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IN THE COURT OF COMMON PLEAS I
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OF CUMBERLAND COUNTY
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STATE OF"':;"~;
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PENNA.
KIMBERLY A. MARKHAM,
-lliillUlJ
NO.
9$1-6602 crVl1. TFRH _.
VERSUS
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Defendant
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DECREE IN
DIVORCE
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AND NOW,
2000 . IT IS ORDEREO AND
DECREED THAT
KIMB8RLY A. HARKIlAM
PLAI NTI FF.
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BENJAlofIN J. MARKHAN
AND
. DEFENDANT.
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ARE DIVORCED FROM THE BONDS OF MATRIMONY,
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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:
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None. The Post-Nuptial Agreement dated February 17, 2000 is hereby
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incorporated but not merged into this Decree.
ROTHONOTARY
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POST-NUPTIAL AGREEMENT
THIS AGREEMENT made and entered into this
17".,8
day of
+' ~-+Q. '( , 2000 by and between:
KIMBERL Y A. MARKHAM, of Mechanicsburg,
Cumberland County, Pennsylvania, party
of the first part, (hereinafter "Wife")
AND
BENJAMIN 1. MARKHAM, of (}.A-P, r lS'[E' I tu."'1l.:ev bl-tL
Lc; t.Q, n l' Y , Pennsylvania, party of
the second part. (hereinafter "Husband")
WITNESSETH:
WHEREAS, Husband and Wife (collectively referred to herein as "the parties") were
married to each other on September 16. 1995 in Cumberland County, Pennsylvania and separated
on November 2. 1998; and
WHEREAS, the parties last resided with each other at 910 Greenbriar Drive,
Mechanicsburg, Cumberland County, Pennsylvania; and
WHEREAS, the parties have accumulated certain assets and incurred certain debts during
their marriage; and
LAW OFFICES
SNELBAKER.
BRENNEMAN
8: SPARE
WHEREAS, the parties have one child of their marriage: namely, Joshua Tyler Markham,
born June 8, 1997; and
WIIEREAS, certain diflcrences have arisen between the panics, as a consequence of
which they have separated and now live separate and apart from each other, and
WHEREAS, on November 19, 1998 Wife initiated an action in divorce docketed to No,
98-6602 in the Court of Common Pleas of Cumberland County, Pennsylvania (hereinafter the
"Divorce Action"); and
WHEREAS, the parties agree that their marriage is irretrievably broken; and
WHEREAS, the parties acknowledge that each has had the full opportunity to be advised
independently and represented by separate counsel concerning their respective rights, duties and
obligations arising out of their marital status and with respect to the terms and provisions of this
Post-Nuptial Agreement and the meaning and legal effect thereof: Husband by Lindsay Dare
Baird, Esquire and Wife by Keith O. Brenneman, Esquire of Snelbaker, Brenneman &
Spare.P. c.;
WHEREAS, the parties having a full opportunity to be so advised of their respective
rights, duties and obligations arising out of their marital status, and each having a full opportunity
to investigate and evaluate assets, liabilities and all other aspects of each other's property and their
jointly owned assets and liabilities, have voluntarily come to an agreement for the final settlement
of their property and affairs, which they believe to be fair, just and equitable.
NOW THEREFORE, in consideration of these presents and the mutual covenants,
I..AW OFFICE~
SNELBAKER.
BRENNEMAN
& SPARE
promises, terms and conditions hereinafter set forth and to be kept and perfonned by each party
I hereto, and intending to be legally bound hereby, the parties mutually agree as follows:
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I, INCORPORATION OF PREAMBLE, The foregoing preamble and paragraphs arc
incorporated by reference herein in their entirety,
2. MUTUAL SEPARATION. Husband and Wife shall be free from constraint or control
by the other as fully as ifhe or she were unmarried. Neither shall disturb, trouble or interfere in
any way with the other or with any person for associating with the other,
3. DECLARATION AS TO ASSETS AND WAIVER OF EVALUATION,
The panies declare and agree that they have, prior to the executiun of this Post-Nuptial
Agreement, voluntarily agreed to divide and have physically divided and distributed between
themselves all assets which they acquired during their marriage, Said division and distribution has
occurred as set fonh herein whether or not said property is or would be deemed to be marital
property under the Pennsylvania Divorce Code and subject to equitable distribution.
The panies declare and acknowledge that they are fully aware and familiar with all assets
and real property that each has brought into the marriage and that has been obtained or acquired
separately or jointly by them during the course of their marriage and therefore waive any valuation
thereof. Each party expressly releases the other of and from any and all right of equitable
distribution or claims to assets and property of any kind or nature whatever possessed in
accordance with the division that occurred prior to the execution of this Agreement and possessed
as a result of this Agreement by the other party and hereby declares and acknowledges that the
voluntary division by them of all property, whether marital or not, is fair and equitable,
LAw OFFICES
SNEL.BAKER.
BRENNEMAN
8: SPARE
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4. M,\RITAL RESIDENC{~t\J 910 GR{;ENBRIAR DRIVE. MECHANICSBURG
Ilusb"nd "nd Wifc "cknowledgc Ihatthey acquired during thcir marriage real property
improvcd with a residcncc located at 910 Greenbriar Drivc, Mechanicsburg, Pennsylvania
(hereinafter the "marital residence"), It is further acknowledged by the parties that the marital
residence has been sold and Ihe closing on that sale took place on March 26, 1999.
The parties also acknowledge that Husband contributed certain funds in the amount of
$1,543.80 at rime of settlement in order 10 conclude the sale of the marital residence. Husband
specifically releases Wife from any and all claims, suits, demands or actions for contribution for or
reimbursement of any funds paid by him at closing as noted above.
5. DIVISION OF DEBT AND LIABILITIES. The parties acknowll'dge that they have
incurred debts and liabilities during their marriage which remain unpaid. The debt due as of
March, 1999 is as follows:
Credit Union consumer loan:
Americhoice F.C.U, credit card:
Capital One Visa card:
$5,647.00
2,136,08
5,347.03
Wife agrees to be solely responsible for the payment and extinguishment of the Credit
Union consumer loan identified above, which loan is secured by a motor vehicle identified in
Paragraph 6, infra, Husband agrees to be solely responsible for the payment and extinguishment
of the Americhoice and Capitol One credit card debts. Each party agrees to be solely responsible
for the payment and extinguishment of the debts as agreed to herein whether or not the other
LAW OFFICES
SNEL.BAKER.
BRENNEMAN
& SPARE
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Post-Nuptial Agreement
8. PENSION. 401K. RETIREMENT PLANS. BENEFITS AND
EMPLOYMENT BENEFITS,
Each party waives and forever releases the other of and from any and all claims which
either may have against the other's pension. 40 I K Plan, retirement plan or any other retirement
plan benefit or employee benefit or benefits,
9. RELEASE OF SUPPORT AND RIGHTS UNDER DIVORCE CODE.
Each party waives and forever releases the other party of and from any and all claims
which either may have against the other for spousal support and except as otherwise set forth
herein. for all claims which either may have against the other by reason of and pursuant to the
Pennsylvania Divorce Code (and the divorce law of any other jurisdiction) including, but not
limited to, alimony, alimony pendente lite, equitable distribution of marital property, counsel fees,
costs and expenses, except that the performance of any obligation created hereunder may be
enforced by any remedies under the Pennsylvania Divorce Code,
10. DIVORCE. The parties agree to terminate their marriage by mutual consent without
counseling and each agrees to execute the necessary affidavits, waivers and consents to procure a
consensual divorce under the provisions of the Pennsylvania Divorce Code. Said affidavits,
waivers and consents shall be utilized for purposes of obtaining a divorce in the Divorce Action
docketed to No, 98-6602, Cumberland County.
l.AW OFFICES
SNELBAKER.
BRENNEMAN
Be SPARE
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15, GENEMJ,j~l'-IJ;I\SE Ilushand relinquishes his inchoate intestate right in the estate I
of Wife. and Wife relinquishes her inchoate intestille right in the estate of Husband, and each of
the parties hereto by these presents, for himself or herself: his or her h~irs. executors.
administrators or assigns, docs hereby remise, release, quit-claim and forever discharge the other
party hereto, his or her heirs, executors. administrators or assigns. or any of them, of any and all
claims, demands, damages, actions, causes of action or suits at law or in equity of whatsoever
kind or nature, for or because of any matter or thing done. omitted or suff~red to be done by such
other party prior to the date hereof, except that this release shall in no way exonerate or discharge
either party from the obligations and promises made or imposed by reason of this Agreement.
16, SURVIVAL OF AGREEMENT. It is the intention of the parties that this Post-
Nuptial Agreement shall survive any action in divorce which may be instituted or prosecuted by
either party, and no order, judgment or decree of divorce, temporary, interlocutory, final or
permanent, shall affect or modifY the terms of this Agreement. but said Agreement may be
enforced by any remedy at law or in equity, including enforcement proceedings under the
Pennsylvania Divorce Code, The parties agree to incorporate this Agreement into a separate
order of court to be entered in the Divorce Action, but this Agreement shall not be merged into
said order or decree in divorce.
17. COOPERATION. The parties agree to cooperate with each other and to make,
execute, acknowledge and deliver such instruments and take such further action as may hereafter
LAW OFFICE!;
SNEI..BAKER.
BRENNEMAN
Be SPARE
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20. fNH!W AGBm,l\1EN.I This Post-Nuptial Agreement contains the entire
understanding of the panics and there arc no representations, warranties, covenants or
undenakings other than those expressly set fonh herein. The panics acknowledge and agree that
the provisions of this Agreement with respect to the distribution and division of marital and
separate propeny are fair, equitable and satisfactory to them based on the length of their marriage
and other relevant factors which have been taken into consideration by the panies. Both panies
hereby accept the provisions of this Agreement with respect to the division of propeny in lieu of
and in full and linal selllement and satisfaction of all claims and demands that they may now have
or hereafter have against the other for equitable distribution of their propeny by any coun of
competent jurisdiction pursuant to the Pennsylvania Divorce Code or any amendments thereto.
Each pany voluntarily and intelligently waives and relinquishes any right to seek a coun ordered
determination and distribution of marital propeny, but nothing herein contained shall constitute a
waiver by either pany of any rights to seek the relief of any coun for the purpose of enforcing the
provisions of this Agreement.
21. WAIVER, The waiver of any term, conditions, clause or provision of this Agreement
shall in no way be deemed or considered a waiver of any other term, condition, clause or
provision of this Agreement.
22. APPLICABLE LAW, This Agreement shall be construed, interpreted and enforced
LAw OFFIces
SNEL.BAKER.
BRENNEMAN
8: SPARE
according to the laws of the Commonwealth of Pennsylvania.
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COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND
55.
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On this the
l,tO
day of .Q~u IlI2 'l
, 2000, before me, a Notary
Public in and for said State and County, the undersigned officer, personally appeared BENJAMIN
1. MARKHAM, known to me (or satisfactorily proven) to be the person whose name is
subscribed to the within instrument and acknowledged that he executed the same for the purposes
therein contained,
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
1\ (H OM ..l/~CLl'/l L
\ Notary Public
,,'_:...,:~1 Seal
Niven J. e~;.> '~'::~my Public
Carlisla Bora, t:,.tll!.lcrland County
My Commissien I.,'" .~:; Nov. 2, 2002
Member, P,-mn:Jyiv.:., , .. <:If NClanes
COMMONWEALTH OF PENNSYLVANIA) i
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COUNTY OF CUMBERLAND I
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On this the ;;<Cjfl.. day of I ::'b~ .. , 2000, before me, a Notary Public I
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in and for said State and County, the undersigned officer, personally appeared KIMBERLY A.
MARKHAM, known to me (or satisfactorily 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 hereunto set my hand and official seal.
A<rc-1 ?t ~
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! KIMBERLY A. MARKHAM,
I Plaintiff
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INTI IE COllin OF COMMON PI.EAS OF
CUMBERLANO COUNTY, PENNSYLVANIA I
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NO, 99-6602 CIVIL TERM
CIVIL ACTION - LAW
BENJAMIN 1. MARKHAM.
Defendant
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
TO: Prothonotary of Cumberland County:
Please transmit the record, together with the following information, to the Court for entry
of a divorce decree:
Code.
I, Ground for divorce: irretrievable breakdown under Section 330 I (c) of the Divorce
2. Date and manner of service of Complaint: by certified mail, restricted delivery on or
about November 25, 1998 (see Affidavit of Service filed herein),
3. Date of execution of the Affidavit of Consent required by Section 330 I (c) of the
Divorce Code: by the Plaintiff: February 29, 2000; by the Defendant: February 17, 2000.
4. Related pending claims: None,
5, Date of execution of Waiver of Notice in Section 3301(c) Divorce: by the Plaintiff:
February 29, 2000; by the Defendant: February 17, 2000.
SNELBAKER, BRENNEMAN & SPARE. P. C.
LAW OFFICE5
SNELBAKER.
BRENNEMAN
Be SPARE
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By: ){t " h'1:#U/L
Attorneys for Plaintiff
Date: March I, 2000
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KIMBERLY A. MARKHAM,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERI,ANO COUNTY, PENNSYLVANIA
v.
NO. 98- /./. (' .L._' CIVIL TERM
CIVIL ACTION - LAW
': BENJAMIN J. MARKHAM,
!I Defendant
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IN DIVORCE
NOTICE
i' You have been sued in Court. If you wish to defend against
:, the claims set forth in the following pages, you must take prompt
Ii action. You are warned that if you fail to do so, the case may
i' proceed without you and a decree of divorce or annulment may be
iientered against you by the Court. A judgment may also be entered
il against you for any other claim for relief requested in these
Ipapers by the Plaintiff. You may lose money or property or other
I, rights important to you, including custody or visitation of your
Ii children.
;1
Ii When the ground for divorce is indignities or irretrievable
Ibreakdown of the marriage, you may request that the court require
I' you and your spouse to attend marriage counseling prior to a
Idivorce decree being handed down by the court. A list of
. marriage counselors is available in the Office of the
Prothonotary at the Cumberland county Court House, Carlisle. You
are advised that this list is kept as a convenience to you and
you are not bound to choose a counselor from the list. All
necessary arrangements and the cost of counseling sessions are to
be borne by you and your spouse.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF
PROPERTY, LAWYER'S 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 Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
(717) 249-3166
LAW OF'FICES
SNELBAKER.
BRENNEMAN
8: SPARE
By:
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I KIMBERLY A. MARKHAM,
II Plaintif [
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 98-t..G.O.l., CIVIL TERM
CIVIL ACTION - LAW
BENJAMIN J. MARKHAM,
Defendant
IN DIVORCE
COMPLAINT
1. The Plaintiff in this action is KIMBERLY A. MARKHAM, an
adult individual residing at 1817 Hunter Drive, Mechanicsburg,
Cumberland County, Pennsylvania.
2. The Defendant in this action is BENJAMIN J. MARKHAM, an
adult individual residing in 910 Greenbriar Drive, Mechanicsburg,
Cumberland County, Pennsylvania.
3. Both the Plaintiff and Defendant have been bona fide
residents of the Commonwealth of Pennsylvania for at least six
(6) months immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were lawfully joined in
marriage on September 16, 1995 in Carlisle, Cumberland County,
Pennsylvania.
5. There have been no prior actions of divorce or
for annulment between the parties hereto in this or any other
jurisdiction since the date of the marriage averred in Paragraph
LAW OFFICES
5NEL.BAKER.
BRENNEMAN
8: SPARE
4, above.
6. Neither party is a member of the armed forces of the
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states of America.
COUNT I - DIVORCE
7.
The Plaintiff avers as the grounds upon which this
action is based is that the marriage between the parties hereto
I
lis irretrievably broken.
8. The 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.
9. The Plaintiff requests this Court to enter a decree of
divorce.
COUNT II - EOUITABLE DIVISION OF PROPERTY
10. The Plaintiff and Defendant have legally and
beneficially acquired property both real and personal during
their marriage from September 16, 1995.
11. The Plaintiff requests this Court to equitably divide
all marital property pursuant to Section 3502 of the Pennsylvania
Divorce Code.
WHEREFORE, the Plaintiff, Kimberly A. Markham, requests this
Court to:
LAW OFFICES
SNEL.BAKER.
BRENNEMAN
8: SPARE
(a) enter a decree of divorce, divorcing the Plaintiff from
the bonds of matrimony heretofore existing between the
Plaintiff and Defendant;
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(b) order equitable distribution of marital property; and
(c) order such other relief as the Court deems just
and reasonable.
SNELBAKER, BRENNEMAN & SPARE, P.C.
Date: N.1IE>rhate. 1'-, /9f.
By: Vh~
Keith o. Brenneman, Esquire
44 West Main Street
Mechanicsburg, PA 17055-0318
Telephone: 717-697-8528
Attorneys for Plaintiff
Kimberly A. Markham
i:,
LAW OFFICES
SNELBAKER.
BRENNEMAN
8: SPARE
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I KIMBERl.Y A MARKIIAM.
Plaintiff
I N TilE COURT OF COMr-.'ION Pl.EAS OF
CUMBERl.AND COUNTY, PENNSYl.VANIA
v
NO, ')8.6b()~ CIVIl. TERM
nVI L ACTION. l.A W
BENJAMIN J MARKIIAM,
Defendant
IN DIVORCE
PLAINTIFF'S WAIVER OF NOTICE OF INTENTION
TO REQUEST ENTRY OF A DIVORCE DECREE
UNDER SECTION JJOI(~J OF '[tUU!!VORCE CODf;
I. I consel1lto the entry of a final decree of divorce wilhoutnotice,
2, lunderstand that I may lose rights concerning alimony, division of property, lawyer's
fees, or expenses if I do not c1aimthel11 before a divorce is granted,
J, 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.
4, I verify that the statemenls 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: J..~'9/0()
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Ki Serly A. Markham
LAW OFFICE!:
SNELDAKER.
BRENNEMAN
& SPARE
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KIMBERI.Y A MARKIIAM,
Plaintiff
IN TilE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY. PENNSYLVANIA
v
NO, 98-6602 CIVIL TERM
CIVIL ACTION - LAW
BENJAMIN J MARKHAM,
Defendant
IN DIVORCE
DEFENDANT'S WAIVER OF NOTICE OF INTENTION
TO REQUEST ENTRY OF A DIVORCE DECREE
UNDER SECTION 330 Hc) OF THE DIVORCE CODE
I, I consent to the entry of a linal decree of divorce without notice.
2, I understand that [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 tiled with the
prothonotary,
4, 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. !i 4904 relating to
unsworn falsilication to authorities.
Date: .:2 ( /'1 ( :1.00 t)
,L5} / ;/J{;ct/
. /I3~ A. Markham
LAW OFFIce:::
SNEL.ElAKER,
BRENNEMAN
8: SPARE:
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I KIMBERLY A. MARKHAM,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 98-6602 CIVIL TERM
CIVIL ACTION - LAW
BENJAMIN J. MARKHAM,
Defendant
IN DIVORCE
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA)
SS.
COUNTY
OF
CUMBERLAND)
Keith O. Brenneman, Esquire, being duly sworn according to
law deposes and says: that he is a principal in the law firm of
Snelbaker, Brenneman & Spare, P. C., being the attorneys for
Kimberly A. Markham, the Plaintiff in the above captioned action
in divorce; that on November 23, 1998, he did send to Defendant
Benjamin J. Markham by certified mail, return receipt requested,
restricted delivery, a duly certified copy of the Complaint in
Divorce which was filed in the above captioned action as
evidenced by the attached cover letter of the same date and
Receipt for Certified Mail No. Z 462 229 685; that both the
Complaint and cover letter were duly received by Benjamin J.
Markham, the Defendant herein, as evidenced by the return receipt
card for said certified mail dated November 25, 1998; that a copy
of the aforementioned cover letter dated November 23, 1998 is
LAW OFFICES
SNELDAKER.
8RENNEMAN
& SPARE
attached hereto and incorporated by reference herein as "Exhibit
A" and that the original Receipt for certified Mail and the
Domestic Return Receipt are attached hereto and incorporated by
reference herein as "Exhibit B"; and that the foregoing facts are
true and correct to the best of his knowledge, information
and belief.
O. Brenneman
Sworn to and subscribed before
me this .3 001 day of )zClf-C 1,~6-Or.' , 1998.
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Notary PUblic
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MECIMN/C58URC. PENNSYLVANIA 17055
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November 23, 1998
Benjamin J. Markham
910 Greenbriar Drive
Mechanicsburg, PA 17055
Re: Markham v. Markham
No. 98-6602, Cumberland County
Dear Mr. Markham:
Enclosed please find a certified copy of a Divorce
Complaint, the original of which was filed on November 19, 1998.
'lours truly,
Keith O. Brenneman
KOB/sz
Enclosure
CC: Kimberly A. Markham (wi enclosure)
Via certified mail, restricted delivery, return receipt
requested, Parcel No. Z 462 229 685
EXHIBIT A