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HomeMy WebLinkAbout01-03450 , , , Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, P A 17070 (717) 774-1445 LINDA C. PINOS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2001-03450 ROBERT 1. PINOS, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 330 I (c) of the Divorce Code was filed on June 5, 2001. 2. The marriage of the Plaintiff and Defendant is irretrievably broken. Ninety days have elapsed since the filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! do not claim them before a divorce is granted. 5. I verify that the statements made in this affidavit are true and correct. I understand that false statements are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. DATE: stof0 ~t~'.o U C. PINOS . ~,._~, 0 _ _ ~ ~ ,_ " , _ 'r,o,_ . '_ "'" n-- ^, ,_ _. .," ~c I I, " " ,,". , ',' ,--~ ~< ~ >",-.,_ ,,' .~.J ~ '. ~. _'0' CA'~ . ". . .. .. ',". ~-. '^" ',- '-,---,","~i'n_"~--'.'.,'~",,,, ;rt;<1"i"~'''~- .~ ,~- '", ,= _"","~_c no'_', l; "''',.,e ,'. .. __,__~ .. ,".',r, --~O., "'~':'''-::1:>,-~ ':'~!'T _}1'~-;:".-,"~: :~~~_8~1f.i:~_~_'!'_,. o -o~ rnf" Zj] g;~ ~~ :( ;:""'-\'-"---~ .. 'l'T'" f (" "" r,o ~. ::,::;' --.( *"" , ' ';";' ~8 -< .:".:1 .0'.) .' .,~ , . Barbara Sump1e-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, P A 17070 (717) 774-1445 LINDA C. PINOS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2001-03450 ROBERT J. PINOS, Defendant CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE lINDER ~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 statement herein are made subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn falsification to authorities. DATE: ~#=< w < .'00':--" _ "~o;.__'____ . -., "",.-,,,.-. ,-- '-, ^"~; ^->"',.'- .. ~.. ,'-- --""'~--- 0'1-' , <. 1 =. ~~ "~~o'!''':~ () c <~ ~"G-i5-~ r:p rt Lt-: ~:2: !:::C} ,- ~~ ~ o N Z j;_.". -~ i"-J ~TJ :.~ en 0:) "-~ , . ,--& ~ ,-~ - .}~,,,,~~.._ ''P-~~'''"'- ,__C'",,)J,::. ,m:J SAIDIS SHUFF, FLOWER & LINDSAY ATTORNEYS-AT-LAW 26 W. High Street Carlisle. PA !I . :J " LINDA C. PINOS, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION. LAW NO. 01-3450 CIVIL TERM Plaintiff V5. ROBERT J. PINOS, Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under !l3301 (c) of the Divorce Code was filed on June 5, 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 in 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 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. iJdIJ/iv / RObe~. Pinos, Defendant Date: 5"/(p(p,/ I I :--,-~, ~ .."~ ~""_.--~ ,'" 'I. - -"0'"' ~'r"_ '0 - _ "" '1'.'''.", -'".", _',_-' _"',0' '. _ ",r , ..- ~"c .~ _, __ ., _ e. , -----."'- " reo ~ ~, ',; .-'.- ~_"!!'"'!'~"l'~,~lIII!II'!"'~ - ""' . , () c' f; N 0 :-u:s..- :Jil: '<fJ r-tlCI-.! ~f!;F ~ "1 -." -17r72 -- 71'~'" ~. ':,~J(~l ...:::- "-;:'c~. )i>.,-.., .:n.. -?\.- ::::: ;~~z, ~C-) >c:' - - 2: =< ;:..., 5;.1 CJj .::0 -< ~r<><:,"~:,"<,,:,,,,,,,,,,,,,,,,,~NJ?J'il~w~Jq'lll~~'!'ti~~iIll~_.....,,~_M_~~~l :r -- SAIDIS SHUFF, FLOWER & LINDSAY ATIORNEYS-AT-LAW 26 w. High Street Carlisle, P A -:;;;'l!.: " ., ,,, v LINDA C. PINOS, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 01-3450 CIVIL TERM Plaintiff VS. ROBERT J. PINOS, Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER S301(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 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: :.I. Pinos, Defendant f)/~ to 7__ I I 2 -_-,~r:",,'_N , -,",- _ ,-, '_~', r.____ -'c. "- - ~ '~"'" .< - - - - <C'-" -__ ,-, - ,_ , , -:-,-'~-, _. - ...-q' ,"(n" "-"" , . ~ . ,=~ ~,;LL "( '.. -, .. ".- 1JI!lfIl _ ',",,"~ .,,! . -,^ "~"~~ "_H.. ,() C:> () C. "" U~::,: ~f1 ::;~ :_::3 n,CL-l :t:~ Ln: -.,:: --';'-1.JJ -.2:': Z<., r- ~~'; ..,." - .:-~; f]:J ,,~ ~E~, .,~ ..~:;~ ~) ~- ::::~, -'. -r, zr, -~, /.:;.--ri ~O ~5FX c 2: b! =< w :0 en -< ~~~~~II';;;'m1'fW!ll''-,''llil~~~J!~: L,)i,.M1I~~~ . Barbara Sumple-SulJivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, P A 17070 (717) 774-1445 LINDA C. PINOS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2001-03450 ROBERT J. PINOS, Defendant CIVIL ACTION - LAW IN DIVORCE NOTICE OF INTENTION TO RESUME PRIOR NAME NOTICE is hereby given that Plaintiff in the above-captioned matter, having been granted a fmal decree in divorce on the 29th day of May , 2002, hereby intends to resume and hereafter use the previous name of Linda I. Cheney and gives this written notice avowing her intention in accordance with the provisions of the Act of 54 Pa. C.S. S704. ~tjuUJ inda C. Pinos TO BE KNOWN AS: COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND : SS. On this, the 31 st day of May ,2002, before me, a Notary Public, the undersigned officer, personally appeared Linda C. Pinos, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the foregoing Notice ofIntention to Resume Prior Name for the purposes contained therein. ESS WHEREOF, I hereunto set my hand and official seal. , Noltl1laI8eIII . , 8IdI8I8 .....1IuIIvatl. NaIIry PlilllI8 . <: '. 1Il:.d Ilonl, c....t "Id~ (SEAL) .. ]". 11"~No_ !ltli,~,; i~).,!~., _ ~'~.~_"o "_"",^," "_'" ',." ~"', 'n".'__', "_7'_--['_ "_,_",-, . '.' ." .. ~ ~, ,..~ -', ,- - "~ .,- - ~~ b1R p, ~, .-,,^- ""'",~_.~"L" ~ ,_, -,' ,?" '- )J II) ~ JJ , .' "'. =~-"-~,,, ',__J 'd.- -", ,,,.+~ ,--~~.,".,,",''''''''' ~. 'Ii (J .(q, T" ~ ih. 0 o ~ V ~~ 1) :f:::. '-...( ~~ , " (i~~~~~~ y ,'" ._... .0< (') co C ~~'0 ~, '- ~lJ c' c:: ," rn p-' ,""'" -':;.' :~j ~7 ; I (j~! ,--- (.cO, r;-:: --C; -'~ 'z:. .., " ""., '-'. ; o '-n _,,_I . -~, ,j 'r rr, t;::' :.i:1'); ;~~(~; ~~~'Ti ,~-j .::.~;: :0 -< ". 'T"0~~ ;"'~- '~!'~11~-'0_,__b,_"t ' j -C",A,,,,~~rr; .~ -~ , . .,.. to ., -,';:4\l.1l\"<l .~. ~. LINDA C. PINOS, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION. LAW : NO. 01.3450 CIVIL TERM Plaintiff V5. ROBERT J. PINOS, Defendant : IN DIVORCE PROPERTY SETTLEMENT AND SEPARATION AGREEMENT THIS AGREEMENT made this I fp fh day of c1~ , 2002, BY AND BETWEEN ROBERT J. PINOS, of 1527 Fisher Road, Mechanicsburg, Cumberland County, Pennsylvania, hereinafter referred to as Husband, AND LINDA C. PINOS, of 2048 Chestnut Street, Harrisburg, Pennsylvania 17104, hereinafter referred to as Wife. RECITALS: R.1: The parties hereto are husband and wife, having been joined in marriage on August 11, 1973 in Chester County, Pennsylvania; and R.2: A Complaint for Divorce has been filed in the Court of Common Pleas of Cumberland County, Commonwealth of Pennsylvania, to Number 01-3450, Civil Term; and R.3: The parties hereto desire to settle fully and finally their respective financial and property rights and obligations including, but not limited, of all matters between them relating to the ownership of real and personal property, claims for spousal support, alimony, alimony pendente lite. -~ - " -,.,'- ""11-, .'" ..~ ,,",- .' --,,~ e ."',~ ,~ ~~~ NOW THEREFORE, in consideration of the covenants and promises hereinafter to be mutually kept and performed by each party, as well as for other good and valuable consideration and intending to be legally bound, it is agreed as follows: (1) 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 from time to time may choose or deem fit, free from any control, restraint or interference from the other, Neither party will molest the other or endeavor to compel the other to cohabit or dwell with him or her by any legal or other proceeding. Each party shall be free of the interference, authority or contact by the other as if he or she was single and unmarried except as maybe necessary to carry out the terms of this agreement. (2) DIVORCE: The parties acknowledge that the marriage is irretrievably broken and that they will secure a mutual consent no-fault divorce decree in the above- captioned divorce action. Upon the execution of this Agreement, the parties shall execute and file Affidavits of Consent and Waiver of Notice Forms, necessary to finalize said divorce, (3) REAL PROPERTY: The parties are the owners of certain real estate with improvements thereon erected at 1527 Fisher Road, Mechanicsburg, Pennsylvania, On the same day as the date of this Agreement, Wife will execute a special warranty deed transferring to Husband all her right, title and interest in the marital property. Said deed shall be held in escrow by Barbara Sumple-Sullivan, Esquire, until such time as the Affidavits of Consent have been signed and filed and the property refinanced as set out below, Husband shall pay for all household expenses including, but not limited to, 2 C_" . -,- " ,. ,., --~ " ".. .," -'" mortgages and liens of record, utility bills, insurance and real estate taxes in connection with said property. With regard to all such expenses, Husband hereby shall hold Wife harmless and indemnify Wife from any loss thereon. Husband shall refinance said mortgage obligation within 60 days from the date of this Agreement at which time the escrow deed shall be released to him. (4) DEBT: A. MARTIAL DEBT: The parties acknowledge that each had in his or her own name certain debt which might be considered marital debt. Each party will be solely responsible for the payment of any debt in his or her name, and shall indemnify and hold the other party harmless from claims of any creditor which he or she hereby agrees to pay. B: Post Separation Debt: In the event that either party contracted or incurred any debt since the date of separation, the party who incurred said debt shall be responsible for the payment thereof regardless of the name in which the debt may have been incurred. The parties disagree as to the date of separation, but both aver that there are no debts in joint names and that each has incurred no liability for which the other may be liable, at least since the filing of the Complaint in Divorce on June 5, 2001. C: Future Debt: From the date of this agreement neither party shall contract or incur any debt or liability for which the other party or his or her property or estate might be responsible and shall indemnify and save the other party harmless from any and all claims or demands made against him or her by reason of debts or obligations incurred by the other party. 3 ." - ,.' .~ '. (5) MOTOR VEHICLES: Each party relinquishes any right, title and interest he or she may have to any and all motor vehicles currently in possession of the other party. There are no vehicles jointly titled. (6) TANGIBLE PERSONAL PROPERTY: The parties hereto mutually agree that they have effected a satisfactory division of the furniture, household fumishings, appliances. tools and other household personal pmperty between them, and they mutually agree that each party shall from and after the date hereof be the sole and separate owner of all such property presently in his or her possession whether said property was heretofore owned jointly or individually by the parties hereto. This agreement shall have the effect of an assignment or bill of sale from each party to the other for such property as may be in the individual possession of each of the parties hereto. (7) INTANGIBLE PERSONAL PROPERTY: Each party hereby relinquishes any right. title or interest he or she may have in or to any intangible personal property currently titled in the name of or in the possession of the other party, including, but not limited to. stocks. bonds, insurance, bank accounts. individual retirement accounts, employment benefits including retirement accounts, savings plans, pension plans, stock plans, 401 K plans and the like. On the same day as Husband refinances the marital home as set out in Paragraph 3 above, upon the passing of the rescission period, Husband will pay to Wife $65,000.00. (8) WAIVER OF ALIMONY: The parties acknowledge that each has income and assets satisfactory to his and her own reasonable needs. Each party 4 :r,"~"'"' '^~_<_'__ -'--"='-,')-c,~'-" ,~~""" . ...-~ ,,-~- r . I' ,'~ "-". - '" .!!. .' '""",,, waives any claim he or she may have one against the other for alimony, spousal support or alimony and alimony pendente lite. (9) ADVICE OF COUNSEL: The parties hereto acknowledge that each has been notified of his or her right to consult with counsel of his or her choice, and have been provided a copy of this Agreement with which to consult with counsel. Husband is represented by Carol J. Lindsay, Esquire, and Wife is represented by Barbara Sumple- Sullivan, Esquire. Each party acknowledges and accepts that this Agreement is, under the circumstances, fair and equitable, and that it is being entered into freely and voluntarily after having received such advice and with such knowledge as each has sought from counsel, and the execution of this agreement is not the result of any duress or undue influence, and that it is not the result of any improper or illegal agreement or agreements. Each party shall pay his or her own attorney for all legal services rendered or to be rendered on his or her behalf. (10) ADDITIONAL INSTRUMENTS: Each of the parties shall from time to time, at the request of the other, execute, acknowledge and deliver to the other party any and all further instruments that may be reasonably required to give full force and effect to the provisions of this Agreement. (11) INCOME TAX: The parties have heretofore filed joint Federal and State Tax retums. Both parties agree that in the event any deficiency in Federal, state or local income tax is proposed, or assessment of any such tax is made against either of them, each will indemnify and hold harmless the other from and against any loss or liability for any such tax deficiency or assessment and any interest, penalty and 5 ''',~_ , H .,- ," ". ;-.~u__ ~ expense incurred in connection therewith. Such tax, interest, penalty or expense shall be paid solely and entirely by the individual who is finally determined to be the cause of the misrepresentations or failures to disclose the nature and extent of his or her separate income on the aforesaid joint returns. (12) BANKRUPTCY: The parties hereby agree that the provisions of this Agreement shall not be dischargeable in BanknJptcy and expressly agree to reaffirm any and all obligations contained herein. In the event a party files such bankruptcy and pursuant thereto obtains a discharge of any obligations assumed hereunder, the other party shall have the right to declare this Agreement to be null and void and to terminate this Agreement in which event the division of the parties' martial assets and all other rights determined by this Agreement including alimony shall be subject to court determination the same as if this Agreement had never been entered into. (13) COMPLETE DISCLOSURE: The parties do hereby warrant, represent, acknowledge and agree that each is fully and completely informed of, and is familiar with, the wealth, real and personal property, estate and assets, eamings and income of the other and has made any inquiry he or she desires into the income or estate of the other and received any such information requested. Each has made a full and complete disclosure to the other of his and her entire assets, liabilities, income and expenses and any further enumeration or statement thereof in this Agreement is specifically waived. (14) RIGHTS AND RESPONSIBILITIES: Husband and Wife acknowledge that each of them has read and understand his and her rights and responsibilities under 6 '''-.' , , ~.- this Agreement and that they have executed this Agreement under no compulsion to do so but as a voluntary act. (15) FULL SETTLEMENT: Except as herein otherwise provided, each party hereby releases the other from any and all claims, or demands up to the date of execution hereof. It is further specifically understood and agreed by and between the parties hereto that each party accepts the provisions herein made in lieu of and in full settlement and satisfaction of any and all of said party's rights against the other for past, present and future claims on account of support, maintenance, alimony, alimony pendente lite, counsel fees, costs and expenses, equitable distribution of marital property and any other claims of the party, including all claims which have been raised or may be raised in an action for divorce. (16) RELEASE OF ALL CLAIMS: Except as may be otherwise specifically provided in this Agreement, Husband and Wife, for themselves, their heirs, representatives and assigns, each hereby forever releases, remises, discharges and quitclaims the other, and such other's heirs, representatives, assigns and estate, from and with respect to the following: A. All liability, claims, causes of action, damages, costs, contributions and expenses or demands whatsoever in law or in equity; B. All rights, title, interest or claims in or to any property of the other, whether real, personal or mixed and whether now owned or hereafter acquired; C. All rights of courtesy and dower and all claims or rights in the nature of courtesy and dower; 7 i~,< ",f_ - - ~.,..""".. . - ,~. p",." ~ , > ' 7 . ,,~ ,-....,,~- ~,- ,.. . ~. ". D. All widow or widower's rights; E. All right, title, interest or claim in or to the other's estate, whether now owned or hereafter acquired, including but not limited to all rights or claims: (1) to take against the other's will; (2) under the laws of intestacy; (3) to a family exemption or similar allowance; and (4) all other rights or authority to participate or intervene in a deceased spouse's estate in any way, whether arising under the laws of Pennsylvania or any other country, territory, state or political subdivision. F. All rights or claims to any accounting; G. All rights, claims, ?emands, liabilities and obligations arising out of or in connection with the marital relationship or the joint ownership of property, whether real, personal or mixed; H. All rights, claims, demands, liabilities and obligations arising under the provisions of the Pennsylvania Divorce Code, as the same may be amended from time to time, and under the provisions of any similar statute enacted by any other country, state, territory or political subdivision; I. All rights, claims, demands, liabilities and obligations each party now has, or may hereafter have, against or with respect to the other. 8 IWL~ '-. .", .'-,.,' . ''''',r .".,. , '. ' ".. , , , .,= ~ c" (17) GOVERNING LAW: This Agreement shall be construed under the law of the Commonwealth of Pennsylvania. If any provision of this Agreement is determined to be invalid or unenforceable, all other provisions shall continue in full force and effect. (18) INCORPORATION INTO DECREE: In the event that either of the parties shall recover a final judgment or decree of absolute divorce against the other in a court of competent jurisdiction. the provisions of this Agreement may be incorporated by reference or in substance but shall not be merged into such judgment or decree and this Agreement shall survive any such final judgment or decree of absolute divorce and shall be entirely independent thereof. (19) BREACH: In the event that either party breaches any provision of this Agreement, he or she shall be responsible for any and all costs incurred to enforce the Agreement, including, but not limited to, court cost and counsel fees of the other party. In the event of breach, the other party shall have the right, at his or her election; to sue for damages for such breach or to seek such other and additional remedies as may be available to him or her. (20) ENTIRE UNDERSTANDING: This Agreement constitutes the entire understanding between the parties and there are no covenants, conditions, representations, or agreements, oral or written, of any nature whatsoever, other than those herein contained. (21) AGREEMENT BINDING ON PARTIES AND HEIRS: This Agreement shall bind the parties hereto, their respective heirs, executors and assigns. 9 -, :',-" -T-'-I,__ , , .. . ~ I .:.' ( ". Ir~'~,-<-,' ,: IN WITNESS WHEREOF, the parties hereto intending to be legally bound have hereunto set their hands and seals the day and year first written above. 4!lf4 t-- 10 ~'~-'""""".,"-;,<, "~,- "'.." '-,-".-,^ 1,'-,,~'-""'t "-<, '''''',-,~, . -" '--" ~, ,- ~ ~~ ~ ',~~ ,~~~-- I ~ _~~ ~!liW~-~""""'" '" ~ -" o n'TI_ ,_~,' e'" ~~,,' .~ '" ~.", -""".,. .'''''&'-,->-~~. ' ". ''''." ,-_. () c: <-~. -o~ Q)tt' zt (f) ~~> ---..:>' <t~} :';>C;. Z,-. )>:~' I..._.~ "'::::.. =2 . .., ..--.. " ~'_.v__"_ 'I C'-~ f',) .~( :'-) "'r) cO .'~..> :.'1 :iJ -, .""""""'~~~~'61lj{lll'11'@.1'~-",.,#~9~!';',~';:'~;:;o/!I;','Mk"I-'_>'i-'\I!;'1'if.!!l~f1~-4'!!i\I'~'''t"1i~'7.$-'"~'lN,,*'!iJ!01,,''-m~~~~~~ , . .. Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, P A 17070 (717) 774-1445 : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA LINDA C. PINOS, Plaintiff v. : NO. 01-3450 ROBERT J. PINOS, Defendant CIVIL ACTION - LAW 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. Ground for divorce: Irretrievable breakdown under 9330I(c) of the Divorce Code. 2. Date and manner of service of the complaint: United States Mail, Certified Mail, Restricted Delivery on June 6, 2001. 3. Date of execution of the affidavit of consent required by ~ 3301(c) of the Divorce Code: by Plaintiff May 20, 2002; by Defendant May 6, 2002. 4. Related claims pending: All matters have been resolved pursuant to the Property Settlement and Separation Agreement reached by the parties dated April 16, 2002 and incorporated, but not merged into the Decree. 5. Date Plaintiff's Waiver of Notice in 9330I(c) Divorce was filed with Prothonotary: May 21, 2002. Date Defendant's Waiver of Notice in ~3301(c) Divorce was filed with Prothonotary: May 14,2002. Dated: May;Q 2002 , Barbara Sump Ie-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 (717)-774-1445 Supreme Court ill #32317 Attorney for Plaintiff ~, ""'."_"T -~_~"'C- ""';',<F^,~__ ,-,-CO" ,.".~.,;:,. ~..]'" "___~_~<_'_}:., <_~ __,___ _, . ,~, - ,c.- >_~,_ _"" ',' , Barbara Swnple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cwnberland, P A 17070 (717) 774-1445 LINDA C. PINOS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA VI. : NO. 01-3450 ROBERT 1. PINOS, Defendant CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE I, Barbara Sump Ie-Sullivan, Esquire, do hereby certify that on this date, I served a true and correct copy ofthe foregoing Praecipe to Transmit Record, in the above-captioned matter upon the following individual by first class mail, postage prepaid, addressed as follows: Carol J. Lindsay, Esquire Saidis, Shuff, Flower & Lindsay 26 West High Street Carlisle, PA 17033 Barbara Sump Ie-Sullivan, Esquire Attorney for Plaintiff 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. No. 32317 DATED: May~, 2002 - ~-'-,'-:;::;~>-<f<'-':S"_!;';"'"' ,1'""_"-~_'f,c_ ,- '" _oJ',__'''" ~_-_~"_~ ~__<_ ,. -, -,,-~-~-- ,"-,'" ,- -- -;~- - ,-.- r, ,,_~,_.~,~,,~, ~~__~,__w__ ,'-' ".", . fi~ I I I' '""~" "."~""'" ';...' .'t.o.',".-,"_"" -~'" " ",. ,-- "-, " " ,'~ "'.' ".". -~"~, " '-.,-; "_=.,,,,,,,,,,,,-,,-,~.,~" "-"'-"">'W"'~~I'- ",~-, ~,~~" ~~~ () c.) C) C j',,~~ -q ~~ :11:: -nlX' :r~' [t) LT --< ~-~""'- 1'0 ~~~: r;:C --0 -j> -, Z~~ :..~) S>C , :n -j -, CO _~,.-t'0',~,-*~~~_,'_ ,_,_,,':'1"~"_'___'::,____' _~r,_". '-"-'-," r .~,,",' " '""1:'7 ,li",,~, . '" '" '" '" '" '" '" "'''' "'''' '" L '" '" '" "'''''''''''''''' '" '" "'''' '" "'''' '" '" "'''' '" ~'" "''''''''''~ . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY . . , , . . STATE OF . . . . . . LINDA C. PINOS, Plaintiff VERSUS ROBERT J. PINOS, . , , . Defendant PENNA. No. 2001-3450 . . . . . . DECREE IN DIVORCE . . . . AND NOW,~ Z 4 LINDA C. PINOS . . . DECREED THAT . . . 2002 , IT IS ORDERED AND , PLAINTIFF, AND ROBERT J. PINOS , 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; All matters have been resolved pursuant to the Property Settlement and Separation Agreement reached by the parties dated April 16, 2002 and incorporat bllt "nt- mer'JF'<'l ; "to t-h; s Decree , . . , . . . , . . . ATTE ~~PROTHONOT^R' '" "'''' '" "'''' "'''''''''''''''' "''''~ "'''' '" "''''''' "'''' "''''''' ""'",,, ~'. "'7"C - .".'_0__'-'-"_,__,_",,",_'"__'_,''' f,"-~" ~,~~,,-, "'_" .. . -,- ~-. d _, " _, . . . . , . , . . , . , . , . . . . . . . , , . . . . . . , . . . . . . . . . , , , , . . . . . . . . . . . . . . . . . , . . . . J. . . . , . . . . . . . . . . . . . . . . . . . . . . (:z"~" '~h'';''-l. ",," ~, ~Milliil'I~.l[!jl4i~_~k~l;jjiY ~ii:~ilIi"-c'~ " -"",""""" "'M 5 $' - II! . " -"-.,, ,0;;; '0.) ":1 i ~1 .-i ;i1 ::1 rJ "' q ~~ :i :.1 r] , - - "- 11 .' r~,. . ;." i &/-~~' zai'''~rtf-~I );~ /u~..4, 6.i7j ~:f:/ ! I I I ! " 'iliLi"-" ,..,.,. ~~ '~, ~ ..