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HomeMy WebLinkAbout03-1873SHARON L. SMITH, Plaintiff ARLIN C. SMITH, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02- 157~ CIVIL ACTION -~LAW 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 and visitation of your children. When the grounds for a divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Domestic Relations Office at the County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF TI-~M. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE Carlisle, Pennsylvania 17013 (717) 249-3166 SHARON L. SMITH, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 177,3 ARLIN C. SMITH, CIVIL ACTION - LAW Defendant IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is SHARON L. SMITH, an adult individual residing at 530 Lavina Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Defendant is ARLIN C. SMITH, an adult individual residing at 530 Lavina Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. Both Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months prior to filing this complaint. 4. The Plaintiff and Defendant were married on July 7, 1973 in New Castle, Delaware. 5. There are no minor children bom of this marriage. 6. The parties separated on April 16, 2003. There have been no prior actions for divorce or annulment between the parties. 8. Neither Plaintiffnor Defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 9. Plaintiffhas been advised that counseling is available and that Plaintiffhas the right to request that the court require the parties to participate in counseling. COUNT I - DIVORCE NO FAULT 10. The averments in paragraphs 1 through 9, inclusive, of Plaintiffs Complaint are incorporated herein by reference thereto. 11. The marriage is irretrievably broken and no possibility of reconciliation exists. WHEREFORE, Plaintiff.requests entry of a divorce decree in her favor in accordance with § 3301 of the Pennsylvania Divorce Code. COUNT H EQUITABLE DISTRIBUTION 12. The averments in paragraphs 1 through 11 of Plaintiff's Complaint are incorporated herein by reference thereto. 2 13. The Plaintiff requests the Court to equitably divide, distribute or assign the marital property between the parties in such proportion as the Court deems just after consideration of all relevant factors. WHEREFORE, Plaintiffrequests this Court to equitably divide said property in accordance with Section 401 (d) of the Pennsylvania Divorce Code. COUNT m SUPPORT, AIJMONY PENDENTE LITE AND ALIMONY 14. The averments in paragraphs 1 through 13, inclusive, of Plaintiffs Complaint are incorporated herein by reference thereto. 15. Plaintiffrequires reasonable support to adequately sustain herself with the standard of living established during the marriage. WHEREFORE, Plaintiffrequests an award of Support, Alimony and Alimony Pendente Lite. WHEREFORE, Plaintiff, judgment: A. B. C. SHARON L. SMITH, prays this Honorable Court to enter Awarding Plaintiff a decree in divorce; Awarding Plaintiff support, alimony and alimony pendente lite; Equitably distributing the marital property; and Dated: A. Awarding Plaintiff a decree in divorce; B. Awarding Plaintiff support, alimony and alimony pendente lite; C. Equitably distributing the marital property; and D. Awarding other relief as the Court~e' Barbara Sumple-Sullivan, Esquire Attorney for Plaintiff 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. No. 32317 4 SHARON L. SMITH, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. ARLIN C. SMITH, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT REGARDING COUNSEl,lNG 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 require 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.A Section 4904 relating to unsworn falsification to authorities. Dated: q ~l~O ,2003 SHARON L. SMITH SHARON L. SMITH, Plaintiff ARLIN C. SMITH, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW IN DIVORCE VERIFICATION I, SHARON L. SMITH, hereby certify that the facts set forth in the foregoing COMPLAINT IN DIVORCE are true and correct to the best of my knowledge, information and belief. I understand that any false statements made herein are subject to penalties of 18 Pa. C.S.A. Section 4904 relating to unswom falsification to authorities. Dated: Z'/-t/~ ,2003 SHARON L. SMITH Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 SHARON L. SMITH, Plaintiff ARLIN C. SMITH, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-1873 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF SERVICE I, Barbara Sumple-Sullivan, Esquire, do hereby certify that I served a copy of the Complaint In Divorce in the above-captioned matter by United States Mail, Restricted Delivery, Certified No. 7000 0600 0028 3892 3455, Return Receipt Requested, on the above-named Defendant, Arlin C. Smith, on April 28, 2003 at Defendant's last known address: 530 Lavina Drive, Mechanicsburg, Pennsylvania 17055. The original receipt and return receipt card are attached hereto as Exhibit "A". I hereby certify that the facts set forth above are true and correct to the best of my knowledge, information and beliefi I understand that any false stater~nts made herein are subject / to penalties of 18 Pa. C.S.A. {}4904 relating to unsworn falsificatio to authorities. Dated: May 2, 2003 //. ~~ mr=--~' 549 Bridge Street New Cumberland, PA 17070-1931 (717)-774-1445 Supreme Court ID #32317 Attorney for Plaintiff Postage Certified Fee Return Receipt Fee (Endorsement Required) Restricted Delivery Fee (Endorsement Required) Total Postage & Fees (Pleas; $ ~0.60 $2.30 $ $8.15 · ~ itlmS 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. · Print your name and address on the reverse · o that we can return the card to you. · Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: A. Received by (Please Print ~ B. Date of Delive7 i C. Signa re D ~ ,, [] Agent X , C~ ,I-I Addressee D, Is detive~/address different from item 17 [] Yes If YES, enter delivery address below: [] No 3. Service Type ~l~';;ertified Mail [] Express Mail [] Registered [] Return Receipt for Merchand~e [] Insured Mail [] C.O.D. EXHIBIT "A" Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 SHARON L. SMITH, Plaintiff V. ARLIN C. SMITH, Defendant 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-1873 CIVIL ACTION - LAW IN DIVORCE ORDER OF COURT AND NOW, this ~ day of ., 2003, upon' consideration of the attached Petition for Alimony Pendente Lite, it is hereby directed that the parties and their respective , the Domestic Relations Conference Officer on counsel appear before at o'clock .m. at the Domestic Relations Office located at 13 North Hanover Street, Carlisle, Pennsylvania for a conference, after which the Conference Officer may recommend that an order for Alimony Pendente and interim counsel fees and costs be entered. You are further ordered to bring to the conference: (1) (2) a true copy of your most recent Federal Income Tax Return, including W-2's as filed. your pay stubs for the preceding six (6) months. (3) the Income and Expense Statement attached to this order, completed as required by Rule 191-. 11 (c). (4) proof of medical coverage which you may have, or may have available to you. If you fail to appear for the conference or bring the required documents, the court may issue a warrant for your arrest. BY OR FOR THE COURT Date of Order: Conference Officer YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND REPRESENT YOU. 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 MAY GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE Carlisle, Pennsylvania 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is re.quired by law to comply with the American with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any heating or business before the court. You must attend the scheduled conference or hearing. BY OR FOR THE COURT: Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 SHARON L. SMITH, Plaintiff V. ARLIN C. SMITH, Defendant · IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-1873 CIVIL ACTION - LAW IN DIVORCE PETITION FOR Al JMONY PENDENTE LITE 1. Plaintiff is SHARON L. SMITH residing at 530 Lavina Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Defendant is ARLIN C. SMITH residing at 530 Lavina Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. Plaintiff lacks sufficient assets to provide for her reasonable needs and is unable to support herself fully through appropriate employment. 4. Defendant has sufficient assets to provide continuing support for Plaintiff. 5. Defendant has sufficient assets to provide alimony pendente lite for Plaintiff· WHEREFORE, Plaintiff requests the pendente lite pursuant to 23 Pa. C.S.A. 3702. Court to enter an Order awarding her alimony DATE: May ~, 2003 Respectfully submitted, n~Ptrlee;tSullivanl E squire New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. 32317 Attomey for Plaintiff SHARON L. SMITH, Plaintiff V. ARLIN C. SMITH, Defendant · IN THE COURT OF COMMON PLEAS · CUMBERLAND COUNTY, PENNSYLVANIA · NO. 03-1873 · CIVIL ACTION - LAW · IN DIVORCE VERIFICATION I, SHARON L. SMITH, hereby certify that the facts set forth in the foregoing PETITION FOR ALIMONY PENDENTE LITE are tree and correct to the best of my knowledge, information and belief. I understand that any false statements made herein are subject to penalties of 18 Pa. C.S.A. ~4904 relating to unswom falsification to authorities. DATED: Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (7_T~ 774-1445 SHARON L. SMITH, Plaintiff V. ARLIN C. SMITH, Defendant · IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-1873 CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE I, Barbara Sumple-Sullivan, Esquire, do hereby certify that on this date, I served a true and correct copy of the foregoing PETITION FOR ALIMONY PENDENTE LITE in the above-captioned matter upon the following individual(s) by first class mail, postage prepaid, addressed as follows: Reverend Arlin C. Smith 530 Lavina Drive Mechanicsburg. PA 17055 DATED: ~ ~.~.i~arVa~.~clJmple_Sullivan, Esquire Attorney for Defendant 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. No. 32317 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 SHARON L. SMITH, Plaintiff V. AR_LIN C. SMITH, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 03-1873 : : CIVIL ACTION - LAW : IN DIVORCE DR ATTACHMENT FOR APL PROCEEDINGS PETITIONER NAME Sharon L. Smith ADDRESS BIRTH DATE SOCIAL SECURITY NUMBER 221-40-5063 HOME PHONE (717) 795-9944 WORK PHONE EMPLOYER NAME EMPLOYER ADDRESS Unemployed JOB TITLE/POSITION DATE EMPLOYMENT COMMENCED GROSS PAY NET PAY OTHER INCOME ATTORNEY'S NAME ATTORNEY'S ADDRESS ATTORNEY'S PHONE NUMBER 530 Lavina Drive Mechanicsburg, PA 17055 06/20/53 Barbara Sumple-Sullivan, Esquire 549 Bridge Street, New Cumberland, PA 17070 (717) 774-1445 RESPONDENT NAME Arlin C. Smith ADDRESS BIRTH DATE SOCIAL SECURITY NUMBER 074-46-9274 HOME PHONE (717) 795-9274 WORK PHONE 530 Lavina Drive Mechanicsburg, PA 07/07/51 17055 (717) 732-6506 (717) 732-3787 Maranatha Bible Church EMPLOYER NAME EMPLOYER ADDRESS 688 Front Street West Fairview, PA 17025 JOB TITLE/POSITION Minister DATE EMPLOYMENT COMMENCED GROSS PAY $17,387.01 Annual NET PAY OTHER INCOME ATTORNEY'S NAME AYTORNEY'S ADDRESS A'I'TORNEY'S PHONE NUMBER MARRIAGE INFORMATION DATE OF MARRIAGE July 7, 1973 New Castle, Delaware PLACE OF MARRIAGE DATE OF SEPARATION ADDRESS OF LAST MARITAL HOME DESCRIPTION OF DOCUMENT RAISING APL CLAIM DATE APL DOCUMENT FILED April 16, 2003 530 Lavina Drive Mechanicsburg, PA 17055 Divorce Complaint filed on April 23, 2003 SHARON L. SMITH, Plaintiff/Petitioner VS. ARLIN C. SMITH, Defendant/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE NO. 2003-1873 CIVIL TERM IN DIVORCE Pacses# 294105652 ORDER OF COURT AND NOW, this 23~ day of July, 2003, upon consideration of the attached Petition for Alimony Pendente Lite and/or counsel fees, it is hereby directed that the parties and their respective counsel appear before R.J. Shadday on August 25t 2003 at 9:00 A.M. for a conference, at 13 N. Hanover St., Carlisle, PA 17013, after which the conference officer may recommend that an Order for Alimony Pendente Lite be entered. YOU are further ordered to bring to the conference: (1) a tree copy of your most recent Federal Income Tax Return, including W-2's as filed (2) your pay stubs for the preceding six (6) months (3) the Income and Expense Statement attached to this order, completed as required by Rule 1910.11© (4) verification of child care expenses (5) proof of medical coverage which you may have, or may have available to you IF you fail to appear for the conference or bring the required documents, the Court may issue a warrant for your arrest. BY THE COURT, George E. Hoffer, President Judge Mail copies on Petitioner 7-23-03 to: < Respondent Barbara Sumple-Sullivan, Esquire Date of Order: July 23, 2003 ,~ :2' ~lS,?J. Sh~day, C~nf~¥en~e 6fficer -- ~ YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND(/ REPRESENT YOU. 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 MAY GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVE. CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 CC361 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION SHARON L. SMITH ) Docket Number Plaintiff ) vs. ) PACSES Case Number ARLIN C. SMITH ) Defendant ) O~ler State ID Number 03-1873 CIVIL 294105652 Order AND NOW to wit, this that: AUGUST 25, 2003 it is hereby Ordered THE DEFENDANT, ARLIN C. SMITH, MAINTAIN THE CURRENT MEDICAL COVERAGE PLJkN ON HIS WIFE, THE PLAINTIFF. ANY UNREIMBURSED MEDICAL EXPENSES THAT EXCEED $250.00 PER YEAR FOR THE PLAINTIFF ARE TO BE SPLIT PROPORTIONATELy AND DEFENDANT WILL BE OBLIGATED TO PAY 56% OF HER UNREIMBURSED EXPENSES THAT EXCEED $250.00 PER YEAR. DRO: RJ Shadday xc: plaintiff d~f~ndant Barbara Sumple-Sullivan, Esquire Service Type M BY THE COURT: Edw-drd E. Guido JUDGE Form OE-001 Worker 21oo5 THIS AGRE Smith, hereinafter re "WIFE." VVITNESSEI WHEREAS MARITAL SETTLEMENT AGREEMENT *.MENT, made this ~// day of October, 2003, by and between Arlin C. ~rred to as "HUSBAND," and Sharon L. Smith, hereinafter referred to as H, That: he parties hereto are husband and wife, having been lawfully joined in marriage on July 7, WHEREAS, WHEREAS financial and propert relationship or othep relating to the owner them relating to the WIFE; and (3) the setl interests, claims and p~ NOW THERt reference and deemed mutual promises, cove~ October 14, 2003 1 ,73 in New Castle, Delaware; *ur (4) children were born of this marriage; however, none are minors; : is the intention of the parties to settle fully and finally their respective rights and obligations as between each other arising out of the marriage .se, including without limitation (1) the settling of all matters between them tip of real and personal property; (2) the settling of all matters between st, present and future support and/or maintenance of HUSBAND and ling of all matters between them relating to any and all fights, titles and ~ssible claims in or against the estate of the other. FORE, with the foregoing recitals being hereinafter incorporated by m essential part hereof in consideration o:~'the foregoing recitals, the rants and undertakings herein set forth, and for good and valuable consideration, receip and WIFE, each inte~ 1. ADVICE O} HUSBAND ~ obtain independent It represented by Barba representation and de that attorney for WIF HUSBAND has chos, HUSBAND hereby a~ and has been fully inf( received more or less rights, if any, to utiliz~ Agreement. Each par voluntarily, having ob' Each party acknowled fraud, coercion, dures: October 14, 2003 of which is hereby acknowledged by each of the parties hereto, HUSBAND tding to be legally bound hereby, covenant and agree as follows: SECTION I GENERAL PROVISIONS COUNSEL ad WIFE declare that they have each had a full and fair opportunity to ;al advice of counsel of their selection. WIFE has been independently 'a Sumple-Sullivan, Esquire. HUSBAND is cognizant of his right to legal :lares that he has chosen not to retain an attorney notwithstanding the fact E has told him that he has an absolute right to be represented by an attorney. ~n instead to negotiate directly with counsel and/or with his WIFE. knowledges that he has done so willingly and he fully understands the facts rmed and understands that, had a Court decided this matter, he may have :han is provided for in this Agreement. HUSBAND knowingly waives his , the lack of his legal representation as a basis to attack the validity of this further declares that they are executing this Agreement freely and ined such knowledge and disclosure &their legal rights and obligations. *s that this Agreement is fair and equitable and is not the result of any undue influence or collusion. 2 Both parties financial situations tc acknowledge and ag~ this Agreement is fai~ and in good faith an influence, coercion, 2. PERSONAL HUSBAND shall be free from all all respects as if she c of this Agreement. E for his or her separat~ profession or empl'oy~ taken, however, to be of the causes, which 1, WIFE shall not mole~ compel the other to c the peaceful existence October 14, 2003 Urther acknowledge and agree that each has fully disclosed their respective the other, including their assets, liabilities and income. Each of the parties ee that, after having received such information and with such knowledge, reasonable and equitable and that it is being entered into freely, voluntarily :hat the execution of this Agreement is not the result of any duress, undue ~llusion and/or improper or illegal Agreement. RIGHTS ad WIFE may and shall, at all times hereafter, live separate and apart. Each :ontrol, restraint, interference or anthority, direct or indirect, by the other in he were unmarried, except as may be necessary to carry out the provisions ch may reside at such place or places as :she or he may select. Each may, use or benefit, conduct, carry on and engage in any business, occupation, aent which to him or her may seem advisable. This provision shall not be an admission on the part of either HUSB AND or WIFE of the lawfulness ~d to, or resulted in, the continuation of their living apart. HUSBAND and harass, or malign the other or the respective families of each other, nor habit or dwell in any manner with him or her, nor in any way interfere with separate from each other. 3 3. FINANCIAl The parties h~ liabilities, holdings ar accurately described she is aware of his or interrogatories, motk available through the have had the right to information is necess~ 4. MUTUAL C, The parties ir of Section 3301 (c) of necessary to effectuat Agreement. The parties ag simultaneously with tt 5. SUBSEQUE~ A decree in dix October 14, 2003 , DISCLOSURE ire fully complied with the other's requests for disclosure of income, assets, estate. Each party warrants that the infurmation provided has fully and extent of his or her holdings. Each of the parties acknowledge that he or her right to seek discovery including, but not limited to, written ns for document production, depositions, and other means of discovery Pennsylvania Rules of Civil Procedure. The parties acknowledge that they have property fully appraised. Each party is fully satisfied that no additional .ry for the execution of this Agreement. )NSENT D1VORCE end to secure a mutual consent, no fault divorce pursuant to the provisions the Divorce Code of 1980, as amended and will execute the documents a divorce under those provisions concurrently with the execution of this :e that the Affidavits of Consent and the Waivers of Notice shall be signed is Agreement. T D1VORCE orce, entered by the court of Cumberland County, shall not suspend, 4 supersede or affect contained herein, as upon the granting of Cumberland County, shall remain in full fo or attempt reconcili~ not be a modificatio by both parties, exect null and void. Both 1; but shall not be deem 6. OTHER DO~ HUSBAND forthwith execute an releases, satisfactions. proper effectuation ot 7. MUTUAL Ri Except as oth{ A. Each I the other and the esta either may have or at October 14, 2003 terms of this Agreement. This Agreement, and the terms and conditions ~11 as the enforcement of said terms and conditions, shall not be contingent a Divorce Decree to either party by the Court of Common Pleas of Pennsylvania, or any other Court of competent jurisdiction. This Agreement 'ce and effect even if the parties reconcile, cohabit as HUSBAND and WIFE ion. This Agreement shall continue in full force and effect and there shall or waiver of any of the terms hereof unless the parties, in a writing signed tea statement declaring this Agreement or any term of this Agreement to b~ arties hereto agree that this Agreement mtay be incorporated by reference ~d merged into any judgment or decree for divorce obtained by either party. 2UMENTATION id WIFE covenant and agree that upon request of the other party, they will deliver to the other party, any and all written instruments, assignments, deeds, notes or such other writings as may be necessary or desirable for the this Agreement. ;LEASES wise expressly provided by this Agreement. my hereby absolutely and unconditionally releases and forever discharges e of the other for all purposes from any and all rights and obligations which [ny time hereafter have for past, present or future support or maintenance, alimony pendente lite right or obligation, e* otherwise, including supplements and amc only except all rights: under this Agreemen obligation to the oth B. Each the other and his or l all rights, claims, den the parties or otherw! effective regardless o engagements or liabil exemption or similar spouse's will, or the rights of a surviving laws of Pennsylvania country. It is express subsequent entry of a insurance proceeds at the beneficiary design right of either party tt his or her will, or to a other, whether such v C Excep' have, and except for are expressly reserve, absolute and uncondit demands whatsoever. other. 8. SUCCESSI This Agreeme~ the benefit of the parti assigns. October 14, 2003 , alimony, equitable distribution, counsel Fees, costs, expenses and any other ;onomic or otherwise, whether arising out of the marital relationship or dl rights and benefits under the Pennsylvania Divorce Code of 1980, its ndments, as well as under any other law of any other jurisdiction, except and agreements and obligations ofwhatsoew,~r nature arising or which may arise or for the breach of any provision thereefi Neither party shall have any r not expressly set forth herein. ~arty hereby absolutely and unconditionally releases and forever discharges ,r heirs, executors, administrators, assigns, property and estate from any and ands or obligations arising out of or by virtue of the marital relationship of se, whether now existing or hereafter arising. The above release shall be ?whether such claims arise out of any former or future acts, contracts, ties or the other or by way of dower, cun:esy, widow's rights, family fllowance, or under the intestate laws, or the fight to take against the ght to treat a lifetime conveyance by the other as testamentary, or all other pouse to participate in a deceased spouse's estate, whether arising under the any state, commonwealth or territory or the United States, or any other ly understood, however, that neither the provisions of this release nor the divorce decree are intended to defeat the fight of either party to receive any the death of the other of which she or he is the named beneficiary (whether ~tion was made prior or subsequent to execution hereof), nor to defeat the , receive any legacy, bequest or residuary portion of the other's estate under :t as personal representative or executor iif so named by the will of the 'ill was executed prior or subsequent to this Agreement. for any cause of action for divorce which either party may have or claim to he obligations of the parties contained in this Agreement and such rights as herein, each party gives to the other by tlhe execution of this Agreement an [onal release and discharge from all causes of action, claims, rights or in law or in equity, which either party ever had or now has against the ?S RIGHTS AND LIABILITIES shall, except as otherwise provided herein, be binding upon and inure to ~ hereto, their respective heirs, executors, administrators, successors or 6 9. SEVERABI If any provisi, invalid, void, or unen and effect without be 10. ENTIRE AG HUSBAND of the representation purposes set forth in representations not h, enforced or enforcea 11. BINDING E This Agreeme~ pursuant to the terms The failure of e Agreement shall not b~ nature, nor shall such f provision of this Agree October 14, 2003 ,ITY ~n in this Agreement is held by a court of competent jurisdiction to be ~)rceable, the remaining provisions shall nevertheless continue in full force ng impaired or invalidated in any way. REEMENT id WIFE do hereby covenant and warrant: that this Agreement contains all >romises and Agreements made by either of them to the other for the ae preamble hereinabove; that there are no claims, promises or rein contained, either oral or written, which shall or may be charged or unless reduced to writing and signed by both of the parties hereto. ECT OF AGREEMENT/WAIVER t shall remain in full force and effect unless and until terminated under and ~fthis Agreement. ither party to insist upon strict performance of the provisions of this construed as a waiver of any subsequent default of the same or similar filure be construed as a waiver of any other term, condition, clause or aaent. 7 12. BREACH If either parl right, at his or her relief as may be avail~ for payment of reaso~ this Agreement. 13. CONTROLI This Agreeme Commonwealth of P 14. TAX RETU~ The parties al declare income or th~ Internal Revenue Sev consequence of the breaches any provision of this Agreement, the other party shall have the ction, to sue for damages for such breach or seek such other remedies or [ble to him or her, and the party breaching this contract shall be responsible table legal fees and costs incurred by the other in enforcing their fights under ,ING LAW nt shall be construed and governed in accordance with the laws of the nnsylvania. tee that in the future if any penalties or interest or any liability for failure to wrongful claiming of any deduction shall be assessed by the United States 'ice or the Commonwealth of Pennsylvania, or any other state as a rties' Federal and State income tax returns which were filed jointly by the parties, said tax, pena failed to provide the r grossly negligent erro assessment. In that sit October 14, 2003 ties or interest shall be the sole responsibility of the party found to have ecessary information leading to the tax assessment or whose intentional or or omissions in reporting or failure to report or file income resulted in the ttion, the party responsible for the assessment of liability shall indemnify and save harmless the result of a computati~ conduct of either par penalties and interest During the m~ disposition of which i 1. ASSETS A. PERS HUSBAND al marital and marital pe clothes, furniture, and of the date of executk parties agree that all Agreement shall be ti specifically waive, rek have with respect to a: other. October 14, 2003 other from all additional tax, penalty, and interest. If the liability is the ~n error or an error not attributable to the intentional or grossly negligent y, the parties shall share equally in all future tax liability or tax assessment, SECTION H EQUITABLE DISTRIBUTION rriage, the parties have accumulated various assets and liabilities, the intended as follows: )NAL and HOUSEHOLD PROPERTY td WIFE do hereby acknowledge that they have heretofore divided the non- · sonal and household property, including but without limitation, jewelry, other assets. The parties agree that all assets in the possession of WlFE as of this Agreement shall be the sole and separate property of WIFE. The ets in the possession of HUSBAND as of the date of execution of this : sole and separate property of HUSBAND. Each of the parties do hereby ase, renounce and forever abandon whatever claims, if any, he or she may , of the above said items which are the sole and separate property of the This docum~ B. REA 1. The p~ County, Pennsylvani, The parties presently upon sale, the net prc a) b) The p, expeditiously as possi terminate that contra~ Realtors at a price su day of the date oflisti intervals. The price r{ automatically reduce t work together to ensu price. October 14, 2003 t shall constitute a bill of sale for said sole property. · ESTATE 530 Lavina Drive ;rties jointly own property at 530 Lavina ]Drive, Mechanicsburg, Cumberland Said house is unencumbered and all taxes and insurance are paid current. rave the house listed with "For Sale by Owner." The parties agree that ceeds shall be divided as follows: WIFE shall receive the first NINETY TttOUSAND DOLLARS ($90,000.00) of the proceeds; and HUSBAND shall receive the remainder. /ties both indicate the mutual agreement to sell the property as >le. In the event the house is not sold within sixty (60) days, they agree to ~. in accordance with its terms and shall list the property with Jack Gaughen gested by the realtor. In the event the house is not sold within sixty (60) ~g, they agree to adjust downward the price of the home in thirty (30) day duction can be reached upon consultation with the realtor, the price shall y three (3%) percent per month thereafter until sale. Each party agrees to 'e the home is maintained at optimum condition to bring the highest sale 10 o HUS[ Gunden Subdivision Christian M. Smith. property (approxim~ were that of his fath that TEN THOUSA card and those funds Based agrees to presently rel promissory note due WIFE agrees to sign joint marital credit ca owing by son to HUS WIFE waives any clai: the full repayment oft estates of these partie~, a) b) October 14, 2003 Son's Property AND has also acquired an interest in real estate known as Lot No. 3, Warrington Township, York County, Permsylvania with the parties' son, tUSBAND warrants that all monies advanced in the purchase of this ~ly FORTY-THREE THOUSAND EIGHTY DOLLARS ($43,080.00)) Charles E Smith and were not marital funds. It is further acknowledged DOLLARS ($10,000.00) was charged by HUSBAND on a marital credit vere used to acquire the home. an HUSBAND's representations that the monies were his father's, WIFE inquish her marital interest in said property and claims to the proceeds ora nd owing by their son. This house is currently under contract for sale. quitclaim deed provided that the proceeds are initially used to satisfy the fl and said card account is then closed. The note for the remainder due and 3AND, as trustee for his father, shall be paid by son to said grandfather. n to said monies. However, if HUSBAND and his father should predecease ae debt, it is agreed that any debt outstanding shall then be handled by the as follows: One-third (1/3) shall be forgiven for Christian M. Smith; One-third (1/3) shall be paid by Christian M. Smith to son, Shawn Smith; 11 c) HUSBAND underlying the transt 3. The p Mobile Home. Said E DOLLARS ($9,500.( sign any and ail title C. MO'I At the time 1. 2. 3. 4. 5. 6. 7. 8. October 14, 2003 and One-third (1/3) shall be paid by Christian M. Smith to son, Jeremy Smith. hall provide notice to WIFE of full satisfaction by the son of the note ,r as marked paid in full. Mobile Home ,rties additionaily have ownership of a 1986 Fleetwood Manufactured ~me has a value of approximately NINE THOUSAND FIVE HUNDRED ,0). Said home shall be the sole property of HUSBAND. WIFE agrees to ocuments necessary to transfer said trailer to HUSBAND. )R VEHICLES separation, the parties owned or had interest in various vehicles as follows: 1994 Pontiac Sedan, V1N #1G2HX52LSR4220435; 1998 Ford Truck, VIN #2FTZA54USWBD23766; 1994 Laredo Jeep, VIN # 1J4GZ58 S6RC265843; 1990 Cadillac Sedan, VIN # 1G6CB5334L4260539; 1988 Ford Truck, VIN #1FTHX25G3JKA66757; 1993 Dodge Sedan, VIN #2B3ED56F6PH639493; 1981 Duke, #ZDI9246; and 1987 Blue Fin 19' Sportsman Boat. 12 With the exce separate property church. WIFE shall has no interest in the this vehicle to W1FE agrees to pay insuran, At the 1. October 14, 2003 BAN]~ time of Penns' Titled:' At the THOU ($5,38: satisfa{ Penns2 Titled: At the TWO q ($42,72 of his g persom funds a accoun~ AIIFirs Titled: This ac~ ~tion of the 1994 Laredo Jeep, all vehicles shall become the sole and [USBAND or his church, as appropriate in regard to his agreement with the ave sole ownership of the 1994 Jeep. HIJSBAND warrants that his church ~ehicle transferred to WIFE. HUSBAND shall cooperate to transfer title of tnd HUSBAND waives any and all claims to said vehicle. HUSBAND ',e on said vehicle through the conclusion of calendar year 2003. ACCOUNTS separation, the following accounts exist: ,lvania State Bank, Account No. 10400141 Arlin C. Smith and Sharon L. Smith. :ime of separation, said account had an approximate balance of FIVE SAND THREE HUNDRED EIGHTY-TWO DOLLARS and 18/100 !.18). This has been divided equally between the parties to their tion. Ivania State Bank, Account No. 26400473 (Out Bac Money Market) Arlin C. Smith and Sharon L. Smith ime of separation, this account had a balance of approximately FORTY- 'HOUSAND SEVEN HUN-DRED THIRTY DOLLARS and 73/100 0.73). HUSBAND warrants that this account contained solely the monies :andmother, Ethel Slusher despite HUSBAND's use of same for various 1 transactions. Ba.s, ed on said representations and in reliance that these 'e all Ethel Slusher s monies, WIFE waiw~s any and all claims in said Bank, Account No. 10551921 ~rlin C. Smith and Sharon L. Smith :ount has been divided to the mutual agreement of the parties. 13 4. AIIFi~ (now This a This a that tt for va fun& accou'. 5. AIIFir This a, The bl ($8,oo father repres, moni, HUSBAND' controlled these acc and all claims, includi~ costs incurred by her i account. E. COIN! The parties hac parties. October 14, 2003 st Bank, Account No. 09502-8200-5 M&T Bank, Account No. 10551506) :count is titled: Arlin C. Smith and Ethel Slusher :count had a date of separation value ofF. LEVEN THOUSAND ONE )RED TWO DOLLARS and 50/100 ($11,102.50). HUSBAND warrants is account contains the assets of his grandmother despite HUSBAND's use ious transactions. Based on said representation and in reliance that these tre all HUSBAND's father's monies, WIFE waives any and all claims to said rt. ~t Bank, Account No. 001678471-5 :count is titled: Arlin C. Smith and Charles E. Smith lance of this account is approximately EIGHT THOUSAND DOLLARS 3.00). HUSBAND warrants that this account contains the asset of his iespite HUSBAND's use for various transactions. Based on said ,,ntation and in reliance that these funds are all HUSBAND's father's WIFE waives any and all claims to said account. xrants and acknowledges that he has been the individual who has nts. HUSBAND agrees to indemnify and hold WIFE harmless from any g misappropriation or mishandling of said funds, and to pay any and all defense of any actions brought against her because she was named on any ;/COLLECTABLES various coins and collectibles. These shall be shared equally by the 14 F. LAW The parties hi wrongful death of the reimbursement of rea of Angela Smith, shal G. PENS Each party wa H. INSU] Each party sh, 2. DEBTS. Each party re which the estate offi herein, and that excepl hereafter incur any lia[ will be liable. With thi Christian's home, whir parties confirm no oth~ WIFE harmless for thi~ October 14, 2003 ~UIT vea civil lawsuit pending captioned Smith v. Greenfield, arising out of the ir daughter, Angela Smith. The parties agree that any and all proceeds after ;onable counsel fees, costs and expenses, or any sums realized for the Estate be shared equally between them. IONS AND EMPLOYMENT BENEFITS rrants that the other has no pension or other employment benefit. tANCE retain ownership of any life insurance policy in his or her name. ~sents that they have not contracted any debt or liability for the other for other party may be responsible or liable except as otherwise provided only for the rights arising out of this Agreement, neither party will ility whatsoever for which the other part)' or the estate of the other party exception of the credit card debt relating; to the debt associated with debt will be satisfied from the proceeds of the sale of the home, the debt or joint credit cards exist. HUSBAND agrees to indemnify and hold credit card debt. Each party agrees to indemnify and hold harmless from 15 and against all futur The parties SI Both parties t equitable distribution accepted by them in li may now or hereafter pendente lite. HUSB~ any right to seek from and maintenance. Ho~ insurance on WIFE un October 14. 2003 obligations of every kind incurred by them, including those for necessities. -ther confirm that all joint credit cards haYe been terminated. SECTION HI 'PPORT, ALIMONY PENDENTE LITE, ALIMONY :knowledge and agree that the provisions of this Agreement providing for ~f marital property are fair, adequate and satisfactory to them and are ,~u of and in full and final satisfaction of any claims or demands that either have against the other for support, maintenance, alimony or alimony dx~D and WIFE further, voluntarily and intelligently, waive and relinquish the other any payment for spousal support, alimony, alimony pendente lite ?ever, HUSBAND agrees at his cost to continue to maintain medical :il she is able to secure same through an employer. 16 1. CONDITIOb The parties SECTION IV PRECEDENT TO THE AGREEMENT'S EFFECTIVENESE :nowledge that this Agreement shall become effective when actually signed by both parties. October 14, 2003 A~Jn C~ Smith Shad'on L. Sm~t~ -"-- ' 17 COMMONWEALT~ I OF PENNSYLVANIA COUNTY OF ~.~?~ ) ) ss ) Before me, th County, personally at deposes and says thai Settlement Agreem~ Affirmed and / T Y-PUBLIC My cq, ........ s.v.fl~5?[g JAMES E. GRE Camp Hill, Cur My Commission E COMMONVOgALTI- COUNTY OF CUMt Before me, th County, personally a[ deposes and says that Settlement Agreeme Affirmed and mission expir NOTA JAMES E. GE Camp Hill, C My Corem ss on October 14, 2003 undersigned officer, a Notary Public in and for said Commonwealth and >eared ARLIN C. SMITH, who being duly affirmed according to law, the facts and matter set forth in the within and foregoing Marital nt are true and correct to the best of his knowledge, information and belie£ ~ubscribed to before me this day of October, 2003. ~'1~ SEAL I ;N, Notary Public [ ~bedand County <pires June 6, 2005 i OF PENNSYLVANIA ~EKLAND (SEAL) ) )ss. ) ; undersigned officer, a Notary Public in and for said Commonwealth and peared SHARON L. SMITH who being duly affirmed according to law, the facts and matter set forth in the within and foregoing Marital at are true and correct to the best of her knowledge, information and belief. ;ubscribed to before me this :~IAL SEAL =EN, Notary Public ~ Jmberland County ~ Expires June 6, 2005[ day of October, 2003. (SEAL) 18 Barbara Surnple~Sullivar Supreme Court #32317 549 Bridge Street New Cumberland, PA 17 (717) 774-1445 SHARON L. SMIT} Plaintiff V. AR.LIN C. SMITH, Defendant 1. A Con April 23, 2003. 2. The m have elapsed since th~ 3. I conse intention to request en 4. I unden ' awyer s fees or expens 5. I verify that false statements ar, unsworn falsification tc Esquire )70 : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 03-1873 : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENI'_ ~lalnt in Divorce under Section 3301 (c) of the Divorce Code was filed on fiage of the Plaintiff and Defendant is inetrievably broken. Ninety days filing and service of the Complaint. ~t to the entry of a final decree of divorce after service of notice of :fy of the decree. tand that I may lose rights concerning alimony, division of property, ~s ifI do not claim them before a divorce is granted. :hat the statements made in this affidavit are true and correct. I understand ~ made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to authorities. DATE: ~.~, 2003 SItARON L. SMITH Barbara Sumple-Sullivar Supreme Court #32317 549 Bridge Street New Cumberland, PA 17 (717) 774-1445 SHARON L. SMIT Plaintiff ARLIN C. SMITH, Defendant 1. I conse 2. Iundm lawyer's fees or expen 3. I under Court and that a copy, prothonotary. I verify that the, false statement herein ar falsification to authoritie ,Esquke )70 : IN THE COURT OF COMMON PLEA---~-'~ : CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-1873 CIVIL ACTION - LAW 1N DIVORCE IVER OF NOTICE OF INTENTION TO REQUESI' _ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE at to the entry ora final decree of divorce without notice. ;tand that I may lose rights concerning alimony, division of property, ~s ifI do not claim them before a divorce is granted. !and that I will not be divorced until a divorce decree is entered by the fthe decree will be sent to me immediately at~er it is filed with the ~tatements made in this affidavit are true and correct. I understand that made subject to the penalties of 18 Pa.C,.S. ,~904 relating to unsworn )03 SHARON L. SMITH Barbara Sumple-Sullivan, Supreme Court #32317 549 Bridge Street New Cumberland, PA 170 (717) 774-1445 SHARON L. SMITH Plaintiff V. AP, LIN C. SMITH, Defendant 1. A Con April 23, 2003. 2. The mn have elapsed since the 3. I conse intention to request en 4. I unden lawyer's fees or expens 5. I verify that false statements ar unswom falsification 1 Esquire 70 : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA · NO. 03-1873 : CIV1L ACTION - LAW · 1N DIVORCE AFFIDAVIT OF CONSENT dalnt in Divorce under Section 3301(c) c,fthe Divorce Code was filed on riage of the Plaintiff and Defendant is irretrievably broken. Ninety days filing and service of the Complaint. to the entry of a final decree of divorce after service of notice of ' of the decree. tand that I may lose rights concerning alimony, division of property, :s ifI do not claim them before a divorce is granted. :hat the statements made in this affidavit are true and correct· I understand made subject to the penalties of 18 Pa. C S.A. Section 4904 relating to authorities. DATE: / O' O2 / 2003 COMMONWEALTE COUNTY OF Before me, th~ County, personally ap and says that the facts CONSENT are true Affirmed and OF PENNSYLVANIA ) )SS. undersigned officer, a Notary Public in and for said Commonwealth and 3eared Arlin C. Smith, who being duly affirmed according to law, deposes and matter set forth in the within and foregoing AFFIDAVIT OF nd correct to the best of his knowledge, information and belie£ ubscribed to before me this ~,~ / day ofd~W_~'~, ,2003. //b~T~U~LIC ~[ - /J My Commission Expi4es: [" NOTARIAL SEAL "-] // (SE~ / [ JAMES E. GREEN, Nota~ Public ~ ~ ~ Camp Hill, Cumberland County ~ ~M~ Commission Expire~ June 6, 200~ 2 Barbara Sumple-Sullivan Supreme Court #32317 549 Bridge Street New Cumberland, PA 17 (717) 774-1445 SHARON L. SMITE Plaintiff ARL1N C. SMITH, Defendant W 1. I cons 2. I un& lawyer's fees or expe 3. I und~ Court and that a co prothonotary. I verify that false statement herei: Esquire 7O 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-1873 CIVIL ACTION - LAW IN DIVORCE LIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(C) OF THE DIVORCE CODE ent to the entry of a final decree of divorce without notice. rstand that I may lose rights concerning alimony, division of property, ~ses ifI do not claim them before a divorce is granted. ~.rstand that I will not be divorced until a divorce decree is entered by the of the decree will be sent to me immediately after it is filed with the statements made in this affidavit are tree and correct. I understand that are made subject to the penalties of 18 Pa.C.S. {}4904 relating to unsworn falsification to autho [ties. DATE: .A~RI~IN C. SMIT~ COMMONARE~TF COUNTY OF Before me, th County, personally al; and says that the fact: OF INTENTION Ti OF THE DIVORC[ beliefi Affirmed and OF PENNSYLVANIA ) ) SS. ; undersigned officer, a Notary Public in and for said Commonwealth and peared Arlin C. Smith, who being duly affirmed according to law, deposes and matter set forth in the within and foregoing WAIVER OF NOTICE ) REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(d) CODE are true and correct to the best of his knowledge, information and subscribed to before me this ,:~// day ofe~"~:~~-- ~ 2003. /t~T ~d~-V ~UB Li ~--] - ~Vly Commission Expires: I NOTARIAL SEAL I JAMES E. GREEN, Nota~ Public (SE~) ~ Camp Hill, Cumberland County My Commission Expires June 6, 2005] 2 Barbara Sumple-Sullivan Supreme Court #32317 549 Bridge Street New Cumberland, PA 17~ (717) 774-1445 SHARON L. SMITI: AP, LIN C. SMITH, To the Prothonotar Transmit the divorce decree: 1. Ground f 2. Date and n Restricted Delivery 3. Date of ex Code: by Plaintiff Oc 4. Related cla: Settlement Agreemel but not merged into 5. Date Plainti October 23, 2003. D. Prothonotary: Octobe Dated: October 22, 2( Esquire ~70 Plaintiff Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-1873 · CIVIL ACTION - LAW : IN DIVORCE PRAECIPE TO TRANSMIT RECORD cord, together with the following information, to the court for entry of a divorce: Irretrievable breakdown under §3301(c) of the Divorce Code. anner of service of the complaint: United States Mail, Certified Mail, n April 28, 2003. cution of the affidavit of consent required by' 3301(c) of the Divorce ~ber 21, 2003; by Defendant October 21, 2003. ms pending: All matters have been resolved pursuant to the Marital ~t reached by the parties dated October 21, 2003 and incorporated, :he Decree. See Paragraph 5, page 4 of the Agreement. frs Waiver of Notice in §3301(c) Divorce was<l .led with Prothonotary: itc Defendant's Waiver of Notice in '3301(6) 1~ ,orce was filed with 23,2003. i/'~/ ~' Barbara/st~mple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 (717)-774-1445 Supreme Court ID #32317 Attorney for Plaintiff Barbara Sumple-Sull Supreme Court #323 549 Bridge Street New Cumberland, Pi (717) 774-1445 SHARON L. SMIT} Plaintiff Defendant I, Barbara Su and correct copy of th upon the following in¢ DATED: October 22, van, Esquire 17 17070 : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA · NO. 03-1873 : CIVIL ACTION[- LAW : IN DIVORCE CERTIFICATE OF SERVICE ~le-Sullivan, Esquire, do hereby certify that on this date, I served a tree foregoing Praecipe to Transmit Record, in the above-captioned matter ividual by first class mail, postage prepaid, addressed as follows: 2003 Reverend Arlin C. Smith 530 Lavina Drive .~/;~ Mechanicsburg, PA 17055 ~ ///~ ~;~--b-~ara Su~nple-Sullivan, Esquire Attorney for Plaintiff 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. No. 32317 IN THE SHARONL. SMITH Plaintiff ARLIN C. SMITB Defendant AND NOW DECREED THAT AND ARE D~VORCED THE COURT BEEN RAISED OF YET BEEN ENTE~q All matters ha, reached into the + + + + ++ COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE Of PENNA. SUS DECREE IN DIVORCE SHARON L. SMITH , PLAINTIFF, ARLIN C. SMITH , DEFENDANT, F ~OM THE BONDS OF MATRIMONY. R :-TAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE RECORD IN THIS ACTION FOR WHICH A FINAL ORDEr HAS NOT ED; 'e been resolved pursuant to the Marital Settl~me~nt Agreement ~rties dated October and incorporated, but not mer, , 2003 , it is ORDERED AND ATTEST: THE Cou '~ - - "~ ' ' - /PROTHONOTARY NO. 03-1873