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HomeMy WebLinkAbout07-0653ROBERT E. HAHN, SR., Plaintiff V. KRISTINA M. HAHN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW No. 07 -, ?- 93 IN DIVORCE NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree 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 Court House, High and Hanover Streets, Carlisle. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Phone: (717) 249-3166 (800) 990-9108 AMERICANS WITH DISABQ,ITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. ROBERT E. HAHN, SR., IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW v NO. b'r _ ( ?c c> KRISTINA M. HAHN, Defendant IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Robert E. Hahn, Sr., who currently resides at 2120 Waggoners Gap Road, Cumberland County, Pennsylvania, 17013 since June, 1994. 2. Defendant is Kristina M. Hahn, who currently resides at 254 B Petersburg Road, Carlisle, Cumberland County, Pennsylvania, since October, 2005. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on August 14, 1994, in Mt. Holly Springs, PA. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available, and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 8. Plaintiff requests the Court to enter a Decree in Divorce. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree in Divorce and such other Orders as may be just and appropriate. Respectfully submitted, ROMINGER & WHARF Date. Michael O. Palermo, Jr., Esquire Attorney for Plaintiff 155 South Hanover Street Carlisle, PA 17013 Supreme Court I.D. #93334 (717) 241-6070 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. § 4904, relating to unworn falsification to authorities. Z d? Date: R ert E. Hahn, Sr., Plaintiff N V N c::a 1 w cti> ?T?-{ Film ROBERT E. HAHN, SR., Plaintiff V. KRISTINA M. HAHN, Defendant :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW No. 07-653 IN DIVORCE PETITION TO ENFORCE MARITAL SETTLEMENT AGREEMENT AND NOW, comes Robert E. Hahn, Sr., by and through his counsel, Michael O. Palermo, Jr., Esquire and in support of his Petition to Enforce Marital Settlement Agreement avers as follows: 1. Plaintiff, Robert E. Hahn, Sr., and Defendant, Kristina M. Hahn entered into a Marital Settlement Agreement on or around July 25, 2007. Attached as Exhibit "I". 2. Paragraph fourteen (114) of the Agreement specifically states that both parties would execute the documents including the Affidavits of Consent and Waivers of Notice necessary to finalize the Divorce at the above captioned docket. 3. In March of 2008, undersigned counsel had sent correspondence including an Affidavit and Waiver to Attorney Ruby Weeks, Defendant's counsel at that time inquiring as to whether or not Attorney Weeks was still representing the Defendant and requesting that her client sign and return the Affidavit and Waiver. 4. Undersigned counsel again sent correspondence to Attorney Weeks on or around September 4, 2008, inquiring to the status of her representation of the Defendant, Kristina M. Hahn. 5. On or around October 1, 2008, Attorney Weeks responded with correspondence stating that she had been unable to contact Kristina M. Hahn and advised undersigned counsel that he should contact the Defendant directly. 6. Correspondence was forwarded to the Defendant on or around October 7, 2008, with an Affidavit and Waiver for her signature in order to move forward with finalizing the Divorce. 7. No response was forthcoming from the Defendant and another letter including an Affidavit and Waiver and the advisement that undersigned counsel would file this Petition was forwarded again on or around January 8, 2009. 8. No response has been received by undersigned counsel's office. 9. Defendant has breached the Marital Settlement Agreement by not signing the paperwork necessary to finalize the Divorce. 10. Almost two (2) years have passed since the initial signing of the Marital Settlement Agreement and Plaintiff has completed all of his obligations under the Agreement including due diligence in attempting to provide Defendant said documentation on numerous occasions. 11. Plaintiff is entitled to reasonable attorney's fees for the filing of the Petition to Enforce in the amount of $300.00. 12. Pursuant to Cumberland County Local Rule(s) 208.3(a)(2) and L&9), no other Judges of this Honorable Court have ruled upon this docket' and the consent of the other party was sought but not obtained due to the Defendant's failure to respond to any correspondence forwarded to her. 1 The Honorable Edward E. Guido signed an Order in consideration of the Marital Property Settlement, however that docket was under a separate Domestic Relation docket, docketed at 261 Support 2007. Attached as Exhibit' 2". WHEREFORE, your petitioner respectfully requests that this Honorable Court order the Defendant, Kristina M. Hahn to comply with the provisions of the Marital Settlement Agreement and execute the documents necessary to finalize the Divorce at the above captioned docket. Date: Fe7'1.:30 q-zw I Respectfully submitted, ROMING & ASSOCIATES Michael O. Palermo, Jr., uire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 93334 Attorney for Plaintiff/Petitioner ROBERT E. HAHN, SR., :IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW V. No. 07-653 KRISTINA M. HAHN, Defendant IN DIVORCE CERTIFICATE OF SERVICE I, Michael O. Palermo, Jr., Esquire, do hereby certify that I served a copy of the Motion upon the following by depositing same in the United States mail, postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Kristina M. Hahn, pro se 254 B Petersburg Road Carlisle, PA 17013 Dated: F&? 2 Respectfully submitted, ROMINGER & ASSOCIATES Michael O. Palermo, Jr., Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 93334 Attorney for Plaintiff ROBERT E. HAHN, SR., Plaintiff V. KRISTINA M. HAHN, Defendant CIVIL ACTION LAW No. 07-653 IN DIVORCE MARTIAL SETTLEMENT AGREEMENT THIS AGREEMENT made this 2s6daY of 2007 by and between Robert E. Hahn, Sr., hereinafter referred to as "HUSBAND", and Kristina M. Hahn, hereinafter referred to as "WIFE." WITNESSETH: WHEREAS, HUSBAND and WIFE were lawfully married in the Commonwealth of Pennsylvania on August 14, 1994 and separated on or about October 25, 2005. WHEREAS, diverse, unhappy differences, disputes and difficulties have arisen between the parties and it is the intention of HUSBAND and WIFE 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; the settling of all matters between them relating to the ownership and equitable distribution and real and personal property; the settling of all claims and possible PLAINTIFF'S EXHIBIT /z :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA claims by one against the other or against their respective estates and equitable distribution of property and alimony for each party. NOW, THEREFORE, in consideration of the promises and the mutual promises, covenants and undertakings hereinafter set forth and for other gook and valuable consideration, receipt of which is hereby acknowledged by each of the parties hereto, HUSBAND and WIFE, each intending to be legally bound, hereby covenant and agree as follows: The parties intend to maintain separate and permanent domiciles and to live apart from each other. It is the intention and purpose of this agreement to set forth the respective rights and duties of the parties while they continue to live apart from each other. 2. The parties have attempted to divide their matrimonial property in a manner that conforms to just and right standards, with due regard to the rights of each party. It is the intention of the parties that such division shall be final and shall forever determine their respective rights. The division of existing marital property is not intended by the parties to constitute in any way a sale or exchange of assets. 3. Further, the parties agree to continue living separately and apart from each other at any place or places that he or she may select. Neither party shall molest, harass, annoy, injure, threaten or interfere with the other party in any manner whatsoever. Each party may carry on and engage in any employment, profession, business or other activity, as he or she may deem advisable for his or her sole use and benefit. Neither party shall interfere with the uses, ownership, enjoyment or disposition or any property now owned and not specified herein or property hereafter acquired by the other. 4. The consideration for this contract and agreement is the mutual benefits to be obtained by both of the parties hereto and the covenants and agreements of each of the parties to the other. The adequacy of the consideration for all agreements herein contained is stipulated, confessed, and admitted by the parties, and the parties intend to be legally bound hereby. 5. Each parry to this agreement acknowledges and declares that he or she, respectively: A. Enters into this agreement voluntarily after receiving the advice of counsel of his or her own choosing or has voluntarily elected not to obtain counsel; B. Is fully and completely informed of the facts relating to the subject matter of this agreement and of the rights and obligations of the parties; C. Has given careful and serious thought to the making of this agreement; D. Has carefully read each provision of this agreement; and E. Fully and completely understands each provision of this agreement, both as to the subject matter and legal effect. F. It is noted that at the time of execution of this document, HUSBAND is represented by Attorney Michael O. Palermo, Jr., of the Rominger & Associates and WIFE is represented by Ruby Weeks, Esquire. 6. Each party represents and warrants that he or she has made a full and fair disclosure to the other of all his or her property, interests of any nature, including any mortgage, pledge, lien, charge, security interest, encumbrance, or restriction to which any property is subject. Each party further represents that he or she has made a full and fair disclosure of all debts and obligations of any nature for which he or she is currently liable or may become liable. Each further represents and warrants that he or she has not made any gifts or transfers of Marital Property for inadequate consideration without the prior consent of the other. Each party acknowledges that, to the extent desired, he or she has had access to all joint and separate state and federal tax returns filed by or on half of both parties during the marriage. 7. DEBTS: It is further mutually agreed by and between the parties that the debts of the parties existing as of the time of the execution of this agreement shall not be finally released or addressed by the foregoing agreement, and that any debts incurred by the parties after the execution of this agreement shall be the sole responsibility of the party incurring that obligation. REAL PROPERTY: The parties agree that HUSBAND shall remain in exclusive possession of the marital residence, located at 2120 Waggoner's Gap Road, Carlisle, PA 17013. It is noted that the parties leased/rented these premises and neither claims and ownership interest in the marital residence, husband will simply continue the lease/rent and effectuate the removal of WIFE from said lease should her name appear on the same. The parties further agree that the residence is not a marital asset. HUSBAND shall bear the responsibility for maintaining timely payments on the residence including taxes and insurance on the marital residence. WIFE hereby agrees to cooperate in executing any and all documents to effectuate the removal of her name from said lease if the need to do the same should arise. 9. PERSONAL PROPERTY: All other personal property belonging to the parties has been separated to the parties' satisfaction at the date of this agreement. 10. INCOME TAX RETURNS: The parties shall file a separate tax return for the tax year 2007, and shall individually keep their own respective refunds. All future income tax returns will be filed separately and the parties will each retain any refund due to them 11. SUPPORT AND ALIMONY: HUSBAND hereby agrees pay to WIFE, the sum 00 of $4,000.00 in monthly payments of Z so. to tie wage attached [via k-,\n HUSBAND'S employer ROADWAY EXPRESS] and distributed by the Domestic Relations Office of Cumberland County. Should HUSBAND leave his employer or become terminated from the same the agreed to sum will remain due and owing to WIFE, in addition HUSBAND hereby agrees that he will notify WIFE and Cumberland County Domestic Relations of any and all new employment within seventy-two (72) hours to effectuate the continuous payments on the $4,000 balance. The $4,000.00 will be the entire amount due and owing to WIFE and once completed HUSBAND and WIFE hereby agree no further support or alimony will be granted or distributed. 12. RETIREMENT ACCOUNTS: Both parties hereby waive and forego all interests in each other's retirement account. WIFE waives any and interest in HUSBAND'S RETIREMENT, 401 K accounts or PENSION FUNDS or SUPPLEMENTAL PENSION FUNDS accumulated during the marriage of the parties and after the separation of the parties. The acceptance of WIFE of the limp sum of four-thousand dollars ($4,000.00) is the consideration given for WIFE abstaining from making a claim on any and all of HUSBANDS pensions, 401K and/or other retirement accounts. 13. WAIVER OF CLAIMS AGAINST THE ESTATES: Except as otherwise provided herein, each party may dispose of his or her property in any way, and each party hereby waives and relinquishes any and all rights he or she may now have or hereafter acquire, under the present or future laws of any jurisdiction, to share in the property or the estate of the other as a result of the marital relationship, including without limitation, dower, curtesy, statutory allowance, widow's allowance, right to take the intestacy, right to take against the Will of the other, and right to act as administrator or executor of the other's estate, and each will, at the request of the other, execute, acknowledge and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waive and relinquishment of all such interest, rights and claims. The sole exception to this paragraph shall occur if HUSBAND should die before the entire $4,000.00 is paid in full to WIFE. Should HUSBAND die, HUSBAND'S ESTATE through the EXECUTOR shall complete payments to WIFE or elect to pay WIFE the remaining BALANCE in a lump sum payment. 14. ADDITIONAL INSTRUMENTS: Each of the parties shall from time to time, at the request of the other, execute, acknowledge and deliver to the other party any and all further instruments that may be reasonable required to give full force and effect to the provisions of this agreement. This shall include any and all documentation and affidavits and waivers to finalize the underlying Divorce action docketed at 07-653 in the Court of Common Pleas of Cumberland County. 15. VOLUNTARY EXECUTION: Both parties fully understand the terms of this agreement and were given full opportunity to discuss said terms with their respective attorneys. Both parties agree that they are executing this agreement freely and voluntarily. Both parties acknowledge that it has been suggested to them that they review this agreement with independent legal counsel and has either done so or has voluntarily chosen not to do so. 16. ENTIRE AGREEMENT: This agreement contains the entire understanding of the parties and there are no representations, warranties, covenants or undertakings other than those expressly set forth herein. 17. APPLICABLE LAW: This agreement shall be construed under the laws of the Commonwealth of Pennsylvania. 18. PRIOR AGREEMENTS: It is understood and agreed that any and all property settlement agreements which may or have been executed or verbally discussed prior to the date and time of this agreement are null and void and of no effect. 19. INCORPORATION NOT MERGER: It is hereby acknowledged by the parties that this Marital Property Settlement shall be incorporated into the Divorce of the parties but shall not be merged into the same. 20. EFFECTIVE IMMEDIATELY: This agreement shall become effective immediately upon its execution by both parties and their respective counsel. IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the day and year first above written. t o, t Dat Date -. Q 7 Date Michael O. Palermo, Esquire Kristina M. Hahn Ruby WeekA, )?squire Robert h. Hatin, Jr. In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION 13 N. HANOVER Sr, P.O. BOX 320, CARLISLE, PA. 17013 Phone: (717) 240-6225 MICHAEL O. PALERMO, JR. CIO ROMINGER & WHARE 155 S HANOVER ST CARLISLE PA 17013-3455 JULY 25, 2007 Fax: (717) 240-6248 6 / 40 Distribution Cover Letter Plaintiff Name: KRISTINA M. HAHN Defendant Name: ROBERT E. HAHN SR PACSES Case Number: 065109086 Please note: All correspondence must include the PACSES Case Number. Dear MICHAEL O. PALERMO, JR. Please note the attached document and/or correspondence. This information is being sent to update you on the above captioned case. Sincerely, R. J. SHADDAY Service Type M a PLAINTIFF'S W EXHIBIT J Form CM-520 Worker ID 21302 KRISTINA M. HAHN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : DOMESTIC RELATIONS SECTION ROBERT E. HAHN, SR., PACSES NO. 065109086 Defendant DOCKET NO. 261 SUPPORT 2007 ORDER OF COURT AND NOW, this 25th day of July, 2007, this matter having been scheduled for a hearing de novo before the Support Master on the Plaintiffs complaint for spousal support, and the parties having reached an agreement on all outstanding issues, upon recommendation of the Master it is ordered and decreed as follows: A. The Husband shall pay to the Wife spousal support in the total sum of $4,000.00 payable in monthly increments of $250.00 commencing with the month of August, 2007 pursuant to the terms of the parties' Marital Settlement Agreement, a copy of which is attached hereto as Exhibit "A." B. A wage attachment shall be issued. IMPORTANT LEGAL NOTICE PARTIES MUST WITHIN SEVEN DAYS INFORM THE DOMESTIC RELATIONS SECTION AND THE OTHER PARTIES, IN WRITING, OF ANY MATERIAL CHANGE IN CIRCUMSTANCES RELEVANT TO THE LEVEL OF SUPPORT OR THE ADMINISTRATION OF THE SUPPORT ORDER, INCLUDING, BUT NOT LIMITED TO, LOSS OR CHANGE OF INCOME OR EMPLOYMENT AND CHANGE OF PERSONAL ADDRESS OR CHANGE OF ADDRESS OF ANY CHILD RECEIVING SUPPORT. A PARTY WHO WILLFULLY FAILS TO REPORT A MATERIAL CHANGE IN CIRCUAI ANCe3 MAY BE ADJUDGED IN CONTEMPT OF COURT, AND MAY BE FIIOR IMPRISONED. o PENNSYLVANIA LAW PROVIDES THAT ALL SUPPORT OAS SHALL BE REVIEWED AT LEAST ONCE EVERY THREE (3) YEARt# SUEH REVIEW IS REQUESTED BY ONE OF THE PARTIES. IF YOU W TO REQUEST A REVIEW AND ADJUSTMENT OF YOUR ORDER, YOUMUStbO THE FOLLOWING: CALL YOUR ATTORNEY. AN UNREPRESENTED PERSON WHO WANTS TO MODIFY (ADJUST) A SUPPORT ORDER SHOULD CONTACT THE DOMESTIC RELATIONS SECTION. ALL CHARGING ORDERS FOR SPOUSAL SUPPORT AND ALIMONY PENDENTE LITE, INCLUDING UNALLOCATED ORDERS FOR CHILD AND SPOUSAL SUPPORT OR CHILD SUPPORT AND ALIMONY PENDENTE LITE, SHALL TERMINATE UPON DEATH OF THE PAYEE. A MANDATORY INCOME ATTACHMENT WILL ISSUE UNLESS THE DEFENDANT IS NOT IN ARREARS IN PAYMENT IN AN AMOUNT EQUAL TO OR GREATER THAN ONE MONTH'S SUPPORT OBLIGATION AND (1) THE COURT FINDS THAT THERE IS GOOD CAUSE NOT TO REQUIRE IMMEDIATE INCOME WITHHOLDING; OR (2) A WRITTEN AGREEMENT IS REACHED BETWEEN THE PARTIES WHICH PROVIDES FOR AN ALTERNATE ARRANGEMENT. UNPAID ARREARAGE BALANCES MAY BE REPORTED TO CREDIT AGENCIES. ON AND AFTER THE DATE IT IS DUE, EACH UNPAID SUPPORT PAYMENT SHALL CONSTITUTE, BY OPERATION OF LAW, A JUDGMENT AGAINST YOU, AS WELL AS A LIEN AGAINST REAL PROPERTY. IT IS FURTHER ORDERED THAT, UPON PAYOR'S FAILURE TO COMPLY WITH THIS ORDER, PAYOR MAY BE ARRESTED AND BROUGHT BEFORE THE COURT FOR A CONTEMPT HEARING; PAYOR'S WAGES, SALARY, COMMISSIONS, AND/OR INCOME MAY BE ATTACHED IN ACCORDANCE WITH LAW. PAYOR IS RESPONSIBLE FOR COURT COSTS AND FEES. By the Court Edward . Gu o. Cc: Kristina M. Hahn Robert E. Hahn, Sr. Ruby D. Weeks, Esquire For the Plaintiff Michael O. Palermo, Jr., Esquire For the Defendant DRO VERIFICATION I verify that the statements made in this Petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unworn falsification to authorities. Date: Robert E. Hahn, Sr., Plaintiff ?? C. ? ? -+? ? C' ??) ?? ,? `? '? t.s ;? ?',? "? ( '+? y. ?u+ ..? FEB 19 2009 M ROBERT E. HAHN, SR., :IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW V. No. 07-653 KRISTINA M. HAHN, Defendant IN DIVORCE ORDER OF COURT AND NOW, this &2 301 day of Mn!? , 2009, upon consi eration of p ? / Eve--sue the within Motion to Enforceyarital Settlement Agreement, the Motion is gwwwd t,and.the -fQ; 46F Wedeh of the f4w iteh sett4effi@M ApseffiWIL 6;; By the Court: J. Distribution: ?Mi ael O. Palermo, Jr., Esquire Kristina M. Hahn E L 9?cc S '.A ROBERT E. HAHN, SR., :IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW vi. No. 07-653 KRISTINA M. HAHN, Defendant IN DIVORCE MOTION TO FINALIZE DIVORCE NOW COMES, Robert E. Hahn, Sr., by and through his counsel, Michael O. Palermo, Jr., Esquire, and asks this Court enter a Divorce in the above captioned matter and in support of his Petition avers as follows: 1. Petitioner filed for a Complaint in Divorce on February 2, 2007. 2.. Respondent accepted the Complaint by certified mail, return receipt, restricted delivery on February 3, 2007. 3. Respondent retained Attorney Ruby Weeks to represent her in the Divorce. 4. The parties entered into a Marital Settlement Agreement on or around July 27, 2007. 5. All of the marital assets have been divided by the parties. 6. Paragraph fourteen (¶14) of the Agreement specifically states that both parties would execute the documents including the Affidavits of Consent and Waivers of Notice necessary to finalize the Divorce at the above captioned docket. 7. In March of 2008, undersigned counsel had sent correspondence including an Affidavit and Waiver to Attorney Ruby Weeks, Defendant's counsel at that time inquiring as to whether or not Attorney Weeks was still representing the Defendant and requesting that her client sign and return the Affidavit and Waiver. 8. Undersigned counsel again sent correspondence to Attorney Weeks on or around September 4, 2008, inquiring to the status of her representation of the Defendant, Kristina M. Hahn. 9. On or around October 1, 2008, Attorney Weeks responded with correspondence stating that she had been unable to contact Kristina M. Hahn and advised undersigned counsel that he should contact the Defendant directly. 10. Correspondence was forwarded to the Defendant on or around October 7, 2008, with an Affidavit and Waiver for her signature in order to move forward with finalizing the Divorce. 11. No response was forthcoming from the Defendant and another letter including an Affidavit and Waiver was forwarded again on or around January 8, 2009. 12. No response has been received by undersigned counsel's office. 13. More than two years have lapsed since Plaintiff and Defendant have separated. 14. There are no issues remaining to resolve in this matter. WHEREFORE, Plaintiff respectfully asks that this Court enter a Decree in Divorce in this matter. Respectfully submitted, Rominger & Associates Date: April 1,, 2009 Michael O. Palermo, qui V 155 South Hanover Str Carlisle, Pennsylvania 17013 (717) 241-6070 Supreme Court ID# 93334 Attorney for Plaintiff ROBERT E. HAHN, SR., :IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW V. No. 07-653 KRISTINA M. HAHN, Defendant IN DIVORCE VERIFICATION Michael O. Palermo, Jr., Esquire, states that he is the attorney for Robert E. Hahn, Sr., Plaintiff in this action; that he makes this affidavit as attorney because he has sufficient knowledge or information and belief, based upon his investigation of the matters averred or denied in the foregoing document; and that this statement is made subject to the penalties of 18 Pa. C.S. Pa.C.S. §4904, relating to unsworn falsification to authorities. Date: l / Michael O. Palermo, Jr., q ire Attorney for Plaintiff ROBERT E. HAHN, SR., :IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW V. No. 07-653 KRISTINA M. HAHN, Defendant IN DIVORCE CERTIFICATE OF SERVICE I, Michael O. Palermo, Jr., Esquire, certify that I this day served the Defendant a copy of the attached Motion to Finalize Divorce in the above referenced matter postage prepaid in the United States mail, addressed as follows: Kristina M. Hahn, pro se 254 B Petersburg Road Carlisle, PA 17013 Respectfully submitted, Rominger & Associates Date: April 1, 2009 ` Michael O. Palermo, Jr.' qui 155 South Hanover Street Carlisle, Pennsylvania 17013 (717) 241-6070 Supreme Court ID# 93334 Attorney for Plaintiff RLEX `a OF THE PR©'?ARY 7009 APR -1 FM 3: 00 CAKKA PD#Z YAW APR 0 2`2009 ? ROBERT E. HAHN, SR., :IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW V. No. 07-653 KRISTINA M. HAHN, Defendant IN DIVORCE ORDER OF COURT AND NOW, this 7 day of , 2009, upon consideration of Plaintiff- .'s Mo Aja tion to Finalize Divorce, t is heleb ve 11w LQ ? .?.t?oytc? ; dE.. U ? BY T RT, J. ichael O. Palermo, Jr., Esquire Vristina M. Hahn, pro se A 1 £ :C W8 C- 8dv 6001 ROBERT E. HAHN, SR., Plaintiff V. KRISTINA M. HAHN, Defendant :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW No. 07-653 IN DIVORCE PRAECIPE TO AMEND DIVORCE COMPLAINT TO THE PROTHONOTARY: Please amend the above captioned matter to include sections 3301C and 3301D of the Divorce Code. Date: V (S-00,1 Respectfully submitted, ROMINGER & ASSOCIATES IW--- -4 A - Michael O. Palermo, r., uire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 93334 Attorney for Plaintiff/Petitioner ROBERT E. HAHN, SR., :IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW V. No. 07-653 KRISTINA M. HAHN, Defendant IN DIVORCE CERTIFICATE OF SERVICE I, Michael O. Palermo, Jr., Esquire, do hereby certify that I served a copy of the Praceipe upon the following by depositing same in the United States mail, postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Kristina M. Hahn, pro se 254 B Petersburg Road Carlisle, PA 17013 Dated: 8 ZO O Respectfully submitted, ROMINGER & ASSOCIATES A:.- Nfichael O. Palermo, quire 155 South Hanover Stree-fJ Carlisle, PA 17013 (717) 241-6071) Supreme Court ID # 93334 Attorney for Plaintiff OF THc ^ -In fi' {",',!r iIT RY 2009 APR -8 PH 3: 44 r n`?{1yi?t+AIA ITfi. ROBERT E. HAHN, SR., Plaintiff V. KRISTINA M. HAHN, Defendant :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW No. 07-653 IN DIVORCE NOTICE If you wish to den, counter-affidavit within tw statements will be admitted. any of the statements set forth in this Affidavit, you must file a ;nty (20) days after this Affidavit has been served on you or the AFFIDAVIT UNDER 1. The parties to th4 action separated on or around October, 2005, and have continued to live separate and apart for a 2. The marriage is iod of at least two years. broken. 3. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not ?laim 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 unworn falsification to authorities. i Date: /G Robert E. Hahn, Sr./Plaintiff 'NOTARY 2069 APR 1 3 PM 3; 20 CUB; s I i„ R1 a t? ROBERT E. HAHN, SR., Plaintiff V. KRISTINA M. HAHN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW No. 07-653 IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE TO: Kristina M. Hahn/Defendant: You have been sued in an action for divorce. You have failed to answer the complaint or file a counter-affidavit to the plaintiffs affidavit. Therefore, on or after May 10, 2009, the plaintiff can request the court to enter a final decree in divorce. If you do not file with the Prothonotary of the court an answer with your signature notarized or verified or a counter-affidavit by the above date, the court can enter a final decree in divorce. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. A COUNTER-AFFIDAVIT WHICH YOU MAY FILE WITH THE PROTHONOTARY OF THE COURT IS ATTACHED TO THIS NOTICE. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 :. FILED or 2609 SI --6 P 3; 4 1 ROBERT E. HAHN, SR., Plaintiff V. KRISTINA M. HAHN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW No. 07-653 IN DIVORCE PROOF OF SERVICE OF DIVORCE COMPLAINT ¦ 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. Article Addressed to: --kQ/4 ? N A. B. R i by (PH44O 1 C. Date of D. Is delivery address different from item 1 If YES, enter delivery address below: 1)1(N0 3. Service Type IvLCertifiied Mail ? Express Mail ? Registered -10 Return Receipt for Merchandise ? Insured Mail 13 C.O.D. 4. Restricted Delivery? (Extra Fee) es ? Agent 2. Article Number (rransrerfiomservice Is 70106 2760 0002 7405 9638 PS Form 3811, February 2004 Domestic Return Receipt 102595.02-M_1540 Fi% 7? ROBERT E. HAHN, SR., Plaintiff V. KRISTINA M. HAHN, Defendant CIVIL ACTION LAW No. 07-653 IN DIVORCE MARTIAL SETTLEMENT AGREEMENT THIS AGREEMENT, made this day of , 2007 by and between Robert E. Hahn, Sr., hereinafter referred to as "HUSBAND", and Kristina M. Hahn, hereinafter referred to as "WIFE." WITNESSETH: WHEREAS, HUSBAND and WIFE were lawfully married in the Commonwealth of Pennsylvania on August 14, 1994 and separated on or about October 25, 2005. WHEREAS, diverse, unhappy differences, disputes and difficulties have arisen between the parties and it is the intention of HUSBAND and WIFE 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; the settling of all matters between them relating to the ownership and equitable distribution and real and personal property; the settling of all claims and possible :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA claims by one against the other or against their respective estates and equitable distribution of property and alimony for each party. NOW, THEREFORE, in consideration of the promises and 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, HUSBAND and WIFE, each intending to be legally bound, hereby covenant and agree as follows: I . The parties intend to maintain separate and permanent domiciles and to live apart from each other. It is the intention and purpose of this agreement to set forth the respective rights and duties of the parties while they continue to live apart from each other. 2. The parties have attempted to divide their matrimonial property in a manner that conforms to just and right standards, with due regard to the rights of each party. It is the intention of the parties that such division shall be final and shall forever determine their respective rights. The division of existing marital property is not intended by the parties to constitute in any way a sale or exchange of assets. 3. Further, the parties agree to continue living separately and apart from each other at any place or places that he or she may select. Neither party shall molest, harass, annoy, injure, threaten or interfere with the other party in any manner whatsoever. Each party may carry on and engage in any employment, profession, business or other activity, as he or she may deem advisable for his or her sole use and benefit. Neither parry shall interfere with the uses, ownership, enjoyment or disposition or any property now owned and not specified herein or property hereafter acquired by the other. 4. The consideration for this contract and agreement is the mutual benefits to be obtained by both of the parties hereto and the covenants and agreements of each of the parties to the other. The adequacy of the consideration for all agreements herein contained is stipulated, confessed, and admitted by the parties, and the parties intend to be legally bound hereby. 5. Each party to this agreement acknowledges and declares that he or she, respectively: A. Enters into this agreement voluntarily after receiving the advice of counsel of his or her own choosing or has voluntarily elected not to obtain counsel; B. Is fully and completely informed of the facts relating to the subject matter of this agreement and of the rights and obligations of the parties; C. Has given careful and serious thought to the making of this agreement; D. Has carefully read each provision of this agreement; and E. Fully and completely understands each provision of this agreement, both as to the subject matter and legal effect. F. It is noted that at the time of execution of this document, HUSBAND is represented by Attorney Michael O. Palermo, Jr., of the Rominger & Associates and WIFE is represented by Ruby Weeks, Esquire. 6. Each party represents and warrants that he or she has made a full and fair disclosure to the other of all his or her property, interests of any nature, including any mortgage, pledge, lien, charge, security interest, encumbrance, or restriction to which any property is subject. Each party further represents that he or she has made a full and fair disclosure of all debts and obligations of any nature for which he or she is currently liable or may become liable. Each further represents and warrants that he or she has not made any gifts or transfers of Marital Property for inadequate consideration without the prior consent of the other. Each party acknowledges that, to the extent desired, he or she has had access to all joint and separate state and federal tax returns filed by or on half of both parties during the marriage. 7. DEBTS: It is further mutually agreed by and between the parties that the debts of the parties existing as of the time of the execution of this agreement shall not be finally released or addressed by the foregoing agreement, and that any debts incurred by the parties after the execution of this agreement shall be the sole responsibility of the party incurring that obligation. REAL PROPERTY: The parties agree that HUSBAND shall remain in exclusive possession of the marital residence, located at 2120 Waggoner's Gap Road, Carlisle, PA 17013. It is noted that the parties leased/rented these premises and neither claims and ownership interest in the marital residence, husband will simply continue the lease/rent and effectuate the removal of WIFE from said lease should her name appear on the same. The parties further agree that the residence is not a marital asset. HUSBAND shall bear the responsibility for maintaining timely payments on the residence including taxes and insurance on the marital residence. WIFE hereby agrees to cooperate in executing any and all documents to effectuate the removal of her name from said lease if the need to do the same should arise. 9. PERSONAL PROPERTY: All other personal property belonging to the parties has been separated to the parties' satisfaction at the date of this agreement. 10. INCOME TAX RETURNS: The parties shall file a separate tax return for the tax year 2007, and shall individually keep their own respective refunds. All future income tax returns will be filed separately and the parties will each retain any refund due to them 11. SUPPORT AND ALIMONY: HUSBAND hereby agrees pay to WIFE, the sum of $4,000.00 in monthly payments of 2 to be wage attached [via HUSBAND'S employer ROADWAY EXPRESS] and distributed by the Domestic Relations Office of Cumberland County. Should HUSBAND leave his employer or become terminated from the same the agreed to sum will remain due and owing to WIFE, in addition HUSBAND hereby agrees that he will notify WIFE and Cumberland County Domestic Relations of any and all new employment within seventy-two (72) hours to effectuate the continuous payments on the $4,000 balance. The $4,000.00 will be the entire amount due and owing to WIFE and once completed HUSBAND and WIFE hereby agree no further support or alimony will be granted or distributed. 12. RETIREMENT ACCOUNTS: Both parties hereby waive and forego all interests in each other's retirement account. WIFE waives any and interest in HUSBAND'S RETIREMENT, 401K accounts or PENSION FUNDS or SUPPLEMENTAL PENSION FUNDS accumulated during the marriage of the parties and after the separation of the parties. The acceptance of WIFE of the limp sum of four-thousand dollars ($4,000.00) is the consideration given for WIFE abstaining from making a claim on any and all of HUSBANDS pensions, 401 K and/or other retirement accounts. 13. WAIVER OF CLAIMS AGAINST THE ESTATES: Except as otherwise provided herein, each party may dispose of his or her property in any way, and each party hereby waives and relinquishes any and all rights he or she may now have or hereafter acquire, under the present or future laws of any jurisdiction, to share in the property or the estate of the other as a result of the marital relationship, including without limitation, dower, curtesy, statutory allowance, widow's allowance, right to take the intestacy, right to take against the Will of the other, and right to act as administrator or executor of the other's estate, and each will, at the request of the other, execute, acknowledge and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waive and relinquishment of all such interest, rights and claims. The sole exception to this paragraph shall occur if HUSBAND should die before the entire $4,000.00 is paid in full to WIFE. Should HUSBAND die, HUSBAND'S ESTATE through the EXECUTOR shall complete payments to WIFE or elect to pay WIFE the remaining BALANCE in a lump sum payment. 14. ADDITIONAL INSTRUMENTS: Each of the parties shall from time to time, at the request of the other, execute, acknowledge and deliver to the other party any and all further instruments that may be reasonable required to give full force and effect to the provisions of this agreement. This shall include any and all documentation and affidavits and waivers to finalize the underlying Divorce action docketed at 07-653 in the Court of Common Pleas of Cumberland County. 15. VOLUNTARY EXECUTION: Both parties fully understand the terms of this agreement and were given full opportunity to discuss said terms with their respective attorneys. Both parties agree that they are executing this agreement freely and voluntarily. Both parties acknowledge that it has been suggested to them that they review this agreement with independent legal counsel and has either done so or has voluntarily chosen not to do so. 16. ENTIRE AGREEMENT: This agreement contains the entire understanding of the parties and there are no representations, warranties, covenants or undertakings other than those expressly set forth herein. 17. APPLICABLE LAW: This agreement shall be construed under the laws of the Commonwealth of Pennsylvania. 18. PRIOR AGREEMENTS: It is understood and agreed that any and all property settlement agreements which may or have been executed or verbally discussed prior to the date and time of this agreement are null and void and of no effect. 19. INCORPORATION NOT MERGER: It is hereby acknowledged by the parties that this Marital Property Settlement shall be incorporated into the Divorce of the parties but shall not be merged into the same. 20. EFFECTIVE IMMEDIATELY: This agreement shall become effective immediately upon its execution by both parties and their respective counsel. IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the day and year first above written. t 4%2S Dat M" - Michael O. Palermo, ., Esquire -7, ;,S-. 0-7 .1. ? /- L Date Kristina M. Hahn Date Ruby Week squire rwoer[ C. Hann, Sr. FLED o;,_ : y ? .. r ? i I- c THE ROBERT E. HAHN, SR., Plaintiff V. KRISTINA M. HAHN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW No. 07-653 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. Grounds for divorce: irretrievable breakdown under § 3301(c) and § 3301 (d) of the Divorce Code. 2. Date and manner of service of the Complaint: Certified Mail/Return Receipt/Restrict Delivery, February 3, 2007. Praecipe to Amend Divorce Complaint to Include § 3301 (d) served on Respondent April 9, 2009. First Class Mail. 3. Related claims pending: Marital Settlement Agreement signed on July 25, 2007. 4. (1) Date of execution of the Plaintiff's Affidavit required by §3301 (d) of the Divorce Code: April 10, 2009. Date of filing and service of the Plaintiff's Affidavit upon the Respondent: Filed April 13, 2009, served on Respondent April 14, 2009. 5. Date and manner of service of the Notice of Intention to Request Entry of Divorce Decree a copy of which is attached: April 14, 2009, first class mail. Date: vl-t=' 2009 at??t Michael O.Pale r., Esquire 155 South Hanover eet Carlisle, PA 17013 (717) 241-6070 Supreme Court ID No. 93334 OF THE 2009 JU -7 PM 3.2 i \iTy ROBERT E. HAHN, SR. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. KRISTINA M. HAHN NO. 2007 - 0653 CIVIL TERM ORDER OF COURT AND NOW, this 20TH day of JULY, 2009, the Plaintiff's request for the entry of a divorce decree is denied for the following reasons: 1.) No amended complaint was ever filed and served upon the Defendant. 2.) There is no proof of service filed in connection with the 3301(d) affidavit. 3.) There is no indication that a counter-affidavit required by 3301(d) was served upon the Defendant. Edward E. Guido, J. Xichael O. Palermo, Jr., Esquire 155 South Hanover Street Carlisle, Pa. 17013 l)e 1Jtina Hahn 254B Petersburg Road Carlisle, Pa. 17013 :sld FILED,,-,IFFfGE OF THE ° 07F?'\K)T`ARY 2009 JUL 21 PM 3: 51 cum F E NN3, Y bA" a ROBERT E. HAHN, SR., IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW V. No. 07-653 KRISTINA M. HAHN, . Defendant IN DIVORCE NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree 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 Court House, High and Hanover Streets, Carlisle. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Phone: (717) 249-3166 (800) 990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. ROBERT E. HAHN, SR., Plaintiff v KRISTINA M. HAHN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 07-653 IN DIVORCE AMENDED COMPLAINT TO INCLUDE SECTION 3301(c) AND SECTION 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Robert E. Hahn, Sr., who currently resides at 2120 Waggoners Gap Road, Cumberland County, Pennsylvania, 17013 since June, 1994. 2. Defendant is Kristina M. Hahn, who currently resides at 254 B Petersburg Road, Carlisle, Cumberland County, Pennsylvania, since October, 2005. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on August 14, 1994, in Mt. Holly Springs, PA. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available, and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 8. Plaintiff requests the Court to enter a Decree in Divorce. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree in Divorce and such other Orders as may be just and appropriate. Respectfully submitted, ROMINGER & ASSOCIATES Date: 3b1SM"t WpdaMAM I& =.-, Michael O. q 're Attorney for Plaintiff 155 South Hanover Street Carlisle, PA 17013 Supreme Court I.D. #93334 (717) 241-6070 VERIFICATION I verify that the statements made in this Petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unworn falsification to authorities. ' Date: Z9 o ert E. Hahn, Sr., Plaintiff -'/ F E ' j ?.?."PY TL 2Pj G9 Jt L 631 F 3 G v (, T k! ROBERT E. RAHN, SR., IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW V. No. 07-653 KRISTINA M. HAHN, Defendant IN DIVORCE PRAECIPE TO TRANSNM RECORD TO THE PROTHONOTARY: Transmit the record, together with'the following information, to the Court for entry of a divorce decree: Grounds for divorce: irretrievable breakdown under § 3301(c) and § 3301 (d) of the Divorce Code. 2. Date and manner of service of the Complaint: Certified Mail/Return Receipt/Restrict Delivery, February 3, 2007. Amended Complaint, Praceipe to Amend Divorce Complaint, Counter Affidavit; processed served October 5, 2009. Attached as Exhibit "A". 3. Related claims pending: Marital Settlement Agreement signed on July 25, 2007. 4. (1) Date of execution of the Plaintiff s Affidavit required by §3301 (d) of the Divorce Code: April 10, 2009. Date of filing and service of the Plaintiff s Affidavit upon the Respondent: Filed April 13, 2009, served on Respondent October 5, 2009 by process service. 5. Date and manner of service of the Notice of Intention to Request Entry of Divorce Decree; Process served on October 5, 2009. Date: Af/0 ? 2009 Michael O.Palermo, Jr., squire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID No. 93334 2099 HO'i 12 Nil 3. 33 lop, ROBERT E. HAHN, SR., Plaintiff v. KRISTINA M. HAHN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW No. 07-653 IN DIVORCE EXHIBIT "A" PROOF OF SERVICE OF AMENDED DIVORCE COMPLAINT. PRAECIPE TO AMEND DIVORCE COMPLAINT. NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE. AFFIDAVIT AND COUNTER AFFIDAVIT I r I • • Commonwealth of Pennsylvania Case Number: 07-653 Plaintiff: Robert E. Hahn, Sr. vs. Defendant: Kristin M. Hahn For: Michael Palermo Rominger & Associates AFFIDAVIT OF SERVICE County of Cumberland Common Pleas Court Received by Pennsylvania Professional Process Svc. to be served on Kristine Hahn, 254 B Petersburg Rd., Carlisle, PA 17013. I, ,. being duly sworn, depose and say that on the !;2!?7day of , 20j at ,executed service by delivering a true copy of the Letter, Notice of Intention to Request Ent of Divorce Decree, Counter-Affidavit Under Section 3301 (d) of the Divorce Code, Notice, Amended Complaint to Include Section 3301(c) & Section 3301 (d) of the Divorce Code, Praecipe to Amend Divorce Complaint, Affidavit Under Section 3301(d) of the Divorce Code in accordance with state statutes in the manner marked below: *INDIVIDUAL SERVICE: Served the within-named person. () SUBSTITUTE SERVICE: By serving as () NON-SERVICE: For the reason detailed in the Comments Below () OTHER r004W "-\- 60 I certify that I have no in eresi which this service was made. -c..,?=?=?s G?dv?s?l ??;s•u n a E-?ah.r?. ?e5 nc?- 1? v e het?? in the above action, am of legal age and have proper authority in the jurisdiction in 7Y-4'kd PROCESS SERV # who is Appointed in accordance with State Statutes Pennsylvania Professional Process Svc. 48 W. High St. P.O. Box 1148 0% Al 1 PA 17013 COMMOWVEALTH OF PENNSYLVANIA a s e, Notarial seat (800) 863-2341 LM. Michelle Guyton, Notary Public Our Job Serial Number: 2009000474 Carlisle Soro, Cumberland County My Commission Expires July 1, 2012 - ht C 1892.2005 Database services, Inc. - Process server's Toolbox V5.5i Member, Pennsylvania Association of Notaries 1?,r5 ©® k0 ki IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ROBERT E. HAHN, SR. V. KRISTINA M. HAHN NO. 07-653 DIVORCE DECREE AND NOW, a uU , it is ordered and decreed that ROBERT E. HAHN, SR. plaintiff, and KRISTINA M. HAHN , defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") A Marital Settlement Agreement is incorporated into but not merged with the Divorce Decree. By the rt, Attest: J. rotho Jo2t a Wry 1/,ao O? wozi? ti