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HomeMy WebLinkAbout98-00425 r ~ <l -.Q < <:) ~, ~ 0 q/ .' It N N ,. ~ ! / ( ... ~ - . . .:) .. <::J \r, l"1 ~ , 0... 0- . ~ .~-'~**~**~*-**~--****'Y'~~;*::_.,~**~:,~~ ~ -----...--~...._........... --. ..........-.-....-..~~--------.,--.---..-,- ~ ~ $ : IN THE COURT OF COMMON PLEAS ~ y y i ~,. ~ ~.~ w ~,. w ~.' w ~,' ,'~ ~ .'~ ~ ~ ~ ~ ~.. ,', ~ ,', ~ OF CUMBERLAND COUNTY t.n~1'Jt f'tf()~',~ ' t .... ,io ". .".,~~.#--,.~r ,'. ~ ~ '.~ ,', * *. '.~ ,', ~ STATE OF PENNA. ~HE:LBY,..S,...P.IZZARRO , il ~ '.' *. ',' il N ()...........~}~.., ....,............ I C) 98 .', ~ W ~.. ~ ~ ~ , 'I Vet':H1:-i I I " ,I ;! ~ ~.. ,', ~ .'~ ~ r~ ,', ~ ~ ~.~ ~ ~.. ~ ~.~ ...J.OH~ H. .LONGBOT'rOM ~ '.' rt: '.' ." rt: '.' rt: ',' DECREE IN D I V 0 R C E..::t 3:o4/.;v1. AND NOW, ........~.I....,., 197.&:,.., it is ordered and decreed that.. ... .~~~~.~~. ~:. .~~~.z.~~~!J" .,... ... .. .... .. .. .., plaintiff, and. .. . . . . . . . . . . . . .;rP,f!~, !J". ,y9tJ~.~Qrr.QI-!. , . . . . . . . . . . . . . , . . . " defendant, are divorced from the bonds of matrimony, ~ ~.~ ~ ~ ~.~ rt: '.' ~ '.' ,', ~ , ~ ~.' ,'. $. ~.~ ,', ~ ~ '.~ ~ w ;.~ rt: ~.~ rt: '.' ~.; ~ 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; ~ ~.. ~ ~ $. ',' ~ :-' NONE ~ '.' .... .... .........."" .................... ....... ,. ......... ... ........ .... * .. ~ $ * rt: ~ At::: t~rk ~>>~ A%~'N~ J. i; ~ ^?,#Yld. ,.1:'. ~I-Y I" " ~ {/ I Prothonotary I': ~ ~ --- ------,_.-_., ._,' ." . .....-. .............. .......'~ ~~._~*~*~*****~*~*~*****@~~~~*~ tj .;) .t)s tU-.!dJ'tI ,414<-~/ ~ 4 ~(kJdJ tf-;;,t/f 71.1-10. rr1~/ Ii. dfI. '. " Now, Therefore, the parties, In consldaratlon of the foregoing premises, and the mutual promises and undertakings hereinafter set forth, agree as follows: 1. RIGHT TO LIVE SEPARATE It shall be lawful for Husband and Wife at all times hereinafter to live separate and apart from each other and to reside from time to time at such place or places as he and she shall respectively deem fit, free from any control, restraint or Interference, direct or Indirect, by each other. The foregoing provisions shall not be taken to be any admission on the part of either Husband or Wife of the lawfulness or unlawfulness of the causes leading to their living apart. 2. FREEDOM FROM INTERFERENCE Each party shall be free from Interference, authority and contact by the other as if he or she were single and unmarried except as necessary to carry out provisions of this Agreement. Neither party shall harass the other or attempt to endeavor to harass the other, nor compel the other to cohabit with the other, or In any way malign the other, nor in any way interfere with the peaceful existence, separate and apart from the other. 3. DISTRIBUTION AND RELEASE OF MARITAL DEBT Wife assumes full responsibility for any Indebtedness which she has contracted or incurred in her name, alone or jointly, after the date of the execution of this Agreement. Wife represents and warrants to Husband that, since the filing of the divorce action, she has not contracted or incurred any debt or liability, for which Husband or his Estate might be responsible, and shall indemnify and save Husband harmless from any and all claims or demands made against his or his Estate by reason of debts or obligations incurred by Wife and/or assumed herein. , Husband assumes full responsibility for any Indebtedness which he has contracted or Incurred In his name, alone or Jointly, after the date of the execution of this Agreement. Husband represents and warrants to Wife that, since the filing of the divorce action, he has not contracted or Incurred any debt or liability, for which Wife or her Estate might be \.-\.''/'" responsible, and shall Indemnify and save IiI1Sbend harmless from any and all claims or demands made against her or her Estate by reason of debts or obligations incurred by Husband and/or assumed herein. The parties expressly agree that all marital deets shall be paid from the proceed$ of tl'le sale of tAeir martial resldenoe. 4. DISTRIBUTION OF REAL PROPERlY During the course of this marriage, the parties resided In a marital residence which Is presently being sold. When the reilldlilnClil iil finally seld, the preeeees sAallee utilized to pay all marital ~obtG anel '.\lito Ehall be entitled to the sum of 10,000 sterling from the romainlng proceeds tr-cm the sale of tAe marital property. The marital residence described in the foregoing paragraph is the residence situate and known as 55 Westcliffe Terrace, Harrogate, North Yorkshire purchased by the ""'....~ husband prior to the marriage/is and shall remain the property of the husband. On the sale of the said residence the husband shall pay to the wife the sum of 10,000 sterling or earlier at this discretion. 5. CONTENTS OF THE MARITAL RESIDENCE As of the date of the execution of this Agreement, the parties shall transfer and assign their rights, title, claim and interest in specific property. Wife shall have as her own, free and clear of any claims of Husband, all of the items, household goods, furniture, furnishings, appurtenances, and appliances in her possession. Husband shall have as his own, free and clear of any claims of Wife, all of the Items, household goods, furniture, furnishings, appurtenances, and appliances In his possession. Wife shall also be entitled to two (2) Vasslly chairs which are presently in England. Additionally, there are several boxes that were left at the martial residence by Wife which shall be returned to Wife. Said boxes include various personal items of Wife. Wife shall be responsible to pay husband for one half of the costs Incurred by husband relative to the shipping of wife's possessions. 6. MISCELLANEOUS PROPERlY - PERSONAL and MARITAL It is further agreed that both Husband and Wife shall retain as his or her own any and all personal effects, clothing, and personal jewelry. The parties further agree that any property not assigned in this Agreement as marital or nonmarital property will be deemed the property of the physical possessor of said property. 7. RETIREMENT ACCOUNTS The parties shall keep all IRA's, 401 k's and other retirement accounts which are held in their names as personal property, free and clear of claims from the other party. 8. JOINT ACCOUNTS All joint bank and charge accounts, credit card accounts and any other joint accounts shall be terminated and each party shall take those steps necessary to have the other removed as a responsible party from such accounts. The parties further specifically agree that all bank, savings, cash and checking accounts shall become the sole property of party named on the account. 9. TAX LIABILITY The parties hereto believe and agree that the division of property heretofore made by this Agreement Is a non.taxable dMslon of property between co-owners rather than a taxable sale or exchange of property. Each party promises not to take any position with respect to the adjusted basis of the property assigned to him or her with respect to any other Issue which Is Inconsistent with the position set forth In the preceding sentence on his or her Federal or State income tax retum. 10. MUTUAL RELEASE Subject to the provisions of this Agreement, each party waives his or her right to alimony any further distribution of property Inasmuch as the parties hereto agree that this Agreement provides for an equitable distribution of their marital property in accordance with Pennsylvania's Divorce Code. Subject to the provisions of this Agreement, each ,party has released and discharged, and by this Agreement does for himself or herself, and his or her heirs, legal representatives, executors, administrators and assigns, release and discharge the other of and from all caused of action, claims,' rights or demands whatsoever in law or equity, which either of the parties ever had or now has against the other, except any or all causes of action for divorce and except any or all caused of action for any breach of any provision of this Agreement. Each party also waives his or her right to request marital counseling pursuant to Pennsylvania's Divorce Code. 11. ALIMONY Both parties mutually waive all spousal support or alimony from the other. Both parties acknowledge and agree that the provisions of this Agreement providing for the waiver of alimony are fair, adequate and satisfactory based on actual need, ability to pay, duration of the marriage and other relevant factors taken Into consideration by the parties. Although the approval of this Agreement by a court of competent jurisdiction in connection with this action In divorce flied by Husband or Wife shall be deemed an order of the court any may be enforced as such, this Agreement, Insofar as it pertains only to spousal support and the payment of alimony following the entry of a final Decree In Divorce between the parties, may not be modified, suspended, terminated or reinstated at the Instance of request of either party, or subject to further order of any court upon changed circumstances. Upon that condition, both parties hereby accept the provisions 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 spousal support or alimony and both parties voluntarily and Intelligently waive and relinquish any rights to seek a modification, suspension, termination, reinstatement, or other court order with respect to the terms of this Agreement pertaining to the payment of support or 'alimony. 12. ALIMONY PENDENTE LITE. COUNSEL FEES AND EXPENSES Both parties hereby acknowledge and accept that the provisions of this Agreement providing for the equitable distribution of marital property are fair, adequate and satisfactory to them. Both parties agree to accept the provisions of 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, counsel fees any expenses during and after the commencement of any divorce proceeding between the parties. 13. INCOME TAX RETURNS Husband and Wife agree to file separate Individual tax retums for 1998 and thereafter until their divorce is final. 14. WAIVER OF CU\IMS AG'AI~ST ESTAn;S 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 martial relationship, Including, without limitation, dower, curtesy, statutory allowance, widoW's allowance. right to take intestacy. right to take against the will of the other. and right to act as administrator or executor of the other's estate. 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 waiver and relinquishment of all such interests. rights and claims and both parties will revoke prior wills or testamentary documents. 15. AGREEMENT NOT PREDICATED ON DIVORCE It is specifically understood and agreed by and between the parties hereto and each of the said parties does hereby warrant and represent to the other. that the execution and delivery of this Agreement Is not predicated upon nor made subject to any agreement for Institution. prosecution, defense. or for the non-prosecution or non- defense of any action for divorce; provided, however, that nothing contained in this Agreement shall prevent or preclude either of the parties hereto from commencing, instituting or prosecuting any action or actions for divorce. either absolute or otherwise, upon just, legal and proper grounds; nor to prevent either party from defending any such action which has been, mayor shall be instituted by the other party, or from making any just or proper defense thereto. 16, SUBSEQUENT DIVORC!; There has been a divorce proceeding commenced by Wife against Husband on in Cumberland County to No. 425 Civil Term 1998. The parties hereby mutually consent to a divorce and the entering of a divorce dacree on the no.fault grounds that their marriage Is Irretrievably broken pursuant to !i3301 (c) of the Pennsylvania Divorce Code. Parties herein shall execute Affidavits of Consent and a final decree in divorce will then be obtained. 17. BREACH AND ENFORCEMENT If either party hereto breaches any of the provisions of this Agreement, the other party shall have tl'!e right to bring any actions or actions in law or equity for such breach, and the breaching party shall be responsible for the payment of all costs and reasonable legal fees incurred by the other party in enforcing his or her rights under this Agreement. It is expressly understood and agreed by and between the parties hereto that this Agreement may be specifically enforced by either party in Equity, and tha parties hereto agree that If an action to enforce this Agreement is brought in Equity by either party, the other party will make no objection on the alleged ground of lack of jurisdiction of said Court on the ground that there is an adequate remedy at law. The parties do not intend or purport hereby to improperly confer jurisdiction on a Court in Equity by this Agreement, but they agree as provided herein for the forum of equity in mutual recognition of the present state of the law, and in recognition of the general jurisdiction of Courts In Equity over agreements such as this one. 18. RE-ACKNOWLEDGMENI Each party acknowledges that it may be appropriate and required that this Agreament be re-acknowledged at Some time In the future before the Clerk of the Commonwealth Court, Clerk of Orphans Court or some other Court, and each party agrees that they will re-acknowledge their signature before the Clerk of such Court upon request of the other party so that this Agreement may comply with the acknowledgement rules and provisions of any such Court. 19. ADDITIONAL INSTRUMENTS Each of the parties hereto agrees that he or she will join in the execution, acknowiedgment and delivery of any deed or other document which may be reasonably necessary to carry out the intent of this Agreement, and, In the event either of the parties hereto would not join in the execution, acknowledgement and delivery of such Instrument, then such party does hereby Irrevocably appoint the other party hereto as his or her Attomey-in-Fact to execute, aCKnowledge and deliver such instrument hereby ratifying all that such other party hereto may do by virtue hereof with a copy of this Agreement to be a sufficient Power of Attomey to carry out the intent and purpose of this paragraph. Nothing contained In this section shall affect the right of one party to expressly Include or exclude, as the case may be, the other party as beneficiary in any will,insurance policy or other document whether the same is presently In effect or would become effective in the future. 20. VOLUNTARY EXECUTION The provisions of this Agreement and their legal effect have been fully explained to the parties by their respective legal representatives, 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 no the result of any duress or undue Influence. The parties acknowledge that they have been fumished with all Information relating to the financial affairs of the other which has been requested by each of them or their respective counsel. 21. EWlf1E AGREEM~NT This Agreement contains the entire understanding of the parties and there are not representations, warranties, covenants or undertaklngs other than those expressly set forth herein. 22. DISCLOSURE Each of the parties hereto acknowledges that there has been full disclosure of all relevant matters of each party to the other party, that eaCh of the parties Is fully cognizant of his and her legal rights and liabilities with respect to the terms and conditions of this Agreement, that he and she understand the legal effect of this provisions of this Agreement and acknowledge that this Agreement is fair and equitable to each of the parties hereto, and that this Agreement was entered into voluntarily and without any undue influence or duress upon either party hereto. 23. tt10DIFICATlON AND WAIVe~ This Agreement shall constitute a full, complete, and total binding Agreement between the parties conceming support, maintenance, alimony and property settlement, and Is precluded from modification EXCEPT If the parties specifically agree to modify this Agreement. Any and all modifications to this Agreement shall only be by written agreement containing the same formalities as this Agreement and shall exhibit the notarized signatures of both parties, along with two witnesses. The parties specifically agree that they may rescind this Agreement only by written agreement containing the same formalities as this Agreement which shall exhibit the notarized signatures of both parties, along with two witnesses. Any waiver of a breach of any provision of this Agreement shall not constitute an ongoing waiver. 24. PRIOR AGREEMENTS This Agreement constitutes the entire understanding and agreement between the parties hereto, and there are no other representations. warranties, covenants, understandings or agreements other than those expressly set forth herein. 25. INCORPORATlQN INTO DECREE OF DIVORCE Unless as otherwise provided herein, this Agreement shall be Incorporated but not merged into and made a part of any Decree that might be entered in any dissolution proceeding between the parties hereto upon the filing by either or both parties of an executed copy of this Agreement in such action and seme may be incorporated by reference Into any such Decree or court order. 26. DESCRIPTIVE HEADINGS The descriptive headings used herein are for convenience only. They shall have no effect whatsoever in determining the rights or obligations of the parties. . , 27. II')IDEeE~QENr AI')ID SEPARATE COVENANTS It Is specifically understood and agreed by and between the parties hereto, that each paragraph shall be deemed a separate and Independent covenant and agreement. 28. APPLICABLE LAW This Agreement shall be Interpreted In accordance with the laws of the Commonwealth of Pennsylvania. 29. VOID CLAUSES If any term, condition, clause or provision of this Agreement shall be determined or declared to be void or Invalid In law or otherwise, then only that term, condition, clause or provision shall be stricken from this Agreement and in all other respects, this Agreement shall be valid and continue in full force, effect and operation 30. AGREEMENT BINDING ON HEIRS This Agreement shall inure to the benefit of and shall be binding upon the parties hereto, their heirs, executors, administrators, successors and assigns. 31. EFFECTIVE DATE This Agreement shall be considered to be effective at 12:01 a.m. on the date set forth on page one of this Agreement. In Teetlmony Whereof, witness the signature of the parties hereto this _\ 1 ~h day of A\,.L~" .\ >r .1998. ~~c=v_ Witness - \.~~~, Witness >- CI ?= ~ ...." :~~ c~ -" :~} c'" ~IJ _,~ "t?O .,- (..L..~ fj: :.1-: .'- o:;j> ;g'; c:'... .'-!.:~-j ':.: t.i.:H': ..:r ::~ ~! ...1 C'oJ G: ~I..l C-'.. ',I,":J .' ::: ,-, "'" ;;.~...l.. 11- r:""I ~j c: U; u , , < , .; .. \ fr; i~: ~ .c: .. ::-) < C) ~ U.l-~,. .~::.:. oc-::' .- (~-,I~~ u:~( .>- '.1--- 0.. ._1.",:".1 ~h ~ \~~ )c: L. C'J ~ ,- .~'.r' u:I'! r.!l ~ni'l) ..' =:: :;:1[.1.. f",; 0<::: '.- .~~ u. r:o ::J 0 0' U . v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION. LAW q '6 - I/c?S' NO. $r- CIVIL TERM IN DIVORCE SHELBY S. PIZZARRO Plaintiff JOHN H. LONGBOTTOM 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 mujst take prompt action. You are warned that if you fail to do so, the case 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, Cumberland County Court House, Carlisle, Pennsylvala. 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 Lwwyers Referal Service Association 2 Liberty Avenue Carlisle, Pa. 17013 (717) 249-3166 (800) 990-9108 PETER J. RUSSO, ESQUIRE PA Supreme Court ID: 72897 61 West Louther Street Carlisle, PA 17013 (717) 249-2721 Attorney for Plaintiff SHELBY S. PIZZARRO Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW cl'6- IIJ ( NO..97'- IN DIVORCE v. JOHN H. LONGBOTTOM Defendant CIVIL TERM COMPLAINT IN DIVORCE UNDER SECTION 3301 (c\ AND 3301 (d\ OF THE DIVORCE CODE AND NOW comes the above-named Plaintiff by and through her attorney Peter J. Russo, and seeks to obtain a Decree in Divorce from the above-named Defendant, upon the grounds hereinafter more fully set forth: 1. Plaintiff Is an adult individual residing at 3514 Hawthorne Drive, Camp Hill, Cumberland County, Pennsylvania and is a citizen of the United States. 2. Defendant is an adult individual residing at 55 West Cliffe Terrace, Harrogate, North Yorkshire, England, HG2 OPU. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for a period in excess of 6 months. 4. Plaintiff and Defendant were married on December 30, 1983 in Phoenix, Arizona. SHELBY S. PIZZARRO Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION. LAW 'i 'B' - II J ~~ NO. !1t- CIVIL TERM IN DIVORCE v. JOHN H. LONGBOTTOM Defendant VERIFICATION I, Shelby S. pizzarro, verify that the statements made in this Complaint-Civil Action are true and correct to the best of my knowledge. 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. Date: :2. \ 'J)t c : t'\ 1- v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 98-425 CIVIL TERM IN DIVORCE SHELBY S. PIZZARRO Plaintiff JOHN H. LONGBOTTOM Defendant PLAINTIFF'S AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO ENTER DIVORCE DECREE UNDER SECTION 3301 (c) OF THE DIVORCE CODE 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on January 23, 199B and received by the Defendant on February 3, 1998. 2. The marriage is irretrievably broken and ninety days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a Final Decree of Divorce without further notice. 4. I understand that I may lose rights concerning alimony, division of property, lawyers fees or expenses if I do not claim them before a divorce is granted. 5. 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's Office. 6. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate In counseling. I understand that the court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me on request. 7. Being so advised, I, Shelby S. Pizzarro, do not request that the Court require my spouse and me to participate in counseling 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 subjec to the penalties of 18 Pa.C.S. ~ 4904 relating to unsworn falsification to Author ti s. 1\ M~ "w DATE ~ .... Lf) ~ O. ",' .!- \-' .. :~:1 .. 1': UJQ - nc.,; ( )...... ;:.C C'Jr'" ~.(~, ~.i: l1::r: .'t'"'::; '71;:.J -,., qr.::. C"") .::~~~ or" LLI'....- .1"-/ :.:.:.JU,1 ,... ii,jLD a:'[ .'~: j~OU- r-. :.::: ~.:;: .<- l.l- co :::J Q CT. U v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION. LAW NO. 98-425 CIVIL TERM IN DIVORCE SHELBY S. PIZZARRO Plalnt"f JOHN H. LONGBOTTOM Defendant DEFENDANT'S AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO ENTER DIVORCE DECREE UNDER SECTION 3301 (c) OF THE DIVORCE CODE 1. A Complaint In Divorce under Section 3301 (c) of the Divorce Code was filed on January 23, 1998 and received by the Defendant on February 3, 199B. 2. The marriage is irretrievably broken and ninety days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a Final Decree of Divorce without further notice. 4. I understand that I may lose rights concerning alimony, division of property, lawyers fees or expenses if I do not claim them before a divorce is granted. 5. 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's Office. 6. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate In counseling. I understand that the court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me on request. 7. Being so advised, I, John H. Longbottom, do not request that the Court require my spouse and me to participate in counseling 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 penal s of 18 Pa.C.S. !i 4904 relating to unsworn falsification to Authorities. 'G. 7.. ~ $' - ~'\ f DATE / I.V ongbottom ..... CI t Cc; ~,l ". 1- ::-/....'1" UJQ ..:r :.-~! :?; ,-).. -. '~..,l." Li: Cl Ci: ~-:1 ?:j '~~: ~. :.,.~ ,," .':. (fl L. I... ('oj _"1~: uJ': . ""7 ~!II: ~ !"il[i] u.., , ~~ 0.. i,:: ;;;: 'J.. CO ::.J l.> c' U , , v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 98-425 CIVIL TERM IN DIVORCE SHELBY S. PIZZARRO Plaintiff JOHN H. LONGBOTTOM Defendant PROOF OF SERVICE OF PLAINTIFF'S COMPLAINT UPON DEFENDANT NOW COMES, Peter J. Russo, Attomey for Plaintiff, Shelby S. Pizzarro, and certifies that on January 23, 1998, he did serve the Defendant, John H. Longbottom, with a true and correct copy of the Divorce Complaint filed against him alleging the parties marriage was irretrievably broken under Section 3301(d) and Section 3301(c) of the Divorce Code. Said complaint was served upon the defendant by placing same in an envelope, retum receipt requested and addressed to John H. Longbottom,.55 West Cliffe Terrace, North Yorkshire, England HG20PU. Service of Plaintiff's Complaint on the defendant, John H. Longbottom,.was effected on February 3, 1998. A true and correct copy of the U.S. Postal Service Re~9m Receipt for Intemational Mail is attached hereto and the original is affixed to the reverse of this document. Respectfully submitted, ~-to(V~~~ Peter J. Russo 61 West Louther Street Carlisle, PA 17013 (717) 249-2721 "- ... SHELBY S. PIZZARRO Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION. LAW NO. 98-425 CIVIL TERM IN DIVORCE v. JOHN H. LONGBOTTOM Defendant CERTIFICATE OF SERVICE NOW COMES, Peter J. Russo, Attorney for Plaintiff, Shelby S. Pizzarro, , and certifies that on Wednesday, February 11, 1998, he did serve the Defendant, John H. Longbottom, with the attached PROOF OF SERVICE OF PLAINTIFF'S COMPLAINT UPON DEFENDANT via U.S. mail. Respectfully submitted, Q-hAQ~~Q Peter J. Russo Date: Februarv 11. 1998 ~ ' .I :', j ) ( ( >- ..... ?= ~ N -... wO N :5<: UZ 0--' rea .... ()~~ :1'- ~ ~ ~r-: (.;);:i 0 n: N :1~U5 UJCl. _12 --JL, . c:> u'z rei: LAJ l11LlJ r- LA... ~qO- U. ..i.: co ::> 0 0'1 U _. '.-AI