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HomeMy WebLinkAbout98-00612 II) > J c., '1 \J ~ t " ~ : ., - i . .5 - U ri - ~ . .:.:. .:+:. .:+:. .:+:. .:+:. .:.:. .:+:. .:+:. .:+:. .:.:. .:+:. .:+:. .:+:. .:.:. .:.:. .:.:. .:+:. .:.:. .:+:. .:.:. :..:+:. .:+:.:'.:.:. .:.:. .:.:. .:.:. .:+:. ':+:',' .:+:.;'.;.. ~ ....~------.... ....,-,._- .-- -......-------.--............--- - --- -....... ..~~....-.... ~-----.-~-_._~_.~ -....-....---.....-- ----........_.-.- ..' '.' , I ~ ~ .' ,'~ ~ ~ ~.' ~ IN THE COURT OF COMMON PLEAS ~ '.' OF CUMBERLAND t.,.:;~' i>f{/~~ f _~<t!i"~'.j. "~~.#~"r PENNA. COUNTY s ~ .', ~ STATE OF ,', ~ ,', ~ ~ ~.' DONNA C.PRESSLEY, Plaintiff N<<), ...9S",612..,CIV.IL......., 'I " ~ '.' .' ~ ~.~ ~ ~ ',' ." .', ~ VCJ'SlIS RUSTIN L... PRESSLEY, . Defendant ~ ',' DECREE IN D I V 0 R C E ....:t'~.. s). ~.1Yl AND NOW, . r:..--:'4..?:.7........... 19,~~..., it is ordered and decreed that......... .~C?~~!\. S:. ~.~~I?;:;~Ei~..,..,...,........., plaintiff, and. .. . , .. .. .. . . .. .. ..~P~.~:J;~. ~.'.. :r!l~~I;q'!!l.Y: .. , , . .. . .. .. .. ". defendant, are divorced from the bonds of matrimony, ~ '.' ~ w :.' ,', ~ ~.' ~ ~ ;': ~ ~.: ,', ~ ~ ~ ~.' The court retoins jurisdiction of the following claims which have been raised of record in this action for which a final order has not yet been entered; ~ ~.' ~ " . . ~C!~<<:l... . .~1,1!'!. .~9~~.-:~~p~,i,~+. !\,9:r;~~~~t. ~~~~!l, ,fo!'!-FE" .~,. ,l,~~!l. .i,fi. . . . , hereby incorporated but not merged into this Decree. .. .......... ................ .... ... ... ...... ...... ...... .......... ......... ~ ~ ~.' ~ "; ~ .'~ ~'. ~ ~ :.~ ~ ~ ~ ~ ~ ~- ,..:. '~:'.. .:+:. .:+:. .:+:. .:+:. I~ }~ I'.' ~ '".' I,.. l~ ..~--..--~ ~.-..__,.~ ._....~...........~._.. _,_b_' . _'--__..., i ~ '..:' .:+:. .:+:. .:+:. .:+:. .:+:- -:+;. .:+;. .:.:. .:+:. .:+;. .:+;. .:+;. .:.;. .:.;. .:+;. -:~:. .:+;. .:.;. .:.:. .:.;. .:+;. '.:+:.' AlIe'I:4'~ ~~..4~?~ ~;!.!41cz.. ~'J;r:;~/ rfl.7 ... . {/ '/7 Prothonotary lly ,', ~ .', ~ * '.' .', * .', ~ .', ~ ~ ~ '.' ~', ~ ~ ... ,,~ ~ ~ '.~ ~ ~.' *- ... *- .,. !.- ~ ~.' *- ? *- ',' ~ ~.~ ~, ~ *- ;.~ *- ;.~ ~ ~.; ~ ~-: ~ '.' ~ ~.' ~ ... ~ '.' !t! ... ~ ... ~ '.' * J. A-.... .. DONNA C. PRESSLEY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 98-612 CIVIL TERM CIVIL ACTION - LAW RUSTIN L. PRESSLEY, Defendant IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO: Prothonotary of Cumberland County: Please transmit the record, together with the following information, to the Court 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: via personal service on February 11, 1998. (See Affidavit of Service filed herein. ) 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by the Plaintiff: January 13, 1999; by the Defendant: January 13, 1999. 4. Date of execution of Waiver of Notice of Intention to Request Entry of Divorce Decree under Section 3301(c) of the Divorce Code: by the Plaintiff: January 13, 1999; by the Defendant: January 13, 1999. 5. Related pending claims: None. All claims resolved by Post-Nuptial Agreement dated March 9, 1998. LAw OFFICES SNELDAKER. BRENNEMAN {\ SPARE SNELBAKER, BRENNEMAN & SPARE, P.C. Date: ~1/t1 .~ By: p AtQorn ys f r Plaintiff ,- '~ .. (') V) '."".) ~7.;' '.0 " '.- "TJ 1 ~~ , -n r;J , fr; >.: :~ '" >.., :"'~L ;._~ ~:;:' : ".~ r:~ l, .,.) '::::'H >: .. ..~ ~ ~;.~ :;;~i f:.~ c:: ~j ~*.1 , - C.: -'. ::3 ;" "0 -', In =< WHEREAS, the parties agree that their marriage is irretrievably broken; and WHEREAS, on February 3, 1998, Wife commenced an action in divorce docketed to No. 98-612 civil Term in the Court of Common Pleas of Cumberland County, Pennsylvania (hereinafter called "Divorce Action"); and WHEREAS, the parties acknowledge that each has had the full opportunity to be advised independently and represented by separate counsel concerning their respective rights, duties and obligations arising out of their marital status. Wife is represented by Philip H. Spare, Esquire of the firm of Sne1baker, Brenneman & Spare, P. C. and Husband has elected not to engage the services of an attorney despite being advised that he should do so; and WHEREAS, the parties having a full opportunity to be advised of their respective rights, duties and obligations arising out of the marriage and each having a full opportunity to investigate and evaluate the assets, liabilities and all other aspects of each other's property and their jointly owned assets and liabilities, have come to an agreement for the final settlement of their property and affairs. NOW THEREFORE, in consideration of these presents and the mutual covenants, promises, terms and conditions hereinafter set -2- forth and to be kept and performed by each party hereto, and intending to be legally bound hereby, the parties mutually agree as follows: 1. INCORPORATION OF PREAMBLE. The foregoing preamble and paragraphs are incorporated by reference herein in their entirety. 2. DECLARATION AS TO ASSETS AND WAIVER OF EVALUATION. The parties agree that the items of property set forth in "EXhibit A" are all of the assets which they acquired during their marriage and which would be the subject of equitable distribution if submitted to a court for division under the provisions of the Pennsylvania Divorce Code. The parties declare and agree that they are familiar with said assets and hereby waive the evaluation thereOf, although each party declares that she/he has had full opportunity obtain such evaluation. 3. DIVISION OF ASSETS. Upon the execution of this Agreement and except as otherwise provided, the parties agree to divide, allocate, retain and/or transfer the assets shown on "Exhibit A" as follows (the items numbers refer to the corresponding numbers on "EXhibit A"): A. ASSETS TO WIFE 1. Marital residence located at 463 Rich Valley Road, Carlisle (Silver Spring Township), Cumberland County, PennSYlvania; -3- . 2. 1995 GMC Jimmy sport utility vehicle; 5. Bank accounts in Wife's name; 7. Wife's retirement and/or 401(k) account; 9. York Federal account in joint names; 12. Household goods, furniture and other tangible personal property currently in Wife's possession, except those items listed in paragraph 11 of Exhibit A; B. ASSETS TO HUSBAND 3. 1988 Chevrolet Pickup truck; 4. 1986 Chevrolet Monte Carlo automobile; 6. Bank accounts in Husband's name; 8. Husband's retirement and/or 401(k) account; 10. Household goods, furniture and other tangible personal property currently in Husband's possession; 11. Stereo (disassembled), 27-inch television set, race car, go-kart, Wheel Horse lawn mower, Husband's tools and tool boxes, tire press, lathe, sheet metal bender, portable shelving, miscellaneous race car parts, truck cap; 4. REMOVAL OF PERSONAL PROPERTY It is agreed and understood that Husband shall remove the items set forth in sUbparagraph 3.B.ll above from the real estate known as the marital home within thirty (30) days of the execution of this Agreement. In the event Husband fails to remove said items within the given time period, Wife may take any steps necessary to dispose of said items without any liability to Husband. -4- 5. MARITAL HOME. Contemporaneous with the execution of this Agreement, Husband shall execute a deed granting and conveying to Wife all of his interest in the real property located at 463 Rich Valley Road, Carlisle (Silver Spring Township), Pennsylvania. Wife covenants and agrees not to sell her interest in the marital home for a period of five( 5) years from the date of this agreement. Wife shall be solely responsible for current mortgage and home equity loan payments (which obligations are identified in l paragraph 6 below), insurance, taxes, maintenance, repairs and all other expenses related to the marital home. Wife shall hold husband harmless and shall indemnify him for any and all amounts 1 \ , I due under the current mortgage and home equity loan. 6. CURRENT LIABILITIES. The parties agree that the only existing joint liabilities of the parties are: ( ( r { l \ \ . ,~ , ' II , I A. First United Mortgage Services, Inc. Loan Number 206940062 evidenced by the mortgage dated October 10, 1995 and recorded in the Recorder of Deeds Office in and for Cumberland County, Pennsylvania at Mortgage Book 1286, Page 299 which Mortgage was subsequently assigned to Standard Federal Bank by instrument dated October 10, 1995 and recorded at Miscellaneous Book 50S, Page 998 and subsequently assigned to Mellon Mortgage Company by instrument dated July 16, 1996 and recorded in I I " -5- I \ I~. Miscellaneous Book 528, Page 335; and B. York Federal Savings and Loan Association home equity loan evidenced by the Note referred to in the Mortgage dated December 9, 1996 and recorded in the Recorder of Deeds Office in and for Cumberland County, Pennsylvania at Mortgage Book 1355, Page 1147. wife shall be solely responsible for the two preceding obligations pursuant to Paragraph 5 above. Each party shall be solely responsible for paying any debt or obligation incurred in his or her name since September 6, 1997, the parties' date of separation. Parties agree to indemnify one another and hold each other harmless of and from any and all debts, damages costs and expenses which either party may incur directly as a result of the other party's failure to pay his or her individual debts or obligations incurred since the date of separation. 7. FUTURE OBLIGATIONS. The parties agree that any and all obligations incurred subsequent to the date of this Agreement, shall be the sole and separate liability and responsibility of the party incurring the obligation and each party agrees that he/she will not incur or attempt to incur any obligations for or on behalf of the other party and will indemnify and hold harmless the other party of and from any and all liability arising from such future obligation. -6- "' 8. RELEASE OF RIGHTS UNDER DIVORCE CODE. Except only as specifically provided to the contrary hereinabove in this Agreement, each party hereby waives and forever releases the other party of and from any and all claims which either may have against the other by reason of and pursuant to the Pennsylvania Divorce Code (and the divorce law of any other jurisdiction) including, but not limited to, alimony, alimony pendente lite, equitable distribution of marital property, counsel fees, costs and expenses, except that the performance of any obligations created hereunder may be enforced by any remedies under the Pennsylvania Divorce Code. 9. INDIVIDUAL PROPERTY. Except only as may be provided specifically to the contrary hereinabove, each party shall retain all property, real, personal and otherwise, which is presently titled in his or her name and ownership, whether or not said property is or would be deemed to be marital property under the Pennsylvania Divorce Code and each party hereby expressly releases the other of and from any and all right of equitable distribution in and to said individually owned property of such other party. 10. GENERAL RELEASE. Husband relinquishes his inchoate intestate right in the estate of Wife, and Wife relinquishes her inchoate intestate right in the estate of Husband, and each of the parties hereto by these presents, for himself or herself, his -7- I~ or her heirs, executors, administrators or assigns, does hereby remise, release, quit-claim and forever discharge the other party hereto, his or her heirs, executors, administrators or assigns, or any of them, of any and all claims, demands, damages, actions, causes of action or suits at law or in equity of whatsoever kind or nature, for or because of any matter or thing done, omitted or SUffered to be done by such other party prior to the date hereof, except that this release shall in no way exonerate or discharge either party from the obligations and promises made or imposed by reason of this Agreement. This Agreement shall not be construed to affect or bar the right of either party to an action for the enforcement or performance of this Agreement which may be instituted pursuant to the remedies available under the Pennsylvania Divorce Code. 11. SURVIVAL OF AGREEMENT. It is the intention of the parties that this Post-Nuptial Agreement shall survive any action in divorce which may be instituted or prosecuted by either party, and no order, jUdgment or decree of divorce, temporary, interlocutory, final or permanent, shall affect or modify the terms of this Agreement, but said Agreement may be enforced by any remedy at law or in equity, including enforcement proceedings under the Pennsylvania Divorce Code. The parties agree to incorporate this Agreement into a separate order of court to be entered in the Divorce Action, but this Agreement shall not be -8- "'~ -' 15. ENTIRE AGREEMENT. This Post-Nuptial Agreement contains the entire understanding of the parties and there are no representations, warranties, covenants or undertakings other than those expressly set forth herein. The parties 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 the Pennsylvania Divorce Code or any amendments thereto. Each party voluntarily and intelligently waives and relinquishes any right to seek a court ordered determination 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. 16. WAIVER. The waiver of any term, condition, clause or provision of this Agreement shall in no way be deemed or considered a waiver of any other term, condition, clause or provision of this Agreement. -10- 17. APPLICABLE LAW. This Agreement shall be construed, interpreted and enforced according to the laws of the Commonwealth of Pennsylvania. 18. HEADINGS. The headings or titles of the numbered paragraphs of this Agreement have been used only for the purpose of convenience and shall not be resorted to for the purposes of interpretation or construction of the text of this Agreement. 19. BREACH. It is expressly stipulated that if either party fails in the due performance of any of his or her material obligations under this Agreement, the other party shall have the right, at his or her election, to sue for damages for breach thereof, to sue for specific performance or to seek any other legal remedies as may be available, and the defaulting party shall pay the reasonable legal fees for any services rendered by the non-defaulting party's attorney in any action or proceeding to compel performance hereunder. 20. AFTER-ACOUIRED PROPERTY. Each of the parties shall hereafter own and enjoy independently of any claim or right of the other, all items of property, be they real, personal or mixed, tangible or intangible, which are hereafter acquired by him or her, with full power in him or her to dispose of the same as fully and effectively, in all respects and for all purposes as though he or she were unmarried. -11- 21. COUNSEL FEES. COSTS AND EXPENSES. Each party shall be responsible for his or her own legal fees, costs and expenses, if any, incurred in connection with their separation and/or the dissolution of their marriage. 22. INDEMNIFICATION. Each party represents and warrants to the other that he or she has not incurred any debt, obligation, or other liability, other than described in this Agreement, on which the other party is or may be liable. Each party covenants and agrees that if any claim, action or proceeding is hereinafter initiated seeking to hold the other party liable for any other debts, obligations, liability, act or omission of such party, such party will at his or her sole expense, defend the other against any such claim or demand, whether or not well-founded, and that he or she will indemnify and hold harmless the other party in respect of all damages as resulting therefrom. Damages as used herein shall include any claim, action, demand, loss, cost, expense, penalty, and other damage, including without limitation, counsel fees and other costs and expenses reasonably incurred in investigating or attempting to avoid same or in r I i I , I ,\~ , 1 opposing the imposition thereof or enforcing this indemnity, resulting to Husband or Wife from any inaccurate representation made by or on behalf of either Husband or Wife to the other in this Agreement, any breach of any of the warranties made by Husband or Wife in this Agreement, or breach or default in performance by Husband or Wife of any of the obligations to be -12- , \ ! . I!.~, performed by such party hereunder. The Husband or Wife agrees to give the other prompt written notice of any litigation threatened or instituted against either party which might constitute the basis for a claim for indemnity pursuant to the terms of this Agreement. 23. MODIFICATION. No modification, rescission or amendment to this Agreement shall be effective unless in writing signed by each of the parties hereto. 24. SEVERABILITY. If any provision of this Agreement is held by a Court of competent jurisdiction to be void, invalid or unenforceable, the remaining provisions hereof shall nevertheless survive and continue in full force and effect without being impaired or invalidated in any way. IN WITNESS WHEREOF, the parties have hereunto set their respective hands and seals the day and year first above written intending to legally bind themselves and their respective heirs, personal representatives and assigns. WITNESSED BY: ~~~~ r qJir~h- ~~.~~ (SEAL) -13- :~ EXHIBIT A 1. Marital residence located at 463 Rich Valley Road, Carlisle (Silver Spring Township), Cumberland County, Pennsylvania; 2. 1995 GMC Jimmy sport utility vehicle; 1988 Chevrolet Pickup truck; 1986 Chevrolet Monte Carlo automobile; Bank accounts in Wife's name; Bank accounts in Husband's name; 3 . 4. 5. 6. 7. Wife's retirement and/or 401(k) account; 8. Husband's retirement and/or 401(k) account; 9. York Federal account in joint names; 10. Household goods, furniture and other tangible personal property currently in Husband's possession; 11. stereo (disassembled), 27-inch television set, race car, go-kart, Wheel Horse lawn mower, Husband's tools and tool boxes, tire press, lathe, sheet metal bender, portable shelving, miscellaneous race car parts, truck cap; 12. Household goods, furniture and other tangible personal property currently in Wife's possession, except those items listed in 11 above; .~ ACKNOWLEDGMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND SS. On this, the q~ day of March, 1998, before me, a Notary Public in and for the Commonwealth and County aforesaid, the undersigned officer, personally appeared DONNA C. PRESSLEY, known to me (or satiSfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. {'~~ {ik ~ Notary Pub ic NolaJlal Seal ChJlst'ne M Whi1e, Notary Public Mechamcsburg Born, CUmbe!fand Coonly My Commission EXplres Sept, 17 2001 Milmber, P9nnsytvania AssocIat1on 01 NoIart8s LAW OFF'ICCG SNELDAKER. BRENNEMAN Be SPARE DONNA C. PRESSLEY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 98- t;1;). CIVIL TERM CIVIL ACTION - LAW v. RUSTIN L. PRESSLEY, Defendant IN DIVORCE NOT ICE 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 for 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 divorce is indignities or irretrievable breakdown of the marriage, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce decree being handed down by the court. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, Carlisle. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from the list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DECREE OF DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 SNELBAKER, BRENNEMAN & SPARE, P.C. By: P1aJ.nt~ff .' ~ ..--.,,, 7. The marriage between the parties hereto is irretrievably broken. 8. The Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 9. The Plaintiff requests this Court to enter a decree of divorce. COUNT II - EOUITABLE DISTRIBUTION OF PROPERTY 10. The Plaintiff and Defendant have legally and beneficially acquired property both real and personal during their marriage from October 14, 1995. 11. The Plaintiff requests this Court to equitably divide all marital property pursuant to section 3502 of the Pennsylvania Divorce Code. WHEREFORE, the Plaintiff, DONNA C. PRESSLEY, respectfully requests your Honorable Court to: (a) enter a decree of divorce, divorcing the Plaintiff from the bonds of matrimony heretofore existing between the Plaintiff and the Defendant; LAW OFFIces SNELDAKER. BRENNEMAN 6: SPARE (b) order equitable distribution of marital property; and -2- ~ ,>" f:~ ,.0' 'n ,'') .;'1 '! i?J .iT! 'CJ , ' ; L';~~ --,' ", (-5 ,_.:. ~ II " .,- :.X) -: , . : t',) "TI l~'? '~..., (;1 .' , i , .~I . DONNA C. PRESSLEY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 98-612 CIVIL TERM CIVIL ACTION - LAW v. RUSTIN L. PRESSLEY, Defendant IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT UNDER SECTION 3301(CI OF THE DIVORCE CODE 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on the 3rd day of February, 1998. 2. The marriage of the Plaintiff and the Defendant is irretrievably broken and ninety (90) 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 after service of notice of intention to request entry of the decree. 4. 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. S4904, relating to unsworn falsification to authorities. Date: I 'I I, ///1/;11/ /~ '. / /..--) (/.7;) I / ./r(j, J . } .~, ~/- ~ Donna C. Pressley /9'i~' , LAW OF"CES SNELBAtcER. BRENNEMAN &- SPARE (-, t..:.",' ,'-) ,-' I.,:.'J , 1 , -1.:, , ..,. ." I> ! , ..:: :l:Vl~ ," 1'-.( .,-' )C) - , . 1.... "" '-0'1 .. . ~ ('.;; , ~. ! r:-? ;::,iTl .... :'::1 , -" :"'.) :.q ...) lr' -, -'. (") v:J ,C) f,; I..l:) iJ'1! v r~:. ;~~~: :1] ril L: ,- ~:: N .......",..) ('/) , :,0 , eL, ~~ " .~ ..~' ~II , : ,,'.~! f~5 , - " . i:1 ;...:.:,rn ~ ( =j :;." N -" ,,3 ~, -. Cl'> -< " . . (') l.O ,..1 ~;~ I...~:J -n .' q~t;:.; " " , '''-1 " , .-lj'~ ,'/ ,. .." ',ITI , , ." ' ,e) ,,' .) , C. , -' ~;:- -0 f: ~ ( ,.'. I ~;: /1 ',~" , , :-.:1 . ,'0 :i; ..) 0' -:; ,., d--o" . 1.- .. (') c9 (:J r-~ \0 II 1:'-; (.- ~'I 'B :;.;. ,,'1 r,} , ,.:- ".1r- l-.:J "hrn \"li , ;'[ ~ .-- , .-::.C) - ''0 :~'~ ~1J ,"\ . ,.- . (..) ;::jl"i\ ., ~',"; r;.? .:;,.-t O:J '" ~.j . IT' 00<; 1.\ ~' IN TilE COURT OF COMMON !'I,EAS OJ.' CUMIlRRI,AND COUr-;TY, PENNSYI,VANIA CIVIl. AC'I'JON - I,AW : : ~)\il\o.. (1 -p('C."..,~"-€-i : Pla ntiff : 9'R -(./7 C./Ll/L : File No. : vs. : IN DIVORCE <\(\.6-\1 Vl : / 'P\'C'~,,:,,~ I'f'Jt Defen ant : NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff/Defendant in the above matter, having been granted a Final Decree in Divorce on the :J 7 day of fIr.nllf'l.A\.1 ,19 qq , hereby elects to resume the prior surname~00 ev...h.l,.i (1<" Sr'\\ld{',J", and gives I this written notice pursuant to the rovisions of 54 P.S. S 704. DATE: COMMONWEALTH OF PENNSYLVANIA: : 55. COUNTY OF CUMBERLAND : On the ) ~-a:.-. day of , 19 q.q , before me, a Notary Public; personally appea ed the above aff~ 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 my hand and official seal. 1101A~~~\I~~~~ P~BUU~1'I SO>>O~B~~~E CUIlBtR~E~B~ \~, \9'l'l CM\lI"\ \011 t~P\~t~ 110 M~ COMI~\~S .--, (') to -~ \.0 0 ~ ." 6:; ~. " 92[!1 ." -I ~ #r ~~Cl ^' i:-r.::n tllp ~ (1.' ..~o Ul o-.:tm :;-J r:.;":_: ~~;,O <"C... ,..) L ...:I ~ '1" -0 __~CJ ";8 -, - .,. ~::=c ,'-rl .0 ~.)r ()1 ~c: =:? fJ,-A ~ I" :-t ..- r:; \0 .'0 -< -'(] :R ~ .~ I ". I' "