In c::: 2 -, :..:> )::-.: =< :0 en -< - ~~ ~ 'I'"""'~ _.J~-l~!P<!JiI!l!l:fj~~"''''t~Wl:',~~~iWil~~ili!~~~_ , (x)-I.{foc;.j C0JT~ . MARITAL SETTLEMENT AGREEMENT :tt.- THIS AGREEMENT, made thisd7 day of July, 2000, by and between Vicki Kimmel Ramey (hereinafter referred to as "Wife") of Newville, Cumberland County, Pennsylvania and Dale Ray Ramey (hereinafter referred to as "Husband") of Carlisle, Cumberland County, Pennsylvania. WITNESSETH: WHEREAS, the parties are Husband and Wife, married on February 26, 1997, in North Carolina; and WHEREAS, no children were born of the marriage; and WHEREAS, unhappy differences and difficulties have arisen between the parties, in consequence of which the parties intend to live separate and apart for the rest oftheir natural lives; and WHEREAS, the parties desire to settle fully and [mally their respective financial and property rights and obligations as between each other, including but not limited to the ownership and equitable distribution of real and personal property; past, present and future support, alimony and/or maintenance; and any and all claims which either party has, or may have, against the other or the other's estate; NOW, THEREFORE, in consideration of the mutual promises, covenants and undertakings hereinafter set forth and for other good and valuable consideration, receipt of which the parties acknowledge, Husband and Wife, each intending to be legally bound, hereby covenant and agree as follows: Document # 179839 """. . ',0 r ~. . 1. SEPARATION Each party shall have the right to live separate and apart from the other party, free from the other party's interference, authority and control. Neither party shall interfere with the other or attempt to interfere with the other, nor compel the parties' cohabitation. 2. HUSBAND'S AND WIFE'S DEBTS Except as otherwise set forth in this Agreement, the parties represent and warrant to each other that they have not incurred and will not contract or incur any debt or liability for which the other or the other's estate might be responsible. Each party shall indemnify and save hannless the other party from any and all claims or demands made against the other by reason of debts or obligations incurred by that party. 3. WAIVER OF RIGHTS AND MUTUAL RELEASES Except as provided in this Agreement, both parties absolutely and unconditionally release and forever discharge each other and their heirs, executors, administrators, assigns, property and estate from any and all rights, claims, demands or obligations arising out of or by virtue of the marital relationship, whether such claims exist now or arise in the future. This release shall be effective regardless of whether such claims arise out of former or future acts, contracts, engagements or liabilities of the parties or by way of dower, curtesy, widow'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 -2- Pennsylvania, any state, commonwealth or territory of the United States, or other country. Except for any cause of action for divorce which either party may have or claim to have, and except for the obligations of the parties contained in this Agreement, each party gives to the other an absolute and unconditional release and discharge from all causes of action, claims, rights or demands whatsoever, in law or in equity, which either party ever had or now has against the other, including but not limited to alimony, alimony pendente lite, spousal support, equitable distribution of marital property, counsel fees or expenses. 4. REAL ESTATE The Wife currently owns improved real property situated at 14 Carter Place, Carlisle, Cumberland County, Pennsylvania, hereinafterreferred to as "marital residence." This property is currently in the sole possession of Husband. In consideration of the mutual promises of the parties, it is agreed as follows: (a) Husband shall vacate the premises at 14 Carter Place, Carlisle, Cumberland County, Pennsylvania within ten days after the signing of this agreement. (b) In exchange for husband's tender of possession of the marital residence, Wife agrees to pay Husband the sum of$3,000.00upon the signing ofthis Agreement. (c) Husband specifically waives, releases, renounces and forever abandons all of his right, title, interest or claim, whatever it may be, including, but not limited to, any right or interest in said property under the Divorce Code of 1980 and its amendments. -3- ~ ' 5. DIVISION OF PERSONAL PROPERTY The Wife shall receive the following items of personal property: Big screen television, secretary, cherry bedroom suite, queen size brass bed, treadle sewing matching, corner curio cabinet, dry sink, maple dining room suite, oak kitchen table and chairs, marble top table, Tiffany style lamp, oak chest of drawers, six walnut dining room chairs, two cane-bottom chairs, blanket chest, steamer trunk and library table. The husband shall receive the following items of personal property: Clothing, tools, fishing rods and supplies, and couch. The parties stipulate and agree that otherwise all personal property has already been divided between themselves. 6. MOTOR VEHICLES Wife shall retain sole and exclusive ownership of the 1986 Oldsmobile Cutlass Supreme vehicle currently in her possession and agrees to assume sole responsibility for all outstanding encumbrances, if any. Wife agrees to turn over ownership and possession of the 1987 Dodge truck and the 1970 Impala camper to Husband upon his leaving of the marital residence as specified in Paragraph4(a). Wife further agrees to execute any and all forms, titles and documents necessary to transfer the aforesaid motor vehicles to Husband within ten days of his leaving of the marital residence as specified in Paragraph 4(a). Husband agrees to assume sole responsibility for all outstanding encumbrances on the 1987 Dodge truck and the 1970 Impala camper, if any. -4- ""',Ji", ' R' ~ " 7. JOINT DEBTS The parties acknowledge that they have no debts which were jointly incurred during their marnage. Any debts or obligations incurred by either party in his/her individual name, whether incurred before or after separation, are the sole responsibility of the party in whose name the debt or obligation was incurred. 8. RETIREMENT BENEFITS Wife shall retain exclusive control and ownership over all forms of retirement held in her name, including, but not limited to: Pinnacle Health, Copeland and TSA Lincoln. Husband does not own or is not a participant in any type of pension, retirement or profit sharing plan. Each of the parties does specifically waive, release, renounce and forever abandon all of their right, title, interest or claim, whatever it may be, in any pension/retirement!profitsharing plan of the other party, whether acquired through said other party's employment or otherwise, and hereafter the pension/retirement! profit sharing plan identified above as being either husband's or wife's shall become the sole and separate property of the party in whose name or whose employment said plan is carried. 9. DIVISION OF BANK ACCOUNTS Husband and Wife acknowledge that all joint bank accounts have been closed or divided to their mutual satisfaction prior to the execution of this Agreement. Any individual accounts shall be the sole and separate property of the party in whose name the account is held. -5- ,t.. '_' . 10. AFTER-ACOUIRED PROPERTY Each of the parties shall own and enjoy, independently of any claims or rights of the other, all real property and all items of personal property, tangible or intangible, hereafter acquired, with fuIl power to dispose of the same as fully and effectively as though he or she were unmarried. Any property so acquired shall be owned solely by that party and the other party shall have no claim to that property. 11. SPOUSAL SUPPORT, ALIMONY PENDENTE LITE. AND ALIMONY Husband and Wife waive and relinquish all rights, if any, to spousal support, alimony pendente lite, and alimony. Any transfer of monies between the parties pursuant to any term of this Agreement shall not constitute alimony but is made as part of the parties' equitable distribution settlement. 12. TAX MATTERS The parties have negotiated this Agreement with the understanding and intention to divide their marital property. The parties have determined that such division conforms to a right and just standard with regard to the rights of each party. The division of existing marital property is not, except as may be otherwise expressly provided herein, intended by the parties to constitute in any way a sale or exchange of assets. It is understood that the property transfers described in this Agreement fall within the provisions of section 1041 of the Internal Revenue Code, and as such will not result in the recognition of any gain or loss upon the transfer by the transferor. The parties may sign and file joint federal, state and local tax returns for the calendar year of 2000. -6- ~ ,'< ~ 13. SUBSEOUENTDIVORCE There is pending between the parties an action for divorce instituted in the Court of Common Pleas of Cumberland County, Pennsylvania, at Docket No. 00-4693. Husband and Wife agree that their marriage is irretrievably broken and that the same shall be dissolved pursuant to ~3301(c)) of the Divorce Code of Pennsylvania. The parties therefore agree as follows: (a) Husband and Wife agree to sign the Court Affidavits of Consent agreeing to the entry of a final decree of divorce as well as Waiver of Notices of Intention to Request Entry of a Divorce Decree under Section 3301 (c ) of the Divorce Code. (b) Neither party requested counseling prior to the filing of said Affidavits of Consent and therefore the right to request such counseling shall be deemed waived. (c) Wife agrees to pay Husband $2,000 within ten days of the issuance of the Final Divorce Decree in this matter provided that Husband does not breach any of the terms in the aforesaid Agreement. 14. COUNSEL FEES AND EXPENSES Except as otherwise specified herein, each party shall be responsible for payment of his/her own counsel fees and expenses. 15. ADVICE OF COUNSEL The parties acknowledge that each has received or has had the opportunity to receive independent legal advice from counsel of their selection and that they have been informed fully as -7- c&?'"",r " . . to their legal rights and obligations, including all rights available to them under the Pennsylvania Divorce Code of 1980 as amended, and other applicable laws. Each party confirms that he/she understands fully the terms, conditions, and provisions of this Agreement and believes them to be fair, just, adequate and reasonable under the existing circumstances. The parties further confirm that each is entering into this Agreement freely and voluntarily and that the execution of this Agreement is not the result of any duress, undue influence, collusion, or improper or illegal agreement. 16. EFFECT OF DIVORCE DECREE ON AGREEMENT Either party may enforce this Agreement as provided in section 3105(a) of the Divorce Code, as amended. As provided III section 3105(c), provisions of this Agreement regarding equitable distribution, alimony, alimony pendente lite, counsel fees or expenses shall not be subject to modification by the court. 17. DATE OF EXECUTION The "date of execution", "date of this agreement" or "execution date" of this Agreement is the date upon which it is signed by the parties if they sign the Agreement on the same date. Otherwise, the "date of execution", "date of this agreement" or "execution date" shall be the date on which the last party signed this Agreement. 18. HEADINGS NOT PART OF AGREEMENT The descriptive headings preceding the paragraphs are for convenience and shall not affect the meaning, construction or effect of this Agreement. -8- ,~, ~.,-==' 19. SEVERABILITY AND INDEPENDENT AND SEPARATE COVENANTS Each separate obligation shall be deemed to be a separate and independent covenant and agreement. If any term, condition, clause or provision of this Agreement shall be determined or declared to be void or invalid in law or otherwise, then only that term, condition, clause or provision shall be stricken from this Agreement and in all other respects this Agreement shall be valid and continue in full force, effect and operation. 20. AGREEMENT BINDING ON HEIRS This Agreement shall be binding on and shall ensure to the benefit of the parties and their respective heirs, executors, administrators, successors, and assigns. 21. INTEGRATION This Agreement constitutes the entire understanding of the parties and supersedes any and all prior agreements and negotiations between them. There are no representations, warranties, covenants or promises other than those expressly set forthin this Agreement. 22. MODIFICATION OR WAIVER TO BE IN WRITING No modification or waiver of any term of this Agreement shall be valid unless in writing and signed by both parties. 23. NO WAIVER OF DEFAULT The failure of either party to insist upon strict performance of any term of this Agreement shall in no way affect the right of such party hereafter to enforce the term. 24. VOLUNTARY EXECUTION The parties acknowledge that this Agreement is fair and equitable, and that they have -9- ~,o ~ ~- =- ....,~, . reached this Agreement freely and voluntarily, without any duress, undue influence, collusion or improper or illegal agreements. 25. APPLICABLE LAW This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania and more specifically under the Divorce Code of 1980, as amended. 26. ATTORNEYS' FEES FOR ENFORCEMENT If either party breaches any provision of this Agreement, the breaching party shall pay all reasonable legal fees and costs incurred by the other in enforcing this Agreement, providing that the enforcing party is successful in establishing that a breach has occurred. IN WITNESS WHEREOF, the parties have set their hands and seals the day and year fust written above. WITNESS: (J;j>L'~ ~ Vicki Kimmel Ramey a ;JcJ ~ ~ Dale Ray Ramey -10- _. . . COMMONWEALTH OF PENNSYL VANIA ss COUNTY OF CUMBERLAND On this, theoZ1~ay of J;A.~ ,2000, before me, the undersigned officer, personally appeared Vicki Kimmel Ramey known to me or satisfactorily proven to be the person whose name is subscribed to in the foregoing Marital Settlement Agreement, and acknowledge that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, 1 hereunto set my hand and official seal. ~~iS~ Notarial Seal *.luilii,*A. Cunningham, Notary Public York, York County My Commission Expires May 7. 2001 ":~.~.".. . ..;,."t:0"- "f ~lntHies ********************************************************* COMMONWEALTH OF PENNSYL VANIA ss COUNTY OF CUMBERLAND On this, the ().~ay of ~ personally appeared Dale Ray Ramey known to me or satisfactorily proven to be the person whose , 2000, before me, the undersigned officer, name is subscribed to in the foregoing Marital Settlement Agreement, and acknowledge that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, 1 hereunto set my hand and official seal. ~mmiqon~' Notarial Seal Judith A. Cunningham. Notary Public York, York County My Commission Expires May 7, 2001 Member. Pennsy!var-18 Association r;f ~J0taries Document # J 79839 ~~ ~ - >;.,:""".."M' i ~ I ,. II II II " I ,I , i' Ii I' ,I 11 I: I Ii J~]T ~~, ~ '='""''" " ~ ."" '!'~ --........"',': 0 c::) () C 1'-' n :::< ~ ~'D '~J._} '"~~ , '1'1 , .- ~ , I t;=:, ., --' ~ c;~ .":~) }~~ i~.\ J:; C.,,} :"~~) C- - ~~} =, :0 -- , 0 -< !?l!l~f;~~%!~!I~'lF,f;;~'1f',ml~ffiWffll!m~;j<rm'!~i'Ilf!i VICKI KIMMEL RAMEY, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 2000-4693 Civil Term DALE RAY RAMEY, Defendant : CIVIL ACTION - LAW : COMPLAINTIN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on June 30, 2000 and served upon Defendant on July 14,2000. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. 1 consent to the entry of a fmal decree of divorce after service of notice of intention to request entry ofthe decree. 1 verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. S 4904 relating to unsworn falsification to authorities. Date: ~ 10'7 / D~ (1'cY-/f. f2~ Vicki K. Ramey Document#: 187175.1 ,"~'~ ~~ ~~ ,_., ,~~~Iif!1IlJll1!1', ,~~~_,~_.l':fflw 0 c::; ,~ C I') ,;-",,1 II S-: z -OGJ b rnrT~ ~: ::;D Z::[I h-, / C I : c7; ~,L;': .-J ,,) -< .<::i:, ::) 3~; () '.' :.:~ :;:.: c> C) )> C) ~:5rn ,- Z .".' =< <.0 5:; -< ~..,~,~!l~lI"'" .fI!ll!fljj!!llM!ll!l~J!lIi\~.~I!iJlJp!flifi'j~""'~~'~'l1~::!1~~~-!)~.w~'I!1'1''"'''''f''''I''-i:W.i1~:~~!j!i~qW-ll~;~~'!!!!'~lili':m!.illiliK~l!l'l!W !\fl"!'l'I'l1I~1i'm1 VICKI KIMMEL RAMEY, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 2000-4693 Civil Term DALE RAY RAMEY, Defendant : CIVIL ACTION - LAW : COMPLAINT IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE UNDER !l 3301(c) OF THE DIVORCE CODE 1. 1 consent to the entry of a fmal decree of divorce without notice. 2. 1 understand that 1 may lose rights concerning alimony, division of property, lawyer's fees or expenses if! do not claim them before a divorce is granted. 3. 1 understand that 1 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. 1 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. ~ 4904 relating to unsworn falsification to authorities. Date:~ &ft(1 ,C ~ ~ lcki K. Ramey Document #: 187175.1 ,r '. ~~. , ~, . "." . ~ W~" ,,;tW:mmqll~~~lU.,~ ~~I!5IMJll~~J!), o C 2' -oi'r, r~lf f': Z:'T' zc- ;~{'~~ :i:C:, '~~ -< o p-J I~i '-~ .", \.,-" "" . __J :;':':;:i~ '2:\ , _I() ',-.--{.I ,..,--".... ~S?~ ;r;: ~ -0 ~~.,,, '.0 .1'1~"'~""'~,l*""lmj1H!.f~<i?j-~';-1Ff1i'!f'-11.'9?lW~"Oi**m'Pii"1~<l'ilMli"l'W""'r"""'l~"''i'friW.<ffi;JIl(, "" '""",e'""",,' VICKI KIMMEL RAMEY, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 2000-4693 Civil Term DALE RAY RAMEY, Defendant : CIVIL ACTION - LAW : COMPLAINTINDIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on June 30, 2000 and served upon Defendant on July 14,2000. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. 1 consent to the entry of a [mal decree of divorce after service of notice of intention to request entry of the decree. 1 verifY that the statements made in this affidavit are true and correct. 1 understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 11 4904 relating to unsworn falsification to authorities. Date: ---D 10'7 JD a 1 iJaA R,{(~ Dale Ray Ramey Document #: 187175.1 .7-, ~ .~ ~ ill,iJn_tll"''''~~ o C <:" "'Oii; nlfT'i :Z:::~1 '+........ ~~, v~ ~:~2 z ."] -< C::J N Z t.::J. < () -n ;,-n --:G~ :'i::::r '~'::'~j(~) ." ,-::-" '~:.;(~ ('~;,T: =, "T..,. :J..:.j --<. I -_l '-0 ~-:-,'" ",."~ \,0 _~~" ~~~~ffi'$': ~lrnr~IW.~~-\i!"W"1j!ll~~ll\i!',;J>>Wjt'fH:S<>!I1l~a'~roIi!~\<Al~];JiIi""m'~ ,~"~"",,rJlU!!!l!!il!!~ VICKI KIMMEL RAMEY, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2000-4693 Civil Term DALE RAY RAMEY, Defendant : CIVIL ACTION - LAW : COMPLAINTINDIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE UNDER!! 3301(c) OF THE DIVORCE CODE 1. 1 consent to the entry of a [mal decree of divorce without notice. 2. I understand that 1 may lose rights concerning alimony, division of property, lawyer's fees or expenses if! do not claim them before a divorce is granted. 3. 1 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. 1 understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 94904 relating to unsworn falsification to authorities. Date:~llol /()~ , ua,k. 6<. ~ Dale Ray Ramey Document #: 187175.1 ''''''IF""~~ = .'.~ '- ^ . ~. I'zr_ ~~ 0 c' .-.~ C P'.J ;-ri << z "0 l~j C) rT1 f'n ,-;;:::: Z ::.7) &I~~, -, -, . ~S -'0 ~:.::. C.: _."'~ ..~ C') = - (.) ..v C ., _.,.1 2~ 1;0: -' :'D -c \.0 -< <,~~Jt$Q,,,,,,,~,,,_,,",_IIIll!IIlIDIlil@'IlM; [illlITt1M'll!l~_"'__~fM\ll~J!'f?l~C$l;~,'W"rn~"'i~;r1l:""1"''''''-IRIp;e!V~r__!'!iJ''''-!1I';fil!I,,;li>W!WOOli!>!ilWI'''';o\lll'~-'!~~~lI't.\t!1 VICKI KIMMEL RAMEY, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 2000-4693 Civil Term DALE RAY RAMEY, Defendant : CIVIL ACTION - LAW : COMPLAINTINDIVORCE AFFIDAVIT OF SERVICE I, Heather L. Harbaugh, Esquire, counsel for Plaintiff, Vicki Kimmel Ramey, hereby certifY that a true and correct copy of the Complaint in Divorce was served upon the following, by certified mail, return receipt on July 14,2000. Attached hereto, marked as Exhibit "A" and incorporated herein by reference is a copy of the return receipt card indicating service upon: Dale Ray Ramey 14 Carter Place Carlisle,PA 17013 METZGER, WICKERSHAM, KNAUSS & ERE, P.C. ~~ I.D. No. 83997 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorney for Plaintiff Date: July 20, 2000 Document #: 180201.1 "',.".;' , , EXHIBIT A 1111I1 First-Class Mail Postage & Fees Paid USPS Permit No. G-10 UNITED STATES POSTAL SERVICE . Print your name, address, and ZIP Code in this box · METZGER, WICKERSHAM, KNAUSS & ERB, P.C. 3211 North Front Street PO Box 5300 Harrisburg, PA 17110-0300 r!-I L I-/- (~~')I"'llllll'll""lll'lll\'lt.'lll"'ll"lll"ll <;; SENDER: l:e . Complete Items 1 and/or 2 for additional seNices. , CfJ . Complete items 3, 4a, and 4b. Q) . Print your name and address on the reverse of this form so that we can return this f! card to you. . :... Atta~ this form to the front of the mailplece, or on the back if spate does not III 'permit. 1.0 . Write "Return Receipt Requested" on the mailpiece below the article number. ! . The Return Receipt will show to whom the article was delivered and the date - delivered. 6 3. Article Addressed to: * f1Je Rfttt R~ ~ I L{ Carfi.r- f{di: 8 r. C(X.r- :slc. P/r: no13 I I also wish to receive the following services (for an extra fee): 1. 0 Addressee's Address 2. 0 Restricted Delivery Consult postmaster for fee. 4a'fJle/8~bm GtfD 4b. Service Type o Registered o Express Mail o Return Receipt for Merchandise 7. Date of Delive!)! ai " ~ .. II) a ';; " .. !t c ~ " o..<r"l. l; ~ertjfied a: o Insured g' o COD .~ .e " g, -" c " .r; l- 8. Addressee's Address (Only if requested and fee is paid) 1025'S-'8,S"'22' Domestic Return Receipt Document #: 180201.1 . ~iI!IlIlI,~ ... ~~ ~., _~r:l"" .. ,~,- "~,,., , ,,- ,~,~~ "'" ..~_ w.~ "; ~''''r\'~';' (-, ., s 2~ff: "c_ , :::0 " _/ r":: ~~~J ~1 -' , (::J- o o i~ i..- ~,) '-" (~.l ""-' "-J -;-i ;;~~ ~l'~ ;:;:~ ~ -< ~" , ",,'ffliil-~;~""_~"f&;;;iI'!'fl/tf~~!jf~~lll.W!lill~~~~~m~IIIl~_".-.,- ~t';'