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HomeMy WebLinkAbout98-01655 .), VI ... tv ;,..... ('" ,: '1 > vi III ~ ;r- ~ .! J i I I / / , . ~ \. ~l ,. ~- . ';) - CJ ~ ~ ~ ,..~ .;;:,;;,;, . I , , S:IWPOOCSIDOMESTICIMSAlmyers.'es,.ms.. wpd Oclobe, 27,1999 MARITAL SETTLEMENT AGREEMENT THIS AOREEMENrr, mado this f)J~dIlY of ~lUt~~, H)!)O, by and betweon LESLIE D. MYERS of Enola, Ponnsylvania, (hol'oinafter "WIFE") and NINO MYERS of Summerdale, Pennsylvania, (hominaftol' "HUSBAND"); WIT N E SSE T H: WHEREAS, tho parties hOl'eto WOI'O married on Docemhor 12, 1!JfJ2 in Cumberland County, Pennsylvania; and WHEREAS, a divorco action was filed by WIFE on 01' ahout Mfll'ch 25, 1f)f)8, in the Cumberland County Court of Co 111m on Pleas at 98.1(;55 CIVIL ACTION .LAW; and WHEREAS, difficulties havo arisen betweon the partills and it is therefore their intention to live separate and apart for the I'ost of their livos and tho pHl'ties are desirous of settling completely tho economic and othol' rights and obligations betwoen each other, including, hut not limited to: the equitahle distribution of the marital propel'ty; past, pl'osent and future support; alimony, alimony pendente lite; and, in general, any and all other claims and possible claims by one against the other or against their respoctive estatos; and NOW THEREFORE, in consideration of tho covenants and pl'Omises hereinafter to be kept and perfOI'mod by each party and intending to bo legally bound hereby, the parties do hereby agree as follows: Page 1 of 9 S:IWPDOCSIDOMESTICIMSAlmyo,..le.l.msa,wpd October 27, 1999 ' 1. ADVICE OF COUNSElL. The provisions of this agreement and theil'legal offoct havo hoen fully oxplainod to tho parties by their rospoctive counsol. WIFE is I'(\presontod by Dobra Denison GHntol', Esquire. HUSBAND is reprosented hy Potor J. RltSSO, Esquire. The pfllties further doclaro that oach is oxecuting the Agreemont freely and voluntarily having either obtained sufficient knowledge and disclosurfl of their respoctive legal rights and obligations 01', if counsel has not heen consulted, expressly wHiving the right to obtain such knowledge. The parties each acknowledge that this Agreement is fail' and equitablfl and is not the result of any fraud, coercion, duress, undue influence OJ' collusion. 2. PIVORCE ACTION. The parties acknowledge that their mHl'I'iage is irretrievably bl'Oken and that they shall secure a mutual consent no fault divorce pmsuant to ~ 3301(c) of the Divorce Code. The parties agree to execute AffidHvits of Consent for divorce and Waivers of Notice ofIntention to Request Entry of a Divorce Decree concurrently with the execution of this Agreement. This Agreement shall remain in full force and effect after such time as a final decree in divorce may be entered with respect to the parties. The parties agree that the terms of this agreement shall be incorporated into flny Divorce Decree which may be entered with respect to them and specifically referenced in the Divorce Decree. This Agreement shall not merge with the divorce decree, but shall continue to have independent contractual significance. 3. DATE OF EXECUTION. The "date of execution" 01' "execution date" of this Agreement shall be defined as the date upon which it is executed by the parties if they have each executed the Agreement on the sallie date. Otherwise, tho "date of execution" 01' "cxecution date" of this Agreement shall be defined as the date of execution by the party last executing this Agreement. Page 2 of 9 S:\WPDOCSIDOMESTICIMSA\myors.losl.nlSlI,wptl October 27,1999 4. MUTlJAL RELEASES. Each party absolutely and unconditionally releases the other and the estate of the other fl'om any and allrij:(hts und oblij:(ations which oither may havo for past, prOflOnt, 01' future obligations, arisinj:( out of the marital relationship 01' otherwise, including all rightfi and benefits under the Pennsylvania Divorce Cede of WHO, and amendments except as defJcribed herein. Each party absolutely and unconditionally releases the other and his 01' her heirs, executors and estate from any claims arising by virtue of the marital relationship of the parties. The above release shall be effective whether such claims arise by way of widow's er widower's rights, family exemption, 01' under the intestate laws, 01' the right to take against the spouse's will, 01' the right to treat n lifotimH conveyance by the other as testamental'y, 01' all other rights of a surviving spouse to participate in n deceased spouse's estate, whether arising under the laws of Pennsylvania, any state, Commonwealth, 01' territory of the United States, 01' any other country. Except for any cause of action for divorce which either party may have 01' claim to have, each party gives to the other by the execution of this Agreement an absolute and unconditional release from all claims whatrlOever, in law 01' in equity which eithel' party now has against the other. 5. FINANCIAL AND PROCEDURAL DISCLOSURE. The palties confirm that each has relied on the accuracy of the financial disclosure of the other as an inducement to the execution of this Agl'eement. Each party understrmds that he/she had the right to obtain from the other party a complete inventory 01' list of all propelty that either 01' both parties owned at the time of separation 01' cU1'renUy and that each party had the right to have all such property valued by means of aJlJll'llisals 01' otherwise. Both parties understand thut they have a right to have a court hold hearings and make decisions on the Page 3 of fJ '...;' S:IWPDOCSIDOMESTICIMSAlmyo".,os,.m... wpd Octobor 27, 1999 . mutt(lI'S covered by this Agroement. Both p/ll'ties horoby ucknowledge that this Agrooment is filiI' IInd oquituble, und thut tho tOI'ms adequatoly provide 1'01' his 01' hor interests, and that this Agreoment is not u result: of frflud, duross or unduo inf1uenco exercisocl by oither party upon tho othor or by flny person or porsons upon oither party. 6. SEPARATION/NON INTERFERENCE, WIFE und HUSBAND muy and shull, nt all times h(1reafter, Iivo separate ancl apart, They shall bo free from any interforence, direct or indirect, by tho othor in all respects liS fully us if they were unmal'l'ied, Each may, for his 01' her lJepal'ate uso OJ' benefit, conduct, carryon and engage in any business, Occl.lpation, profes~Jion or cmployment which to him or he" may seem advisablc, WIFE and HUSBAND shall not hamss, disturb Ol' malign each other or the respective families of each othor. 7, REAl, PROPE~TX. The partios are not ownors of any roul proporty. 8. DJJ;BTS. Euch party has made payments on back taxes, Said parties agrc;e that theso puymonts wero fuir and oquitablo. Tho romaining taxes have boon assumed by WIFE undor I a consolidution loun plan and WIFE agroes to bo solely rosponsiblo for said dobt. Tho partios incurrod a joint debt with Nations Credit for the purchuse of HUSBAND's vehicle. WIFE hereby agrees to bo sololy responsible for suid debt and to indemnify und hold HUSBAND harmless from suid debt. HUSBAND represents and warrants to WIFE thut since the sepurution he has not, und in the future he will not, contl'Hct or incur any dobt or liability fill' which WIFE or hel' estate might be responsible, and he shall indemni(y and save WIFE harmless from IIny IInd all Page 4 of fJ S:IWPDOCSIOOMESTICIMSAlmyers.le.l.msa.wpd Oolober 27, 1999 claims 01' domllnds mado against her by reason of such debts 01' obligations incurred by him sincl) the date ef said sepal'Ution, excopt aB otherwiso sot forth horein, WIFE represents and warrants to HUSBAND that, since tho separatien she has not, and in the future she will not, contract 01' incur any debt er liability for which HUSBAND 01' his estate might be responsible, and she shall indemnify and save .HUSBAND harmless from any and all claims or demands made against him by rOfwon of such debts 01' obligations incu1'l'ed by her since the date of said separation, oxcept as otherwise sot forth hOl'Oin, 9, RETIREMEN'!' BENJj:FITS HUSBAND is the owner of a profit sharing plan thl'Ough his employer valued at approximately Ten Thousand ($10,000) Dollars. WIFE had ownership ofMerk Stock from her employer valued at approximately Ten Thousand ($10,000) Dollars. HUSBAND waives his right, title and interesL to WIFE's Merk stock and its ]Jl'Oceods. WIFE heroby waives her right, title and interest to HUSBAND's profit sharing plan. 'I'he parties waive any and all other rotirement benefits obtained by the parties post separation. 1'he individual who holds said benefits shall own the property solely and individually. Each party waives their right to title and interest to the other party's benefit. 10. BANK ACCOUNTS. The parties aeknowledge that they have divided the marital bank accounts to their satisfaction, The bank accounts held solely in individual names shall become the sole and separate property of the party in whose name it is registered, Each party does hereby specifically waive nnd release his/her right, title find interest in the other party's respective nceounts. Page 5 of 9 S:IWPOOCSIOOMESTICIMSAlmyers-losl.ms..wpd Ootober 21, 1999 . 11, 1>.E8SP..NALL,PROPERTY. 'rho pal'tioH horoto mutually all.l'oe that they have divided all fu l'Il it. lIl'O , hOllH(,hold furnishingH Ilnd perAonal property bet.ween t.hem in a manner agreeablo to both partios. 'rhe pllrtios mutuully agroe that each party shall from and after the date of thi~l Agroemont bo tho sole and separato owner of all tangiblo pOl'sonal property in hiB 01' her pOHHession. 12. VEHICLES. WIFE is the owner of a 1ll!l4 Saturn pUl'chased post-separation. HUSBAND iH the owner off a 1996 Mazda 626 purchused post.separation, Each party heroby waives any right, title and int.erest in said vehicleB, 13. ALIMONY. SJJ~PORT. AND ALIMONY PENDENTE LITE The parties hereby expressly waive, release, discharge and give up any and all rights 01' claims which either may now or hereafter have for spousal support, alimony pendente lite, alimony, or maintenance, The parties further release any rights that they may have to seek modification of tho torms of this Agreement in a court oflaw 01' equity, with the understanding that this Agreement constitutes a final determination for all time of either party's obligations to contribute to the support 01' maintenan(:e of the other. 14, ATTORNEY FEES. COURT COSTS. Each party hereby agrees to be solely responHible for his 01' her own counsel fees, costs and expenses. Neither shllll seek any contribution thereto from the other party except as otherwise expressly provided herein. 15. ATTORNEYS' FEES FOR ENFORCEMENT. In the event that either party breaches any pl'ovision of this Agreement and the other party retains counsel to assist in enforcing tho terms thereof, tho breaching pUl'ty will pay ll11roasonahle attornoys' foos, court costs IInd exponses (including interest and \:t'avel costs, Page G of' !l .,' S:IWPOo'CSIOOMESTICIMsAlmyur..I.sl ."'s.' wpd October 27, 1999 COMMONWEALTH OF' PENNSYLVANIA : SS, COUN'rY OF CUMmmLAND On tho .-J.-J-- day of AhL'C ." (".,- . _ ., WOO, boforo mo, a Not.ary Public in nnd for tho Commonwonlth ofPennsylvaniu, tho undorsignod officer, personally appeal'ed LESLIE D. MYERS, known to me (01' satisfactorily proven) to bo one of the purties oxecut.ing tho foregoing instrument, and sho acknowledges the foregoing instrument to be hor freo uct and deed. IN WITNESS WHEREOF, I have hereunte set my hand and notarial seal the day nnd year first above written. (/JeJVnC(L (;1 J(.,c/ Netary Public My Commission Expires: , I NOIAHIAI SlAt P!RMA I HOCII. NOIAHY PU~lIC AIItNIOWN, lEIlllill COllNtY. PA MY COMMISSION rXl'lIllS r [II II. 1001 COMMONWEALTH OF PENNSYLVANIA :SS. COUN'I'Y OF On the _~~day of ~O"'EMeER- ,199.9., before me, n Notnry Public in and for the Commonwealth of Pennsylvania, the undersigned officer, personally appeared NINO MYERS, known to me (01' satisfactorily pl'Oven) to be one of the parties executing the foregoing instrument, and he acknowledges the foregoing instrument t.o be his froe act and dood. IN WITNESS WHEREOF, I have horeunto set my hnnd and not.arial seal t.ho day and year first above written. j~) /~"" /J / ;.-- '-.-::.---;. .,~ Not.ary Public My Commission Expires: - \ NOTARiAl SEAL ROSIE M. BURTON. NOIaIY public CarIlGl.. Oumblr1'nd.~aoo3 My oommlllllon ElcpIlM .....V y, Page 9 of 9 ElItl"e9L ILILI Z*"HOL~ Vd 'lllH dv-4VO 1iI3YJ.9 J.3~YVW l EEZ M'I1 J.V SA3NYOllV 'Od 'Y310V 111 YilPVilY 111 ('d ">-~ ''"'' 1:.:; [}: (,:) ,- ; I.U~ ) ( , ( rf Ci , I CI [', , ("; ': , , t'i:: .1 ( I ,.l, , (~ I , 0 , c> (.,j .. ~ LESLIl1 0, MYERS, Plainliff; : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, I'ENNSYLV ANIA v, NO, 98.1655 NINO MYERS, Defendunt. CIVIL ACTION - LA W IN DIVORCli I'UAELll'ETILI'BA~SMITREC()RI> TO THE PROTHONOTAR Y: Trnnsmit the record, togelher with the following infomlation, to the court for enlry of un appropriute divorce decree: I. Ground for divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2, Date and manncr of scrvice 0" comlllaint: The Complaint was med on March 25, 1998 and was served on Nino Myers by certilled mall on March 28. 1998, 3. (Complete either pllragraph (a) or (b).): (0) Date of execution of the aftidavil of consent required by Section 3301(c) of the Divorce Code; by Plaintiff November 27. 1999; by I>efendant December 14, 1999, (~-.,\;)a\e-Qt:.U~~~flda~iI-l~quustUd..by_!i-~j).1(df.o,Llhe..Dl"OlCt:..code: -------------------------~ fJ1--Bftl&--ef-Hlillg-!lfld.-6ef'o'ie&-ef.-1he-..pjaifKHj:'tl_at:f1dllv#-.R_lhe-~Q~ ---------------------- --------- 4, Related Economic Claims Pending: There are no economic claims pending as the distribution of all personal and real property has been settled by agreement of the pal'tles. 5. (Complete either (a) or (b).) fa+---.,\;)ale-aOO.lll3M<ll'~.j;U~Ilt:ihe.~Ilt:.intUllUaJ~Io.iile.P~ipe..to.~wit ~9~~k~tl~<<1I~_____________________~ (b) Datc Plaintiff's Waiver of Notice in ~ 3301(c) Divorce was filed with the Prothonotary: December 20. 1999. Dale Defendant's Waiver of Notice in ~ 3301(c) Divoroe was filed with the Prothonotury: December 20.1999. Respectfully Submitted: REAGER & ADLER, P.C. Date: Decembcr 20, 1999 / B( C:IOFFIC(IWPWINIWPDOCSIDOMESTICICOMPLAINIMYEASL.CMP Maroll 24, 1096 . , RI';MlER & AUUIR,I'C lIY: mmRA UENISON CANTOR, ESQUIRr~ Allol'lley J.D. No. 6637H 2JJ I Murket Street CUlllp IIill,l'A 17011 Telephone: (717) 76J-1 .lID Allorncy.~ It)r Plaintiff LESLIE D. MYERS, : IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA : NO. ft, /t-55 cwJ~ CIVIL ACTION - LA W Defendant DIVORCE NOTICE TO DEI<'END AND CLAIM RIGHT1'i Plaintiff v, NINO MYERS, 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 arc warned that if you fail to do so, the case may proceed without you ,1I1d a decrec of divorce 01' annulment may be entered against you by the COUl'l. A Judgment may also be entered against you It)r any other claim 01' relief requested in these papers by the Plallltiff. You may lose money 01' property 01' other rights important to you, including custody 01' visitation of YOUI' children, When the ground for the divorce is indignities 01' irretrievable breakdown of the marriage, you may request mal'f'lage counseling. A list of marriage cOl:nselors is available in the Office of the Prothonotary, Room 101, Cumberrand County C01ll1house, I Courthouse Square, Carlisle, Pennsylvania. ~ Wy~:R~ ~~llgIl\;t~k~~~lJ>JMkk~O~vJ>A~WWRNBrNJ~'tW~i'~ GRANTED, YOU MA Y LOSE THE RIGHT TO Cl,AJM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LA WYER AT ONCE. IF YOU DO NOT HAVE A LA WYEI{ OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH lIELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumbcrland County Lawyer Referral Service COUl'l Administl'lltor South Hanover Street Carlisle,PA 17043 (717) 240-6200 I C:IOFFICEIWPWINIWPO(JCSIOOMES T1CICOMPLAIN\MYE nSL,CMP Muroh 24, 10U8 REAGER & AnUII{ PC IIY: /lEIIRA D1INf.1l0N CANTOR, ESQlIlRE Allol'l1cy I.D. No, 663711 2331 MlIrket Strcet ('limp lIill, PA 17()1 I Telephone: (717) 763- I .'1113 Allol'llcys for Plaintiff LESLIE D. MYERS, : IN THE COURT OF COMMON PLEAS :CUMBEftLAND COUNTY, PENNSYLVANIA : NO. 9 f' - /(,. 5',>f; ~r;.<,- CIVIL ACT/ON - LA W DIVORCE Plaintiff v. NINO MYERS, Defendant COMPLAINT IN DIVORCE UW..ER ~ 3301(C) OR (0) OF THE m\::QRCE COQE I. Plaintiff is Lcslie D. Myers who currcnlly resides at 3 North EllOla Drive, EllOla, Cumberland County, Pennsylvania, 17025. 2. Defendant is Nino Myers who currently resides at 114 Summer Lane. Summerdale Cumberland County, Pennsylvania, J 7025. 3. Plaintiff and Dcfendant have been bona fide residents in the Commonwealth for at least six (6) months immcdiately previous to the filing of this Complaint. 4. The Plaintiff and Defcndant were married on December 12, 1992, at Carlisle. Pennsylvania. 5. There have been no prior actions of divorcc or for annulmcnt bctwcenthc parties. 6. Neither Plaintiff nor Defendant is inlhe military or naval service of the Uniled States or ils allies Wilhinthe provisjons of the Soldiers' & Sailors' Civil Rclief Act of the Congress of 1940 and its amendments. 7. Plaintiff avcrs thaI thcrc arc no childrcn of Ihis marriage. 8. Thc marriagc is irrclrievahly brokcn. 9. Plainliff has hecnadvi~cd Ihat counseling is availablc and that Dcfendant may have the right 10 requcst thaI thc court rcquirc thc parlics to participatc in counseling. C:\OFFICEIWPWINIWPDOCSIDOME STICICOMPlAINIMYEASl. CMP March 24, 1998 ". forth. 10. Afwr ninety (l)O) days havc elapscd til1mthc date of the filing of this Complaint. Plaintiff intends to file an Affidavit eonscntlng to a divorce. Plaintiff hellevcs that Defcndant llIuy ulso /llc sueh unuffiduvit. WHEREFORE.Pluintiff respectfully requests tlw Court to cntcr u decrec of divorce pursuunt to Section 3301 (c) or (d) of the Divorce Codc. COlINTI INDIGNlTm~ II. Puragraphs one (I) through ten (10) arc incorporated herein by reference as If fully set 12, In violation of Defendant's marriage vows and the laws of this Comlllonwealth. the Defendant has offered such indignities to the person of the Plaintiff as to render her condition intolerable und life burdensome. WHEREFORE. Plaintiff respectfully requests the Court to enter a decree of divorce purSUant to Section 330 I (a)(6) of the Divorce Code. COUNT II ADULTERY 13. Parugl'llphs one (I) through twelve (12) of this Complaint lire incorporated herein by refel'ence. 14. Through the ('ourse of the murriuge. Defendant engaged in adulterous affairs to the detriment of the marital relation. WHEREFORE. Plaintiff respectfully requests the court to enter a decree of divorce purSUant to ~330 I (a) of the Divorce Code. 2 C:\OFFICE\WPWINIWPOOCSIOOMESTIC\COMPLAINIMVERSL. CMP MRrch 24. 1996 ". COUNT IU EQ1iITAnu~ I>ISTRIIJUTION IS. PUl'llgruphs one (I) through li)urtcen (14) of this COll1pluintarc incorporatcd hcrein hy refcrcncc. 16. Pluintiff and Dctimdanl have acquil'ed property, holh realund pcrsonal, during their Il1IIlTiagc. WHEREFORE, Plaintiff respectfully rcquests this Honorable Court to equitubly divide ull murilal properly und deht. COIJNUY AUMONY PENI>ENTE LITE. ALlMON):: 17. Puragraphs one (I) through sixteen (16) urc incorporated herein as if fully sct forth. 18. Pluintiff lacks sufficient property and resources to provide for her reusonuble means during the course of litigulion. 19. Pluinliff requires reusonuble supporllo udequutely muintain herself in accordunce with the slundard of liVing estuhlished during the murriuge. 20. Defendunt has sufficient funds to muillluin Plaintiff. WHEREFORE, Pluintiff requests this Honorable Court to enter unuwurd of alimony pendente lite until finul hearing and thereupon to enter un order of ulilllony in her fuvOl'. illl!NI..Y COUNSEL FEES 21, Pal'llgruph one (I) through twenty (20) are incol'poruted herein as if fully set forth. 22. Plaintiff has employed Dehl'll Denison Omtor, Esquire, us counsel but is unable to pay the necessary und reusonable ullorney's fees for said counsel. 23. Pluinliff is in need of hiring various experts to uppraise the parties' lIluritalussets und does not huve the funds to puy the necessary und reusonuble costs. 24. Defendunt has sufficient funds to puy Pluintiff's fees unci costs. 3 . .. ~i i ,>. to. ,. ~ lr .,) f:; i~ : ' .. . ,I ,.r r-, ('" ( /:".. ~ *t ) ~It~ ' ~-'~ ),"-. . ii. '''-Ll d. "':.:", r1 I. j (J... ~ -~, f \ ~ (,I '. In ,-:' Ii} ~ (j'I': ,..J .. ~ ~ 'f (,_. : .I>J \ G.,t_:.! ", ,\n.i ~ ~ I .1" "j 1\) ~ .' t~) () .~ c.' ('r\ \t) ~ ~ 1l l . \S \ ~ \/) \) ~ ~j f\ \) ~ " '0 ro , ' lC!~J ej~~~i ~il!~ " "l;:: m !!; ~<(a~ ."O'tllt.'....nl'~ H."lt.,~O-t.., J'JJ"u.,..,.. OHIWO~-OOA~1YO ... ..... LESLIE D. MYERS, : lN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. NO. 98-1655 NINO MYERS, CIVIL ACTION - LAW Defendant IN DIVORCE AF'FIDA VIT QE..coNSEN1 I. A Complaint in divorce under section 3301(c) of the Divorce Code was filed on March 25, 1998. 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. 1 consent to the entry ofa final decree of divorce after service of notice of intention to request entry of the decree. 4. I understand that I may los~ "ight~ :;;Jl1ccrning alimony, dh'ision of prop crt)'. Iawyor's fees or expenses if I do not claim them before a divorce is granted. 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. 9 4904 relating to unsworn falsification to authorities. Dated: I" ~ . I q .. '1 c7 '-., 1 . ,'" .~, LESLIE D, MYERS, : IN TIlE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, I'ENNSYL VANIA PlaintilT v. NO. 98-1655 NINO MYERS, CIVIL ACT/ON - LA W Defendant IN DIVORCE !YAIVRR OE..NOTICR OF INTI~NTION TUBEQImST El'IIRY.m: A OIY.ORCE..llECREE UNDF:R SECTION 3301 (C)..QF 'I'm: DIVORCE CODF; 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if ( 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, Dated: I (-~l-q~ rJH,l(tD~yr!JS'fUL -,.. ..:I' C: c'''' ~ji ,-...! .-:;~ ~' ~ -. lI.1r.? ..;1 .:) ': ) ('". ..~'" , 8' (. t- J ( ~.. t:ilt: ('..J G" .,.\ L_. I ----Jll. C'.' t).:. ' (l; f" ..... ll.. (0 ,) 0 (..,r\ () N ~~l;;! ; ~i.Ji ~ ! 08 u " a: ::l" l!lo :1:1:: ~~a~- , , . tl.~Ulll tt. ~O"ll" '1.'CI I U, ".1'1101 U ONIWO,j'OOAloWne -,.0,' I1n.'n. KARL MARCHUT, Plaintiff v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 98.1684 CIVIL TERM TERESA S. MARCHUT, Defendant : IN DIVORCE CER'fIFICAT.E OF SERVICE I, Erin Pharris, hereby certify that a true and correct copy of the Complaint Under Section 3301(c) of the Divorce Code, as well as a true and correct copy of the Petition for Special Relief, in the above captioned matter were duly served upon Bradley L. Griffie, Esq., counsel for the defendant, by depositing them in the U.S. Mail, on April 1, 1998, first class, postage prepaid, addressed as follows: Bradley L. Griffie Griffie & Associates 200 North Hanover Street Carlisle, PA 17013 I hereby verify that the statements made in the foregoing are true and correct, I underst,and that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Dated: Lfl} I~ (lUll) PIYAiJ?i,l' Erin Pharris -,.. ".0 ..,.. b; C"J (.. r:.t ~z. .. -;'-1 UJ~: \'1 -.I ( ) .~"'~ '1::(-) (.\,.... t\.; "-t',lr--, '.",1 'i' " \:',,'. Ul" I , .' dl_i ".' \i'lril (.l.,'" (.'l_ i'.;-'L~ (' .:X '~:\ .- 1.1.. ~:D 0 0' '~_I t8tl.t8L (LLL) ~Hlv'LLOLL Vd '111H dWV:l U3YiS i3~IIVW ltt~ M\fl i'l/ SA3NIIOll'l/ 'O'd '11310'1/ " 113D'l/311 1\" (") ',.~ ,. .lei ('. I,." j','.1: .. I c' (~i u; '. , !: p: J, ('it:" (:J G' n;~-,: ("~,i [:/ C UJ ,--, ,. 1.1 (f) 0 en .