HomeMy WebLinkAbout97-05135
'"
..,
a
C!>
I;)
.,
C)
~
~
{
\.
~
.....
.
..
.:;)
..
~
'0
I't)
-
I.;
~
a-.
.
~
"
s
$
~
M
"
~
"
M
"
~
.
*.*-~~*.**~*.~**~..~.~~..~,}.~.~~*.~*.~*.~~~
~ ----.~,-,-.. --.-----,--- ..----,..,..-,... .',..... ,.., '.',... ',. ...............'v'.'IM
~ l~
~ IN THE COURT OF COMMON PLEAS ~
~l ~
$ OF CUMBERLAND COUNTY ~
r~
:,
STATE OF ~~ PENNA.
~
~
"
w
"
$
$
No, ,9.7,-::51.35,.., """"........, 19
.~
~
8
~
.,
Vl'I'''IlH
Christi Ann Goss
Defendan t
~
"
"
','
,"
~
~
"
DECREE IN
DIVORCE
.~
~
~
!!I
..;
$
~
liI
~
"
~
~
$
AND NOW, ' , , , , " , -1""'~ . . , /'~,~. " 19, ,~~, '. it is ordered and
decreed that""..", J.~nr,ey' .'f.. .<lo(l~,..",.,.,.""""".. plaintiff,
and"""..."",..., ,Cbrlsti. Ann, G.oss"",..""""",.. 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;
.~?~.~'. , ~~,~ ,~~.o.I!e:~~Y, .~~~,q~~:~.n.~ . Mr:G~D,i'!,f\ t, \!){.f1Gl,I!;.e.d .Se,ptember, 16,
,~~?~ ,~~~..~~ ~,a.~h~d, ,~~r~,t,~ . ~~,a.~ ~, ~,c. . ~~~,~~{l!,;r:',~~\l~, All ~9, .~l)'il. .D.hor,ce
Decree.
:i:
!="'
D~ye~~Il;?IL
AlIcst'YW<<;i ..,:J .,y-';:f- /1~...:-?il,7
~1~~1l~ r ~ W:.
;... f/ . Prothonotary
..
~
8
~
~...;-:;.;.:..;;,- :>>::-:i, -It:
~
.:.;. .:.:. .:.:. .;6:- -:.;. .:.:. -:.:. .:.:. .:.:. .~.:'
$
~
~
~
~
"
~
.~
:::
~
~
~
~
f~
$
~
8
~
~.
:,
~
.,
~
.,
~
~
$
~
"
$
~
"
\~
, '
)~
!'~
~
I'"
I~
J.
*
'~
~
)~
PROPERTY SETTLEMENT AGREEMENT
THIS AGREEMENT mad~ and entered into this
~{C.I"dx.? 1997, by and between CHRISTI ANN GOSS of the County
/6tiJ
day of
of Cumberland, Commonwealth of Pennsylvania (hereinafter referred
to as "Wife"),
a
n
d
JEFFREY THOMAS GOSS of the county of Cumberland, Commonwealth of
Pennsylvania (hereinafter referred to as "Husband").
WITNESSETH:
WHEREAS, the parties were married on December 30, 1984 in
Cumberland County, Pennsylvania; and
WHEREAS, certain differences have arisen between the parties
and as a consequence thereof, they have chosen to live separate and
apart; and
WHEREAS, the Husband and Wife desire to settle and determine
matters of support, property settlement, and related items, and
also other matters that are more fully set forth in the within
Agreement.
NOW THEREFORE, in consideration of the promises, mutual
covenants, and agreements hereinafter set forth, the parties hereto
covenant, promise and agree with one another as follows:
1. Husband relinquishes his inchoate intestate rights in and
to the estate of the wife and the wife on her part relinquishes her
inchoate intestate rights in and to the estate of her Husband, and
each of the parties hereto by these presents, for himself and
herself, his or her heirs, executors, administrators or assigns,
does remise, release, quitclaim and forever discharge the other
party hereto, his or her heirs, executors, administrators or
assigns, of any and all claims or demands, damages, actions, be
they civil or criminal, causes of action, or suits at law or in
equity, of whatever kind of nature for or because or any matter or
thing done, committed or suffered to be done by said other party
prior to and including the date thereof, except that this release
shall in no way affect any cause of action in absolute divorce
which the Wife or Husband may contemplate against each other, nor
shall this complete and final release in any way mitigate against
either of the parties hereto filing suit against the other in
equity or at law enforce any right or covenant incorporated in this
Agreement. Each of the parties further renounces and relinquishes
any and all claims and rights that he or she may have or hereafter
acquire to act as executor or administrator of the other party's
estate, unless such party shall specifically designate otherwise.
2. It shall be lawful for the Husband and the Wife at all
times hereafter live separate and apart from each other and to
reside from time to time at such place or places as they deem fit,
free from all restraint or interference, either direct or indirect,
by each other. Neither party shall molest the other or compel the
2
other to cohabit, dwell with, or support the other party by any
legal proceeding.
3. Both parties waive and relinquish any claim for, or right
to, or interest in any Order of alimony, alimony pendente lite,
spousal support, or the like, from the other party. This
provision, for the full and complete waiver of alimony, alimony
pendente lite, spousal support or similar payment, is not
modifiable by any Court, even if there should be a change in
circumstances for the parties.
4. It is noted that Husband is the record owner of certain
real estate known and identified as 736 Hummel Avenue, Lemoyne,
Pennsylvania. said property has served as the marital residence,
The property was purchased by Husband prior to the date of marriage
and he has remained the sole owner of record of the property. Wife
agrees to relinquish any and all interest to the property,
including any appreciation thereon during the time of marriage. It
is noted that Bellco Federal Credit union holds a mortgage on the
property in the amount of approximately $15,049.00. Husband agrees
to be solely responsible for the payment of the mortgage.
5. Wife agrees to waive and relinquish a"lY and all right to,
claim against, or interest in Husband's Conrail pension/retirement
plan.
6. Husband agrees to wai ve and relinquish any and all right
to, claim against, or interest in Wife's pension/retirement plan
through Hecht's.
7. It is noted that Wife is the owner of a business known as
3
the Susquehanna Spice Company. Husband does hereby waive and
relinquish any and all right to, claim against, or interest in the
Susquehanna Spice Company. Wife, however, agrees to be responsible
for and pay any and all debt associated with the ownership and
operation of the Susquehanna Spice Company. Wife agrees to hold
Husband harmless for any such debt. It is noted that Wife has,
prior to the execution of this Agree~ent, received all assets and
inventory of the Susquehanna Spice Company, including a van and
inventory valued at approximately $3,000.00.
8. Each party does waive and relinquish any and all right
to, claim against, or interest in the bank accounts of the other.
9. Each party shall receive their own personal effects,
which are and shall be considered to be the sole and exclusive
property of such party. It is specifically noted that this
includes their clothing, jewelry, and other purely personal
effects. It is specifically noted that Wife has, prior to the
execution of this Agreement, retrieved all items of personalty from
the marl tal residence that she wished to obtain. Husband is to
receive the remaining personalty in the marital residence.
10. Each of the parties hereto covenants and agrees that they
have not or will not at any time in the future incur or contract
any debt, charge or liability whatsoever for which either of them,
their legal representatives, or their property or their estate may
become liable, other than those set forth in this Agreement; and
each of them further covenants at all times to keep the other free,
harmless and indemnified of and from all debts, charges and
4
11a0111C1es herearCer contracted by them.
11. The parties acknowledged that no mad tal debt exists.
Each party shall be responsible for, and indemnify and hold the
other harmless, for any other debt that he or she has individually
incurred prior to and during the time of separation.
12. It is acknowledged that Husband has received independent
legal advice from his counsel, Gregory J. Katshir, Esquire and Wife
has chosen not to obtain 0ounsel.
13. Each party acknowledges that he or she fully understands
the facts and accepts that this Agreement is, under the
circumstances, fair and equitable, and that it is being entered
into freely and voluntarily and that the execution of this
Agreement is not the result of any duress or undue influence and
that it is not the result of any collusion or improper or illegal
agreement or agreements.
14. The parties agree that if he/she were to file for
Bankruptcy under any section of the Bankruptcy code, he/she must
notify the opposing party of such.
15. The parties acknowledge that a Divorce Complaint will
been processed by the Husband. The parties agree to share equally
in the cost of the filing fee for the Divorce Complaint. It is
acknowledged that the Husband will file a Divorce Complaint setting
forth a count for a divorce based upon irretrievable breakdown. No
other counts will be set forth in this Divorce Complaint. The Wife
will execute an appropriate Acceptance of Service when presented
with the Divorce Complaint. No responsive pleading shall be
5
required by the Wife. The parties specifically acknowledge their
understanding t~at Pennsylvania law speaks of a waiver of claims
for alimony, counsel fees, equitable distribution and other
matters, in the event that such a claim is not made prior to the
entry of the final divorce decree. The Husband will not present
any such claim in conjunction with his Divorce Complaint, and the
Wife shall not file any form of responsive pleading making a demand
for the same. However, this shall not act in any manner to serve
as a waiver of such claims in the event that the parties do not
proceed under the terms and conditions of this Agreement, and/or if
further litigation is necessary.
'lhe parties shall promptly execute ani file Affidavits
of Consent, after the expiration of the ninety (90) day waiting
period required by Pennsylvania law. Gregory J. Katshir, Esquire
shall provide the parties with these Affidavits of Consent, and
shall promptly file them so as to have a Divorce Decree issued.
16. The parties agree and acknowledge that they have reached
a fair distribution of property. That each party has received
their share of any and all marital estate matters, unless otherwise
noted in this Agreement. The parties again acknowledge that they
will retain full ownership of any items in their possession, and
expressly waive and relinquish any claim against any of the
personalty, tangible assets, intangible assets, or any other
matter, of the other party, unless otherwise noted in this
Agreement.
17. The parties specifically acknowledge that the settlement
Ii
arranged herein is an equitable distribution of the property of
the parties, and each party waives distribution of marital property
by a Court.
18. The parties expressly waive and relinquish any right to
or claim for any entitlement provided by law and not expressly
provided for herein. It is acknowledged by the parties that the
receipt of those benefits and distributions set forth in this
Agreement are in full satisfaction of or any entitlement provided
for by law.
19. The parties acknowledge that they have made, to each
other, a full and complete disclosure of all matters related to the
assets and/or liabilities of the marital estate, and that they
waive any specific listing or documentation thereof, for the
purposes of this Agreement.
20. This Agreement constitutes the entire understanding of
the parties. There are no representations or warranties other than
those expressly herein set forth.
21. The parties agree that all questions pertaining to the
effect and validity of this Agreement, and the administration of
its provisions, shall be governed by the laws of the Commonwealth
of Pennsylvania. The parties agree that any further action to be
brought for the enforcement of this Agreement shall be brought in
the Courts of Cumberland County, Pennsylvania.
22. It either party defaults in the due performance of any of
the terms, conditions and/or covenants of this Agreement on his or
her part to be performed, the other party shall have the right to
7
sue for specific performance, damages for such breach, or seek such
other remedies or relief as may be available to him or her and the
party breaching the Agreement shall be responsible for payment of
any attorney's fees, costs and expenses incurred by the other party
in enforcing his or her rights under this Agreement.
23. If any term, condition, clause or provision of this
Agreement shall be determined to be void or invalid at law or for
any other reason, then only that term, condition, clause or
provision shall be stricken from this Agreement as is deemed to be
void or invalid at law, and in all other respects this Agreement
shall remain in full force and effect.
24. This Property Settlement Agreement shall be incorporated
into the Divorce Decree to be issued in this matter in the Court of
Common Pleas of Cumberland County, Pennsylvania.
25. This Agreement shall maintain its independent vitality,
and shall survive any incorporation, by reference or otherwise,
with separate Order of Court.
WITNESS WHEREOF, the parties hereto have hereunto set their
hands and seals the day and year aforesaid intending to be legally
bound hereby,
WITNES~~3/~AL/
ac;f{ It ~
Christi A. GOss
~J~uq."p"'-AJ.--.L.-7#7.' 'j-;'~
{/I J f Y , Goss
8
~, VI f:
~.~ <"-
., N ,') ,'r
tj~; , -
'. ..
u.. , '"-
II. . ,,'
C(i ..
\D :,. ,.Ii'
8',., I I;'"
.,.. ~
;::'-."11 -, , ,~ "1
* 1.15..-
u...:i: .-
I- -, .
'.
t:> co :.J
en U
, .
.
:>- 0' f.::
fy4
"'-i! <=>
. - " ,~
llle:, - ,:':i.-r
f ....,. '~.J
I'" "..
!...'! i:~ ',...1'",>
'.-. ",
@' ':}
_ r.: ',.
1.0 ~,'IY)
I :":!;;i
Ci.:l:i :;..:
F "'" ;.j~l)
-, .u.
"- >
0 IY) :::;
0' U
-,
-
,'.
1,\
"',"
I' GREGORY J. KATSHIR '
Al10rney at Law
900 Market Street
Lemoyne, Pennsylvania 17043
(717) 763,6133, Fax (717) 763.9425
.'
"
" I
.~' .~
"
JEFFREY T. GOSS
Plaintiff,
) IN THE COURT OF COMMON PLEAS OF
) CUMBERLAND COUNTY, PENNSYLVANIA
)
) 97-5135 CIVIL TERM
)
)
) CIVIL ACTION - LAW
)
)
) IN DIVORCE
vs.
CHRISTI ANN GOSS
Defendant.
PRAECIPE TO TRANSMIT RECORD UNDER SECTION 3301(c)
OF THE DIVORCE CODE
TO THE PROTHONOTARY:
Kindly transmit the record and the following information
for entry of a Divorce Decree.
1. Ground for divorce: Irretrievable breakdown under section
3301(c) of the Divorce Code.
2. Date and manner of service of Complaint: Complaint
accepted by Defendant on September 25, 1997. An Acceptance of
Service is filed and is of record.
3. Date Affidavit of Consent under section 3301(c) of the
Divorce Code signed:
By Plaintiff: December 30, 1997
By Defendant: December 30, 1997
4. Date of execution of Defendant I s Waiver of Notice of
Intent to Request Entry of Divorce Decree: December 30, 1997.
5. Related claims pending: All matters have been resolved
by way of the Property Settlement Agreement executed by the
parties.
. Katshir, Esquire
for Plaintiff
I'
t
"R c-
o-
~ ~ f':: 0 .9 ~
c-6
g K .,. LO ~
~~:) Q ':,J... -
{-' ;. .
.!..(; :t~ 1. .~.. ,I ~ 1:J '#
l.i ...; ?i~
~'\' N ~ c::L..
'j-oI. N 1','
E~" 0.. ."..
.t;"tJ 19
~_l.. lu .:'u...
v; ,~
(; r- ;,J
0' tJ
" .. .
"
'.\
"
'. .' .
. ,.. ','
I' GREGORY J. KATSHIR .'
h
Attornoy al Law
900 Markol Slroot
Lemoyne, Pennsylvania 17043
(717) 763,6133. Fax (717) 763.9425
".
JEFFREY T. GOSS
Plaintiff
vs.
) IN THE COURT OF COMMON PLEAS OF
) CUMBERLAND COUNTY, PENNSYLVANIA
)
)
) CIVIL ACTION - LAW
)
) NO.q'l- 5135
)
) IN DIVORCE
CHRISTI ANN GOSS
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 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 di vorce
irretrievable breakdown of the marriage, you
counseling. A list of marriage counselors
Office of the Prothonotary at:
Office of the prothonotary
Cumberland County Court House
Carlisle, Pa1nsylvania 17103
is indigni ties or
may request marriage
is available in the
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 HAY 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 HELP:
Court Administrator, Fourth Floor
Cumberland County Court House
Carlisle, Pennsylvania 17103
(717) 240-6200
.
JEFFREY T. GOSS
Plaintiff, l IN THE COURT OF COMMON PLEAS OF
l CUMBERLAND COUNTY, PENNSYLVANIA
vs. l
l
l CIVIL ACTION - LAW
CHRISTI ANN GOSS )
Defendant. l NO. '17, !fUr L'wi.{ T; .....
l
l IN DIVORCE
COMPLAINT IN DIVORCE
AND NOW comes Plaintiff, Jeffrey T. Goss, by his attorney
Gregory J. Katshir, Esquire with the following Complaint and prayer
for relief wherein it is set forth as follows:
COUNT I - DIVORCE
1. Your Plaintiff is Jeffrey T. Goss, an adult individual
residing at 736 Hummel Avenu~, Lemoyne, Cumberland County,
Pennsylvania.
2. The Defendant is Christi Ann Goss, an adult individual
residing at 333 Park Avenue, Hersh9Y, Dauphin County, Pennsylvania.
3. Defendant is a national of the United states of America.
4. Plaintiff and Defendant I~ere married on December 30,
1984, in Cumberland County, Pennsylvania.
5. Both parties have been bona fide residents of the
Commonwealth of Pennsylvania for at least six months prior to the
VERIFICATION OF KNOWLEDGE. INFORMA~ION AND BELIEF
I verify that the facts set forth in the foregoing
complaint are true and correct to the best of my knowledge,
information and belief. I understand that false averments herein
are made subject to the penalties of 18 Pa. C.S. section 4904,
relating to unsworn falsification to authorities.
DATE:
'{-/<(;- ?/
~r~~
J . Goss
5
>- o. !::
c....
" c;
..
... ..
~~~! - ~'j6-
:.J ~;;:
r-l , :r: ",
:-- ~ ! Cl... -, ~
i:-" ; ~1 :~
L:_ 'D -I.V,}
l"l. I I-.~
.. - 0-''''
G:': ' . ,.ire.
~~ ~ ~:hl..
I.:.. CI':) :.j
U en U
~ I ~ l '. -
,
: .. ,.. GREGORY J. KATSHIR *' .
jl ,
Allorney el Law
900 Market Street
Lemoyne, Pennsylvania 17043
(717) 763-6133' Fax (717) 763-9425
JEFFREY T. GOSS ,
Plaintiff
V.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: 97-5135 CIVIL TERM
CHRISTI ANN GOSS,
Dafendant
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in divorce under Section 3301 (c) of the
Divorce Code was filed on September 22, 1997.
2. The marriage of Plaintiff and Defendant is irretrievably
broken and ninety (90) days have elapsed from the date of filing
and service of the Complaint.
3. I consent to the entry of a final decree of divorce after
service of notice of intention to request entry of the decree.
I verify that the statements made in this affidavit are true
and correct. I understand that false statements herein are made
subject to the penalties of 18 Pa,C.S. ~4904 relating to unsworn
falsification to authorities.
DATE:
/) hOh)
, t
/
-
.,
JEFFREY T. GOSS,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
97-5135 CIVIL TERM
V.
CHRISTI ANN GOSS,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT REGARDING COUNSELLING
1. I have been advised of the availability of marriage
counselling and understand that I may request that the Court
require that my spouse and I participate in counselling.
2. I understand that the Court maintains a list of marriage
counsellors in the Domestic Relations Office, which list is
available to me upon request.
3. Being so advised, I do not require that the Court require
that my spouse and I participate in counselling prior to a divorce
decree being handed down by the Court.
I verify that the statements made in this affidavit are true
and correct. I understand that false statements herein are made
subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn
falsification to authorities.
DATE:
/2/30/9)
,
Plaintiff
fr. o' i':.
., c
.c .. :-j.-
~:n - u ,"
8-<" ' .~'. ().\:
'-'r L~ ; ..~--~
!- f
6r' L.D '(J~
I J.
lll" . I: :-;.;
,I , ;/' '! J!JJ
u..:1I .... 1..10_
, -,
u, CO :j
0 L.l' U
"
"
\.
.. ,
. .
,.-
"
"
II
GREGORY J. KATSHIR.. '.
u';
"
;
Attorney al Law
900 Markel Slreet
Lemoyne. Pennsylvania 17043
(717) 763.6133' Fax (717) 763-9425
.
..
V.
: IN THE COUhT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
97-5135 CIVIL TERM
JEFFREY T. GOSS,
Plaintiff
.
.
CHRISTI ANN GOSS,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUEST
ENTRY OF A DIVORCE DECREE UNDER
3301lcl CF 'DIE orn::R::E nTF.
1. I consent to a final decree without notice.
2. I understand that I may lose rights concerning alimony,
division of property, lawyer's fees or expenses if I do not claim
them before a divorce is granted.
3. I understand that I will not be divorced until a divorce
decree is entered by the Court and that a copy of the decree will
be sent to me immediately after it is filed with the prothonotary.
I verify that the statements made in this affidavit are true
and correct. I understand that false statements herein are made
SUbject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn
falsification to authorities.
DATE:
/~b'",/f/
/ /
du..-t1 It"", /!J",~
Christi Ann Gois, Defendant
JEFFREY T. GOSS,
Plaintiff
V.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
97-5135 CIVIL TERM
CHRISTI ANN GOSS,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
bFFIDAVIT REGARDING COUNSELLING
1. I have been advised of the availability of marriage
counselling and understand that I may request that the Court
require that my spouse and I participate in counselling.
2. I understand that the Court maintains a list of marriage
counsellors in the Domestic Relations Office, which list is
available to me upon request.
3. Being so advised, I do not require that the Court require
that my spouse and I participate in counselling prior to a divorce
decree being handed down by the Court,
I verify that the statements made in this affidavit are true
and correct. I understand that false statements herein are made
subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn
falsification to authorities.
DATE:
lJ.htJ In
/ I
tit. " ~
' l,v't.. llMI ./ L'~
Christi Ann Goss, Defendant
"';.. 'D C
if; c ,
i ~ {~ , ~
!") ,
Ill, "
~ ~ ( ~ I : I
,,- "
I.... .::
\~~ ~ ...) " .IJ
C.. I I .~:
l.I-1' -. ,
~- II ,-- . ;"lj
U_ (.." !'.:..
j.: CJ
" r- ~~)
() '" (J
~ .... 'f",
-.'
.... '..
"
GREGORY J. KATSHIR.'
Attorney at Law
900 Market Street
Lemoyne, Pennsylvania 17043
(717) 763,6133' Fax (717) 763-9425
.. .- f .
'"".. ..
.'
-'
..
'0 ,
-'
to
Plaintiff
) IN THE COURT OF COMMON PLEAS OF
) CUMBERLAND COUNTY, PENNSYLVANIA
)
) No. 11. C; I \ ,,-
)
) IN DIVORCE
)
)
JEFFREY T. GOSS
VS.
CHRISTI ANN GOSS
Defendant
ACCEPTANCE OF SERVICE
I, the undersigned and Defendant herein, accept service of
the Complaint in Divorce.
Date:
9)r /97
/
~~4-~ ~.~
Christi Ann Goss
Defendant
-
IN TilE COURT OF COMMON PI.EAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
.
.
i1f ()fie~ 005 S .
--- .
'I ' .
.
Plaintiff . 97-5/.35'
(/ .
File No.
vs. IN DIVORCE
.
.
'I .' /1(1(1 .
6r.lS5 .
( flrIL); .
.
Defendant ,
.
NOTICE TO RESUME PRIOR SURNAME
matter, having been granted a Final Decree in
day of 1/1f1(1{/I"t , 19 <'i . hereby elects
{; (} (ll I, '11 flI1
prior surname 'Of fl/I:d', /1-'.. ",,:,n,1'iq~(L'
n 'r
this written notice pursuant to the provibi6ns of 54
Notice is hereby given that the Plaintiff/Defendant in the
Divorce on the
above
11 h
I~
/
to resume the
, and gives
P.S. S 704.
DATE:
/C.I / 7/1'tJ
/ I '
~ ~
(~ ~-6 ~/Y7 ~
Signature
-6
Signature of
COMMONWEALTIl OF PENNSYLVANIA:
: 55.
COUNTY OF CUMBERLAND
On the .2:tL.- day of ~t: ~~ ' 199'1 , before me, a
Notary Public, personally appe~ed the above affiant known to me to
be the person whose name is subscribed to the within document and
acknowledged that he/she executed the foregoing for the purpose
therein contained.
In Witness Whereof, I have hereunto set my hand and official
seal.
,Jx . /1 i,1-//-
~ -'''''.-I~~
Notary Public
NOTARIAL SEAL
PA TRICIA A SHA rro, NOlary Public
Call1s'e 00'0, Cumberland Counly
My Comm"!'oll Expires December 17, 2001
.
q
;C)
-d d
~ J-) (1- j
c~ .:J !---
,
, , ({
,I'" - ( G
, , :~.:.:
" {: <J
.
, ',', . ~r~
. , t' i
r- )
I " /
..:. ..... " u r::d.
L.; " J.. ""-
c;:.'~ "
I 0' ':l
c; (J' u