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HomeMy WebLinkAbout00-04900 . . , .. :~;:.::~~:)>>>;:..~~>>':+':::::~.::~:-:~~~::.::!~:>~C~:X.>,::~f~(:~<C:.;;:::C:f>>x-;.::<+x::::+:Cf~).::+;;:-l:f::C+;;:':::~3tf,;:':~!-::.X:(:f:::.::f~::~<~~)f::.::f';::~!-::.:::f;y,KXC!Z~~~"I~f~X:o.::.,;rc:f::.~:,:::~3&!r~,f::~fl ~ \* ~.~ {I :"l ~~ M I C I ! IN THE COURT OF COMMON PLEAS I ~ ~ ,,'~ ;.<;~ J ~.~ ~ ,"< ~,' ~ ~.~ ~ ~.~ ~ ;"S t t !i'.~ ,,> a i ~.'~ ~ ~." w ~.~ ;.-:~ ~ ~ ~ ;..; * .".,., w ~.~ ~ ~<.' I ~\'" l) ~ !l'.~ ~ ~! ~ ?'< ~~ ~ ~ ~ ."< ~.~ ~ ~.~ ~ ~.~ ~ * !i'.~ OF CUMBERLAND STATE OF * COUNTY PENNA. .,., "". MARK- .E~, .,F.ERRIS, mmmuumUuu I II No. .......(').(>>=49.00................. 19 Versus . .u" LORI. ,J,.u TERRIS".... ..u" DECREE IN DIVORCE \ r'6 ~, AND NOW,. .j~...............,...+9'":'":...., it is ordered and decreed that .... ~p..:t:15. :E... .~~;r.:t:~f? . . . . . . . . . . . . . . . , . . . . . . . . . . ., plaintiff, and Lad. J.. . Fe.r.ds. ....................,.................., defendant, are divorced from the bonds of matrimony. The court retains jurisdiction of the following claims which have been raised of re~~d in this ac.tion for which a final order has not yet been entered; \V 0 \1\9-. The Ma~riage Settlement Agreement entered into b above ~'~ ~ ~ ~.,; "..". W l>:"<! .'" ~~~ ~ ~ ~~ I . i ~ /4Ei().>>::O..,)3E(""" ,. .......................................... ........ .Gi;lP.t.~Q{l!!.d. .P<L;t'.1<i<;l:3. .~~. n.e.:r:et>y. .~I)CP.I:PQ By T Attest: a ~.~ ~.~ * ,'." >,.,< W !i'.~ ~.~ ~ ~':~ ~ t-;. i ~.~ ~ ~~~ ~ ~.~ ~ i ~.~ ~.~ ~ ~.s ~ ~ ~ I ~ N ~ ',.,< S ;,.;; ;.,:~ ~ ;.;; ~ ~.~ ~ .,,~~ ~'s ~ ~~~ ~ J. ",.", w ~:~ ~ j ~~~ ti '.~ ~ ~ ~.! ~ ;;.; ~ ,',; A ~ ~ y ~ ~.~ ~ ~.~ -- ~ ~ '" _ ~...( :';:c~::.::;:+>_;:'::o.,.::: :.,;::+::~;._ :::;:+-;<< :':';::+:>:,::::0::+::< ':..::+::.;;: )::+::';;, "'';::+::<'':';::+':''': ::'';::+':'''' ~ ~ ~~ :;'::+':()::.':<::';::+::",: >::.::()::+::.,;: :::,;::+::< ,:"::+::'..: ::.::+::''::.:''::+::-'': :':';:+::~:: . . """.."' , .",,1!JlIl' _,_ ~, - r j.cI<-o/ 1-~-c'l , - ., .~, ""'~'O-' ~~,~_ -,,~h~' ,,.., ',,," , 'u' '" ",.<>'_ '~-~,,_,_ ,~ -- ".--.~ ." ".~."v,' . M-~/u~~"4' ~- '?!~ -. /?, " /:J.'-41 . flt4~ 0 /C', rvr~-A ,- i, .L~ "-"" !lfWW"~W ..,....._,'>.,",',.'._'0 __~,_c:_."'~- . "~. " ~'- '-~'",-, ,',,,,- '- "' . Ii/I;N;' . c " ~GESETTLEMENTAGREEMENT THIS AGREEMENT, made this ~~ay of ~ee(1/1Y!be17 2000, by and between MARK E. FERRIS, of Enola, Cumberland County, Pennsylvania, hereinafter referred to as "Husband," and LORI J. FERRIS, of Clarks Green, Lackawanna County, Pennsylvania, hereinafter referred to as "Wife." WITNESSETH: WHEREAS, Husband and Wife were lawfully married on October 26, 1996; and WHEREAS, differences have arisen between Husband and Wife in consequence of which they intend to live separate and apart of each other; and WHEREAS, Husband and Wife have made a full disclosure of their assets to each other; and WHEREAS, Husband and Wife desire to settle and determine their rights and obligations with respect to each other, including the disposition and distribution of property rights and interests between them. . , ;,',-. ,~-, ~ -- ~: > "".~ < . " NOW, THEREFORE, in consideration 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. ADVICE OF COUNSEL. The provisions of this Agreement and their legal effect have been fully explained to the Parties by their respective counsel, Gerald S. Robinson, Esquire, for Husband, and Richard A. Fanucci, Esquire, for Wife. The Parties acknowledge that they have had an opportunity to receive independent legal advice from counsel of their selection, and that they fully understand the facts and have been informed as to their legal rights and obligations and they acknowledge and accept that this Agreement is, in the circumstances, fair and equitable and that it is being entered into freely and voluntarily, after having received such advice and with such knowledge and that execution of this Agreement is not the result of any duress or undue influence and that it is not the result of any collusion or improper or illegal agreement or agreements. 2. SEPARATION. It shall be lawful for each Party at all times hereafter to continue to live separate and apart from the other Party at such places 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. j, ,I II 2 ..:- ""'j) ,!-: ""-, ---", ' __"-""'J{'-~~',',:, "-- , 3. AGREEMENT TO BE INCORPORATED IN DNORCE DECREE. The Parties agree that the tenus of this Agreement shall be incorporated into any Divorce Decree, which may be entered with respect to them at the request of either Party. The Parties agree that the Court of Common Pleas of Cumberland County, Pennsylvania, shall retain continuing jurisdiction over the Parties and the Agreement for the purposes of enforcement of any of the provisions thereof. The Parties agree that unless otherwise specifically provided herein, if a Decree is entered divorcing the Parties, although this Agreement shall be incorporated into said Decree, this Agreement shall not merge with, but shall continue in full force and effect after such time as a Final Decree in Divorce may be entered with respect to the Parties and may be enforced in an action independent of the Divorce Decree. The Parties agree and it is the intent of each of them that this Agreement may be enforced either under the provisions of the Pennsylvania Divorce Code or in an action independent of the Divorce Decree in accordance with Section 3502 of the Pennsylvania Divorce Code. The provisions of this Agreement regarding the disposition of existing property rights and interests between the Parties, alimony, alimony pendente lite, counsel fees and expenses shall not be subject to modification by any Court. 4. SUBSEOUENT DNORCE. The Parties hereby acknowledge and express their agreement that the marriage is irretrievably broken, and the Parties agree to cooperate in any necessary way to obtain a mutual consent, no-fault divorce, pursuant to Section 330 I C of the Pennsylvania Divorce Code. 3 II II ',- I, "_ _ "<' i .,~, '0' _. , '. 8. MUTUAL RELEASE. Subject to the provisions of this Agreement, each Party has released and discharged, and by this Agreement, does for himself or herself, and his or her heirs, legal representatives, executors, administrators and assigns, release and discharge the other of and from all causes of action, claims, rights, or demands, whatsoever in law or equity, which either of the Parties had or now has against the other, except for any and all causes of action for divorce and except for any and all causes of action for breach of any provisions of this Agreement. 9. DISCLOSURE OF PROPERTY. Husband and Wife acknowledge and agree that they have made a full and complete disclosure to the other of all information pertaining to the Parties' separate and marital property owned, possessed and/or controlled by the other at the time ofthe separation of the Parties. Further, that the Husband and Wife voluntarily and intelligently agree to waive any rights which they may have to receive an Inventory and Appraisement of all property owned or possessed by them, either jointly or individually, at the time of the delivery of this Agreement or of the commencement of any action of divorce. I O. EQUITABLE DISTRIBUTION. Husband and Wife acknowledge and agree that the provisions of this Agreement with respect to the distribution and division of marital and separate property are fair, equitable and satisfactory to them based on the length of their marriage and other relevant factors that have been taken into consideration by the Parties. I il II 5 , - _''''u..'_;C '~~ IlIlm' , " a. PERSONAL PROPERTY. The Parties have divided between themselves, to their mutual satisfaction, all items of tangible, personal property previously used by them in the marital home. Husband shall pay Wife $7,500.00 in full settlement of all ~ ( ~" ,,'tal claims at th, ,tim, ofth, ~_onofth;, Agreom<m!. .",,>. /~ /1tjY (;.. -;?I/I H>rlhHfdlty .bHf~~~ - :?71b/r b. MOTOR VEHICLES. With respect to the vehicles owned by the Parties, the Nissan Maxima shall become the sole and exclusive property of Wife, which title shall be transferred to her by Husband contemporaneously with the signing of this Agreement. Wife shall be responsible for the costs associated with her vehicle including but not limited to insurance, registration, maintenance and repair, and shall hold Husband harmless for any claim made against him relative to the vehicle. Husband agrees to assume sole liability for the repayment of the car loan. He shall indemnifY and hold Wife hannless for any and all claims made against her relative to the car loan. Husband shall also maintain liability insurance on said vehicle until he pays off the car loan. c. EMPLOYMENT-RELATED BENEFITS. Wife shall relinquish all rights that she may have in Husband's 40l(k) plan, Husband's IRA account, and any other employment-related benefits he~, c d during the marriage. The parties agree that ~ 't~'{ fop- 1; Husband shall continue(l.Wife's e cw insurance for a period of twelve (12) months from the date of the signing of this agreement or until Wife secures her own insurance benefits. I II II 6 ~~ '_"'0"" ,-< - '. '. d. CHECKING AND SAVINGS ACCOUNTS. With regard to checking and savings accounts, each Party hereto waives any interest they may have in the other's personal checking and savings accounts. e. MARITAL DEBTS. The Parties acknowledge that the parties have incurred debt during the marriage. The parties shall be responsible for the debts they each incurred during the marriage respectively. Husband shall assume sole financial responsibility for the car loan associated with the 1999 Nissan Maxima in Wife's possession.. He shall indemnify Wife and hold her hann1ess for any and all claims made against her relative to the car loan. II. Both Parties hereby accept the provisions of this Agreement with respect to division of property in lieu of and in full and final settlement and satisfaction of all claims and demands that they may now have or hereafter have against the other for the equitable distribution of their property by any Court of competent jurisdiction pursuant to Section 3502 of the Divorce Code or any other laws. Husband and Wife voluntarily and intelligently waive and relinquish any rights to seek a Court-ordered determination and distribution of marital property, but nothing herein shall constitute a waiver by either Party of any rights to seek their relief of any Court for the purpose of enforcing the provisions of this Agreement. 12. ALIMONY, ALIMONY PENDENTE LITE, COUNSEL FEES AND EXPENSES. Both Parties accept the provisions of this Agreement in lieu of and as full and final 7 I: II A'. ei. , '. " settlement and satisfaction of all claims and demands that they may now or hereafter have against the other for alimony, alimony pendente lite, counsel fees or expenses, or for any other provision for support and maintenance before, during or after the commencement of any proceedings for the divorce or annulment between the Parties. 13. BANKRUPTCY. It is hereby understood and agreed by and between the parties that their obligation pursuant to this agreement shall not be affected by any bankruptcy proceeding and shall not be deemed to constitute or be a dischargeable debt of a bankruptcy, Both parties warrant that he or she has not heretofore instituted any proceedings pursuant to the bankruptcy laws nor are there any such proceedings pending with respect to him or her that have been initiated by others. 14. PAST DUE TAXES, The parties have heretofore filed joint Federal and State tax returns. Both parties agree that in the event any deficiency in Federal, State, or Local income tax is proposed, or any assessment of any such tax is made against either of them, each will indemnify and hold hannless the other from and against any loss or liability for any such tax deficiency or assessment and any interest, penalty or expense shall be paid solely and entirely by the individual who is finally determined to be the cause of the misrepresentations or failures to disclose the nature and extent of his or her separate income on the aforesaid joint returns. 15. APPLICABILITY OF TAX LAW TO PROPERTY TRANSFERS. The parties hereby agree and express their intent that any transfer of property pursuant to this agreement 8 i II II =~. r ' - -, ," ",',-.- '~' ". ". shall be within the scope and applicability of the Deficit Reduction Act of 1984 (hereinafter the "Act"), specifically, the provisions of said Act pertaining to the transfers of property between spouses and former spouses. The parties agree to sign and cause to be filed any elections or other documents required by the Internal Revenue Service to render the Act applicable to the transfers set forth in this agreement without recognition of gain on such transfers and subject to the carry-over basis provisions of the said Act. In the event there is a transfer tax assessed then said tax shall be the responsibility of the party receiving the property. 16. WAIVER OF CLAIMS AGAINST ESTATE. 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 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 marital relationship, including, without limitation, dower, courtesy, statutory allowance, widows allowance, right to take property under equitable distribution, right to take in intestacy, right to take against the will of the other's estate, and who 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. 17. BREACH. If either Party breaches any provision 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 advisable to him or her. The Party breaching this Contract should be responsible for payment oflegal fees and costs incurred by the other in enforcing their 9 - 1,1 " '-.1:". ~:-J '~'" _'C, '_ '. '. ". rights under this Agreement. 18. 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. 19. MODIFICA nON AND WAIVER. The modification or waiver of any of the provisions of this Agreement shall be effective only if made in writing and executed with the same formality as this Agreement. The failure of either Party to insist upon strict performance of any of the provisions of this Agreement shall not be construed as a waiver of any subsequent default of the same or similar nature. 20. DESCRIPTIVE HEADINGS. The descriptive headings used herein are for convenience only. They shall have no effect whatsoever in determining the rights or obligations of the Parties. 21. INDEPENDENT SEPARATE COVENANT. It is specifically understood and agreed by and between the Parties hereto that each paragraph hereof shall be deemed to be a separate and independent covenant and agreement. 22. APPLICABLE LAW. This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania. I II II 10 ~, - ' ~- .~ , 23. VOLUNTARY EXECUTION. Husband and Wife acknowledge and represent that the provisions of this Agreement are fully understood by both Parties and each Party acknowledges that this Agreement is in all respects fair and equitable, that it is being entered into voluntarily and knowingly, and that it is not the result of any duress, undue influence, collusion or improper or illegal agreement or agreements. IN WITNESS WHEREOF, the Parties have hereunto set their hands and seals the day and year first above written. WITNESS: ~-~.~ ~42 (SEAL) ~ dflyJl[;~EAL) II I~~ , -". ~ ;;;Ri;M, , .. MARK E. FERRIS, Plaintiff, IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00-4900 LORI J. FERRIS, Defendant. CNIL ACTION--LA WIN DNORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the Court for the entry of a divorce decree: I. Ground for divorce: irretrievable breakdown under section 330 I ( c) of the Divorce code. 2. Date and Manner of service of the Complaint: Certified Mail, Return Receipt Requested, Restricted Delivery to Addressee Only on or about July 13, 2000. 3. Date of execution of the affidavit required by section 3301 (c) of the Divorce Code: by Plaintiff on December 21, 2000 and by Defendant on December 14, 2000. 4. Related claims pending. The economic claims have been settled by agreement. 5. Date the Plaintiffs waiver of Notice in section 3301 (c) of the Divorce was filed with the Prothonotary: is January 8, 2001. II II ~\I,.'" . ~ Respectfully submitted, 6. Date the Defendant's Waiver of Notice in section 3301 (c) of the Divorce was filed with the Prothonotary: January 8, 2001. ROBINSON & GERALDO ,~~ By: Gerald S. Robinson, Esquire Attorney J.D. No. 27423 4407 North Front Street P.O. Box 5320 Harrisburg, Pennsylvania 17110 (717) 232-8525 Attorney for Plaintiff. 'u'_'_,_ -'-" "", --,,-, :'-. '-. - -..--.',,,,,_r;~_,' ";;,,-,,.Ji,i "d,-~",;,"" -".--';;"'i~M -,.-.<,.-, .--.....'U MARK E. FERRIS, Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00 - "I9DO e,'oiL/~ LORI 1. FERRIS, Defendant. CIVIL ACTION-DIVORCE NOTICE TO 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 child. When the ground for the divorce is indignities or irretrievable breakdown ofthe marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Courthouse, One 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 THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VB A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CQMBERLAND COUNTY LAWYER REFERRALSERVICES CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE PA 17013 (717) 249 3166 or 1 800 990 9108 I Ii . .. ^-~ , .~. ~"e'_'," -"'_ '0 --,..., ,. _~ "';;'''.~'' _ ",;. . .,_ ~ MARK E. FERRIS, Plaintiff, v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. LORI J. FERRIS, Defendant. CIVIL ACTION-DIVORCE A VISO USTED HA smo DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas, debe tomar accion dentro de los proximos veinte (20) dias despues de la notificacion de esta Demanda y A viso radicando personalmente 0 por medio de un abogado una comparecencia escrita y radicano en la Corte por escrito sus defensas de, y objecciones a ,Ias demandas presentadas 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 caulquier otra reclamacion 0 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 importances para used. SED DEBE LLEV AR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO 0 NO PUEDE P AGARLE A UNO, LLAME 0 VA Y A A LA SIGUIENTE OFICINA PARA A VERIGUAR DONDE PUEDE ENCONTRAR ASISTENCIA LEGAL. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE Cumberland County Court Administrator 4th Floor, Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 I II '. _ ,., "" ,..-' ~-,,L,, .,--,j,,:.", .'...,' ,.-.;,-" ',' -,-",,',-, "",'-"-'>- MARK E. FERRIS, Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ; NO. f>1} _ if q /)t) c...;a -r ~ v. LORI J. FERRIS, Defendant. : CIVIL ACTION-DIVORCE COMPLAINT UNDER SECTION 3301 (C) OF THE DIVORCE CODE COUNT I I. Plaintiff is Mark E. Ferris, who currently resides at 68 Tory Circle, Enola, Cumberalnd County, Pennsylvania. 2. Defendant is Lori J. Ferris, who currently resides at 309 Fairview Road, Clarks Green, Pennsylvania. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on October 26, 1996 in Clarks Summit, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the Parties. I ,I II '" "-~ . ~ '~_c.-_ , , ;' ~ ., ,,- ~'" ... ,~, ''''.''-- i__, .' 6. The marriage is irretrievably broken. 7. Neither Party is a member of the Armed Forces of the United States or any of its allies. 8. The Plaintiff has been advised ofthe availability of counseling and that either Party may compel the other by Order of Court to attend counseling sessions. WHEREFORE, Plaintiff respectfully requests that your Honorable Court enter a Decree in Divorce under Section 3301(c) of the Divorce Code. COUNT IIo-EQUlTABLE DISTRIBUTION 9. The Plaintiff incorporates by reference Paragraphs I through 8 of the Complaint for Divorce as fully set forth herein. 10. During the marriage, Plaintiff and Defendant have acquired various items of marital property, which are subject to equitable distribution under Section 3502 of the Pennsylvania Divorce Code of 1980, as will be fully set forth in the Plaintiff's Inventory and Appraisement to be filed pursuant to the Pennsylvania Rules of Civil Procedure. 2 cl'. ", -,'c<;.- --'_". "i.i''',:, .10 11. Plaintiff and Defendant have been unable to agree as to an equitable division of marital property. WHEREFORE, Plaintiff requests your Honorable Court to equitably divide ail marital property. RespectfuIIy submitted, ROBINSON & GERALDO Date: 1 /Ib/ CP By: raId S. Robinson, Esquire Attorney I.D. #27423 4407 North Front Street P.O. Box 5320 Harrisburg, PeIll1sylvania 17110-5320 (717) 232-8525 Attorney for Plaintiff 3 _ J" ,~ _, , -'- ,', - - - ~'~- -;, ',_'~. "-x_ '"' '_'_' VERIFICATION I verifY that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. ~-' ~~~ E. Ferris, Plaintiff il -,,_k , 00", ,-. "- " ,-- ;, (~ -, .-,.., --- ~"'" '~-', ,;. > , ~~'i CERTIFICATE OF SERVICE I, Gerald S. Robinson, Esquire, do hereby certifY that on the lOth day of July, 2000, I . cau~ed a true and correct copy of the Complaint to be served upon the following individual by certified mail restricted delivery to addressee only by depositing same in the United States, postage prepaid, in Harrisburg, Pennsylvania. Lori J. Ferris 309 Fairview Road Clarks Green, P A 18411 Respectfully submitted, ROBINSON & GERALDO BY:~~ o'erald S. Robinson, Esquire Attorney J.D. #27423 4407 North Front Street P.O. Box 5320 Harrisburg, Pennsylvania 17110-5320 (717) 232-8525 II II .",-/i .. MARK E. FERRIS, Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00-4900 LORI J. FERRIS, Defendant. CIVIL ACTION-DIVORCE PROOF OF SERVICE The undersigned makes the following return of service: the Complaint in Divorce was served upon Lori J. Ferris, the Defendant, on July 13, 2000 at 309 Fairview Road, Clarks Green, County, Pennsylvania. The signed receipt is attached as Exhibit 1. SIGNATURE AND AFFIDAVIT I, Gerald S. Robinson, Esquire, certify that I am a competent adult not a party to this action. I verify that the statements made in this affidavit and return of service 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 falsfication to authorities. Respectfully submitted, Dated: ~/ 5/(JO ROBINSON & GERALDO BY~~ Gerald S. Robinson, Esquire Attorney LD. No. 27423 4407 North Front Street P.O. Box 5320 Hanisburg, Pennsylvania 17110-5320 (717) 232-8525 Attorney for Plaintiff ~-. ,'- J,. Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. . Print your name and address on the reverse so that we can return the card to you. . Attach this card to the back of the mailpiece, or on the front if space permits. 1. Arti~I~Adr~ ~~~ ~,~,PA 1%4\\ _ii .. ,h_, 3. irvice Type Certified Mail Registered o Insured Mail "'--."'" ~ Express Mail Return Receipt for Merchandise C.O.D. 4. Restricted Delivery? (Extra Fee) Yes ""! l-,' l Bomestic Return Receipt 102595-99-M-1789 ~ " " 3 EXHIBIT 1 - o' '~"""';" MARK E. FERRIS, Plaintiff, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00-4900 LORlJ. FERRIS, Defendant. CIVIL ACTION-DIVORCE I'! il !'i AFFIDAVIT OF CONSENT !'i 1. A Complaint in Divorce under ~ 3301 (c) of the Divorce code was filed on July 11, 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. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 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 falsification to authorities. Date: ~.: L. Mark E. Ferris, Plaintiff /.2-2/....00 1"-" ,I -;~ .. . , MARK E. FERRIS, Plaintiff, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00-4900 LORI J. FERRIS, Defendant. : CIVIL ACTION-DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER!i 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! 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 veriJy 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. 94904 relating to unsworn falsification to authorities. Date: ~ ~...~ Maf1(E. Ferris, Plaintiff /.2~.2-J -~ I II i I l~- T......_~ ,,,",,,~, ._.~. ~ . . ~ _.~"''''"''~_ --'~~~~'u, ~;.-lLJ ~ ..,_.'.--,b...........;"",~...."'~ .... . . . . . MARK E. FERRIS, PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY VS. NO. 00 - 4900 LORI J. FERRIS, DEFENDANT CIVIL ACTION - DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce was filed under Section 3301( c) of the Pennsylvania Domestic Relations Code on or about ,2000. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of a Final Decree of Divorce. 4. I understand that I may lose rights concerning alimony, division of property, lawyers 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 are made subject to the penalties of 18 Pa. C.S. 94904 relating to unsworn falsification to authorities. I;;. ~ Jj /2fi1) Date j / ik< (J, r;; ULJ o J. FE S ) , '"'"~ -,""~ <~- "'*'Milfi!~f- _. ~. 1iI~~+'~."'lcl&wi,!ffiiMIi~~' ~~'"""~w~""''''''''~llfi~ , 4'> - . ~1\;Ui!li:_liillri - , o <;; "':c -.::.1 C;.~- rilr', '2;~ -;:'i-' .?...-,',-- ~ii:: .-"-", -r:.",,--c '":;7'-,.,: .-( . 5c ?':i :.:< ~-I o <-- -- o -"-"-~ -- - ,,-,~ n ""',; "'i:,:::::< ~'-'," ....- ;:'~\ --'::\"\,,' . J r'~'. '.-:::~- ~:(', ~;> -.:.;~, ~~l:"'-t:1 :::::j ::CJ --':;:, - - - ,0 ^"",~""'-~' .~-._~~""" - b"~'.l,~-,-"~~w.... .~.....~..~"' I' ~".._~~, I~ ''"''~ ~" n' " _ . . . . . " . " " '> ., MARK E. FERRIS, PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY VS. NO. 00 - 4900 LORI 1. FERRIS, DEFENDANT CIVIL ACTION - DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A 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! 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 falsification to authorities. /J2/JLj )::2CtJO Date / . ~*~i.h ~, ..;.< "'[.C --"" "~_. ,~" '-'-~ ." ''''''"''~T-j<,*%.~__t~ItI<\\'J~i!o'-',!"~l)''J::'ili~Itl\g~~ . " -~~-~. =~,~-~-,. ~. ~-' . "-'" ,~" '-"-~-""~--~ .---'--" " ~~.""",, -. ~. -'~'~ '"""""'-~""l!M' T'~-iiI!--~.i<lIl;ijillilllif8"- v (') C") t:-) c.:: -n --" \.'} 0 ',:J. .:::::;0 rn j-r .;::;~ " Z L~' /..::.. (/~ C) , > r:::: '.. '- ):""; "'C:'.!.... ." C ~-~,. J y C C.J c.:: -" Z )"r"'; -'i :n -::-" , 0 -< ~" ~" '"~: '. w . "J! " ~-~ '. MARK E. FERRIS, PLAINTIFF VS. LORI J. FERRIS, DEFENDANT .. ~~ hi '"~. _ .~k ~j-~-, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO. 00 - 4900 CIVIL ACTION - DIVORCE PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Kindly enter my appearance on behalf of Defendant, Lori 1. Ferris, in regard to the above-referenced matter. Date: 1/2 1 (co RICHARD A. FANUCCI, ESQUIRE Attorney for Defendant Attorney LD. No. 55762 1418 Main Street, Suite 102 Peckville, P A 18452 Telephone: (570) 383-0652 -:.i!;~~ - " '~i1li:iIl <', >~W"~""_ MARK E. FERRIS, PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY VS. NO. 00 - 4900 LORI J. FERRIS, DEFENDANT CIVIL ACTION - DIVORCE CERTIFICATE OF SERVICE I, Richard A. Fanucci, Esquire, hereby certify that I am this day serving the foregoing Praecipe for Entry of Appearance upon the following individual(s) by United States First Class Mail, Postage Prepaid, on the Z 7 day of I ~ ,2000: Gerald S. Robinson, Esquire Robinson & Geraldo 4407 North Front Street P.O. Box 5320 Harrisburg, P A 17110-5320 RICHARD A. FANUCCI, ESQUIRE Attorney for Defendant Attorney J.D. No. 55762 1418 Main Street, Suite 102 Peckville, PA 18452 Telephone: (570) 383-0652 .i....'.", "~'" "-~J!i1ljl~ililS!l.!Ujlil_~~~a'.li~~ilOj;iJ!'lli~""~~- ,..... ....".........."". ',. o ~: -;)C ~ S2.\..'. "0-, ,->- ~c~~: J? C'~ -:? ~ -, 1IiIii.',;,"'''''-'~'~ ..,~ ;.- -;') - ""-<-'Ii-! II 'I Ii [:1 rl ~I " I I I I , II , I , I I II r;:: ,- ~,..j ,'i ~. .;". ',-:' '0 <'" ',-',;:: ~ . MARK E. FERRIS PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY VS. CIVIL ACTION - LAW IN DIVORCE LORI 1. FERRIS, DEFENDANT NO. 2000-04900 NOTICE OF ELECTION TO RETAKE MAIDEN NAME NOTICE IS HEREBY GIVEN that Defendant in the above-captioned divorce matter, LORI J. FERRIS, having been granted a final decree in divorce from the bonds of matrimony on the 18th day of January, 2001, hereby elects and chooses to retake and hereafter use her previous maiden name of LORI J. PACYNA. SIGNATURE OF DE~ANT: ~cJU (j, ~ J. FERlUS ELECTED NAME: (2 W'Q a'C;U .~ LORI J. PACYNA Sworn to and subscribed before me this .30~ day of ~un~ ,2002- yfaL:.,":n4,dv LL NOTARY PUBLIC ,'i., ~.. ~. ,., ,_~:i;' - .J t "):l!' I. _ I Notarial Seal Nadloe Matech,!k, 'Notary. Public Blakely Bore, Lackawanna County My Commission Expires Apr. 23. 2005 -? .,.; . -1;. OJ Ol-t ,-' , -. '-\:) !',., "-ic'""""" 'c , .Llr-IJ t'" -~Illfi__~:W.(J :ailll~l!o __a,o] _ HJ .,;]., ,',,',--.-," , Pt' ~ ~ .c 8 'tI1-cJ ~~p-- ~ 1- -, ~_ - ._r" n c -CJ: f.~:~ rnr'''-' Z~U 2:r (f).Y'- ..:/' -;: c; c.:'; "- O-~('.' z....-:' ~--( ) >c: '7 :::=j -" ,. r .. ,co . . ,;" , ") '-.-::) 1"0 -" ('''1 ,.X! C) "n I eel "0 "J ,--./ :;:) .t:'" ~. :D -< .\:,-,.':. " ;