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JEFFREY C. PAWLOWSKI,
Defenr1i.lnt
IN DIVOHCE
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,/17 It i" ordered and
AND NOW,
decreed that
and
AMY R, PAlvLOWSKI
JEFFREY C. PAWLOWSKI
plointiff,
ore divorced frorn the bonds of 1110 T'/{''',':l',! ,
defendont,
The court retains jurisdiction uf the) 1(,/10"''';''9 cloirns which hove
been raised of record in this acllon I", \',I':ch " fiilul order has not yet
been entered;
NONE, The terms of the Marital Settlement Agreement dated July 15, 1999
areincorfloz:ated ,but not merged into this Decree in Divorce,
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p<?'w'lows.... . 1115<1 . Jllly l~'. FI'I(j
AMY R. PAWLOWSKI,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - DIVORCE
NO, 98 - 6108 CIVIL TERM
Plaintiff
vs,
JEFFREY C, PAWLOWSKI,
Defendant
IN DIVORCE
MARITAL SETTLEMENT AGREEMENT
THIS Agreement made this
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day of
I.
, 1999 by and
between AMY R. PAWLOWSKI, of 106 Wolfs Bridge Road, Apt. D, Carlisle, Pennsylvania,
hereinafter referred to as WIFE, and JEFFREY C. PAWLOWSKI, of 2129 Schwab Avenue,
Bethlehem, Pennsylvania, hereinafter referred to as HUSBAND,
WITNESSETH:
WHEREAS, the parties hereto are husband and wife, having been joined in marriage on
June 3, 1995, in Tamaqua, Pennsylvania; and
WHEREAS, a Complaint for Divorce has been filed in the Court of Common Pleas of
County, Pennsylvania, to No, 98-6108, Civil Term; and
WHEREAS, the parties hereto are desirous of settling fully and finally their respective
financial and property rights and obligations as between each other, including, without limitation, the
settling of all matters between them relating to the ownership of real and personal property, claims
for Spousal support, alimony, alimony pendente lite, counsel fees and costs, and in general, the
settling of any and all claims and possible claims against the other or against their respective
estates,
Pi'oWIOW5k.
rIl5i1 Jul., 12 l~'~YI
NOW, THEREFORE, in consideration of these considerations, and the mutual promises and
undertakings hereinafter set forth, and for other good and valuable consideration. receipt and
sufficiency of which is hereby acknowledged by each of the parties hereto, HUSBAND and WIFE.
each intending to be legally bound. hereby covenant and agree as follows:
1, 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. WIFE is represented by Carol J, Lindsay. Esquire.
and HUSBAND has been advised that he may be represented by counsel of choice, Each party
acknowledges and accepts that this agreement is, in 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 that execution of this agreement is not the result
of any duress or undue influence. and that it is not the result of any improper or illegal agreement or
agreements,
2, Divorce: The parties agree to the entry of a Decree in Divorce, The parties will
execute. on the date of this agreement, Affidavits of Consent and Waivers of Notice under Section
3301 (c) of the Divorce Code. consenting to the entry of a Decree in Divorce,
3, Personal Property: The parties acknowledge that they have equitably and
satisfactorily divided all of their personal property. and that all personal property shall be the sole
and individual property of the party in whose possession it is as of the date of this agreement.
4, Alimony: The parties waive any claim that they may have one against the other for
alimony. alimony pendente lite or spousal support, The parties acknowledge that each has sufficient
assets with which to maintain themselves after divorce,
p<;wloWSkl
111~;1 .July 1~', 19u9
5, Marital Debt: The parties were indebted to Hous(lhold Credit in the amount of
approximately $500,00 on the date of separation, Said obligation will be the sole responsibility of
WIFE, HUSBAND will pay to WIFE $250,00 on account of said obligation, Said payments will be
made at the rate of $10,00 per month commencing July 15, 1999 and continuing on the same day
each and every month for 25 months,
The parties filed a Bankruptcy in September, 1997 listing on the Bankruptcy schedules
a Volkswagen Jetta, Subsequently, the vehicle was repossessed, The vehicle was encumbered by
an obligation to Volkswagen Credit Company, In the event said debt is not discharged in
Bankruptcy and Volkswagen Credit Company seeks payment on a deficiency, said obligation will be
the sole responsibility of HUSBAND.
6, Exchange of Information: The parties have requested from each other and received
any information regarding their assets, liabilities, income and expenses which the party requires
prior to entering into the terms of this Agreement. The parties acknowledge that the terms of this
Agreement are fair and equitable and constitute an equitable distribution of marital property and
debt, taking into account all of the relevant factors set out in Section 3502 of the Divorce Code, 23
Pa, C,S,S3502 including the length of the marriage; any prior marriage of the parties; the age,
health, station, amounts and sources of income, vocational skills, employability, estate, liabilities and
needs of each of the parties; the contribution by each party to the education, training or increased
earning power of the other; the opportunity of each party for future acquisitions of capital assets and
income; the sources of income of both parties, including but not limited to, medical, retirement,
insurance or other benefits; the contribution or dissipation of each party in the acquisition,
preservation, depreciation, or appreciate of the marital property, including the contribution of a party
as homemaker; the value of the property set apart to each party; the standard of living of the parties
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during the marriage; the economic circumstances of each party including federal, state and local tax
ramifications at the time of the division of the property, and whether the party will be serving as
custodian of any dependent minor children,
7, Modification: No modification, rescission, or amendment of this agreement shall be
effective unless in writing signed by each of the parties hereto,
8, Applicable Law: All acts contemplated by this agreement shall be construed and
enforced under the laws of the Commonwealth of Pennsylvania,
9, Agreement Binding on Parties and Heirs: This agreement, except as otherwise
expressly provided herein, shall bind the parties hereto, and their respective heirs, executors,
administrators, legal representatives, assigns and successors in any interest of the parties,
10, Agreement Not to be Merged: This agreement shall be incorporated into the final
decree of divorce of the parties hereto for purposes of enforcement only, but otherwise shall not be
merged into said decree, The parties shall have the right to enforce this agreement under the
Divorce Code of 1980, as amended, and in addition, shall retain any remedies in law or in equity
under this agreement as an independent contract. Such remedies in law or equity are specifically
not waived or released,
11, Documents: The parties hereto agree that they will execute and deliver one to the
other any documents necessary to give effect to the terms of this Agreement.
12, Full and Final Settlement: WIFE and HUSBAND each do hereby mutually remise,
release, quitclaim and forever discharge the other and the estate of such other, for all time to come,
and for all purposes whatsoever, of and from any and all rights, titles, interests or claims in or
against the property (including income and gain from property hereafter accruing, of the other) or
against the estate of such other, of whatever nature and wheresoever situate, which she or he now
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has or at any tim'? hereafter may have against such other, the estate of such other or any part
thereof, whether arising out of any former acts, contracts, engagements or liabilrties of such other, or
by way of dower or curtesy, or claims in the nuture of dower or curtesy, or widows' or widowers'
rights, family exemption or similar allowance, or under the intestate laws, or the right to take against
the spouse's will; or the right to treat a lifetime conveyance by the other as testamentary, or all other
rights of a surviving spouse to participate in a deceased spouse's estate, whether arising under the
laws of Pennsylvania, any other State, or any other Country, or any rights which either spouse may
have, or at any time hereafter have, for past, present or future support or maintenance, alimony,
alimony pendente lite, counsel fees, costs or expenses, whether arising as a result of the marital
relation or otherwise, except and only except, all rights and agreements and obligations of
whatsoever nature arising or which may arise under this Agreement or for the breach of any term
thereof. It is the intention of HUSBAND and WIFE to give to each other by the execution of this
Agreement a full, complete and general release with respect to any and all property of any kind or
nature, real, personal or mixed, which the other now owns or may hereafter acquire, except and only
except, all rights and agreements and obligations of whatsoever nature arising or which may arise
under this Agreement, or for the breach of any term thereof, subject, however, to the
implementation and satisfaction of the condition precedent as set forth herein above,
13, 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, including, but
not limited to, court costs 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,
p:twlow:;\.1
Im,l July 1;', l~,!j~1
IN WITNESS WHEREOF, the parties hereto have set their hands and seals the day and year
first above written,
Witness:
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(Seal)
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()J rye, Pawlowski
(Seal)
AMY R. PAWLOWSKI,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION. DIVORCE
NO, 98.6108 CIVIL TERM
Plaintiff
vs,
JEFFREY C. PAWLOWSKI,
Defendant
IN DIVORCE
PRAE~PETOTRANSMITRECORD
To Ihe Prothonotary:
Transmit the record. togelher with the following informalion, to the court for enlry of a divorce decree:
1, Ground for divorce: irrelrievable breakdown under Section 3301(c) ~4)f+) of the Divorce
Code, (Strike out inapplicable section),
2, Date and manner of service of the complaint: Certified Mail; Return Receipt signed by
Defendant, Jeffrey C, Pawlowski, on October 30, 1998,
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 July 15, 1 999; by the Defendant July 15, 1999,
(b) (1) Date sf allocution ef tho Plaintiffe arHdovit ro~uirod bj' Seclion 3301 (El) of
Iho Dil'orco Cedo:
(2) Date ef sorvico ef tho Plaintiffs affidavit-\Ij3efHAe-Dofonsant:
4, Related claims pending: None
5, Complete either (a) or (b),
(a) Date and manner of service of the notice of intention to file praecipe to
transmit record, a copy of which is altached: August
1999.
(b) Date Plaintiffs Waiver of Notice in 3301(c) Divorce was filed with the
Prothonotary: August
,1999,
Date Defendant's Waiver of Notice in 3301 (c) Divorce was filed with the Prothonotary:
. .
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Carol J, Lindsay, Altorney(for Plaintify~,
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AMY R. PAWLOWSKI,
Plaintiff
VS,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
JEFFREY C, PAWLOWSKI,
Defendant
CIVIL ACTION. DIVORCE
NO, 98. ,1/ CIVIL TERM
IN DIVORCE
NOTICE
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, tbe 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 otber rigbts important to you, including
custody or visitation of your children,
When tbe 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 Court House, Carlisle, Pennsylvania, 17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR
EXPENSES BEFORE A DECREE OF DIVORCE OR ANNULMENT IS GRANTED. YOU MAY LOSE THE
RIGHT TO CLAIM ANY OF THEM,
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE. GO TO OR TelEPHONE THE OFFICE SET FORTH BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP,
CUMBERLAND COUNTY BAR ASSDCIA TIDN
2 LIBERTY A VENUE
CARLiSLE, PENNSYL VANIA 17013
(717) 249-3166
FLOWER, MORGENTHAl FLOWER & LINDSAY, P,C,
Attorneys f~U>Jaintiff
By:
Date:
(Ot~.
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VERIFICATION
I, the undersigned, hereby verify that the statements made herein ore true and correct.
understand that false statements herein ore made subject to the penalties of 18 Pa, C,S, S 4904,
relating to unsworn falsification to authorities,
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Amy R,PowloW'Ski
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Date: ," ): LC.
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AMY R. PAWLOWSKI,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS,
CIVIL ACT/ON. DIVORCE
NO, 98.6108 CIVIL TERM
JEFFREY C, PAWLOWSKI,
Defendant
IN DIVORCE
AFFIDAVIT OF CONSENT
1, A ComplamlHI Dlvor",! IIIld," Ii THill') 011111' lJIVorCI! Co(le was filed on Oclober 26,1998,
2, Tho mamagu (J( pl,,,"t,(t oIlId dl'l"IH)oIIII i:, III"I""VoIIJly IJroken and ninety days have elapsed
from the dale of filing alll) S'!lVICU 1111,,,, 1:""'1",""1
3, I consenllo lilo "IItry 01 01 IllIoI'III'<:II'I! '" lJIVorCI! i1l1er serv,ce of nC'lice of inlention to request
entry of the Decree.
I verify thai tile stall!/lll!/lls II1<"II! HI II,,:; ^,1'dilvll dre I,ue and correct 10 the besl of my knowledge,
information and belief IlJ/H)"':;I:llId 111<11 fil",I! "Iillo"'enls ilorein are made subject '10 the penalties of 18
Pa,C,S, 4904 relating 10 unswo", lillslllCdlHJIl 10 i1ulllonl_, "",
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WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
!l3301(cl OF THE DIVORCE CODE
1, I consenllo lile enlry 01 a final Decree 01 Divorce wilhoul notice,
2, I understand thai I may lose nglils concerning alimony, division of property, lawyer's fees or
expenses if I do not claim them before a ellvorco IS grantod
3, I underslaml tllat I will not lJo divorced un Iii a Divorce Decree is entered by the Court and
that a copy of the Decree will bo senllo 1110 inl/llOe!latoly aftor il is filed wilh the Prothonotary,
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I verify thallilo slatolllenls Il1:1do HI tlHS ^,lldavII are true ahi:{ com;c;t.to the best of my knowledge,
informalion and boliof /lJ/H!orslalleltll:11 fil/so slalornonls herein are made subject to the penalties of 18
Pa,C,S, 4904 relaling 10 on,;worn Iilbll,eilt,oll 10 il~tnlliilie:h,' .. ),
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, Amy R PowlOWski, Plaintiff
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
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AMY R, PAWLOWSKI,
VS,
CIVIL ACTION. DIVORCE
NO, 98.6108 CIVIL TERM
JEFFREY C, PAWLOWSKI,
Dofelldant
IN DIVORCE
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AFFIDAVIT OFCQfIcl.!?_ENT
A COlllpl,III1III1IlIVOIU! Ulld", Ii :U01(c) of Ihe Divorce Code was filed on October 26,1998,
;' It", """rld<)" of pl;\Il1lltf ;Hld defelldal1t 1$ "retrlevably broken and ninety days have elapsed
frol11l1le ddle 01 fllll1<1 dlld ""rVlt:" of 111" COl1lpldlnl
3 I cOII",,"ltn III" ""lIy of a filIal Decree Ifl DIvorce after service of notice of Intention to request
entry of the Decrt!o
I verify that th" stalelllerlts I11nde In thIS AffIdaVIt are true and correct to the best of my knowledge,
information and behe}l I 11l1dorstnnd Ihilt false stiltements herein are made subject to the penalties of 18
Pa,C,S 4904 relatln9 10 unsworn fnlslllciltlOl1to authorities,
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, Date I \ I 'i 111
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
&3301/c) 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 and
that a copy of IIle 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,
inlorrnatlon ill1d 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,
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AMY R. PAWLOWSKI,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
vs,
CIVIL ACTION - DIVORCE
NO, 98 - 6108 CIVIL TERM
JEFFREY C. PAWLOWSKI,
Defendant
IN DIVORCE
CERTIFICATE OF SERVICE
AND now, this /'1"< day of ~. , 1998, I,
CAROL J, LINDSAY. Esquire, of the law firm of FLOWER, MORGENTHAL, FLOWER &
LINDSAY, Attorneys, hereby certify that I served the Defendant, JEFFREY C. PAWLOWSKI, on
October 3D, 1998 with the Complaint by Certified Mail, Return Receipt Requested, Restricted
Delivery, Addressee Only, addressed to:
Mr, Jeffrey C, Pawlowski
2129 Schwab Avenue
Bethleham, PA 18015
and proof thereof, the signed Return Receipt Card, is attached hereto,
FLOWER, MORGENTHAL FLOWER & LINDSAY, P,C,
Attorneys for Plaintiff
By:
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I, AMY R. PAWLOWSKI,
IN THE COURT OF COMMON PLEAS OF
CUMBERLANDCOUNTy,PENNSYLVAN~
Plaintiff
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VS,
CIVIL ACTION. DIVORCE
NO, 98. 6108 CIVIL TERM
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JEFFREY C, PAWLOWSKI,
Defendant
IN DIVORCE
PROOF OF SERVICE
';; ER:
'tJ -Completo hems' andror 2 lor additional "'MCSI.
.. -Complete 110m. 3, 4a, and <lb.
J. -Print your name and address on 1110 raverse ollMi! form 50 Ihat we can return this
ii card loycu.
-Attach this form 10 the Ironl of lhe mailpiece, or on Ihe back il apace dOBS not
e po""l. DELIVER TO ADDRESSEE
CD -Write oRe/um Recsipt Requested' on Ihe rnaiJpiace below Ihe article numb or.
5 -The Return Receipt will show 10 whom the er1ic1a waa delivered and the dala
c delivered.
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I also wish to receive the
following services (for an
extra tee):
Nt p Addressee's Address i
2. bl: Restricted Delivery UJ
Consult postmaster for fee. I
48, Article Number ;
Z 452 470 130 a:
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3. Article Addressed to:
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Mr. Jeffrey C. Pavlowski
2129 Schwab Avenue
Bethleham, PA 18015
4b. Service Type
o Registered
o Express Mail
o Return Receipt for Merchandj~e
7, DjI't at Delivery .
U /0- 'YO'
8. dressee's Address (Only it requested
nd tee is paid)
Dl Certified
o Insured
o COD
PS Form 3811, December 1994
Domestic Return Receipt
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
AMY R. PAWLOWSKI,
'IS,
CIVIL ACTION. DIVORCE
NO. 98.6108 CIVIL TERM
JEFFREY C, PAWLOWSKI,
Defendant
IN DIVORCE
NOTICE OF INTENTION TQ
RESUME PRIOR NAME
NOTICE IS HEREBY GIVEN that, the in the above matter, having been granted a Final
Decree in Divorce on September 3, 1999 hereby intends to resume and hereafter use the previous
name of Amy R. Boyle, and gives this written notice avowing her intention in accordance with the
provisions of the Act of April 2, 1980, PL, 23 P,S, 702, effective July 1, 1980,
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- A~y~R: PawloWSRCPetitioner
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COMMONWEALTH OF PENNSYLVANIA
ss.
COUNTY OF CUMBERLAND
.' 'f II
ON this, the -~~' day of\. )( 1)( II L/jl ( , 1999, before me, a Notary Public,
personally appeared Amy R. Pawlowski, known to me or satisfactory proven to be the person
whose name is subscribed to the within instrument and acknowledged that she executed the same
for the purposes therein contained,
IN WITNESS WHEREOF, I have hereunto set my hand and official seal.
NOTA!u.AL StAt
metA L elJl:::V. N<;.tc:y P'uO!k
Scvthampion Twp., Cvmb"",kJnd Co., PA
My Commlu.iun E.piru Avg. 12, 2002
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