HomeMy WebLinkAbout00-06575
. .
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
..
.
.
.
.
.
.
.
.
~ >
~~ ""
. .
,
~ ~ ~ ~ ~~~ ~ f.~ ~ ~ ~
.
;f. Of. :f.:tiili
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF
PENNA.
JEFFREY LEE POTTINGER,
Plaintiff
No. 00-6575 CIVIL TERM
VERSUS
MATI~FFl\l GAV POTTIl\TGER
~ .
Defendant
DECREE IN
DIVORCE
AND NOW,
O~"a.. J~
2000 , IT IS ORDERED AND
DECREED THAT
JEFFREY LEE POTTINGER
PLAINTIFF,
AND
MAUREEN GAY POTTINGER
, 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
YET BEEN ENTERED;
IT IS FURTHER ORDERED that the parties I Marital Settlement
Agreement and Agreement for Child Support and Alimony, dated
September 18, 2000, shall be incorporated into, but not merged
with, this Decree in Divorce.
.
. . .
.
.
o~
R THONOTARY
.
.
.
.
.
.
. . .
.
. .
-'"~'
, -f1".,(,
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
J.
.
.
.
.
.
.
.
.
.
.
"
;,._,
"
". ,.,,~ ""Y'^."
/0-]00
/03-0::;
<
,-"....- ,
-~ "
fl' ~.~_
>"~~-~-"'.'--',,,,,,,~, >..~ "-~ ~ <~-"=-.~'"
.,'~ I"<'''''-'I''.'(',:;;d
..'
.. ,
&I-~ /UaJ/-z4~
'Jt~~~~.
--,'~-~
~'= _M~~
~_....~. f':jj!ll!l'!lP!1l
mlIU__ "'_ ,~S~~_
V!M1r- ~~~:: ~,,-;-
C._'"~ ~~_~ _
- < - "'-~",," . - ~ ,'-~~-- ,-.",' '"'
..c..c,..................,c...... .._P......,"'
,- ,"'''-'~" 1'll~~
C'
Ii..'.
,
i
"7lc. UV.. (.j- 76- (' . 'J.
"
,.
MARITAL SETTLEMENT AGREEMENT
AGREEMENT made this pi day of September, 2000, by and between
JEFFREY LEE POTTINGER, hereinafter called "Husband," and
MAUREEN GAY POTTINGER, hereinafter called "Wife."
WITNESSETH:
WHEREAS, in consequence of disputes and unhappy differences,
the parties are separated and living apart from each other; and
~;
WHEREAS, the parties desire to confirm their separation and
make arrangement in connection therewith; and
WHEREAS, seven children were born of the marriage;
IT IS THEREFORE AGREED:
1. CONSIDERATION - The consideration for this Agreement is the
mutual promises, covenants and agreements herein contained.
2. SEPARATION - It shall be lawful for each party at all times hereafter
to live separate and apart from the other party at such place or places as he or
she may from time to time choose deem fit.
3. NO INTERFERENCE - Each party shall be free from interference,
authority and control, direct or indirect, by the other, as fully as if he or she
were single and unmarried.
4. COUNSEL FEES
A. Husband agrees to pay all counsel fees incurred by him since
the separation of Husband and Wife.
1
--" ", '_P "
- ~"
'~","-" '~" ''',",'';'' ,'" ... -i'" "~, {_'_ _', ~,
'," 'L c...~'.' -~- "'-'~__',,".;,
.,',.',,""
,/-0- ;-' __ /c;,;J,'"-"'_L:d,-~~::>&;,,,,:;;',,\-;^,:-,:'::;','>>~:<s8\;',
.- ,"'-"'"" ~'''-r[:;-
.
B. Wife agrees to pay all counsel fees incurred by her since the
separation of Husband and Wife.
5. DIVISION OF PERSONAL PROPERTY - Husband shall be the
sole owner of the items of personal property currently in his possession,
including the following items: The 1996 Jeep, 1994 Altima, all funds in his
Navy Federal Credit Union checking and savings accounts, the USAA mutual
fund and the Series EE bonds.
Wife shall be the sole owner of the items of personal property
currently in her possession, including the 1994 Altima, 1992 Dodge van, and
her funds in checking, savings, and stock.
Except as outlined in this paragraph, the parties will divide their
remaining personalty to their mutual satisfaction, and hereafter each shall own
and enjoy, independently of any claim or right of the other, all items of
personal property of every kind, which are now owned or held or which may
hereafter belong or come to him or her, with full power of disposition as if he or
she were unmarried.
6. AFTER-ACOUlRED PROPERTY - Each of the parties shall
hereafter own and enjoy, independently of any claim or right of the other, all
property, tangible or intangible, real, personal or mixed, acquired by him or
her, whether or not marital assets were utilized in the acquisition, since the
date of the parties' separation, or if not separated, the date of the execution of
2
, = - -" ~,- ~ -. H_"~"<"~ ,__=_=~ -- ",,-,' --.-'=',-'.-"",-, ",'^'."-'- "'''''-''_"C:''~__'''''~',,''.._' '70"l8
. .
<
this Agreement, with full power in him or her to dispose of the same as fully
and effectively, in all respects and for all purposes as though he or she were
unmarried; and each party hereby waives, releases, renounces and forever
abandons any right, title, interest and claim in and to said after-acquired
property of the other party pursuant to the terms of this paragraph.
7. NO-FAULT DIVORCE - The parties acknowledge that their marriage
is irretrievably broken and that they shall secure a mutual consent no-fault
divorce. The parties shall execute Affidavits of Consent and Waivers to permit
the entry of a Decree in Divorce.
8. DISCLOSURE AND WAIVER OF PROCEDURAL RIGHTS - Each
party understands that he or she has the right to obtain from the other party a
complete inventory or list of all of the property that either or both parties own
at this time or owned as of the date of separation, and that each party has the
right to have all such property valued by means of appraisals or otherwise.
Both parties understand that they have the right to have a court hold hearings
and make decisions on the matters covered by this Agreement. Both parties
understand that a court decision concerning the parties' respective rights and
obligations might be different from the provisions of this Agreement.
Each party hereby acknowledges that this Agreement is fair and
equitable, that it adequately provides for his or her needs and is in this or her
best interests, and that the Agreement is not the result of any fraud, duress, or
3
~ ',,'~' ,n ^ ^_~~ ",~ ."
.," ~'.. '-", ,~,'c' ,_,. ;',. - ~"-..r_- ~"",'.
,v~.;";;",- ".,.,-,,<,:,,',,; ,,-G:"-:C;,_,,"'^-';'~,~..J.i,c::;<;' -,,,""__ '-;';.:"';;':;J"-:';"~',:;i;,"'~
;.-..,>.-,-,,>,;;>:
.
undue influence exercised by either party upon the other or by any other
person or persons upon either party. Both parties hereby waive the following
procedural rights:
a. The right to obtain an inventory and appraisement of all marital
and non-marital property as defined by the Pennsylvania Divorce Code.
b. The right to obtain an income and expense statement of the
other party as provided by the Pennsylvania Divorce Code.
c. The right to have property identified and appraised.
d. The right to discovery as provided by the Pennsylvania Rules of
Civil Procedure.
e. The right to have the court determine which property is marital
and which is non-marital, and equitably distribute between the parties that
property which the court determines to be marital, and to set aside to either
party that property which the court determines to be the parties' non-marital
property .
f. The right to have the court decide any other rights, remedies,
privileges, or obligations covered by this Agreement and/ or arising out of the
marital relationship, including but not limited to possible claims for divorce,
child or spousal support, alimony, alimony pendente lite (temporary
alimony), equitable distribution, debt allocation, and counsel fees, costs and
expenses.
4
,h <,.- , . ,,-~-,.~,' ,.;",",_,~...,..,'~ '_.', _ , ~ ,~ "/.~".' 0'''' .,,-,. - ',,00..;;-.' -..,', ",,,,-"'L',,,,'~"" "",,,,,,,,_ -,'-.. ""'." -'~';_~'",--,~",,,{,".;.,,;<;,,<;_~c;, .,<.<,;,~\.o;,J.,;;."_ '''"'_'_,' ';;~_:"" ,. '''~
9. PENSION BENEFITS - The parties acknowledge that Husband is
the owner of a military retirement benefit package resulting form his years of
service with the United States Navy. The parties agree that Wife shall be
entitled to one-half of the value of said pension from the date of the parties'
marriage until the date of the parties' final decree in Divorce. Husband and
Wife agree that each shall execute any documents necessary to secure this
right in Wife.
10. MARITAL DEBTS - The parties acknowledge that they have
previously divided the obligations and payments required thereof of any debts
and obligations arising during the marriage and in accordance therewith any
obligation being paid by a party shall continue to be so paid and said party
shall indemnify, protect and save the other party harmless therefrom.
A liability not disclosed in this Agreement will be the sole responsibility of
the party who has incurred or may hereafter incur it, and each agrees to pay it
as the same shall become due, and to indemnify and hold the other party and
his or her property harmless from any and all such debts, obligations and
liabilities. From the date of execution of this Agreement, each party shall use
only those credit cards and accounts for which that party is individually liable
and the parties agree to cooperate in closing any remaining accounts which
provide for joint liability.
5
^'^^
no _
qd ~ ~,'
'" "<--',';''-''''y"',; "'~"--"".-"""--' ..-' "" -< ,_;~'-"'J' ",. "-, - ,""~,i-"',,,,, .;;;;"'""'"....?-.--;.,<~,;,;.i', --;:""e":~' ';"~,,:s;,, :-,~~i,,," .,'00''.. ',- '" '-' ,;_ ""'~_~
Specifically, each party shall be fully and solely responsible for payment
of the loans secured by vehicles in his or her name and the credit card debts in
his or her name alone. Each party agrees to hold the other party harmless
from any liability arising out of his or her failure to pay these debts as agreed.
11. WIFE'S DEBTS - Wife represents and warrants to Husband that she
will not contract or incur any debts or liabilities for which Husband or his
estate may be responsible and she shall indemnify and save Husband harmless
from any and all claims or demands made against him by reason of debts or
obligations incurred by her since the date of the separation.
12. HUSBAND'S DEBTS - Husband represents and warrants to Wife that
he will not contract or incur any debts or liabilities for which Wife or her estate
may be responsible and he shall indemnify and save Wife harmless from any
and all claims or demands made against her by reason of debts or obligations
incurred by him since the date of the separation.
13. REAL ESTATE - The parties acknowledge that they are the owners of
three parcels of real estate:
1. The real estate known and numbered as 282 Ridge Hill Road,
Mechanicsburg, Cumberland County, Pennsylvania, shall remain titled in joint
names with Wife having exclusive possession and full ownership rights for
income tax purposes. Wife further agrees to be solely and fully responsible for
payment of all debts and expenses associated with the real estate, including
6
.:;~ L:_~:_'"; "_ ,_,;'
"'-, ".:-'
co'_ ,i:..\',:-,:,':(,,~., ;i: '-,
but not limited to the mortgage debt, taxes, insurance, and maintenance. Wife
agrees to hold Husband harmless from any liability arising out of Wife's failure
to pay any of these expenses. If Wife elects to sell the real estate, Husband
shall have the right of first refusal to purchase the real estate at fair market
value. If Husband chooses not to purchase the real estate, Wife may sell the
real estate to any third party at a price to be determined solely by Wife. Wife
shall be entitled to receive all of the profits from the sale, and shall be fully and
solely responsible to pay any losses associated with the sale. Wife agrees to
apply for refinance with respect to the property upon inception of her monthly
receipt from Husband's military pension. The purpose of the refinance is to
remove any liability that Husband may have with respect to the mortgage debt
secured by the real estate. Wife shall acquire and maintain life insurance in an
amount sufficient to pay the remaining mortgage balance in the event of her
death prior to repayment in full or refinance.
2. The real estate located at 14083 Tontine Road, Jacksonville,
Florida, shall remain titled in joint names with Husband having exclusive
possession and full ownership rights for income tax purposes. Husband
further agrees to be solely and fully responsible for payment of all debts and
expenses associated with the real estate, including but not limited to the
mortgage debt, taxes, insurance, and maintenance. Husband agrees to hold
Wife harmless from any liability arising out of Husband's failure to pay any of
7
"~F_
, "-~
-, ^".~''',"' ",'"
",,-^,"' -,." ; "'~',,,,-,,-- _'''_.0-,:;""__.,, - '=L>
"el'. '__'~"L- "_. "",",_ _~~~_..::::>
<;,
these expenses. If Husband elects to sell the real estate, Wife shall have the
right of first refusal to purchase the real estate at fair market value. If Wife
chooses not to purchase the real estate, Husband may sell the real estate to
any third party at a price to be determined solely by Husband. Husband shall
be entitled to receive all of the profits from the sale, and shall be fully and
solely responsible to pay any losses associated with the sale. Husband agrees
to apply for refinance with respect to the property upon inception of his
monthly receipt of his military pension. The purpose of the refinance is to
remove any liability that Wife may have with respect to the mortgage debt
secured by the real estate.
3. The real estate located at 105 Sweet Gum Drive, Athens,
Georgia, shall remain titled in joint names, with Husband having full and sole
responsibility for its management and upkeep. Husband shall be fully and
solely responsible for payment of the mortgage, taxes, insurance, and
maintenance. Husband shall entitled to any rental profits, and shall be solely
responsible for payment of any rental losses. If Husband decides to sell the
real estate, Wife will cooperate with the sale. All proceeds from the sale will be
divided equally between the parties.
14. TAXES - Husband and Wife agree to indemnify and hold each other
harmless should either party have to pay any taxes, interest and/ or penalties
assessed as a result of any error in the reporting of income and/ or in the
8
',,", "-,-",,.,
preparation of any tax return by the other party during the years in which they
were married.
15. WAIVER OF WIFE'S CLAIMS AGAINST HUSBAND'S ESTATE - Wife
does hereby remise, release, quitclaim and forever discharge Husband and his
estate of and from any kind of every claim of any nature and kind whatsoever,
including but not limited to any claim arising out of the marital relationship,
whether arising out of any former contracts, engagements, or liabilities of
Husband, or by way of dower or claim in the nature of dower, widow's rights, or
under the intestate laws, or the right to elect against Husband's Will, or any
other claims of any nature whatsoever, except only the rights accruing to Wife
under this Agreement. Wife hereby waives and renounces any preference or
right to claim appointment or to qualify as the personal representative of
Husband, or to administer Husband's personal estate and effects in the event
that Wife survives Husband.
16. WAIVER OF HUSBAND'S CLAIM AGAINST WIFE'S ESTATE -
Husband does hereby remise, release, quitclaim and forever discharge Wife and
her estate of and from any and every claim of any nature and kind whatsoever,
including but not limited to any claim arising out of the marital relationship,
whether arising out of any former contracts, engagements or liabilities of Wife,
by way of curtesy, or claim in the nature of curtesy, widower's rights, or under
the intestate laws, or the right to elect against Wife's will or any other claims of
9
, '.'.
, ',~ ,._~_'~_<'" q ^. ., ,..,,'C>
-,,'" -,,---"-- <"~---'~ .<,".,,~.,-~ "~, '. "~.-,-~.lJ,,-';i.1" ,.,.-_"0",,,,,,,-,/'_ '_ :,c,,*_"v';"-':O"_'~''''''''''''''''k.: -,'-
any nature whatsoever, except only the rights accruing to Husband under this
Agreement. Husband hereby waives and renounces any preference or right to
claim appointment or to qualify as the personal representative of Wife, or to
administer Wife's personal estate and effects in the event that Husband
survives Wife.
17. SUBSEQUENT DIVORCE - Nothing herein contained shall be
deemed to prevent either of the parties from maintaining suit for absolute
divorce against the other in any jurisdiction based upon any past or future
conduct of the other, nor to bar the other from defending any such suit. In the
event any such action is instituted, the parties shall be bound by all terms of
this Agreement and this Agreement shall be the sole remedy available to the
parties.
18. EQUITABLE DIVISION OF PROPERTY - By this Agreement, the
parties have intended to effect an equitable division of their marital property.
This division is not intended by the parties to constitute in any way a sale or
exchange of assets.
19. MUTUAL RELEASE - Subject to the provisions of this Agreement,
each party has released and discharged, and by this Agreement does for
himself or herself, or his or her heirs, legal representatives, executors,
administrators and assigns, release and discharge the other of and from all
causes of action, claims, rights or demands whatsoever in law or in equity,
10
"'",',-' ~---"",
C'_;"_~_' ',_._,- -'.,..___,-.
-n "");:",, ' "
,-,",
which either of the parties have, or have ever had, against the other including
any and all rights under the Pennsylvania Domestic Relations Code, including
spousal support, alimony, alimony pendente lite, equitable distribution of
property and counsel fees.
20. BREACH - If either party breaches any provision of this Agreement,
then he or she shall have the right to sue for damages for such breach, or seek
such other remedy or relief as may be available. Counsel fees and costs of the
prevailing party shall be paid by the defaulting party.
21. ADDITIONAL INSTRUMENTS - Each of the parties shall, from time
to time, at the request of the other, execute, acknowledge and deliver to the
other party within a reasonable time period (presumed to be thirty (30) days
after such request is made) any and all further instruments including deed(s)
or releases which may reasonably be required to give full force and effect to the
provisions of this Agreement.
22. VOLUNTARY EXECUTION - The provisions of this Agreement and
their legal effect have been fully explained to the parties and each party
acknowledges that the Agreement is fair and equitable, that it is being entered
into voluntarily, and that it is not the result of any duress or undue influence.
The parties acknowledge that full disclosure has been made and they have
been furnished with all information relating to the financial affairs of the other
which has been requested and that counsel for each of the parties have
11
,-~"",,--,~,.~.,_,"":;'T"" -"-""=_'_"
reviewed the document, or, in the absence of counsel, the party has waives his
or her right to counsel.
23. ENTIRE AGREEMENT - This Agreement contains the entire
understanding of the parties, and there are no representations, waivers,
covenants or undertakings other than those expressly set forth herein.
24. MODIFICATION AND WAIVER - A modification or waiver of any of
the provisions 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 on strict performance of any of the provisions of this Agreement shall
not be construed as a waiver of any subsequent default for the same or similar
nature.
25. PARTIAL INVALIDITY - If any provision of this Agreement is held to
be invalid or unenforceable, all other provisions shall nevertheless continue in
full force and effect.
26. BINDING EFFECT - Except as otherwise stated within, all of the
provisions of this Agreement shall be binding upon the respective heirs, next of
kin, executors and administrators of the parties.
27. INTENT OF PARTIES - It is the intention of the parties hereto that
this Agreement is a complete and final disposition of their property rights and
not a mere Separation Agreement.
12
"-'-'L"c""
.- ..."" ". . ~" ~," ., , ~.- ',,"_c"' .., Oi,'"._ =/!,,' ,~",:' '''-r';'~ ,~,~.~,'--~" "',, ~'-"d_",1_'__.illO",,; --~-, ___, ."/"cO:\:,;','cf0",'"""",.",-~-~"" ";', "'''
'-&!I
28. INCORPORATION - The parties agree that the terms of this
Agreement shall be incorporated but not merged into any Decree of Divorce
which may be entered. The parties understand and agree that this Agreement
shall survive any such final Decree of Divorce and shall be independent
thereof. Said incorporation shall be for the sole purpose of obtaining additional
rights of enforcement and the parties understand that the provisions of
this Agreement shall not be subject to any modification, unless specifically
provided for in the relevant paragraph.
29. ENFORCEMENT - The parties agree that any action necessary by
either party to enforce their rights under this agreement against the other shall
be filed before the Court of Common Pleas of Cumberland County,
Pennsylvania, and, regardless of where any divorce action between them is
conduded, both parties hereby stipulate to the jurisdiction and venue of the
Court of Common Pleas of Cumberland County, Pennsylvania, for purposes of
interpretation or enforcement of this agreement.
30. HEADINGS NOT PART OF AGREEMENT - Any headings preceding
the text of the several paragraphs and subparagraphs hereof, are inserted
solely for convenience of reference and shall not constitute a part of this
Agreement nor shall they affect its meaning, construction or effect.
BY SIGNING THIS AGREEMENT, EACH PARTY ACKNOWLEDGES
HAVING READ AND UNDERSTOOD THE ENTIRE AGREEMENT, AND EACH
13
"i-.' -i-,', - '~;i' _ ~ -,
'''''_'O'~''''''''~--_ " '-'h' ""
. ,
PARTY ACKNOWLEDGES THAT THE PROVISIONS OF THIS AGREEMENT
SHALL BE AS BINDING UPON THE PARTIES AS IF THEY WERE ORDERED BY
THE COURT AFTER A FULL HEARING.
IN WITNESS WHEREOF, the parties have hereunto set their hands and
seals the day and year first above written.
r-/t- ~ ~ /I..vt
WITNESS
t'l.~r~
WITNESS
14
-
'-'d'~
, r..!I.IIIIIL,.,
--~., ;;w'-i'" ""
~," . . . .," ~_J;' ,,,:,,oe, . ",-, ~'.'" .. ",y -",c, .'" .' .~" , . .... "'4 . ,-,
"' ~," """''''''''~_'''~''''"'~-'''_ ,~. -.,"",,,0 ;<-"""'_",, ,,,, ",.
"", ~ -.", ,,^ ,~" ~.~
(") C)"- C:")
C L_' "",-j
-"'" c:J
<
"'tJtj] r-) .-:1
\1'1;--': ."~1
/''71
2: c: ,. , ,_.
~2:~> r.,j
C C .--;:)
~ C~, .'_.~ , ,
<C. C=J
5" C)
c: .::,-,
L. :~f1 E.
.-j ~
-<. I v
-, ~~ ~
00
.
..
~,Vv- (,.,r7( C Tv
AGREEMENT FOR CHILD SUPPORT AND ALIMONY
AGREEMENT made this %-d. day of September, 2000, by and
between JEFFREY LEE POTTINGER, hereinafter called "Husband,"
and MAUREEN GAY POTTINGER, hereinafter called "Wife."
WITNESSETH:
WHEREAS, in consequence of disputes and unhappy differences,
the parties are separated and living apart from each other; and
WHEREAS, the parties desire to confirm their separation and
make arrangement in connection therewith; and
WHEREAS, seven children were born of the marriage;
IT IS THEREFORE AGREED:
1. Husband shall pay to Wife the sum of Four Hundred Dollars
per child per month for each child under the age of eighteen (18) and
residing with Wife as child support. The parties presently have four
children under the age of eighteen (18) years residing with Wife, and
Husband will pay Wife the sum of One Thousand Six Hundred Dollars
($1,600.00) per month in child support. Child support for each child will
stop when each child graduates from high school or reaches age eighteen
(18), whichever occurs first.
2. Husband shall pay to Wife the sum of Four Hundred Dollars
($400.00) per month in alimony. This shall remain in effect until the
first of the following events occurs:
..'
<=> .~,
"'---"' .' , , .-,'~.-, ..;,-;i-h,O , ;", ""~--" -;-~~,;:" "'b,"""""~ ." ,,'., ., .~. ("~,';;-. C -;,;'.'~ " ,~:j.h;"""""", , "'.- ,.,.'."...,.
.
a. Wife remarries.
b. Wife receives her first monthly payment from Husband's
military retirement benefits.
c. The death of either party.
3. Neither party shall be responsible for payment of post-high
school expenses for any child.
4. Husband shall maintain health insurance coverage for himself
and for the parties' minor children until their eligibility for
medical/ dental benefits expires, through his United States Navy provided
medical/ dental benefits or through the United States Navy's TRICARE
PRIME for medical coverage and the United Concordia Plan for dental
coverage. The parties shall divide equally any liability for the children's
unpaid medical bills. Husband shall be solely responsible for any unpaid
medical/ dental bills of his own.
5. Upon the issuance of a decree in Divorce, Wife shall maintain
her own separate medical and dental insurance coverage, either by
maintaining/reacquiring her military insurance benefits, or through
private insurance. Wife shall be solely responsible for any unpaid
medical/ dental bills of her own.
,;':,.::)'~;;,'-c;".;'.".~.;",;-',. " '~_:"_'~:~'
-, >--~,.,
""--,,.'<.',.,
. '_-'",~'" -'f"--
'.f"""~i",;_
6. This Agreement shall be enforceable through the Domestic
Relations office of Cumberland County, Pennsylvania, or through any
other enforcement tribunal at Wife's sole election.
IN WITNESS WHEREOF, and intending to be legally bound, the
parties have hereunto set their hands and seals the day and year first
above written.
e.G~ t:,,4A
WITNESS
/'~~~~
WITNESS
",-
-L ~~~-~"J4
~
~ > .
~~ ~-
~ _~,_,<,,,.,~c <'
CO"~ _,<_~"
~"~,,.. ".~....
,-'-..
...
(")
-ot~
;f.'
~lE.~.
):~;; r~
s=;~j
z
:;;I
,~
c:)
:::>
:;.')
,--t
I
, r;
j,,-;
__~J::i
,-- ,
<;:~;~~
~];--:1
:J>
:r..1
-<
"TJ
.-"1;..
U1
(.;>
"
,~,,~''''',j-''''''I'''''"''-''''~''"''1ll1l'OlJ
~-
" ,
~ -, "~
,~---- "-~
~. ~-'~~_lIil."".,
1
~.'"
JEFFREY LEE POTTINGER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CMLACTION - LAW
VS.
NUMBER: tl\-l.S1S CML TERM
NAUREEN GAY POTTINGER,
Defendant
IN DNORCE
PRAECIPE TO TRANSMIT RECORD
TO THE PROTHONOTARY:
Transmit the record, together with the following information, to the court
for entry of an appropriate divorce decree:
1. Ground for divorce: Irretrievable breakdown under @3301(c) of the
Divorce Code. (Strike out inapplicable section).
2. Date and manner of service of complaint: April 5, 2000, by
certified mail.
3. Complete either paragraph (a) or (b):
(a)(l) Date of execution of the affidavit of consent required by
3301(c) of the Divorce Code: by plaintiff: September 8,2000; by defendant:
September 8,2000.
(a)(2) Date of execution of the Waiver of Notice of Intention
required by @3301(c) of the Divorce Code: by plaintiff: September 8,2000; by
defendant: September 8,2000.
(b)(l) Date of execution of the affidavit required by @3301(d) of the
Divorce Code:
(b)(2) Date of filing and service of the plaintiffs affidavit upon the
respondent: Filed: ; Served:
4. Related Claims Pending: No claims raised.
5. Complete either (a) or (b):
(a) Date and manner of service of the notice of intention to file
praecipe to transmit record, a copy of which is attached:
Lli<!'~~~-.~' ~~ ~ ~m~',..~~~ _..
,.../l> ...
.~
-,~
~""'""''''~' -j"IiL1iirl;,i:l\.f,j.
.
(b) Date plaintiffs Waiver of Notice in g330 1 (c) Divorce was filed
with the prothonotary: September 14, 2000.
(c) Date defendant's Waiver of Notice in S3301(c) Divorce was
filed with the prothonotary: September 14,2000.
~~-. ~~~
CHARLES E. PETRIE
ATTORNEY FOR PLAINTIFF
"~i '-.~lli~,*,-l.>OHHE-;t;"d",,"-,-r,",'~";;~"'-",-Ji~_~h'6i~~~i"iC'.Loi1'lli.Ibil'_"~~~.111i w.
1_, ,_ ~"""'h",'''~" __
.~,.."
~~... .-
'.',.'"
,,,., .~ . ". -~ -,
~ _......~ ;. - '""'-
.
~.~" ~.
'-f:;W
t
.. . ....---'
C) 0 ,"_,1
c: C:-, .
5.~ :::~
nVGJ n
'frj'" "."of , T!
Z:T ,f:'~
z: ~'.
(f) P,) ;'j '".1
-< ..,<. '.-) )-,
r::: 0 - -~ -'~j
:P -0 :H
(') :J,"..: ,~.)
Z C- D
5>c 0 rT~
:7 ---{
::::t LI1 ~:>.
-< (.0 JJ
-<
Ii:
~ " '~"'=
I....
,..
" ~ -, - - -
- :~".
" - '.
fJ(Jd-6576 ~
, ,
IN THE COURT OF COMMON PLEAS OF'THE FIFTY-NINTH
JUDICIAL DISTRICT OF PENNSYLVANIA
JEFFREY LEE POTTINGER,
Plaintiff
.
COUNTY BRANCH - CAMERON
.
.
MAUREEN GAY POTTINGER,
Defendant
CIVIL ACTION T L{'-W F~ ' ,"
i i
NO. 2000-2115 \ \
\ \
i \
I I :-~..
I I' :..:
ORDER OF COURT \ \ ~.. ,C) .
AND NOW, September 15, 2000, upon consideration ~f br~ci~ to irl:lnsmit
.
VS.
.
.
r'"}
.
\.w
record; and, upon review, the Court noting that the parties are requesting approval and
incorporation of a marriage settlement agreement in the divorce, that the parties are the
parents of minor children to which the marriage settlement agreement does not speak;
that this Court is not inclined to approve a divorce between a non-residents of Cameron
County where there are children and no arrangements made with regard to the
custody/support of said children; IT IS THEREFORE ORDERED AND DECREED that
the request for entry of divorce decree is denied and the proceedings transferred to the
County of Cumberland, where the action originally could have been initiated pursuant to
PaRC.P. No. 1920.2(c).
Cost of transfer are imposed upon the plaintiff and shall be paid within 20 days
from date of entry of this Order.
BY THE CO RT:
T e and Correct Copy
.tied from the
. rds of Cameron Co.
ne.
Judge
Ve
,
-
J&llWl-t
, .
IN THE COURT OF COMMON PLEAS OF CAMERON COUNTY
Fifty - Ninth Judicial District
NO: 00- 2115
RECORDED: 03/30100
BOOK: PAGE: 0
KIND: DIV
DEBT: $
SURCHARGE:
PRO:
JCP FEE:
SAT DATE:
0.00
10.00
40.50
5.00
09/15/00
<PLAINTIFF> 1 POTTINGER
JEFFREY LEE
<DEFENDANT> 1 POTTINGER
MAUREEN GAY
MARCH 30, 2000 - Plaintiff's Complaint in Divorce filed by CHARLES E. PETRIE,
ESQ.
SAME DATE: Certified copy of Complaint with endorsement thereon to plead to
same, issued for service upon the defendant.
Verification and Affidavit of Non-Military Service filed.
SEPTEMBER 13, 2000 - Affidavit of Service, certified card, Plaintiff's and
Defendant's Affidavits of Consent, Plaintiff's and Defendant's Waivers
of Notice of Intention to Request Entry of a Divorce Decree and Praecipe to
Transmit the Records filed ($9.00 fee paid) .
SEPTEMBER 19, 2000 - Order of Court filed.
And Now, September 15, 2000, upon consideration of praecipe to transmi
record; and, upon review, the Court noting that the parties are requesting
approval and incorporation of a marriage settlement agreement in the divorce,
that the parties are the parents of minor children to which the marriage
settlement agreement does not speak; that this Court is not inclined to
approve a divorce between a non-residents of Cameron County where there are
children and no arrangements made with regard to the custody/support of said
children; It Is Therefore Ordered and Decreed that the request for entry of
divorce decree is denied and the proceedings transferred to the County of
Cumberland, where the action originally could have been initiated pursuant to
Pa.R.C.P.No. 1920.2(c).
Cost of transfer are imposed upon the plaintiff and shall be paid within 20
days from date of entry of this Order.
BY THE COURT: Isl Vernon D. Roof, President Judge
certified copy of Order sent to Atty. Petrie.
True and Correct Copy"
certified from the
Records of Cameron Co.
~n~Af~) .
~":;~
.
.,.~
,
.MiL -,
~- ~"n:.
'.'
JEFFREY LEE PO'ITINGER,
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS
CAMERON COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
rftrMBER: 2006 -;1/} b
MAUREEN GAY PO'ITINGER,
Defendant
IN DIVORCE
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 o~h~r ::' g
claim or relief requested in these papers by the plaintiff. You majldse'
I ;,'"
money or property or other rights important to you, including cus~odyor ::'
visitation of your children. i \ _, ~.~
When the groun~ for the divorce is indigniti~s or irretrie,:able I \;
breakdown of the marrIage, you may request marrIage coUnSelmgft l[$t
of marriage counselors is available in the Office of the Prothonotaliy, SJ ~
Cameron County Courthouse, Emporium, PA.
r._?S;
: ".- ~~1
.";
. -)
~- " -']
~--u
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF
PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR
ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY
OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF
YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE
YOU CAN GET LEGAL HELP.
DMr'J.
-DANIEL J. REED, PROTHONOTARY
CAMERON COUNTY COURTHOUSE
EMPORIUM, PA 15834
frue and Correct Copy (814) 486-3355
certified from the .
Records of eameron Co.
/1:~~
~~honotary
_i"""'~
""'-"-",ll
JEFFREY LEE POTIINGER,
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS
CAMERON COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NuIiBER: 2000 - .( /I ~
MAUREEN GAY POTIINGER,
Defendant
IN DIVORCE
COMPLAINT UNDER SECTION 330lfcl OF THE DIVORCE CODE
1. Plaintiff is JEFFREY LEE POTTINGER, who currently resides
at 282 Ridge Hill Road, Mechanicsburg, County of Cumberland,
Pennsylvania, since October, 1998.
r--.,:)
(~
c';)
~
r---..r-:'l
I I
I I
2. Defendant is MAUREEN GAY POTTINGER, who cur1e~tly U
resides at 282 Ridge Hill Road, Mechanicsburg, County of Cum~er 8.f1d, 'r',
1-;
C'
':~.J
n
(11
Xl
Pennsylvania, since October, 1998.
3.
Cl
Ul
Plaintiff has been a bona fide resident in the Commonwealth
'~.O
for at least six months immediately previous to the filing of this
Complaint.
4. The plaintiff and defendant were married on July 2, 1977,
in Columbus, County of Franklin, Ohio.
5. There have been no prior actions of divorce or for annulment
between the parties.
6. The marriage is irretrievably broken.
True and Correct Copy
certified from the .'
Records of Cameron Co.
@ <j!;;o/lil/v
;j( A1)
rothonotary ~
"<fI,'<te
7. 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.
8. Plaintiff is a member of the Armed Forces of the United
States of America.
9. After ninety (90) days have elapsed from the date of service
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 ti a[ divorc8
after ninety (90) days have elapsed from the date of service of ~hi~" f;
Ii, u
I i .'"_
Complaint, plaintiff respectfully requests the Court to enter a 1e9r;e of::
, .
divorce pursuant to Section 3301(c) of the Divorce Code. c,_.
f)
1.1 0
on
I verify that the statements made in this Complaint are true and <.'1
(') n;
-~ <--1
',-,
, -:.J
,"U
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.
DATE: ()f ;Jilt /av
;~~/ -
True and Correct Copy
certified from the
~ of ,,"","0" Co
~ czf~mtU?)
Prothonotary ~
~-4.t.~e"d~
CHARLES E. PETRIE
3528 Brisban Street
Harrisburg, PA 17111
(717) 561-1939
ATTORNEY FOR PLAINTIFF
.~~,~ ,
: '
,", ;. ;-, .- ~1"" "~~-;,.
-hi;"""-
. ,
JEFFREY LEE PO'ITINGER,
Plaintiff
IN THE COURT OF COMMON PLEAS
CAMERON COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
vs.
,
NlAIBER:
2000 -;/. )I.~
MAUREEN GAY PO'ITINGER,
Defendant
IN DIVORCE
AFFIDAVIT OF NON-MILITARY SERVICE
I, Plaintiff herein, do hereby depose and say that I am advised and
believe that the above named Defendant is not presently in the active
military service of the United States of America and I aver that the
Defendant is not a member of the Army of the United States, United
States Navy, the Marine Corps, or the Coast Guard, and is not an officer
of the Public Healt~ Service detailed by p~oper au~ority for du~ wl:th the~
Army or Navy; nor IS Defendant engaged In any mIlItary or Navy rrpts, :c:;:
covered by the Soldiers and Sailors Civil Relief Act of 1940 and 1'; : ;
designated therein as military service; nor has Defendant, to the b~st of ~~
my knowledge, enlisted in the military service covered by this ac . I .'.
Thi.s .Affidavit is made under the provisions of the Soldiers fa Id tJ ~,
Sailors ClVlI Relief Act of 1940. 1 S'J CJ
<.n
c: PJ
:'"]
:" )
'. ,
>;(3
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. /1 __' ...... ,~_
c.1f /Fj~Ll.. cl['CC .~ ~ .I?;fc~ -,.,
DATE EE POTIINGER
True and Correct Copy
certified from the
Records of Cameron Co.
enna. .
A-" --. "
-~, ~
. " ._ ,0. '~"
--,,.
. ,
JEFFREY LEE POTIINGER,
Plaintiff
IN THE COURT OF COMMON PLEAS
CAMERON COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
vs.
NUMBER: 2000-2115
MAUREEN GAY POTIINGER,
Defendant
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A complaint in divorce under Section 3301 (c) of the D!iv~rce C~
was filed on March 30,2000. ! i. L'
I i (~
I ,
2. The marriage of plaintiff and defendant is irretrievably broken i[nd
ninety days have elapsed from the date of filing and service of theictmPlai~_:.
3. I consent to the entry of a final decree of divorce after, s~rvlce qI;
notice of intention to request entry of the decree. I I u ("
.-
r....., ~'J
. )
" u
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 au rities.
DATE: 1 ~ tlO
SWORN TO AND SUB~ED
BEFORE ~THIS
DAY OF ~~. , 2000.
~~Q.J.,ki_
OTARY P BLIC
MY COMMISSION EXPIRES:
../1 "t-Icfi;
'::-iQj.J' Ol, ,
I rue and Correct Copy
certified from tht \
Records of Camon-'~-~.",'."TO ....It.
uu. ' "" DA.
9id . . -0'
~~) ~;:;;/-/Z)-
Prothonotary ~
:~-~
- .~" "iilI!Jf
, ,
JEFFREY LEE POTIINGER,
Plain tiff
IN THE COURT OF COMMON PLEAS
CAMERON COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
vs.
NUMBER: 2000-2115
MAUREEN GAY POTIINGER,
Defendant
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A complaint in divorce under Section 3301(c) of the Divorce Code
was filed on March 30,2000.
! I .' r:~
2. The marriage of plaintiff and defendant is irretrievably broken :ahd
ninety days have elapsed from the date of filing and service of the! C?mplaifiJ,
3. I consent to the entry of a final decree of divorce aft) s~rvjce df
notice of intention to request entry of the decree. 1 I "; ?":
I verify that the statements made in this affidavit are true ~4 cprre~i I
understand that false statements herein are made subject to the penafties-JOf
18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities.
(.-'f"l
~'-)
DATE:
?/2/00
SWORN TO AND SUBSCRIBED
BEFORE~ THIS 'B'+L.
DAY OF o~ ' 2000.
~~ &(X)\
.
~M!; "~
~~
,~
. ,
. ,
JEFFREY LEE POTIINGER,
Plaintiff
IN THE COURT OF COMMON PLEAS
CAMERON COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
vs.
NUMBER: 2000-2115
MAUREEN GAY POTIINGER,
Defendant
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301(cl OF THE DIVORCE CODE
1. I consent to the entry of a final decree of divorce withou~ npt~ce. f~
I ,- r ,)
2. I understand that I may lose rights concerning alimOny'ldi~ision of
property, lawyer's fees or expenses if I do not claim them before 1 d~vorce is-
, w
granted. I I ,- ?':
3. I understand that I will not be divorced un~l a divorce dedre~j is ~..~
entered by the Court and that a copy of the decree WIll be sent tal ;Je ~ '0'::;
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. Section 4904 relating to unsworn falsification to authorities.
DATE:
65rtlO
True and Correct Copy
certified from the
Records of Cameron Co.
~)y3-~
Prothonotary ~
""--' .
~ ,.,.'-..;",,;,
.~--., ....n
,
~.. l.J
~~
i _^
- - ~ - v ~,
~"'-'
, '.
4 \, ',-
JEFFREY LEE POTIINGER,
Plain tiff
IN THE COURT OF COMMON PLEAS
CAMERON COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
vs.
NUMBER: 2000-2115
MAUREEN GAY POTIINGER,
Defendant
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301(c) OF THE DIVORCE CODE
1. I consent to the entry of a final decree of divorce withou1 nptic,e. r:c.~
'. f' ~
i! '-'
2. I understand that I may lose rights concerning alimonY'llditrision o~
property, lawyer's fees or expenses if I do not claim them before a: d~'vorce is'
granted. I ; .~" (,,)
f I "":'""3
3. I understand that I will not be divorced unt~l a divorce 4ectee; is ;~
entered by the Court and that a copy of the decree Will be sent t9 ~e [" c~
immediately after it is filed with the prothonotary. ;.u ~
~-)r~
, ,
-,
;->---'LJ
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.
DATE, ~ (fJ
~--~
MAUREEN GAY POTII
DEFENDANT
True and Correct Copy
certified from the
Records of Cameron cO.
~
~AJ:zf~~
- - . honotary ~
-
~, " ",",..- ~ -:-";''"--l~'~-o-
< '.
, (,) ,.
JEFFREY LEE POTIINGER,
Plaintiff
IN THE COURT OF COMMON PLEAS
CAMERON COUNTY, PENNSYLVANIA
CMLACTION - LAW
VS.
NUMBER: 2000-2115
MAUREEN GAY POTIINGER,
Defendant
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
TO THE PROTHONOTARY:
Transmit the record, together with the following information, to the court
for entry of an appropriate divorce decree:
...,
i I -.-.' =
,--:-
. 1. Grou~d for di:vorce:. Irretrieva?le breakdown under ~3301(c) ~tithe '-,
Divorce Code. (Strike out mapphcable section). I : '. ..,j
, .
i .
2. Date and manner of service of complaint: April 5, 2000, by
J' ~
certified mail. ' i
i 11' C3
I . "
i Sj Ul
-i--
Co.)
3.
Complete either paragraph (a) or (b);
(a)(l) Date of execution of the affidavit of consent required by
3301(c) of the Divorce Code: by plaintiff: September 8,2000; by defendant:
September 8, 2000.
(a)(2) Date of execution of the Waiver of Notice of Intention
required by ~3301(c) of the Divorce Code: by plaintiff: September 8,2000; by
defendant: September 8, 2000.
(b)(l) Date of execution of the affidavit required by ~3301(d) of the
Divorce Code:
(b)(2) Date of filing and service of the plaintiff's affidavit upon the
respondent: Filed: ; Served:
4. Related Claims Pending: No claims raised.
5. Complete either (a) or (b):
True and Correct ~~ate and manner of service of the notice of intention to file
certif~tYi9.'i9J< tt19 traniimit record, a copy of which is attached:
Records of Cameron (.;0.
a.
-'-'--"._,"'-
,-..~
~ . -j
. ,
,
,
.--J
,-;0.
'i
\I:i&'"
- ,
. ... ,
.. t, ,..
(b) Date plaintiffs Waiver of Notice in 9330 1 (c) Divorce was filed
with the prothonotary: September 14,2000.
(c) Date defendant's Waiver of Notice in 93301(c) Divorce was
filed with the prothonotary: September 14, 2000.
t"~ &. ~7t;-
CHARLES E. PETRIE
ATTORNEY FOR PLAINTIFF
! .. ....~
~~ ('~', t-:J
r.-~
! 4.:.':'>
i (,-')
I . .
I -'~J
,
I <...>
, I
I , :--""
, I ,
,
I ,~1 r:':::J ,
I -~ 01 '. _'_J
.;..- r-'u
True and Correct Copy
Certified from the .
Records of Cameron Co.
>'.-_..
'"
"
. ,,"---_.
'""
.'
~ .. ,
t,' l.' ""
JEFFREY LEE POTTINGER,
Plain tiff
IN THE COURT OF COMMON PLEAS
CAMERON COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
vs.
NUMBER: 2000-2115
MAUREEN GAY POTTINGER,
Defendant
IN DIVORCE
AFFIDAVIT OF SERVICE
CHARLES E. PETRIE, Esquire, being duly sworn according to law,
deposes and states that he served a true and correct copy of the NqTlpE,TO~
DEFEND AND CLAIM RIGHTS, COMPLAINT UNDER SECTION 330i(c), and ~3
MILITARY AFFIDAVIT, upon Maureen Gav Pottinger. defendant, in th~ abovd~~
captioned matter, by mailing a true and correct copy of same by U.S. fertifid
Mail, return receipt requested, Article Number Z 196 837 586, postage ~rt1Pa).d, 6rl
April 3. 2000, to the following address: i ~~
1"- 0
Name: Maureen Gay Pottinger I s en
~
~.fiJ
~: . -"4
,
.,
;->'0
Address: 282 Ridge Hill Road, Mechanicsburg PA 17055
Defendant personally received said documents on April 5. 2000, as
evidenced by.her signature on the certified mail return receipt card which is
attached hereto and marked Exhibit "A".
I verify that the statements in the foregoing Mfidavit 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.
T
.~ .. ~.r: '.-,." -,-...~.
SENDER: COMPLETE THIS SECTION
. Complbte Items 1, 2, end 3. Also complete
item 4 if Restricted Delivery is desired.
. Print your name and address on the reverse
so that we can return the card to you.
. Attach this card to the back of the mailpiece.
or on the front if space permits.
1. Article Addressed to:
. .
>>-, " ~
&.~
. PETRIE
~OR PLAINTIFF
D, Is delivery address d'
If YES, enter delivery a d
o Agent
o Addressee
m Item 11 Cl Yes
below: Cl No
x
, Service Type
pc Certified Mall 0 Express Mail
[J Registered Cl Return Receipt for Merc
o Insured Mall 0 C.O.D.
4, Restricted Delivery? (Extra Fee) J( Yes
True llfld CorreGt Copy
oortlfied from the
~ gf CemfKOn Co.
2. Article Number (Copy ftom service label)
Z 196 837 586
PS Form 3811 , July 1999 Domestic Return Receipt
102595-99-M-1789
~~"'~'ill\'~f'iiil~~~~.~"'~.
iiiIiIiiiIrf""''';," d,= ~I..;
. '.,,',
1 .__ .
"@
~5
(); t+:-
W
~
-
~
~
~
8
~
~
-,
~
,,"'~.
-~<
0 0 0
c 0
<'" -"
~fo U')
fi1:n_ ~1
~:;; "-::J ;J?
''0 '-::J!n
0,-4 -("I c:r
(--1,[
r:: CJ _.'~~j(J
~8 -0 ~:~i
:3.:
r.-
'''? .. '~,.J
~:," -."
::;;! w "'"
.z:- :D
-<
I!:'
,<"""~"~~",,,..'-
'1
=~"- -~.
~;._.~ ~-l'"
JEFFREY LEE PO'ITINGER,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
V8.
MAUREEN GAY PO'ITINGER,
Defendant
NUMBER:M-'.S,,, CIVIL TERM
IN DIVORCE
SOCIAL SECURITY INFORMATION SHEET
PURSUANT TO 23 Pa.C.S.A. SECTION 4304.1 (a)(3) ALL DIVORCES
MUST INCLUDE THE PARTIES SOCIAL SECURITY NUMBER
PLEASE FILL IN THE APPROPRIATE INFORMATION AND RETURN TO
THE PROTHONOTARY'S OFFICE
DATE: September 27. 2000
DOCKET NUMBER: l'ltl-ld';,~ CIVIL TERM
PLAINTIFF/PETITIONER SS# Z~\. 5l,,-1~1l
NAME: JEFFREY LEE POTTINGER
DEFENDANT/RESPONDENT SS# ZCoCl-ul.\-fiIO<.o
NAME: MAUREEN GAY POTTINGER