The URL can be used to link to this page

Home My WebLink About00-07575 V': ~ /~" i'~ ~ ~ ~ ~..,. b ~ j ~ it,; i:i ~ ~ I~"' - ~~;::::_" :::....,: ":.::..: -:'*::.;., .:- ..~;:>:C~;,. )3E( -:'.>>::< ''':<+::..;' )::.::;,~: ""::+::':._ .:..3t~.,: "-'::.;"" ,::.a-::~::' '.~:+::~,.' :"'::.::." - .::+::...: '.::+;'" "'::+::'" ~'S J .,.", ~ ~.'! "~,,, W ~.~ ~.s ~ ;"; t;, * i'~ ~ ~ ~.'! ~.~ '1 ~ 'l.~ ~ ",,' ~ ~.'! ~A ~ Il'.~ ~ ~.~ ~.~ ~ ':'.' ~~ a ~~ f! ,,;, ~.~ :h' I r'. ~ ~.~ ~ i '" ;~~ ~ ~~ ~ IL ~- 'l.. , ,.l- I - .~ ~ "' "".f., ~. 0.: .,0' ", ;'~~,"..-:-' '~. .~ ::~.;;;;- ~::<<.,,)::c~.: >:::C:{):+::~::::';'::<<<':.;.:,::( :~~::.:);~)::.::~;::::<C:~:::~~:+::~~;:::::.:cO;:: }:+::( -,~>:.::;,:c.;:::-!:+::(.,.::c:.;::,:~:+::;<::~::.~::~~::c<,;,;~;*~~,::~::C:~i':"~:C(':;!::C:~~:XC;';::,'~3&~:::~~~~:~:;!1 ~,...' ~ ~ ~ ",.< ;".< i x ~.'~ IN THE COURT OF COMMON PLEAS ~ ~ ~.~.;. N ~ ~.~ ~ i ~.~ ~.~ ~ ~ ;..~ ~ ~ ~~ ~ ~.'! OF CUMBERLAND COUNTY STATE OF PENNA. ~~ c:hr~~s~L.(G.u~i~g:atll1E>](~i,~~uuuuu~u.. I II N O. uo.Ou~"uu7..5.7.5 .dy.i.L P l~aJJ1t.i1':fuuuu__ ff? !'.~ N ~ ~ ~.! Versus .. ~ ~ ~ ~ ~ ~.;r()lln~ ~ ~ ~ ~, ~ ~ ~ l1J g~a. t\llSk: i ~ 'u ~ ~u .u~Def~endant~~u______ ",,' ~ li'.~ ',,' ~ '-' ~' ~... DECREE IN ,. D I V 0 R C E .:r1:41 /,#1 . AND NOW, . . . . .l':"~. .~~. . . . " 19 .2EJO'c' it is ordered and decreed that .. .Christi. Ill... .MigatuJ.s.ki. . . . . . . . . . . . . . . . . . . . " plaintiff, and. . . .~C?!1!l. .r;:. ~~g~~:u.1,~~~.. . . .. .. " . . .. . . . . . . . . . . .. .. .. ", defendant, are divorced from the bonds of matrimony. i ~.~ ~ ~ ~? 8 ~ ~ ~.<; ~ "-.'" W ~.~ ;;,i ts * 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; ~ ~ v ~ ;.~ ~ ~ '.' ~ . . .'rp.~. .M:,Hr.i.<Ige. .Settl.ement. .Agre.emen.t .betw.een. :the. par-ties .shaJ..1 ,be ,.~ . . )~~.o.9?9!.a.t:~?~l!t. .s.1'~'\:P. .1'\Qt. JlI.EP:g~. .V{ . .fJIl9;L. .D.eCr.e.El . in. Di. vorce. ~ J. ~ ~.~ ~ ... ~ ~.~ ~ '.~ Attest: ';1~~~4:-uu --~~ ,', * ~ ... -.......... ---.._---- Prothonotary ~ v ,'~ ~~ ::,:+;,:::>::+;.::>::.::,-,>:+::.-::>::+::...:::;.::+::.' --"::+;'" ,:.::"::<',-'::.::'. :'.::.::~:' !lJlli$Iiililiili"~ ~'~"""'" "'~i:lmH~";~-~" -"",~~.---" '-'i--,-,--~.';';,'c I' -.~!) '_1'- i ;1 , I; fl ;;: i II .1 ,~ II " 'I ~ H, , ,I i -,J 1 U 'I i I i I I I :1 I 'h t: ~-ztn~ eo" '(5' ~fr $- ~~ -/"') ~r?' 'c<'C'" ~ '.. ~ ," '.""~ Jr --." " I ~ J! .,lim'IlIJ~ .... CHRISTI G. MIGATULSKl, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 00-7575 CIVIL JOHN C. MIGATULSKl, Defendant : CIVIL ACTION - LAW : IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the Court for entry of a Divorce Decree: I. Ground for divorce: irretrievable breakdown under Section (x) 3301 (c) () 3301 (d) ofthe Divorce Code. (Check applicable section.) 2. Date and manner of service of the Complaint: November 8, 2000, by Certified Mail. 3. Complete either (a) or (b). (a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: January 3, 2002, by Plaintiff; January 22, 2002, by 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 and Property Settlement Agreement between the parties shall be incorporated, but shall not merge with the final Decree in Divorce. """"'-"-h"'""""" ..... ~.1 JI - u L - ~ llllli ,. . 5. Complete either (a) or (b). (a) Date and manner of service of Notice ofIntention to File Praecipe to Transmit Record, a copy of which is attached: (b) Date Plaintiffs Waiver of Notice in ~3301(c) Divorce was filed with the Prothonotary: January 10,2002. Date Defendant's Waiver of Notice in g3301(c) Divorce was filed with the Prothonotary: January 22, 2002. 6. Social Security Numbers: (a) Plaintiff: 170-60-6247 (b) Defendant: 184-54-6614 ~-:-h //. .~/~ ~----c.._ ,/ .// ~ Attorney for Plaintiff . -~-' "'1Iilii. ':Usii ~~~1-;':-;e,t"it,,*~l!'j\iH-ii..~'m~M1':41~s*~~;t',;#~'""!,~,,t~i,r*,""'..,-,~,~,', "-.% "1~';<""'4',k,~,,,4i';'jj;~i~-!E;it,g~mt~ - t.il.mr iII~t!Uit~ -1'!~~lIjlmJ!!!'!IiL"J - C) ~<~ <~~ 2~(' fB> ' r~ (~~ E_~ '.Fe:- 2: -l -< c:) r,~; ~'"il .'1 '-.'') !"') l~ :~q "_~ J ::'~J :Jl ()1 . ,. A Ii I'.:.' j: if I ~ ~ , ii, I -<~,,~.~ ;-: I ~~~ . : DIVORCE AND PROPERTY SETTLEMENT AGREEMENT MADE THIsJ.~n,,( DAY OF]"" OJ) ~' 200~ BY AND BETWEEN CHRISTI G. MIGATULSKl, hereinafter referred to as "WIFE", AND JOHN C. MIGATULSKI, hereinafter referred to as "HUSBAND". WITNESSETH: WHEREAS, the parties are Husband and Wife, having been married on August 27, 1994; and WHEREAS, unhappy differences, and disputes have arisen as a result of which the parties have separated and ilfltend to continue to remain separate and apart; and WHEREAS, Wife has instituted an action in divorce and there are outstanding claims for equitable distribution of marital property, and WHEREAS, the parties desire to settle all matters currently pending between them; and WHEREAS, the parties hereto respectively acknowledge that before signing this Agreement they fully lUlderstand their rights and obligations, and have carefully read and lUlderstand the terms of this Agreement, and have freely consented to this Agreement, believing it to be fair, just and reasonable; and WHEREAS, the parties have consulted with their attorneys, or with full knowledge of their right to consult with an attorney, have decided not to consult with an attorney. NOW, THEREFORE, in consideration of the foregoing recitals hereinafter incorporated into and made a part of this Agreement, and for the mutual exchange of ~ .a 'J : J ~ -'.......~M6, " covenants herein contained and induced and intending to be legally bound hereby, the parties hereby agree as follows: 1. SEP ARA TION. Husband and Wife may live separate and apart from each other, each to be free from constraint or control by the other, as fully as if he or she were unmarried. Neither shall disturb not interfere in any way with the other or with any persons who are associating with the other. 2. REAL PROPERTY. Husband and Wife own jointly a tract of ground with a house situated thereon in Franklin Township, York County, Pennsylvania. It is agreed by Husband and Wife that Wife will convey all of her right, title and interest in and to the property to Husband. Wife will execute a quit-claim deed conveying said interest in the property to Husband. Husband agrees that he will be responsible for the payments associated with the house, including, but not limited to, mortgage payments, home equity loan, tax payments and insurance payments. It is further agreed by the parties that Husband will refinance the outstanding mortgage and home equity loan into his name only. Said refinancing to occur within one year of execution of this agreement. It is further agreed that Wife will execute a Quit Claim Deed to be held in escrow to be tendered at the time Husband is able to refinance the outstanding mortgage and home equity loan into his name. 3. ALIMONY. Husband and Wife agree that each waives any claim they have against the other for alimony, support, maintenance, and/or alimony pendente lite. Both parties acknowledge that they have sufficient sources of income to meet their present and future needs. 4. CUSTODY. It is agreed by the parties that they shall have joint physical and legal custody of their son, Christopher Migatulski. However, nothing shall preclude Wife from claiming Christopher as an income deduction for each year unless and until the parties agree otherwise or the present custody situation should change by agreement of the parties or by the tenus of a Court Order. 5. LIFE INSURANCE. Both parties agree that any life insurance policies that are in effect as of the date of this Agreement will be changed to reflect that the beneficiary of said policy will be the parties' minor child, Christopher Wade '""~ ~~ -4 - j, j~; = ~-vc,; 'J I, .' Migatulski. Both parties agree that they will provide at the request of either party written documentation indicating that the beneficiary has been changed to reflect that of their son. 6. AUTOMOBILES. It is agreed by Husband and Wife that Husband shall receive the 1995 Chevrolet Blazer that is currently in his possession. Husband will be responsible for all payments associated with the ownership of said vehicle, including, but not limited to, car payments, and insurance payments. Wife shall receive the Chevrolet Malibu that is currently in her possession. Wife shall be responsible for any loan, obligations or insurance payments that are due on the vehicle. Both parties agree that they will execute any documents nece.ssary in order to effectuate the obligations that are set forth herein. 7. LOANS AND OBLIGATIONS. Husband and Wife agree that each shall be responsible for all loans and obligations which they have incurred since the date of separation. Additionally, it is agreed by the parties that Husband shall be responsible for the VISA card that is titled in his name only and Wife shall be responsible for all credit cards that she incurred since the date of the marriage. Wife agrees that she will provide to Husband a listing of those credit cards so that confirmation can be made that those accounts are solely in Wife's name. 8. PERSONAL PROPERTY. It is agreed by Husband and Wife that the parties have amicably divided the personal property acquired during the course of the marriage. To that end, the parties shall retain the personal property that is in their possession. 9. ATTORNEY'S FEES, COSTS AND EXPENSES. Each of the parties shall be responsible for tlleir own attorney's fees, costs and expenses. 10. PENSION, PROFIT SHARING AND RETIREMENT PLANS. Each of the parties waives any claims they have against the other party's pension, profit sharing or retirement plans and/or deferred compensation plans. The parties agree that they will execute any and all documents necessary in order to effectuate this provision of the Agreement. 11. MUTUAL RELEASE. Wife and Husband each do hereby mutually remise, release, quitclaim, and forever discharge the other and the estate of such other, for all time to come, and for all purposes whatsoever, of and from any and all I~" 1,1 Jb ~ ~~~- , r .' rights, titles and interests, or claims in or against the property (including income and gain frOllll property hereafter accruing) of the other or against the estate of such other, of whatever natme and wheresoever situate, which she or he now has or at any time hereafter may have against such other, the estate of such other, or any part thereof, whether arising out of any former acts, contracts, engagements, or liabilities of such other or widow's or widower's rights, family exemption, or similar allowance, or under the intestate laws, or the right to take against the spouse's will; or the right to treat a lifetime conveyance by the other as testamentary, or all other rights of a surviving spouse to participate in a deceased spouse's estate, whether arising under the laws of ( a) Pennsylvania, (b) any State, Commonwealth or territory of the United States, or (c) any other country. It is the intention of the. Wife and Husband to give to each other by the execution of the Agreement a full, complete and general release with respect to any and all property of any kind or natme, real, personal, or mixed, which the other now owns or may hereafter acquire, except and only except all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any thereof; subject, however, to the implementation and satisfaction of the conditions precedent as set forth herein. 12. OTHER DOCUMENT A TION. Wife and Husband covenant and agree that they will execute any and all written instruments, assignments, releases, satisfactions, deeds, notes, or such other writings as may be necessary or desirable for the proper effectuation of this Agreement, and as their respective counsel shall mutually agree should be so executed in order to carry out fully and effectively the terms of this Agreement. 13. SUCCESSORS' RIGHTS AND LIABILITIES. This Agreement shall, except as otherwise provided herein, be binding upon mid inme to the benefit of the parties hereto, their respective heirs, executors, administrators, successors or aSSIgns. 14. ENTIRE AGREEMENT. Wife and Husband do hereby covenant and warrant that this Agreement contains all of the representations, promises, and agreements made by either of them to the other for the purposes set forth in the preamble hereinabove; that there are no claims, promises or representations not herein contained, either oral or written, which shall or may be charged or enforced or enforceable unless reduced to writing and signed by both of the parties hereto; and the waiver of any term, condition, clause, or provision of this Agreement shall ~ ,1:1 : I ~ ~ ... in no way be deemed to be considered a waiver of any other tenu conditions , , clauses, or provisions of this Agreement. 15. SEPARABILITY. If any tenu, condition, clause, or provision of this Agreement shall be detenuined or declared to be void or invalid in law or otherwise , then only that tenu, condition, clause, or provision shall be stricken from this Agreement and in all other respects this Agreement shall be valid and continue in full force, effect, and operation. 16. VOLUNTARY EXECUTION. Husband and Wife hereto acknowledge that each ooderstandsthe respective rig.qts and obligations. herein and they have had the ability to, and do understand the tenus hereof with full knowledge and infonuation as to their legal rights, liabilities. and effects; they are satisfied the Agreement is fair, just and reasonable; they desire and intend to proceed in accordance with the tenus hereof; they consent hereto of their own volition and intend to be penuanently and legally bound hereby. 17. ENFORCRJ\1ENT PROVISIONS. Husband and Wife agree that if it becomes necessary for either party to seek Court action to enforce any of the tenus of this Agreement, the refusing party shall be responsible for any and all reasonable attorneys' fees and costs necessary to enforce this Agreement for both parties. 18. AMENDJ\1ENT TO THIS AGREEJ\1ENT. The tenus and conditions of this Agreement shall not be subject to amendment except by written agreement of the parties. This Agreement represents the complete and fmal agreement of the parties and any change in circumstances of the parties shall not give rise to a right in either party to amend the tenus and conditions of this Agreement. 19. INCORPORATION AND J\1ERGER WITH DECREE OF DIVORCE. It is agreed by the parties that this Agreement shall be incorporated with the Court's Decree in Divorce and shall become a part of that Decree settling all claims of Husband and Wife against each other arising out of said divorce, said merger to allow this Agreement to be superseded as a contract and take on the attributes of a court order for purposes of modification and enforcement. 20. NO-FAUl,T DIVORCE. It is agreed by Husband and Wife that they will execute all papers that are necessary so that the Court of Common Pleas of Cumberland County, Pennsylvania can enter a no-fault Divorce Decree pursuant to ,,~W.. - .I~I l ~" --~~j; . . Section 3301(c) of the Divorce Code. Both parties agree that they will execute the Affidavits of Consent and Waivers of Notice forms within 90 days after the service of the Divorce Complaint. 21. LUMP SUM PA YMRNT. It is agreed by the parties that Husband shall pay to Wife a lmnp smn cash payment of$7,000.00. Said payment due within thirty (30) days of the execution of this agreement. 22. BANKRUPTCY. It is acknowledged and agreed by the parties that the payments called for in this Agreement are not intended to be a debt which is affected by discharge in banYJuptcy. The parties further specifically intend that Husband's and Wife's obligations under the terms of this Agreement shall not be subject to discharge in bankruptcy because such payments of debts and other liabilities are necessary for Husband and Wife to meet his or her respective financial obligations and to support and maintain his and her respective standard of living. Husband and Wife represent that there are no bankruptcy proceedings presently pending in which he or she is involved. Husband and Wife expressly agree not to file a bankruptcy action prior to the completion of his or her obligations pUIsuant to this paragraph. These debts are not intended to be nor shall they be discharged in a bankruptcy action filed by or on behalf of either Husband or Wife. Furthermore in the event that, at any time prior to Husband or Wife's fulfillment of all of the financial obligations set forth in this Agreement, either he or she declares personal or professional bankruptcy, this Agreement shall constitute conclusive evidence of the parties' intent that the obligations of this Agreement are in the nature of maintenance and are not dischargeable under current Bankruptcy Law or under any amendment thereto. Further, if Husband or Wife institutes any action in bankruptcy, and the U.S. Bankruptcy COlUt, contrary to the terms of this Agreement, declares that any or all of the said payments required hereunder are dischargeable, then in that event the affected portions of the Agreement shall become null and void. Husband or Wife shall have the absolute right to prosecute his or her economic claims in the divorce action as they relate to the portions of the Agreement that are null and void. ~2<i._ _ I-i _I. - ~~ , .. " IN WITNESS WHEREOF, the parties hereto have set their hands and seals the day and date first above written. (SEAL) (SEAL) ~_~~;d_tJjtiM~~~~ " ~1!I&9&~~~@i-ffilg~","~-Rf~~~" IIIlr .i"illlmtiiiJn ,,, -,i~d' -~.J _t.- . - ... 0 C) (~) C f~' ~ ---I -n ..." __,I CU ;~.j'l Q] Li ! :::1:) L 7~ f'.) en (=, _c ~ , ."':'.J :.-:::: '- :,~~.: () -:.::.:" ~d F3 IT1 F ~~: " j:-O: ::~ - . :':-1) Ul -< . F.~"'~"~" j~ JI 1- - -~.. bd'~~_ CHRISTI G. MIGATULSKI, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA o-v - 7S7,r- /1 d" /J : NO. ::] ~ JOHN C. MIGATULSKI, Defendant : CIVIL ACTION - LAW : IN DIVORCE/CUSTODY 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 in Divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for divorce is indignities or irretrievable breakdoWn of marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, 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 A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO ANY OF THEM. YOU SHOULD TAKE TIllS 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, P A 17013 Telephone: (717) 249-3166 r ~11i__c=..~ ~. [~.M,,' CHRISTI G. MIGATULSKI, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ; NO. thJ/ 7)15 ~ -rJU- JOHN C. MIGATULSKI, Defendant CIVIL ACTION - LAW : IN DIVORCE/CUSTODY COMPLAINT IN DIVORCE 1. The Plaintiff is Christi G. Migatulski, an adult individual currently residing at 14 South Point Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. The Defendant is Jo1m C. Migatulski, an adult individual residing at 145 Locust Grove Road, Dillsburg, York County, Pennsylvania. 17019. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania, for a period in excess of six (6) months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on August 25, 1994, in North Carolina. 5. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. ~~~ ,'L-" - ~ . ~- " II 1-- ~~L' 6. This action is not collusive. 7. Plaintiff and Defendant separated on or about July 1,2000. 8. The causes of action and sections of the Divorce Code under which Plaintiff is proceeding are: A. Section 3301(c) - The marriage of the parties is irretrievably broken. B. Section 3301(d) - The marriage of the parties is irretrievably broken. The parties separated on or about July 1,2000. 9. Plaintiff and Defendant have one child under the age of eighteen, namely Christopher Migatulski, born January 7, 1997. 10. Plaintiff has been advised of the availability of marriage counseling and understands that she may request that her spouse and she participate in counseling. II. Plaintiff does not request that the Court require that her spouse and she participate in counseling prior to a divorce decree being handed down by this Court. Wherefore, Plaintiff respectfully requests this Honorable Court enter a final decree in divorce. .- ~~ , ~ IL", J *1 JiItl' t,.;,- COUNT I CHILD CUSTODY 12. Paragraphs one through eleven are incorporated herein by reference. 13. The subject child is Christopher Migatulski, born January 7, 1997. 14. The relationship of the Plaintiff to the subject minor child is that of natural mother. 15. The relationship of the Defendant to the subject minor child is that of natural father. 16. The minor child has resided at the following addresses, in the custody ofthe following individuals: 17. There have been no prior actions for custody of the subject minor child in this or any other jurisdiction. 18. The Plaintiff is not aware of the existence of any other individuals who have any type of claim whatsoever regarding the custody of the subject minor child. ~, :I. ~ '; l-- ~~ 19. The Plaintiff believes and therefore avers that she is much better able to meet the needs of the subject minor child than the Defendant. 20. The Plaintiff believes and therefore avers that it is in the best interest of the subject minor child that he be placed in her legal and physical custody. WHEREFORE, Plaintiff requests this Honorable Court award hirn/her custody of the subject minor child. COUNT II EOUITABLE DISTRIBUTION 21. Paragraphs one through twenty are incorporated herein by reference. 22. During their marriage, Plaintiff and Defendant have acquired various items of marital property, both real and personal, which are subject to equitable distribution under Sections 3501 et.seq. of the Divorce Code of 1980. .~.~, ",\>'- ....Ii .1..-1_.-- -.~...u lm..~.!" WHEREFORE, Plaintiff respectfully requests this Honorable Court equitably distribute all marital property, both real and personal, owned by the parties. Date: JtJ/~) I". f Mark T. Silliker, Esquire 5922 Linglestown Road Harrisburg, PA 17112 (717) 671-1500 LD. No. 33671 Attorney for Plaintiff - - Ji L I~ ~, AFFIDA VIT I,CJJnJ/.i t$, ~tJl..Jsh: hereby certify that the aforegoing is true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. 4909 relating to unsworn falsifications to authorities. Dated: /0/11/00 (l~;IJ?uja/'~~ ' ". .,' -~. '!j ~"<~r ___I ~, L ~ .' .1..._1 '.-""~~,;.;= CHRISTI G. MIGATULSKI, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 00-7575 CIVIL JOHN C. MIGATULSKI, Defendant CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE The undersigned, Renee Dreisbach, hereby certifies that a copy of a Complaint in Divorce was served upon John C. Migatulski on November 8, 2000, by Certified Mail, return receipt requested, addressed as follows: John Migatulski 145 Locust Grove Road Dillsburg, PA 17019 I hereby certify that the afore going is true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. g4904 relating to unsworn falsification to authorities. ~ Date: rel~ruar; 1f).:2OD;;l.., . VJ)i&S!naIL Renee Dreisbach c;; SENDER: ~ :!' . Complete items 1 and/or 2 for additional services. (I) . Complete items 3, 4a, and 4b. . G) . Print your name and address on the reverse of this form so that we can return this ~ card to you, !il . Attach this form to the front of the mailpiece, or on the back if space does not G) permit. _ .. . Write "Return Receipt Requested" on the mailpiece below the article number. .! . The Return Receipt will show to whom the article was delivered and the date .. delivered. c " ." ~ is. E " u I also wish to receive the ,following services (for an extra tee): 3. Article Addressed to~ JOhn (Y]; qo.1ubki . . /1/5 Loc.-&6+ GroIJePd. D'd!0burg I prt nor? oj dress .~ estricted Delivery ~ Consult postmaster for fee: i. 4a. Article Number . l 760 /) 0 lDoo 0 OJ g 33& 7 110 I. c ~ ~ ... 0: 01 c 'in ~ ~ .E 4b. Service Type o Registered o Express Mail o Return Receipt for Merchandise 7. Date of Delivery r6 8. Addressee's Address (Only if requested and fee is paid) i ~ Certified o Insured o COD ~ " >- ... c .. .c .... ~ ~ " >- .!Il 102595-,a.B'()22' Domestic Fleturn Receipt ;_k~:'cib J~~lN~.L]'ltl~i'lfjjY'.]u~J>ffl'b(;t;i,m;i>ll"iliso!!-~:~@rhl?~#!l:M;~:~rjif;_.r~,>~;j- --;.:_;. --!~1l~ 'j"nbl".- ", .." ,..,. '- .. '~', ''''~~'"i n c:> C tv ?: -,., 'tJ en ~ , ; m ~I -~:-J Z 2: l~:' N (;') c-' .< ~ c v )-::::": C~; ~~:J'-- ~;;'" ,-, ""',..... >-..:' ;-..;;. '~.-' 2~ U! ~;;_' =< ::c., en -< ,., :rr--"'.' ,- _1==. ~ l..-I_ ,~ ~~:lI!U!;1t . CHRISTI G. MIGATULSKI, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA v. : No. 00-7575 Civil JOHN C. MIGATULSKI, Defendant : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on October 26, 2000. 2. The marriage of the Plaintiff and Defendant is irretrievably broken, and ninety days have elapsed since the date of filing and service of 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. 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. S 4904, relating to unsworn falsifications to authorities. Date: I/S/D.A , , @Jnu~ / Christi G. Mi atulski ~~:,~",~L~f(-:f:!-,r;J'ij~;,~~"'1im!il:~~~~t~~~:_-~iJl~_!l-'![j:~,.;..,~,,.,,,. 1ii !i!f~'<':,H:!i1-_MtWtfi..i ., .., ,-; ""'< '.' ,,-. "-]u( d '1IiIIIiil" 0 ,-, ~~ {~'2 c~ f'-,.) "'t)$: L. r<--c " QJi'h :,~ L-~' :i:: , zf i-- ,,' (l) ~V CJ ,~~ ;::S;'C kC v p zQ --"" ~~2 ZS ~- j:; CJ f:-? C ~3rT, Z :.:-.{ :;t Ul S "...I -< --~~ - .1 II -.L...I--- , l_~~~~~f, , > . CHRISTI G. MIGATULSKI, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 00-7575 Civil JOHN C. MIGATULSKI, Defendant : CIVIL ACTION - LAW : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 (c) OF THE DIVORCE CODE I. 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! 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. Section 4904 relating to unsworn falsification to authorities. Date: / /J/ D^ / I ~~ Christi G. Migatulski r.~h'1\~",,-,jj~~t~,,~ti\<'l' """'~?~_'/'--f'S"""j,,,qr.i1'8~iflfill..~~~l1i~~4i;~~~~"''''-'"' '11~~ ""'~tr'im1'_-~Uilii:~iilliili!lWillliMti_ii , ,~~-,- "-~ ~.."' ,-,,"-'=,"~'" ,,'''-' """-,',",,, "-,- .?m~_ ~ ,~ '-~ ,-' .,--." -J-", -".~'l ~--"'''''''~-'';'''';'~''-1t:1 (J C r'"'. C :"-.) ,j ..G~-;i ""I '- nlri:~ ~,::.<.., Z-j~: --""'" Zc" Sf:!:? 0 - ~ !;:=C ~ :t;,-., ~, ~t:; .... Pc f\) .,,--- C) Z :.J') ~ =< S ..... -< ;;'" ,~"~C~ j: i' ~~ .~ , ," .,. j""'Hid , . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY . , PENNSYL VANIA CHRISTI G. MIGATULSKI, PLAINTIFF No. 00-7575 vs. CIVIL ACTION LAW IN DIVORCE/CUSTODY JOHN C. MIGATULSKl, DEFENDANT AFFIDA VIT OF CONSENT 1. A Complaint in Divorce under Section 330 1 (c) of the Divorce Code was filed on October 26,2000. 2. The marriage of the 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 [mal decree of divorce after service of notice of intention to request entry of the decree. 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 fa sification to authorities. ULr- Date: /-;JJ}-O-'; ~'@t-m~fM~~Fj;~i1~!;j",~~~~,.g:li&.*'ri'~'W"'h~trl!'!,j'Ullih""'o"'I~:"";4!i~fu.<i'0i;iW*""tMl~~ """{'~'""'iJl~'M,~~~I'~--"'=" ~ ~',6lI >., -"._"-,,>~--> : . 0 0 (j C r....) ~n g -." -U CD ;T1 m L~ CO ~~ " Z -"-' n ~IS, .. ,-:;' f'0 -<:/., ,~ r:::C} .....,-, ::n :p; <="'7(") ~1 .L...C~ - :PC ~1 ~i 2'::: j......,) :::;:;} =2. CA." ~ ',,,","_m,<.. "~~,, ..~_~..~ ,_.~, ~_ ."ft, , ''-''''''''-', ".. , _ < "', _-,-., '''''"'_',~ d,"~ ,. ". 4 ___!~ " .-~ ,- " <_ ,_, . ~_ '. '_'~M " ~ ",'". ~,~ 'w'md-~ , J" _rll i;L, J ~ =1," ~ " ;;.'"' ",',>",- , . " IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY , PENNSYL VANIA CHRISTI G. MIGATULSKI, PLAINTIFF No. 00-7575 VS. CIVIL ACTION LAW IN DIVORCE/CUSTODY JOHN C. MIGATULSKI, DEFENDA...lI,)T 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 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. Section 4904 relating to unsworn falsification to authorities. ;;;/% (! /J1;~/dk John C. Migatul . Date: 1-;31,;) -0';;; _"'~~l~~~llItHh:ili-'tJ#:lUj."'fid!;lf"'~'h<lN8-~",1:~"""'_'$i;!!,",k"'t;"Jr;'jM~,,^j;;;,l>lililil:!ii~~-" ~ ,~. o~, ~ ".~ . _~"d iIiJi~.iWiiilI~);t\I_K_jlr in ~~> --, -~ -", " 0 Cl (') C i-"":'" -n ~, .." ~~ -OU) rr. lllr"i'"' 0:> z:c ~~; N r~r.'-; :."--.....",, ',; )>r; ~(-') ~? >-'r :z -"'," ::1. f"'" :D (,0 -< . -~ o. ., ". ',-. , """ "" '"," "= ~ J I' . J.-I" -.,:, CHRISTI G. MIGATULSKl, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 00-7575 Civil JOHN C. MIGATULSKI, Defendant : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF INTENTION TO RESUME PRIOR NAME COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN Christi G. Migatulski, being duly sworn according to law, deposes and says that she is the Plaintiff in the above suit in which final decree from the bonds of matrimony was entered and she elects to resume her prior name of Christi L. Gates, and, therefore, gives this written notice avowing said intention, in accordance with the provisions of the Act of May 25,1939, P. 192, as amended July 13, 1953 (23 P.S. 98). , to be known as Sworn and subsc~ to ~:frf~~J-1 ,A Notary Public NO'fAl'll4L seAL RENEE DREISBACH. Notary F'ublic City of fofmPisbtJ.g Dauphin County My Commiss101HOx!,,1eS ~v. 3().2002 1 N <~,:",,-I-;;.," -, '~~l!!i~i\j'~~~fd_"'''''k~4.''iit,,,,~~_cjF~-<<I;' ,. ,",-.t'~1i1i~...."- 'It::r~;-'il5l~~~_J-: ."", :...,:"- _. 0 f) (;\ 8. it '_<O"'_~'_ _w~ _ "',=~,_~ ...... "iQ.. ~ C> o ~F! 8) -.... ~ is --0 -~p 2 <' -o6:} rnroc Z:D ?c ~:':' !:2C_: ~~] z ::~ "'~- --~, o N o ,-.. -I I '0 -c .~ " "'" ., ..~~"''',i II ii II " il I 'I n 'I \i !I 'I ., ~I I I 'i I Ii I I 1 'I c:? .:::;> G) o -n :::::1 _:{ip} ':3tn6~' ,:; . ,,'j ~,J 'j~,j ~~ ~~~, ,------..1Tl ,~,' -..{ .",. :I1 -<