Loading...
HomeMy WebLinkAbout97-01795 '" ~ ... \I '" \l t c3 \ \.., "'." \. ~ .. .~ '-' ~ ~, ,- I t', 1.)--: . ;z .::4::' .:.:..~:. -:.:. .:+;. .:~~., .:+;. .:+:. .:+:. .x. .:+:. -:.:. .:+;. .:+:. .:+:. .:+:. -:.:. .:+:. -:.;'":-:-:+:'::':+:-::':+:<':+:'u':+:'" .:+:. .:+:. ':+:'. .:.:o"~~' ~ w ~ ? ~ ~ ~ ~ '.' $ ~ ... ~ '.' ~ ~ '.' ~ '.' " ~ '.' ~ ~ ~ ~ .'~ ~ '.' ,', ~ ~ ~.~ ~ ~ ~ $ ~ ~. ~ ~ '.' ~ ~ " ~ ~ ., , , >(: i'ot l~ .. . - . .~ -:.;. .:+;. .:..:- <It;' .:+;. .:+:. .:.:- .:+;. .:+:. .:+;. ?- ~ ~ ',' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY ~~~ ~~:,,' . 'r.~" .... ,. ,._,~~,.".,...t ~ " ~ ;(. ~ ~ ~ ~ -- -~~-- ,...:. ...:. ...:' .... ~ ~ STATE OF PENNA, VICTORIA L, COMERER N (I'd 17.9.5........ 'dddddd. It) 97 VC)",:o;lIS DONALD C. COMERER DECREE IN DIVORCE AND NOW, ' .. ,A r.;J ,'a....., .... .. " 19 .~,~.., it is ordered and decreed that .".,.""".,. VlCTO~l~. L., CO~E~E~, , , . " ,.. .. . . ", plaintiff, and. . , , , .. P9~A~P. ~.., .C9!1,E,R,E.R. .. , . . , . , , ,. , . , , , . , . . , . . , . , . . , . ", defendant, are divorced from the bonds of matrimony. The court retains jurisdiction of the following claims which have been raised of record in this action for which a final order has not yet been entered; '" .N'O.N,E,... .T.HE, ,l1A.RITA.~ ,s,~~~~~f!~~~ Aq~~~f!~tj~ .Qti~~Q .-1titjl!tiI!X .~, .m~, ,J).l!IU'IjI;:, . . . .~.E.Np~,E~.T, ,T,o, .T.HE. ,/1A;~I~<\L .S.~T~~~f!~~~ .tiq~~~f!~tj~ ,Qti~~Q ,-1til!l!tiI!X .\q, . m~ I . . BOTH OF WHICH ARE ATTACHED HERETO, SHALL BE INCORPORATED HEREIN, BUT NOT MERGED, By The lJ)~ If- OLr { ^""'.o- /I . (/' ~~ Prothonotary :- .:+;. .:+;. .:.;. .:.;. .:+:- .:+;. -:.:- .:.:. -:.:- -:.;. .:+:. ~ i ~ " ~ ~ ',' " ~ ~ " ., ~ ',' ~ '.' $ ~ ,', ~ s $ ~ !~ ~ ~ ,,. ~ '.' ~ " .:' ~ $ ~ ~.' .' ~ '.~ $ s ~ ',' $ .. ~ I~ ~ ~ ~ J. I~ ).. I: i~ . ' I~ ,",' C:\OFFICE\WPWIN\WPDOCS\OOMESTIC\MSA\COMEnEn2.WPo JQhuQ'Y 9, 10000 THIS AGREEMENT, made this 9th day of January, 1998, by and between VICTORIA L, COMERER, of 6304 Salem Park Circle, Mechanicsburg, Cumberland County, Pennsylvania, 17055 (hereinafter "WIFE") and DONALD C. COMERER, of 3 Creek Road, Mechanicsburg, Cumbel'land County, Pennsylvania. 170!i5 (hereinaller "HUSBAND"); W ITN E S SETH: WHEREAS, the parties hereto were married on March 20, 1976, in Enola, Pennsylvania; and WHEREAS, there is one child under the age of eighteen years born of this marriage, namely Donald C, Comerer, Jr" date of birth June 26, 1985; and WHEREAS, difficulties have arisen between the parties and it is therefore their intention to live separate and apart for the rest of their lives and the parties are desirous of settling complete the economic and other rights and obligations between each other, including, but not limited to: the equitable distribution of the marital property; past, present and future support; alimony, alimony pendente lite; and, in general, any and all other claims and possible claims by one against the other or against their respective estates; and Page 1 of 15 C;\OFFICE\WPWIN\WPOOCS\OOMESTIC\MSA\COMEIIE 1l2.WI'O January 0, 1090 2, DIVORCE AC'rION. An action seeking the dissolution of the marriage is pending in the Cumberland County Court of Common Pleas and bears docket number 97-1795. The parties hereby agree to execute Affidavits of Consent for divorce and Waivers of Notice of Intention. to Request Entry of a Divorce Decree no later than April 15, 1998, The parties agree that the divorce will not be finalized prior to April 30, 1998, The parties acknowledge the availability of counseling and both parties have waived their right to counseling. The terms of this Agreement shall be incorporated into any divorce decree, but sholl n'ot be merged with the divorce decree, 3. SEPARATION AND NONINTERFERENCE, WIFE and HUSBAND may and shall, at all times hereafter, live separate and aport. They sholl be free from any interference, direct 01' indirect, by the other in all respects os fully as if they were unmarried, Each may, for his or her separate use or benefit, conduct, carryon and engage in any business, occupation, profession or employment which to him or her may seem advisable. WIFE and HUSBAND shall not harass, disturb or malign each other or the respective families of each other. 4, DATE OF EXECUTION, The "date of execution" 01' "execution date" of this Ab'l'eement shall be defined as the date upon which it is executed by the parties if they have each executed Page 3 of 15 C:IOFFICEIWPWIN\WPOOCSIOOMESTICIMSAICOMEnEll2,WPO January 0, '006 the Agreement on the same date. Otherwise, the "date of execution" or "execution date" of this Agreement shall be defined as the date of execution by the party last executing this Agreement, 5. MUTUAL RELEASES, Each party absolutely and unconditionally releases the other and the estate of the other from any and all rights and obligations which either may have for past, present, or future obligations, arising out of the marital relationship or otherwise, including all rights and benefits under the Pennsylvania Divorce Code of 1980, and amendments except as described herein. Each party absolutely and unconditionally releases the other and his or her heirs, executors and estate from any claims arising by virtue of the marital relationship of the parties, The above release shall be effective whether such claims arise by way of widow's or widower's rights, family exemption, or under the intestate laws, or the right to take against the spouse's wi\l, 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 Pennsylvania, any state, Commonwealth, or territory of the United States, or any other country. Except for any cause of action for divorce which either party may have or claim to have, each party gives to the other by the execution of this Ab'Teement an Page 4 of 15 C:\OFFICE\WPWIN\WPDOCSIDOMESTICIMSAICOMERER2.WI'D January 0, 1000 I: ' absolute and unconditional release from all cluims whatsoever, in law or in equity which either party now has against the other. 6. WARRANTY OF DISCLOSURE. '. Each party hereby confirms that he or she fully understands the terms, conditions and provisions hereof and believes same to he fair, just, adequate and reasonable under the existing facts and circumstances, The parties acknowledge their respective rights pursuant to the Pennsylvania Divorce Code of 1980 to obtain formal .valuations and appraisals and to engage in formal discovery, including interrogatories. The parties have determined that they will not undertake this expense and rely on the disclosures thus given. 7. OTHER DOCUMENTATION, Within ten (10) days after demand therefore, the parties will execute any and all written instruments, assignments, releases, satisfactions, deeds, notes or such other writings as may be reasonable, necessary or desirable for the property effectuation of this Agreement. 8. NO WAIVER OF DEFAULT, This Agreement shall remain in full force and effect unless terminated under the terms of this Ab'1'eement, The failure of either party to insist upon strict Page 5 of 15 C:\OFFICElWPWIN\WPOOCS\OOMESTICIMSA\COMERER2. WPO January 8, 1998 that all such property in possession of Wll~E shall be the sole and separate property of WIFE, Each of the parties does hereby specifically waive, release and renounce any further claims with respect to said items, Notwithstanding the above, Wll~E is the owner ofa 1995 Pontiac Grand Prix, HUSBAND is the owner of a 1990 Van and 1930 Model A Street Rod, HUSBAND agrees to waive his right, title and interest in the 1995 Pontiac Grand Prix, WIFE hereby agrees to waive her right, title and interest in the 1990 Van and 1930 Street Rod. 11. REAL PROPERTY, HUSBAND and WIFE acknowledge that they arc the owners of real property located at 3 Creek Road, Mechanicsbul'g, Cumberland County, PA 17055 (hereinafter the "marital home") and 33 Sample Bridge Road, Mechanicsburg, Cumberland County, PA 17055, (hereinafter the "rental property"). The parties also acknowledge that a lien exists against the marital property in the approximate amount of $50,000 to which both parties are liable to Harris Savings Bank. WIFE ab'Tees to transfer her right, title and interest in both the marital home and rental property to HUSBAND. WIFE shall execute deeds prepared by HUSBAND's counsel which will be held in escrow by WIFE's counsel until such time as the mortgage is refinanced and WIFE's name is released from the obligation, WIFE's counsel shall present the deed(s) to HUSBAND's title company for settlement, Page 7 of 15 C:IOFFICElWPWIN\WPoOCSloOM9STICIMSAICOMERER2. WPO January 6, 1006 HUSBAND agrees to refinance the marital home within sixty (GO) days of the execution of this Agreement. HUSBAND shall be solely responsible for all present, past Dr future costs and liabilities associated with or attributable to the mal'ital home and rental property, including, but not limited to, all real estate taxes, mortgage or loan payments, water, sewer, gas, electric and telephone service. At the time of refinance, HUSBAND shall pay to WIFE the sum of $50,000 payable to "Victoria Comerer and Reager & Adler P,C," Said payment shall be reflected on the HUo.l Statement which shall be provided to WIFE's counsel prior to the refinance. WIFB's payment along with an executed settlement sheet shall be provided to WIFE's couesel after the expiration of the recision period, In the eVllPt the home is not refinanced within sixty (60) days of the execution of this Agree"ent, HU~BAND and WIFE agree to sell the rental property, The parties shall list .e property with a mutually agreeable Realtor. WIFE shall receive the first $60,OO~fthe proceeds after the payment of all reasonable settlement costs and expenses, HUTSl3AND shall receive the remaining proceeds. Upon receipt of$60,OOO, WIFE shallllxCfute a mortgage satisfaction piece prepared by HUSBAND. HUSBAND shall be responsible for the filing and filing costs of said satisfaction piece. In the event the rental property proceeds are unable to pay the full $60,000, HUSBAND shall execute an additional mortgage against the marital home guaranteeing whatever additional amount is necessary to assure WIFE's receipt of a total of $60,000. Page 8 of 15 C:\oFFICr:.WPWINlWPDOCSIDOMESTICIMSA\COMERER2.WPD January O. 1000 the parent believes will allow the other to obtain u complete view of the circumstances underlying the decision to be made. The method of communication may include direct oontact or written correspondence. Each parent shall act reasonably with the other in regard to the decision, by listening to his or her viewpoint, and by making every effort to reach a decision which is agreeable to all, In every instance when a major decision is being made, each parent will make every eflill'llo act in lhe hest inleresls of the child. B. While in the child's presence, neither parent shallmuke or allow any other person to make any remarks or do anything which could be construed as derogatory or uncomplimentary to the other parent, It shall be the express duty of each parent to uphold the other parent as one whomlhe child should respect and love, Each parent therefore agrees to make every reasonable ullemptto show support for the other parent in his or her role as a caring and concerned parent. C. When emergency decisions must be made, the parent who has physical custody at the time shall be permitted to make the decision necessitated by the emergency without consulting the other in advance, The custodial parent shall also be responsible for informing the other of the emergency as soon as it is reasonably possible to do so. D. Each parent shall be entitled to receive information, including written reports, from any hospital, doctor, dentist or mental health professional treating the child, or any authority in his schoo\. Both parents may attend school Page 10 of 15 1 C:\oFFICEIWPWINIWPOOCSIOOMESTIClMSAICOMERER2.WPO Janu.'Y B, 199B 21. 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 heroin, A modification or waiver of any of the provisions of this Agreement shalI be effective only if made in writing and executed with the same formality as this Agreement, 22. CONTRACT INTERPRETATION. For purposes of contract interpretation and for the purpose in resolving any ambiguity herein, the parties agree that this Agreement was prepared jointly by the parties. IN WITNESS WHEREOF, the parties hereto have set their hands and seals of the day first above written. This Agreement is executed in duplicate, and in counterparts, WIFE and HUSBAND acknowledge the receipt of a duly executed copy hereof. \~"f-.n.... ~... _~. (';;--. J.......... ..Ji'o Victoria L, Comerer ~Ac? C fZw.,~ Donald ,Comerer Page 14 of 15 C:IOFFICElWPWINIWPOOCSIOOMESTICIMSA\COMERER AMO Janun'YO, 1096 .~~/ THIS AGREEMENT, madc this J1..[ day of ,January, 1998, by and bctwccn VICTORIA L, COMERER, of 6304 Salcm Park Circlc, Mcchanicsburg, Cumbcrland County, Pennsylvania, 17055 (hcrcinaftcr "WIFE") and DONALD C, COMERER, of 3 Creck Road, Mcchanicsburg, Cumbcl'land County, Pcnnsylvania, 17U55 (hcrcinafl.cr "HUSBAND"); WITNESSETH: , " WHEREAS, thc parties hcrcto wcrc married on March 20, 1976, in Enola, Pennsylvnnia; and ~ WHEREAS, thc partics cxecutcd a Marital Scttlemcnt Agrccmcnt datcd January ~ ;I. 1998, with thc intent to settlc complctcly thc economic and othcr rights and obligations bctwccn each othcr; and WHEREAS, thc partics dcsirc to amcnd thc Marital Scltlcmcnt Agrccmcnt by including the following provisions, Pagc 1 of 4 to pay WIFE the sum of Ten Thousand and 00/100 Dollars C.\OFFICE\WPWNIWPOOCS\OOMESTICIMS^\COMEnE II.^MO January~, 1008 NOW THEREFORE, in consideration of the covenants and promises hereinaller to be kept and performed by each party and intending to be legally bound hereby, the parties do hereby agroe as follows: .~ 1, Paragraph Eleven of the Marital Settlement Ab'Teement dated January 1 ~ 91.1998, is hereinafter reviscd to incl ude the following provision: In addition to the sums provided for under the original Marital Settlement Agreement dated January 8, 1998, HUSBAND agrees ($10,000,00) over the next two (2) years, As security for this payment, concurrently with the execution of this Agreement, HUSBAND shall execute a mortgage against the marital home in the amount ofTen Thousand and 00/100 Dollars ($10,000,00) in favor of WIFE. HUSBAND shall pay WIFE I~ive Thousand and 00/100 Dollars ($5,000.00) no later than January 1, 1999, HUSBAND shall pay WIFE an additional Five Thousand and 00/100 Dollars ($5,000.00) no later than January 1, 2000, Upon payment ofTen Thousand and 00/100 Dollars ($10,000,00) in full, WIFE agrees to execute a mortgage satisfaction piece prepared by HUSBAND within lilleen Page 2 of 4 ... CO. ;.,- , " C'.' j: ~ -.: t1.lt ') ..:, C,); ; fl:.. 1'- ~il . I. C~r. 0,' ., ; ll/. I t:i;' ('-: .lirj ,J.: .',.. ,- -.: .-. II. r.r~ ~-) Q e)\ U N ~~~! ~...~~~ ~<~<~ ffii!?~~ "Q~:>::E ~ ~ a ~ - --. ...,., ...... .-.. '-.. WI"HU'-IOU.,"'. 11""4_ IIU' OJolrM:I,O:U\unl1YOJlIUiI'lW ,.. . . . VICTORIA L. COMERER, : IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA : NO, 97-1795 CIVIL TERM : CIVIL ACTION - LAW DIVORCE Plaintiff v. DONALD C, COMERER, Defendant PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the court for entry of an appropriate divorce decree: 1. Ground for divorce: IrretrIevable breakdown under ~ 3301 (c) of the DIvorce Code, 2, Date and manner of service of complaint: The Comp'lalnt was flied on April 7 1997, and was served on Defendant via United States Postal Service, First Class, certified mall, restricted delivery on April 15, 1997, 3. (Complete either paragraph (a) or (b): (a) Date of execution of the a(fjdavit of consent required by 9 3301 (c) of the Divorce Code: by PlaIntiff April 1, 1998j by Defendant March 19, 1998. (b)(1) Date of excwtion of the affidavit re~uired b) ~ 3301(d) of the Divorce Code. , (2) Date of filing and 3ervice of the r'laintiff'3 affidavit tJpon the respondent. . 4, Related claims pending: There are no economic claims p'endlng as the dIstrIbution of all personal and rear property has been settled by agreement of the parties. 5. (Complete either (a) or (b).) (a) Date and manner of ,serylce of the notice of intention to file prllecipe to tran3mit record, II cop~ of ....hlch IS IIttllched, . (b) Date Plaintiff's Waiver of Notice in 9 3301 (c) Divorce was filed with the Prothonotary: April 2, 1998. Date Defendant's Waiver of Notice in 9 3301 (c) Divorce was filed with the Prothonotary: April 2, 1998. Respectfully Submitted, REAGER & ADLER, PC Date: April 2, 1998 RE y By: 0.66378 2331 Market Street Cam!> Hill, PA 17011-4642 Telephone No. [717] 763-1383 Attorneys (or Plaintiff C:IOFFICEIWPWINIWPDOCSIOOMESTICICOMPLAIN)COMERER.CMP Ap<114, 1997 REAGER & ADLER, PC BY: DEBRA A, DENISON, ESQUIRE Attorney 1.0. No, 66378 2331 Market Street Camp Hill, PA 17011 Telephone: (717) 763-1383 Attorneys for Plaintiff VICTORIA L. COMERER. : IN THE COURT OF COMMON PLEAS :CUMBERLANO COUNTY, PENNSYLVANIA : NO, 91]-I'19S Gc:,~'l k~ CIVIL ACTION - LAW DIVORCE Plaintiff v, DONALD C. COMERER, Defendant 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 m 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 Sround for the divorce is indignities or irretrievable breakdown of the marriage. you may request marnage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Room 101, Cumberland County Courthouse, I Courthouse Square, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM, YOU SHOULD TAKE TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, I ! Cumberland County La~er Referral Service Court Administrator South Hanover Street Carlisle. PA 17043 (717) 240-6200 r ,-. ,- (I'; co: , i;": UJ' , c..~ ; I:, . .I r ,I. G~i ; ,~' , " , L...ll I" ; ., 1'. ( .- C- lI. r-' U <.F (i ~~IJj~ ~~~~S ~~~~~ a:Za:$:f;:: w :i-... "I=' :J:t;:, ~~a~ C:\oFFICEIWPWINIWPDOCSIOOMESTICICOMPLAINICOMER ER.AMD October 2, 1997 REAGER & ADLER, PC BY: DEBRA A, DENISON. ESQUIRE Attorney 1.0. No. 66378 2331 Market Street Camp Hill, PA 17011 Telephone: (717) 763-1383 Attorneys for Plaintiff VICTORIA L, COMERER, : IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA NO, 97-1795 CIVIL TERM CIVIL ACTION - LAW DIVORCE Plaintiff v, DONALD C. COMERER, Defcndant NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to dcfcnd against thc claims sct forth in thc following pagcs, you must take prompt action. You arc warncd that if you fail to do so, the casc may procecd without you and a decrec of divorcc or annulment may be cntcred against you by the Court. A judgmcnt may also be entered against you for any other claim or rclicf rcqucstcd III these papcrs by the Plaintiff. You may lose money or property or othcr rights important to you, including custody or visitation of your children. When the ground for the divorce is indignitics or irretrievable brcakdown of the marriage, you may rcquest marnagc counseling, A list of marriagc counsclors is available in the Office of the Prothonotary, Room 101, Cumbcrland County Courthollsc, 1 Courthouse Square, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM, YOU SHOULD TAKE TillS PAPER TO YOUR LA WYER AT ONCE, IF YOU DO NOT IIA VE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TilE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, Cumbcrland County Lawyer Rcfcrral Service Court Administrator South Hanover Strcet Carlisle, PAl 7043 (717) 240-6200 I C:\oFFICEIWPWINIWPDOCSIDOMESTICICOMPLAINICOMERER .AMD October 2, 1997 Plaintiff : IN THE COURT OF COMMON PLEAS :CUMDERLAND COUNTY, PENNSYLVANIA NO, 97-1795 CIVIL TERM CIVIL ACTION - LAW DIVORCE VICTORIA L, COMERER, v, DONALD C, COMERER, Defendant AVISO PARA DEFENDER Y RECLAIMAR DERECHOS USTED IIA DlSO DEMANDANDO EN LA CORTE, Is desea defenderse de las quejas expuestas en las paginas siguientes, debar tomar accion con prontitud. Se la avisa que is no se defienee, el case purde proceder sin usted y decreto de divorcio 0 anulamiento puede ser emit ado en su contra ~or la Corte. Una decision puede tambicn ser emitida en Sll contra por caulquier otra queja 0 compensaclIon reclamados por el demandante. Usted pucde perder dinero, 0 sus propiedaees 0 otros derechos importantes para usted, Cuando la base para el divorcio es indignadades 0 rompimiento irreparable del matrimonio, usted puede solicitar consejo matrimonial. Una Iista de consejeros matrimoniales esta disponible en la oficina eel Prothonotary, en la Cumberland County Court of Common Pleas, Room 101, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania. SI USTED NO RECLAMA PENSION ALIMENTACIA, PROPIEDAD MARITAL, 1I0NORARIOS DE ABOGADO U OTROS GASTOS ANTES DE QUE EL DECRETO FINAL DE DIVORCIO 0 ANULAMIENTO SEA EMITIDO, USTED PUEDE PERDER EL DERECHO A RECLAMAR CUALQUlERA DE ELLOS. USTED DEBE LLEVAR ESTE PAPEL A UN ABOGADO DE INMEDlATO. SI NO TIENE 0 NO PUEDO PAGAR UN ABOGADO, VA Y A 0 LLAME A LA OFICINA INDICADA ABAJO PARA A VERIGUAR DONDE SE PUEDE OBTENER ASISTENCIA LEGAL, Cumberland County La~er Referral Service Court Admimstrator South Hanover Street Carlisle, PA 17043 (717) 240-6200 C:IOFFICEIWPWINIWPDOCSIDOMESTICICOMPLAINICOMERER.AMD October 2, 1997 Respectfully Submilled, REAGER & ADLER, PC Date: October 6, 1997 By: 2331 Market Street Camp Hill, P A 17011-4642 Telephone No. [717] 763-1383 Allorncys for Plaintiff 3 C:\oFFICEIWPWINIWPDOCSIOOMESTlCICOMPLAINICOMERER.CMP September 23, 1997 VERIFICATION I, Victoria L, Comerer, verify that the statements made in this Amended 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, /.' jl t1 ~~A~. '. '7nvUA- Victoria L, Comerer Date: !J~ I, /491 4 >. ", r: l.r. "" ., , . " ; n .:r 111.- , (.li' . (!;. II.... ..... '1';. - U' '" w' , , .--!l' r_ , l!..;. -I r" II ..- .." ". (T' :.) (..J 0' u N ~~~! ~I-~~~ ~o(t:-:~;;: ~i:!~ld ffi~~;f~ ,",0 :J:[; ~~a~ -- _. ~ '"", ~.-- l'IlOMIU'lO&tI."'."U."."II' DrtIW04 03A\ut'Of;'Ml.lInll n, i~ ('J t. c-.; i;:; ~; ~.j. .' lJ.l ~. ; t.H (1_ ., ,~- " .' II r C? N r:l' I ltJI. ,;<1 .Jl, C.: l":.;_ ,,- :L_ ,- ..< .,.. u. "" ~-) () r. ~ . U N ~~~~ ~I-~~~ C<t;:~:i: <U)~~id ffii5;!~ CJo:Ex6 ~~a~ -.--. -'- ~'- "."Il.'U>st.U".Ulu.".nIU ~MtO. 00,1,,.,,,..,.,01111..1."" ... (') ,>. ,..... C'..: L. " ", , I:: , I..,i .:1 ;, ( , ". . L, l' .' , ":j (.. , ' "I (~ ' I I il-'t. ., r' li,.i t'. e ~ u.. ,. .. ~ C:} :j (J' u N ~~~~ ~~~~~ <(1"~~13 ollGi ... ffiti~;fE ,,0 :I:t: ~~a~ -- _.,~ ~- _Mln.iDU.".,. C'U"41' ",,, (>>lfM)4I OOA\owl'lI'M)JlJnU"nw :>- C\J 1.i7 (~: ,.< ", IH0 ..;; CI. [., o. ': Cli'. '.. , , 0 (\j l./' I ,.j Ii: t ~ (.: 1.'- ,'- I' Jd I., "" .:"1... 1;, (Q :~, 0' cJ ~~~~ ~~~~lil ffi~~~! CJo~:cE ~~a~ -'....... ~-, -.....-- ""'"Uf' ~O"Ij""'"U"""U' OOlNllO. OJ'\wnI'PItII1II'l'11f :-- '" n; N r ..~ IJj(..' .:J , c.li' CI:. (5!" u, , <. 0' \'\1 ! L.ll. I c:\ r " j:- [t.. j tl'" ~ I... ('J :~ ) u U' U ~~~~ ~\(~ii!lil ~~~~~ ffi~i;f~ CJO Xc ;51=~ll. a:<~~ '-'" oc-. -.......- <--- _"I"'40UU""(lltI.". lS.n ~ra.oJ ~lolou/'ll"lWtlnlnll-TN >- U'l C": ". .' 1-- 'S ltJ' , <"J; . , '.l. l'- . 1.1. - i ~.l' ~), '::1 ! G" it' r .; G:I' f. "1 I. i '- '~:i " r- l... ," (.J N ~;::lii ~ ri:3w ~ ~!;(~ :; .... ~ ~ ~lJl~ it 12 ffii~;f .... ;::: ",0 :I: E ~~a~ .. . . . _MU.....O""tI.'.uu..nrsu. ClNrNO' O).I.~1YDIlJn&..,.,., . . ' C:\oFFICE\WPWINIWPOOCS\oOMESTlC'AFFIOAVIICOMER ER. SVE AprI/23, t 997 REAGER & ADLER, PC BY: DEBRA A. DENISON, ESQUIRE Attorney I.D. No. 66378 2331 Market Street Camp Hill, PA 17011 Telephone: (717)763-1383 Attorneys for Plaintiff VICTORIA L. COMERER, : IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYL VANIA NO. 97-1795 CIVIL TERM CIVIL ACTION - LAW DIVORCE Plaintiff v, DONALD C. COMERER, Defendant AFFIDA VIT OF SERVICE I, Debra A. Denison, Esquire, being duly sworn according to law, depose and state that service of the Complaint in Divorce in the above-captioned matter was served by certified mail, restricted delivery, on the Defendar.t, Donald C. Comerer at 3 Creek Road, Mechanicsburg, P A 17055 on April IS, 1997. The certified receipt is attached hereto as "Exhibit A." Date: April 23, 1997 Respectfully Submitted, REAGER & ADLER. PC '\ ( ~~',,""1S0N' ESQUIRE Attorney I.D:-No. 66378 2331 Market Street Camp Hill, P A 17011-4642 Telephone No. [717] 763-1383 Attorneys for Plaintiff By: \ C:IOFFICEIWPWINIWPDOCSIOOMESTlC'AFFIDA VIICOMERER.SVE Aprll23,11l97 x . . 1 1 C:IOFFICEIWPWINIWPDOCSIOOMESTIC'AFFI DA VIICOMER ER .SVE Apfil23, 1997 ,,~. . ...;. . il........:.,~,..lc?m.r.,~~,1~'7~~ __-'::l.~~_':'~anextra~. '... I 1':.,::;'1~/''2f<r~~V l:J V.:.. "'-':.:.. ' l,i:J~~Mwu"':,j f.:='::"lhIl1onl~lhIma1lp1oco.""'IhI,**I"","~' 'J, l, ..... ponnIL ResI11ct8d Dellvely I'.. ,,'1lIlIIlRlmRlcollllIlll_llwllomllloll1lclowu_!Il!lhIdaIJ I i ':......,. · .' Conau~ po&1rnaStar lor fee. . 1 . " to: cle Number I, Mr~ Donald C. Comere .3"Creek Road I MeChanicsburg , PA I. . '" I I, 1 4b.1lorvlco'l\'P8 x CERTIFIED 7, Date 01 Delivery 8. Addrnoeee'. Add...... (Only R req and fee II paid) J I I " ..--, 1unl .0e0InWr ,., i L _...' ._._ ____.~.. _ ~.