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HomeMy WebLinkAbout07-1305TRACT L. TURNER , : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v : NO. Q 7 - 1365 CIVIL TERM SCOTT E. TURNER, : IN DIVORCE Defendant NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the grounds for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Prothonotary's Office 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 A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PENNSYLVANIA 17013 TELEPHONE: (717) 249-3166 TRACT L. TURNER , Plaintiff v SCOTT E. TURNER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. D7- /30~ CIVIL TERM IN DIVORCE COMPLAINT UNDER SECTION 3301(C) OR (D) OF THE DIVORCE CODE Plaintiff, Traci L. Turner, by her attorney, Lindsay D. Baird, Esquire, sets forth the following: 1 Plaintiff, Traci L. Turner, is an adult individual residing at 101 Hilltop Drive, Mt. Holly Springs, Pennsylvania, 17065. 2 Defendant, Scott E. Turner, is an adult individual residing at 6115 Springford Drive, Apt. J11, Harrisburg, Pennsylvania 17111. 3 The parties were married on October 1, 1994, in Cambria County, Pennsylvania. 4 Defendant has lived continuously in the Commonwealth of Pennsylvania for at least six months prior to the commencement of this action. 5 This action is not collusive. 6 There have been no prior actions for divorce or annulment in this or any otherjurisdiction within the knowledge of the Plaintiff. 7 In accordance with Section 3301(c) of the Divorce Code, the marriage between the parties is irretrievably broken. 8 Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. WHEREFORE, the Plaintiff requests your Honorable Court to decree that the Plaintiff be divorced from the Defendant. JJ f .. r ' dsay D. Bai , Es ire Attorney for the Plaintiff 37 S. Hanover Street Carlisle, PA 17013 717 - 243-5732 I verify that to the best of my knowledge and belief, the statements in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 PaCS §4904 relating to unsworn falsification to authorities. Traci L. Turner, Plaintiff C.~ N ~ „~ 'S'7 Q a ~ ~~ ~ ~ ~i ~ ~ ~ ~'~ ~ W n c ~~ TRACT L. TURNER, Plaintiff v. SCOTT E. TURNER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW N0. 07-1305 IN DIVORCE PROPERTY SETTLEMENT AND SEPARATION AGREEMENT THIS AGREEMENT made this ~ day of ~~~ n~.~- , 2007, between TRACT L. TURNER, of 101 Hilltop Drive, Mt. Holly Springs, Cumberland County, Pennsylvania, hereinafter referred to as "Traci", and SCOTT E. TURNER, of 6115 Springford Drive, Apartment J-11, Harrisburg, Dauphin County, Pennsylvania, hereinafter referred to as °S~tt". RECITALS: R.1: The parties hereto are husband and wife, having been joined in marriage on October 1, 1994, in Cambria County, Pennsylvania; and R.2: A Complaint for Divorce has been filed in the Court of Common Pleas of Cumberland County, Commonwealth of Pennsylvania, to Number 07-1305 Civil Term; and R.3: The parties hereto desire to settle fully and finally their respective financial and property rights and obligations inGuding, but not limited, of all matters between them relating to the ownership of real and personal property, claims for spousal support, alimony, alimony pendente life. R4: The parties also desire to set out a plan for the parenting of their minor children, LYNDSEY TURNER, bom January 6, 2000, and JOSHUA TURNER, born June 20, 2003, counsel fees and costs, and the settling of any and all claims and possible claims against the other or against their respective estates. i NOW THEREFORE, in consideration of the covenants and promises contained herein, and other good and valuable consideration, and intending to be legally bound, Traci and Scott 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 or places as he or she from time to time may choose or deem fit, free from any control, restraint or interference from the other. Neither party will molest the other or endeavor to compel the other to cohabit or dwell with him or her by any legal or other proceeding. Each party shall be free of the interference, authority or contact by the other as if he or she was single and unmarried except as maybe necessary to cant' out the terms of this agreement. (2) DIVORCE: Traci and Scott acknowledge that the marriage is irretrievably broken and that they will secure a mutual consent no-fault divorce decree in the above-captioned divorce action, and will execute and file the necessary documents to finalize the divorce after the expiration of ninety (90) days of the service of the Complaint and Traci shall move for the entry of the divorce decree at that time. (3) REAL PROPERTY: The parties are owners of certain real estate which has been the marital home at 101 Hilltop Drive, Mt. Holly Springs, Pennsylvania. Scott waives all his right, title and interest in the marital home. Within 45 days of the date of this Agreement, Traci will refinance the marital home so that Scott is no longer liable on the mortgage. At the time of the refinance, Scott will give Traci a special warranty deed and Traci will pay Scott $35,000.00. Pending the refinance, Traci shall pay all household expenses including, but not limited to, mortgages and liens of record, utility bills, insurance and real estate taxes in connection with said property. With regard to all such expenses, Traci hereby shall hold Scott harmless and indemnify him from any loss thereon. 2 (4) DEBT: A. Marital Debt: Scott and Traci know of no debt which is marital, other than the mortgage on the marital home and a lien encumbering Traci's 2005 Honda Pilot for which the other might be liable incurred prior to the signing of this Agreement. B: Post Separation Debt: In the event that either party contracted or incurred any debt since the date of separation on September 1, 2006, the party who incurred said debt shall be responsible for the payment thereof regardless of the name in which the debt may have been incurred. C: Future Debt: From the date of this agreement neither party shall contract or incur any debt or liability for which the other party or his or her property or estate might be responsible and shall indemnify and save the other party harmless from any and all claims or demands made against him or her by reason of debts or obligations incurred by the other party (5) MOTOR VEHICLES: Each party relinquishes any right, title and interest he or she may have to any and all motor vehicles currently in possession of the other party. Within ten (10) of the date of this agreement each party shall execute any documents necessary to have said vehicles properly registered in the other party's name with the Pennsylvania Department of Transportation. Each party shall assume full responsibility of any encumbrance on the motor vehicle received by said party, and shall hold harmless and indemnify the other party from any loss thereon. Scott received the 2002 Chevrolet Malibu and made all of the payments owing on that vehicle and has traded it in after separation for a vehicle titled in his own name. With regard to any obligations owing on that vehicle, he hereby indemnifies and holds Traci harmless. Traci retained the 2005 Honda Pilot which is encumbered by a lien. Within 45 days of the date of this Agreement, Traci will refinance the Honda Pilot so that Scott is no longer liable on the obligation and she indemnifies and holds him harmless against any claim related to the Honda Pilot. 3 (6) TANGIBLE PERSONAL PROPERTY: The parties hereto mutually agree that they have effected a satisfactory division of the furniture, household furnishings, appliances, tools and other household personal property between them, and they mutually agree that each party shall from and after the date hereof be the sole and separate owner of all such property presently in his or her possession whether said property was heretofore owned jointly or individually by the parties hereto. This agreement shall have the effect of an assignment or bill of sale from each party to the other for such property as may be in the individual possession of each of the parties hereto. (7) INTANGIBLE PERSONAL PROPERTY: Each party hereby relinquishes any right, title or interest he or she may have in or to any intangible personal property currently titled in the name of or in the possession of the other party, including, but not limited to, stocks, bonds, insurance, bank accounts, individual retirement accounts, employment benefits including retirement accounts, savings plans, pension plans, stock plans, 401(k) plans and the like. Traci will retain the PSECU checking and savings accounts, her Ahold 401(k) plan, the Market USA Federal Credit Union account, the WM Group of Funds joint account and a Vanguard IRA. Scott will retain the Intellimark 401(k) plan. (8) PARENTING OF CHILDREN: Scott and Traci will share legal custody of their children, Lyndsey and Joshua. They understand that they will both have access to information regarding their children and the right to participate in important decisions regarding their children. They commit to consulting with each other regarding any such decision and sharing with each other all information relevant to the children's health and welfare. The children will reside primarily with Traci. Since Scott currently lives in a small apartment, until he acquires more commodious accommodations, he will visit with the children two evenings each week, picking them up from and dropping them off at Traci's at the conclusion of the visit and he will have the children for one weekend day each week. Once Scott moves to a larger residence, he will still visit with the children two evenings each week, but he will also have 4 them every other weekend from Friday evening until Sunday evening. Scott and Traci will share the transportation duties at that point. Both Scott and Traci may enjoy one week of uninterrupted vacation time with their children each year. They will continue to share holidays. They commit themselves to flexibility in order to accommodate the needs of the children and their own needs. (9) CHILD SUPPORT: Scott will pay to Traci for the use, benefit, support and maintenance of their children, the sum of One Thousand Two Hundred Dollars ($1,200.00) per month. That payment will be made each month in two equal installments. Traci will continue to provide health insurance for the benefit of the minor children and to pay the cost of their daycare. Scott and Traci agree that in the event of a material change in circumstances of either one of them, or a change in the parenting plan set forth herein, the amount of support payments shall be subject to an appropriate adjustment by agreement or, if the parties are unable to agree, by order of a court of competent jurisdiction, and the amount ordered by any such court shall be deemed to be the amount due hereunder. (10) WAIVER OF ALIMONY: The parties acknowledge that each has income and assets satisfactory to his and her own reasonable needs. Each party waives any claim he or she may have one against the other for alimony, spousal support or alimony and alimony pendente lite. (11) ADVICE OF COUNSEL: The parties hereto acknowledge that each has been notified of his or her right to consult with counsel of his or her choice, and have been provided a copy of this agreement with which to consult with counsel. Traci is represented by Lindsay Baird, Esquire and Scott is represented by Carol J. Lindsay, Esquire. Each party acknowledges and accepts that this agreement is, under the circumstances, fair and equitable, and that it is being entered into freely and voluntarily after having received such advice and with such knowledge as each has sought from counsel, and the execution of this agreement is not the result of any duress 5 or undue influence, and that it is not the result of any improper or illegal agreement or agreements. Each party shall pay his or her own attorney for all legal services rendered or to be rendered on his or her behalf. (12) ADDITIONAL INSTRUMENTS: 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. (13) INCOME TAX: The parties have heretofore filed joint Federal and State Tax returns. Both parties agree that in the event any deficiency in Federal, state or local income tax is proposed, or assessment of any such tax is made against either of them, each will indemnify and hold harmless the other from and against any loss or liability for any such tax deficiency or assessment and any interest, penalty and expense incurred in connection therewith. Such tax, interest, penalty or expense shall be equally divided and paid by the parties. Scott will take the income tax exemption for Lyndsey each year and Traci will take the income tax exemption for Joshua each year and claim the cost of daycare for both children. Should Traci be unable to take the child and dependent care expense credit for both children, Scott will take the lesser of the credits on his tax return. Traci will execute IRS Form 8332 each year before April 15 to document this agreement for the IRS. (14) BANKRUPTCY: The parties hereby agree that the provisions of this Agreement shall not be dischargeable in Bankruptcy and expressly agree to reaffirm any and all obligations contained herein. In the event a party files such bankruptcy and pursuant thereto obtains a discharge of any obligations assumed hereunder, the other party shall have the right to declare this Agreement to be null and void and to terminate this Agreement in which event the division of the parties' marital assets and all other rights determined by this Agreement including alimony shall be subject to court determination the same as if this Agreement had never been entered 6 into. (15) COMPLETE DISCLOSURE: The parties do hereby warrant, represent, acknowledge and agree that each is fully and completely informed of, and is familiar with, the wealth, real and personal property, estate and assets, earnings and income of the other and has made any inquiry he or she desires into the income or estate of the other and received any such information requested. Each has made a full and complete disclosure to the other of his and her entire assets, liabilities, income and expenses and any further enumeration or statement thereof in this Agreement is specifically waived. (16) RIGHTS AND RESPONSIBILITIES: Husband and Wife acknowledge that each of them has read and understand his and her rights and responsibilities under this Agreement and that they have executed this Agreement under no compulsion to do so but as a voluntary act. (17) FULL SETTLEMENT: Except as herein otherwise provided, each party hereby releases the other from any and all claims, or demands up to the date of execution hereof. It is further specifically understood and agreed by and between the parties hereto that each party accepts the provisions herein made in lieu of and in full settlement and satisfaction of any and all of said party's rights against the other for past, present and future claims on account of support, maintenance, alimony, alimony pendente life, counsel fees, costs and expenses, equitable distribution of marital property and any other claims of the party, including all claims which have been raised or may be raised in an action for divorce. (18) RELEASE OF ALL CLAIMS: Except as may be otherwise specifically provided in this Agreement, Husband and Wife, for themselves, their heirs, representatives and assigns, each hereby forever releases, remises, discharges and quitclaims the other, and such other's heirs, representatives, assigns and estate, from and with respect to the following: A. All liability, claims, causes of action, damages, costs, contributions and expenses or demands whatsoever in law or in equity; B. All rights, title, interest or claims in or to any property of the other, whether real, personal or mixed and whether now owned or hereafter acquired; C. All rights of courtesy and dower and all claims or rights in the nature of courtesy and dower; D. All widow or widower's rights; E. All right, title, interest or claim in or to the other's estate, whether now owned or hereafter acquired, including but not limited to all rights or claims: (1) to take against the other's will; (2) under the laws of intestacy; (3) to a family exemption or similar allowance; and (4) all other rights or authority to participate or intervene in a deceased spouse's estate in any way, whether arising under the laws of Pennsylvania or any other country, territory, state or political subdivision. F. All rights or claims to any accounting; G. All rights, claims, demands, liabilities and obligations arising out of or in connection with the marital relationship or the joint ownership of property, whether real, personal or mixed; H. All rights, claims, demands, liabilities and obligations arising under the provisions of the Pennsylvania Divorce Code, as the same may be amended from time to time, and under the provisions of any similar statute enacted by any other country, state, territory or political subdivision; I. All rights, claims, demands, liabilities and obligations each party now has, or may hereafter have, against or with respect to the other. 8 (19) DISPUTE RESOLUTION: The parties commit themselves to returning to a form of alternative dispute resolution, such as collaborative law or mediation, in the event that issues arise into the future regarding the subject matter of this Agreement before either one of them seeks resolution through the court system. (20) GOVERNING LAW: This Agreement shall be construed under the law of the Commonwealth of Pennsylvania. If any provision of this Agreement is determined to be invalid or unenforceable, all other provisions shall continue in full force and effect. (21) INCORPORATION INTO DECREE: In the event that either of the parties shall recover a final judgment or decree of absolute divorce against the other in a court of competent jurisdiction, the provisions of this Agreement may be incorporated by reference or in substance but shall not be merged into such judgment or decree and this Agreement shall survive any such final judgment or decree of absolute divorce and shall be entirely independent thereof. (22) BREACH: In the event that either party breaches any provision of this Agreement, he or she shall be responsible for any and all costs incurred to enforce the Agreement, inGuding, but not limited to, court cost and counsel fees of the other party. In the event of breach, the other party shall have the right, at his or her election; to sue for damages for such breach or to seek such other and additional remedies as may be available to him or her. (23) ENTIRE UNDERSTANDING: This Agreement constitutes the entire understanding between the parties and there are no covenants, conditions, representations, or agreements, oral or written, of any nature whatsoever, other than those herein contained. (24) AGREEMENT BINDING ON PARTIES AND HEIRS: This Agreement shall bind the parties hereto, their respective heirs, executors and assigns. 9 IN WITNESS WHEREOF, the parties hereto intending to be legally bound have hereunto set their hands and seals the day and year first written above. WITNESS: 2.l4~~ ( C.tt~c_~~ ._ Traci L. Tumer ,~~~ Scott .Tumer io C~ ~j~~ tom ~~ . +i:. . 't't i ~t"i ~ ~. i ~.~7 r~ - _,;' " _-} " ~~ ... ~~ -5,3 .r ~v-1 _..,. ~ : « .e__ ~. C`.~ y r. ~. ~`.. "~ TRACT L. TURNER , : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v : NO. 07-1305 CIVIL TERM SCOTT E. TURNER, : IN DIVORCE Defendant AFFIDAVIT OF SERVICE I, Lindsay Dare Baird, Esquire, being duly sworn according to law do depose and state that a copy of the Complaint filed in the above-captioned matter along with a copy of a Notice to Plead and a Notice of Availability of Marriage Counseling was served on the Defendant, March 12, 2007, by Acceptance of Service by his counsel, Carol J. Lindsay, Esquire. Acceptance of Service attached. t /~'~1 L' dsay D. Bair squir ttorney for Plaintiff 37 South Hanover Street Carlisle, PA 17013 717 - 243-5732 Sworn and Subscribed to before me this 13th day of June, 2007. 1 ~1 ` G~ ~ti Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Niven J. Baird, Notary Public ~ i~Fu.~~ir ~ovN .~2, 2010 Member, Pennsylvania Association of Notaries ti TRACT L. TURNER, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v : NO. ~'~ '/3a~ CIVIL TERM SCOTT E. TURNER, : IN DIVORCE Defendant ACCEPTANCE OF SERVICE I, Carol J. Lindsay, Esquire, hereby accept service of the Complaint in Divorce behalf of the Defendant, Scott E. Turner. ~ Z~ Date ~~ Carol J. Linds ,' squire Attorney fo efendant r-~ {' } [] c~a ~t t G~, ~ { ~ ~..- ~ t _;1; ~ . . t ,~.y. ~ .j,; , "~~ C C~:. : ~ TRACI L. TURNER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW . N0.07-1305 SCOTT E. TURNER, Defendant IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was tiled on March 8, 2007. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree in Divorce after service of notice of intention to request entry of the Decree. I verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information and belief. 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: 6 1 i~L~ Zo D-7 ~ ~ ~~ Scott E. Turner DEFENDANT'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 3301 (cl OF THE DIVORCE CODE 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 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 SAIDIS, FLOWER SZ LINDSAY 26 West High Streec Carlisle, PA 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 to the best of my knowledge, information and belief. 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: b ~ 12 ~ Z,dp~ IA~~ ~~ Scott E. Turner ~ ~ r ~' ~' l -'fit ~ (..) ~... ., ~ - - t-+. _ -~-: ' - ~ :~° -~c - ~ rn '~~ .. ~., r ~a :; ; ~ -~: TRACT L. TURNER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW N0.07-1305 SCOTT E. TURNER, Defendant IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on March 8, 2007. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree in Divorce after service of notice of intention to request entry of the Decree. I verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsifica ' to authoriti Date: (2 02 Traci L. Turner PLAINTIFF'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER& 3301 lc) OF THE DIVORCE CODE 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 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 SAIDIS, FIAWER ~ LIlVDSAY 26 West High Street Cazlisle, PA 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 to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn f ation to a rities. Date: ~ ya'' U Traci L. Turner C`7 0 (~ cM "~ "ra ~~ ~ ~~ ; ~z ~ ~ w .~- ~ t.A7 - , ~ ~~ ~ ~~•j.5 =; ~ _.. 4~s s~ fifi 1 r~ f`~.? (`:: ~ TRACT L. TURNER , : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v : NO. 07-1305 CIVIL TERM SCOTT E. TURNER, : IN DIVORCE Defendant 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. Ground for Divorce: Irretrievable breakdown under Section 3301 (c) of the Divorce Code. 2. Date and manner of service of the Complaint: March 12, 2007, Acceptance of Service by counsel. 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: By Plaintiff: June 12, 2007; by Defendant: June 12, 2007. 4. Related claims pending: None. 5. Date Plaintiffs Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: G ~~3• ~ Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: ~-~~~~ ~ ~~~~ ndsay Dare ' d, Esquire Attorney for the Plaintiff ~ y C r a ~ ' ~ 1' :J .y:,,. ~ y i~ ' .:..y r J C' `S ` ~ ~ ~ ._ ~ 'e 1 N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF ~~ PENNA. ~ _ .. .~ t~ TRACI L. ZURNER, ,-_: a~ Plaintiff VERSUS SCOTT E. 'I'[JRNER, Defendant N O . 07-1 X05 DECREE [N D[VORCE AND NOW, ~ ~~- ( IT IS ORDERED AND DECREED THAT TRACI L. T[JRNE12 PLAINTIFF, SCOTT E. 'TURNER AND DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECOR~THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; ~V~ /~~ The Property Settlement Agreement is incorporated, but not merged into the final decree. BY TH ATTEST: ~ J . PROTHONOTARY .~ ~• . .,, ~, : .