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HomeMy WebLinkAbout98-00977 t-... t'-- ()-. . 0- ~ . ~ ':....' 'ltC-' ,*' .le....*" -:00:' .;.-..' {lit. "le" 'le- .;.-.. '.:.:, 'le' 'It> 'le' .:.:. 'le":':' .ltC- 'lC,',y':.*~>_>_>ltC-:;,*,o*,: :'lIC-::.-c:.-c~ ~ - JJ! ,. ~ ~ IN THE COURT OF COMMON PLEAS : 8 OF CUMBERLAND COUNTY ~ 8 8 ~ .~ ~ g STATE OF ~ PENNA. i e a ~ ~ ~ ~ 8 ..,(;ro.;:(;()IlX..J\,~..lJLP!, "" ,."....,.................,.... I ~ . i N (), ..,?~::-.?~.?..S,~VI,~.............. 19 98 '. : ......,...,..,..,I';l,~~t,ff .... ....,..............,......'....... II ~ ,', VCI'SUS I ~ ~ '. ."....t<I.M.B.E~X,J\~..CAs.r.L.E, ....,..'" .............. I 8 ~ .... ,'.. ' ..D!:lfendiIDt ..,. ...... ~ , 8 ~ ~ ~ ~ M D E C R EEl N .: ~ ~ e DIVORCE ~ ~ <;;" .; AND NOW, . .. .J iA11.c... ,~.. .. .. .. . .. ...., 19,10... it is ordered and 8 z ~ .. " ~ decreed that........... ,~~~ ,":'~ .'!l:'~... ..... .....,..,......, plaintiff, ~ ~ ~ ~ and....,.... ..I,<~I):~~. fl.... ~f9:rH'.. .. ,..'...... ...... .....,... 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; None. ~ , ~ ~ The Separation iIDd Property Settlerrent AgreeIrent, dated February 16, 1998, ~; :0; .......................................................................... r ~ ~.~:, "~~. ;ipf:9FPPF?):~... P).I,t. .n.o.t. ~gep.,. ,~~i,r]'" ",. ..",." ."..,.'""."",. ~ ~ ~ ' ~ ~ ~ ~ ~ ~,...... c' .. Dy ThO. C,o/,/I: /J ~ ,.."...., ,.,.. W~,~ OYV.. C. Allesl: 'd."zj k~~~ .4 ' ~ J, , ,..... ..,~~'!L.., ..,J:d&.., "~la'~Y' .. .', ~ s * " ~ '.' ~ ~. I', I~. .~ ,~~~~.;.-......~~~~-:.-...._----_-:.-..--:.-..- GREGORY A. VLI', Plaintiff : IN TilE COURT OF COMMON I'J.EAS OF : CUMHERLAND COUNTY, I'ENNSYLV ANI A : NO, 98-977 CIVIL TERM "5, KIMBERLY A, CASTLE, Defendant : IN DIVORCE PRAECIPE TO THE PROTHONOTARY: Kindly docket the attachcd Scparation and Propcrty Scttlement Agreement, dated February 16, 1998, to the within casc. Dated: Zn /'J17 q y IRE ." I. S~;I'AnATION: It shall bc lawful 1(lr caeh party at alltimcs hcrcllficr to Iivc 1\, ( .. l. I' ! , 'I ~ , , (, El scparatc and apart from cach othcr at such placc or placcs liS hc or shc may from limc to timc choose or dccm fit. 2. INTEnFEnENCE: Elich party shllll bc frcc from intcrfcrencc, authority and contact by thc othcr, as fully as if hc or shc wcrc singlc and unmarricd, cxccpt as may bc ncccssary to carry outthc provisions of this Agrccmcnt. Ncithcr party shllll molcst the othcr nor attempt to endcavor to molest the othcr, nor eompc1 the other to cohabit with the othcr, nor in any way harass or malign thc othcr, nor in any way intcrfcrc with the pCllccable existencc, separate and apart from the othcr in all rcspects as ifhe or shc wcre single and unmllrricd. 3. WIFE'S DEBTS: Wifc rcprcscnts and warrants to Husband that sincc their separation on Octobcr 15,1997, shc has not, and in thc futurc shc shall not, contrllct or incur any debt or lillbility for which Husband or his Estate might be responsible and shall indemnify and save Husband harmless from lIny and all claims and demands made against him by reason of debts or obligations incurred by her. ;, 't I ), ~ ,(', , , T f: ';(' , , ! 4. HUSBAND'S DEBTS: Husband rcpresents and warrllnts to Wife that since their separation on Octobcr IS, 1997, he has not, and in the future he will not, contract or incur any debt or lillbility for which Wifc or her Estate might be responsible and shall indemnify and save Wife harmless from any and lIll claims and demllnds made against hcr by reason of debts or obligations incurred by him, " I I 2 5, OUTSTANJ>JNG .JOINT J>EIlTS: Husband and Wife lleknowlcdgc and agree tllllt they have no outstanding debls and obliglllions of the Husband and Wife including prior to the signing of this Agrcemcnt. cxccpt as follows: Item Pcrson Assuming Rcsnonsibilitv AT & T credit Card Account No. 539641002234 Ill/sbam/ Mellon Credit Linc Account No, 0275,040701-179 HI/sblllu/ Mellon Installmcnt Loan No. 0275,125-4006739 HI/sballd GMAC Car Loan No. 034060975505 Hl/sballd Balance of lcase of 817 Briarwood Lanc, Camp Hill Wife Hilton & Diminick (Orthodontic work for Jessica) Wife Each party agrees to pay the outstanding joint debts set forth hcrein and further agrecs to indemnify, defend, and save hannless the other from any and all claims and demands made against either of them by rcason of such debts or obligations, 6. MUTUAL RELEASE: Subject to the provisions of this Agreement, each party waives his or her rights to alimony and any further distribution of property inasmuch as the parties hereto agree that this Agreement provi,des for an equitable distribution of their marital property in accordance with the Pennsylvania Divorce Code of 1980, as amended. Subject to the provisions of this Agreement, cach party has releascd and discharged, and by this Agreement does for himself or hcrse1f, and his or her heirs, legal representatives, executors, administrators, and assigns, release and discharge the other of and from all causes of action, claims, rights or demands whatsoever in law or equity which either of the parties ever had or now have against the other, exccpt any or all causc or causcs of action for divorce and except in any or all causes of action for divorcc and exccpt in any or all causes of action for brcach of any provision of this 3 , , Agrecmcnt, Ench party nlso wnivcs his or hcr right to rcqucstmarilnl counseling pursoant to 23 7. ROtJITAnu: mSTIUnUTION OF MARITAL I'IWI'RRTY: Thc parties /' ~ ' J I, Pa, C.S.A. Section 3302. have allcmptcd to distributc their marital property in a manner which conforms to thc critcria set forth in 23 Pa. C,S,A, Section 3501, cl, scq., and taking into nccount thc following considerations: the length of marringe; the fact that it is the second mnrriage for Wifc and first marriage for Husband; the age, hcnlth, station, amount and sources of income, vocational skills, employability, estate, liabilities and needs of each of the parties; the contribution of cach party to " the education, training for increnscd earnings power of the othcr party; the opportunity of each party for future acquisitions of capital assets and income; the sources of income or of both parties, including but not limited to mcdieal, retirement, insurance or other benefits; thc contribution or dissipntion of each party in thc acquisition, preservation, depreciation or ') I , I appreciation of the marital property, including thc contribution of each spouse as a homemaker; the value of the property set apart to each party; the standard of living that the parties established ~ , in the marriagc; and the economic circumstances of each party at the time the division of property is to become effective. The division of existing marital propcrty is not intended by the parties to constitute in any way sale or exchange of assets, and the division is being effected 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 agrce that thcy have affcctcd a satisfactory division of the furniture, household furnishings, appliances and othcr household pcrsonal property between them and they mutually 4 :~ agrcc that cuch purt)' shull fromund uftcr thc dalc hcrcof bc Ihc solc and scparnlc owncr of all such tangihlc personul propert)' as listcd on Exhibit "A" allachcd hcrcto. Further, this Agrccmcnt shall havc cffect of an assignmcnt or bill of salc from cach party 10 thc othcr for such properly as may bc in thc individual posscssion of cach of Ihc partics hcrclo. 111C partics hereto have divided bctwecn thcmsclvcs to thcir mutual satisfaction, all itcms of tangiblc and intangiblc marital property, Ncithcr party shall makc any claims to any such itcms of marital property, or of thc separatc personal property of each othcr, which is now in thc possession and/or under the control ofthc othcr cxccpt as identified in Exhibit "A" to this Agrcement. Should it bccomc ncccssary, the parties each agrce to sign, upon request, any titlcs or documents necessary to give effcct to this paragraph. Property shall be dcemcd in the possession or undcr the control of eithcr party if, in the casc of tangible personal property, thc item is physically in thc possession or control of thc party at the timc of the signing of this Agrecment and, in the case ofintangiblc personal propcrty, ifany physical or written cvidence of ownership, such as passbook, chcckbook, policy or certificatc of insurancc or other similar writing is in the possession or control of the party. Husband and Wifc shall cach be deemed to be in thc possession and control of his or hcr own individual pension or other cmployce bencfits, plans or retirement bcnefits in any naturc with ihc cxception of Social Security Benefits to which cither party may have a vested or contingcnt right or interest at the time of the signing of'this Agreement, and ncithcr will make any claim againstthc othcr for any intcrest in such benefits. From and after the datc of thc signing of this Agreemcnt, both parties shall have the complete freedom of disposition as to hislher separate propcrty and any propcrty which is in their possession or control pursuant to this Agrccment and may mortgagc, scll, grant, convey, or 5 otherwise encumber or disposc of such propcrly, Whclhcr rcnlor pcrsonal, whclhcr such property wns nequircd beforc, during or nncr mnrringc nnd ncithcr IIusbnnd nor Wife necd join in, eonscnt to, or ncknowlcdge nny dced, morlgagc or olhcr instnllllcnl of thc olher pcrtaining 10 such disposition fproperly. B. nrSTIUIlUTION OF REAL ESTATE: 1l1crc is no rcal cstntc acquired by the parlies prior 10 dalc of scparation, C. TAX UAIlILITY: Thc partics belicvc and agrcc that thc division of propcrty hcretoforc made by this Agreement is a non-taxable division of property betwccn co- owncrs rather than a taxablc salc or cxchangc of such property, Each party promiscs not to takc any position with respect to thc adjusted basis of thc propcrty assigncd to him or her or with respect to any other issues whieh is inconsistent with thc positions set forth in the preceding sentences on his or Federal or Stalc Incomc Tax Return. 8. MOTOR VEHICLES: With rcspcct to thc motor vehicles owned by the parties, they agrce that Husband shall rctain the 1997 Pontiac Grand Am titled in the Husband's name which shall be the exclusivc property of the Husband. Wife shall receive the 1990 Pontiac 10. SUPPORT, ALIMONY PENDENTE LITE, ALIMONY: Both parties I ~f II i I ,), 1" ,'I; r, ,I. 'I'. 'I Grand Prix which is presently titled in Husband's namc. Husband agrees to transfer the title to thc 1990 Pontiac Grand Prix upon the execution of this agreemcnt. Once titled in Wife's name, the said Grand Prix shall be the exclusive propcrty of the Wife. '9, HEALTH INSURANCE: Aftcr the date ofenlry ofthc Decrce In Divorec, the parties shall be responsible for oblaining thcir own individual health insurancc coveragc, acknowlcdgc and agrec thai the provisions of this Agrecmcnt providing for equilable distribution of marital property are fair, adcquatc and satisfactory to thcm and arc acccpted by them in Iicu of L J .' 6 I r a full und finul sclllcmcnt and sutisfaction of uny claims or dcmands that cithcr may now or hcreinaftcr havc againsl thc othcr for sUJlPort, maintcnancc, or alimony. Husband and Wife / , , , ) furthcr, voluntarily and intclligcntly, waivc and rclinquish any right to scck from thc othcr any paymcnt for support, alimony Jlcndcntc Iitc, or alimony, 11. COUNSEL FEES, ANI> EXPENSES: Husband and Wifc acknowlcdge and agrce that thc provisions of this Agrccmcnt providing for thc equitablc distribution of marital property of the partics arc fair, adcquatc and satisfactory to thcm, Both partics agrcc to acecpt , the provisions sct forth in this Agrccmcnt in lieu of and in full and final scttlcmcnt and satisfaction of all claims and demands that cithcr may now or hcrcaftcr have against thc othcr for counsel fees or expcnscs or any other provision for their support and maintenance bcfore, during, and after the eommenccment ofthcse procccdings for divorcc between the parties. 12, INCOME TAX PRIOR RETURNS: The parties have hcreunto filed certain ,\ , I joint Income Tax Returns through and including Tax Year 1996. Thc parties represent and warrant to each other that thcy have heretofore duly paid all Income Taxes due on such rcturns; I , , and he or she does not owe any intercst or penalties with respect thereto; and that no tax deficiency is pending or threatened against him or her; and that no audit is pending with respect to any such return. If therc is any deficiency assessment on any of the aforesaid returns, the noticed party shall give the other immcdiatc noticc thereof, in writing. The parties further the amount ultimately dctennined to be duc, togcther with interest and pcnalties, if any, as well warrant that the party who has caused thc pcnalty, deficiency assessment, or interest, shall pay as all cxpenses that may bc incurrcd if he or shc dccidcs to eontcst thc asscssment, Further, the defieicnt party shall indcmnify, defend, and hold hann1ess that party who has not caused the said defieicncy, ~ 7 , ," I :\~ I, , I,' 13, WAIVF.RS OF CLAIMS AGAINST ESTATES: Exccptlls hcrcin othcrwisc r,; , i I ) providcd, cach pllrty may dcposc of his or hcr propcrty in IIny WilY, IInd cllch propcrty hcrcby waivcs and rclinquishcs any and 1111 rights hc or shc may now havc or thcrcaftcr acquirc, undcr thc prcscnt or futurc IlIws of any jurisdiction, to shllrc in thc propcrty of thc cstatc of the othcr liS a rcsult of thc marital rclationship, including without limitation, dower, curtscy, stlltutOry allowancc, widow's allowancc, right to takc intcstacy, right to takc against thc will of thc othcr, and right to act as Administrator ur Exccutor of the othcr's cstatc. Each will, at thc rcqucst ofthc other, execute, aeknow1cdgc, and dclivcr any and all instrumcnts which may bc nccessary or advisable to carry into effect this mutual waiver and rclinquishmcnt of all such intcrcst, rights, and claims. 14, MUTUAL CONSENT DIVORCE: The parties agree and acknowlcdgc that their marriagc is irretricvab1y brokcn, that thcy do not desire marital counscling, and that they both eonscnt to the cntry of a Dccree in Divorce pursuant to 23 Pa. C.S.A. Scction 3301(c), . I , , Accordingly, both partics agrcc to forthwith execute such conscnts, affidavits, or othcr ! documents and to dircctthcir respcctive attorneys to forthwith filc conscnts, affidavits, or other documents as may be neccssary to promptly procced to obtain a divorce pursuant to said Section 23 Pa. C.S.A. Scction 3301(c). Upon request and to the extent permitted by law, and thc applicable Rulcs of Civil Procedurc, the namcd Defendant in such divorce action shall execute any waivers ofnoticc or othcr waivcrs nccessary to expeditc such divorcc. It is thc intcntion of the partics that the Agreement shall survivc any action for divorce which may bc institutcd or prosecuted by eithcr party and no Ordcr, Judgment or Decree In Divorec, tcmporary, final or permancnt shall affcct or modify the financial terms of this 8 Agrcemcnt. This Agrccmcnt shall bc incorporutcd but shnll not bc mcrgcd with said Judgmcnl or Dccrcc of Finnl Divorcc, but slmll bc incorporutcd for thc purposc of cnforccmcnt only, 15, BREACH ANI) ENFORCEMENT: If eithcr party brcachcs any provision of this Agrccmcnt, thc othcr party shall havc thc right, at his or hcr elcction, to suc for damagcs for such breach, or scck such othcr rcmcdics or rclief as may bc availablc to him or hcr, and thc party brcaching this Agrccmcnt shall bc rcsponsible for paymcnt of attorncy fccs, Icga1 fccs and costs ineurrcd by thc othcr in cnforcing his or hcr rights undcr this Agrccmcnt. 16. ADDITIONAL INSTRUMENTS: Each of thc partics shall from timc to timc, at the request of the other, exccutc, acknowlcdge and dclivcr to thc othcr party any and all furthcr instruments that may bc rcasonably required to givc full force and cffcct to the provisions ofthis Agreemcnt. 17, TAX ADVICE: Both partics hercto hereby acknowledge and agrcc that they have had the opportunity to retain thcir own accountants, ecrtified public accountants, tax advisor, or tax attorncy with refcrcncc to tax implications of this Agrcemcnt. Furthcr ncither party has been given any tax advicc whatsoever by their respectivc attorneys. Further, both parties hereby acknowledge that they have been advised, by their rcspcctivc attorneys, if any, to seek thcir own indcpcndent tax advice by retaining an accountant, ccrtified public accountant, tax attorney, or tax advisor with refcrence to the tax implications invo1vcd in this Agreement. Furthcr, thc parties acknow1cdgc and agrec that thcir signatures to this Agrccmcnt scrvc as thcir acknowledgmcnt that thcy have rcad this particular paragraph and havc had thc opportunity to scck indcpcndcnt tax advice. 18. VOLUNTARY EXECUTION: Thc provisions of this Agrccment and thcir Icgal cffcet havc bccn fully cxplaincd to thc partics by their rcspcctive counscl, and cach party 9 I' t I':, ncknowlcdgcs tllllt thc Agrccmcnt is fair and cquilnhlc, tlmt it is bcing cntcrcd into volunlnrily, , , with the full knowlcdgc of thc usscts of hoth pnrtics, und t1ull il is not thc rcsult of uny durcss or , , , i unduc innucncc, 'Illc partics acknowlcdgc Ihut thcy havc bccn furnishcd with all infonnation ) ~ ' relatcd to thc finnncialuffnirs of thc other which has bccn rcqucstcd by cach of thcm or by thcir rcspcctivc counscl. 19. ENTIRE AGREEMENT: This Agrccmcnt contains thc cntirc undcrstanding of thc parties. Thcrc are no representations, warrantics, covenants, or undcrtakings 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 1 I , I have against the other for equitable distribution of their property by any Court of competent jurisdiction pursuant to 23 Pa. C.S.A. Section 3501, et. seq., or any other laws. Husband and i , , Wife each voluntarily and intelligently waiver or relinquish any right to seek a court ordered tcrmination and distribution of marital propertY but nothing herein contained shall constitute a waiver of either party of any rights to seek the relief of any Court for the purpose of enforcing thc provisions of this Agreement. 20. DISCLOSURE: Husband and Wife each represent and warrant to the other that ~ I he or shc has made full and complete disclosure to the othcr of all assets of any nature whatsoever in which such party has an intcrest, the sources and amount of income of such party or cvcry type whatsoever and of all other facts relating to the subjcct matter of this Agreemcnt. 10 '~ 21. MOIHFICATION ANn WAIVlm: Modificnlion IInd wniver of any othcr ,\1 ( " ~, , I' I" ...\0, ( , V' , 1 provisions of this Agrccmcnt shnll bc cffeelivc only if madc in writing and cxccutcd with thc snmc formnlity of this Agrccmcnt. Thc failurc of cithcr pnrty to insist upon strict pcrformancc of any of thc provisions of this Agrccmcnt shall not bc construcd as a waivcr of any subsequcnt dcfault ofthc samc or similar naturc, 22, PRIOR AGREEMENT: It is undcrstood and agrccd that any IInd all propcrty settlcmcnt agrccmcnts which may havc bcen cxccutcd prior to thc datc and timc of this Agrccmcnt arc null and void and of no cffcct. , 23. DESCRIPTIVE HEADINGS: The deseriptivc headings uscd hcrein are for eonvcnienee only. They shall have no cffcct whatsoevcr in detennining thc rights or obligations 24. INDEPENDENT AND SEPARATE COVENANTS: It is specifically of the parties. understood and agreed by and bctwecn the partics hcrcto that cach paragraph hereof shall be I , ! dcemed to be separate and independcnt covenant and agrecment. 25, APPLICABLE LAW: This Agrccmcnt shall be construed undcr the laws of the Commonwealth of Pennsylvania. 26, VOID CLAUSES: If any' tenn, condition, clause, or provision of this Agreement shall be dctennined or declared to be void or invalid in law or otherwise, then only that tenn, condition, clause, or provision shall be stricken from this Agreement and in all other respects this Agreement shall be valid and continue in full forcc, effect and operation. 27, AGREEMENT BINDING ON HEIRS: This Agreement shall be binding and shall inure to thc bencfit of the parties hercto and thcir rcspective heirs, executors, administrators, succcssors, and assigns. It >. 0' r~ '" i~~ , tLJC~ t'~ i4'j:T:: ()"" \ .I ..., [' C' :;1;:. 1_ :J .- C)I-: , :! ~:l J CJ .'" t..:): : '" . .~ 'r.? C" ' . uJu. ,-;: <; ~~IU~ ;... I ;-'j,j L.1.. ", ..,", " ~ ".-j.. I' ::;- 1,- a~ :::i 0 C,;\ U .....,~/ GREGORY A, ULP, 1'lalntlIT : IN TilE COURT OF COMMON nEAS : ClJl\lIJERLANO COlJNTY,I'A V5. : NO, 98-977 CIVIL TERM KIMBERLY A. CASTLE, Dcfcndant : IN DIVORCE I'RAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Kindly t.ransmit the rccord, togcthcr with thc following information, to thc Court for cntry of a divorec dccrce: 1. Ground for divorcc: irrctrievablc brcakdown undcr Scctlon 3301(c) of thc Divorce Code. 2, Date and manner of service of thc complaint: Fcbruarv 25, 1998 bv Ccrtlficd Mall. Rcstrlctcd Dcllvcrv, U.S. Postal Scrvlcc. 3. (Complcte eithcr paragraph (a) or (b),). a, Date of cxccution of the affidavit of consent requircd by Scction 3301(c) of the Divorce Code: by plaintiff on Mav 31.1998; by defendant on ,Junc " 1998. b. (I) Date of exccution of the affidavit requircd by Scction 3301(d) of the Divorce Codc: (2) Datc of filing and servicc of the plaintiffs affidavit upon the defcndant: 4. Rclated claims pending: NONE 5. (Complcte cithcr (a) or (b),) (a) Date and manncr of scrviec of the noticc of intention to file praccipe to transmit record, a copy of which is attached: (b) Date plaintiffs Waivcr ofNoticc in Scction 3301(c) Divorce was filed with the Prothonotary: Mav 31,1998. Datc defcndant's Waivcr ofNoticc in Scction 3301(c) Divorce was filed with the Prothonotary: Junc 1. 1998. Datc: (/J 1. JVN "I ~ \ L A MARIE COYNE, E /tomey for Plai/l/iff .-' ..-.- >- co r-: IT, is z ~g ..:J :::J or.1~ 0=,' u:: ?~, - u;? ..... ~~ Cl.. C)~ 2 co :~;.- "l t.J1 lJ.. I ....1.,:, a;LU 2: I:r:z :1: ::> MjUJ t- -.. ~~ a.. 1.1. ..~ 0 ro ::> 0> Q GREGORY A, ULP, Plaintiff, vs. : IN TilE COURT OF COMMON PLEAS OF : CUMIlERLANI> COUNTY, PENNSYLVANIA : NO.qJ ~ (/ 77 CIVIL TERM , KIMIlERL Y A. CASTLE, I>crcndant. : IN mVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have becn sucd in court. If you wish to defcnd againstthc claims sct forth in the following pagcs, you must takc prompt action. You are wamcd that if you fail to do so, thc case may procecd without you and a dccrcc of divorce or annulmcnt may bc cntercd against you by the court, A judgmcnt may also bc cntercd against you for any othcr claim or relief rcqucstcd in thcse papcrs by thc plaintiff, You may lose money or propcrty or other rights important to you, including custody or visitation of your children, When thc ground for the divorce is indignities or irretricvablc breakdown of the marriage, you may rcquest marriage counseling, A list of marriagc counsclors is availablc in the Office of thc Prothonotary, Cumberland County Courthouse, I Courthousc Squarc, Carlislc, P A 17013 '\ ; \ , I IF YOU DO NOT FILE A CLAIM FOR ALIMONY, mVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES IlEFORE A mVORCE 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, TO GET LEGAL HELP YOU SHOULD CONTACT: Cllmberlalld COllllty Lawyer Referral Service 2 I.iberty Ave/l/le, Carlisle, Pellllsylvallia 1-(800)-990-9108 sa a Ie Coync, . squirc 390 I Markct Str t Camp Hill, PA 17011-4227 (717) 737-0464 Pa.. Suprcmc Ct, No, 53788 AI/omey fot' Plaill/iff I l, I : ( I , , ~, i\( ~\'! I' h ~: I I i I VERIFICATION '" The facts set forth in the foregoing are true and correct to the best of the undemigned's knowledge, information and belief and are verified subject to the penalties for unsworn falsification to authorities under 18 Pa. C,S.A. 64904. l Dated: tf ~I; g )< .~ , I i ~ >- 5-1: "" LL'O. (..J-"" r.c ~l) ll..r~ 9r;' ~,,:' u:P:, r.: u. o ~ cr. c"': r; .0 .~.. N ::ir '... o~, (1.: :..J ;.-.= ,::':~~ '.r. :":"; J"O.- cd ~ IJ .,'-1.. -- ;:) u C> N ro I. oJ I.l.. 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