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HomeMy WebLinkAbout98-01656 V V? 0 F ? q V e? 4 i r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA• ? y v+lla ' "+ GARMAN E. DIXON, Plaintiff VERSUS MELANIE ANN DIXON, N O 1998-1656-C3V Defendant DECREE IN DIVORCE AND NOW,__ M Z64 IT IS ORDERED AND DECREED THAT CARMAN E. DIXON PLAINTIFF, AND MELANIE ANN DIXON ARE DIVORCED FROM THE BONDS OF MATRIMONY, DEFENDANT, 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; N/A BY THE COURT; 4---a ATTESV /I 1 (17 J• PROTHONOTARY ,. ?, ? `'?' '. THIS AGREEMENT, made and entered Into this :)",`Iday of 1 e`,n. c if, 2004, by and between GARMAN E. DIXON, currently of U.S. Embassy Box 33, APO AP 96546, hereinafter referred to as "HUSBAND", AND MELANIE ANN DIXON, currently of 3004 Warren Way, Mechanicsburg, Pennsylvania, 17050, hereinafter referred to as "WIFE". WHEREAS, diverse unhappy differences, disputes and difficulties have arisen between the parties and It Is the Intention of HUSBAND and WIFE to live separate and apart; and WHEREAS, the parties hereto agree that they intend to obtain a mutual consent divorce and HUSBAND filed a Complaint in the Court of Common Pleas, Cumberland County, on March 25, 1998. WHEREAS, HUSBAND has hired DAVID R. THOMPSON, Attorney at Law, to represent him In this divorce proceeding who shall undertake to advise HUSBAND and explain the legal implications involved with this document. WIFE has hired KEIRSTEN L. DAVIDSON AND MELISSA PEEL GREEVY, Attorney at Law, to represent her In this divorce proceeding who shall undertake to advise WIFE and explain the legal implications Involved with this document. The parties further declare that each is executing this Agreement freely and voluntarily having obtained sufficient knowledge and disclosure of their respective legal rights and obligations from their chosen counsel. The parties each acknowledge that this Agreement is fair and equitable and Is not the result of any fraud, coercion, duress, undue Influence or collusion. WHEREAS, the parties desire to fully and finally settle their respective financial and property rights and obligations as between each other, and to settle without resort to litigation all other Issues; and WHEREAS, both parties hereby agree to release and discharge any and all claims which either may have against the other. NOW, THEREFORE, in consideration of the mutual covenants, promises and agreements herein contained, and intending to be legally bound hereby, the parties do covenant and agree as follows; 1. SEPARATION; It shall be lawful for each party at all times hereafter to live separate and apart from the other party at such place as she or he may from time to time choose or deem fit. The foregoing provision shall not be taken as an admission on the part of either party of the lawfulness of the causes leading to their living apart. 2. INTERFERENCE; Each party shall be free from Interference, authority and contact by the other as fully as if she or he were single and unmarried except as may be necessary to carry out the provisions of this agreement. Neither party shall molest the other or attempt to endeavor to molest the other, nor compel the other to cohabit with the 1 other, nor In any way harass or malign the other, nor In any way Interfere with the other's peaceful existence, separate and apart from the other. 3. DESIRE OF THE PARTIES: It Is the desire of the parties, after long and careful consideration, to amicably adjust, compromise and settle all property rights and all rights in, to, or against each other's property or estate, Including property heretofore or subsequently acquired by either party, and to settle the following disputes existing between them, those being any and all claims for WIFE'S and/or HUSBAND'S maintenance and/or for support, alimony, counsel fees and costs, and equitable distribution. 4. DEBTS: HUSBAND and WIFE represent and warrant to each that neither one has contracted any debt or debts, charges or liabilities whatsoever except as hereinafter expressly set forth, for which the other party or their property or their estate shall or may be or become liable or answerable, and they covenant that they will at all times keep each other free, harmless, and Indemnified against and from any and all debts and liabilities heretofore or hereafter contracted or Incurred by either of them, except as expressly provided In this Agreement. A. The parties hereby agree that the joint debts shall be paid as follows: (1) MORTGAGES: HUSBAND agrees to pay and be liable for the mortgage to Chase Manhattan Mortgage Company against the real property located at 12801 Plantation Drive, Spotsylvania, Virginia 22553. HUSBAND shall be responsible for all past, present, and future taxes and homeowner's insurance on the property. HUSBAND further agrees to refinance said promissory note and mortgage Into his name, removing WIFE'S liability for the same. HUSBAND agrees to complete said refinance within ninety (90) days of the date of this Agreement and shall be responsible for all costs and fees associated with the refinancing. HUSBAND agrees to Indemnify, save and hold WIFE harmless from any liability for payment of the same. HUSBAND further covenants and agrees that if any claim, action or proceeding Is hereafter brought seeking to hold the WIFE Ilable, HUSBAND will, at his expense, defend the WIFE against any such claim or demand, whether or not well-founded. (2) PERSONAL LOAN; HUSBAND agrees to pay and be liable for the debt to Commercial Credit, making all payments In a timely manner, holding WIFE harmless from any liability of the same. To the extent the joint credit account with Commercial Credit remains open, the parties' joint commercial credit account shall be closed within ten (10) days of the execution of this Agreement. (3) CREDIT CAgpS: (A) It is agreed that credit cards held in WIFE's name only, shall be assumed by and paid for by WIFE, and WIFE agrees to Indemnify save and hold HUSBAND harmless from any liability for payment of the same. WIFE further covenants and agrees that if any claim, action or proceeding Is hereafter brought seeking to hold the HUSBAND liable, WIFE will, at her expense, defend the HUSBAND against any such claim or demand, whether or not well-founded. (B) It is agreed that credit cards held In HUSBAND'S name only, shall be assumed by and paid for by HUSBAND, and HUSBAND agrees to Indemnify save and C r ?• hold WIFE harmless from any liability for payment of the same. HUSBAND further covenants and agrees that if any claim, action or proceeding Is hereafter brought seeking to hold the WIFE liable, HUSBAND will, at his expense, defend the WIFE against any such claim or demand, whether or not well-founded. ( Q It is agreed that all credit cards Currently held jointly and during the marriage shall assumed by and paid for by HUSBAND, and HUSBAND agrees to Indemnify save and hold WIFE harmless from any liability for payment of the same. HUSBAND further covenants and agrees that if any claim, action or proceeding Is hereafter brought seeking to hold the WIFE liable, HUSBAND will, at his expense, defend the WIFE against any such claim or demand, whether or not well-founded. (D) The parties agree that all joint charge accounts shall be closed within fourteen (14) days of the date of this Agreement. 5. MARITAL PROPERTY: The parties have agreed to the following division and distribution of their marital property: A. MARITAL PERSONAL PROPERTY: Furniture and other personal items have been divided between the parties as of the signing of this agreement, and, each of the parties hereto shall hereafter keep as his or her sole property any personalty in his or her possession, except as to specific Items otherwise referred to by the terms of this Agreement. It Is further understood and agreed between the parties that WIFE received dishes and glassware, and HUSBAND received furniture, lawn mower and other household good. r. B. VEHICLES: Each party shall maintain any and all possession and ownership rights to vehicles that they now have in their possession, remaining liable for any debts, maintenance or Insurance costs associated therewith. Each party herein acknowledges that Shannon Dixon received the parties' 1989 Eagle Summit. The parties acknowledge that two vehicles owned by the parties during the marriage have been previously "totaled" and are not In the possession of either party. HUSBAND represents that the debt on those vehicles has been satisfied, C. MARITAL REAL PROPERTY: HUSBAND and WIFE are the owners of property located 12801 Plantation Drive, Spotsylvanla, Virginia 22553. The parties agree that WIFE shall convey her Interest In the said real property to HUSBAND by quit claim deed. The deed shall be executed by WIFE at the time of signing this agreement and shall be held In escrow at the Law Offices of Johnson, Duffle, Stewart, & Weidner until such time as the joint Mortgage to Chase Manhattan Mortgage Corporation is satisfied or refinanced Into HUSBAND'S name only In accordance with paragraph 4(A)1 herein. HUSBAND shall receive any and all economic benefit from the said real property and shall pay and remain liable for any and all debts associated therewith. HUSBAND shall bear the cost of the preparation of the Deed and all costs of refinancing. 6. CHECKING AND SAVINGS ACCOUNTS; It is agreed between the parties that all Joint checking and savings accounts have been closed. 7. MARITAL PENSIONS AND INVESTMENTS: The parties hereto agree that there exists a 401 Retirement/Savings plan through Allied Signal In the name of ff ?z . HUSBAND. It is understood between the parties that the marital amount to be divided equally between the parties is $40,799.62 as of December 31, 2001. It Is the Intent of the parties to promptly follow through the execution of the necessary stipulations and Court Orders to obtain a Qualified Domestic Relations Order from the Court which shall be served upon the pension plan administrator. Counsel for HUSBAND shall present a draft Qualified Domestic Relations Order consistent with the terms of this paragraph within fourteen (14) days of the execution of this Agreement. HUSBAND shall bear the expense of the preparation of the Order and any actuarial costs associated therewith. Therefore, within sixty (60) days of the execution this Agreement, the Qualified Domestic Relations Order shall be submitted to the pension plan administrator. 8. MUTUAL RELEASE: Subject to the provisions of this Agreement each party has released and discharged, and by this Agreement does for herself or himself and his or her heirs, legal representatives, executors, administrators and assigns, release and discharge the other of and from all cause 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 cause or causes of action for divorce and except any or all causes of action for breach of any provision of this Agreement. 9. ALIMONY, ALIMONY PENDENTE LETE and SPOUSAL SUPPORT: HUSBAND agrees to pay WIFE the amount of $400.00 a month for a period of five (5) years (60 months), commencing the fifth day of the month following the entry of the Decree in Divorce. Said payments shall be made via wage attachment to be set up l through the Statewide Collections and Disbursement Unit (SCDU), It Is agreed between the parties the amount set forth above is non-modifiable, and said payments shall be made no later than the St' day of each month. The parties stipulate and agree that the present Spousal Support Order docketed to PACSES Case No, 111100017, Docket No. 1128 S 1997, shall be terminated upon the entry of the Decree in Divorce, and that a copy of this Marriage Settlement Agreement and Decree in Divorce shall be presented to the Domestic Relations Section for the Implementation of the parties' agreement related to alimony, thereby eliminating the necessity of a hearing and creating the arrangement that allows for the alimony award to be entered as an Administrative Order. Upon the completion of the five-year payment period, HUSBAND and WIFE agree to waive and release any rights they may have against the other for alimony, alimony pendente lete and/or spousal support, except as expressly provided for herein, it shall thereafter be the sole responsibility of each parry to sustain himself or herself without seeking alimony or spousal support from the other party. Further, each party shall be responsible for the payment of his or her own attorney's fees and costs. The parties intend that only the alimony paid pursuant to this paragraph and spousal support are taxable to WIFE as Income and deductible to HUSBAND. Any payments HUSBAND makes on debts of the parties, the mortgage, credit cards and loans shall not constitute alimony or taxable income to WIFE. Rather, they are part of the equitable 10, INSURANCE; HUSBAND shall be responsible for providing medical Insurance for the parties' son, Sean, for his lifetime as long as he remains employed and has the ability to provide said coverage through his employment. If and In the event HUSBAND Is unable to provide said hospital, major medical, prescription and dental coverage through his employment, the parties agree to pay, in a pro rata fashion based on their net Income, for any uncovered expenses after payment by medicare, medical assistance and the like through Sean's Social Security Supplemental Security Income, 11. ENTIRE AGREEMENT: This 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 intend that the Marriage Settlement Agreement should be incorporated, but no merged, Into the Decree of Divorce. 12. BREACH: In the event that either party breaches any provisions of this Agreement and the other party retains counsel to assist In enforcing the terms thereof, the breaching party will pay all reasonable attorneys' fees, court costs and expenses (including Interest and travel costs, if applicable) which are incurred by the other parry In enforcing the Agreement, which enforcement Is ultimately achieved by litigation or by amicable resolution. It is the specific Agreement and Intent of the parties that a breaching or wrongdoing party shall bear the obligation of any and all costs, expenses and reasonable counsel fees Incurred by the non-breaching party in protecting and enforcing his or her rights under this Agreement. 11 13, WAIVER OF RIGHTS: Both parties hereby waive the following procedural rights: A. The right to obtain an Inventory and the appraisement of all marital and non-marital property; B. The right to obtain an Income and expense statement of either party; C. The right to have all property Identified and appraised; D. The right to discovery as provided by the Pennsylvania Rules of Civil Procedure; E. The right to have the court make determinations regarding marital and non-marital property, equitable distribution, spousal support, alimony pendente lite, alimony, counsel fees and costs and expenses. 14. WAIVERS OF CLAIMS AGAINST ESTATE: 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 hereinafter acquire, under the present or future laws of any jurisdiction, to share in the property of the estate of the other as a result of the marital relationship, Including without limitation, dower, courtesy, statutory allowance, widow's allowance, right to take property under equitable distribution, right to take In Intestacy, right to take against the Will of the other, and the right to act as administrator or executor of the other's estate, and each will, at the request of the other, execute, acknowledge and deliver any and all instruments which may be AT necessary or advisable to carry Into effect this mutual waiver and relinquishment of all such Interests, rights and claims. 15. FINANCIAL DISCLOSURE: The parties represent and warrant that the disclosures each have made are truthful, accurate and complete. The parties confirm that each has sufficient knowledge of the financial circumstances of the other or has relied on the accuracy of the financial disclosure of the other as an Inducement to the execution of this Agreement. Each party understands that he/she had the right to obtain from the other party a complete inventory or list of all property that either or both parties owned at the time of separation or currently and that each party had the right to have all such property valued by means of appraisal or otherwise. Both parties understand that they have a right to have a court hold hearings and make decisions on the matters covered by this Agreement. Both parties hereby acknowledge that this Agreement is fair and equitable, and the terms adequately provide for his or her Interests, and that this Agreement is not the result of fraud, duress, or undue Influence exercised by either party upon the other or by any person or persons upon either party. 16. ADDITIONAL INSTRUMENT: Each of the parties shall from time to time, at the request of the other, execute, acknowledge and deliver to the other party any and all further instruments that may be reasonably required to give full force and effect to the provisions of this Agreement, including Deeds, vehicle titles and sales tax forms and any and all other forms which may be required to effect said transfer of vehicles and/or property. 17. DIVORCE; HUSBAND and WIFE agree to cooperate in obtaining a no-fault divorce under Section 3301(c) of the Divorce Code In the divorce action in the Cumberland County Court of Common Pleas filed to No. 98-1656-CV, HUSBAND and WIFE shall, contemporaneously with the execution of this Agreement, execute Affidavits of Consent and Waiver of Notice of Intent to Request Entry of the Divorce Decree and the Stipulation for the Entry of the Quallfled Domestic Relations Order, 18. 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. 19. INDEPENDENT SEPARATE COVENANTS: It is specifically understood and agreed by the parties hereto that each paragraph hereof shall be deemed to be a separate and independent covenant and agreement. 20. APPLICABLE LAW: This Agreement shall be construed under the law of the Commonwealth of Pennsylvania. 21. VOID CLAUSES: If any term, 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 respects this Agreement shall be valid and continue In full force, effect and operation. IN WITNESS WHEREOF, the parties have hereunto set their hands and seals as of the day and year first above written, f a?r? (SEAL) ss Garman E. Dixon Witness -? (SEAL) *Ia+nlAnn Dixon 4' C >, q+ COMMONWEALTH OF PENNSYLVANIA Kfordom 14 1 Ko.,;lA 71e!rnrydi? 99 :ss: COUNTY OF 4mb+nv 'Irdw hdbnl3tafaU UI r?ee11.IRRGOn this sda'df' 2004 , 2004, before me, a Notary Public, the undersigned officer, personally appeared, GARMAN E. DIXON, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Instrument and acknowledge that he has executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal the day and year first above written. ? N.P. WaynoW,I)AVIS COMMONWEALTH OF PENNSYLVANIA (bosuiarAssociateOf the ? SS; U nUcd Statca of Au> crlca COUNTY OF (lr h ?F ? ? ? Gl G( On this,V day of l d a it / ; 2004, before me, a Notary Public, the undersigned officer, personally appeared, MELANIE ANN DIXON, known to me (or satisfactorily proven) to be the person whose name Is subscribed to the within Instrument and acknowledged that she has executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my and and official seal the day and year first above written. A / C:\My Documents\divorce\dixonmas.wpd:ajd F Kdsw K. MNoianal ow yere, y k: Me Born, CjUn*W entl County ?slon area Dec. 2, ZIX18 Membs,, Nen,gyp g,ye AssoWum a W arias I IN T11E COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GARMAN E. DIXON vs. MELANIE ANN DIXON NO. 98-1656-CVCIVIL 19 PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Grounds for divorce: irretrievable breakdown under Section 3301 (d)(1) of the Divorce Code. (Strike out inapplicable section) 2. Date and manner of service of the complaint: First Class, Certified, Return Receipt Requested - Defendant signed on April. 2, 1998 T 3. Complete either Paragraph A. or. B. A. Date of execution of the affidavit of consent required by Section 3301 (c) of the Divorce Code: by the plaintiff by the defendant B. (1) Date of execution of the plaintiff's affidavit required by Section 3301 (d) of the Divorce Code: 3/16/04 (2) Date of service of the plaintiff's affidavit upon the defendant: 04/01/04 4. Related claims pending: N/A 5. Indicate date and manner of service of the notice of intention to file praecipe to transmit record, and attach a copy of said notice under Section 3301 (d)(1)(i) of the Divorce Code --Attorney for PlaintifffBefandaat i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA, i CIVIL ACTION - LAW GARMAN E. DIXON, ,I * PLAINTIFF * No. 98- VS. * TYPE OF PLEADING: COMPLAINT MELANIE ANN DIXON, * IN DIVORCE * DEFENDANT { * FILED ON BEHALF OF: * Plaintiff * * COUNSEL OF RECORD FOR THIS * PARTY: * * David R. Thompson, Esquire * P.O. Box 587 * 308 Walton Street, St. 4 * Philipsburg, PA 16866 * (814) 342-4100 * Supreme Court I,D, No. 73053 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA. CIVIL ACTION - LAW GARMAN E. DIXON, * PLAINTIFF * Vs. * MELANIE ANN DIXON, * DEFENDANT No. 98- TYPE OF PLEADING; COMPLAINT IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHT 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 fall to do so, the case may proceed against you and a Decree of Divorce or annulment may be entered against you for any other claim. 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 the marriage counselors is available in the Office of the Prothonotary at Cumberland County Courthouse, Carlisle, Pennsylvania, 17013-3387. IF YOU DO NOT FILE FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES, OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS ENTERED, 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 SE FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle PA 17013 2 -3166 (7174Z/M&L By. hop n, , Esquire D IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA, CIVIL ACTION - LAW GARMAN E. DIXON, PLAINTIFF VS. MELANIE ANN DIXON, DEFENDANT No. 98- /6 66 Cwl r'44-- TYPE OF PLEADING: COMPLAINT IN DIVORCE AND NOW, comes the Plaintiff by and through his attorney, DAVID R. THOMPSON, and files this Complaint against the Defendant, and In support thereof avers as follows: 1. Plalntiff Is GARMAN E. DIXON, who resides at U.S. Embassy Box 33, APO AP 96546, 2. Defendant Is MELANIE ANN DIXON, who resides at 220 Four Season Lane, Enola, Pennsylvania, 17025. 3. Plaintiff and Defendant have been bonafide residents of the Commonwealth for at least six months. 4. Plaintiff and Defendant were married on July 10, 1976, In New Bloomfield, Pennsylvania, COUNT I - DIVORCE Code), 5. This action is not collusive. [Does not apply to Sections 201 © and (d) of the Divorce 6. There is no prior or pending litigation between the Parties. 7• The marriage is irretrievably broken, WHEREFORE, Plaintiff requests the entry of a Decree of Divorce, COUNT II - EQUITABLE DISTRIBUTION Paragraphs 1 through 7 are Incorporated herein by reference as though the same were set forth at length herein, 8, Plaintiff and Defendant have legally and beneficially obtained property during their marriage, 9. Plaintiff and Defendant have been unable to agree to an equitable division of this said property, I i WHEREFORE, Defendant requests this Court to equitably divide the marital property, Respectfully submitted, ad'R?Thom on, Esquire ¦ NOTICE OF AYAI ABI M OF COUNSE NNG The Divorce Code provides that marriage counseling be available to parties In divorce actions. Under some circumstances the Court may require such counseling. You should notify your attorney If you wish the Court to Order marriage counseling. The Domestic Relations Section located In the Cumberland County Courthouse, Carlisle, Pennsylvania, will provide you with a list of qualified counselors, but you are lI2t required to select a counselor from that list. Fees for counseling are set by the counselor, and payment Is the responsibility of the parties involved, The costs of counseling provided by some agencies is based on ability to pay. For additional Information, contact your attorney or the Domestic Relations Section. i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA, CIVIL DIVISION GARMAN E. DIXON , * PLAINTIFF * No. 98.1656-CD * VS. * TYPE OF PLEADING; MELANIE ANN DIXON Affidavit of Service , * DEFENDANT * FILED ON BEHALF OF; * Garman E. Dixon * Plaintiff * * * COUNSEL OF RECORD FOR THIS PARTY; * David R. Thompson, Esquire * P.O. Box 587 * Philipsburg, PA 16866 * (814) 342-4100 * I.D. No, 73053 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL DIVISION GARMAN E. DIXON, PLAINTIFF * NO.98-1656-CD VS. * MELANIE ANN DIXON, DEFENDANT AFFIDAVIT OF SERVICE I, DAVID R. THOMPSON, Esquire, hereby certify that I have caused to be served upon the Defendant, MELANIE ANN DIXON, a certified copy of the DIVORCE COMPLAINT, in the above captioned matter. I served the same by depositing in the U.S. Mail, postage prepaid, certified mall, return receipt requested, addressed as follows: MELANIE ANN DIXON 220 FOUR SEASON LANE ENOLA PA 17025 , ri _7U A, ¦ 0Qgnplela Nina t sWor 2lor addlloMI services. 1 also wish to receive the y0wngws eeew 3, 4s, and 4b. following services (for an apr" yoN name and addmo on the rewree of INS form w that we can relum INS e21ra fee): wall to U. ? Addressee's Address an to the hors of the mwlplece, or on the back If space tloa not •d aAeach INS to •lfebm Realpfqp dewed' on the madOsoe below the ankle number. 2. 13 Restricted DoliVery oYhe Reim Recelf>t AH 11ww, to when IM ankle was delivered and the date detwered. Consult postmaster lot f". 3. Article Addressed to: 4a. Article Number y z (lv W OM «?,?Q In 39 . / 4b, Service Type ? Repfstered Csr88ed ? press Mall ? Insured $$ /T'r ? Return Recelpt for AMldlendse ? COD 7. Date o Delive d - 9d 8. ReceNed By. (Pdnf 1Vems) 8. Addressee's Address (Only I requested and lee is peAd) 8. efgnatuu: (Add, ee or AgenQ PS Form 3811, December ego 102595 e7•e-due olneet a OW WA pt E 1 f IN THE COURTOF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL DIVISION - LAW GARMAN E. DIXON, * No. 98-1656-CD * Plaintiff * VS. * MELANIE ANN DIXON, * Defendant * AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on March 25, 1998, in the Court of Common Pleas of Cumberland County. 2. The marriage of Plaintiff and Defendant is irretrievably broken. Ninety (90) days have elapsed since the filing of the Complaint. 3. Plaintiff consents to the entry of a Final Decree of Divorce. 4. I understand that If a claim for alimony pendente lite, marital property or counsel fees or expenses has not been filed with the Court before the entry of a Final Decree In Divorce, the right to claim any of them will be lost. The party whose signature appears below verifies that the statements made in this Affidavit are true and correct, and that they are made subject to the penalties of 18 Pa. C.S. 4909 relating to unsworn falsification to authorities. Garman E. Dixon, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL DIVISION - LAW GARMAN E. DIXON, VS. MELANIE ANN DIXON, Plaintiff Defendant No. 98-1656-CD FFIDAVIT OF CONSFnrr 1. A Complaint In Divorce under Section 3301(c) of the Divorce Code was filed on March 25, 1998, In the Court of Common Pleas of Cumberland County. 2. The marriage of Plaintiff and Defendant is irretrievably broken. Ninety (90) days have elapsed since the filing of the Complaint. 3. Plaintiff consents to the entry of a Final Decree of Divorce. 4. I understand that if a claim for alimony pendente lite, marital property or counsel fees or expenses has not been filed with the Court before the entry of a Final Decree in Divorce, the right to claim any of them will be lost. The party whose signature appears below verifies that the statements made in this Affidavit are true and correct, and that they are made subject to the penalties of 18 Pa. C.S. 4909 relating to unsworn falsification to authorities. DATED; ,?\\4pk Garman E. Dixon, Plaintiff ' i. _ _ ,. ' (a t l h.? .,? (' ?p? .4^ .F' ? ? ?. ,:. .'. T;?? ... }f? . ' ?? ...? ..{.- :-? ,. .. ,. .,, ___.. .. ? ,.-- ..cF,..,S ., .? ?... .e ?u. r,?i i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA GARMAN E, DIXON, VS. MELANIE ANN DIXON, CIVIL DIVISION - LAW No, 98.1656-CD Plaintiff Defendant WAIVER OF NOTICE OE__ INTE L TO REQUEST ENTRY OF DIVORCE?ee DER CPPTinu -2en4 ._ 1. I consent to the entry of a final decree In divorce without notice, 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses If I do not claim them before a divorce is granted, 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa,C.S. 4904 relating to unsworn falsification to authorities, Date:A *. Garman E. Dixon, laintiff r' '''.. i ? ? ?:" ?7 -? i O ; i , - . ? `. ' e ,. - ir . r-. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL DIVISION - LAW GARMAN E. DIXON, * No. 98-1656-CV Plaintiff * VS. * MELANIE ANN DIXON, * Defendant * AFFIDAVIT OF CONSENT 1. A Complaint In Divorce under Section 3301(c) of the Divorce Code was filed on March 25, 1998, in the Court of Common Pleas of Cumberland County. 2. The marriage of Plaintiff and Defendant is irretrievably broken. Ninety (90) days have elapsed since the filing of the Complaint. 3. Defendant consents to the entry of a Final Decree of Divorce. 4. I understand that if a claim for alimony pendente lite, marital property or counsel fees or expenses has not been filed with the Court before the entry of a Final Decree In Divorce, the right to claim any of them will be lost. The party whose signature appears below verifies that the statements made in this Affidavit are true and correct, and that they are made subject to the penalties of 18 Pa. C.S. 4909 relating to unsworn falsification to authorities. DATED; 1115# q la6?- _ elanie Ann Dixon, Defendant ,? Cry r ' 'fl _.? ??yli ? 1-? 1 ? . (_? , t ?''. ? G ,. ..E n --? /,; ?? ..? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL DIVISION - LAW GARMAN E. DIXON, * * Plaintiff * * * * * Defendant * No. 98-1656-CV VS. MELANIE ANN DIXON, WAIVER OF NOTICE OF INTENTION 1. 1 consent to the entry of a final decree in divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. 1 understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made In this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. Date:-'/,/) LY elanie nn Dixon, Def ndant , A '( I ' ? ?. ? ?; ' ??;, _: t ? ;! t ._, r.' 1 -- ? , l l I A' ti i n : ^. r ? . ':{'('I? t:? . M - ? . ? t ?, ?'?('1 . ' . 'I 1 =C ? ., I ? r i ,, ?? ,., r (I, u p ?. ,. l i, _?, - - 1. Diu IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW GARMAN E. DIXON, * CASE NO. 98-1656-CV Plaintiff * vs. * MELANIE ANN DIXON , Defendant * TYPE OF CASE: Civil Action - Law * * * TYPE OF PLEADING: Praecipe to Incorporate Marriage * Settlement Agreement * * FILED ON BEHALF OF: * Plaintiff * * COUNSEL OF RECORD FOR THIS * PARTY: * David R. Thompson, Esquire * Supreme Court LD. No. 73053 * DAVID R. THOMPSON LAW OFFICE * P.O. Box 587 * Philipsburg PA 16866 (814) 342-4100 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW vs, MELANIE ANN DIXON, Defendant CASE NO. 98-1656-CV TO THE PROTHONOTARY: Kindly Incorporate the Marriage Settlement Agreement dated the OP1 4 day of f ., 20+ Into the Divorce Decree entered in the above captioned matter, R. Thom son, Esquire Attorney for Plaintiff GARMAN E. DIXON, Plaintiff f t i i 1 E'" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW GARMAN E. DIXON, * N0.98-1656-CIVIL PLAINTIFF * VS. * MELANIE ANN DIXON, DEFENDANT * * COUNTER AFFIDAVIT' UNDER SECTION 201(d) OF THE DIVORCE CODE 1. Check either (a) or (b): _(a) I do not oppose the entry of a divorce decree. -(b) I oppose the entry of a divorce decree because (check (1), (II) or both): _(i) The parties to this action have not lived separate and apart for a period of at least two years. _(II) The marriage Is Irretrievably broken. 2. Check either (a) or (b): _(a) I do not wish to make any claims for economic relief. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. `! _(b) I wish to claim economic relief which may Include alimony, division of property, lawyer's fees or expenses or other Important rights. I verify that the statements understand that false statements herein a fi are made i subject to the penalties of 18 Pa. C.S r§ 4904 relating to unsworn falsiflcatlon to authorities. DATE: 5-f- e J JelanleAnn' Dixon, efenclant - 11 .11 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, pA, CIVIL DIVISION GARMAN E, DIXON, * PLAINTIFF * No. 98-1656-CD * vs. * TYPE OF PLEADING * MELANIE ANN DIXON Affidavit of Service , * DEFENDANT * FILED ON BEHALF OF; Garman E, Dixon Plaintiff * * COUNSEL OF RECORD FOR THIS * PARTY- * IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL DIVISION GARMAN E. DIXON, PLAINTIFF * NO. 98-1656-CD VS. * MELANIE ANN DIXON, DEFENDANT AFFIDAVIT OF SERV. I, DAVID R. THOMPSON, Esquire, hereby certify that I have caused to be served upon the Defendant, MELANIE ANN DIXON, a certified copy of the 2-YEAR AFFIDAVIT, in the above captioned matter. I served the same by depositing In the U.S. Mall, postage prepaid, certified mall, return receipt requested, addressed as follows: MELANIE ANN DIXON 220 FOUR SEASON LANE ENOLA PA 17025 DATED: 5/1/98 baflid R. Thom s Esquire Attorney for Plaintiff ¦gtirnplete 0" t eriNar x for edditbneh wrvla.. ¦OomplNe Rom 3.4s, and 4b. I also Wleh to receive the following ssrvkwo (for an Mm W.ddnww94 new" of IN. form w stet we un mt= We eadte yo u r extra fob): y v u 10 ¦I ichh io n to the hord of the mdlpiwa, or m the wd1 H sp.w do" not U 1. 13 Addressee's Address .. pe p ¦wdteh@Wm R"pf Reglwfled on the mWplem bebw the eNole mfter. 2. O Restricted DGIIV$ry eTM Rolm RwNpl Of show to wham eu ankle was delivered bid IM deto di wred. consult poebneater for fee. r y l t 3. Arbc a dressed to, 4s. Article Number z nil '08 Ci I n '? 4b. ervIce Type ? ?•erIMW ? Registered ? xpress MWI 0 Irmured Relum RecW for Merdwda O COD j A Date o 3 8. Received By: (Print Name) S. Addreeeee'e Address (Only N requaafed and fee to psAd) 6.818to: rldraee or penQ x* V bwk 0 , P8 Form 3811 r December 1884 102595 97.9 0179 of116810 Blu-M !C! P Johnson, Duffle, Stewart & Weidner By: Keirsten W. Davidson 14), No. 78243 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 GARMEN E. DIXON, Plaintiff / Counterclaim Defendant V. MELANIE A. DIXON, Defendant / Counterclaim Plaintiff IN DIVORCE You have been sued in court. If you wish to defend against the claims set forth the following pages, you must take prompt action. You are warned that if you fall to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court. A Judgment may also be entered against you for any other claim or relief requested in these pages 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 at the Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE THE 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 Telephone: (717) 249-3166 Attorneys for Defendant / Counterclaim Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 98 - 1656 CIVIL TERM CIVIL ACTION - LAW Johnson, Duffle, Stewart & Weidner 13y; Keirsten W. Davidson I.D, No. 78243 301 Market Street P. 0. Box 109 Lemoyne, Pennsylvania 17043.0109 (717) 761-4540 GARMAN E, DIXON, Plaintiff / Counterclaim Defendant V. MELANIE ANN DIXON, Defendant / Counterclaim Plaintiff Attorneys for Defendant / Counterclaim Plaintiff IN'rHE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 98-1656 CIVIL ACTION -• LAW IN DIVORCE ANSWER AND COUNTER_CLAlM AND NOW, comes the Defendant / Counterclaim Plaintiff, by and through tier attorneys, Johnson, Duffle, Stewart & Weidner, and files this Answer to Divorce Complaint, and in support thereof avers as follows; 1. Defendant is without sufficient information to respond to this allegation, 2. Admitted. 3. Admitted in part and Denied in part. It is admitted that at the time of the filing of the Divorce Complaint, Defendant was a bona fide resident of the'Commonwealth for at least six (6) months, however as of the filing of this Answer, Defendant believes that Plaintiff has been residing out of the country in Thailand for many years. 4. Admitted. CQUNTI, DIVORCE Paragraphs 1 through 4 are incorporated herein by reference as though the same were set forth herein at length. 5. Admitted. 6. Admitted. 7. Denied, COUNTA EQUITABLE DISTRIBUTION Paragraphs 1 through 7 are incorporated herein by reference as though the same were set forth herein at length. 8. Admitted, 9. Admitted. WHEREFORE, Defendant respectfully requests this Court to equitably divide all marital property. feQUNTERCLA/M SPOUSAL SUPPORT, ALIMONY/ALIMONY PENDENTE LITE 10, The Counterclaim Plaintiff has insufficient income and assets to provide for her needs, 11. The Counterclaim Plaintiff has a minimal monthly Income, as she is unemployed. Counterclaim Plaintiff cannot work either full-time or part-time as she Is the sole caretaker of the parties' son, who due to a car accident, has become Incapacitated and requires care and supervision twenty-four (24) II hours a day, seven (7) days a week. 12. The Counterclaim Defendant has a monthly Income far In excess of Counterclaim Plaintiff's and is capable of providing her financial support. 11 WHEREFORE, the Counterclaim Plaintiff respectfully requests that this Honorable Court enter an award and/or maintain the current award of spousal support/alimony pendente lite until final hearing and alimony thereafter. Respectfully submitted, JOHNSON, DUFFIE, STEWAR'f $ WEIDNER By,` i (A Kelrsten W. Davidson .150991 YEBIFI-CA ION I, Kelrsten W. Davidson, attorney for Melanie Ann Dixon, hereby certify that the matters asserted herein constitute matters of record, legal arguments and matters within the direct knowledge of counsel, as represented to her by Melanie Ann Dixon. The statements contained herein are true and correct to the best of the knowledge of the undersigned. This verification Is made pursuant to the provisions of 18 Pa.C.S.A, §4904. KW. Davidson Date: October 29, 2001 CERTIFICATE OF SERV/CE AND NOW, this "day of October, 2001, the undersigned does hereby certify that she did this dale serve a copy of the foregoing Answer and Counterclaim upon the other parties of record by causing same to be deposited in the United States Mall, first class postage prepaid, at Lemoyne, Pennsylvania, addressed as follows: David R. Thompson, Esquire 309 Walton Street, Ste. 4 P.O. Box 587 Philipsburg, PA 16866-0587 Respectfully submitted, JOHNSON, DUFFIE, STEWART & WEIDNER By: Y?" Keirsten W Davidson :150991 - ,A GARMAN E, DIXON, IN THE COURT OF COMMON PLEAS OF Plaintiff C'UMBE3RLAND COUNTY, PENNSYLVANIA v. , CIVIL ACTION - LAW MELANIE ANN DIXON, IN DIVORCE Defendant 98-1656 CIVIL, TERM ORDER OF COURT AND NOW, this 30th day of October, 2001, in the case of Dixon versus Dixon at No, 98-1656 Civil Term, and it appearing that a petition was filed on behalf of Defendant to strike the case from the purge list, and there being no opposition presented in court at this time to such action, the case is stricken from the purge list and shall remain active. By the Court, J/WLdsley 01?,?, ?,7r David R. Thompson, Esquire P Box 587 ajj Phillipsburg, PA 16866-0028 ZO)2Xt4) For the Plaintiff Keirsten W, Davidson, Esquire T?-S P.O. Box 109 Lemoyne, PA 17093-0109 For the Defendant pcb f,7 C.) - , '??,_ rya ir! ? rr; -i cry II f, ti 5 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL DIVISION LAW lAAI 2 fi 2Dp5 y GARMAN E, DIXON, * No, 98-1656-CD Plaintiff * VS. MELANIE ANN DIXON, * Defendant * QUALIFIED DOMESTIC RELATIONS ORDER 2ooS? IT IS HEREBY ORDERED, this day of .?, 2094, as follows; 1. Effect of This Order as a Qualified Domestic Relations Order. This Order creates and recognizes the existence of an Alternate Payee's right to receive a portion of the Participant's benefits payable under Prudential Retirement and Investment Services (hereinafter referred to as the "Cigna', a qualified benefit plan, which is qualified under Section 401 of the Internal Revenue Code (the "Code') and the Employee Retirement Income Security Act of 1974 (ERISA"). It Is intended to constitute a Qualified Domestic Relations Order ("QDRO'D under Section 414(p) of the Code and Section 206(d)(3) of ERISA. 2. Participant Information, The name, address, birth date and social security number of the Plan Participant Is: Garman E, Dixon 91108/1956 Participant Birth Date US EMBASSY Box 33 194-46-9289 APO AP 96546 Social Security No. Address i iiat i ry ,? 1. LAW N 7 3. Alternate payee Infamutkw. The name, address, birth date and social security number of the Alternate Payee Is: Melanie Ann DIx4I1 Alternate Payee 9/1.3/1955 Birth Date 30.04 rren Way Mechanicsburg PA 17050 Address 191-46-3,989 Social Security Number Participant and Alternate Payee were married on July 10, 1976, and divorced on May 20, 2004. 4. Plan Name an Ad ress. The name and address of the Plan to which this Order applies is: CIGNA Retirement & Investment Services Attn: PITS 500 Main Street Dubuque IA 52001 5. Ap llcabblle State Domestic Relations Law. This Order Is Issued pursuant to Section 23 Pa. C.S. Section 3501 et al, which relates to the division of marital property between spouses and former spouses in actions of divorce. 6. This Order signs to the Alternate Payee fifty (50) percent of the December 31, 2001 value of the Participant's accrued benefits. The stipulated value of the Plan on December 31, 2001 was $40,799.62. The Alternate Payee's award is entitled to earning (dividends, Interest, gain and losses) calculated from December 31, 2001, to the date of segregation and ultimate rollover to the Alternate Payee, in proportion to the Alternate Payee's portion of the Plan. This stipulated amount shall become the Alternate Payee's separate property. The Alternate Payee shall receive a lump sum rollover as soon as administratively feasible following the determination that the Order Is qualified. The Alternate Payee shall Initiate the distribution in accordance with the terms of the Plan and the administrative procedures that have been established by the Plan Administrator. The amount distributed to the Alternate Payee will be the value of the Alternate Payee's account on the date the distribution Is processed. It Is Intended that the lump sum distribution to the Alternate Payee shall be a rollover to an IRA such that it Is a non-taxable distribution. 7. Commencement Date and_Form_Qf Payment to Alternate Payee. The Alternate Payee may elect to commence benefits under the Plan as of the earliest retirement age at which the Participant Is eligible to commence benefits under the Plan. The Alternate Payee may elect to receive benefits In any one of the allowable benefit options permitted under the terms and provision of the Plan. The form of benefit elected by the Alternate Payee Is to be based on the life expectancy of such Alternate Payee. Any actuarial adjustment which might be necessary to convert Alternate Payee's benefits to one based on the Alternate Payee's lifetime shall be applied to the Alternate Payee's benefits. Further, should any early commencement reduction be necessary in the event that the Alternate Payee commences her benefits prior to Participant's Normal Retirement Date, then such reduction shall be applied to Alternate Payee's benefits In accordance with applicable Plan provisions. B. Death of Alternate Payee and/or Pg?Ipant Prior mme0cement of B-gMMt Death fleneflt. This Order creates a separate Interest for the Alternate Payee in the benefits assigned to the Alternate Payee which are not Intended, nor shall they be construed as, alimony to the Alternate Payee. Therefore, the death of the Participant prior to the commencement of benefits shall not affect the benefits assigned to the Alternate Payee under this Order Should the Alternate Payee predecease the Participant, the remaining payments of the assigned benefits will be payable to the Alternate Payee's designated beneficiary until the Participant's death. 9. Savings Clause. This order is not intended, and shall not be construed in such a manner as to require the Plan; (a) to provide any type or form of benefit option not otherwise provided under the terms of the Plan; (b) to require the Plan to provide increased benefits determined on the basis of actuarial value; or ( c) to require the payment of any benefits to the Alternate Payee that are required to be paid to another alternate payee under another order that was previously deemed to be a QDRO. 10. Certification of?ecessary Information. All payments made pursuant to this Order shall be conditioned on the certification by the Alternate Payee and the Participant to the Plan Administrator of such information as the Plan Administrator may reasonably require from such parties to make the necessary calculation of the benefit amounts contained herein. li. C?tinued Ou Ii a Status of Order. It Is the Intention of the parties that this QDRO continue to quality as a QDRO under Section 414(p) of the Internal Revenue Code, as It may be amended from time to time, and that the Plan Administrator shall reserve the right to reconfirm the qualified status of the Order at the time benefits become payable hereunder. 12,T??? ?t? Miill?? s r . For Purposes of Sections (402(a)(1) and (72) of the Internal Revenue Code, any Alternate Payee, who Is the spouse or farmer spouse of the Participant shall be treated as the distributee of any distribution or payments made to the Alternate Payee under the terms of this Order and as such, will be required to pay the appropriate federal Income taxes on such distribution. 13, Constru lv€ PC=. In the event that the Plan trustee Inadvertently pays to the Participant any benefits that are assigned to the Alternate Payee pursuant to the terms of this Order, the Participant shall Immediately reimburse the Alternate Payee to the extent that he has received such benefits payments, and shall forthwith pay such amounts so received directly to the Alternate Payee within ten (10) days of receipt. 14. Contin_ ued 305I , I . The Court shall retain jurisdiction with respect to this Order to the extent required to maintain Its qualified status and the original Intent of the parties as stipulated herein. IS. F-ffect of the Plan Termination, In the event that the Plan is terminated, whether on a voluntary or involuntary basis, the Participant's benefits become guaranteed by the Pension Benefit Guaranty Corporation ("PBGC"), the Alternate Payee's benefits, as stipulated herein, shall also be guaranteed to the same extent In accordance with the Plan's termination rules an din the same ratio as the Participant's benefits are guaranteed by the PBGC. The Participant's counsel shall cause an original court certified or true copy of this Order to be served on the Pension Plan Administrator. This Order shall remain in effect until further order of this Court. CONSENTED TO BY: Particlpant/Garman E. Dixon Pa-rtticipa-nrt tt/-MMelanle, nn Dixon 1 ;31 Atto ey for /P-articl nt Attorney for Alternate Payee BY THE COURT: GARMAN E. DIXON, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE NO. 98-1656 CIVIL TERM MELANIE A. DIXON, IN DIVORCE Defendant PACSES CASE: 111100017 ORDER OF COURT AND NOW to wit, this 8th day of June, 2009, it is hereby Ordered that the terms of the Alimony provisions in the parties' Marital Settlement Agreement have been met and paid in full, the Cumberland County Domestic Relations Sections dismisses their interest in the above captioned matter. BY THE C Edward E Guido, J. DRO: R.J. Shadday xc: Petitioner Respondent Form OE-001 Service Type: M Worker: 21005 FUD-OHRC OF THE 3740NOTARY 209 JUN -8 PM 3= 10