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Home My WebLink About01-03281 . . . . . . IN THE COURT OF COMMON PLEAS . . . OF CUMBERLAND COUNTY PENNA. . . . STATE OF . . JOHN R'; PENNINGTON, . . Plaintiff . . VERSUS . LINDA L. PENNINGTON, Defendant . . . . . . . . . . . . AND NOW, DECREED THAT AND No. 01-3281 CIVIL DECREE IN DIVORCE ~31 ;:t ~'J' A.fWl . e100l ,IT IS ORDERED AND JOHN R. PENNINGTON , PLAINTIFF, LINDA L. PENNINGTON , 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; . . . . . . SEPARATION AND PROPERTY SETTLEMENT AGREEMENT INCORPORATED, . BUT NOT MERGED. . . . . . . . . . . . '-"' ^J' .,~,-" .~c"'-n-~' """__r.' >"; C j,"-, B Amsv~~ - 0 PROTHONOTARY . . . . .. . '" "':f. "':Ii:f. Of. ,," " . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J. . . . . . . . . . . . . .' li.i:~i1~iU~~MMiji4i~~~~~=""~~:M;r.~ll.U"li.'!;j~~i>jjill'M ' ~~ .!.!lIl!I>U. ....~"'.,"m.. . ,......0....-' ........ ....... I/J tJ1'CJ! /fdl-O/ , , ~>~>~~ ,'" "_ .'0' .......lIl1li1l '.lMtw .~ ;";;":.\1i ~, ~ -..... ~ .. .' :,~ 6d-~~~4~4< '71k ~ ~ dfI" - '" , . , , v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01- dJ.f'1 G~u~ L c l~ IN DIVORCE JOHN ROBERT PENNINGTON, Plaintiff LINDA LANDRA PENNINGTON, Defendant NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claim 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 judgement may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DMSION 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 TIDS 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 LmERTY AVENUE CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 ,:t,..",," '. -";'",~ ~ .,. " 0__ ", '. v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 0/- 3.2PI &;J ~ JOHN ROBERT PENNINGTON, Plaintiff LINDA LANDRA PENNINGTON, Defendant IN DIVORCE COMPLAINT 1. The Plaintiff is John Robert Pennington, Social Security number 169-52-7454, who currently resides at 38 College Hill Road, Enola, Cumberland County, Pennsylvania 17025. 2. The Defendant is Linda Landra Pennington Social Security number 174-46-5896, who currently resides at 11 Westwood Court, Enola, Cumberland County, Pennsylvania 17025. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the fJl.ing of this Complaint. 4. Plaintiff and Defendant were married on February 14, 1995 at St. Lucia, Caribbean Island. COUNT I - DIVORCE 5. Paragraphs I through 4 of this Complaint are incorporated herein by reference as though set forth in full. 6. There have been no prior actions of divorce or for annulment between the parties. 7. Divorce is sought pursuant to the provisions of the Divorce Code, Sections 3301(c) and 3301(d), in that: a) The marriage is irretrievably broken. b) Plaintiff and Defendant have lived separate and apart since June I, j0~(I_ J. ,~~. .p--' , . ", " 1999 and continue to do so. 8. The Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the court require the parties to participate in counseling. 9. Defendant is not a member of the armed services. WHEREFORE, Plaintiff requests this Honorable Court to enter a Decree of Divorce. Respectfully submitted, Date 5'1-;$/01 I I Austin F. Grogan squ 24 North 32nd Street Camp Hill, PA 17011 (717) 737-1956 Attorney for Plaintiff LD. #59020 *\ , "'~,---- "~' - ., - "1', . , . , VERIFICATION I, JOHN ROBERT PENNINGTON, verify that the statements made in the foregoing Complaint are true and correct to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~ 4904, relating to unsworn falsification to authorities, Date S /:2 'I fa / ~{~~ OHN ROBERT PENNINGTON - w''j " ",,-,_~_, c_c'f. _ .,. _,~_'''' JOHN R. PENNINGTON, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 01-3281 CML TERM LINDA L. PENNINGTON, Defendant IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Austin F. Grogan, being duly sworn according to law, deposes and says that he is the attorney for Plaintiff, John Robert Pennington, and that he did mail a true and correct copy of the Complaint in Divorce in the above matter, by certified mail, return receipt requested, to the Defendant, Linda L. Pennington, on June 4, 2001 at her last known address: 11 Westwood Court, Enola, Pennsylvania 17025, which satisfied the requirements of service by mail pursuant to Pa.R.C.P.403. The signed receipt acknowledging receipt on June 8, 2001 is attached hereto as Exhibit "A". Date it /K~I I ' Austin F. Grogan, squ' e 24 North 32nd Street Camp Hill, PA 17011 (717) 737-1956 Attorney for Plaintiff ID #59020 >-,~J ~- , ~ c', _', ,~"' ' ;'~' , - ., - ,~~ . - II 'Co;:"plete "ems 1. 2, and 3. Also complete item.4 if ReStricted Delivery is desired. .. Print your name and address on the reverse so ,that we- can- return the card to you. II Attach this card to the back of the mail piece, or on the front If space permits, 1. Article Addressed to; j-t17dcuL.&run~ II (;)f4f wood. Cbfid- ~JfYJ- )10d-S' o Agent Addressee DYes DNa 3, Service Type ~fied Mall 0 E~ess Mail o Registered ....Etffeturn Receipt for Merchandise o Insured Mail 0 C.O,D. 4. Restricted Delivery? (Extra Fee) ~ 2, Article Nu'!'ber: (CoRY 'r9'f' ~1V{CI1la~"f!:"70 if:q !31df()(){)~irf)35'l S Lf '?rt? PS F~rm 38115.~1~~*.i:;:,f:;8 . Domestic Return~~fllw1lL.uuM,IJ.llJJ111.J.J,lfl~'11.v"1:1i'lm) I EXHIBIT "A>> . JOHN R. PENNINGTON, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 01-3281 CML TERM UNDA L. PENNINGTON, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was fIled on May 30, 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 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. ~ 4904 relating to unsworn falsification to authorities. Date /O//tp/O{ JrnoJ4> dZ L~ R. PENNINGTON c::? "''''If . ",'. '" ~ ~ , !!i!!IHi~_~ "_'_'~",_I_::",_ ,,_ ", .': ~--~ "0'- """'~,~.~-- '"' _~'-~_ ><TII(" ~ - ""-~''''-'''c- '.-v.'r --'U'f"'" . 0 0 0 ~ ~n 0 ;:RrJJ n -~ 2m -l -',,':;::::rl &5~ ~ Jfn -; ,.,-;Ci -<,~ ~~.1(S ~o "T.J )>0 -. tit! ;So ~..... Pc T>.' ~'fr1 '-) ~ -~ ':11 :t> '.0 ::;::, -<: ~~.o.,,),<=M1'!'I!': ll_ ~"JI!IilllL__. 1I!:fl _Ml__~~ojj!'--<"~,'i';3u.;,'~_'-I'-""~V'Oi:",'f!c>;r,."w,,,,~,j!"_';:iP.J\)(j;'~!C0''i!''";j;'J'8-'f'~'':''',-H',",-''':$1'JWm'~_'1(rt'\'(i!jl't-;;,\;;.>;,~ . . > JOHN R. PENNINGTON, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 01-3281 CIVIL TERM IlNDA L. PENNINGTON, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is fIled with the Prothonotary . I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn falsification to authorities. Date: /0(/"/01 O~ !C f4 ' ~ aOHN R. PENNI~ ~'~'I:?! _..,,_.,e , . . . . .. ~-" '''~ -." ",'. '';""' , . , """,;,.~. -^'-'--~',-,,';~-" ~ ~. '.,,,,,-, '" - "dV" -'--~"-"'''<';'''I';'<-'~,""",''';':d.-"h''0.. "'~" _(" (") 0 (-. c T1 uS:: 0 [L! n mrn --l ' " Z.......' 'F-= :z:~ (j) ~~. -..J :',.)t::1 ~c5 -u ~~~~ ~Q -,... gfr~ ~ :;;;e, ~ c: :z: '..J1 >! -, -< to ::0 -< -~~!"!'ll"l!fl'_" _ I!!I ~.~~iliiWlll!f~'~)fflmM'~'.!ql!4,,,!,ffi#~,_,.-,T~-ii""':(ClIif~,'0"'M"!<)M''''j~!liFi;i?<!,,,,,"?J;(>"',~i'liC,;\'!,-'''''[';>~-''1W'!''''''?>*>F,~I)j1il!~~ ~ , JOHN R. PENNINGTON, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 01-3281 CML TERM UNDA L PENNINGTON, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on May 30, 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 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. ~ 4904 relating to unsworn falsification to authorities. Date I 0 It.~- J 0 I I ~~ c/ P~ifr- N A L. PENNINGTON -~f~;~:l,.",._ . 1" "' ~, < lil,;~ ~ H Jill ~" ,'~_,_,"" '_' '" 'n ,,_ ~_,~ ,,-~>-,. '" ,.", - _'< "0- _...~ "''''''''''-'''''''~'",,;,.'~'''-'~_ <_"~_ '" 0 0 ~~, ~ 'J ..." ""OeD C) ~ft, C) -.., --I""' ;z: :n r (ijl;:, ..:;n; :<.c::~ -..I ~,pr;:: ""- !S:o -'0 ~~Q )>~ -::L-;;:~ 2;:'''' -- $0 l)? ::;-} c--) C ~""::;rn ,-,' 2:: -.j =< ':.n );c. \.0 ::n -<: f0 \l~ ~~> "__,~~~liJIimTr< ITJ"'T~);"!'\'.~~~~~~';;Z"!l';;ffil~l"""k'~W<'"'~?---'","_V"'D'~>{'''l';'~~<'?'''''';'''''!i*,~H',rt'~~'-i".j'ilr,4:,'';R'N;''''''!''i;i'Wt~ll\i~~ . l .. .. . " . JOHN R. PENNINGTON, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 01-3281 CML TERM llNDA L. PENNINGTON, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a fInal decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is fIled with the Prothonotary . I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn falsification to authorities. Date: /0 /I~I 0 I I . ~~~tnL DA L. P NINGTON U 'l~, 1-- _e<v"'.",,, <" ,,,'_,!,,", "".__~ Lo __ ,".,_ ." ^' ~, ~~~ "- ~ -.~", ~- 'o,"",';,,^." . ''''-'<'''."'' -~,,",,'<'~-__' .u~-", "'~ "='~--'.o- ","""'"',,," -. ."O~ """'-"~W"K'P4;"* , (') 0 .'~ C ",j <- ~n '"OfT 0 mn" CJ 2::0 --I ,c:1~ ZC 't)fT! (/)d:::; --..; :,:;Cl ;=:S;." ~i~ ;<0 ""tj J> ZO 3::- :i'>Q 7,0 '- N arn ~ -I 01 ?G lD -<; ~~ ii,- "",~"=,~ j~~_'I:rlllil,. ~"" .._l~~'$-"-m;;",-",,*,,~~;,,,,!~,,,g,"_J'"F; 'l""' "\)l!~)f,~~1'-'W!P'I%)li-",H'I'j:;-"".2P~:;-4!%fHH!9CJ\1'~~~~'~ I i , I' i! Ii I' I' I! I: I[ I' Ii I' 11 11 i I i-"'~,~~,", ~ JOHN R. PENNINGTON, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 01-3281 CIVIL TERM LINDA L. PENNINGTON, Defendant IN DIVORCE fJP~twtd~~ fJP~cA~ THIS AGREEMENT, made this /1.1 t:1L- day of ff)whL/I.- , 2001, by and between JOHN R. PENNINGTON, hereinafter referred to as "Husband", and LINDA L. PENNINGTON, hereinafter referred to as "Wife". WITNESSETH: WHEREAS, the parties hereto are Husband and Wife, having been married on February 14, 1995; and WHEREAS, differences have arisen between Husband and Wife, as a result of which it is the desire of the parties after long and careful consideration, amicably to adjust, compromise and settle all property rights and all rights in, to, or against each other's property or estate, including property heretofore or subsequently acquired by either party, and to settle all disputes existing between them, including any and all claims for maintenance, support, 1 1111 J . nn[.H1I1 ~!IJ!IJ. ,.."".!ti1liJ;~jQw:wmH'11~M~~..t:;fflIl~.M,1i~~1f~f":";"1I!:.,;;,,)f;":,' '(-1!':-",-,-~w "P'V~~t\Jttt~',%'Wlii~~ru~~~,fli,\j.l~~_~_~ alimony, equitable distribution, counsel fees, and costs; and WHEREAS, it is the mutual desire of Husband and Wife to reduce their agreement to writing; and NOW, THEREFORE, in consideration of the mutual promises, covenants, and agreements hereinafter contained, each of the parties hereto, intending to be legally bound hereby promises, covenants, and agrees as follows: 1. PARTIES TO LIVE SEPARATE AND APART The parties mutually agree to live separate and apart. Neither party will molest the other, or in any way harass or malign the other, nor in any way interfere with the peaceful existence of the other. 2. PERSONAL PROPERTY Husband and Wife have divided all personal property, which would constitute marital property. Wife agrees that any property in the possession and control of Husband shall be the sole and separate property of Husband. Husband agrees that all property in the possession and control of Wife shall be the sole and separate property of Wife. Each of the parties does hereby specifically waive, release, renounce and forever abandon whatever claims, if any, he or she may have to the sole and separate property of the other. 2 ~~~II!ll\iI!l=,__~,,",,1j., ,,= _<, ~"_"""'_ r' _, 3. MARITAL DEBTS Husband and Wife each covenant, represent, and agree that each other will now and at all times hereafter save harmless and keep the other indemnified from all debts, charges, and liabilities incurred by the other prior to or after the effective date of this Agreement, except as may be otherwise specifically provided for the by the terms of this Agreement. 4. REAL PROPERTY Husband and Wife agree that the home currently owned by the Husband was premarital property with improvements made by Wife during the marriage. In consideration of $20,000.00 paid subsequent to signing this agreement, Wife waives any interest in the marital portion of the Husband's home. 5. ALIMONY AND SUPPORT FOR SELF Both parties acknowledge and agree that the provisions of this Agreement providing for equitable distribution of marital property is fair, adequate and satisfactory to them and is 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 3 ~~J1~";<l~~WlI&' I'. 1, "'''''':'__ ~~"~_ rR!I.i1f1 ~""!., alimony. Husband and Wife further, voluntarily and intelligently, waive and relinquish any right to seek from the other any payment for support or alimony. Each party shall indemnify, defend and hold the other harmless against any future action for either support or alimony brought by or on behalf of the other such indemnity to include counsel fees. 6. WAIVER OF INTEREST IN RETIREMENT Husband and Wife acknowledge that they both have interest in pension plans. The Husband acknowledges that he has a pension plan with the Federal Employees Retirement System (FERS) and a Thrift Savings Plan in excess of $100,000.00. The Wife acknowledges that she has a pension plan with her employer UPS, stocks through an employee stock option plan, and various deferred compensation rights, which have accrued during the marriage that have not been disclosed to the Husband. Husband and Wife expressly waive and relinquish any right, claim, title or interest in any pension, deferred compensation, ESOP, and any other type of employment benefits, profit-sharing, retirement, or employment-related plans derived from their employment with the United States Post Office and UPS in which the other has any interest, whether vested or unvested, matured or unmatured. 7. LEGAL REPRESENTATION Husband and Wife declare that each has had a full and fair opportunity to obtain and 4 --"'",~~ l~ _lLl ,-< ,- j , i , i i I ~ 1 I consult with legal counsel of his/her selection and that the parties, cognizant of their legal rights, declare and express that: A) Austin F. Grogan, Esquire, represents JOHN R. PENNINGTON; and B) LINDA L. PENNINGTON, acknowledges that she is unrepresented and has been advised of her right to retain counsel of her choosing to represent her in this divorce action. Furthermore, LINDA L. PENNINGTON acknowledges that she has not received any advice from Husbands counsel, nor has Husband's counsel offered any advice other than her right to obtain her own independent legal representation. 8. MUTUAL DISCHARGE Wife relinquishes her inchoate intestate right in the estate of Husband, and Husband relinquishes his inchoate intestate right in the estate of Wife, and each of the parties hereto for himself or herself, his or her heirs, executors, administrators or assigns does remise, release, quitclaim and forever discharge the other party hereto, his or her heirs, executors, administrators or assigns, or any of them, of any and all claims, demands, damages, actions, causes of action or suits of law or inequity of whatsoever kind or nature for or because of a matter or thing done, omitted or suffered to be done by said party prior to and including the date hereof, except that this release shall in no way exonerate or discharge either party hereto from the obligations and promises made and imposed by reason of this Agreement. 5 '~MJI;Jii,rllll__,.'T' ~C '~,_""i'_"_, ~-:-', -, ,~ , . "~ 9. No-FAULT DIVORCE An action for Divorce has been instituted by the Husband in the Court of Common Pleas of Cumberland County, Pennsylvania, docketed to No. 01-3281 alleging that the marriage is irretrievably broken and requesting a no-fault divorce under Section 3301(c) of the Divorce Code. It is hereby agreed that the marriage is irretrievably broken and that coincident to the signing of this Agreement, both parties will execute affidavits of consent to the entry of a Decree in Divorce under Section 3301(c) of the Divorce Code. 10. EXECUTION AND DELIVERY OF DOCUMENTS The parties hereto agree to execute and deliver all papers needed to effectuate the terms and intentions of this Agreement. 11. BREACHING PARTY PAYS COSTS If either party breaches any provisions of this Agreement, the other Pllrty shall have the right, at his or her election, either to sue for specific performance or for damages for such breach, and the party breaching this Agreement shall be responsible for reasonable legal fees 6 "~I).. "'''''_'=~,''_,~ r~ ~_._,,...,,.= _. " and costs incurred by the other in enforcing his or her rights under this Agreement. 12. GENERAL PROVISIONS This Agreement encompasses all agreements between the parties concerning the matters set forth herein and may not be altered or omitted except in writing executed by the parties; the waiver of any term, condition or provision of this Agreement shall in no way be deemed a waiver of any other term, conditions or provisions of this Agreement. If any term, condition or provision of this Agreement shall be determined 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. It is agreed by and between the parties hereto that this Agreement shall survive and shall not be merged into any decree, judgment, or order of divorce or separation. It is specifically agreed, however, that a copy of this Agreement or the substance of the provisions thereof, may be incorporated, by reference, into any divorce, judgment, or decree. This incorporation, however, shall not be regarded as a merger, it being the specific intent of the parties to pennit this Agreement to survive any judgment and to be forever binding and conclusive upon the parties. This Agreement shall be construed under the laws of the Commonwealth of 7 -''''~"'~."'-'_1~ -'~I .~ ~r ., r.~ ~"'_ , Pennsylvania. This Agreement is executed in triplicate, and Husband and Wife, as parties hereto, acknowledge the receipt of a duly executed copy hereof. IN WITNESS WHEREOF, the parties hereto have set their hands and seals the date first above written. WITNESS: J d 8 :';';,r:s:e.ll;Pil!(.lf&~ 1_ ,,"_;r'_~r. .n _ ~ ~~_.~ COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF CUMBERLAND On this, the I ~.tJL. day of l!Jc:tahuL , 2001, before me, the undersigned officer, personally appeared JOHN R. PENNINGTON, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Agreement, and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and notaries seal. r;;i,bnadJQ~ NO ARY PUBLIC Notanal Seal Rhonda D. Rudy, Notary Public Camp Hill Bora, CUmberland County My Commission Expires Aug. 12. 2002 Member, Pennsylvania Association of Notanas "'l!~f). ~~,..l-,. _. 1 ."_ ~ C^ ~ ~." . "" , -~~ COMMONWEALTH OF PENNSYLVANIA COUNTY OF ~l1~rlQ W On this, the l1'!b-day of ~ SS , 2001, before me, the undersigned officer, personal1y appeared UNDA L. PENNINGTON, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Agreement, and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and notaries seal. Notarial Seal Terree L. Knight. Notal)' Public Hampden Twp.. Cumberland County My Commission Expires July 18. 2005 Member, PennsylvanlaAssociaflonotNota~as ii;l_~'ry"~__, _!ll': _,~"~ ~ _ h - ~. .~" _ ~ ~~ c , i i i ! ! I t I [ I ! ~ ! I I , I i. I I ,',,- T~W'!lltjljl.)i.IJ - ..'~........_~ ,,~ . -~,-~ ~., -~ ,. () C:;. (~ C .'n ;;;: :::::> '"PCO " l!)m ...... ,,~. --'. z( ~c~;; 0:) c~ ~o ~J 2t4 -''''''- :;;;0 'd ()rn c: ~ N ~;! ~J L'" -<; R 1'1 vT:fo!,JW_.*n''3_~'f'"lW!''tq'r,''--':'h}!''''''i''"'''~i:'t.-,~'~m'")i\W11:W1fl\>i:ffi~~f':~Jli$!'l:fWI:;;r~~_1Ij'J _ W;___~ ,! -~ JOHN R. PENNINGTON, Plaintiff IN TIIE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 01-3281 CIVIL TERM UNDAL. PENNINGTON, Defendant IN DIVORCE PRAECIPE ,TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Grounds for divorce: irretrievable breakdown under !l 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: By certified mail on June 8, 2001. 3. Date of execution of the Affidavit of Consent required by !l 3301(c) of the Divorce Code: by Plaintiff October 16, 2001; by Defendant October 12, 2001. 4. Related claims pending: All claims raised resolved in Marriage Settlement Agreement dated October 16, 2001. 5. Date Plaintiff's Waiver of Notice in !l 3301(c) Divorce was filed with the Prothonotary: October 17, 2001. Date Defendant's Waiver of Notice in !l 330l(c) Divorce was fIled with the Prothonotary: October 17, 2001. Date: tk.f / '1lliJ(J I =ro1t~ Attorney for Plaintiff 24 North 32nd Street Camp Hill, PA 17011 (717) 737-1956 Id # 59020 ',(~1'i""'1lW"'MI<~ ~ -~r" ~ .j!" - . . _"..-~ ,_ '_"",_" _ - .~ , ~ AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND I, Austin F. Grogan, Esquire, hereby certify that I did mail a true and correct copy of the Praecipe to Transmit the Record in the above-captioned matter to the Defendant, Linda L. Pennington on October 19, 2001, at her last known address: 11 Westwood Court, Enola, Pennsylvania 17025, which satisfied the requirements of service by mail pursuant to Pa. R.C.P. 403. I understand that false statements are made herein are made subject to the penalties of Pa.C.S. ~ 4904, relating to unsworn falsification to authorities. Austin F. Grogan, Attorney for Plain . 24 North 32nd Street Camp Hill, P A 17011 (717) 737-1956 ID #59020 Date: October 19,2001 ;"€:~M""~~ -- ~ - r r ''1':'-, ~ -~- . , l( ~ '11 ~~m " ., ,~..,....,~..".~, - -~ ^~ H .. , .- ~ <,~~""'- ~ ,_ . _ ~O - < . ~ "<. ,- "'... 0 Cl c: 0 "'" -'q u5J <::) O}Q.i C"") -l ,-, ~~;.~ ''-' r::- !:n -<:7~ (...:i '---1 <(j "n ~;,~~ ?fie) 5><':) .-'l. 68 c: 1'-:0 Z o-i :::! .1',-, ?r5 .;:, -< ~ ,_~ ,~l.qDl:r:lJ, ~ :~$,~_~,ti<5'jR{}~(i'~lfC~'\~F'*,iJJ:"'\';f"'-;;;.:"- '-;>'If,"'}'''_;'-;''f'f''':''I1~'fft.'''~i-~IN'';\Vil\1Fii?f'~i'C'fif.lji?~~