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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
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STATE OF
MELINDA C. HUNT
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Plaintiff.
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VERSUS
WADE L. HUNT
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Defendant
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AND NOW,
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DECREED THAT
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AND
PENNA.
No, 00-7877 Civil Term
DECREE IN
DIVORCE
~VJ,,~t zq
, l.eo I , IT IS ORDERED AND
MELINDA C. HUNT
, PLAINTIFF,
WADE L. HUNT
, 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:
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
MELINDA C. HUNT,
Plaintiff
NO. 00-7877 Civil Term
vs.
CIVIL ACTION - LAW
WADE L. HUNT,
Defendant
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Please transmit the record together with the following information, to the Court
for entry of a divorce decree:
1. Ground for divorce: irretrievable breakdown under Section 330l(c) of the Divorce
Code.
2. Date and manner of service of the Complaint: Mailed by certified mail on or about
November 7.2000 and received by Defendant on or about November 14, 2000.
3. [Complete either paragraph (a) or (b).]
(a) Date of execution of the affidavit of consent required by Section 330l(c) of the
Divorce Code: by Plaintiff: August 16, 2001; by Defendant: August 16.2001.
(b) Date of execution of the Plaintiff's Affidavit required by Section 330l(d) of
the Divorce Code: , and, date of service of the Plaintiff's
Affidavit upon the Defendant:
4. Related claims pending: None. All economic claims have been settled.
5. Date and manner of service of Notice ofIntention to file praecipe to transmit record, a
copy of which is attached, if the decree is to be entered under Section 3301(d)(I) of the
Divorce Code:
6. Date and manner of service of Notice oflntention to file praecipe to transmit record, a
copy of which is attached, if the decree is to be entered under section 330l(c) of the
Divorce Code , or, date of execution of waiver of Notice ofIntent
and date offiling: Plaintiff's Waiver of Notice was executed on August 16. 2001. and
filed contemporaneously herewith. Defendant's Waiver of Notice was executed on August
16. 2001 and filed contemporaneously herewith.
7. The Plaintiff's Social Security Number is 192-66-0222. The Defendant's Social
Security Number is 125-50-2431.
#~~
/G. Patrick O'Connor, Attorney for Defendant
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MELINDA C. HUNT
312 Center Street
Eno1a, PA 17025
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs,
WADE L, HUNT
312 Center Street
Eno1a, PA 17025
No,
DO - 1i77 e...{ I~
YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND
AGA'INST THE CLAIMS SET FORTH IN THE FOLLOWING PAGES, YOU MUST
T~E,;~~~~ON W.t:THIN 'rt@lTY .( 2().) DAYS AFTER ,TIllS COMPLAINT AND NOTICE
A~'{~~It~D, BY ENTERING A:WRIT'l'EN APPE.'IU\NCE PERSONALLY OR BY
AN'! ~RNEY AND FILING.. IN wRITIRG .WITH.. THE COURT YOUR DEFE~SES
OROB'JeCTIOtlSTO THE CLAIMS SET FORTH AGAINST YOU. OU ARE WARNED
THN!' IF YOU FAIL TO 00 SO 'l"HE CASE MAY PROCEED WI -HOUT YOU AND
A JUDGMENT MAY BE ENTERED AGAINST YOU BY THE COURT if TROUT FURTHER
NO'l'ICE FoR ANY MONEy CLAIMED IN THE COMPLAINT OR R ANY OTHER
CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU. Y LOS~ HONEY
OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU.
~
.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO THE TF.LEPHONE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL
YOU. .00
OR'1'HE
HELP.
"
CU1BERLAND CXlUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE PA 17013
717 249 3166
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COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
In re: The Marriage of
1%/-.1cb. c: /k.,+
312 Center Street
Enola, PA 17025
and
Case #: c()-/87?6()~ I
IJ, ~ L /L-",I-
312 Center Street
Enola, PA 17025
COMPLAINT FOR DIVORCE
This action is brought by the Plaintiff,
Melinda C. Hunt ,
age, 26
, who resides at 312 Center Street
whose social security number is 192-66-0222
, and who is
employed as a Computer Specialist at House of Representatives
The undersigned Plaintiff states, under oath, the following:
1. RESPDENCY. Plaintiff has been a resident of and domiciled in the
state of Pennsylvania
for the preceding 26 years
and
the County
of Cumberland
for the preceding 8 years
2. SERVICE OF PROCESS. The Defendant
has agreed to file a Waiver
of Service of Process in this cause and, therefore, no service of .
process is necessary at this time.
Page 1
of
5 pages
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3. JURISDICTION. The Court has proper jurisdiction to hear this cause.
The Defendant
has agreed to file an Appearance in this cause.
Neither party has ever been involved in any other domestic relations
proceeding involving the other party in this or any other jurisdiction.
4. MARRIAGE, The Plaintiff and Defendant were married on the 12th
day of April
19 97
in the State of Pennsylvania
and lived together as husband and wife until on or about the 1st
day of December
, 2000, at which time they separated and
ceased to live together and they have lived separate and apart without
cohabitation ever since.
5. CHILDREN.
No children were born or adopted to the marriage.
The wife is not now pregnant.
6. GROUNDS.
As a result of disputes and serious differences, we
sincerely believe that our marriage is irretrievably broken and that
there is no possible chance for reconciliation.
7. AGREEMENT. This proceeding is uncontested. The Plaintiff and
Defendant have both signed a Marital Settlement Agreement, dated
the 7th
day of November
2000, which is attached and
incorporated by reference. By the terms of this Marital Settlement
Agreement they have settled all of the issues relating to their
marriage, including the division of all of the property, the
disposition of all of their bills and obligations, the need for any
alimony, maintenance or spousal support.
Page 2
of 5
pages
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A Financial Statement has been prepared by each of the parties listing
their respective income, expenses, assets, and liabilities and the
individual Financial Statements are attached and incorporated by
reference. The Marital Settlement Agreement and Financial Statements
were signed under no duress or force and without collusion.
8. CONSENT. The Defendant
has agreed to file a Consent to the
incorporation and merger of said Marital Settlement Agreement into a
DECREE OF DIVORCE in this case.
9. WAIVER. The Plaintiff
hereby waives any rights to findings of
fact and conclusions of law, a record of testimony, motion for a new
trial, notice of entry of final judgement or decree, and the right to
appeal, but does not waive any rights to the future modification of any
judgement or decree in this cause.
The Plaintiff respectfully requests and prays:
1. That a Divorce be granted by the court dissolving and terminating
forever the marriage between the parties.
2. That all of the terms and conditions of the party's Marital
Settlement Agreement, which is attached, be approved and be
incorporated, merged into, and made part of a DECREE OF DIVORCE
and that the parties be ordered to comply with all terms and conditions
of the Marital Settlement Agreement survive.
3. That the court award the parties any other further relief as may be
just and equitable.
Page
3
of
5
pages
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Dated this
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day of ~ )\:\0~\"~\o~X
, 1-9 ;;;'000
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Address: 312 Center Street
Enola, PA 17025
Phone: 717 728 - 8899
State of Pennsylvania
SS.
County
of Cumberland
On this day, before me, the undersigned authority, in and for and
residing in the above County
and state, personally appeared the
Plaintiff
Melinda C. Hunt
I who is personally known
to me to be the same person whose name is subscribed to the foregoing
document, and, being duly sworn, she
verified that the information
contained in the foregoing document is true and correct on personal
knowledge and acknowledged that said document was signed as a free and
voluntary act.
Subscribed and sworn to this 7 a;: day of 1\10 u eM t3 r;'~, ~P(Jo
me and signature
6[;ft-tJ E
NOT RIAL SEAL
JOHN F CONNOLl. Y Notary Public
.. unly
M Commission Ex ires Feb. 26, 2001
My commission expires:
Page
4 of 5
pages
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Dated this
7:ri!
day of
AIove_ k
,.,zOo'>,
dJd /.~
Address: 312 Center Street
Enola, PA 17025
Phone: 717 728 - 8899
State of Pennsylvania
SS.
County
of Cumberland
On this day, before me, the undersigned authority, in and for and
residing in the above County
and state, personally appeared the
Defendant Wade L. Hunt
, who is personally known
to me to be the same person whose name is subscribed to the foregoing
document, and, being duly sworn, ~ verified that the information
contained in the foregoing document is true and correct on personal
knowledge and acknowledged that said document was signed as a free and
voluntary act.
Subscribed and sworn to this 7r;[ day of rJolf.z:rvtB/(f2.. , r~
N e and signature
JDtlN F:. COA/Nol(
My commission expires:
NOTARIAL SEAL
JOHN F CONNOllY Notary Public
, , n~
M Commission Ex ires Feb. 26, 200t
Page 5
of
5
pages
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
MELINDA C. HUNT,
Plaintiff
NO. 00-7877 Civil Term
vs.
CIVIL ACTION - LAW
WADE L. HUNT,
Defendant
IN DIVORCE
ACCEPTANCE OF SERVICE
I acknowledge acceptance of service of a Complaint in Divorce filed November 7,
2000 on or about November 14, 2000.
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WadeL. Hunt, Derendant
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
MELINDA C. HUNT,
Plaintiff
NO. 00-7877 Civil Term
vs.
CIVIL ACTION - LAW
WADE L. HUNT,
Defendant
IN DIVORCE
AFFIDAVIT OF CONSENT
I. A Complaint in Divorce under Section 330 I ( c) of the Divorce Code was filed on
November 7,2000 and service made on the Defendant on or about November 14, 2000.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days
have elapsed from the date of filing and service of the Complaint.
3. I consent to the entry of a final decree of divorce after service of notice of intention to
request entry of the decree.
4. I understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses if I do not claim them before a divorce is granted.
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:
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Melinda C. Hunt, Plaintiff
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
MELINDA C HUNT,
Plaintiff
NO. 00-7877 Civil Term
vs.
CIVIL ACTION - LAW
WADE L. HUNT,
Defendant
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 of 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 the foregoing 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: ~ ' 1t,,;Jtlf/
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Melinda C Hunt, Plainti
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
MELINDA C. HUNT,
Plaintiff
NO. 00-7877 Civil Term
vs.
CIVIL ACTION - LAW
WADE L. HUNT,
Defendant
IN DIVORCE
AFFIDAVIT OF MARRIAGE COUNSELING
Melinda C. Hunt, being duly sworn according to law, deposes and says:
1. I have been advised of the availability of marriage counseling and understand that 1 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 Office of the
Prothonotary, 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 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: a?
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Melinda C. Hunt
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
MELINDA C. HUNT,
Plaintiff
NO. 00-7877 Civil Term
vs.
CIVIL ACTION - LAW
WADEL HUNT,
Defendant
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 330l(c) of the Divorce Code was filed on
November 7,2000 and service made on the Defendant on or about November 14, 2000.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days
have elapsed from the date of filing and service of the Complaint.
3. I consent to the entry of a final 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 falsification to authorities.
DATE: fr' 4" ~/
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Wade L Hunt, Defendant
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
MELINDA C. HUNT,
Plaintiff
NO. 00-7877 Civil Term
vs.
CIVlL ACTION - LAW
WADE L. HUNT,
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 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 the foregoing 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: ~ /I~I
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wade L. Hunt, efendant
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
MELINDA C. HUNT,
Plaintiff
NO. 00-7877 Civil Term
vs.
CIVIL ACTION - LAW
WADE L. HUNT,
Defendant
IN DIVORCE
AFFIDAVIT OF r.:IARlliAGE COUNSELn'1G
Wade L. Hunt, 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 Office of the
Prothonotary, 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 understand that false statements herein are made subject to the penalties of 18 Pa. e.s.
Section 4904, relating to unsworn falsification to authorities.
Date t- /~.2ao /
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MARITAL SETTLEMENT AGREEMENT
This agreement is made on the
day of
November
7th
2000, between Melinda Craiq Hunt
312 Center Street
the Wife, who lives at
, in the City
of
Enola
State of Pennsylvania
of
Cumberland,
County
and Wade Lance Hunt
the Husband, who lives at 312 Center Street
, in the
City
Cumberland
Eno1a
County
of
of
State of
Pennsylvania
We were married on the 12th
day of April
, 1997,
in the City
of
of Turbotville
County
Northumberland , State of
pennsylvania
The following children were born or adopted into our marriage:
Child's name
Child's birth date
Child I S sex
Child I S name
Child's birth date
Child's sex
Child I S name
Child's birth date
Child's sex
Child I S name
Child's birth date
Child's sex
Child's name
Child's birth date
Child I S sex
As a result of disputes and serious differences, we sincerely believe
that our marriage is irretrievably broken and that there is no possible
chance for reconciliation.
Page 1
of 8 pages
. .
,
I'
,--
We both desire to settle by agreement all of our marital affairs,
including the division of all of our property and bills.
THEREFORE, in consideration of our mutual promises, and other good and
valuable considerations, we agree as follows:
1. We both desire and agree to permanently live separate and apart from
each other, as if we were single, according to the terms of this
agreement. We both agree not to annoy, harass, or interfere with the
other in any manner.
2. We both agree that the following issues have been resolved as
follows:
REAL ESTATE: The deed for the home at 312 Center Street, Enola,
pennsylvania, 17025, will be transferred to Wade Lance Hunt, who
resides at the home and will be responsible for the mortgage, all
insurance, taxes, utilities and expenses associated with the property.
VEHICLES: Melinda Hunt will receive free and clear title to the
1998 Honda Accord free and clear of any claim by Wade Hunt. Melinda
agrees to pay all taxes arising from the ownership of the 1998 Honda Accord.
Wade Hunt will receive free and clear title to the 2000 Isuzu Rodeo
and free and clear of any claim by Melinda Hunt. Wade agrees to pay all taxes
and debts owed for the Isuzu Rodeo and holds Melinda harmless from any and all
claims arisinq from such debt.
HOUSEHOLD GOODS:
Wade Hunt and Melinda Hunt have agreed on and
divided all household items,
Page 2
of
8 pages
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PERSONAL PROPERTY: All personal property has been divided to the
satisfaction of Wade Hunt and Melinda Hunt.
DEBTS:
Melinda Hunt's debt obligations:
Obligation
a. No debt Obligations
Wade Hunt's debt obligations:
Obligation
a.
b.
Living room suit
Isuzu Rodeo Car Loan
House Mortgage
c.
Owed To:
Owed To:
NB Liebman Furniture
Isuzu Motor Corp.
PSECU
Amount
Amount
$ 1,600.00
22,466.00
83,800.00
BANK ACCOUNTS: All monies in savings and checking accounts have been
divided to the mutual satisfaction of both parties.
''''<'
,- ~ ~
, ~
Page 3
of 8
pages
~-
LIFE INSURANCE FOR SPOUSES: All life insurance policies have been
divided to the mutual agreement of both Melinda Hunt and Wade Hunt.
INCOME TAXES: The tax return has been divided to the agreement of
Melinda Hunt and Wade Hunt prior to the creation of this Marital
Settlement Agreement.
ALIMONY: Alimony will not be paid by Melinda Hunt or Wade Hunt,
Both parties understand that they waive all future claims to alimony.
CUSTODY: We have no minor children.
Page 4
of 8
pages
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VISITATION: We have no minor children.
CHILD SUPPORT: We have no minor children.
MEDICAL COVERAGE & NON-COVERED MEDICAL EXPENSES: We have no minor
children.
Page 5
of 8
pages
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LIFE INSURANCE FOR CHILDREN: We have no minor children.
TAX EXEMPTIONS: We have no minor children,
3. We both agree that, in the event of divorce or dissolution of
marriage, the Wife may desire to and shall have the right to be known
by the name of Melinda Bobette Craig , her maiden or
former name.
4. We both desire that, in the event of our divorce or dissolution of
marriage, this marital settlement agreement be approved and merged and
incorporated into any subsequent decree or judgement for divorce or
dissolution of marriage and that, by the terms of the judgment or
decree, we both be ordered to comply with the terms of this agreement,
but that this agreement shall survive.
We have prepared this agreement cooperatively and each of us has fully
and honestly disclosed to the other the extent of our assets, income,
and financial situation. We have each completed Financial Statements
which are attached and incorporated by reference.
Page 6
of 8
pages
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We both understand that we have the right to representation by
independent council. We each fully understand our rights and we each
consider the terms of this agreement to be fair and reasonable. Both of
us agree to execute and deliver any documents, to make any
endorsements, and do any and all acts that may be necessary or
convenient to carry out all of the terms of this agreement.
We agree that this document is intended to be the full and entire
settlement and agreement between us regarding our marital rights and
obligations and that this agreement should be interpreted and governed
by the laws of the State of Pennsylvania.
We also agree that every provision of this agreement is expressly made
binding upon the heirs, assigns, executors, administrators, successors
in interest, and representatives of each of us.
Signed and dated this
1d
day of
4ve". k-
, ;;boo.
L/O-/L A #/J";)(/
j;;~~ r: /j!J-
~~ ./77. ~~
Witness for Wife
Wi~~&u(
~Yh< ~A-
Witness for Husban
Wit!!1f;;~~~,
Page 7
of
8 pages
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State of Pennsylvania
SS.
County
of Cumberland
On this day, before me, the undersigned authority, in and for and
residing in the above County
and state, personally appeared
Wade L. Hunt
who is personally known to me to
be the same person whose name is subscribed to the foregoing document,
and, being duly sworn,
he
verified that the information contained
in the foregoing document is true and correct on personal knowledge and
acknowledged that said document was signed as a free and voluntary act
for the purposes stated.
Subscribed and sworn to this 77J.. day of ;JOt/f:..f1/lf3[e.d11P
~~~~.
am .and signature
NOTARIAL SEAL
My commission expires: Pu~~
City of Carlisle. cumbe~'::t~u~1
M Commission Ex II'$.S' . .
State of Pennsylvania
SS.
County
of Cumberland
On this day, before me, the undersigned authority, in and for and
residing in the above County
and state, personally appeared
Melinda C. Hunt
, who is personally known to me to
be the same person whose name is subscribed to the foregoing document,
and, being duly sworn, she
verified that the information contained
in the foregoing document is true and correct on personal knowledge and
acknowledged that said document was signed as a free and voluntary act
7 rh. day of
for the purposes stated. Subscribed and sworn to this
cNoVitl\r%f2-- ,~.
Page 8
of 8
TARIAL SEAL
JOHN F CONNOllY Notary Public
. nty
M Commission l:x ires Feb. 26. 2001
My commission expires:
pag
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
..
,
File No.
!~\) -1\11 C iu' \IQx.......
"
vs,
IN DIVORCE
\vo..J..Q. L. ~
Defendant
NOTICE TO RESUME PRIOR SURNAME
Notice is hereby given that the Plaintiff/Defendant in the
above matter, having been granted a Final Decree in Divorce on the
~ C\ day of Q 1-9.;700 \ hereby elects to resume the
prior surname of
this written notice pursuant
, and gives
provisions of 54 P.S. S 704.
--ifuLJ", C. II ~ -~ (I?
Signat~
b, '3&,
DATE: ,~.p~f. J~ ,900 I
I
COMMONWEALTH OF PENNSYLVANIA:
55.
COUNTY OF CUMBERLAND
On the ('),"rf... day of ilil9f. , MJCOI, before me, a
Notary Public, personally appeared the above affiant known to me to
be the person whose name is subscribed to the within document and
acknowledged that he/she executed the foregoing for the purpose
therein contained,
seaL
In Witness Whereof. I have tlereunto set my hand and official
qD S SwU.i:t
~ Notary Pub.lic
._---~-..---'--"-:~.,,"".;.
NOTARIAL SEAL
JODY S. SMITH, NOTARY PUBLIC
Carlisle 8pro. Cvmberland County
My Commission Expires April 4, 2005
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