Loading...
HomeMy WebLinkAbout00-06255 S:~:'01't~?:TH'k;~'r,0lKif4:-1Xlfir1t~~71J~.0Si::F;);;:.rr~"iS'~,~'l,~Tii'1!fI , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , . . . .. :Ii:li:+: :Ii:+::Ii:li:li .. . . .. . IN THE COURT OF COMMON PLEAS STATE OF Plaintiff JOHN H. SHAFFER, VERSUS DEBRA L. SHAFFER , OF CUMBERLAND COUNTY PENNA. No. 00 - 6255 nllOo~llOonrl;:ant- . . . . . . . . . . . AND DECREE IN DIVORCE , _w.uwc-, . . . . . . . . . . . . . . . . . . . . . . . . . . . &t 3t3t(P;t{L 2001, IT IS ORDERED AND , PLAINTIFF, DEBRA L. SHAFFER , DEFENDANT, AND NOW, ~ J-1 DECREED THAT ~AFFER 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 YET BEEN ENTERED; . . . . . The attached Divorce Settlement Agreement dated July 7, 2000 and Addendum dated September 7, 2000 are hereby incorporated into this Decree in Divorce. . . . . . . . . . . . . . ,t . J. HONOTARY . :Ii:+::+: :Ii :Ii ... :Ii:li:li :Ii . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . li<.-~;~f:!T:':;\5gf(~7Y:!'l.Kt;l?,'lP1t~;f,~?jtl~r~ft~};{i~ii&'2~-; ($1h~.lij~i'i:'!i?~t'l}~4i9'J;:{,-V,:;~~'i~;E~;;,tt;~;~tiD~~~M~~ "n ,---~ - -<" /,;6' elf / 'J.S {'/ , ," ~ " . " ~ \ ", ~~ ._-~;;It 'H~ {~ d?f /il~j!/ ~ 4 Vt7fft 711ik,: /1J.l~ z tt(l ?0 T1i.l11f __~"'.,.,."_? ~~""'~ """'. __,~. d, ,. .~,_"~" """"~O?", \C>:8XTI~~~~~q'n-~il!~ij:gf;M&;.,,~_!;g1i,*~h~~~ _..".".,....,.,,,.il ~0'j*-21('W.:>!.#@i1"'t4:j$:r-tf~t0;~11)i(~:;1ffl~iJ;);l)~ . -~-,~ !;,_=u.,-,,,,,",:~_~, , " DIVORCE SETTLEMENT AGREEMENT THIS SEPARA TION AGREEMENT, made this ~ day ot:l\ ~ ,2000, by and between JOHN H. SHAFFER, residing at 1530 Tussey Court, Mechanicsburg, gerland County, Pennsylvania, hereinafter referred to as "Husband", and DEBRA L. SHAFFER, residing at 1530 Tussey Court, Mechanicsburg, Cumberland County, Pennsylvania, hereinafter referred to as "Wife". WITNESS ETH: WHEREAS, Husband and Wife were lawfully married on October 2,1999; and WHEREAS, there were no children born of this marriage; and WHEREAS, differences have arisen between Husband and Wife, the consequence of which, they intend to live separate and apart from each other and commence divorce proceedings; and WHEREAS, Husband and Wife desire to settle and determine certain property rights and obligations growing out of their marital relationship; and WHEREAS, Husband and Wife desire to settle these property rights and obligations fully and fairly and intend that the terms contained herein constitute a separation and final property settlement agreement following the filing and service of a divorce complaint; and WHEREAS, the parties hereto desire to confirm their understanding in writing. NOW THEREFORE, the parties hereto, intending to be legally bound hereby, agree as follows: 1. Separation. The parties hereto shortly after the signing of this Agreement shall live separate and apart and will not cohabitate with each other. Husband presently owns a town home located at 1530 Tussey Court, Mechanicsburg, Cumberland County, Pennsylvania. Wife agrees that she shall vacate the town home located at 1530 Tussey Court, which the parties currently share, no later than July 15, 2000. ""''1{{'}~';;%J:s~~~;~~t;?Ji%&'i{git'\f'7!;}k~;3~f,;W~'iZ#J@I ,~~ ~ MlI<,""",,e%,"-~." 2. Interference. From the date of signing this Agreement, each party shall be free from interference, authority and control of the other, as fully as if he or she were single or unmarried, except as may be necessary to carry out the provisions of this Agreement. Neither party shall molest or attempt to endeavor to molest the other, or compel the other to cohabitate with the other or in any way harass or malign the other, or in any other way interfere with their peaceful existence, separate and apart from the other. 3. Division of Personal Properly. By July 15, 2000, except as set forth herein, each of the parties hereto has divided between themselves, to their mutual satisfaction, all items of tangible and intangible marital personal property, including household furnishing and other similar property. Neither party shall make any claim to any such items of marital property, or of the separate personal property of either party, which are now in the possession and/or under the control of the other. Should it become necessary, the parties each agree to sign, upon request, any title or documents to give effect to this paragraph. The property shall be deemed to be in the possession or under the control of either party if, in the case of tangible personal property, the item is physically in the possession or control of the party at the time of the signing of this Agreement, and in the case of intangible personal property, if any physical or written evidence of ownership, such as a passbook, checkbook, policy or other certificate of insurance or other similar writing is the possession of or control of the party. The basement refrigerator will be the sole and separate property of Wife. The refrigerator will remain in the 1530 Tussey Court residence after July 15, 2000. Wife shall notify Husband of the date in which she intends to pick-up the refrigerator. If Husband signs an Agreement of Sale to sell the 1530 Tussey Court residence, Husband will notify Wife and provide therein fifteen (15) days notice to Wife to retrieve the refrigerator. With respect to the motor vehicles owned by one of both of the parties, they agree as follows: A. The 1988 Chevrolet S-10 pick-up in Husband's name shall become the sole and separate property of Husband. Said automobile is free of any liens and encumbrances, Husband agrees to indemnify and save harmless Wife on account of any incidental or future obligations related to ownership of the 1988 Chevrolet S-10 pick-up. B. The 1999 Mercury Mountaineer in Husband and Wife's name shall be traded in to reputable dealership no later than July 10, 2000. The 1999 Mercury Mountaineer has negative equity. Husband 2 ~}j1-:;;.o;'Ji1t~"i'J;Jfz;.,~:\.~;:7(,j'-;~fi'iii:'~ii1f':1l2,':~;o;iJ;i(:ji;i'-,~/~ ;;:t1i%!;:;:,~;YiY:\:&'1f~y~,:;St't1$Slt~i.('li;t,~,~;l!'(;,:;j~~;i~~1':~ l""~"---"",,,"1<- agrees to pay all monies necessary to trade the 1999 Mercury Mountaineer and thereby allowing Wife to purchase a 2000 Chevrolet Tracker or something similar without suffering any effects of the negative equity from the 1999 Mercury Mountaineer. The 2000 Chevrolet Tracker shall be in Wife's name and Wife agrees to indemnify and save harmless Husband on account of any said obligation relating to the ownership of the 2000 Chevrolet Tracker. The titles to said motor vehicles shall be executed by the parties, if appropriate, for effecting the transfer as herein provided on the date of execution of this Agreement if the title is in the possession of one or the other party. In consideration for Husband's payments representing the negative equity in the 1999 Mercury Mountaineer, Wife agrees to pay Husband One Thousand Five Hundred ($1,500.00) Dollars over a period of one (1) year. There shall be no schedule for these payments and Wife, at her discretion, may make periodic payments or one lump sum at anytime during that one (1) year period. 4. Certificate of Deposit. The Certificate of Deposit with a face value of $1,000.00 in Husband and Wife's names at the First National Bank of Everett shall become the sole and separate property of Husband. Wife agrees to waive any rights or interest she may have in that Certificate of Deposit by execution of this Agreement. 5. Insurance Policies and Pension Funds. Each party shall retain any individual retirement account in his or her name. Wife shall remain the death beneficiary on Husband's life insurance policy with the Associates as well as the death beneficiary to Husband's 401K retirement plan. In the event a Decree in Divorce is entered the parties hereto agree Wife shall no longer be the death beneficiary for either Husband's life insurance policy or his 401 K retirement plan. Husband waives any rights or interest he may have in Wife's individual retirement account or any insurance policies. Should it become necessary, each party agrees to sign any other titles or documents necessary to give effect to this paragraph upon request of the other party. 6. Real Property. Husband purchased a town home located at 1530 Tussey Court, Mechanicsburg, Pennsylvania, on May 15, 1992. Wife was never the legal title holder to the townhomeat 1530 Tussey Court but hereby transfers any of her rights and interest in and to said real estate now and formerly titled in the name of Husband and agrees to immediately now and in the future execute any and all documents and papers necessary to effect such transfer of rights and interests upon request. Wife further acknowledges that upon her execution of this Agreement she has no claim, right, interest or title whatsoever in 3 )F1:~9"4>~{1:lt~E:iff:.:r~{J~~I$:~~$3I*jj.~'t;;'i'2~:ei'1\\_ _ '_>"~I;~~(}rt~~iJ0T,1i4*~;~,;~~E1&kTI'#;t;t,'i~~:<;~;{:~-#I1I " ;f."fu:~;;E~~gMZ~~~i~~~,%'6k~'W~r~lf'[T\~ . ""-"':=c;,,,,j,~,.fu said real property and further agrees never to assert any claims to said property. Said transfer shall be effectively upon Wife's execution of this Agreement. Husband covenants and agrees to assume and pay in full on a timely basis any obligations encumbering or constituting a lien upon said property and further covenants and agrees that he will indemnify and save Wife harmless from any and all liability, expense, cost or loss whatsoever as a result of his non-payment or non-performance of said obligation. 7. Spousal Support/Alimony. In consideration for the rights of Wife set forth herein, upon execution of this Agreement Wife knowingly and voluntarily waives her right to receive spousal support during separation, the pendency of any possible divorce proceeding as well as alimony or alimony pendente lite following divorce. 8. Additional Instruments. Each of the parties shall, on demand, execute and deliver to the other any deeds, bills of sale, assignments, consents to change of beneficiary on insurance policies, tax returns and other documents and do or cause to be done any other act or thing that may be necessary or desirable to effectuate the provisions and purposes of this Agreement. If either party fails, on demand, to comply with this provision, that party shall pay to the other, all attorneys fees, costs and other expenses reasonably incurred as a result of such failure. 9. Debts and Liabilities. Husband and Wife hereby represent and warrant to the other that he or she has not incurred any debts or liabilities or made any contracts for which the other or his or her estate may be liable, except as stated in this Agreement. If either party has incurred an individual obligation during the term of the marriage, that party shall be responsible to discharge said obligation and hereby agrees to indemnify and save the other spouse harmless on account of said obligation. 10. Costs. Wife agrees to pay and reimburse Husband for Court costs and fees in an amount not to exceed three hundred and fifty ($350.00) dollars. Husband will present Wife evidence of payment and Wife will pay and reimburse the same immediately to Husband. 11. Warranty as to Future Obligations. Husband and Wife each covenant, warrant, represent and agree that with the exception of the obligations set forth in this Agreement, neither of them shall hereafter incur any liability whatsoever for which the estate of the other may be liable. Each party shall indemnify and hold harmless the other party for and against any and all debts, charges and liabilities incurred by the other after the date of execution of this Agreement, except as may be otherwise specifically provided for by the terms of this Agreement. 4 ~~.r%;yt1~f~illii~\f;~~li'%E!'0!~fJ1fi~'~l*;0~~\?,f1 ~- ~.. 1'Lr:f&{m~l~-:lNr?'J:%ft~~t~~~~~~ - ---< '_c"""''''_''"~_' 12. Effect of Separation Agreement. By this Agreement, the parties intend to resolve all the economic issues surrounding the marriage including but not limited to alimony, alimony pendente lite, spousal support, equitable distribution, counsel fees, costs and expenses. In the future, if either party files an action in divorce, the rights and obligations set forth herein shall be incorporated into a final divorce settlement agreement. The parties acknowledge that there may be some additions or mutually agreed written modifications to the existing terms of this Agreement, but it is the intent of the parties that the rights, duties and obligations set forth herein survive the divorce, if filed. 13. Waiver of Claims Against the Estate. Except as herein otherwise provided, each party may dispose of his or her property in any way, and each party hereby waives and relinquishes any and all rights he or she may now have or hereafter acquire under the present or future law of any jurisdiction to share in the property or the estate of the other as a result of the marital relationship. Each party will, at the request of the other, execute, acknowledge and deliver any and all instruments that may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interests, rights and claims. 14. Representation by Counsel. This Agreement has been prepared by Johnson, Duffie, Stewart & Weidner, attorney for Husband. Johnson, Duffie, Stewart & Weidner has not represented Wife in any respect with the negotiation and preparation of this Agreement. Wife acknowledges and understands that she has the right, if she so desires, to consult with counsel of her own choice regarding the provisions of this Agreement. This Agreement shall be interpreted fairly and simply and not strictly for or against either of the parties. 15. Modification and Waiver. Modification or waiver of any provision of this Agreement shall be effective only if made in writing and executed with the same formality as this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall not be construed as a waiver of any subsequent default of the same or similar nature. 16. Severability. If any provision of this Agreement is held to be invalid or unenforceable, all other provisions shall nevertheless continue in full force and effect. 17. Successors and Assigns. This Agreement, except as otherwise expressly provided herein, shall be binding upon and shall inure to the benefit of the respective legatees, devisees, heirs, executors, administrators, assigns and successors in interest of the parties. 5 "'!?jii'!i?~m{r~"i~$Jr;:M,!-,~;.llitfi!jJ&\'lff:~!%\t~ ~'~<~. ili'f\tf*It5;f.;.~'1~t~~"!ii;Z~~;T'~~Z:f%!;:g":~;~;;':!:\f;~):';;J;'M ~- "",""",",I".JI~.",_ 18. Governing Law. This Agreement shall be governed by and shall be construed in accordance with the laws of the Commonwealth of Pennsylvania. 19. Entire Agreement. This Agreement contains the entire understanding of the parties and there are no representations, warranties, covenants or undertakings other than those expressly set forth herein. IN WITNESS WHEREOF, the parties hereto, intending to be legally bound hereby, have hereunto set their hands and seals the day and year first above-written. WITNESS: (SEAL) Jo~" ~ ~ l~{1.0!w-0t Debra L. Shaffer (SEAL) :135717 6 .:4N~d;~~IK~~~G:;:qg'it':~~tti{0;~(?:E:rt~,;,;;}~jf,:B10jt.t~ -" .~ DIVORCE SETTLEMENT AGREEMENT ADDENDUM THIS ADDENDUM AGREEMENT, made this ~ day of September, 2000, by and between JOHN H. SHAFFER, residing at 1530 Tussey Court, Mechanicsburg, Cumberland County, Pennsylvania, hereinafter referred to as "Husband", and DEBRA L. SHAFFER, residing at 602 Louisa Lane, Mechanicsburg, Cumberland County, Pennsylvania, hereinafter referred to as "Wife". WI TNESSETH: WHEREAS, Husband and Wife entered into a Divorce Settlement/Separation Agreement on July 7, 2000; and WHEREAS, Husband and Wife wish to incorporate further provisions to said Agreement by this Addendum to the Divorce Settlement Agreement; and WHEREAS, Husband and Wife desire to file a formal Complaint in Divorce and transform this Settlement/Separation Agreement into a full and final Divorce Settlement Agreement; and WHEREAS, the parties hereto desire to confirm their understanding in writing and make final all settlement pertaining to the lawful marriage of Husband and Wife on October 2, 1999. NOW THEREFORE, the parties hereto, intending to be legally bound hereby, agree as follows: 1. Background. The items set forth above as background are hereby incorporated as if fully set forth herein. 2. Engagement ring. In consideration of the rights, duties, and obligations set forth in the Divorce Settlement Agreement/Separation Agreement as well as the Addendum thereto, Wife agrees to return to Husband the engagement ring purchased by Husband. tI u$ bfJ..vti a,yw -to W~.v-b h" r,~ f~ J"'ffi!<"T /M''''''~Yj '. {)M 9/?/~o J~s '17/06 ~9,._.!'t_"i-&,;,.,~"-t_'j;""".1';r,:!'1-,':;'f,,"-,>;-'__,fX'Mi::";,,,,_'Y'-,';:;;'l''):''~ '~,"""i",' "Z~;ftIt'J{:~:":i\~~1'~~'fu);';;1S:~Z~]:~~;s1-r:lS~~~{it€~f({i4 ",<- 3. Cash considerations. In consideration of the rights, duties, and obligations set forth in the Divorce Settlement Agreement/Separation Agreement as well as the Addendum thereto, Husband and Wife agree to amend Paragraph 3.B. to include the language as follows: "Wife shall direct all payments set forth herein to Husband's attorneys at the following address: Johnson, Duffie, Stewart and Weidner, P.O. Box 109, 301 Market Street, Lemoyne, Pennsylvania 17043." 4. No contact. As of the date of this Agreement, both parties agree that they will not contact each other at home or at his/her place of employment. They shall have no contact via written communication or by telephone. Neither party should contact the other party's friends or relatives and shall make no other such attempt to contact directly, or indirectly the other party. Any such contact will be considered by both parties to be harassment. By signing this Agreement, both parties acknowledge receipt of notice of the terms contained in this provision. 5. Representation by Counsel. This Agreement has been prepared by Johnson, Duffie, Stewart & Weidner, attorney for Husband, Johnson, Duffie, Stewart & Weidner has not represented Wife in any respect with the negotiation and preparation of this Agreement. Wife acknowledges and understands that she has the right, if she so desires, to consult with counsel of her own choice regarding the provisions of this Agreement. This Agreement shall be interpreted fairly and simply and not strictly for or against either of the parties. 6. Modification and Waiver. Modification or waiver of any provision of this Agreement shall be effective only if made in writing and executed with the same formality as this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall not be construed as a waiver of any subsequent default of the same or similar nature. 7. Severability. If any prOVISion of this Agreement is held to be unenforceable, all other provisions shall nevertheless continue in full force and effect. invalid or ~1\G?;;"-;:i2?i;g;t'Si:'B'~'Y'L'Y~f~~'i~Yf8i(iWi.:if~ii;~nfl,,~ '~.~=-",,,,~~,,,,,". ' j'i I j" \~! i (' !,! " > ~.;i~j}~_h~~$;~?~i~'i1~,},\{Z:fJt~~-\tt~!&r,-~t:'5.~hAill ~~~., '~;~g,B'~~lfkt;:;:;.;tf;'t';f;;;tY*i~"G14~~';E-iPl7iM;;JJ. 8. Successors and Assigns. This Agreement, except as otherwise expressly provided herein, shall be binding upon and shall inure to the benefit of the respective legatees, devisees, heirs, executors, administrators, assigns and successors in interest of the parties. 9. Governing Law. This Agreement shall be governed by and shall be construed in accordance with the laws of the Commonwealth of Pennsylvania. 10. Entire Agreement. This Agreement contains the entire understanding of the parties and there are no representations, warranties, covenants or undertakings other than those expressly set forth herein. IN WITNESS WHEREOF, the parties hereto, intending to be legally bound hereby, have hereunto set their hands and seals the day and year first above-written. WITNESS: fd'- q -9Ji (SEAL) John H. Sha !~ ~ eJ~_(SEAL) Debra L. Shaffer : 138296 ...............""fu.""'",H;;.,. <~\1l%~~if1tJ.r#~t1K~~R;tR~?'~J1t;~!@KfitZ~!~Jr;~~~ i,,-r'''''':''':';'~ ".,' .L::, ' ii i'l i' II [, II II Ii Ii Ii i' i! , i,1 i'i i.: , i '~ i! .' !:j ii I' H , i1 II 11 II Ii )j r: I, " ii " il i ~ " !,i , ~ " i! II i] Ij ii d Ii il ',~,. . , ~~4iJY~i!I~~}~~J.rjS~h&!",,;:~rr;:~;-Jj;1gtlR-\"c-~!,~,,'\",,"'d'''M'''V_-,~~,,,,;,,,,,,,,~",.~..;- 1IlliiB~l<i~~,.~_l&4lIiI'~~~"'~ "o".::!"',,.-,_., ."",~",,,,,=~,'," ,,'_=._ < ,,','_ _" ~~ IlI.UL -~ Jlljlil'~ 0 G :--:) c " ,- -0 ij'''' ~ 1"1': i,-, ~ c/:' -<. , ') C:- l_.: , '. _. :~:~ ' ' -~ (:=: )> r-'- i'..") '---' '7 " ::-::! ::-:::-1 "-,-; --< (..) =< '-," .t&~f~~ii&-f,~~~~~1\~rt11:~ ~.~ ~, &~~\{i'Yiffi~{~;A;.,~?8ff{%E;fJ2~~~~;%:~~%'4'j}~~ ~. 'l~'~,_:;&'~d'" IN THE COURT OF CCMMON PLEAS OF CUMBERLAND COUNI'Y, PENNSYLVANIA JOHN H. SHAFFER, Plaintiff NO. 00-6255 CIVIL ~ 2001 vs. DEBRA L. SHAFFER, 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. Grounds for divorce: irretrievable breakdown under Section 3301 (c) ~jj:x~:txk of the Divorce Code. (Strike out inapplicable section) 2. Date and manner of service of the complaint: Certified mail, restricted delivery to the Defendant on 9/14/00 and received bv Defendant on ~/18/00. 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 1/16/01 by the defendant B. (1) Date of execution of the plaintiff's affidavit required by Section 3301 (d) of the Divorce Code: (2) Date of service of the plaintiff's affidavit upon the defendant: 4. Related claims pending: The Divorce Settlement Agreement da.ted July 7, 2000 and Addendum dated September 7, 2000 are incorporated 1nto the uecree 1n D1vorce. ' 5. Indicate date and manner of service of the notice of intention to file praecipe to transmit record, and attach a copy of said.notice under Section 3301 (d)(1)(i) of the Divorce Code Waivers of Notice filed in September 13, 2000 and signed by Plaintiff on September 7, 2000 and by Defendant on September 7, 2000. Attorney for Plain Mark C. Duffie, :0::(~_'k;>;ft}~'t~iN;t,f;"'bg"':~'\"-f;;1,Rl\'''''i';t~;;''W:.Wh,)i;-!."!'.o,"ll! , R,;j'"~~- I: i; :1 n ij " 11 :j ., ~- ~ :1 '1 ;J i) i ~ ,j ;, !'; :i " li ,'I ,i :] i~\L""'_"~'''L~~=.C ."-'IUil~-';""'",IfIIOIMl!1L~~~~~~'-~ "~-""'in.__l fIliL'l] _.:ill'_~~_____""JlJo',~t!~~".,,,_, ,,,. '''' , "-~ "-~~,, -'~W ~__ow ~ , ~-- e~,,~ _ (') .- ::~ 2~t L.\~. ~2 ~~-- i~ :c;l -, o ~. \~~ '-- ~, ~-" ~ ~-~I" " '."-:' N (.0 ~~~g.~~~~~~t~~ ;Zk3t;:;gf;:"j1l-'Ja11:~ww:€:~')_~~~i::a:~'i;)';i~.;i;Y0'? ~{':.~::!lfr1!l ~_. -.- ~ - '..-- , "-,~, ""'--, -, .- -"""~--,. ".~- . ~Il>im'~;; Johnson, Duffie. Stewart & Weidner By: Mark C. Duffie I.D. No. 75906 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff JOHN H. SHAFFER, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. CO - (,.~ c'c.>l( ~ Plaintiff v. CIVIL ACTION - LAW DEBRA L. SHAFFER, 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 pages by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE THE DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone: (717) 249-3166 fX1iJ5~!\'~{;;:j,r:c0t;:(ff.:;:i:R:}~~0J%~:1~i;._;~);{:f4!},&>-ke0{j~;;M?_il "" ,w'-','-- '; "'= ----"..) . ~{M.~;;jm,'R\";I:' Johnson, Duffie, Stewart & Weidner By: Mark C. Duffie I.D. No. 75906 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff JOHN H. SHAFFER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. t/-O - (,.2.SS ~ "'-..u.-..-- v. CIVIL ACTION - LAW DEBRA L. SHAFFER, IN DIVORCE Defendant COMPLAINT IN DIVORCE UNDER SECTIONS 3301(cl OR 3301(ci) OF THE DIVORCE CODE AND NOW, comes the Plaintiff, John H. Shaffer, by and through his attorneys, Johnson, Duffie, Stewart & Weidner, and files the following Divorce Complaint against the Defendant, Debra L. Shaffer: 1. The Plaintiff is John H. Shaffer, an adult individual, residing at 1530 Tussey Court, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. The Defendant is Debra L. Shaffer, an adult individual, residing at 602 Louisa Lane, Mechanicsburg, Cumberland County, Pennsylvania 17050. 3. The Plaintiff and Defendant were married on October 2, 1999 in Mechanicsburg, Cumberland County, Pennsylvania. 4. The Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania at least six months immediately prior to the filing of this Complaint. 5. There has been no prior action for divorce or annulment of marriage between the parties in this or any other jurisdiction. !i!},;,p;Xj;t,?-,\)i.'(I?f,EE!:'i',?;;'TB?j~>.t~:k~;~:rR;-~~5t:~ _ ::i::~ '&8:+;;~~,'i1l;~':}i;;\;,;~iii;ftZ%1i~QU~4\i~~%'f,~$~~~1 [" :t:ffJ;.':'fF;S\~'~~~r{Liy~'ij_~i;;ii,~/E:;'4!~;?:5;;jt)~~::it_;'i~~i'i}~];~ ~' -- 6. The marriage is irretrievably broken. "'~__,~,_.,".. ,",,_,_" ,.. ',"n, 7. The Plaintiff has been advised of the availability of marriage counseling and he may have the right to request that the Court require the parties to participate in counseling. WHEREFORE, the Plaintiff respectfully requests that your Honorable Court enter a decree of divorce under Section 3301 (c) or 3301 (d) of the Divorce Code. JOHNSON, DUFFIE, STEWART By: CI rk C. Duffie ;136162 EIDNER "~Y' fik"f,;\q,~\1!-E4Y:~*~i~K!;t1!.Ri'1.i~'ii~tffict~~'~Z\~~~ >.' . .~, ~_ ,"". ^. . h _,,_'_ ."", ","",' ., "~" ' '-'-'.- ',~' ,. " aeJlo~_J~" VERIFICA TION I, John H. Shaffer, verify that the statements made in this Divorce Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are made subject to the penalties of 18 Pa. C.S.A !/4904, relating to unsworn falsification to authorities. Date: '} J b /00 ~.~ffer~ ~ii~~;'f,r~0~;;)~?f:ij{i;itb1O~~t~V($f2;;y&~;;E~;_K',~:,~,if)}'~ i~Tt~!,~.\j.iQ;1f;1't~%t7~J;'&'i~i~~$0)';c~1;~~tiir":iU\~t$fAll V-'-""""d.-"y,~ '~J,';'" '~~~'~.' / ,-' i . -,~....: ^~ f' I -Jil ~~~~&~%rf:M~lw~~~Jikf~"J."_"""".",,,_~,_~,_. . ~'_""'".""_""""_,,'~_'~~_, """,-,,,_ ".."".. '_-.,"">,__r~ >." '"~_." "~-. ~ ~", "P-"'llf ...' , ~ < , _,'0>' '..- ,-, t 0 -6q ~ 'I '" 8 ~ 0 ~ .~ ....... l; ~ 8 ~ () 0 c.--., ...0 c:. C) C> ~ I :z;:. ~/, -Of t n'il,', --~1 ~ -t ~ Z:r.:- "'lJ ......;) P( ~;.:~ C..' ~ C::C,! .-'-1'-' j :~ -- "1>_,_., ?C-) Pc:. 1'-,) ~ ~ ~ ' :J1 .,"~~ -< _JJ p-' -<: . ~ ".~, m;,~t#,~?i~1r.tb~~Jlrl&~~~~f~~~~~~ ~i1Wit~}f!i&'#&:ki!f:;j~l:;a~:;)~1Jitj;)1jmfEii1)1'F~t!i;?~ ,~!, .' -. - __ ,v _~._ " __, ,..- ~ c,' ,~__~ "~,__ "~-, <.....-~ Johnson, Duffie; Stewart & Weidner By: Mark C. Duffie I.D. No. 75906 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff JOHN H. SHAFFER, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 00- (.~ C;u,-l Plaintiff v. CIVIL ACTION - LAW DEBRA L. SHAFFER, IN DIVORCE Defendant CERTlFICA TE OF SERVICE I hereby certify that on the l'f" day of .1;tfm.iur- , 2000, that I served a true and correct copy of the Complaint in Divorce upon the Defendant, Debra L. Shaffer, by certified mail, restricted delivery, to his mailing address at 602 Louisa Lane, Mechanicsburg, Pennsylvania 17050, return receipt requested, attached hereto and made a part hereof. Date: By: :136162 Sworn to and subscribed before me this I '\ ~ay Of~A...2000. ~~ Notary Publi NOTARIAL SEAL DIANNE LENIG, Notary Public Lemoyne Borough Cumberland Co. My Commission Expires Dec. 21, 2001 ~ .:"lli:'2,j:R:)f'J;~~\;;;{'(,ir0~~EJ.~~1~O::-&1~;iJ~?)$*iit;$i~~%&~~ '" ~ - ;'- !ll1li.~~"~~'fillii!1R~""iilll>1,~,4l1:__"~.,"~,"" ,_ iUitilH '~~~~ RiloiIliI"""'-' 0"'",-""- d. -'IfI~~llItil!i!la ,__0_ ~"" , - "'~~ <II liirNalIJiao' ~ (jlllLl~ ~~e_ .~...... "'""" ~- ..." o' g 0 0 0 -r; en ~~:D 2fR r<1 -0 ::rJ -c.f;i ~~ W :oZ () 0 "--I !<: -0 25~ ~g 3 'W iSm ~ '=' ~ CJI '< "" &lZ~tJ~':$r~~~'\i~~~ffilh~"<<~~~\i,~ ;:: ~"~ "~ ;",~i0';I:r;:!$4if~o;~1i4t','t1i'zEffc\C:0.';':;~Si:r~;:i~n~~; "(';),cqi\1 ~. -"'" -" , ' - ",-C, "~0. ""'~ Johnson, Duffie, Stewart & Weidner By: Mark C. Duffie I.D. No. 75906 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff JOHN H. SHAFFER, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. OC - fo2..SS Plaintiff v. CIVIL ACTION - LAW DEBRA L. SHAFFER, IN DIVORCE Defendant AFFIDA VIT OF CONSENT 1. A Complaint in divorce under Section 3301 (c) of the Divorce Code was filed on September 13, ,2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the decree. 4. I have been advised of the availability of marriage counseling, understand that the Court maintains a list of marriage counselors and that I may request the Court require my spouse and I to participate in counseling and, being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to the divorce becoming final. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C,S. !/4904 relating to unsworn falsification to authorities. Date: January 16, 2001 ~Lt{1~ Debra L. Shaffer jRJ~,' '-:-~J ~;'~i~~0:j,I;~/f,~f;J}i~11;;?j;jl?;t/%:i.:'~&~-ffKZ,sIi1;;~;W,~ ~~'%[;4~1i:I*:t!J;-~i\t&~:t.~f;{1:fJili,Y-f.zti&iZ:~'i"J" r____' ~..........,--,..;; ~,~ k~ ......... ,~ '~. __'_~_''''~ -""-7'!' _ - '" ~ .. ,. ",1 <',..c,_, -' ~, ,", -lI'~' 'iii....' '---'~ --. 0 C:) ,'~ C \ } 7'- ., u ct ::r:,;;- fTi fi: 2: =r,i -- z C- O) < ....~1 -< ~:- rc C' ~ <> ;;.~ '\. -,- -'--- ;c...... '- ,.......J C ,,_.J Z > '-J r,-, ~, (,A.k/ :0 -< - ""~~~l'];'f~!~1,:;:;ifj;!2i;-f1ti{(!:<~';;'0jf~'))1i:,;,(,}~j.ifu'i$~~$)J@~:;-~ ;;~iti;':P@~~jZ3;:K;,,%f..fiiSi~-s\J),::G~:;~Y;:f;'Ui;:; ~ji:;;:"" :_,~;~ - ". '0 - ':'-. ,,':'., .-'- ~'~1' Johnson, Duffie, Stewart & Weidner By: Mark C. Duffie I.D. No. 75906 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff JOHN H. SHAFFER, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 6C.> - ~~-.s (?,c..> i ( ~ CIVIL ACTION - LAW Plaintiff v. DEBRA L. SHAFFER, IN DIVORCE Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301lcJ OF THE DIVORCE CODE 1 . I consent to the entry of a final decree in divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn falsification to authorities. Date: q /7 /00 . fl6u, <-A [(j~ Debra L. Shaffer ;~(;';i:s T_:';t!:~~('!>;:?,:<tf,1j;,f4A\n}t:ij11~;;0:J~Sij\~~,~,\:#J.};\1l ;~ - ~~1fti)~'i::>;i~~"M0T~ifi-~M':t'!S.~Y~i%#Ji:~~ _~ _ ~ ~~_~c b>..."~l' ~~ llIJiiIl;l!IO,j ,', -~ .- ~.L :M~_ti ~,--,- ~~......"'~~~-, ~ ,.::,. -Of;:; mr-;-; Z:r 0~-. -----~:_- !~ ::::: ~n (") C) C- C) C0 ;'1 --,':] (..,::. ~, -~ (:;) ~, ~ ~~ir,;;~l~~r~B;ij%0?@$f:J;~{;::;'04%f1~:&~jir;r?}}~ ;oifu~'\'Qt-0<~;~r;;;i-)1:I~~'~;~iilY(:');?;~f,;;ryg1g;~;;Z~~i~}f~i,::~ ~- ''','','' ,-".t-', bU.i.:~,,;j.nfi~~ . . Johnson, Duffie, Stewart & Weidner By: Mark C. Duffie I.D. No. 75906 301 Market Street P. O. Box 109 Lemoyne, Pennsy1vauia 17043-0109 (717) 761-4540 Attorneys for Plaintiff JOHN H. SHAFFER, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. NO. 00 - '-~ tr CIVIL ACTION - LAW DEBRA L. SHAFFER, IN DIVORCE Defendant AFFIDA VITOF CONSENT 1. A Complaint in divorce under Section 3301 (c) of the Divorce Code was filed on September 13, ,2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing 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. 4. I have been advised of the availability of marriage counseling, understand that the Court maintains a list of marriage counselors and that I may request the Court require my spouse and I to participate in counseling and, being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to the divorce becoming final. 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. ~904 relating to unsworn falsification to authorities. Date: January 16, 2001 ~~~ '"'f(t\f~'Y)!:€~~:~;]0t:1~tfi~~;;i1i1i~;fii~~6:~t0Ij;~11 !"'"" .~' ,;;- ~~~}~~~,~.f;'FJr:%iE~{ijitkt'ilt;tf';%i-, 0,_' ai.:J v. _ _~~ ,. _ " " -~ ~-. ~ ~.........,...... .' ",.- -^. "., '_1"",_ ,'~ - ,." "~ - ~'~~. '.........., . o ~~ -C:: nlf~ 2~ :>~ -7:" iQ'~ ,,--.--- '.- "-~, .- ~~~ L:'" :< ,~, '-..' :; ~~ ';' "J ',~ -< ~~) ~.~~: (") ;:::-),-;" ~ ~ :< ::'1 1',) (..) !M;t;iJj~;rfJ'1-[,{iil~;@{~t0:~J5ff.h~#:;;t;!~1jK~;;:~i~''t\'1,~' I ~ " , ~ - ,-'" - " ~ ,. ,- ' , ,~< .-', \-"., _n.~"' ',,, L - - -, ~.- k....ki;- ,; . . Johnson, Duffie, Stewart & Weidner By: Mark C. Duffie I.D. No. 75906 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff JOHN H. SHAFFER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 00 - (.~S'S e,.u.'l ~ CIVIL ACTION - LAW v. DEBRA L. SHAFFER, IN DIVORCE Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301fc) OF THE DIVORCE CODE 1 . I consent to the entry of a final decree in divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn falsification to authorities. Date: 9/7 leD ~.~a~ W~'\."00~;;I~~i/!t~~({il'?;t.;:~ZiK-::-ti1J8~Ifjl1t:}:i-%ii:1!J;~:;'j;i~ '''~S;;:;;*)!t:QtJ?iJ~:r1J.t;4iit;~r1itg:iim~:ig~~,:;i1ii:';js.iil {,: -~ ,-' I I , "~";"-_Iii."]iiJllI ~~~1;~~"'~~~~.\@r,~~Z\ll'l~Ji~T:0!ft1fi~,,_- ">>'<~~~_, e~ ~. ~'~"'Ul:liliiCI~ ~ , -" ""<~... 0_ 'If'riP''+-,t~ ,-~- . ~, n~,;--' Z'.:1. ~~> -</ yC. ~8 PC::: ;::: -d (j ~; c,:) c:) ;_.-") ,..,j -'J -~-: C~', .'",j (..,) ::> p ::0 -< W~'F-~i),~~~~~l1~>\Y&t:,~_t\TjSfi]~~fZt~]'~iili > ,"' '""'0-""..'-' " ," Johnson, Duffie, Stewart & Weidner By: Mark C. Duffie I.D. No. 75906 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff JOHN H. SHAFFER, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. OC> -I,..~~ Co~l<r~ Plaintiff v. CIVIL ACTION - LAW DEBRA L. SHAFFER, IN DIVORCE Defendant AFFIDA VIT DEBRA L. SHAFFER, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the court. 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. 94904, relating to unsworn falsification to authorities. Date: q /7/bO Wwc <-A J!J~ Debra L. Shaffer f~.if:r<~'~~it;-1ll%1:~?;:!f~~;;'f.~f/Wfi'1.i~:~?r;~#;JK::~'j!1 .,~_::' - ff;{.\R;~l{~K~~i':r~?\~1!};4:~:;i\_;N;;':;??:1t~rti;;i3~9'}~$d~~~,ii lh";.:-""~M"');;;>7",,,~ii!X~!~~,'t~,,4#k,,'0:~"'<if,: !" I .MliiiiiiIIl 11 I i Ii I I' II f i , I I I , ! ! , I I I I f " ",,-,;....,= -~ -~~"'"-. illiiW~ ~.......'"~ ~~-~,.. ~...... ~~"~ ('} C :?' OJ ~:~ ~ L-' c.o ~C~J ~2 ...- -< c ...._~' U') ,'1 -:) c :=-~: :.'.) :::> c:) ::-.J -< w;,~~~1t~:~f,!.lg,.'j;msJ{r~~~~~~i$B~~~'gr~ L--"- 0~~;;~tfM~~!l.~~~'iI;\~~ii~~i'i!i;\ffi%S~;i';:2ilfiJt'l. ,. , " " , M. ~ '!ltllliM'IINllofJ'''iJ-'''' Johnson, Duffie, Stewart & Weidner By: Mark C. Duffie I.D. No. 75906 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717)761-4540 Attorneys for Plaintiff JOHN H. SHAFFER, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06 - 1..2~ Ct.>; l ~ CIVIL ACTION - LAW Plaintiff v. DEBRA L. SHAFFER, IN DIVORCE Defendant AFFIDA Vir JOHN H. SHAFFER, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the court. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~4904, relating to unsworn falsification to authorities. Date: ~ / b/ 6D ~~mre~ .~i';;;;D;;:'ii~;:}J:';i'X:/t~tX~i~0t-'S:i!'1'';!;ft:%i~~i\i'SiZ4~iE:\'~,g~ ,T ~ H ',;1',,' C,' ;) ~'1 ".i r,.! q '-1 n l:] .., iil " ~..il~_~"-" ~~Ii.::~ :,1 ;', ::; i ~~}\;~4~~ti?!;1Wr~~'M,~it.ftfr\7W'~P'~,_,:,,~;;~ "'__<o*_,r,>,H;-i-"'",~""~,~",,,,''-L_",\- ~,_, ~'"~ ~","'~~ ~~~-1' J:mili"""- ,< /:v:-~ ,"'- ,,>,"~ '~i" ,~, "" ,-~ .."""~"" __ ,.J-" (') f;;~ -,..- .-:--," n~~~-:; 7!-' 65,~~_:.o ~i<----. K'--' -" z~.) ):';~ 2~ --I -< '} ::> Co c-:> c,:; (j') "1 -'(:i ,-- G." ':~,1 '" :'_"'l fil'ff~s.~r'1;!Ffj~~3!r;$ql~r;-~JJY#~WR~~~~~~~ ~~,*,'?~;'jEt.i:.0.jifu1i$h14t:]~if.:t"r.;'f:\;h0t~~Wss~-;~ " , -' -- ' " ",-,_ '-. . H ,.'" ,~ --'""4._'__' . Johnson, Duffie, Stewart & Weidner By: Mark C. Duffie I.D. No. 75906 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff JOHN H. SHAFFER, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 2000-6255 Civil Term v. DEBRA L. SHAFFER, CIVIL ACTION - LAW Defendant IN DIVORCE CERTIFICA TE OF SERVICE I hereby certify that on the 18th day of September, 2000, that I served a true and correct copy of the Complaint in Divorce upon the Defendant, Debra L. Shaffer, by certified mail, restricted delivery, to her mailing address at 602 Louisa Lane, Mechanicsburg, Pennsylvania 17050, return receipt requested, attached hereto and made a part hereof. Date: By: :136162 Sworn to and subscribed before me this P <;;:, ~ay of 'B~...-..l \^. 2000. ~ ~' _ I}/V\._ .J. otary Public ~ NOTARIAL SEAL DIANNE LENIG, Notary Public Lembyne Bom, ,UDh Cumberland Co. My Commission ~Ires Dec. 21, 2001 '1f~"i_, r~1~~3~7:;:,.~ttFt;;i;;.wJ!SJ!":0~;;J~*":#:t;ff1#iki~l;gi}'~f,gr~~ I,-,~~ ~_". ~ "f1:j?1';1'1JW(~pii.:W;:;~1~3et2:":0:;i5:>j~~i'+$i;::t;~~ijl?!ll , I....., ;" ': ",,~~J._.~iL; ""~"~, il'-I I;: I","."", !:, ;' 'Ii_ ',_J,_:: ! ~~Ii"tk"",L; _........~~_ #-- ~ ~~...~,~..~.- - . ca; SENDER: 'tl 'iij e " > " ~ " E I also :wish to receive the follow- ing services (for an extra fee): o Complete items 1 and/or 2 for additional services. . Complete items 3, 4a, and 4b. [J Print your name and address on the reverse of this fonn so that we can return this card to you. o Attach this fo~'to the front of the rnailpiece, or on the back if space does not permit. ' . [J Write "Ratum Recsipt Requested" on fhe maJJpiece belowthe'anicJe number. o The Return Receipt will show to whom the article was delivered and the date delivered. ' 3. Article Addr~ssed to: 1. 0 Addressee's Address 2. _'Restrict~d Delivery J)&8e.4 J...., St/-A~ !;,oDl. kOlJl~A /.....Jtlol€ /hE~rJlC.> 8u,e.(; / PA ; ~ )(Certltied o Insured DCOD a: !; o >- !!! PS Fdrm3811, December 1994 ee's Address (Only if requested and paid) i"l 1GY.!59s:.9t.~_3 Domestic Return Recel -...........".,-'''''"'e---~..........._----- J , IT' I"- ru CI "" Ul ,." CI "DSRi41., g.J{tFrR Postage ....-.-: Certified Fee r i . Postmark Here R~urn Receipt-Fee (EndorSement Required) Restricted Delivery-Fee (Endor~ement Required) .25 -" CI CI CI 0.75 ~, ,J5.73 09114- g rTota(p<ll..tam.& F...._"I: ~ -!~ ~ f:M LAW OFFICES IT'.~Si JOHNSON, DUFFIE, STEWART & WEIDNER IT' G 301 MARKET STREET ~ 'c, P. O. BOX 109 fYJc..-j) LEMOYNE, PENNSYLVANIA 17043..0109 I , _ __ __ _ __ ""WlIi4iI~ ,; , " Ul ~ a. '.. " '" a: ~., li a: '" c Ui " .2 " o >- ... C ~ ~-__',____-;l.l""'C . i,1 <- 0"-' " :-! ';: .~,:""~,,, 'n'~~.lIilli..It.lll;.lll;~r>r;rH~mJilllUiOllill1n_'it~t<r~Aij'~iI?"'';'rUj-'' ~;' ~&i~~~';{~t.@f~l*1:ivl~ritiM{'~~~l<<%Ji" -', ., ,-1"'" . ".'. "_~,,,,,,,,,_" """"'.-P"..O , ,''''''"."' _" ." .. . '-"j."~" ~ ' ;. - .-,~'''~ ~-=. ...'.IIiiOiiI 'If ',"""" D C-} '~~. C c-:-. -:........ J') -ox;: r'1 ~ f11n -0 i:;:j'IJJ z:n , ", -;~lrn < z(" -UCJ 0?2~' ::;-, I ':<2: ~-':.~ ~"(. ~C) -0 --;- ! ~"'(J == ;;~6 b:n t:? 6rn :l>e: ~ => s;' :0 -< .." .' , . ~f'l:~~i;'?JiPZ'!l;~S?~J4~~11~~i:",'qif~,0L@!&;:?