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Home My WebLink About00-05230 , , , ~-- "",,, ~~ ".', , , , .,,.. d ", .... .. .... "':f. '" :f. :Ii'" .. .. .. .. .. .. "'''' ;t;<f. "':Ii '" "'''';Ii .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY .. PENNA. .. .. STATE OF .. .. JOY EXLER .. .. .. .. 4 HOLLY COURT SHIPPENSBURG PA 17257 NO. 00-5230 CIVIL .. .. .. VERSUS MORRIS EXLER JR. .. 4 HOLLY COURT ; SRIPPENSBURG FA 17257 .. .. .. .. DECREE IN DIVORCE .. AND NOW, ).)4 ,..c,.,. w e-J , Z#OO , IT IS ORDERED AND .. .. .. DECREED THAT JOY EXLER , PLAINTIFF, MORRIS EXLER JR. .. AND , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE .. BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT Y!i:T BEEN ENTERED; .. DIVORCE AGREEMENT DATED JULY 20, 2000 AND THE AMENDMENT TO THE AGREEMENT DATED OCTOBER 30, 2000 WHICH HAVE BEEN FILED WITH THE COURT .. .. .. ---?'" By THE CURT: ATTE .. .. OTHONOTARY .. .. '" '" "''''''' "'''''''''' '" '" '" '" J. ~.. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .. .... ~.:........., l'"i;~''' '.'- .-,~Iolll -- ~~'--~~liI'.Iillii'~lllfir'" . "111 ,_."~".a.,. - ......, ",. ." ~.. " ~ , I Ii II Ii iI , Ii !~ Il ~1 '. I ~ ~ .~ 5/$- ~11/ ~u. (Zl/? CJ( ~:2' ~14( 4k.?:rv c70-J'c;f . "" ~ " . ~ fJil!Iim'lli[' PRAECIPE TO TRANSMIT RECORD Joy Exler 4 Holly Court Shippensburg, PA 17257 (717)532-7495 IN THE COURT OF COMMON PLEAS OF CUMBERLAND, COUNTY, PENNSYLVANIA TERM v. Morris Exler Jr. 4 Holly Court Shippensburg, PA 17257 (717) 532-7495 NO. 00-5230 Civil PRAECIPE 1'0 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 Complaint: August 1, 2000, by acceptance of service. 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 Plaintiff: October 30, 2000 By Defendant: October30, 2000 (b)(l) Date of execution of the Plaintiff's affidavit required by Section 201(d) of the Divorce Code: 4. Related claims pending: Divorce Agreement between the parties dated July 20, 2000 and the Amendment to the agreement dated October 30, 2000 which have been filed with the court. [ 1,11 ' f? Plaintiff d '.1 :llik~*~~~~"'it,'\");J'lli"~"':~<i~I-0,+"1,,","*,lt~ '. II ......j~-~ ~~ -:..il~ , ~'.". ~ 'I (") C::J Q C 0 -:;;.-'" -. z -oCh ~~ S2g.j =:J ,. z C J""';- rTl ~~t ~-..i c.:=: c: C ~~) 3> J::ID= " C' :J;: .-_-:.---: -r; Z C) s;: 0 .,,-- "l c:: C~ Z ':.J'l s:; =l -n -< ():) :< r =. 1liIi...ll.." . . AGREEMENT BETWEEN JOY EXLER and MORRIS EXLER JR. JOY EXLER Pro Se MORRIS EXLER JR. Pro Se Agreement made thisd.-O day of July, 2000, by and between JOY EXLER (hereinafter known as "Wife"), currently residing at 4 Holly Court, Shippensburg, Cumberland County, Pennsylvania, and MORRIS EXLER JR. (hereinafter know as "Husband"), currently residing at 4 Holly Court, Shippensburg, Cumberland County, Pennsylvania. WITNESSETH: WHEREAS, the parties hereto are Husband and Wife having been married on August 16, 1986, in Chambersburg, Franklin County, Pennsylvania. There was one child born ofthis marriage, said child being David, a boy born October 9, 1986. WHERAS, the marriage has been irretrievably broken and it is the intention of Wife and Husband to live separate and apart, and the parties desire to settle their respective financial and property rights and obligations, including the equitable distribution of marital property, spousal support and alimony, child support, child custody and child visitation and all other claims that one party might bring against the other or the other's estate, now or in the future. 1 of 10 '16""-f*" NOW, THEREFORE, the parties agree to be legally bound as follows: I. AGREEMENT WILL NOT PREVENT DIVORCE PROCEEDINGS This agreement shall not affect the right of the Wife or the Husband to a divorce on lawful grounds. The parties intend to secure a mutual consent no-fault divorce pursuant to the provisions of Section 3301(c) of the Divorce Code of 1980, as amended. II. EFFECT OF DIVORCE DECREE The parties agree that the provisions of this agreement, unless otherwise stated, will continue after a Decree of Divorce is entered. III. AGREEMENT SHALL BE INCORPORATED IN DIVORCE DECREE The parties agree that the terms of the agreement shall be incorporated into any divorce decree that may be entered with respect to them, and this Agreement will be independent of any Decree in Divorce. The parties agree that all the provisions of this Agreement constitute a binding contract for the purposes of any enforcement action or proceedings. IV. DATEOFEXECUTION The date of execution of the Agreement is the day on which the Agreement is signed by both parties. V. DATE OF DISTRffiUTION Any transfer of property, funds and/or documents pursuant to the Agreement shall be made on the date of execution of this agreement, unless otherwise specified in this Agreement. 2 of 10 ~~m~:k1R'illml1i;~,*;m~,~a.,..' ',," "" ~ ~""~ .ill!!\laimJ~_' ~_ j "=>~ "U i: I ! ""r" VI. TERMINATION OF AGREEMENT If a final Decree of Di vorce is not entered within two years of the date of execution of this Agreement, the Agreement shall automatically become null and void and the Agreement shall not be binding on the parties. Any property or funds distributed pursuant to the Agreement shall be returned to the party holding the property or funds before the date of execution. VII. PRO SE REPRESENTATION Both parties are aware of their respective rights to seek advice of counsel, and the parties have chosen to reach this Agreement by themselves. The parties each acknowledge that they have made full and complete disclosures of all information relevant to a distribution of their property and to a determination of their respective marital rights and responsibilities. Each party understands the terms, conditions and provisions of this Agreement and believes them to be fair and reasonable. Each party is entering into the Agreement freely and voluntarily and the execution of this Agreement is not the result of any duress, undue influence, collusion or improper or illegal agreement or agreements. VIII. CHILD SUPPORT Husband agrees to pay to Wife $125 per week for the emancipated child for support. These payments will begin within seven days of Husband and Wife separating into separate dwellings. These payments will continue for the child until the child is emancipated. The child will be emancipated on (I) reaching age eighteen or (2) graduation from high school, whichever is later, or (3) entry into the armed services, or (4) marriage, or (5) on becoming self-supporting. 3 of 10 it.l~ii-:ID,j~~~_i"'ltM,~~:lfilIL:ih ,"""., _~T'lIll-' "~ ,<~ - '~, Ir~"'u,~'~' "'" ""-..;;,i I j'l , H i I ri !i il I i i i Ii I " .".~ i '~ . , ~~ ii.\<ii ! IX. ClllLD'S HEALTH INSURANCE Husband agrees to provide health-care insurance for the child. Husband will also be responsible for any reasonable medical expense not covered by such insurance, and will pay whatever deductibles are required by the health-insurance policy. Husband will continue to pay for reasonable medical expenses of the child until the child is emancipated, as described in Paragraph Vill. X. CUSTODY OF CHILD The parties agree that Wife shall have legal and physical custody of the child. Husband shall have the right to speak on the phone with the child during reasonable hours and for reasonable amounts of time. Husband shall have visitation rights whenever the child is not scheduled to be at an activity he is involved in or is expected to participate in some activity with the Wife. David will reside primarily with Wife and can spend occasional nights with Husband as David desires. David will spend Thanksgiving, Christmas, New Years, Easter and Spring Break with Wife. David will spend other holidays as he chooses or as the parties agree. XI. SUPPORT Wife waives all claims to spousal support. XII. ALINlONY Wife waives all claims to alimony. 40fl0 ., - WMW" . XllI. HEALTH AND MEDICAL INSURACE Husband agrees to provide Wife health and medical insurance during the period beginning with the date of execution of this Agreement until the final decree in divorce between the parties is entered. XIV. PERSONAL PROPERTY The parties will divide their personal property upon the Husband moving into a separate dwelling. Husband will take with him the maroon colored loveseat, tweed chair that has padded arm rests, full size bed with headboard, tall book case, student desk, small dark wooden book case, and other small household items as agreed upon with Wife. XV. MOTOR VEIllCLES A. The 1994 Plymouth Voyager, VIN 2P4GH2531RR534578, will remain titled in the Wife's name alone until the lien that is held by Patriot Federal Credit Union is paid in full; at which time Wife will sign the title over to Husband. Husband is responsible for all maintenance from the date of this Agreement. B. The 2000 Saturn SL2, VIN IG8ZK5279YZ138629, shall remain the sole property of Wife. Wife is responsible for all maintenance from the date of this Agreement. XVI. BANK ACCOUNTS The parties agree that all funds in the bank account numbered 3615760 at the Patriot Federal Credit Union will be sole property of Wife upon Husband moving out of the home; and Husband waives any and all future claims to those funds. These funds will be used to pay for jointly acquired debts. 50fl0 ~~~~-4i'iI?i'llW.iUJJll~Ii.~!iHjj ;.;.~. K<_ iIliNil~- -'" -~.._~" CI8.&',,' ~! 'I .;- ..........". . The Wife was removed as joint member on the bank account numbered 3934390 at the Patriot Federal Credit Union on June 28, 2000. XVll. REAL ESTATE TRANSFER Husband has signed and delivered to Wife all documents necessary to transfer title to Wife in the real estate known as 4 Holly Court and situated at 4 Holly Court, Shippensburg Pennsylvania. The Wife assumes the existing mortgage. Wife agrees to indemnify and hold harmless Husband for any mortgage payments, taxes, liability and expense incurred in connection with this property. Husband waives any and all rights or claims he may have to any insurance policies held in connection with said real estate, or the proceeds from any such insurance policies. The documents necessary to carry out the provisions in this paragraph were delivered to the Wife at 4 Holly Court on June 23, 2000. XVIII. RETIREMENT BENEFITS Wife waives all future claims and rights to Husband's retirement assets that accrued during the marriage. Husband waives all future claims and rights to Wife's retirement assets that accrued during the marriage 6 of 10 111II ~~,~,l.:.':"'~ Jt~~''''*~~lIfj-it!~~i!'.~'"~~~R...m.l'' 0' '. ~. ="~""","",~ ~~J '~~ '~~,j !I 'I !, ! II '.I . . ~'"" '~ , .~ 1'{ili:~L . XIX. DEBTS, LIABILITIES AND OTHER OBLIGATIONS The parties agree to divide the responsibilities for paying their debts according to the list below. Each party further agrees to pay these debts in full and on time. Each party releases the other party from those debts not assigned to that party and releases that party from any penalties resulting in connection with these debts and liabilities. Both parties agree that all joint credit accounts will be terminated immediately and no charges shall be made on any jointly held credit account. Further, each party agrees that no debts shall be incurred for which the other may be liable except as stated in this Agreement. Debt Mortgage on 4 Holly Court, Shippensburg, PA Fleet Mortgage Group Loan #0058400391 AT&T Universal MasterCard account # 5491130386610505 VISA account # 3934390-30 Automobile Loan # 3615760 ill 83 2000 Saturn Patriot Federal Credit Union Pavor Wife Husband Husband Wife Loan # 3615760 ill 84 1994 Plymouth Voyager Patriot Federal Credit Union Thrift Savings Plan Loan # 0034970-F Thrift Savings Plan Loan # 9845335-M Husband for $310 per month Wife for $201.92 per month Wife Wife Wife will pay $1,939.68 directly to AT&T Universal MasterCard account # 5491 1303 8661 0505 for charges she incurred; this amount includes interest at 12.9% over a twenty-four month period. The cancelled checks will be proof of payment if Husband wants copies of these he will pay whatever charges the Patriot Federal Credit Union charges to make these copies since checks are not returned to members of the Credit Union. Also as proof of payment the Husband will see payments on his statements from the creditor. 7 of 10 __.l -" ~ 'llii~~_ifl~MUilw._m;I&!tJW\:',~b;~fj;,lli,,,m;~~;;,!,. ., .'""~,. >'~~. .'~. .I-~ ~"'''''''--''~' ~,~ . -I .:1 II !I II I I I' -.. ~~ ~ ~ ^~ o <~,~' XX. PROPERTY ACQUIRED AFfER SIGNING AGREEMENT Any property acquired by either party after this Agreement is executed is owned by the acquiring party, and any and all claims by the other party to that property are waived. XXI. TAXES The parties agree that they will file joint Federal Income Tax and State Income Tax returns for the current tax year. Any refunds will be the property of the Wife. XXII. METHOD OF PAYMENT All payments to Wife, unless specified otherwise, shall be made by transfer from Husband's account number 3934390 to Wife's account number 3615760 at Patriot Federal Credit Union, Chambersburg, Pennsylvania; to begin within seven days of Husband and Wife separating into separate dwellings. These paymen~s will ,occur weekly. Payment amount will be $202.50 ($125 child support; $77.50 for loan # 3615760 ID 84 as mentioned in paragraph XIX). XXIII. PENDING LITIGATION Wife's interests will be kept separate from Husband's interests in any litigation that occurs in relation to the automobile accident Wife and child were in on August 25,1999. Parties agree that marriage was not dissolved because of accident' and that marriage counseling has been utilized for the past nine years. XXIV. CONSOLIDATION This agreement constitutes the entire and full agreement between the parties. No other settlement agreements have been made between the parties. 8 of 10 ::;~.~.t ~"'L1 ! r" ."'~ _h~~lMJiN,j~rj,:.~~"~\fr,~""~~,,,~j]J -'1M '.IiIiit~ ilIllll. 'JoIOjj,,~~' '-.', , " " I I' " I! \; II '. ii I' I' ] ',I , il I ii -- ~ - L ~ "J"'L-...'< ( .. XXV. SEVERABILITY If any clause is held unenforceable or found to be in any way unexecutable, or if a court alters or holds unenforceable any clause in this contract, this shall in no way affect or alter the other clauses in the agreement, which shall remain in full force. Each party has carefully read and fully understands all clauses, statements, provisions and conditions ip this Agreement. 9 of 10 . ~llJ.:'i lr~ r~~~:~.iini'fiMi,'j~,!Wi~~'fij)f""';'--",",,(' LM;.." ~J ."- .._~ Coo ,~""" -'""~'4IJf"''"'" . il<h: \c ,I II II :1 ~ H i . I l' . " ..~ ~~. .~r. ._ I if ,. . , " IN WITNESS THEREOF, intending to be legally bound hereby, the parties have set their hand WITNESS -dtJ JL; (SEAL) .~/7;;' & (SEAL) HUSB COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND On this, the .{J() day of July 2000, before me, a Notary Public of the Commonwealth of Pennsylvania, residing in the town of Shippensburg, Cumberland County, personally appeared Joy Exler, known to me to be the person whose name is subscribed to the within Agreement and acknowledgedthat she executed the same for the purposes therein contained. seal / // COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND On this, the 30 - PEGGY J. BOWMAN, NOTARY pl:lBtfp SH1PPEN$BURG, FRANKliN COUNTY, PA MY COMMISSION EXPIRES OCT. 1,2001 day of July 2000, before me, a Notary Public of the Commonwealth of Pennsylvania, residing in the town of Shippensburg, Cumberland County, personally appeared Morris Exler Jr., known to me to be the person whose name is subscribed to the within Agreement and acknowledged that he executed the same for the purposes therein contained. IN WITNESS THEREOF, I have hereunto set NOT .l:JB I OTAl'lIAl. sEAl. PEGG J. BOWMAN. NOTARY PUBlIC SHIPPENSBURG.FRANKlIN COUN'TY. PA MY COMMISSION EXPIRES-ocT. 1,2001 100flO " 'I('~"i '';'Jl!:!j:l!:i:ii!M"~~ .~o~"'-" ~~~ , ,",,",,-,~,,.,,,""'!, "',, "HI" ~~ ~ , W 'V ~ ~ ~ ~ ~ ~ ~ ....'llti!i9'h ,,~ ~~ G"\ \1 ), ~' "~ , ,~ ~~ Cr-. "- ,1 ~ ~~ \ 'c~ , ~ 'o~ 'Ii"'-~~ '~ o ~;; --," ,;;,'; , Z-- ~~- i 7/'\ ' ~r;~ ~:'\_,.I ]";",:-,- ~3:' ~;; 2 . c~: """':-'\ ': . I I , r C,.,\ .~ , 1'::--: '-',\ ~) C"" '1\(,? .n r<~ . ;'. '~~~ 1.._) ::' ..... .....: "'" . ,,,,;;;-,', """~ ~ ltl.:. "YLu (I'D - 930 C;,.;:J J"~ AMENDMENT TO THE AGREEMENT BETWEEN JOY EXLER and MORRIS EXLER JR. JOY EXLER Pro Se MORRIS EXLER JR. Pro Se Paragraph XIX of the agreement made the 20th day of July, 2000, by and between JOY EXLER (hereinafter known as "Wife"), currently residing at 4 Holly Court, Shippensburg, Cumberland County, Pennsylvania, and MORRIS EXLER JR. (hereinafter know as "Husband"), currently residing at 4 Holly Court, Shippensburg, Cumberland County, Pennsylvania, is hereby amended to read as follows: XIX. DEBTS, LIABILITIES AND OTHER OBLIGATIONS The parties agree to divide the responsibilities for paying their debts according to the list below. Each party further agrees to pay these debts in full and on time. Each party releases the other party from those debts not assigned to that party and releases that party from any penalties resulting in connection with these debts and liabilities. Both parties agree that alljoint credit accounts will be terminated immediately and no charges shall be made on any jointly held credit account. Further, each party agrees that no debts shall be incurred for which the other may be liable except as stated in this Agreement. Debt Mortgage on 4 Holly Court, Shippensburg, PA Fleet Mortgage Group Loan #0058400391 AT&T Universal MasterCard account # 5491130386610505 VISA account # 3934390-30 Patriot Federal Credit Union Capital One Bank card account #5291071748340815 Pavor Wife Husband Husband Husband lof3 ..lll~ "'~^!~~~rii;i']j~IIDu.~,ti~,-'1'l;lIi"","d;i-rH";;,,,,,,"'.-J;'>:'1-<;'~,I",,~~[Ji - ~" ,do' ~, ,~ ~" " ~ "'", -'_I ~~ ,,', .~'- ~~~ - --~~ ~,"" ~ ,~ , '~i~'="'~"'l:Q:<.ll ." lliiUij I ~ II " r: If, '- L...: ~-- ~\ Debt Automobile Loan # 3615760 ill 83 2000 Saturn Patriot Federal Credit Union Pavor Wife Loan # 3615760 ill 84 1994 Plymouth Voyager Patriot Federal Credit Union Thrift Savings Plan Loan # 0034970-F Thrift Savings Plan Loan # 9845335-M Husband Wife Wife All other paragraphs in the agreement made the 20th day of July, 2000, by and between JOY EXLER and MORRI S EXLER JR. remain the same. 2of3 1PJ~';"'-- .......~""'" - '.--'.o_'jJE.l:~~~iM~~:&~!li&t~~~~~M-,~1li\~~- ',-"'IJfu,:0;i&iq,~WiI.'';'''':'" ^ jUJ;jJJ -="""",,,,",' 1iiIIillii~" ~i1 ~. ~ ~- ,~ , ';;oi!filiiM\<tiIW;'~'..1Ii ~ ,- ~ ~'~IiIIii~~, , ,.~ l' "~7)'\ . "" I ~, ~~.^. IN WITNESS THEREOF, intending to be legally bound hereby, the parties have set their hands and seals the 30 day of October 2000. ~iAL Q1 CU-I.~2a /bY\ofl)haiei' _ _~ (SEAL) WITNESS ('JQ.u~o-'- VbIW.J.o~ -;;?7;Jtn/Z/';.; ~(SEAL) WITNESS HUSBA COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND On this, the "3o~ day of October 2000, before me, a Notary Public of the Commonwealth of Pennsylvania, residing in the town of Shippensburg, Cumberland County, personally appeared Joy Exler, known to me to be the person whose name is subscribed to the within Agreement and acknowledged that she executed the same for the purposes therein contained. IN WITNESS THEREOF, I have hereunto set my hand and official seal -A RY PUBLIlITTARIAL SEAL . PATRICIA A. SHATTO. Notary Public Carlisle Bora. Cumberland COWY 2001 My Commission Expires December . 1 I COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND On this, the :!So -zL day of October 2000, before me, a Notary Public of the Commonwealth of Pennsylvania, residing in the town of Shippensburg, Cumberland County, personally appeared Morris Exler Jr., known to me to be the person whose name is subscribed to the within Agreement and acknowledged that he executed the same for the . purposes therein contained. IN WITNESS THEREOF, I have hereunto set my hand and official seal ~j': tI~-'!,7f NOTARY PUBLIC NOTARIAL SEAL PATRICIA A, SHATTO. Notary POblic . . t'llfllll@9olll, CumbtffandCouhty. I ". My CommiSSion ~xPfles Oetomb~r 17.2001 30f3 IlII - .i!!lMJ~~-<f~'_,"-'ID\!)!j&\[f,'!S!;:~,!ii!;~,"'~~t!&i~if'!:\4Mi'-"'i'<illi~:l:!iilll!J;\ill:."",," , ".~"" " ..~. ",.. ,N il!iiiillriI& ..... , -~ ~ -- '-lIlIl~"'!- c~_ ~-r~ 0 0 0 c:: Cl -n s: 0 .,-! -UCC! n . :-"fi 1~'; nlFl -~ Z::l:l w .~;;,7. zc- 0 ~:o (j) "': () 2/ :.~,J ,<:0 -0 '::C-H ~o :x Q(~ t:'? 2m :5>2 S ~ (.:> ~ '"" .., . " ,~"'.;~ " . Joy Exler 4 Holly Court Shippensburg, PA 17257 IN THE COURT OF COMMON PLEAS OF CUMBERLAND, COUNTY, PENNSYLVANIA v. TERM Morris Exler Jr. 4 Holly Court Shippensburg, PA 17257 NO. 00-5230 CIVIL NOTICE OF INTENTION TO RETAKE PRIOR NAME Notice is hereby given that the Plaintiff in the above matter, having been granted a Final Decree in Divorce on the 28th day of November, 2000, hereby elects to retake and hereafter use her previous name of JOY ELLEN STEADMAN, and gives this written notice avowing her intention in accordance with the provisions of the Act of December 16, 1982, P.L. 1309,54 Pa. C.S.A. Sec 704. ~C2L (j TO BE KNO AS: ~;j!' h cia . 5< -ff:::"~ ~r On the :23 {I./.) day of July, 2001, before me a Notary Public, personally appeared JOY ELLEN STEADMAN, known to me to be the person whose name is subscribed to the within document and acknowledged that she executed the foregoing for the purpose therein contained. IN WITNESS THEREOF, I have hereunto set my hand and seal. NOTARIAL SEAL JODY S. SMITH, NOTARY PUBLIC Carlisle B9ro,Cumberland County I My Commission Expires April 4, 2005 f5lj q bfiyj S S w.--IJ. (jVO fl.JJ\J1 ~irlli\a~,t\!;_ti~IH;i~iliiliiY4f:J!~' '.>"'"""""'-'"Uil;!lr'>':':';;'-[i~''''''''''' . 'r. ,-~;, "",," '^ -~; ~ijlllllilti~-"~""" .,. . ,"'-, ..~, "'~ji*OOillK ",J" ;;2 c::> :0 ?:- ~~ ~~t ~ ~-" i~.,~; ,',', v. c., ~ \ r-: --':.:; ~, E':":" ~_,' $;~ r::S , :::t::~ ~ .'- ..-.! ~' -,~ co , ~! ~ " .""', "~' " - ~- " 1Jc.___ Joy Exler 4 Holly Court Shippensburg, PA 17257 (717)532-7495 IN THE COURT OF COMMON PLEAS OF CUMBERLAND, COUNTY, PENNSYLVANIA v. TERM Morris Exler Jr. 4 Holly Court Shippensburg, PA 17257 (717) 532-7495 NO. 00-5230 Civil WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER SECTION 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 the decree will be sent to me immediately after it is filed with the prothonotary. I verify that the statements made in this Waiver 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 (>J I Lf .. ~(}OO #1 Plamtiff '.~. "t ilWf - OOliMil&iU~IT~~..-'itl/ji1flr .' :1llfl.'>~~illll,~"-'*"~tt_~,..,.O!~;>~l " -~~ "~ ~- .~-,~ .". ~"i . MtllilltimlMiii!ilHliliil. t"- C' "llllilW "Ill<li.<i.llil o ~ -rJ e;=~- i~! ~~ -' -< ""~ '~'- "a .~, C) c 2; o:;i_ o -n ['.:J , -,'I ~~~;: , ~ :~?J -.': C') ~;]rrl :::t'J --< ~.....,J ;:c:. :.n G) t ~ w-~"""'''',_J Joy Exler 4 Holly Court Shippensburg, PA 17257 (717)532-7495 IN THE COURT OF COMMON PLEAS OF CUMBERLAND, COUNTY, PENNSYLVANIA TERM v. Morris Exler Jr. 4 Holly Court Shippensburg, PA 17257 (717) 532-7495 NO. 00-5230 Civil WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER SECTION 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 the decree will be sent to me immediately after his filed with the prothonotary. I verify that the statements made in this Waiver 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: 1'1 Mev 00 ~~Ilt v Defendant hiJ'-to. 1] i ~.lMtIIIWijl,**%ifJ>:,*",I~.~~~:'I.d~i!~~iHli&M)~'fu!,*,,~iWf ,",.", . ~" .~,- '--~ "~ '"~ -'~""Iillli'il!!'''''~~ -,. , .~- m II'I''-ltblil~ 0 C ("J c.: a ....n ~t:. i.JC Q Qlrr; "'-- .. L::~j .- ~~" f"..,) , ,":"i ~;:.;'- ..,J -' "r ~C~ -) c:.> :i>c. "'" "I', ~~~-; ....,-, /~C...:; (") >.C ;:.:~ iTl 6 :.11 > -< co ~1J ~~ ~ ACCEPTANCE OF SERVICE Joy Exler 4 Holly Court Shippensburg, PA 17257 (717)532-7495 IN THE COURT OF COMMON PLEAS OF CUMBERLAND, COUNTY, PENNSYLVANIA v. TERM Morris Exler Jr. 4 Holly Court Shippensburg, PA l7257 (717) 532-7495 NO. 00 -Sd.-30 ACCEPTANCE OF SERVICE I hereby accept service of the Complaint in Divorce filed in the above-captioned matter. ..-< J :rIA ')1 ,2000 ndY1/f); /;;?gfl. Defendant Sworn to and subscribed before me r-"---'-'- .. , NOTAR!AL SEAL I PEGGY J. BOWMAN, NOTARY PUBLIC ! SHiPPENSBURG, FRANKLIN COUNT{, PA ~~M!SSl?N EXPIRE~~, 2001 - .....''''''''''-''...''!!1I~~..4.1<~,'ililf~~7~i~;:,~~!''''""fulli*~''''Qci:.-':ti!fu;:ili'~jjl''''' ,~. >-, ~ ~~~~ 0.-- ~~ ,. o';:".....,;.,_~~ 1IIiiiIli.~~. ~i&dllll.n ~ ~-.-=.... ",,- ~) f:,i7,f': "-~ ;?: ::;. ) 6i(: --c:~ r" ~;; 7~-'-:: S;:~~~ ~ ~( r:.) (~ ::,,--::;' ~,~-' S~ -< " ~~ ~,-.. --, ~Z~ AFFIDAVIT OF CONSENT Joy Exler 4 Holly Court Shippensburg, PA l7257 (717)532-7495 IN THE COURT OF COMMON PLEAS OF CUMBERLAND, COUNTY, PENNSYLVANIA TERM v. Morris Exler Jr. 4 Holly Court Shippensburg, PA 17257 (717) 532-7495 NO. 00-5230 Civil AFFIDAVIT OF CONSENT 1. AComplaint in Divorce under Section 3301(c) of the Divorce Code was filed on Julv 26. 2000. 2. The marriage of the Plaintiff and the Defendant is irretrievably broken. Ninety days have elapsed since the filing of the Complaint. 3. Iconsent to the entry of a final decree of divorce. 4. 1 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. 5. 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. Section 4904 relating to unsworn falsification to authorities..". ~ ?7k~ ~gr r (Defendant) Sworn to and. subscribed before me ;;r",yor-;3'J:;, - " . 4...~.a..- g Notary Public NOTARIAL SEAL PATRICIA A. SHATTO, Notary Public Carlisle Boro, Cumberland County My Commission ~xpires December 17, 2001 ~?~~!iIi.~'!,fj~~1'!J_"i~'.-\:Je,'!::"'1dIN'~M.i;~~H::;!'.~~"'0' ,J.-i~BiJR~JlillA ---'.,-",-~,;-- ~--~,,~~"'.""- '^.-.'" "'" "".,--,< .,~,^ "~~_,~~ __ h __,.. r . ,.,.Jo.,",',,,' """". < ","' A'i!i~!!&M"""'""'-"'" _ _~ ..C", '1IiIIIi--- I.liiil -., 0 0 0 c:: 0 .", ;;: 0 ..., ~CJJ C"? 'j~:U -'iTl --l :",-- Z:D (.> .nm ~~ :09 0 Cl ) cc,lc k"O -0 .- -ri ~J_"" ~o :x ~o t:'? -m )>0 9, c:: ~ ~ (.:> '-< ~ . ~ >" " > AFFIDAVIT OF CONSENT Joy Exler 4 Holly Court Shippensburg, PA 17257 (717)532-7495 IN THE COURT OF COMMON PLEAS OF CUMBERLAND, COUNTY, PENNSYLVANIA TERM v. Morris Exler Jr. 4 Holly Court Shippensburg, PA 17257 (717) 532-7495 NO. 00-5230 Civil AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on Julv 26, 2000., 2. The marriage of the Plaintiff and the Defendant is irretrievably broken. Ninety days have elapsed since the filing of the Complaint. 3. I consent to the entry of a final decree of divorce. 4. 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. 5. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are mllde subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ~..~ V (Plaintiff) Sworn to and subscribed before me "'thi~~a.YOfq:O/~ 2000 ~.-A .,... -' -;r Notary Public NdTARIAL SEAL PATRICIA A. SHATTO, Notary Public Carlisle Boro, Cumberland County My Commission Expires Deoember 17, 2001 *" '" ^'}lIfJif ~'~'"' ~~1Mif%!~i'o%1i1~~if",,_&%ii;'-~Jii.%,"_,~J'::''-;''1'''1jj;'''t.f.;''''''8hI'i'>''~~~[mj[ i' .-",'<'"" , "..' lmilil~l'liiMj,jj.iiIJ.ilJj J: ,-"-'- ___ - U~"" () C) 0 C 0 T) <"" <::) "'"Ocr' "-1 J11rn n ~X~ Ti Z::c, -t "1= z;;;; W ;3~ cn~ c:.> -<2 '-0 ~..,( ~ " :,-'Tt 28 ::J::: 0"'" ~ 25 >c din Z ~ :< w -< ~" ""'" "' - :V""~~ ~~ ~ ~'=-~. " . NOTICE TO DEFEND Joy Exler 4 Holly Court Shippensburg, PA 17257 (717)532-7495 IN THE COURT OF COMMON PLEAS OF CUMBERLAND, COUNTY, PENNSYLVANIA v. TERM Morris Exler Jr. 4 Holly Court Shippensburg, PA l7257 (717) 532-7495 NO. OJ -5';;30 &;J 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 my 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 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 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: Court Administrator, 4th Floor, Cumberland County Courthouse, Carlisle, PA 17013, (717) 240-6200. 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 TillS PAPER TO YOUR LAWYER AT ONCE. IFYOUDO 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. Lawyer Referral Service, 4th Floor, Cumberland County Courthouse Carlisle, P A 17013, (717) 240-6200. l--- ~...--..; . ~Ji-~~ti~~.ili.-U;:~*,,&;~~- c, ___'"_,..C"~",~ ~ .., '. ,,-~ ,~ -"- t=~ ,~~-~ >". ..... - ~ ~ " - - o~>-" ,,~ , --~""", -~, ". -., ~-,.",'- ,"^". ~~ ~- <, ,. ld ~. i:, c I I" Ii Ij I , ~ .,"" ,__,f ,,;. . ~ '. ,,'. "" " "--, Joy Exler 4 Holly Court Shippensburg, PA l7257 (717)532-7495 IN THE COURT OF COMMON PLEAS OF CUMBERLAND, COUNTY, PENNSYLVANIA TERM v. Morris Exler Jr. 4 Holly Court Shippensburg, PA 17257 (717) 532-7495 NO. tHJ- 5.23b ~ J:u."v COMPLAINT IN DIVORCE COUNTl REQUEST FOR DIVORCE UNDER SECTION 330l(c) OF THE DIVORCE CODE 1. The Plaintiff is JOY EXLER, who currently resides at 4 HOLLY COURT, SHIPPENSBURG, County of CUMBERLAND, Commonwealth of Pennsylvania. 2. Defendant is MORRIS EXLER JR., who currently resides at 4 HOLLY COURT, SHIPPENSBURG, County of CUMBERLAND, Commonwealth of Pennsylvania. 3. JOY EXLER has been a bona fide resident of the Commonwealth of Pennsylvania for a period of more than six (6) months immediately preceding the filing of this Complaint. 4. The parties were married on the SIXTEENTH day of AUGUST, 1986, at CJ{AMBERSBURG, Commonwealth of Pennsylvania. Attached hereto and marked Exhibit "A" is the certificate of marriage evidencing said marriage. ~~"i_~"""'-"="~~&wi!!!~~;I1'Hj~<i']~~~'&ll>'Siml~~lf_-".ktL: - ..^< '"' ',- ~~-"~ - ~ . ~ ~ " ~~ -.' - .~~"-, .,,- , ,c "'H .'~I I~I ~! ~! 1",1 I::! !f'i t.1 E! Ii ii fi Ii ;i Ii ~! " I' II ,I ii I, fi :! ii I' :, I' Ii I! II ,I I I ,'. . -~ -"..~ .~~ . .'\ ... . . ..i;.Jlw.' . . . 5. Neither plaintiff nor defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers' and Sailor's Civil Relief Act of the Congress of 1940 and its amendments. 6. There have been no prior actions for divorce or for annulment between the parties. 7. The defendant has been advised of the availability of counseling and the right to request that the Court require the parties to participate in Counseling. 8. The marriage of the parties is irretrievably broken. 9. After 90 days have elapsed from the date of the filing of this Complaint, Plaintiff intends to file an affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an affidavit. WHEREFORE, if both parties file affidavits consenting to a divorce after 90 days have elapsed from the date of filing of this Complaint, Plaintiff respectfully requests that a decree of divorce be entered pursuant to Section 3301(c) of the Divorce Code dissolving the marriage between Plaintiff and Defendant. aili.i ""'"'~~ I~Jijj;1itlIf1ii _~____...,.,,", ",w~~,,~,," -., .~ ~~ <,- ~~ h' l'IilSI8iliil!il''''- '",w . - ~ .~, - ";';';", . .J:1U < ~ --~ >. li!i , Ir 'J! ,.. j~" ",-... ,-~ ,~ .., . COUNT II REQUEST FOR INCORPORATION OF MARITAL SETTLEMENT AGREEMENT PURSUANT TO SECTIONS 3104(A)(1) AND (3) AND 3323(B) OF THE DIVORCE CODE 10. Paragraphs 1 through 9 are incorporated herein and made a part hereof by reference as though fully set forth. 11. Plaintiff and Defendant have reached an agreement on issues including alimony, property division, child support and child custody, ...... ~,_.~~"",,,.l."""''""'llli1jj ~'~!!lil~~~ill!il'l;'_W!~i'th!EA~"'\LO!~'''-"''''~~-- , ~" ,,~ -, ."..'.. " . -" ,,~ f'" I', .'. .~~;':"",1';~ l1l.::L~I ,^ ~. ~ ,--~-,,,.-- ,~,,~ UI ..1 Ii !~ ,.~ ' ~ ; , I I , . . d "' """"-~'"'.. ~. .. . WHEREFORE, Plaintiff respectfully requests that this Court approve and incorporate the agreement reached between Plaintiff and Defendant into the final divorce decree, pursuant to Sections 3104(a)(1) and (3) and 3323(b) of the Divorce Code. fv F~ Plaintiff I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Jcr f. 'f-t Plaintiff D'" J.fJ- d4 J tfOC Sworn to and subscribed before me this y P ,b#6-------,--..------- NOTAnV\L SEAL PEGGY J. BOWMAN, NOTARY PUBLlG SHIPPENSBURG, FRANKLIN COUN1Y, PA MY COMMISSION EXPIRES Oei. 1, 2001 -. ~,,'- '''~~~!!iI~~!!iijJ~.miiili,~ii~Mg~~:il~i1iil'''' ." "<, <> , -1Illi!.i!M!iil.il;/~~' o ("" 5: llrr If ,.".....-. r-ot' - ~"-- 5(; )-:2 ~ -M c':) CJ ~:::: ;:== , ;-:~d <:1 :~-l :-;C':".J i-, "-}~h: C5h~! iJ =< "C) 0') r~~_) ::::> '..J IIIUI' , ,I 'I I .1 I , l I I, . ~-," r, ';1-1 f1 ~_.,'--_'-'_'_'-_'C--' 'J::>'"'_ -",,',--' . '-,",',","ok,__"" - , '-'-'~l-- ".,-N-' ;---~ , - '~: ,~-,;;--" ~ ~ -,- -L. ~ --- _____ -- ,-,",':""""--"l_=,':;~-"J,_.r2,.-_,,,f':':;"_L, ",;"~,,,,,,_,-,,,,,,,,,,""'_ I "..., , ~ , r . mupliratr !larrtagr C!Irrttftratr Vol.......??,....,.. No. ....}~fi.... !, Arthur 'Brown one thousand nine hundred and 86 ........ hereby certify that on the ,~,6,t,~...,... day of ...,0,1l,\Lll.Ei~,....... ThB OpBn Door Church, ChambBrsburg, Pa. at n.n ....n..n.uh.n..n.h...nn.h...n......hn..hnn........n..hn."'.hnnu,_,'nu..._.. and ......"..,:),g,IJ..JJ..l".D.,J:;,t.~,<!,qmf\!:l...........,......................,...,.. .....}"P+:,+:.i,i;!...S,<HJJ...,~151!O,r, ..,:),r........,....... 'Were by me united in marriage in accordance 'W-'ith the license issued by Court of Commott ?lcas of Franklin COImty, Pennsyl'lIan-ia, License No. the Clerk of the Orphans' 346 C ol-trt division of the When returned,0yg,ll,s,~....~I:J,!.... ..................,.19 86 Is! Arthur Brown Minister of the Gospel,XiXIlIIltl<)(,J<~~!<~?f1~lI I hereby certify that the above is a true and correct copy of Duplicate Marriage Certificate on file -'in this Office. In witness whereof ha1/e hereunto set my hand and affixed the seal of the Common Pleas Court of Franklin County, Penn- sylvania, this .....;;',~,~,~........ day of .......A.,llgyf3.~..........,......, 19...~,~ ..,.........~1..'If.."..,",...... ..,...........".............,......n......... ~'..'..D'8~~.. Clerk rPhans' Court Division E'\l\...:\';\-A M'-"'.;.....,., ':'1","" " ,- "~,,_"1~,,~~,,, ' -~~',..Ili___~';.-' ,~ i''''',<;<>~. I ~. 'lltl;~ ';;'~~''':' ",_._',>Y, ..~~,'"", -,.~,,,.~, "~'" " :;'}"""';~\f+>~"""~'.'-"-""' ;;',,j'"" ._..._ .... l~ '<~- -~ - ,~~' -'....' "':' .';,-",'t"';'-. ~,~ -2L"LiJ'. ~.. Ct.; , " (i'J -< 1::--\':.1 ";M; _ ""7"_, .(-=c) ?r'- Z ~ C~) c:; r,) C', -'"-:'J ~_.". 1".) :;:) ...J ":0 =< ffi '~-._..,~"". COUNSELING NOTICE Joy Exler 4 Holly Court Shippensburg, PA l7257 (717)532-7495 IN THE COURT OF COMMON PLEAS OF CUMBERLAND, COUNTY, PENNSYLVANIA v. TERM Morris Exler Jr. 4 Holly Court Shippensburg, PA 17257 (717) 532-7495 NO. COUNSELING NOTICE The Divorce Code of Pennsylvania requires that you be notified of the availability of counseling where a divorce is sought under any of the following grounds: Section 3301(a)(6) - Indignities Section 3301(c) - Irretrievable breakdown- Mutual Consent Section 3301(d) - Irretrievable breakdown-Two/Three year separation A list of qualified professionals is available for inspection in Office of the Prothonotary at Court Administrator, 4th Floor, Cumberland County Courthouse, Carlisle, P A 17013; (717) 240-6200. ..'..-~ ";-'"'"-~~~~.:ri~l~~MHi'lll<i'-"':;',;;dl.ti:~""""" .-." , ~ " ~-- , ~ "-' '-...........~:M!_.lliillJli" .'''''''- " .~.. ~",., -- ". '. -Col_"'_' -UL~ ~~"ll!uk ~R" :7 f:. 0-,1" ~e:;: "" 1~8 ~ ?<e (-, C.:' c~'. .-- ,. ,,~ ,'"'.-, ~_."' , "0---)"'1 ;: ;~;~ 2 ~ii -< J.....:;. ~ -J - Alf_i:' '" ':1 " I; i.' I I' I:' ii' I ,~-" ,,1 ~~ ~~ " . AFFIDAVIT OF NON-MILITARY SERVICE Joy Exler 4 Holly Court Shippensburg, PA l7257 (717)532-7495 IN THE COURT OF COMMON PLEAS OF CUMBERL&~, COUNTY, PENNSYLVANIA v. TERM Morris Exler Jr. 4 Holly Court Shippensburg, PA 17257 (717) 532-7495 NO. t!1I,5:2.3o ~-&<h AFFIDAVIT OF NON-MILITARY SERVICE JOY EXLER, being duly sworn according to Law, deposes and says that she knows by her own personal knowledge and therefore avers that defendant, Morris Exler Jf., is 34 years of age; that he is employed by Martin's Famous Pastry Shoppe Inc, 1000 Potato Roll Lane, Chambersburg, P A 17201; and that he is not in the military service of the United States or its allies, or otherwise within the provision of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940 and its amendments. }or.~ - Sworn to and subscribed before me otary ublic " ' .,,' -J"" ---,~~~--- NOTARiAL SEAL PEGGY J.llOWMAN, NO, TAl'lY p. U,BUC SHIPPENSBURG,FRANKUN COUNT'!. pto, MY COMMISSION EXPIRES Q(,~ 1. 200~ "C ~ '- , al "-~-'~-. ~ ~'~fiil~i&.~tf~liWil~ ~~. . .','" c' c' ''','' , -,-" )~ rt':f 5;_' i~ en' -< r'" / ~C~, :;;~8 ""7 =< -< , ',,"-- ~ ,~- () ~:- . C:') 1_',1 :'..) C' :'0 .CJ ._-~~! (') 6 ill ..j 1; -< -::::-> ....J ,'..P