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HomeMy WebLinkAbout97-04058 , , "l 1t \I :J ...J. ! I I \ \ ' ~ , , \ IIJ ~ u :1 ~ ~ / / . I - . . :~ - ~ ~ ~ ..'i" At...' :~,h ,..: , '; ~ " Separation lInd Property Settlement AlII'8emeat - Roxie R. Lucaa and Frederick J. Luclla Page 2 NOW, THEREFORE. in consideration of the above recitals and the following covenants and promises mutually made and mutually to be kept, the parties heretofore. intending to be legally bound, covenant, promise and agree as follows: 1, Separation. It shall be lawful for each party at all times hereafter to live separate and apart from the other party at such place that he or she may from time to time choose or deem fit. The foregoing provision shall not be taken as an admission on the part of either party of the lawfulness of the causes leading to their living apart, 2. Interference. Each party shall be free from interference, authority and contact by the other, as fully as if he or she were single and unmarried, except as may be necessary to carry out the provisions of this Agreement. Neither party shall molest the other nor attempt to endeavor to molest the other. nor compel the other to cohabit with the other, nor in any way harass or malign the other, nor in any way interfere with the peaceful existence, separate and apart from the other. 3. Wife's Debts. Wife represents and warrants to Husband that since the separation she has not and in the future she will not contract or incur any debt or liability for which Husband or his estate might be responsible and shall indemnify and save Husband hannless '" " from any and all claims or demands made against him by reason of debts or obligations incurred by her, 4. Husband'. Debts. Husband represents and warrants to Wife that since the separation he has not and in the future he will not contract or incur any debt or liability for which Wife or her estate might be responsible and shall indemnify and save Wife hannless from any and all claims or demands made against her by reason of debts or obligations incurred by him. 5. Outstanding Joint Debts. The parties aclmowledge and agree that they have no outstanding debts and obligations incurred prior to the signing of this Agreement, except as follows: None In the event that either party contracted or incurred any debts since the date of snparation, the party who incurred said debt shall 1m msponsibln for thl1 paymnnt thnreof, ',,," ~' .'"*",,. .:.', '. ~..." ',' . 1 Separation and Property Settlement Agreement - Roxie R. Lucas and Frodorlck J, Lucas Page 3 regardless of the name in which the account may have been charged, and such party shall indemnify, defend and hold the other party harmless from any claim or demand made against that party by reason of such debt. 6. Equitable Distribution of Marital Property. The parties have attempted to distribute their marital property in a manner which conforms to the criteria set forth in !l3501 et, seq, of the Pennsylvania Divorce Code and taking into account the following considerations: the length of marriage; the fact that it Is the second marriage for Wife and the first marriage for Husband; the age, health, station, amount and sources of income, vocational skills, employability, estate, liabilities and needs of each of the parties; the contribution of each party to the education, training or increased earning power of the other party; the opportunity of each party for future acquisitions of capital assets and income; the sources of income of both parties, including but not limited to medical, retirement, insurance or other benefits; the contribution or diSSipation of each party in the acquisition, preservation. depreciation or appreciation of the marital property, including the contribution of each spouse as a homemaker; the value of the property set apart to each party; the standard of living of the parties established during the marriage; and the economic circumstances of each party at the time the division of property is to become effective. The division of existing marital property is not intended by the parties to constitute " in any way a sale or exchange of assets, and the division of being etIected without the introduction of outside funds or other property not constituting marital property. The division of property under this Agreement shall be in full satisfaction of all marital rights of the parties. A Distribution of Personal Property. The parties hereto mutually agree that they have effected a satisfactory division of the furniture, household furnishings, appliances, and other household personal property between them, and they mutually agree that each party shall from and after the date hereof be the sole and separate owner of all such tangible personal property presently in his or her possession, except as set forth in Exhibit A attached hereto, which items shall be distributed in accordance with Exhibit A. and this Agreement shall have the effect of an assigrunent or bill of sale from each party to the other for such property as may be in the individual possession 01 each of the parties hereto and as set forth in Exhibit A. ,;;~'." '., ".^" "", ~ ~.' .' ;\,:;., ;r Sepa(atlon and Property SetUement Aoreament. Roxie R. Lucas and Frederick J. Lucas Page 4 The parties hereto have divided between themselves, to their mutual satisfaction, all items of tangible and intangible marital property, Neither party shall make any claim to any such items of marital property, or of the separate personal property of either party, which are now ill the possession and/or under the control of the other, or which property will be di':ltributed in accordance with Exhibit A attached hereto, Should it become necessary, the parties each agree to sign, upon request, any titles or documents necessary to give effect to this paragraph, Property shall be deemed to be in the possession or under the control of either party if, in the case of tangible personal property, the item is physically in the possession or control of the party at the time of the signing of this Agreement and, in the case of intangible personal property, if any physical or written evidence of ownership, such as passbook, checkbook, policy or certificate of insurance or other similar writing is in the possession or control of the party. Husband and Wife shall each be deemed to be in the possession and control of their own individual pension or other employee benefit plans or retirement benefits of any nature to which either party may have a vested or contingent right or interest at the time of the signing of this Agreement, and neither will make any claim against the other for any interest in such benefits, except as stated herein. From and after the date of the signing of this Agreement, both panies shall have complete freedom of disposition as to their separate property and any property which is in their possession or control, pursuant to this Agreement, and may m6rtgage, sell, grant, convey, or otherwise encwnber or dispose of such property, whether real or personal, whether such property was acquired before, during or after marriage, and neither Husband nor Wife need join in, consent to, or acknowledge any deed, mortgage, or other instrument of the other pertaining to such disposition of property. B. Distribution of Real Estate. Both parties acknowledge that Wife has transferred to Husband by Deed all of her interest in and title to their jointly owned real estate located at R.D, #1, Box 23, Tower City, Schuylkill County, Pennsylvania in exchange for which Husband agreed to be solely responsible for the mortgage obligation, if any, as well as for the payment of all current and future taxes, insurance and utility bills relative to said real estate. Husband covonants and agrees to pay and dischalge said obligations on said premises, and agrees to indemnify Wife Se aratlon and Pro ert Settlement A ..ment - Roxie R. Lucas and Frederick J. Lucas Pa e 6 from any loss by reason of his default in the payment thereof, and agrees to save her harmless from any future liability with regard thereto, including the cost of defense and actual counsel fees incurred to defend against an action brought against her by virtue of his default. C, Cash Distribution. In consideration for the transfer of the above referenced real estate, Husband paid to Wife the sum of $4,000.00, receipt of which is hereby aClmowledged, 7. Vehicles. Notwithstanding Paragraph 6 of this Agreement, Husband shall retain possession and ownership of the 1993 Ford Festiva, 1984 Nissan Pick-up, and 1981 International Bus presently in his possession. Wife hereby transfers all of her right, title and interest in said vehicle to Husband. In consideration thereof, Husband shall assume full responsibility for payment and eventual satisfaction of any and all liens presently encumbering the vehicle. and to indemnify, defend and hold Wife harmless for the same. Wife hereby agrees to sign any title or other documents necessary to transfer ownership of said vehicle at any time, upon demand, and !unber shall indemnify Husband for any costs, including actual counsel fees. incurred by Husband to enforce this provision, Notwithstanding Paragraph 6 of this Agreement, Wife shall retain possession and ownership of the 1995 Ford Windstar presently in her possession. Husband hereby transfers all of his right, title and interest in said vehicle to Wife, In consideration thereof, Wife shall ., assume full responsibility for payment and eventual satisfaction of any and all liens presently encumbering the vehicle, and to indemnify, defend and hold Husband harmless for the same. Husband hereby agrees to sign any title or other documents necessary to transfar ownership of said vehicle at any time, upon demand, and !unber shall indemnify Wife for any costs, including actual counsel fees, incurred by Wife to enforce this provision, 8, Alimony. Both parties aclmowledge and agree that the provisions of this Agreement providing for equitable distribution of marital property are fair, adequate and satisfactory to them. and are accepted by them in lieu of and in full and final settlement ana satisfaction of any claims or demands that either may now or hereafter have against the other for support, maintenance or alimony. Husband and Wife further, voluntarily and intelligently, waive and relinquish any right to seek from the other any payment for support or alimony. Each pany shall indemnity, defend and hold the other hannless against any future action for '" .~ :~~l.:. t . 'j " Separation and Property Settlement AgrHment - Roxie R. Lucas and Frederick J. Lucas Page 6 either support or alimony brought by or on behalf of tho othor, such indemnity to include the actual cOWlsol fees of the defendant in any such future action, 9. Bank Accounts. Husband shall maintain possession and ownership of all fWlds in the foregoing accoWlts: (A) Members First Federal Credit Union, AccoWlt No, 36855 (checking, savings and Visa) (B) Community Banks Checking AccoWlt, No, 17048-12709 (C) Community Savings AccoWlt, No. 17048-12720 Wife shall rotain possession and ownership of all of all fWlds in the foregoing accoWlts: (A) Members First Federal Credit Union. ACCOWlt No. 1210093 (checking and savings) (B) Mid-Penn Checking AccoWlt No. 4019220 (C) Mid-Penn Savings AccoWlt No. 4020549 (D) All eight existing U.S. Savings Bonds 10. Retirement Accounts. Husband is the owner of certain retirement benefits he is entitled to pursuant to his employment with the Federal Govemment - Defense Distribution ~ Center. The parties agree that Wife shall be entitled to a percentage ot'both his retirement through the Federal Employees Retirement System and his TIuift Savings Plan as of the date of the parties separation (April 1997), and Wife shall receive her interest pursuant to appropriate Coun Orders to be in the form to be approved by the Coun and Husband's employer, copies of which are attached hereto as Exhibits "B" and "C", 11. Allmony Pendente Lite, Counsel Fees and Expenses. Husband and Wife acknowledge and agree that the provisions of this Agreement providing for the equitable distribution of marital property of the parties is fair, adequate and satisfactory to them. Both parties shall accept the provisions set forth in this Agreement in lieu of and in full and final settlement and satisfaction of all claims and demands that either may now or hereafter have against the other for alimony pendente lite. coWlsel fees or expenses, or any other provision for their support and maintonanco boloro, during and aftor tho commencoment of any Separation and Property SetUement Agreement - Roxie R Lucas and Frederick J, Lucas Page 7 proceedings for divorce or annulment between the parties, Each party shall be responsible for his or her own cOWlSel fees, and each agrees to indemnify, defend and save the other harmless from any action conunenced against the other for alimony pendente lite, cOWlSel fees and/or expenses. 12, Divorce. A Complaint in Divorce has been filed to No, 1997-04058 in the Court of Conunon Pleas of Cumberland County, PelUlSylvania. and either party shall be free to proceed without further delay to secure the divorce. Both parties shall sign an Affidavit evidencing their consent to the divorce, pursuant to !i3301(c) of the Divorce Code. In the event, for whatever reason, either party fails or refuses to execute such affidavit upon the other party's timely request, that party shall indemnify, defend and hold the other harmless from any and all additional expenses, including actual counsel fees resulting from any action brought to compel the refusing party to consent. Each party hereby agrees that a legal or equitable action may be brought to compel him or her to execute a Consent form and that, absent some breach of this Agreement by the proceeding party, there shall be no defense to such action assened. 13. Time of Distribution. The assets and interests to be transferred under and pursuant to this Agreement shall be conveyed and transferred to the respective parties immediately upon the execution of this Agreement. All spousal suppon and other such .' obligations, including alimony, shall immediately terminate, The partieS shall cooperate by executing whatever documents are necessary to effectuate a divorce under !i3301(c) or !i3301(d) of the PelUlSylvania Divorce Code, and this Agreement to cooperate shall be enforceable by an assumpsit action for specific performance. However, upon refusal to consent, all distributed property shall be returned to the party originally in possession, until the time of final Decree. 14. 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, indemnity (including actual legal fees) and discharge the other of and from all causes of action, claims, rights, or demands, whatsoever in law or equity, including equitable distribution, spousal suppon, alimony. counsel foos, alimony pendente lite, and expenses which either of the parties against the other Separation and Property Settlement Agreement. Roxie R. Lucas and Frederick J. Lucas Page 8 ever had, now has, or may have in the future under the Pennsylvania Divorce Code, as amended, or under any other statutory or common law. except any and all causes of action for divorce and all causes of action for breach of any provisions of this Agreement, Each party also waives his or her right to request marital counseling, pursuant to !l3302 of the Divorce Code. 15, Waivers of Claims Against Estates. 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 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 in intestacy, right to take against the Will of the other, and right to act as administrator or executor of the other's estate, and any right existing now or in the future under the Pennsylvania Divorce Code, as amended from time to time, and each will, at the request of the other, execute. aclmowledge 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. 16. Rights on Execution. Immediately upon the execution of this Agreement, the rights of each party against the other, despite their continuing marital status, shall terminate ,- .' and be as if they were never married. 17, Breach. In the event of breach of any of the terms of this Agreement, the nOnbreaching party shall be paid, as part of any award or judgment against the breaching party, all costs, including actual coWlSel fees paid to his or her attorney. 18, Incorporation In Final Divorce. The terms of this Agreement shall be incorporated but shall not merge in the final divorce decree between the parties. TIlls Agreement shall survive in its entirety resolving the spousal support, alimony, property and other interests and rights of the parties under and pursuant to the Divorce Code of the Commonwealth of Pennsylvania. TIlls Agreement may be enforced independently of any support order, divorce decree or judgment and its terms shall take precedence over same. remaining the primary obligation of each party. This Agreement shall remain in full force and '1tfecl reuardless of any change in tho mantal status 01 the partles. It is wallanted, Separation and Property Settlement Agreement. Roxie R. Lucas and Frodorick J. Lucas Page 9 covenanted and represented by Husband and Wife. each to the other, that this Agreement is lawful and enforceable and this warranty, covenant and representation is made for the specific purpose of inducing the parties to execute the Agreement. 19. 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 reasonably required to give full force and effect to the provisions of this Agreement. 20. SeparablUty. In case any provision of this Agreement should be held to be contrary to, or invalid under, the law of any country, state or other jurisdiction, such illegality and invalidity shall not in any way affect the other provisions hereof, all of which shall continue, nevertheless, in full force and effect, and each paragraph herein shall be deemed to be a separate and undisputed covenant and agreement. 21. Entire Agreement. This Agreement contains the entire understanding of the parties and there are no representations, warranties, covenants and undertakings other than those expressly set forth herein. 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 which have been taken into consideration by the parties. .. .. Both parties hereby accept the provisions of this Agreement with respect to the 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 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 each voluntarily and intelligently waive and relinquish any right to seek a Court ordered detennination and distribution of marital property, but nothing herein contained shall constitute a waiver by either party of any rights to seek the relief of any court for the purpose of enforcing the provisions of this Agreement. 22. Modlflcation and Waiver. A 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. TIle failure of either party to insist upon strict performance of the '.' Se aratlon and Pro e Settlement A reemeat - Roxlo R. Lucas and Fredorick J. Lucas Pa 0 10 provisions of this Agreement shall not be construed as a waiver of any subsequent default of the same or similar nature, 23. Intent. It is the intent of the parties by this Agreement to fully and finally foreclose any resort to the Courts for relief on the basis of any statute or case law presently existing or which may exist at some time in the future within the Commonwealth of Pennsylvania, including but not limited to equitable distribution, alimony and other relief under the Pennsylvania Divorce Code, as amended, TIlis Agreement has been drafted and accepted on the basis that such resort would constitute a breach under this Agreement, entitling the nOnbreaching party to reimbursement for actual counsel fees, Other than as provided by the terms of this instrument, it is intended that the Court shall treat the parties as if they had never entered into a marital relationship. TIlis Agreement shall be interpreted and governed by the laws of the Commonwealth of Pennsylvania and, where such law is inconsistent, the terms of this instrument shall govern. 24. Voluntary Execution. The provisions of this Agreement and their legal effect have been fully explained to the parties by their respective counsel. and each party aCknOWledges that the Agreement is fair and equitable, that it is being entered into voluntarily, with full knowledge of the assets of both parties, and that it is not the result of any duress or undue influence, The parties aclmowledge that they have been furnished with all ~ information relating to the financial affairs of the other which has been requested by each of them or by their respective counsel. 25, Descriptive Headings. The descriptive headings used herein are for convenience only, They shall have no effect whatsoever in detennining the rights or obligations of the parties. 26. Agreement Binding on Heirs. TIlls Agreement shall be binding and shall inure to the benefit of the parties hereto, and their respective heirs, executors, administrators, successors and assigns. 27. Reconciliation. Notwithstanding a reconciliation between the parties, this Agreement shall continue to remain in full force and effcct absent a writing signed by the parties stating that this Agreement is null and void. l' . .....< ',", . '':':'t' ".... eI!l'" I.~.:'J -" ".-' r ,~:::'i..;:. .. . .,......~: , EXlIlDlT "A' Property of Roxie B, Lucas yard stick Lane chest bl ue small file cabinet micro, stand love seat floor lamp hassock phone end table 3 legged end table wall phone chair dark dresser blue flower pot small tent camp stove bow bike deer clock blue sleeping bag wood goose radio 3 dyno boxes 2 jugs barrel 4 lawn chairs butter chum hand gun door knocker encyclopedias 2 white dictionaries old Bible cork board small safe and keys staple gun toaster tools lint shaver sewing machine large glass vase wood bird VCR TV Van 2 kids life vests 2 TV trays director's chair ']J3 Christmas ornaments Y. dishes ~pans ~ silverware large Christmas tree small Christmas tree 8 savings bonds all Disney tapes .. .. .. '. '. ~,." ""'......"...';~..I'i....'~.,.,.,..l-..". -,:-',.....\~.'-.4.4 .j'~'...-,:J.~+~' . :~~Ai.~ ",',. ,- .+,. .,.J"...~7;. /~.!'51r:},..,~;.,::~~/t't\~:.}y~. /' . I ';";:'l..~' ,.:':'~"f';" . . ,,".,).'.-'-~" "',~., ',!'I_,~~ ROXIE R. LUCAS. Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA va, : NO. 1997-04058 FREDERICK J. LUCAS. Defendant : CML ACTION-LAW : IN DIVORCE RETIREMENT BENEFITS COURT ORDER FREDERICK J. LUCAS, (hereinafter "Employee") SS # 162-42.3645, RD#l, Box 23D, Tower City, PA, 17980, ~ l ~ ~ l is a participant in the Thrift Savings Plan under the Federal Employee's Retirement System Act of 1986. ROXIE R.LUCAS, (hereinafter "Former Spouse"). SS# 192-40-1968, 105 E. Allen Street. Mechanicsburg, P A 17055 is entitled to a share of Employee's Thrift Savings Plan account. Former Spouse is hereby awarded the sum of Twelve Thousand" Five Hundred ($12.500.00) Dollars from the Thrift Savings Plan account of Employee. Former Spouse's share may be transferred directly to an Individual Retirement Arrangement (IRA) or other eligible retirement plan. By the Court Date: I~JN6vJ~ t:xhlblt "e" '~. ~"( r... r ..,.. ., .01' J':' I. ;: ~r.. - , , " , I{).JJ.'M 1lf1w. ~ ~ i ~g 0 ~ .... '"" o.J>O Ill: l'o'" 0 :z:~ l'o 0'" ~ -l:I ~l'o .... .... '" o . .... ~~ ,""Ill: ~ ~~~~ ... ....... ... tili! . c: ::>c: "'... o.Ju :Z:O 841 ~~ .... ... f-< O:Z: . II '" j ~~,S ;]l'o ..,"" 8 ...f:j t1 t . S "'< '" . .... ~ ..."'''' . gj :=w.....,.J ... :- '" f-<'" .... .... iii .... B .> ~ t; :z: 0.... c: .... :z:u '" . . . . . . . ".. ~: f -; r .-:~ " .- .' t {, OJd'~~ llok ~ < .... ",:ij t ~ ~~ ::> ~ 0 ...'" u z~ '" ~ O"-l E-< ~... .... . l<o ~ 0 . .... "'... ~..: u~ .... <c:: 003 ... U CO "-l"-l [:; ~j .... ::>'0 "":il '" c:: ..l c:: 0"" ~';,1 .. E-<O 1 E-<UOZ ..... Z ..: 0 :3;;: .., .. "-l ::>~'''''''-l c ~ o t)u !j i~ U ..... ..: . "'<0 ..: .. .... .... t&J~0\ > > ..: tl jS"'-3_...JH "-l "-l "" ....c .... c l>l S .> >< "-l Z OHZ 0 . .. ..... r--. /- ..:1 i ,. j LoJ{' r~ - II -".-' :. . ,,- " ,-- ) J ( q ~:- In ! L:!t c: '. d l f ;J.. I CoJ I' tr1 "i L' u' U ~ ... ~~ ~ ~ ~>= ,,"en Z;~ ..: ... OlU t; ~ 2Q. ... . ..: o . ... ~i tIl ht ~E ::. ... lUCj ... o::>aoj . e ::>-a 6~ ~~ <ole 0"" .. ~o f-'UOZ; U'" .... l ~!<3g ::>"" ..,.. lU ,.J tjt:l o · tl g U ... . . "'< ..: .. .... ~ !illU~,.J :- ~ "" lU 0 f-'IQ ... ... ... ~ .> I< ~ Z; 0'" ~ .... Z;U . . . . . \ .. 5. Proposed Orders are provided for the Court. Respectfully submitted, .. PURCELL, KRUG & HALLER ", ") t, " BY "-----, . JoM,iS:,,~ 1.0/#29955 ,)7'19 North Front Street Harrisburg. P A 17102 717-234-4178 ROXIE R. LUCAS, Plaintiff : IN TIlE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. FREDERICK J. LUCAS, Defendant : NO. 1997-04058 : CIVIL ACTlON.LAW : IN DIVORCE PRAECIPE TO TRANSMIT RECORD THE PROTHONOTARY: Transmit the record. together with the following information, to the Coun for entry ofa Divorce Decree: I. Ground for divorce: Irretrievable breakdown under Section (X) 3301(c) oflhe Divorce Code. 2. Date and manner of service of the Complaint: Certified Mail on August I. 1997 3. (Complete either paragraphs (a) or (b). (a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff: Dtcembrr 7. 1998 by Defendant: Dtcember 4. 1998 (b) (1) Date of execution of the Plaintiffs Affidavit required by Section 330I(d) of the Divorce Code: (2) Date of service of the Plaintiffs Affidavit upon the Defendant 4. Related claims pending: No tconomic claims han bten raistd. 5. (a) Date and manner of service of the nOlice of intention to file Praecipe to transmit rtcord.s copy of which is attached: (b) Date ofPlaintitfs Waiver of NOlice in HOI(c) Divorce was fik-d with Prothonotary: Filtd contemporantously hel'twith Date of Defendant's Wai,'er of Notice in 3301(c) Divorce wasliled with the Prothonotary Filtd contemporantously hel'tw'ilh ....J (, ..1. .' -:-J. ..... · JOliN W.'Pll~L:~R ESO:==: -.:;:-... .a >- ("oJ >- i--.J I.': Lr. ,.. Ja n\J 0-.- ~ ;: '" . Q V>- ~ 0:) ur. f)" 8a 1'- " l' c." I ' <" ~ " I.') ( , 'r) '1.) . I.. '- f'.; \'- ~ ~ L_ 'C>)--- ~ :..; , .J. " :"l V r- ~ ~ ri.. <.r U .I < .... :z: ~ E~ .... ... ...l>= .... c lal ...'" ... <C U :z:~ ... "" c.: ~ c c g . ~ ~ , 0'" ... .. . ~": <C .... .... 5 .... . II Cl ~ ~: ... "'Cl ~ ~ . ~~ cj :z: . ~ .... o . ~ . - . . :3 ~ 7 . '" t . . 0 I cj )' ;; f-oU :z: . .... . c.: 0 :3 .., :s ~ 8!iE .... f-o ~ ~ Uj U . . < c.: .. .... 0 ~ ",c.: :> Ci U i::::l ...l w .... .... ~ 8 .> ~ z 0.... .... :Z:u . :=.~~=-t~,l~-':'~~~~\'. . )0- co )- Ct:; ...:; - ~..;. , , ~: - "J f) -' I :~ '.J; ~. , ~.r) ..) .~ '-' , .:~.. t;!: C -It,] ., I. ~J{1. C. , It C:"j -' C C, <-> i;: <:u ~ ~- - I-- lU~--' ~ t.) ~ -"- . I.- cj, . l 1.:) , . c, , l1.;- 5.. ...1 C' ..: ~ u: -. ';.'[4 I. , .'fl.. . ~ C) c: -~) "" ~ ROXIE R, LUCAS, Plaintiff IN TIlE COURT OF COMMON PLEAS CUMBERLAND COUNTY , PENNSYLVANIA VS. NO, 97 - 04058 CIVIL TERM FREDERICK J, LUCAS, Defendant CIVIL ACTION-LAW IN DIVORCE AFFlDA VIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA: ) ss; COUNTY OF DAUPHIN I, Carol Masich, secretary to John W. Purcell, Jr.. Attorney for the Plaintiff in the above action. hereby swear and affirm thaI on the 28th day of July. 1991. I sent, by ccnitied mail. return receipt requested. deliver to addressee only. a cenilied copy of the Complaint in Divorce, containing Notice to Defend and Claim RighlS to Frederick J. Lucas, the Defendant in the above action. The return receipt, duly signed by the Defendant is attached hereto and made a pan hereof as Exhibit . A . , , " .:, f I, \ .....".'... ,"I ~_-4 . Carol Masich Secretary to John W, Purcell, Jr. Sworn and subscribed to before me this 'I ~ay lIOTARIAI. WI. BONITA ll0MllARD1, ~ PuIllIc hty'='L~~,,"t8a7 . . . . ... I .~~ '_2101_ _ 18IlOw\III to rlClliw the .~ _ 3. 4.. onl4b. foIlowlng seMell (for III 1.::::...-onl_OII..._oI..._...............um... 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