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HomeMy WebLinkAbout00-04871 \ c--,,", . . . . J .. . .. , . Of. :f. :Ii :f. . . . ""~:f."":f. :Ii "":Ii:li:li :f. . . . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY . . . PENNA. STATE OF . . . . . smrr D. LAMPREY, . . . No. 00-4871 2000 Plaintiff . VERSUS . . . Sl'EFANIE M. LAMPREY, . . Defendant . . . DECREE IN DIVORCE . . j ;: 36,,#1 . ,Jt>()1 ,IT IS ORDERED AND . . . AND NOW, y, . . smrr D. LAMPREY DECREED THAT , PLAINTIFF, , STEFANIE M. LAMPREY , DEFENDANT, AND . . . 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; . . . . . . . . . . . . . By T . . . . . . J. Amso~ ~ ~. ~ PROTHONOTARY . . . . . . .. tF. "'''' '" :Ii , . ~I "!IIlIlliJIi;lIwiiHL' . , . . . . . . . . . . . . . . . . . . . . . . . . , , . . . . . 1;' ^' ~ ,. . ~ ^ , "-.<"""~-=.", i" ' .... ;~.. 'i?;;J-cJ( u~~ ?i?4~' ff~.tJl 7l~ ~ -$.uj-d..4 , . . .~'1W~~,,,!,,,, "C"'''I'"'''..'"''''_.'' - 11,- ,t'-":' . - ~ '", ~',; fl\div\Lamprey.ord SCOTT D. LAMPREY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 00-4871 STEFANIE M. LAMPREY, Defendant CIVIL ACTION - DIVORCE o R D E R MID NOW, this l~ day of ~ , 2001, the property settlement agreement between the parties dated June 28, 2001, and attached hereto is hereby incorporated into the Decree in Divorce. J. .;;' l~"--",_ - .;" , - ~'~~ FFD.()CWF IJ',C 8Y~;'~'".~;;'T'RY "'."": \,_/j'J'J.;"'.r 01 AUG - 2 AH 10: 2 ! CUMBI:RANU COUNTY PENNSYLVll..NIA ~ ~ ~P;/ , . C'" pr.__ ,- ,__'u."", -"7'_-7'~~t~,-;,.":"',,:"'>." ,'_ S,,'7"-, '_~ .c~ '_ ",r,_ 7:'; '.' - L-,'-" ~_~,' _'>_'~"__~,_" ._."",_JHT",,:___> '!;;"~- :1I_.-' -c- ___,'_ _ -",_" ,_u_; ..,Q,-k'_,,_ ,. _,!'!Ill!'!!'_ . '........ ....',.....'.,F oil - _ ~"__.~~'.O - '~ 1'" , .;c_, ~'-'i ! fl\div\Lamprey.pet\7~Ol >>' SCOTT D. LAMPREY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 00-4871 STEFANIE M. LAMPREY, Defendant CIVIL ACTION IN DIVORCE MOTION TO INCORPORATE AGREEMENT INTO DECREE IN DIVORCE Scott D. Lamprey, plaintiff in the above action, by his attor- neys, STONE LaFAVER & SHEKLETSKI, moves that your Honorable Court incorporate the attached agreement dated June 28, 2001, into the Decree in Divorce. STONE LaFAVER & SHEKLETSKI B Attor for Plaintiff s~ ~" " ",--,'-','" ,", ...~,' ,'-'"---,, ~-,,~- ~ <. ,,~',. __C'_" ,',.' -~. ~-"'" fl\agm\lamprey.agm\6~Ol . AGREEMENT THIS AGREEMENT, made this ~r <.fA day of r , 2001, by and between STEFANIE M. LAMPREY, of Cumberland County, pennsylva- nia, (hereinafter referred to as "Wife"), and SCOTT D. LAMPREY, of Cumberland County, Pennsylvania, (hereinafter referred to as "Hus- band") ; WIT N E SSE T H: WHEREAS, Husband and Wife were lawfully married on September 17, 1994, and WHEREAS, one child has been born of this marriage, COLTON S. LAMPREY, born on April 1, 1996; and WHEREAS, diverse unhappy differences, disputes and difficulties have arisen between the parties and it is the intention of Wife and Husband to live separate and apart for the rest of their natural lives, and the parties hereto are desirous of settling fully and finally their respective financial and property rights and obligations as between each other including, without limitation by specification: -1- "1 '~u -- --". "-,' "'~~' ,-,~-=- .. ~~~" , the settling of all matters between them relating to the ownership and equitable distribution of real and personal property; the settling of all matters between them relating to the past, present and future support, alimony and/or maintenance of Wife by Husband or of Husband by Wife; and in general, the settling of any and all claims and possible claims by one against the other or against their respective estates. NOW THEREFORE, in consideration of the premises and of the mutual promises, covenants and undertakings hereinafter set forth and for other good and valuable consideration, receipt of which is hereby acknowledged by each of the parties hereto, Wife and Husband, each intending to be legally bound hereby, covenant and agree as follows: 1. Disclosure of Assets. Each party asserts that he or she has made a full and fair disclosure of all of the real and personal property of any nature whatsoever belonging in any way to each of them of all debts and encumbrances incurred in any manner whatsoever by each of them, of all sources and amounts of income received or receiv- able by each party, and of every other fact relating in any way to the subject matter of this agreement. These disclosures are part of the consideration made by each party for entering into this agreement. -2 - II k 0' -'""-'. ~ ,- ~" ~ ~ 17lil;.,. , . 2. Advice of Counsel. Each party has been represented by an independent attorney, Samuel L. Andes, Esquire, as counsel for Wife, and Gerald J. Shekletski, Esquire, as counsel for Husband, who was selected by the party whom he or she represents, in the negotiation and preparation of this agreement. This agreement has been fully explained to each party by that party's attorney. Each party has carefully read this agreement and is completely aware, not only of its contents, but also of its legal effect. 3. Lawfulness of Separation. It shall be lawful for each party at all times hereafter to live separate and apart from the other party at such place as he or she may from time to time choose or deem fit. The foregoing provisions shall not be taken as an admission on the part of either party of the lawfulness or unlawfulness of the causes leading to their living apart. 4. Personal Riqhts. Each party shall be free from interference, authority, and contact by the other, as fully as if he or she were single and unmarried except as may be necessary to carry out the provisions of this agreement. Neither party shall molest the other or attempt to endeavor to molest the other, nor compel the other to cohabit with the other, or in any way harass or malign the other, nor -3- Ii Ijj ,,- - - ---'~<" " '''''''-''''" . in any way interfere with the peaceful existence, separate and apart from the other, and each of the parties hereto completely understand and agree that neither shall do or say anything to the children of the parties at any time which might in any way influence the children adversely against the other party. 5. Freedom from Interference. Each party shall be free from interference, authority, and contact by the other, as fully as if he or she were single and unmarried except as may be necessary to carry out the provisions of this agreement. Neither party shall molest the other or attempt to endeavor to molest the other, nor compel the other to cohabit with the other, or in any way harass or malign the other, nor in any way interfere with the peaceful existence, separate and apart from the other. 6. Release of Claims. Wife and Husband each do hereby mutually remise, release, quit-claim and forever discharge the other and the estate of such other, for all time to come, and for all purposes whatsoever, of and from any and all rights, titles and interests, or claims in or against the property (including income and gain from property hereafter accruing) of the other or against the estate of such other, of whatever nature and wheresoever situate, which she or -4- II tz " -~ 0.- ~ ,en', ~_.,' . he now has or at any time hereafter may have against such other, the estate of such other or any part thereof, whether arising out of any former acts, contracts, engagements or liabilities of such other or by way of dower or curtesy, or claims in the nature of dower or curtesy of widow's or widower's rights, family exemption or similar allowance, or under the intestate laws, or the right to take against the spouse's will; or the right to treat a lifetime conveyance by the other as testamentary, or all other rights of a surviving spouse to participate in a deceased spouse's estate, whether arising under the laws of (a) Pennsylvania, (b) any state, commonwealth or territory of the United States, or (c) any other country, or any rights which Wife may have or at any time hereafter have for past, present or future support or maintenance, alimony, alimony pendente lite, counsel fees, costs or expenses, whether arising as a result of the marital relation or otherwise, except, and only except, all rights and agreements and obligations of whatsoever nature arising or which may arise under this agreement or for the breach of any thereof. It is the intention of Wife and Husband to give to each other by the execution of this agreement a full, complete and general release with respect to any and all property of any kind or nature, real, personal or mixed, which the -5- 1'" ... . - -.,'-, . .,c. .~ .'0 .'~ c other now owns or may hereafter acquire, except and only except all rights and agreements and obligations of whatsoever nature arising or which may arise under this agreement or for the breach of any thereof, subject, however, to the implementation and satisfaction of the conditions precedent as set forth herein above. 7. Warrantv as to Future Obliaations. Each party represents that they have not contracted any debt or liability for the other for which the estate of the other party may be responsible or liable, and that except only for the rights arising out of this agreement, neither party will hereafter incur any liability whatsoever for which the other party or the estate of the other party, will be liable. Each party agrees to indemnify or hold the other party harmless from and against all future obligations of every kind incurred by them, includ- ing those for necessities. 8. Assumption of Liabilities. This provision sets forth the method for the payment and assumption of the debts and liabilities of the parties. Since the assumption is not binding on the creditor, the party assuming the debt agrees to indemnify the other party in the event the creditor seeks to hold such other party liable. Should the -6- ~ iF "--- -" ~ ~,",' "'.'_--1,'._',.=."..\., ' -,', '"' , , ~_u parties wish to bind the creditor and relieve the original debts from all liability, a novation should be executed. 9. Assumption of Debts. Husband assumes and agrees to pay and hold the Wife harmless against the following debts and obligations: Sears, Account No. 0558923117284; Texaco, Account No. 33-670-5390-1; Discover Card No. 6011002195520747; and Citibank Visa Credit Card Account No. 4128002241147037. If any claim, action or proceeding is hereafter brought seeking to hold the Wife liable on account of such debts or obligations, the Husband will, at his sole expense, defend the Wife against any such claim, action or proceeding, whether or not well founded, and Husband will indemnify and hold Wife harmless from and against such claim, action or proceeding. 10. Assumption of Debts. Wife assumes and agrees to pay and hold the Husband harmless against the following debts and obligations: PSECU Visa Account No. 0165540296; J. C. Penney, Account No. 1924539370; Bon-Ton, Account No. 093035996; QVC, Account No. 0561390105536; and B. Moss, Account No. 6011725101447486. If any claim, action or proceeding is hereafter brought seeking to hold the Husband liable on account of such debts or obligations, the Wife will, at her sole expense, defend the Husband against any such claim, action -7- '" t" '~ , d~~! ,-'~ M-"~; "'_,' ' or proceeding, whether or not well founded, and Wife will indemnify and hold Husband harmless from and against such claim, action or proceeding. 11. Personal Property. Wife and Husband do hereby acknowledge that they have heretofore divided the marital property including, but without limitation, jewelry, clothes, furniture and other personalty and hereafter Wife agrees that all of the property in the possession of Husband shall be the sole and separate property of Husband; and, Husband agrees that all property in the possession of wife shall be the sole and separate property of wife. Each of the parties does hereby specifically waive, release, renounce and forever abandon whatever claims, if any, she or he may have with respect to any of the above items which are the sole and separate property of the other. 12. Pensions and Retirement Accounts. Husband and wife respect- fully waive any and all right, title, claim, and interest which they may have in the other's pension and retirement accounts. 13. Cash. All cash presently in the possession of either party shall be and remain their separate property, free and clear of any claim whatsoever on the part of the other. I II II ! I II -8- = -_.- ~ . ^ ".-;' ~ -", -~ - - " 2.>i_1 14. Automobile to Husband. The Husband shall be the sole owner, free and clear from any claim on the part of the Wife, of the 1997 Dodge Ram Truck currently titled in Husband's name alone. Within five (5) days after the signing of this agreement by the parties, Husband shall have Wife fully and completely released from all liability under the PSECU vehicle loan for said truck. 15. Automobile to Wife. The Wife shall be the sole owner, free and clear from any claim on the part of the Husband, of the 2000 KIA Sport age vehicle currently title in Wife's name alone. 16. Property Not Provided For. The parties hereto agree that they have, by the terms of this agreement, settled, to their mutual satisfaction, all rights that either may have in their property, whether owned by them jointly or separately, real and personal, and wheresoever situated. Any property not specifically provided for in this agreement, which the Husband or Wife owns or has the right to control or possess, shall be and remain his or her property, free and clear from any claim on the part of the other. 17. Real Estate. Wife hereby agrees to convey, transfer and grant to Husband her right, title and interest in the real estate situated and located at 5 Sussex Circle, Camp Hill, Cumberland County, -9- , . .1. """"I -,.-. o~,--, ,__o,c._ '-0 Pennsylvania, upon her release from all liability from and under the existing note and mortgage with Keystone Financial Mortgage Corpora- tion, now by merger M & T Mortgage Corporation, which release from liability shall occur on or prior to five (5) months from the date of this agreement. From the date of this agreement, Husband agrees to assume as his sole obligation any and all mortgage payments, taxes, claims, damages or other expenses incurred in connection with said premises, and Husband agrees and covenants to hold Wife harmless from any such liability or obligation. 18. Payment of Attornev Fees. Each party of this agreement hereby agrees that each of them will be solely responsible for the full payment of all attorney's fees and other costs heretofore and hereafter incurred, respectively, by each of them in connection with the negotiation, preparation, and execution of this agreement, and in connection with any action commenced by either party with respect to the divorce of the parties. Each party further agrees hereby to indemnify and hold the other party harmless from any demand, claim, loss, cost and expense (including additional attorney's fees) arising from a failure to pay all of the aforesaid attorney's fees and other costs. -10- - --- -,- .,,' " --~ . ~" ,.----,-"":.-',-'. ,~ ,- , '--'..~i<: 19. Infor.med and Voluntary Execution. Each party to this agreement acknowledges and declares that he or she, respectively: A. Is fully and completely informed as to the facts relat- ing to the subject matter of this agreement and as to the rights and liabilities of both parties. B. Enters into this agreement voluntarily after receiving the advice of independent counsel, free from fraud, undue influence, coercion or duress of any kind. c. Has given careful and mature thought to the making of this agreement. D. Has carefully read each provision of this agreement. E. Fully and completely understands each provision of this agreement. 20. Mutual Cooperation. The Husband and the Wife shall each concurrently herewith, or at any time hereafter on the demand of the other, execute any other documents or instruments, and do or cause to be done any other acts and things as may be necessary or convenient to carry out the intents and purposes of this agreement. 21. Severability. If any provision in this agreement is held by a court of competent jurisdiction to be invalid, void, or unenforce- -11- "~ ~ -' - ) '-.0"0 ='_, ,,:~,,--:: '" -':':- . ,,_ -"_ ~._l' _. _',. ' H,,-''':': able, the remaining provisions shall nevertheless continue in full force and effect without being impaired in invalidated in any way. 22. Reconciliation. If there should be a reconciliation of the parties after the date of execution of this agreement, this agreement shall nevertheless continue in full force until it is modified or abrogated by another written instrument to that effect signed by each of the parties hereto. 23. Future Earninqs. All income, earnings or other property received or acquired by either party to this agreement on or after the date of execution of this agreement shall be the sole and separate property of the receivi~g Or acquiring party. Each party, as of the effective date of this agreement, does hereby and forever waive, release and relinquish.all right, title and interest in all such income, earnings or oth~r property so received or acquired by the other. 24. Waiver of Riqhts. Each of the parties hereby irrevocably waive all rights which he or she may have to request any court to equitably distribute the marital property of the parties or to have alimony, alimony pendente lite or counsel fees awarded to either party, it being the express intention of the parties hereto to fully -12- - it; -., ." " ~,,; ~.~ . . settle all claims which they have with respect to each other in this agreement. Each of the parties further agree to consent to the entry of a Decree in Divorce. 25. Waiver of Breach. The waiver of any term, condition, clause or provision of this agreement shall in no way be deemed or considered a waiver of any other term, condition, clause or provision of this agreement. 26. Survival of Aqreement. If any term, condition, clause or provision of this agreement shall, by its reasonable interpretation, be intended to survive and extend beyond the termination of the marriage relationship presently existing between the parties hereto, said term or terms, condition or conditions, clause or clauses, provision or provisions, shall be so construed, being the express intention of both parties hereto to have this agreement govern their relationship now or hereafter, irrespective of their marital status. 27. Jurisdiction. This agreement shall be construed under the laws of the Commonwealth of Pennsylvania, and both parties consent and agree to the jurisdiction of the Court of Common Pleas of Cumberland County, Pennsylvania, on account of any suit or action brought with -13- ~ ~ .., =, .-,--, - ,,- -)"-. 1iIIiIIIlIl1~" respect to this agreement or any provisions or matters referred to in any provisions thereof. 28. Aqreement Bindinq on Parties and Heirs. This agreement shall be binding in all its terms, conditions, clauses and provisions of the parties hereto and their respective heirs, administrators, executors and assigns. 29. Divorce. Husband and Wife agree, simultaneous with the execution of this agreement, to execute all Affidavits of Consent and other documentation necessary to have a divorce decree entered pursu- ant to Section 3301(c) of the Divorce Code of Pennsylvania on the ground that the marriage is irretrievably broken. 30. Headinqs. The headings or captions preceding the paragraphs in this agreement are inserted for convenience of reference only and shall not be construed in interpreting this agreement. IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the day and year above first written. (SEAL) LAMPREY -14- '. '." 0 _;.'___ --.~ COMMONWEALTH OF PENNSYLVANIA: COUNTY OF ~a.ncL.- On this, the ~ day ss. of Cf11At , 2001, before me, a Notary Public, the undersigned officer, personally appeared STEFANIE M. LAMPREY, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and seal the day 'anJyear first above written. ~7J1.Yh~ tary Public COMMONWEALTH OF PENNSYLVANIA: COUNTY OF ~ On this, the ,;/?c./I1 day ss. of r , 2001, before me, a Notary Public, the undersigned officer, personally appeared SCOTT D. LAMPREY, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and seal the day and year first above written. -15- ! N TARIAL SEAL i KAYE R. LUCYEY. Notary Public New CtJrt;be[I~,nd Bom. Cumbelland Co. My Commission f.xplres March 27.2005 c " :I;I~~~ '~ - . ~ ~,: fl\div\ltrnsmit.pcp\7-97 SCOTT D. LAMPREY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 00-4871 STEFANIE M. LAMPREY, Defendant ACTION 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 ~ (3301(c)) ~) of the Divorce Code. (Strike out inapplicable section) . 2. Date and manner of service of the complaint: SERVICE ACCEPTED BY DEFENDANT'S ATTORNEY OF RECORD PAUL J. ESPOSITO ON JULY 14. 2000 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent ~ 3301(c) of the Divorce Code: by Plaintiff July 24, 2001 July 19, 2001 required by ; by Defendant (b) (1) Date of execution of the affidavit required by ~ 3301(d) of the Divorce Code: (2) A. Date of filing of Plaintiff's affidavit upon respondent: B. Date of service of Plaintiff's affidavit upon respondent: 4. Related claims pending: ALL CLAIMS SEI'l'LED. 00 ~ PENDING 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 P1ai the Prothonotary: in ~ 3301(c) Divorce was filed with the Prothonotary: Date Defen ant's Waiver of 7Jed-),'~ Notice in ~ 3301(c) Divorce was filed t;;('i\\(!)I. rA~~~;Z'~ with Supreme Court No. 40486 t'ii , '- ~,- <,'^~ - . -, ~ ~,- c__ ~ >_ ~~ SCOTT D. LAMPREY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. .~ NO. IJO... <If'll U CIVIL TERM STEFANIE M. LAMPREY, Defendant CIVIL ACTION - LAW IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a Decree of Divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Courthouse, Carlisle, PA 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 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 Countv Bar Association 2 Libertv Avenue Carlisle, PA 17013 Telephone: (717) 249-3166 ";; ~. ~'^ fl\div\lamprey.com\6-QQ " SCOTT D. LAMPREY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. M; - 'I i' 7/ d;J &-- v. STEFANIE M. LAMPREY, Defendant CIVIL ACTION LAW IN DIVORCE COMPLAINT 1. The Plaintiff in this action is SCOTT D. LAMPREY, an adult 11 individual, who currently resides at 5 Sussex Circle, Camp Hill, Cumberland County, Pennsylvania 17011. 2. The Defendant in this action is STEFANIE M. LAMPREY, an adult individual, who currently resides at 2902 Chester Brook Court #207, 'I ~l, ii Ii :i I I Camp Hill, Cumberland County, Pennsylvania 17011. 3. Both the Plaintiff and the Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this complaint. 4. The Plaintiff and Defendant were lawfully joined in marriage on September 17, 1994, in Fairview Township, York County, PA. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. -1- II I~ , --".', - ,.~ J:........:::I~.!;: 6. The Plaintiff avers as the grounds upon which this action is based is that the marriage between the parties hereto is irretrievably broken. 7. The Plaintiff avers that one (1) child has been born of this marriage. 8. The Plaintiff has been advised that counseling is available and that the Plaintiff may have the right to request that the court require the parties to participate in counseling. 9. The Plaintiff requests the court to enter a decree of di- vorce. II J' B GERALD J EKLETSKI, Esquire Supreme Court ID #40486 414 Bridge Street, P.O. Box E New Cumberland, PA 17070 Telephone 717-774-7435 Attorneys for Plaintiff -2- 'i "-1""'-'" -' - -" :"-~- I ~'. .' '~- Fl\div\l-verifi.aff VERIFICATION SCOTT D. LAMPREY, states that he is the Plaintiff named in the foregoing instrument and that he is acquainted with the facts set forth in the foregoing instrument; that the same are true and correct to the best of his knowledge, information and belief; and that this statement is made subject to the penalties of 18 Pa. C.S.A. 54904 relating to unsworn falsification to authorities. Date: 1~~ " ~ . i '. ~"I~J.ii, fl\div\accept.aty , SCOTT D. LAMPREY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COU}JTY, PENNSYLVANIA v. NO. 00-4871 CIVIL ACTION STEFANIE M. LAMPREY, Defendant CIVIL ACTION - IN DIVORCE ACCEPTANCE OF SERVICE I, PAUL J. ESPOSITO, Attorney at Law, accept service on behalf of the defendant, STEFANIE M. LAMPREY, of a certified copy of the Complaint filed on July 10, 2000, to the above term and number. Datn )~ dODO PAUL J ES OSITO Attorney at Law Supreme Court ID# GOLDBERG, KATZMAN & SHIPMAN, P.C. 320 E Market Street Harrisburg, PA 17101 (717) 234-4161 "f ,~'" ,", '~- - '. s ~L --ii~." " '.' .""."A.:/ - C'. iil(:":':~' " _.."",,""/.., '" ,,;,,,,,,,,",,,./ ,'"'"...' , . . .- . " ,;,;;eil -'""iC,;,,;,;,,,,,;,;;,,,;,",",,',,,, ".;'!""". () (."":1 0 C 0 '. <'" ~- -OeD c:: nlf""n ,- 2:e, ~>-~ \-0 -<r~ ~c; " Pc, 2('< ;'"\.,) ,,_1 j.~C _.~j ~ '-"; " 5J =2 0, -', '~ '-,"_..~~-~" ~'i fl\div\consent.aff . .. SCOTT D. LAMPREY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 00-4871 STEFANIE M. LAMPREY, Defendant CIVIL ACTION - IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under ~ 3301(c) of the Divorce Code was filed on July 10, 2000. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the complaint and service of the complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 4. I 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. ~ 4904 relating to unsworn falsifica- tion to authorities. 1/:tJI-;!)( Date ;1 II J -S'':-~:_; - -i-,k; ~ ^-~ ',c_ "': . < ~_._. _<<0., ,;: riIi~=-"""<..;'~-' ,,,,,-,,...L-~~~: ~~ <-f""." 'w _~._ , . ,~ F "",~, ",,_ -,- ,-,.,.'- '<;',.-~'.'j,,-;,,,; - . " ... ",,", 'C ",-,,;,!',.>;.',"-'.. -",.",,," _',_"_,,,V ~>'-"-~-'~, j ....., '.~ -,- -"-, ,. - ,~ -. -~- fl\div\l-waiver '. - . SCOTT D. LAMPREY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 00-4871 STEFANIE M. LAMPREY, Defendant CIVIL ACTION LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER ~ 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses 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. ~ 4904 relating to unsworn falsifica- tion to authorities. ~. ./' aintiff 7-.z.~ft>/ Date Ci<" i"i-' '^ L~'irBJli'"L_'J ,;;,,-,-".-.,~ ,,~ ~:..,;;"" --, ,,~. . "" _ ,""'"""'"'''''~'''''8'.''' " "",.d"., " "', ' """"," " . ,"'''' ,,-, 'j j' , ' ~~--,- ~,-,"._~' '-'f" <~_i fl\div\consent.aff . '" . r . SCOTT D. LAMPREY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 00-4871 STEFANIE M. LAMPREY, Defendant CIVIL ACTION - IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under ~ 3301(c) of the Divorce Code was filed on July 10, 2000. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the complaint and service of the complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 4. I 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. ~ 4904 relating to unsworn falsifica- tion to authorities. II'.::. Date '0~ )'1 '2.Dn I "~i "" ;c, .~,' ""';"'~""ifoiil~~"Iiiiiol~.'" ",M '.".'M"'....'" P"""m".." ',....'....'.,.........,,'......'..'...', '",'''''' . ~ . " .. ".~ --:,,"'d-,''''- _OJ" .--'-"-' - ,,". - --~,,,,,:;..' ~-""''''-' fl\div\l-waiver .. """,... '0 . SCOTT D. LAMPREY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 00-4871 STEFANIE M. LAMPREY, Defendant CIVIL ACTION LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER ~ 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses 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. ~ 4904 relating to unsworn falsifica- tion to authorities. No ~!~ Date Lu::>/ II );!;, ""C"'_' '., >, -iltfl._ .....".h'~"""flnjhlf..'-~';4~-~,;[~~~- .' "'0,,..,,,,,,,,, ,.'",."" ""'-",'",-~-, .. ',.' """,. """~V""..,'" ' -, ,,','" """'1 , "' . '" ~ ,~ . _ _ '-.,- u~ .'--. ~-CI I I I I I 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: July 24, 2001 DOCKET NUMBER: 00-4871 PLAINTIFF/~ SS# 210-54-9676 NAME: Scott D. Lamprey DEFENDANT~ S5 # 165-54-0296 NAME: Stefanie M. Lamprey t' ~\., ~ .. ':."I SCOTT D. LAMPREY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 00-4871 CIVIL TERM STEFANIE M. LAMPREY, Defendant IN DIVORCE PETITION FOR ECONOMIC RELIEF AND NOW comes the above-named Defendant, by her attorney, Samuel L. Andes, and makes the following Petition for Economic Relief in this matter: COUNT I - EQUITABLE DISTRIBUTION 1. During the course of the marriage, the parties have acquired numerous items of property, both real and personal, which are held in joint names and in the individual names of each of the parties hereto. WHEREFORE, Defendant prays this Honorable Court, after requiring full disclosure by the Plaintiff, to equitably divide the property, both real and personal, owned by the parties hereto as martial property. COUNT II - COUNSEL FEES AND EXPENSES 2. Defendant is without sufficient funds to retain counsel to represent her in this matter. 3. Without competent counsel, Defendant cannot adequately prosecute her claims against Plaintiff and cannot adequately litigate her rights in this matter. 4. Plaintiff enjoys a substantial income and is well able to bear the expense of Defendant's attorney and the expense of this litigation. II .~ .. WHEREFORE, Defendant prays this Honorable Court to order Plaintiff to pay the legal fees and expenses incurred by Defendant in this litigation of this action. ~.@JJ Sa . Andes Attorney for Defendant Supreme Court ID # 17225 525 North 12th Street Lemoyne, Pa 17043 (717) 761-5361 \I _tb:; / {!- '-. I verify that the statements made in this Petition are true and correct. I understand that any false statements in this Petition are subject to the penalties of 18 Pa. C.S. 4904 (unsworn falsification to authorities). Date: L\. - d D -0 \ . \I -,- ,~ -, ~-- -~- -.-'-<',.-""~_ ,'= ",,--,",~,,""".~' ~","_'o_"., ---w,_{,---""",,,~","o,~ .rC'f;")! M ,~QJKl/nda~ Sgna e 1'\] 1] ii ~ i.' \ ~] ~ ~ ,j !1 ., !i ii 11 n " ~ i1 ~l II ~i ~ I, I ;1 ! , ., i I I' ~i wi ~i 'I' ~ I 11 ~ i , SCOTT D. LAMPREY, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. STEFANIE M. LAMPREY, Defendant : No.: 00-4871 : CIVIL DIVISION NOTICE OF INTENTION TO RETAKE PRIOR NAME Notice is hereby given that the Defendant in the above matter, having been granted a Final Decree in Divorce, on the 151 day of August, 2001, hereby elects to retake and hereafter use her previous name of Stefanie Marie Brown, and gives this written notice avowing her intention in accordance with the provisions of 54 Pa.C.S.A. 3704. TO BE KNOWN AS: ,~~ S efi Marie Brown On the ---1L day of , 2002, before me, a Notary Public, personally appeared Stefanie M. Lamprey, own t me to be the person whose name is subscribed to the within document and acknowledged that she executed the foregoing for the purpose therein contained. IN WITNESS TIlEREOF, I how h&ourto ..~rumd "'" ,001. ~llAl u_J) ~CA Public Notarial Seal Gwe~ M. 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