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HomeMy WebLinkAbout01-1733 FX . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ~ ~ ~ ~ ~ ~ ~ ~~~ ~~ ~~~~~ ~ ~~~~~~ ~~ ~ ~ ~~~~~ ~~~ ~~ ~~~~~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. JENNIFER S. BURTNER, Plaintiff No. 01-1733 CIVIL TERM VEHSUS GEORGE M. BURTNER, Defendant DECREE IN DIVORCE AND NOW, ~30 c.A /.{:o df./II- 2005 , IT IS ORDERED AND DECREED THAT JENNIFER S. BURTNER , PLAINTIFF, AND GEORGE M. BURTNER , 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; The Marital Settlement 2001 is 20 incorporated but not merged ArrE"/~, PROTHONOTARY . . ~ ~ ~ ~~~ ~ ~~ ~ ~~~~~ ~ ~ ~~~ ~~ ~ ~~~~~ ~~ ~~ . -", O'!~ o"'~' A", I,," '1 ~ 1-' ',',",,- ~' T , .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J. . . . . . . . . "'''''''''' ",Of. "~ . ,~~;JIfjj~iIoll~~~mooijU,u,iA!miU!;~",N~;!(~'$kl"",",.'"~#"'>i:LlOOri]""~'-''''''''''''''''-''''''''''',,~............,~~ ~~- -'~~" c ._ _iLl /f1/i 51 ''1l~'~'\ ~ \Jj' " . " '-...; ~ ~.\'. . . . ) - ~-~-a5 a/- (1~~ .Q~ ~ f.~~~~~ '$~_ UIL__ lti '. . . 'II ~fl~l~flLS~TTL~~~~fl9~~~~~~ THIS AGREEMENT, is made this dDIl-h dayof ~evm6.eA ,2001, by and between JENNIFER S. BURTNER, of Mechanicsburg, Cumberland County, Pennsylvania, hereinafter referred to as "Wife" and GEORGE M. BURTNER, of Camp Hill, Cumberland County, Pennsylvania, hereinafter referred to as "Husband." WHEREAS, the parties were married on November 21, 1998; and WHEREAS, in consequence of disputes and unhappy differences, the parties have separated and are now and for some time have been living apart from each other and since their separation, have agreed to live separately and apart during the rest of their lives; and WHEREAS, the parties desire to confirm their separation and make arrangements in connection therewith, including the settlement of their property rights and any other rights and obligations growing out of the marriage relationship. IT IS THEREFORE AGREED by and between the parties that: 1. CONSIDERATION. The consideration for this Agreement is the mutual promises and agreements herein contained. 2. SEPARATION. It shall be lawful for each party at all times hereafter to live separate and apart from the other party at such place or places as he or she may from time to time choose or deem fit. 3. NO INTERFERENCE. Each party shall be free from interference, authority and control, direct or indirect, by the other as fully as if he or she were single and unmarried. Neither shall molest the other, nor compel, nor endeavor to compel the other to cohabit or dwell with him or her. 4. DIVISION OF MARITAL AND PERSONAL PROPERTY. Other than as otherwise set forth in this Agreement, the parties hereto agree that the marital property and personal property of the parties has been divided to their mutual satisfaction. The parties agree !hat they shall retain all personal property in their respective possession and waive all rights as to marital property and personal property in the possession of the other '" ';':1:~--,~ "0,7 ~ ' 'J.. ,,- ~~ -(-" _,h" " " , ~.~>' '. ",...", "';" spouse as of the date of the execution of this Agreement except that Wife hereby agrees to allow Husband to store the following items of personal property at her residence until such time as he is able to remove them, or one year from the date of this Agreement: burgundy love seat and sofa, entertainment center, oak gun cabinet, work bench and tools. 5. RELEASE OF INTEREST IN SEPARATE ASSETS. The parties hereto agree to waive any and all right to claim any interest or share in the separate assets retained by the other spouse. This waiver and release specifically includes any interest in each other's pension, employee benefits, life insurance, business interests, and any and all other separate assets. 6. WAIVER OF CLAIMS AGAINST ESTATES AND MUTUAL RELEASE. Each party may dispose of his or her property in any way and each party hereby waives and relinquishes any and all right he or she may now have or may hereafter acquire, under the present or future 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, thirds, courtesy, allowance, widow's allowance, homestead rights, right to take in intestacy, right to take against the will of the other, right to act as administrator/executor of the other's estate, and each party 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. The parties hereto have been informed of their rights or have been advised to seek counsel to inform them of their rights under and pursuant to the Divorce Code, particularly the provisions concerning alimony, alimony pendente lite, equitable distribution of marital property, counsel fees or expenses. Both parties agree that this Agreement shall conclusively provide for the distribution of property under the said law and hereby waive, release and relinquish any further rights they may respectively have against the other for alimony, alimony pendente lite, equitable distribution of marital property, counsel fees or expenses. Each of the parties hereto, for himself or herself, his or her executors, administrators, or assigns, does remise, release, quit claim and forever discharge the other 2 1"-'" ,--,-,1< . ~" " ,-- party hereto, his or her heirs, executors, administrators or assigns or any of them, of any and all claims, demands, damages, action causes of action, or suits at law, or in equity, of any kind or nature, for or b~cause of any matter or thing done, omitted or suffered to 1:-e done by said other party prior to and including the date hereof. 7. WAIVER OF PENSION AND OTHER EMPLOYEE BENEFITS. The parties hereby waive any and all right to claim any interest or share in each other's retirement, pension or individual retirement accounts. The parties acknowledge that Husband has a retirement by virtue of his employment by the Commonwealth of Pennsylvania and Wife has an individual retirement account with Prudential. 8. AFTER-ACOUlRED PROPERTY. Each of the parties shall hereafter own and enjoy, independently of any claim or right of the other, all items of property, be they real, personal or mixed, tangible or intangible, which are hereafter acquired by him or her with full power in him or her to dispose of the same as fully and effectively, in all respects and for all purposes, as though he or she were unmarried. 9. MOTOR VEHICLES. The parties agree that Wife shall become the sole owner of the 1996 Ford Taurus, which she owned prior to the parties' marriage. Wife shall also become the sole owner of the Bass boat and trailer which is encumbered by a loan with Bank of the West and which has an outstanding balance of approximately $7500.00. Wife shall be solely and fully responsible for the payment of this loan. Husband shall become the sole owner of the 1998 Ford F150 Truck which he is leasing through First Union National Bank. Husband shall be solely and fully responsible for the payment of this lease. The parties agree that they will hold each other free and harmless from any and all liability as a result of ownership of these vehicles. 10. REAL ESTATE. Wife is the lessee in a Rental Agreement with an option to purchase the marital residence located at 4909 Shasta Way, Mechanicsburg, Cumberland County, Pennsylvania. Said rental agreement was entered into prior to the parties' marriage. Wife shall retain possession of the property. Husband shall hereby waive any interest he may have in said real estate by virtue of the parties' marriage. Husband shall execute whatever documents are necessary to assign, convey and 3 -;,ij" ~~ '.H' ',' --I~ ,,__ ~. transfer to Wife all of his right, title and interest in the aforementioned real estate. 11. ACCOUNTS. The parties agree that Wife shall become the sole owner ofthe checking and savings account at Member's First Credit Union currently in her name and the checking account at Waypoint Bank currently in joint names. Husband shall cooperate and shall execute any documents necessary to transfer the Waypoint Bank checking account to Wife. 12. PARTIES' DEBTS. The parties represent and warrant to each other that since separation, they have not incurred any debts or made any contracts, other than those listed herein, and in the future they will not incur any debts or make any contracts for which the other shall be held liable. Husband has paid the following outstanding amounts due debt in his name: Sears in the amount of$75.00 Husband shall be solely responsible for any future debt incurred on the Home Depot account, Sears and FNANB MasterCard. Wife agrees to be solely liable for the outstanding amounts due as of this date on the following debt in her name: Boscov's in the amount of$150.00 CitiFinancial in the amount of $840.00 Discover in the amount of$1500.00 First USA VISA in the amount of$1100.00 Fleet Credit Card Services in the amount of $2200.00 MBNA in the amount of$1600.00 Wife also has paid the following amount due on debt in Husband's name: FNANB MasterCard in the amount of $4383.00 13. EOUlTABLE DISTRIBUTION. The parties have attempted to distribute their marital property in a manner which conforms to the criteria set forth in the Divorce Code, and taking into account the following considerations: the length of the marriage; the fact that it is the first marriage for Wife and the second marriage for Husband; the age, health, station, amount and sources of income; contribution of each party to the education, training or increased earning power of the other party; the opportunity of each party for 4 """, ", -~ " ,,'~ _,~ ,,, I ._ future acquisitions of capital assets and income; the sources of income of both parties, including but not limited too medical, retirement, insurance or other benefits; the contribution or dissipation of each property, including the contribution of each spouse as a homemaker; the value of the property set apart to each party; the shared responsibility for all of the debts of the parties; the standard of living of the parties established during the marriage; and the economic circumstances of each party at the time the division of property is to become effective. The division of existing marital property is not intended by the parties to constitute in any way a sale or exchange of assets, and the division is being effected without the introduction of outside funds or other property not constituting marital property. The division of property under the Agreement shall be in full satisfaction of all marital rights of the parties. 14. INTENDED TAX CONSEOUENCES. By this Agreement, the parties have intended to effectuate an equal division of their marital property in accordance with the Pennsylvania laws pertaining to divorce and equitable distribution. The parties have determined that such equitable division conforms to a right and just standard with regard to the rights of each party. The division of existing marital property is not intended by the parties to constitute in any way a sale or exchange of assets and the division is being effected without the introduction of outside funds or other property not constituting the marital estate. As a part of the equitable division of the marital properties and the marital settlement herein contained, the parties agree to hold each other free and harmless from all income taxes assessed against the other resulting from the division of the property as herein provided. 15. TAX FILINGS All federal, state and local tax returns required to be filed be the parties have been filed, and all federal, state and local taxes required to be paid with respect to the periods covered by the returns have been paid. Neither party has been delinquent in the payment of any tax, assessment, or governmental charge. Neither party has had any tax deficiency proposed or assessed against him or her, nor has executed any waiver of the statute of limitations on the assessment or collection of any tax. 15.A. In the event that there be any deficiencies in state or federal income taxes, 5 -,'. . ~ ", ,-" - I,~ _ ' . including penalties and interest, related to the joint income tax returns of the parties for years prior to tax year 2001 (the year of the divorce decree), it is agreed that the parties shall be proportionately entitled to any refund due to the parties for those years. Accordingly, the parties shall be proportionately responsible for the payment of any and all costs of defending the parties against any asserted deficiencies, or of prosecuting any refund claim. Both parties agree to cooperate fully in filing any and all necessary pleadings and documents, including protests, petitions, refund claims, and powers of attorney. 16. REPRESENTATION BY COUNSEL. The parties acknowledge that both have sought or have had the opportunity to seek independent legal counsel. The parties further acknowledge that Wife is represented by Kathy M. Shughart, Esquire and that at no time has Husband been represented by Kathy M. Shughart, Esquire. Husband specifically acknowledges that he has every right to contact his own counsel, be advised by them and review in detail the contents of this Agreement before its execution. Husband acknowledges that he has conducted a full and through investigation of all of the assets of the parties and is satisfied with the distribution of the assets as set forth in this Agreement and that it is fair and equitable. 17. DIVORCE. The parties hereto agree to enter into a mutual consent divorce, The parties agree to execute the Affidavits of Consent and other requisite documents necessary to finalize the divorce. 18. BREACH. If either party breaches any provision of this Agreement, the other party shall have the right, at his or her election, to sue for damages of such breach or seek such other remedies as may be available to him or her, and the party breaching this Agreement shall be responsible for payment of legal fees and costs incurred by the other in enforcing their rights under this Agreement. 19. FINANCIAL DOCUMENT DISCLOSURE. The parties waive their rights to require the filing of financial statements by the other, although they have been advised that it is their legal right to have such disclosures prior to entering into this Agreement. By executing this Agreement, the parties hereby acknowledge their satisfaction with the information presently available to them and agree not to use non-disclosure as a basis to 6 {'" -', ',' -'~ ,< _7, eo " "'~ r, overtum this Agreement. 20. EXECUTION OF DOCUMENTS. Both parties hereby agree to execute any documents required to implement this Agreement. 21. ADDITIONAL INSTRUMENTS. Each of the parties shall, from time to time, at the request of the other, execute, acknowledge, and deliver to the other any and all further instruments that may be reasonably required to give full force and effect to the provisions of this Agreement. 22. SUBSEQUENT RECONCILIATION. The parties agree that the terms of this Agreement shall not be effected by their subsequent reconciliation or resumption of marital relations unless the parties otherwise specifically agree in writing. 23. ENTIRE AGREEMENT. This Agreement contains the entire understanding of the parties and there are no representations, warranties, covenants or undertakings other than those expressly set forth herein. 24. MODIFICATION AND WAIVER. A modification or waiver of any of the provisions of this Agreement shall be effective only if made in writing and executed with the same formality as this Agreement. The failure of either party to insist upon strict performance of any ofthe provisions of this Agreement shall not be construed as a waiver of any subsequent default of the same or similar nature. 25. PARTIAL INVALIDITY. If any provisions of this Agreement are held to be invalid or unenforceable, all other provisions shall nevertheless continue in full force and effect. 26. VOLUNTARY EXECUTION. The parties hereby acknowledge that this Agreement is fair and equitable and that it is entered into freely and voluntarily, and that it is not the result of any duress or undue influence. 27. AGREEMENT TO BE INCORPORATED INTO DIVORCE DECREE. The parties agree that the terms of this Agreement shall be incorporated into any Divorce Decree which may be entered with respect to them. The parties further agree that the Court of Common Pleas which may enter such Divorce Decree shall retain continuing jurisdiction over the parties and the subject matter of this Agreement for the purposes of enforcement of any of the provisions thereof. 7 \i",. '. . ^" ~ '-1. ,< ___, -'2 ,- I~,~, ;,:~, --" ,'-' ,'-"- " 28. APPLICABLE LAW. This Agreement shall be construed in accordance with the laws of the Commonwealth of Pennsylvania. 29. BINDING EFFECT. Except as otherwi~e stated herein, all provisions of this Agreement shall be binding upon the respective heirs, executors, or administrators of the parties. IN WITNESS WHEREOF, the parties hereto have set their hands and seals the date and year first above written. WITNESS: ~~J (1~!~ Wi6tess .r~~~~ ~';~~ ACKNOWLEDGMENT COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN On this, the d CJ+:h day of Q E:f1~ m O~ \" ,2001, before me, the undersigned officer, a Notary Public in and for said County and State, personally appeared JENNIFER S. BURTNER, known to me or satisfactorily proven to be the person whose name is subscribed to the within instrument, and acknowledged the above Marital Settlement Agreement to be her voluntary act and deed. IN WITNESS WHEREOF, I have hereunto set my hand and seal. 7fI 00, oDa He p~ Notary Public ~SEAL ~A A POI.lNG, Notary Public' f;6'/!t!f "!lllIlln'l'wp., Dauphin Coun~' 1,1YQtJffll!liss!(m Expires Sept. 1, ~" ,. .__-':'=~"",'I~""""'_~o' . 8 -, , ~, \' . "-,, -I -- ,", I' ", , '\. >) ,,-- .---,,~. ' ACKNOWLEDGMENT COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN I f." On this, the \9 - day of A~I\-''- ,200I,beforeme, the undersigned officer, a Notary Public in and for said County and State, personally appeared GEORGE M. BURTNER, known to me or satisfactorily proven to be the person whose name is subscribed to the within instrument, and acknowledged the above Marital Settlement Agreement to be his voluntary act and deed. IN WITNESS WHEREOF, I have hereunto set my hand and seal. NO~~ NOTARIAL SEAL u.avo P. SCHROEDER, Nota.,. Public Han'1sbutg, Dauphin Coumv. PA My CommJsslOh expires Aprif 23. 2001 9 ,,'T 1'),,'_ ""'~:I_',_ ,- T' '~"'__> '-",r, ,-'. , III '!''!IfI'l ~"~~"'~_ ~ ,,~~~~W'Ir.~ .&.3- ~ ~~ ''-~,^,' "" ~.~=~<'N"'~ = III [all!' 1'1'" ~. 0 ..., = C> r-. = en -0 G "", --i c: :r.: 'T1 (;-:;. rnr= '" I:JfTl Ul 9~ ';~ r~' ""D ~;~ <- -~,- ~ , '- 1') 2.:: =:'.l ::<, 0 5; -.l -< .~,~~ '" , i!!I..4!~~-I'W'4~ft''',"'''(Il\'I'>":,~,:"}"",,,,'l'';'1:W'~__;J;0t:1t~~~i~~f$0llI'-":u.~;!i~~\f'!l"",,:~Jj1WIOI;'!f'''!rf~if'-!l''i>~~~,,,; - v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO: 01-1733 CIVIL TERM JENNIFER S. BURTNER, Plaintiff GEORGE M. BURTNER, Defendant : Civil Action - Law : Divorce PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a divorce decree: I. Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and marmer of service of the complaint: First class mail pursuant to an Acceptance of Service signed by the Defendant on April 6, 2001, and filed on April 12, 2001. 3. (a) Date of execution of the affidavit of consent required by Section 330l(c) of the Divorce Code: by the Plaintiff on August 22,2005; by the Defendant on April 28, 2002. 4. Related claims pending: Marital Settlement Agreement dated December 20,2001, resolved all claims. 5. (b) Date Plaintiffs Waiver of Notice in Section 330l(c) Divorce was filed with the Prothonotary: Same as this Praecipe. Date Defendant's Waiver of Notice in Section 330l(c) Divorce was filed with the Prothonotary: May 21,2002. 6. The social security number for Plaintiff is 184-62-8881. The social security number for Defendant is 164-60-2030. Date: (f-z.3 -0.5 ... ...~ r - (~..J C:'~~;~ESq.C Attorney for Plaintiff P.O. Box 6315 Harrisburg, PA 17112-0315 (717) 540-8511 Supreme Court #39779 ""~'l'~ I' - r r" r ~_" =..",'" < """"':"'"_,",~ ~,~ 1IIr~~~ ' ilW ,~~~ Ll..",~,,,,,,,,, ~ " 63"" ~ '4 ""'"~' ~ ~, '~~y - - (") ~ ~n;' ~r- :~(-,~ {~~~' z --I --.<, - TIll. I "" = = "-" ""' c: (7) N Cfl o 'T! .-1 ::r: rn~ --om au ~._,l~ ;5=8 ~'?"'C5 (jrn ::;: :n .<; -v :I.: l),:> a -' '0 .,,,,_~\Wf.~W~"!'!"}')!~%",,iWt~"!"jfijl~~~~.. '~"""_. ..~~rm,- _,l~I~) 1",< < >" -< , , JENNIFER S. BURTNER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 01- I7JJ CVl.l I~ GEORGE M. BURTNER, Defendant 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. When the ground for 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 . IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Lawyer Referral Service Cumberland County Bar Association Two Liberty Avenue Carlisle, PA 17013 (717) 249-3166 ,,' ",~ " ,,~";'" ,~; , ~ , I --I ~~"-~ , ~, vs. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ; NO. eJ/-/13.3 ~ (.LlML JENNIFER S. BURTNER, Plaintiff GEORGE M. BURTNER, Defendant : CIVIL ACTION - LAW : DIVORCE COMPLAINT COUNT 1 - DIVORCE AND NOW comes Plaintiff, JENNIFER S. BURTNER, by her attorney, Kathy M. Shughart, and files this Complaint, based upon the following: 1. Plaintiff, JENNIFER S. BURTNER, born July 11,1973, is an adult individual and national of the United States of America, who currently resides at 4909 Shasta Way, Mechanicsburg, Cumberland County, Pennsylvania 17050. 2. Defendant, GEORGE M. BURTNER, born January 31,1965, is an adult individual and national of the United States of America, whose last known address is 242 Cumberland Road, Camp Hill, Cumberland County, Pennsylvania 17011. 3. Plaintiff and Defendant were married on November 21, 1998 in Harrisburg, Pennsylvania. 4. Plaintiff and Defendant are living separate and apart. 5 There are no children of the parties. 6. Plaintiff has been a bona fide resident of this Commonwealth for at least six (6) months immediately prior to the filing of this Complaint. 7. Defendant is not presently a member of the Armed Forces on active duty. Plaintiff is not presently a member of the Armed Forces on active duty. 8. There are no pending actions in divorce or annulment in this jurisdiction or in any other jurisdiction brought by either Plaintiff or Defendant above-named. -, '-' , ,'[ ..~ -" 'I' ~ [ : r . - 9. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the court require the parties to participate in counseling. 10. Plaintiff avers that the marriage is irretrievably broken. WHEREFORE, Plaintiff requests your Honorable Court to enter a Decree of Divorce from the bonds of matrimony. ResP7 submitted, 1/ DATE: 3 -Ie-o\ ..-----'"' ath hughart, Esqu' Supreme Court ill #39779 27 South Arlene Street Post Office Box 6315 Harrisburg, PA 17112-0315 (717) 540-8511 ;'Yll!! f , '. - -" ,'. ~,"~~ ,- - "'1-":;' -0 '. -,' '~1' " , ~v . r . .' JENNIFER S. BURTNER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. GEORGE M. BURTNER, Defendant : CIVIL ACTION - LAW : DIVORCE VERIFICATION I, JENNIFER S. BURTNER, verify that the averments made in the within foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~ 4904, relating to unsworn falsification to authorities. DATE: ~&~ JE R. BURTNER !:,~ ~ - ,'__~", 'h~'o-',' '-.p-' 1"-",:- ~-- "I .- , r"~ I " ., JENNIFER S. BCRT:"iER, Plaintiff : f.'i THE COURT OF COM:-'I00: PLEAS : CU:-'lBERlA0:D COl;P;TY. PE~:-;SYL V.-\~L\ v, : 1\0: 01 - 1733 Civil Term GEORGE i\l. BCRTNER, Defendant : Civil Action - Law : Divorce AFFIDAVIT OF CONSENT I. A Complaint in Divorce under Section 3301(c) of the Divorce Code was tikd on March 23, 200 I. 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. [ consent to the entry of a tinal decree of divorce after service of notice of intention to request entry of the decree. [ verify the statements made in this affidavit are true and correct. [ 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?/ #/0) "': ~ I" r : ~ T~ " ~ , "" ,~..,., _, ~,JIlfIl~'1ffJI!1'!1IlI"J'1I1~!l'~~~I~ IE!',~ ~~ ~ ~ .,..,.,., ,!"~!lir!";j';"'I""-T""" Q ....., = 0 = -n on .-~, :0> --4 -c~,,",:,-, ::c..,., ~~:-T: = GO n1F .> >". "In un; 1'0 -r-IC1 .-< c.n (j < :~ -1(--" _. . 7::1:{ I'J' ,.,::,;" -;,," 70 5> :~~; r:-2 ;=:.::;rn Z ~: .-., 0 :n .~:::.:. -.J .< """~:,'lnl""'l;m,f+-'-=iiAfi~l'liII,I!lf!!m,l'Hll'jl~l'itr~,W1fl!~~~: JENNIFER S. BURTNER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO: 01 - 1733 Civil Term GEORGE M. BURTNER, Defendant : Civil Action - Law : Divorce AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on March 23, 2001. 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. 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 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: LJj-'?5"-O?- ~~~~ Geor M. Burtner, Defendant :~ " , 0' .:"" '- . h~ ~<"- 1'- "1' . 1'1 1'- ~ '~ JE:\:\IFER S. Bl'RT:\ER, Plaintiff : ]).i THE COCRT OF CO\-I\-IO'.: PLEAS : Cl'MBERLA:--;D COL~TY, PE~:-;SYL \"A'.:L-\ v. : NO: 01-1733 Civil Term GEORGE M. BURTNER, Defendant : Civil Action - Law : Divorce WAIVER OF NOTICE OF INTENTION TO REOUEST 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 alier it is filed with the Prothonotary . I verify 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 falsitication to authorities. -. Date: ~/ J105 '. "' , , ' . - - 1 J.1.!IIMIRm!!'ff.l'll~ljjT:lImm~~ _f.. ,,' ,~ :~~g" ~:?: -'-, .- ~~~~- <--s-.- ~ o (; ~ c.T' ~ <n r<:' (,n :2 -~-,. Q. --' :J:.-n rnr:: -C~rr; ..)-.C, t~~J, :::;.-'-;"1 ;~25 f~\'; ::::{ -"'''- S ~"" .t:..". f';? 0, _,.=_~ iJI!_~,""","""",lffi'''''i;':j!'~i<",F,'',,'F'''c--'' 'r'~"~""' ~""r_>:'1ill:~~K""'lmff1"'Ft1(!fW'j;fil!fWi",i&l~~!~'J\'i ? JENNIFER S. BURTNER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO: 01 - 1733 Civil Term GEORGE M. BURTNER, Defendant : Civil Action - Law : Divorce WAIVER OF NOTICE OF INTENTION TO REOUEST 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 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: l.( i:)f) -<J d- . , I'~ 'I,~~'. , ' ,,- _ 'T , - ,~ ~ ' JENNIFER S. BURTNER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA v. : NO. 01 - 1733 Civil Term GEORGE M. BURTNER, Defendant CIVIL ACTION - LAW DIVORCE ACCEPTANCE OF SERVICE I, GEORGE M. BURTNER, the Defendant in the above-captioned matter, do hereby certify that I have on this day accepted service of the Complaint which was filed in this Divorce action on March 23, 200 I. Date: q - h -0 ( ,~ M-tSLAJAue Georg M. B ner, Defendant SWORN AND SUBSCRIBED TO BEFORE ME THIS ,~o;i DAY OF ~I ~ rn~ b ~ Notarial Seal Mary J. Gouffer, Notary Public Sir'" ~m'::g Twp,. Cumberland County tl""" ,>\sion Expires Nov. 17, 2003 Mr '. "~:" , ,~::~Oci21:G~ of NotE.l"les '.f'" _, '.,,' 1 ,~ ~ ~~ ,..- .'..., r' r~." ,.,~~~ ~" Ka1hy M. Shughart, Esquire I.D. No. 39779 27 Sou1h Arlene Street P.O. Box 6315 Harrisburg, PA 17112-0315 (717) 540-8511 JENNIFER S. BURTNER, Plaintiff v. GEORGE M. BURTNER, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO: 01-1733 : Civil Action - Law : Divorce AFFIDAVIT OF INTENTION TO RESUME PRIOR SURNAME COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND '. I, JENNIFER S. BURTNER, being duly sworn according to law, deposes and says that she is the Plaintiff in thl;: above-captioned divorce action, and she hereby elects to resume her prior surname of McCLURE and hereafter use and be known by the name of JENNIFER S. McCLURE, and therefore, gives this written notice avowing said intention, in accordance with Section 704 of the Act of November 15, 1972, P.L. 1063,54 Pa.C.S. 704. Sworn to and subscribed to before me this 2. '2. ~d. day of A1 'S \ AS:\:.- , 2006 ~, ,~, I' s JENNIFER S. McCLURE 1 ' ~ >I!I!, -O-:'.,f'" ?'- 11II, AJ if=- - ~ ~ ~ "...-",.,,-..-"','--~I,~,~" ~ , ~ -lQ. ~ D o - tv -U ~ r ~ +-- (' ---. (":) 1. .'~, ~, lllil r i If (') "-' 0 = C = '-n "' "" ~ :t-, .~ rn..!- C;"';l , N -afn -"J~'" \.D CJ~( "V :~::f1 -rr- <':--"-);;:5 zfJ'l W (J' ~ 0 '< jlJ'I.lI~M~;'.!Hlr-!1l "'!,.., ~!.. 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