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Home My WebLink About00-08692 ~.. ;.~~ " ~ -,.- ~ '.~ ~.~ ~ '," ~ ~., ~.~ ~ ~ ~ ~\ a ~.~ ks ~ ~.s ~ \f~ ~ ~.~ ~ ~.~ ~ ~.; ~l ~ ~.~ .;.; r.'~ ~ ~'s I ,"- \/ W ~.~ ~ ~.~ ~ ;..; ~ a ~.~ I ~'s , ~.~ ~ ;..~ ~ ?'.~ ~, ~.~ ~ ~' ": ;..~ ~ IJ .. . .- ., ~~.."" .... 1\ '~ - STATE OF PENNA. JACK E. .. ..m.............. I III I No, ,..2. ().C?.c?:::,8. 9,;) 2 '......P.... ~ PATTI, .._m. ""Pl'ainti-fi'..m- Versus DEBRA L. PATTI, _...........______.___....u_ - ..-lh~.fe-ria-~iiit.. DECREE IN D I V 0 R C E d 11:00 ",M. AN/) NOW".... .M-....l.~.......,' ~. .2.QQl-, it is ordered and decreed that....., .~~~~. .p;:~.a.~~~............................, plgintiff, and. , . . . . . . . . . . . . . J;l!'!.l~J::9. ~'" .l?iil):.~~ . . . . . . . . . . . . . , , . . . . . . . . . " 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; _ "",1 ~ . ~, ~ 'l, ~.~ ~ i ~.~ ,.'~ ~ ~ :~ ~ ~~~ ~ ~.~ ~ .~,. 8 ",.,., w ~.~ -'," ~ ~."J r.~. ~'s ~ ~ v ~ ;"S ~ i '.<! ~." ~ ~.S * ~ l~ ~ ~.~ ~ ~ ~.<! i '.<! ~ ~.~ The attached Matrimonial Settlement Agreement is incorporated herei ~ ~.~ .......................................... ................................. ~ ~'.' * ~ i ~ III I ~~~~~~~~~~~~~~~~~~~.~.~ By Attest: 11.__ ~..!~ _.. ....~~~>t'1 Prothonotary ~ '.~ ~ ~.~ ~ '.' ~ ".' J. ~ ".' ~ '.' ~ ',' ~ .:'::.::~:":~'::.::<::'::.::' >~.::,-::)::.::~"..::-::.::,', ,"::.;', :'-'::+::":' :.::.::. :',.::.i/ ~ . i i:}1 !:1 !' :'1 '~i 1';1 i:' i' , ! II I: " . ^ "~-' <~~~-"-' <..,. . . - ~ . ~, ~,. ,,~"~- , ~^ .~ "~ ~. .' .:,.;..; . ' 4-/~'CJI lU-C~~ ~~~ lI/gP~/ 7J~ ~ # ~ ~ - - ~ . '- '<, "~" __ "~,_JIIi . . "^^_~~!JR!!<:'~"I;~~f~~~_"_lNl~,~r -". ~""''T''} ,;",JJ! "I.; , ill --~ ..-, . MATRIMONIAL SETTLEMENT AGREEMENT THIS AGREEMENT, made this 2:1'../ day of ~ , 2001, by and between JACK E. PATTI, hereinafter referred to as "Husband", and DEBRA L. PATTI, hereinafter referred to as "Wife". WITNESSETH: 31, 1995; and WHEREAS, Husband and Wife were lawfully married O~Ausust~ ? -n L!~:'~ ~'" -f 5I! ;~!: i ';::0 7.--. I tr) C', .--' (-~ ' C~ --0 ~-,-<;c: WHEREAS, certain differences have arisen betwe~~he:;par~J.=ejs -<--- ~ :: i:,~~r n as a result of which they have separated and now live~epgfa~ and apart from one another, anc are desirous, therefore, of -T! entering into an agreement w~~c~ will provide for their mutual responsibilities and rights growing out of the marriage relationship; and WHEREAS, Husband, after being properly advised by his attorney, Herschel Lock, and Wife, after being requested to obtain legal counsel but choosing not to do so, have come to the following agreement. NOW, THEREFORE, in consideration of the above recitals and the following covenants and promises mutually made and mutually to be kept, the parties heretofore, intending to be legally bound and to legally bind their heirs, successors and assigns thereby, covenant, promise and agree as follows: - 1 - . ; I) '-l - 1. SEPARATION: It shall be lawful for each party at all times hereafter to live separate and apart from the other at such place or places as he or she may from time to time choose or deem fit. 2. INTERFERENCE: Each party shall be free from interference, authority and contact by the other, as fully as if he or she were single and unmarried, except as may be necessary to carry out the provisions of this Agreement. Neither party shall molest the other nor attempt to endeavor to molest the other, nor compel the other to cohabit with the other, nor in any way harass or malign the other, nor in any way interfere with the peaceful existence, separate and apart from the other. 3. WIFE'S DEBTS: Wife represents anc warrants to Husband that since the separation she has not, and in the future she will not, contract or incur any cebt or liability for which Husband or his estate might be responsible and 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. However, Wife agrees too that she shall be solely responsible for the payment of her Teamsters' Mastercard and will indemnify Husband and hold him harmless for any liability therefore. - 2 - c ~ '-.00 '. ,. . I ""~ : ~ ~._- 4. HUSBAND'S DEBTS: Husband represents and warrants to Wife that since the separation he has not, and in the future he will not, contract or incur any debt or liability for which Wife or her estate might be responsible and 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. Further, Husband agrees to be solely liable for the debt he now owes the IRS and to indemnify Wife and hold her harmless for any liability therefore. 5 . MUTUAL RELEASE: Subject to the provisions of this Agreement each party waives his or her right to alL~ony and any further distribution of property inasmuch as the parties hereto agree that this Agreement provides for an equitable distribution of their marital property in accordance with the Divorce Code of 1980, its supplements and amendments. Subject to the provisions of this Agreement, each party has released, discharged, and by this Agreement does for himself or herself, and 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 equity, which either of the parties ever had or now has against the other, except any or all cause or causes of action for divorce and except in any or all causes of action for breach of any provisions of this Agreement. Each party also waives their right - 3 - . , .1' :~ ~ ~ to request marital counseling pursuant to the Divorce Code. For purposes of interpretation, this Agreement shall be deemed to have been drafted by both parties hereto. 6. DIVISION OF PERSONAL PROPERTY: Husband and Wife agree that Husband shall remain the sole owner of his Winchester 30.06 rifle, his Grandmother's cedar chest and her dishes. As to all other personal property, household furnishings, furniture and the like, as well as stocks and bonds, savings, retirement accounts or pensions of any sort and any other personalty presently in the possession of each party, these shall remain the sole and exclusive property of that party in whose possession they are. Specifically, too, it is agreed by and between the parties that Husband shall hereafter remain the sole owner of his 1987 and 1997 Chevrolet pick up trucks and 1998 Chevrolet Tahoe vehicle, with Wife giving up all of her right, title and interest thereto. Husband agrees to pay all encumbrances presently on these vehicles, if any there be, until they are paid in full and shall indemnify Wife and hold her harmless therefore. However, specifically as to the business known as Jack Patti Framing Contractor, Husband and wife agree that by this Agreement Wife shall transfer to Husband all of her right, title and interest therein, if any there be. Further, it is agreed by and between Husband and Wife that they shall sell their 1996 Saturn automobile and payoff the encumbrance thereon. Towards this end, Wife agrees to execute contemporaneously with - 4 - ~- '; I' ,~ - .~ - '." ;.r' , the execution hereof, a Power of Attorney in Husband's favor so that he is able to act for himself and for Wife in this sale. Towards this end and contemporaneously with the execution hereof, Wife shall execute a Special Power of Attorney in favor of Husband allowing him to act on her behalf to sell said vehicle. If after the vehicle is sold and the debt thereon, as well as the costs of sale, are fully paid there remains any profit, it is agreed by the parties that Wife shall keep it. Lastly, so as to equalize the division of assets hereunder and contingent upon both Husband and Wife executing the Affidavit of Consent and Waiver of Notice of Intent to File for Divorce required to conclude this divorce, Husband shall pay Wife One Thousand Five Hundred ($1,500) Dollars. 7. DIVISION OF REAL PROpBRTY: Husband and Wife agree that Husband shall remain the sole owner of the approximately seven (7) acres of unimproved land located in South Middleton Township, Cumberland County, Pennsylvania, and Wife agrees to transfer by Quit Claim Deed executed contemporaneously with this Agreement all of her right, title and interest thereto to Husband, who thereafter shall remain solely responsible for the mortgage to Waypoint currently thereon and hold Wife harmless and indemnify her for any liability therefore. Additionally, Husband and Wife acknowledge that they are presently attempting to sell their time share at Cyprus Palms, Orlando, Florida, and agree to fully cooperate with - 5 - - . - - "- '-- ~I! each other in the selling thereof. Additionally, contemporaneously with the execution hereof, wife agrees to execute a Limited Power of Attorney in favor of Husband so that he can act for himself and on her behalf in doing so. When it is sold, they agree further to equally divide the profits realized therefrom or, alteratively, to be equally responsible for any outstanding debts remaining after the sale. 8. ALIMONY: Both parties acknowledge and agree that the provisions of this Agreement providing for equitable distribution of marital property are fair, adequate and satisfactory to them and are accepted by them in lieu of and in full and final settlement and satisfaction of any claims or demands that either may now or hereafter have against the other for support, maintenance or alimony. Husband and Wife, further, voluntarily and intelligently waive and relinquish any right to seek from the other any payment for support or alimony. 9. ALIMONY PENDENTEL:TE. COUNSEL FEES. AND EXPENSES: Husband and Wife acknowledge and agree that the provisions of this Agreement providing for the equitable distribution of marital property of the parties is fair, adequate and satisfactory to them. Both parties agree to accept the provisions set forth in this Agreement in lieu of and in full and final settlement and satisfaction of all claims and demands that - 6 - .'I~ - .. .- ~ '- ..~ ~ '" '".: either may now or hereafter have against the other for alimony pendente lite, counsel fees or expenses or any other provision for their support and maintenance before, during and after the commencement of any proceedings for divorce or annulment between the parties. The provisions of this Agreement dealing with alimony, alimony pendente lite, counsel fees, spousal support and the like are intended by the parties to be in full and complete satisfaction of any statutory marital rights or obligations of the parties. 10. WAIVERS OF CLAIMS AGAINST ESTATES: Except as herein otherw~se provided, each party may dispose of his or her property ~n any way, and each party hereby waives and relinquishes any and all rights she or he may now have or hereafter acquire, under the present laws of any jurisdiction, to share in the property or the estate of the other as a result of the marital relationship, including without limitation, dower, curtsy, statutory allowance, widow's allowance, right to take in intestacy, right to take against the will of the other, and right to act as administrator or executor of the other's estate, and each will, at the request of the other, execute, acknowledge and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interests, rights and claims. - 7 - w - -~~. H , i , - 11. TAX RAMIFICATIONS: The parties have negotiated this Agreement with the understanding and intention to equally divide their marital property. The parties have determined that such equal division conforms to all rights and just standards with regard to the rights of each party. The division of existing marital property is not intended by the parties to constitute or any way be a sale or exchange of assets. It is understood that the property transfer described in this Agreement fall within the provisions of Section 1041 of the Internal Revenue Code, and as such will not result in the recognition of any gain or loss upon the transfer by the transferor. 12. SUBSEOUENT DIVORCE: A Complaint in Divorce has been filed by Husband. Husband and Wife each agree to sign contemporaneously with the execution hereof an Affidavit of Consent and Waiver of Notice of Intent to File for Divorce to be filed in said divorce action. The parties further agree that each of them shall be responsible for their own attorney's fees, if any there be. In the event such divorce is concluded, Husband shall be entitled to receive a copy of the Decree In Divorce for the normal fee charged by the Prothonotary. In the event such divorce action is concluded, the parties shall be bound by all the terms of this Agreement, which shall be incorporated by reference into the Divorce Decree, but, - 8 - u," ~ , , ", ","-~~,~- "'; notwithstanding such incorporation, this Agreement shall not be merged in such Decree, but shall in all respects survive the same and be forever binding and conclusive upon the parties. 13 . BREACH: If either party breaches any provision of this Agreement, the other party shall have the right, at her or his option, remedies or relief as may be available to her or him, and the party breaching this contract should be responsible for payment of legal fees and costs incurred by the other in enforcing their rights under this Agreement. 14. ADDITIONAL INSTRU~BNTS: Each of the parties shall from time to time, at the request of the other, execute, acknowledge and'deliver to the other party any and all further instruments that may be required to give full force and effect to the provisions of this Agreement. 15. VOLUNTARY EXECUTION: The provisions of this Agreement and their legal effect have been fully explained to the parties by their respective counsel, and each party acknowledges that the Agreement is fair and equitable, that it is being entered into voluntarily, with full knowledge of the assets of both parties, and that it is not the result of any duress or undue influence. The parties - 9 - 1'1 < .' 1 ~ .'^""-.- ';-4i acknowledge that they have been furnished with all information relating to the financial affairs of the other which has been requested by each of them or by their respective counsel. 16. ENTIRE AGREEMENT: This Agreement contains the entire understanding of the parties and there are no representations, warranties, covenants or understandings other than those expressly set forth herein. Husband and wife acknowledge and agree that the provisions of this Agreement with respect to the distribution and division of marital and separate property are fair, equitable and satisfactory to them based on the length of their marriage and other relevant factors which have been taken into consideration by the parties. Both parties hereby accept the provisions of this Agreement with respect to the division of property in lieu of and in full and final settlement and satisfaction of all claims and demands that they may now have or hereafter have against the other for equitable distribution of their property or for alimony, alimony pendente lite, counsel fees or costs by any court of competent jurisdiction pursuant to the Divorce Code or any other laws. Husband and Wife each voluntarily and intelligently waive and relinquish any right to seek a court ordered determination and distribution of marital property, but nothing herein contained shall constitute a waiver by either party of any rights to seek the relief of any court for the purpose of enforcing the provisions of this Agreement. - 10 - . , ....I~~ 17. DESCRIPTIVE HEADINGS: The descriptive headings used herein are for convenience only. They shall have no effect whatsoever in determining the rights or obligations of the parties. 18. INDEPENDENT SEPARATE COVENANTS: It is specifically understood and agreed by and between the parties hereto that each paragraph hereof shall be deemed to be a separate and independent covenant and agreement. 19. APPLICABLE LAW: This Agreement shall be construed under the law of the Commonwealth of pennsylvania. 20. VOID CLAUSES: If any term, condition, clause or provision of this Agreement shall be dete~ined or declared to be void or invalid in law or otherwise, then only that term, condition or provision shall be stricken from this Agreement and in all other respects this Agreement shall be valid and continue in full force and operation. 21. AGREEMENT BINDING ON HEIRS: This Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective heirs, executors, administrators, successors, and assigns. - 11 - ,~ ---, 1 . ,~ ". --, , ,- .4;' 22. 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 upon strict performance of any of the provisions of this Agreement shall not be construed as a waiver of any subsequent default of the same or similar nature. IN WITNESS WHEREOF, the parties hereto have set their hands and seals the day and year first above written. WITNESS: ~),( , cPd't \ X\"\ '\ 'A'<"-\'" \'. ':' \; , ''.\\ '~, ~- '. , . - 12 - , ,-" """_'. ' 'n,_ ? 5/ - """1 AFFIDAVTT COMMONWEALTH OF PENNSYLVANIA COUNTY OF J;il\.Ul'HINCurnbe.r ~ ; 55: On this, the c0A.C1 day of ~pr; \ , 2001 before me, a Notary Public, the undersigned officer, personally appeared JACK E. PATTI, known to me (or satisfactorily proven) to be the same person whose name is subscribed to the within instrument and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and notarial seal. ~,~W (;1 ~\ Lc j Not~DTlc NOTARIAL SEAL DARCIE ,", NEIL, Notary Public I Shippensburg, Cumberland CounW , '" ; n 'roe: (Il", ')'1 '}nn-' My C~:nml:::O" EXpL"" ".1. ", :::~_, ~" " , '~ , 11.-- ""-"''','v' AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA . SS: COUNTY OF LlAUFHIN CLtmbu~'-01 ; On this, the <0 Iv.:! day of 'lJpn' J , 2001, before me, a Notary Public, the undersigned officer, personally appeared DEBRA L. PATTI, known to me (or satisfactorily proven) to be the s~~e person whose name is subscribed to the within instrument and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and notarial seal. (" . / . f~CltLU, dtLLC j Notary Public I . NOTARIAL SEAL I DARCIE A NEil. Notary Public I Shippensourg, Cumberland County My Commiss'Q" Evpir>;l~ ~l",/ '),1 1)'1('1'. ____~_:_..:,' ., ..w........ ''-'l''''-'~' '--'--' -II .J ~ ,.-", ,- >,"~d _ '",:_.-. -..........~~; J ",' : IN THE COURT OF CCMMON PLEAs' OF " CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000-8692 JACK E. PATTI, plaintiff : vs. : CIVIL ACTION - LAW ACTION IN DIVORCE DEBRA L. PATTI, Defendant PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record. together with the following information, to the court for entry of a divorce decree: 1. Grounds for divorce: irretrievable breakdown under Section 3301 (c) X3Ollx~)l(lllj: of the Divorce Code. (Strike out inapplicable section) 2. Date and manner of service of the complaint: Certified Mail, Return Receipt Requested December 19, 2000 3. Complete either Paragraph A. or B. A. Date of execution of the affidavit of consent required by Section 3301 (c) of the Divorce Code: by the plaintiff ApriL 2, 2001 by the defendant April 2, 2001 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: None 5. Indicate date and manner of service of the notice of intention to file praecipe to transmit record, and attach a copy of said notice under Section 3301 (d)(l)(i) of the Divorce Code Herschel Lock A torney for Plaintiff!oef~~~ ~-"''"'';''-''''I- -~-1" ~""~i!!i~;~i..~>~>>y~~,$~l!.'l",*,?~w.~l'lIliii"~ , "" ,,~..i"""'..<' "'1iIIiliIii ~-~=- ~~,~ ~ () t:J~ iIln-, Z,=-;'~:I Z-C ~;r" 'J"'.......- '- ;2 :z; =< o :r::~ -;;J ~;-::J ,~l')l '~-- ~, C) I 0T<b ,;--" -::~;:;) :5 ~~?, ,_!,,~ :::-} --.',..-..... ~5rrl -I "'> :::0 .< -0 .'.,." -" - ., r:- ()") " ' II n1:iJ~ J JACK E. PATTI, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : vs. NO. 2000-'Y(P9~ CIVIL TERM DEBRA L. PATTI, Defendant . . CIVIL ACTION - LAW ACTION 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 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 the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, 1 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 LOST 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. COURT ADMINISTRATOR CUMBERLAND COUNTY COURTHOUSE, 4TH FLOOR ONE COURTHOUSE SQUARE CARLISLE, PA 17013-3387 (717) 240-6200 ~ ,I' - .; .-w~ JACK E. PATTI, Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 2000 CIVIL TERM DEBRA L. PATTI, Defendant . . CIVIL ACTION - LAW ACTION IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN NAMED DEFENDANT: YOU HAVE BEEN NAMED AS DEFENDANT in a divorce proceeding filed in the Court of Common Pleas of Cumberland County, pennsylvania. This Notice is to advise you that, in accordance with Section 202 of the Divorce Code, you may request that the Court require you and your spouse to obtain marriage counseling prior to a divorce decree being handed down by the Court. A list of professional marriage counselors is available at the Office of the Prothonotary, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from the list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty (20) days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. PROTHONOTARY - ~.-~I~- ~ _, I,' _ .. ~.J It. 'C"""; JACK E. PATTI, Plaintiff . . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 2000 - 't1A:J... CIVIL TERM DEBRA L. PATTI, Defendant CIVIL ACTION - LAW ACTION IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE AND NOW, comes the Plaintiff JACK E. PATTI, by his attorney, Herschel Lock, and seeks to obtain a Decree in Divorce from the bonds of matrimony with the above-named Defendant, and avers the following: 1. Plaintiff Jack E. Patti is an adult individual residing at c/o PO Box 336, Shermans Dale, Perry County, Pennsylvania 17090. 2. Defendant Debra L. Patti is an adult individual residing at 310 E. North Street, Carlisle, Cumberland County, Pennsylvania 17013. 3. Both Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on August 31, 1995, in Alexandria, Virginia. 5. There have been no prior actions of divorce or annulment between the parties. 6. The marriage is irretrievably broken. 7. Defendant is not a member of the Armed Services of the United States or any of its Allies. - ~I,I ';'L'_; 8. Plaintiff has been advised of the availability of counseling, and understands that he has the right to request the Court to require the parties to participate in counseling. WHEREFORE, Plaintiff respectfully requests the Court to enter a Decree in Divorce. DATED: nJ)~JD6 . e:Jetj /( ( HERSCHEL LOCK, ESQUIRE ATTORNEY FOR PLAINTIFF 3107 North Front Street Harrisburg, PA 17110 (717) 238-6661 -IJ. ,,~~L c ~ L ok. ""*_;,; , VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: Jd/J9J~o , ''''', ~"'" ,-2.:. "'~ , . JACK E. PATTI, Plaintiff . . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 2000 CIVIL TERM DEBRA L. PATTI, Defendant : CIVIL ACTION - LAW ACTION IN DIVORCE CERTIFICATE OF SERVICE I, Herschel Lock, Esquire, do hereby certify that on this !~ day of fk~ , 2000, I served a copy of the Complaint in Divorce for Plaintiff by depositing same in the United States Post Office, certified mail, return receipt requested, at Harrisburg, Pennsylvania, as follows: Debra L. Patti 310 E. North Street Carlisle, PA 17013 DATED: 11//1/00 .. Jf.",'1 ~<I( BY~ HERSCHEL LOCK, ESQUIRE ATTORNEY FOR PLAINTIFF 3107 North Front Street Harrisburg, PA 17110 (717) 238-6661 ',I, - ;"~,iii .....;,.~~ ~"""~illlijrd f .. """'liifui\l~,i!lJIi!;:-o--- '.....,~..~~"lr;jWb\"'J;I!W~ . I: I l< .....'ilmtJlt"' - '" . ~, , J> () a 0 C-~ 0 Tl =, S- o ---' 0>- -occ r'l -.,.-' - - rnrn 0 r!i,J1 ~ h? 2:1) ~ Lf) -+J ~~; 88 ~ U) :~~~S 0 c:c) ~ V) " ~ '-I'"" 0' v, :8:---., :::!;: ~~~ () () z( ~ .-,. ,-0 ~ ~ ~~ .P--c--= () ~ ~ z a ~ -< :n ~ >l -< -< ~ r (' r .. _ = ~ ,I, .'-f^ '~,~-I "~' , "~,,~<, _ ,,,",,'_ __~._~, ~<A, -~ '"'~ ...^' . ~ . JACK E. PATTI, Plaintiff . . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 2000-8692 CIVIL TERM DEBRA L. PATTI, Defendant . . CIVIL ACTION - LAW ACTION IN DIVORCE AFFIDAVIT OF SERVICE Herschel Lock deposes and says: 1. That he is an adult individual residing in Dauphin County, Pennsylvania. 2. That on December 19, 2000, he sent by Certified Mail, Return Receipt Requested from Harrisburg, Pennsylvania, No. PI60-938-337 the Complaint in Divorce in the above-captioned case to: Debra L. Patti 310 E. North Street Carlisle, PA 17013 3. That on December 21, 2000, Debra L. Patti signed the receipt No. PI60-938-337 which is attached to this Affidavit. DATED: 4-4-01 BY~ j( HERSCHEL LOCK, ESQUIRE ATTORNEY FOR PLAINTIFF 3107 North Front Street Harrisburg, PA 17110 (717) 238-6661 Sworn to and subsc~ibed before me this 'Ii-II day of /I ~ ' 2001- ~h~)/oJc Notary Public tiorAl!lAl SEAl. ., :~ .. ~ L fAIMliiOCK. HclIIIY I'Ublz Horrlobufjl, Deuph!n QIuIIlV Mrti 1'. ___23.- I I ~'..r , . ~ < I, }',",'."O_. .. . · Compiln~, ,,:' ,1lrtd a.A1so comp"'te item 4 if Restridt~d 'Delivery is desired. · Print your naniE! ~nd address on the reverse so that we 'can return the card to you. · Attach this carq to the back of the mailpiec9, or on the fro~jf ~pace permits. 1. Article.Addressed to: , Debra L. Patti 310 E. North Street Carlisle, PA 17013 . Ucle Number (Copy from service labelj 3. ~rvice Type .L:. Certified Mail 0 Express Mail o Registered 0 Return Receipt for Merchandise o Insured Mail 0 C.O.D. 4. Restricted Delivery? (Extra Fee) 0 Yes , ," f fi . ~ it ; i ( ~ 1811,Julyj999 " j j 1! i .~,~~ll~,Ofi9r!~f~~31j! ~ , jD~~tic R~furn Receipt ;; 102595-99--M-1789 h'~~___.,______,,____,_~ _ __ p 160 938 337 i. us Postal Service ';., ,,_ ',' . Receipt tor, Certified Mall No IllSIIrance Covllhlge ProVIded. 81 ~ Do not use for International Mall (See reve"'~ \lr'JBra L. Patti Street & Number st. 310 E. North ~ll.il'riS~tU~P~ 17013 Postage $ .55 Certified Fee J':[O Speda! Delivery Fee Restricted Delivery Fee Retum Receipt Showing to /.75 Whom & Date ~Iivered a Return ReceiplSI\o.Wing 19 Whom, ": Date,&Ad_sAd_ 310 TOTAl Postage. & Fees $ Poslmalk or Date E ,f 12/19/00 ff Q Q CO ... ~_.. '"~-~, i L U_l1Il~llJlI[ldllii!i~.lU1iIlJH h" "__~,~,~ ~."~~__ 1l:~~a;iff,k"l~I~!I1i!MJi'~J~ ~ ,,' "~ ~",,^, .,' _0, ~__^_ lilIl.f~'- -~' ,," -.. , " ~~ . , -< " () C) ~ ()- -., -0- '!','!Iio mL' V -."1,, :::.:J:; - ~-;;:;: &5_\ I ,TI _.~ 0") " ~_: ,'-0- r - C) .', :s? - <~- C~, '--:.-.; :0 5~ (-~ 0 c.:: '" z :::2 r.- 5; I (n -< ~ , ~'~'-' , ''-'~L''''I . . JACK E. PATTI, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 2000-8692 CIVIL TERM DEBRA L. PATTI, Defendant . . CIVIL ACTION - LAW ACTION IN DIVORCE AFFIDAVIT OF CONSENT personally appeared before me, a Notary Public in and for the aforesaid Commonwealth and County, JACK E. PATTI, who, being duly sworn according to law deposes and says that: 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on December 19, 2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. after service decree. I consent to the entry of a final decree of divorce of notice of intention to request entry of the 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 author' Date: 'i I ?, J 0 ( NOTARIAL SEAL ; DARCIE A. NEIL, Notary Public \ Shlppensburg, cu~berland 9.oU~~n . My commission ExPlres~~!?~;~~:.':_,:~~, ~":;","'':"O~Mi; ~..-'" ",- --i.UijnlJ~rW~~-',[' ,,~ lliilli;iiIiili --'-" . (") '-' 0 c: :5;:': " -0 tT.! ~ .~,I ", IT] 1J Z :t:l :::I,J -~'" C;;~ I /.~ CO C' -<~::'-- , ~. , ~_"~C' () i~ --0 _i;: -ri :J:::: '1'1 i~) - -or; Z ~i ~ ,- ~n en -< , " ....~ ...L""",,~~ JACK E. PATTI, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : vs. : NO. 2000-8692 CIVIL TERM DEBRA L. PATTI, Defendant CIVIL ACTION - LAW ACTION IN DIVORCE WAIVER OF NOTICE OF INTENT TO REQUEST ENTRY OF DIVORCE DECREE UNDER SECTION 330l(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. division of them before I understand that I may lose rights concerning alimony, property, lawyer's fees or expenses if I do not claim 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 related to unsworn falsification to authorities. DATED: '1) ;)J)tll -&'&...:.'-~'" "","r."-'1 \~ia!;bl:ildtJh_ "-'L "-'G/i""'-"''-''''ti'"\lIijjBf ~""RiI" ~;-, .,.- ....;...~ ii/ii,lIIIiI'-'-;';"'" .~ ~- ,~~~"'" .. ~j- (") ~ ~ft; .G....__.. "7'r' ~~ <'~ '1>,-_ ~~; 7" :< o C) >'l ~ -a ::-J I C--. 0' -',} -'1 -:--;G~] --~~~? ~:. --H ~:~? (") 8rn :::~) -< ~I.) r- ,,., , ,'" -~~ "'~.. , ...iI.. ..c _i _ "I "' '"..fi',; , . JACK E. PATTI, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : vs. : NO. 2000-8692 CIVIL TERM : DEBRA L. PATTI, Defendant CIVIL ACTION - LAW ACTION IN DIVORCE AFFIDAVIT I, JACK E. PATTI, 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 Domestic Relations Office, which list is available to me upon request. 3. Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the Court. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4909 relating to unsworn falsification to authorities. Sworn to and subscfibed before me this dU)/ day o UL 01. l NOTARIAL SEAL \1 DARCIE A. NEIL, NotalY Public . Shlppensburg, Cumberland County ", My C~iSS~~r: Expires Nov. 24, 200, I ~~l'Jllhtrj' m'~""-'" --'" ~,' ), 'l_.liik~t.~' fi\;j_~JI>lliiIIW'-'-" W,"'~,~~ '"~'-lIir~' .-, , ., '. . U1r/ljrMIfi""""""" "=~- . () C ? if0 <\..~ ~~:? ::r:.~ '>..,-' ;; ::::; -< ~~ ,~, , "-~,--" "' J-', Q 1-=) "-1 "'" '""l:'J ~':J , C') ." lJ :::;,: l:- e", _~(l) ~.' -< . ,->>~~ ~ 11_ ... .-~ -'I . . , , JACK E. PATTI, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : vs. . . NO. 2000-8692 CIVIL TERM : DEBRA L. PATTI, Defendant . . CIVIL ACTION - LAW ACTION IN DIVORCE : AFFIDAVIT OF CONSENT Personally appeared before me, a Notary Public in and for the aforesaid Commonwealth and County, DEBRA L. PATTI, who, being duly sworn according to law deposes and says that: 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on December 19, 2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. after service decree. I consent to the entry of a final decree of divorce of notice of intention to request entry of the 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 ::t::1~~~~;;;cation to aUJ}::A /Jfli DEBRA ~TT'{1t Sworn to and subscribed before me this i\)~ day o r; \ , 001. NOTARlAl SEAL DARCIE A. NEil, Notary Public Shippensburg, Cumberland County My Commission Expires Nov, 24, 200': , ,,~~- --~-' ~. -..."",' ""'"1'- '11M! ., "",-,,-: ~""'~.k-,_ "ili ,~ " '\..i, i jilllil!L~iu." - "~ ~,~ I~ . . . ~" o s: "l:Jf.[:,I 111(,'1 Z::'..i ~~~. ~~.., ~:f; Pc z ::2 , " C) CJ " -= '", --....1 -;.Q I V' ,,,,;-f'1 1)-:::; ~8 ~ -"1:) ::L~ r:- tT' lit . 1'-, J.,i , o'_''''',-V_,: . . . , , JACK E. PATTI, Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 2000-8692 CIVIL TERM DEBRA L. PATTI, Defendant CIVIL ACTION - LAW ACTION IN DIVORCE WAIVER OF NOTICE OF INTENT TO REQUEST ENTRY OF DIVORCE DECREE UNDER SECTION 330l(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. division of them before I understand that I may lose rights concerning alimony, property, lawyer's fees or expenses if I do not claim 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 related to unsworn falsification to authorities. DATED :1J~d/Jd/ _JJ~ DEBRA L. AT I ~--'" "_~.i,w,;, [Hnli. . " Tll~~' , . '-,~" '_iilooiiliiO,~ ~- ,.~-, ... ~~' --- . () 0 I:) C -n "': ~ l:)ce V " m tTJ :;0 r ~ Xi <,- I ["it Z " " :::;> (J)~.k. G"', , -j/~, ~;~:." :~ "v '., '- -' ~~? ;) ~~j l51 -I "'-:, r. 'J> ~-;i )J -, ()"\ -< . ~-~-- Ih>_, _ -- ,1., - .~ ~., .- ";';c,: . .') .. '"' '. , JACK E. PATTI, Plaintiff . . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : vs. NO. 2000-8692 CIVIL TERM DEBRA L. PATTI, Defendant CIVIL ACTION - LAW ACTION IN DIVORCE AFFIDAVIT I, DEBRA L. PATTI, 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 Domestic Relations Office, which list is available to me upon request. 3. Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the Court. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4909 relating to unsworn falsification to authorities. DBiJ~ Sworn to and subsc~fbed befo e me this 6)flQ day of eJ I. ' 2001: NOTARIAL SEAL DARCIE A NEIL, Notary Public Shippensburg, Cumberiand County My Commission Expires Nov, 24, 200', . __m'-'''''',,~_~ _...._.. l~'""'~' '='>'""'".....~liI'~~ .~'-'<" ~~!d-"';' ~.L.~ , .. . Jj{ll ~ iIIiliIlII'- ~=~- ~[[ 11r' I ," ,~- -il.I1o- . . (") 0 0 C -n ;;:: , 't.j r'rT '''0 p ~~l: ;,0 zc I -"f"J :JJ if) 1"_. 0') --, , ,C-n -< ~< "~'. 0 ~0 "c r".J '-ri -- (") c: r ~'1 :s ~ "'"':~ ~ :'\"J -< cr. -< ~ -,," --~ Ii ~;:I , . , . JACK E. PATTI, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 2000-8692 CIVIL TERM DEBRA L. PATTI, Defendant CIVIL ACTION - LAW ACTION IN DIVORCE PRAECIPE TO THE PROTHONOTARY: Plaintiff's Social Security *180-50-2146 Defendant's Social Security *043-56-6604 DATED: 4-4-01 ~J1'( HERSCHEL LOCK, ESQUIRE Attorney for plaintiff 3107 North Front Street Harrisburg, PA 17110 (717) 238-6661 Supreme Court No. 22691