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HomeMy WebLinkAbout01-03556 ,,~ ''''- . 4 . . ,., ,.,;Ii;F. . . . ;Ii ;Ii ff.;F. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY . PENNA. . STATE OF DEIDRA K. GARNEl'T, Plaintiff, No. 2001 3556 . . VERSUS TIMOI'HY A. PRYOR, Defendant. DECREE IN DIVORCE . Now~~1~ , 2fDO \, IT IS ORDERED AND AND . . Deidra K. Garnett DECREED THAT , PLAINTIFF, . . AND Timothy A. Pryor , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. . THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF REC,?f}D IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED: V~ The marital settlement agreement dated is incorporated but not merged into this decree. . BY THE COURT: / r( J. . . . . . PROTHONOTARY . . . . . . .. . .. .. . .. . ", '-',.' II ,C.' " -~-, ,1 __ :'~."',~ ,. ~- ~ '" . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ~-~ i2i"lh'~' >C- ~ '1iE-~ ~~..l;,~jl&t[~11'-"'" -" ~6.II1iil1UHlllitIlliltij"liI:lii&. ..,.........,...... ~-,,-"~ ~ili1M~; '-~,,~,~ -~,' '. ~,. = ~ ~ 01 sJ /cJ;J!-tJ ( I () :)I-t:? ( .. , ' .,' M,~ ~ -t-'4~ 'l?~ /~ ~ df~ .' ~ Michael S, Travis ill No. 77399 4076 Market Street, Suite 209 Camp Hill, PA 17011 (717) 731-9502 In the Court of Common Pleas of Cumberland County, Pennsylvania TIMOTHY A. PRYOR, Defendant. ) ) ) ) ) ) No, 2001 - 3556 DEIDRA K. GARNETT, Plaintiff, vs. CIVIL TERM 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 S 3301(c)(1) of the Divorce Code. 2. Date and manner of service of the complaint: Complaint was mailed June 8, 2001, via United States certified mail, restricted delivery, return receipt requested to Defendant, which was received by Defendant on June 19, 2001, Affidavit of service attached hereto. 3. Date ofexecufon of the affidavit of consent required by S 3301(c) of the Divorce Code: by plaintiff on /z ~I ., / ; by defendant on ~ /31 ~ / 4. Related claims pending: Economic claims are resolved by Marital Settlement Agreement dated ''-/3110/ ,incorporated by reference hereto. 5, prothonotary: Date plaintiffs Waiver of Notice in S 3301(c) Divorce was filed with the ,-t, 131/0 , , prothonotary: Date defendant's Waiver of Notice in S 3301(c) Divorce was filed with the hf,,;', . ~ ~ c el S. Travis -" Attorney for Plaintiff 't: - .,', '-"~,,,",<" ,-,~_,_;c, ""..>., . -'c.--'-~r:I"'~:'_ T"~'_"",,~~,,"'~M"'_,_*_, ,-" ,- i I ~~,- ~ " o c: s: "Do.: flln-t 2:r, ZC' (1)_", ;=$j1:: K--' ~8 Pc: 2 =< [':/ to c) c"' ~ i'l .-, ",c' o f71 c-" W :':;1fI1 f:~;~/? '-.) ,3~rt "cO Om S! ;J,J -< '"1:J ;:g ~ N , ~-r""!"IIM_~A)l~<ll;f:l~Ni'iI!<.iW!.Wl,m!lrwJ'~~~~~'!'@l'~ NUUUUAGESETTLEMENTAGREEMENT TillS AGREEMENT made this a~day of'DB1 .",,~OOI, by and between Timothy A. Pryor, (hereinafter referred to as "Husband,") and Deidra K. Garnett, (hereinafter referred to as "Wife"). WITNESSETH: WHEREAS, the Husband and Wife were lawfully married on March 17, 2001; and WHEREAS, there were no children born of this marriage; WHEREAS, differences have arisen between Husband and Wife in consequence of which they intend to live apart from each other; and WHEREAS, Husband and Wife desire to settle and determine their rights and obligations; and NOW, THEREFORE, the parties intending to be legally bound hereby do covenant and agree as follows; 1. DEFINITIONS (a) Date of Execution of this Agreement. The phrase "date of execution" or "execution date" of this Agreement shall be defined as the date of execution by the parties if they each have executed the Agreement on the same date. Otherwise, the "date of execution" or "execution date" of this Agreement shall be defined as the date of execution by the party last executing this Agreement. (b) Distribution Date. The phrase "distribution date" shall be defined as fourteen days following the entry of a final decree in divorce and the filing of Waivers of Appeals by each party. If the fourteenth day falls on a weekend or holiday, the distribution date shall be the next business date. 1 "'''",,,,~ ,"" -"- "- 1-'1-< 'j' , . 2. ADVICE OF COUNSEL The parties have had an opportunity to review the provisions of this Agreement with their respective counsel. Husband and Wife acknowledge that this Agreement is not the result of :my duress or undue influence and that it is not the result of any collusion or improper or illegal agreement or agreements. The parties further acknowledge that they have each made to the other a full accounting of their respective assets to the extent that it has been requested. Each party agrees that he or she shall not at any future time raise as a defense or otherwise the lack of such disclosure in any legal proceeding involving this Agreement with the exception of disclosure that may have been fraudulently withheld. 3. SEPARATION It shall be lawful for each party at all times hereafter to live separate :md apart from the other party at such place or places as he or she may from time to time choose or deem fit. The foregoing provisions shall not be taken as an admission on the part of either party as to the lawfulness or unlawfulness of the causes leading to their living apart. 4. INTERFERENCE Each party shall be free from interference, authority, and contact by the other as fully as if he or she were single and unmarried except as may be necessary to carry out the provisions of the agreement. Neither party shall molest the other or attempt to endeavor to molest the other, nor compel the other to cohabit with the other, or in any way harass or malign the other, nor in any way interfere with the peaceful existence, separate and apart from the other. 5. DIVISION OF PERSONAL PROPERTY The parties hereto have divided between themselves, to their mutual satisfaction, all items of tangible and intangible marital property. Neither party shall make any claimjJ.y other such items of marital property, or to the separate personal property of either prope '.. ~. ,,j; which are now in the possession and/or under the control of the other. j..; ~hltv fJW 6. SPOUSAL SUPPORT/. A T niDNY FENBEIUE LITE YW. -.-1 {)"'I~ ~c-........l <S....-r-r- ""2... c;uat:) "I' .....-, $~'"' Wife shall receive alimml') p",iId~nte lite in the amount of$2QQ.BQ per Hl8B.tft ('''',,,.... paR-Bmg eaky ,,[the rl1un-rr-~ tj~('ree. Tbe-~~:fter, .,~.;f8 aB.all13e entitlea ta alimSA.:r pYFsn...~t ta ~""'~ as"i ~ . ~:""'" Roo''- "go"" '" mIl".,;.' ~ right" ....., ''PP'''''M' A"'c>:~~ ~"""~'''''''"'''"' . , I-I' . ~ ,8'. 7. ALIMONY (a) In recognition e criteria set forth in Sec 'on 3701 of the Divorce Code, 23 Pa.C.S.A. 9 3701, commencin on the distribution date oft s Agreement, Husband s 11 pay to Wife as alimony the sum 0 wo-Hundred Dollars ($20 0) per month for twenty- ne (29) months, payable on the day of each month whic all terminate only under e provisions of paragraph (b). The trst payment shall be due 0 he 4th day of the month D owing the distribution date 0 . s agreement, 2001. ) Notwithstanding the pro sions of the above paragr , the alimony pa ents provided for this paragraph shall term' te upon the first to occur f: (i) Wife's rem . ge; (ii) itation pursuant to 23 Pa. . .A. 93706; (iii) Wife's ath; or (iv) Husb s death. represent and acknowl ge that they each ve sufficient eeds and are able to su ort herself or him If through (c) Wife and Husb prop for her or his reasonabl app' opdate employment. (d) Wife do hereby acknowledge that Husband's income assets may substantia increase in valu , that she is not pr ently fully employed; that he ealth may deteriorate d she may not b employed at vari the future; that Husb d may receive subst ral inheritance in e future; and that notwithstanding th e or other economic c' cumstances whic may be a change' circumstances of substantial and conf ing nature, the p nents for her sup' ort and maintenance pr 'ded for in this Para aph are fair, just d reasonable, and '11 provide her with sufficien ancial resources t aintain and sup rt herself in accor ce with the standard of l' ing to which she is ccustomed. Not . standing anythin to the contrary in the Divorce C e, Wife does expre ly waive, dischar e and release any II all rights and claims which sh may have now or h eafter by reason the parties' marria to additional alimony, alimon)j endente lite, supp and/or mainten ce or any other ben fits resulting from the partie status as husband d wife, and furt r waives, discharge and releases any right which she ay hereafter have t seek modificatio of the terms of this greement in a court oflaw or eq , it being underst od that the foreg g constitutes a fma determination for all time of H sband's obligation Wife's support d maintenance. (e) usband does he by acknowledge tha e current rate of inflation may change; that his ing power ma decrease, or his hea may deteriorate; that Wife's income and assets may ubstantially incr ase in value; that she ay be employed at various times in the future; and th notwithstandin these or other econo ic circlunstances which in circUlllst ces of a substan . al and continuing nat e, the payments for WiD s 3 :--,:~"- ,.,. ,-<,," ,~ , T'''"I . ~~ - - , . . 1 '. except as set forth ip tins Agreement, Husband does hereby expressly waive, discharge and release any and all rights and elaims which he may have now or hereafter by reason of the parties' marriage, to alimony, alimony pendente lite, support and/or maintenance or any other benefits resulting from the part' s' status as wife and husband, and er waives, discharges and rele es any and all rights w ch he may now or hereafter have t eek modification of the terms of s Paragraph in a co of law or equity, it being under od that the forego. g constitutes a al determination fi r all time of Husband's obligati 0 contribute to W. s support and maintenance. . g contained. IS Agreement to t contrary, if a final de ree of divorce has not be awarded to eithe ife or Husband wi n three months of the d e of execution of this A eement due to the ction or inaction of fe, Wife hereby forti ts those payments who she is to receive der this Paragraph Husband's obligation to m e such payments sha cease. (g) twithstanding ing contained in this greement to the contrary, if final decree of d' orce has not bee awarded to either Wife Husb within three mon the ~ of ex ution of this A ement due to the action inaction f usband, Husban h r:~ orfeits those payment which he has paid. ~ 8~IFE INSURANCE - tv It shall not be necessary for either party to maintain a policy of life insurance for the benefit of the other party. 9. AUTOMOBILES (a) Wife is the owner of a 2000 Hyundai Elantra automobile. Wife shall have sole and exclusive possession of the Hyundai. Should any action be required to transfer title or other document of ownership, the parties will take steps to transfer and reflect ownership as soon as possible after the distribution date, (c) Wife agrees to assume all responsibility and hold Husband harmless for any and all liability, including insurance, costs and expenses associated with ownership of the above. The costs of any title transfers or fees shall be borne equally by the parties. 10. DIVISION OF REAL PROPERTY The parties acknowledge that they have not acquired any real property. Husband agrees to waive any right to funds in Wife's possession received on the sale of her real property in Missouri, currently held in Certificates of Deposit. 4 ";"-~'-'I I-I ~- - , . " " 11. PENSION AND RETIREMENT ACCOUNTS Husband and Wife shall maintain their separate pension, IRA and/or retirement accounts. Wife relinquishes any other rights, title, and interest she may have in all other existing and future retirement assets or benefits of Husband's pension or retirement plans. Husband relinquishes any and all rights, title, and interest he may have in all existing or future retirement assets or benefits of Wife's pension or retirement, 401K or other account. 12. MEDICAL INSURANCE The parties shall be responsible for their own medical insurance. 13. MARITAL DEBTS Each of the parties agrees to keep the other indemnified and saved harmless from all debts or liabilities incurred by him or her prior to the date of this agreement and from all actions, claims and demands whatsoever with respect thereto, and from all costs, legal or otherwise, and any counsel fees whatsoever pertaining to such actions, claims and demands. Since separation, neither party has contracted for any debts which the other will be responsible for and each party indenmifies and holds harmless the other for obligations separately incurred or assumed under this Agreement. 14. FILING OF IRS RETURN/TAXES , uol. Husband and Wife agree to file separate t x returns for the tax year.iR ';;hiCR thp . '11f" .. '"&, "" ;"'m, ..... ..- .'. "".'1" 15, The parties agree to cooperate with each other in obtaining a final divorce of the marriage. It is agreed that the parties will execute and allow to be filed the necessary documents to obtain a divorce under Section 3301(c) of the Divorce Code. 16. DEATH PRIOR TO DIVORCE If either Husband or Wife dies before the entry of a [mal decree in divorce between the parties, this Agreement is deemed to survive the death, and the parties, heirs or assigns shall enter into the same status as after the Agreement was entered into. 5 -,"~"""", ~~ _~r II 1- """"",., . ; , 17.' INCORPORATION This agreement is to be incorporated for the purposes of enforcement, but not merged into any subsequent Decree in Divorce. 18. CONTINUED COOPERATION The parties agree that they will, after the execution of this Agreement, execute any and all written instruments, assignments, releases, deeds or notes or other such writings as may be necessary or desirable for the proper effectuation of this Agreement. 19. COUNSEL FEES Except as otherwise provided for in this Agreement, each party shall be responsible for his or her own legal fees and expenses. 20. 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 for such breach, and the party breaching this contract shall be responsible for the payment of legal fees and costs incurred by the other in enforcing their rights under this Agreement or for seeking such other remedies or relief as may be available to him or her. 21. VOLUNTARY AGREEMENT The provisions of this Agreement are fully understood by both parties and each party acknowledges that the Agreement is fair and equitable; that it is being entered into voluntarily; and that it is not the result of any duress or undue influence. 22. WAIVER OF CLAIMS AGAINST ESTATES Except as herein otherwise provided, each party may dispose of his or her property in any way, and each party hereby waives and relinquishes any and all rights he or she may now have or 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, curtsey, statutory allowance, widows allowance, right to take in intestacy, right to take against the will of the other and the right to act as administrator or executor of the other's estate. 6 ,:>!'[litl~. " - n, __~ _ o. "I I-~, p " . . . .,' 23. BINDING EFFECT This Agreement shall be binding upon the parties' heirs, successors and assigns. 24. MODIFICATION AND WAIVER Any modifieation or waiver of any of the provisions of this Agreement shall be effective only if made in writing and executed with the same formalities as this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall not be construed as a waiver of any subsequent default of the same or similar nature. 25. PRIOR AGREEMENTS It is understood and agreed that any and all prior agreements which may have been made or executed or verbally discussed prior to the date and time ofthis Agreement are null and void and of no effect. 26. ENTIRE AGREEMENT This Agreement contains the entire understanding ofthe parties and there are no representations, warranties, covenants or undertakings other than those expressly set forth herein. 27. DESCRIPTIVE HEADINGS The descriptive headings used herein are for convenience only. They shall not have any binding effect whatsoever in determining the rights or obligations of the parties. 28. APPLICABLE LAW This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania. 7 ',~rrl>llm_ <~.' ',I I. "^^ . . -~ ~,..,..., . . " . . . '. IN WIlNESS WHEREOF, the parties set their hands and seals the day and the year first written above. ~~'D. ~-tt# Witness ~. 8 >~"", ,"',to,.,., '''"_''''' "'" , ,~ 11: p -~--- " ;c~~ - 4 . ~"_~ W~, . ."",,"Jl!IiilI/ill;ocrrl!'im~1llm ~, .. T , - ~"<";.-- -... -~~, -~" ~ <- o (") ~~i ~~E ~C:-; 2";- L:...I....l- 5>2 ~ --.-.- t.::' (0 , ~ -"e.'"'' ,-' 'c. ('l'T~""" C'_"'" r- "_.J --:h 4 'd (' f' ),d N } ::::> r"'''-l Ci L> "'. ~ , >,-.-. 2 -.;~ >;() ~-: -1'-1 ~f~ .:;:-i. 55 -< 1'3 ~ ~ _ "'"~~. ~,.~"""",._~~~'JIi~l'if'rijp.-rR"~Fi,--Wf '-""f'<'~.;''';'''~O'''''-.Y 'C"C_"'li""-'('T"""t!i<'!';'!~rrS".w'w,jl\r,!!\~!~~q,~~~.w'~~{ ~ ~ ~ ~I ~, I:: . ~ t: l.,,,,,,,,",,,, ..""'~ ""'~...," . ' In the Court of Common Pleas of Cumberland Connty, Pennsylvania DEIDRA K. GARNETT, Plaintiff, ) ) ) ) ) ) No. 2001 - 3J)0 CIVIL TERM IN DIVORCE vs. TIMOTHY A. PRYOR, Defendant. 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 inlportant 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 at: Office of the Prothonotary Cumberland County Courthouse Carlisle, Pennsylvania 17013 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 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. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, P A 17013 (717) 249-3166 1>",,~,"_.,_. ., <_'" , _,' "."'.'WT< l.-A"c-'-~'" "-":' ,~_ -,.~ ,","'^ ,r, ""1"'" . ~.., ~ ''', "r . " , ~,. ~n- ". , . ' . In the Court of Common Pleas of Cumberland County, Pennsylvania DEIDRA K. GARNETT, Plaintiff, TIMOTHY A. PRYOR, Defendant. ) ) ) ) ) ) No. 2001 - 3S57., CIVIL TERM IN DIVORCE vs. NOTICE OF A V All..ABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: 'I ,J n ~ ! ! Ii I I I: ! ~ l1 ~ Ij ~ " '. I. I, ~ , il You have been named as the Defendant in a Complaint in divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302(d) of the Divorce Code, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. ~ i f , I', l' I ! I, IJ i, I, " ~' [,i [, r, " ~ If you desire to pursue counseling, you must make your request for counseling within twenty days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. l' I 11 Ii i,~,~." v" .___-'l__ ,-__~w"'. ". ',- .~ . ". ""'FI .,--- '""",'''''--- "-'~-'__<'__,r"",_, ~"'";l''''__''(,''' _ ,>" ," , . Michael S, Travis ID No. 77399 4076 Market Street, Suite 209 Camp Hill, PA 17011 (717)731-9502 In the Court of Common Pleas of Cumberland! County, Pennsylvania DEIDRAK. GARNETT, Plaintiff, ) ) ) ) ) ) No. 2001- .35~ CIVIL TERM IN DIVORCE vs. TIMOTHY A. PRYOR, Defendant. COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE IN DIVORCE Plaintiff, by her attorney Michael S. Travis, respectfully represents: 1. Plaintiff is Deidra K. Garnett, who resides at 211 4th Street, New Cumberland, Cumberland County, Pennsylvania, 17070, since April 10, 2001. 2. Defendant is Timothy A. Pryor, who resides at 211 4th Street, New Cumberland, Cumberland County, Pennsylvania, 17070, for more than six months. 3. Defendant has been a bona fide resident of the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The plaintiff and defendant were married on March 17, 2001, in Las Vegas, Nevada. 5. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. The parties have been living separate and apart. At a subsequent time, plaintiff may submit an Affidavit that the parties have lived separate and apart for at least two (2) years. "'''"'. ,- " !~-,- 1'1 " ; 1-:" ". - --. ,.. 8. 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 employed by the Federal Gove=ent at a military instillation of the United States Armed Services, and may fall within the provisions of the Soldiers' and Sailors' Relief Act of Congress of 1940 and its amendments. 10. Plaintiff requests the court to enter a decree of divorce. I verify that the statements made in this Complaint 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~ ~ tYif- (:) / tdr~ ~~ Deidra K. Garnett, Plaintiff ravis Attorney for Plaintiff J.D. # 77399 4076 Market Street, Suite 209 Camp Hill, P A 17011 (717) 731-9502 Fax 731-9511 -"n ,," ':.:"''''--')" - -~ - I I , '- " ." In the Court of Common Pleas of Cumberland County, Pennsylvania DEIDRA K. GARNETT, Plaintiff, TIMOTHY A. PRYOR, Defendant. ) ) ) ) ) ) No. 2001 - 3556 CIVIL TERM IN DIVORCE vs. AFFIDAVIT OF CONSENT 1. A complaint in divorce under S 3301(c) of the Divorce <::ode was filed on June 8, 2001. ,., ",. 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. S 4904 relating to unsworn falsification to authorities. DATED: /~ /3'/~/ ~.a,k~ Deidra K. Garnett, Plaintiff ,',; .~-, ~,"--y----' _~_e ,;.~_" I~I!_'_'_' ,","'",'" __.." '~",' ~/~'I~;"_ f! ~ il " i! Ii 11 [\ , Ii Ii i tMI'IJ _ "~~<" - _. "" __._._v'", ,~~ _~ ~ =. ,~"'" "- ,~.<< A"' "_._,~.'""'~"_ "''''~~<~'"-"~,_~ -~ _._''''~,~,~~_."-=~- -, ~'" _'I; (") 0 0 c -,~, ;g:: Cl ;:BCD {" rT: r.ry. n"r:.' "'"?'-r-1 ~_e W :;-:2'3 zc (f')"'~'. ;,-) , '<-, ~~: C;:;C.: -0 :.) j;; C) .01' :J: ' l C, 20 r;:> tS~":-; >c L. .::) i~ =<' co :::::: ['5 EO , "'~ .~~~1Jf'~~'1jI~!i!'i',~,;:m;llfi1!"pl'.~';IPil~ti!~~'!l\i.....",,,,~__,'t;\!".~f'(~} - DEIDRA K. GARNETT, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2001 - 3556 CIVIL TERM TIMOTHY A. PRYOR, DEFENDANT IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on June 8, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of 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. I acknowledge that pursuant to Rule 1920.42(e) I have waived the requirement that I receive 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 subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: /{A/;(Ol / '.'",,"'''' ",,..,,-.." -,-"><--,q~,-'" .. ,-. ~- ""I.. ~...., '"' '" -'~ ~,"_..""",, .,.A, -"'~,,~ - .~~, .~,~ "_~ -"". ~'"''''''' "J-.;~"'" _'~"~'''"1_ 8,""" "'"","".' ,-<"" "'<~r~'- .~ .' t="if<4' " '---"-~"""-"""~;'J\.1.' 0 Cl ,:; C ..";., s: c:J -OeD ", ~g:; " ~~~; w kC ~ p.~--. 'j ~- z"-' ._~ >~ N C,I ~ Z ..-j ~ ':::> 55 OJ -< ~s (0 . ..,.......... ~ ~ L,_~J fi ,,~~ ~.", "",,?~,~,.R~~,l!!!',~_.!0l~;il>\"'~)'il'ln,1"'~:~"';;:Cf"'i1""i0'f'?1~'l'~o/~-;;-'\~l"l"lli~a;ij;.f;li\J~~~~~ In the Court of Common Pleas of Cumberland County, Pennsylvania DEIDRA K. GARNETT, Plaintiff, TIMOTHY A. PRYOR, Defendant. ) ) ) ) ) ) No. 2001 - 3556 CIVIL TERM IN DIVORCE vs. WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER ~ 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! 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 eorrect. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. S 4904 relating to unsworn falsification to authorities. Date: /2)3/ ~I /~ c::/~ Deidra K. Garnett, Plaintiff ; ~, <-., ----~--~.- ~ ,""..".'-,:,-' "~- - "~~~ -"<~--~"'~ ^ ",--~~~.-~- ~-~ o c S -00:.1 fl1f'T1 z-n zt; ~.:~:. !;2C ~Q ..;::U "...c: ~ -<. C? o '"''' M w:> ,~~~~,-"~~~.,-- "''''ed''''-' () ,'1 -"" "..:;.. ;-- -:-\~-f;8 t~~~q, 'r>(! Cftr. ~(fA !..,_J ~~ ~;J <J') -"-0> "iJ "< fS, [0 .~""''' ~- ~-- _,. ~,"'" ",,_~rI'~~~~j\W;~~j~!I:~~~~t~1-~':o-"~-_'~"'-"t~T~ " DElORA K. GARNETT, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2001 - 3556 CIVIL TERM TIMOTHY A. PRYOR, DEFENDANT IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(0) OF THE DIVORCE CODE 1. I consent to the entry of a final decree 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 subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: jj. /3/ /01 . I I ~d~ TIM A. PR R '}'~~ -" "''',-. ^ ',~ ,0.-,-,"""-0 'ow. ~"",,'-~, -,oF I . ~ L.HI. ~ ~ I ~ .!l!'!!l~~,~~._ '"~.. ".Il!'II,'n",!,~_.~, "._-~,,~-~,~ ~"'''''.' ~~"..~-,,- ~.~" ,~ "~n -"'<~, ''fl'' --~'~---'''''''<-M;;,'j'0 " C) 0 c: 0 ;s: 0 "n uii; ::i mrro rq Z=r' {""} ;i'""'; -','! Zfj:c G0 - (J)=,- " ~;f~: :) rc ',- ~'-., .v __"3~~'J ::P'() -". ~t'f~~ ffo L...."'" ~ is' ."'~ ::::J '::> '):" -< Co S:.l -< [5 [0 ,.,.~kt,~~~~"jF""H""1~;;;n;:."I':",;?,i"'!".}~'r,;~'~il.'ll';~~~~l'i'lr~>illi1iJ~~)~~~'~! , "l:i!V~""","",r'l~ _, ,",~"",c,,,,,,,'-",,"."',,,,_,, ,-",-;_, "'-"", ~ _ ,-,--'~ . bomplete~ .1, 2, and 3. Also complete ilem 4 ~ Reslricted Delivery is desired. . Prim YflUl' neme. ~ address on lhe reverse so~ we,opri'leIurn Ihe cerd 10 you, ' . Atliicfl;lhis cerd 10 the!back o!the msilpiece, Qr9h the fronl if space pennits. ,- ., 1. Article' Addressed to: "//mo'T1lf-.4. j1Rf'6R: <i. ~ I </4-(1_ rr"A'"T~ .,. Ao?Pv 44/"".;J~/#V.o 1""-4 ;7o-?O 11 os If YES, address ow: No 1/1 poPUU- 120. fV~fu~fi(.i-I4AJ~ ~ 3. Serv!SJ! Type []J..C"'ertlfied Mall CI !:xpress Mall [J Registered 0 Return Receipt for Merchandise I:] Insured Man I:] C,O.D. 4. Restricted Delivery? (Extra Fee) gj.:Ies"" 2. ArtIc~NUmibier~opym>m7'1ce~o ,', ! :' ,a2 '4{t . ,70l10.. .~ '7tl. (i)/./atJ" fi>tf.f.if., ,,; ; ;; PS Fonn3811, July 1999., Domestic Return Receipt .,.. < 1 rl, " 102595.0D-M-0952 . In the Court of Common Pleas of Cumberland County, Pennsylvania TIMOTHY A. PRYOR, Defendant. ) ) ) ) ) ) No. 2001 - 3556 DEIDRA K. GARNETT, Plaintiff, vs. CIVIL TERM IN DIVORCE AFFIDAVIT OF SERVICE I, Michael S. Travis, attorney for Plaintiff, in the above captioned action for divorce, hereby state that a conformed and certified copy of the Complaint in Divorce was served upon the Defendant by Certified Mail No. 7000 1670000089540229, return receipt requested, by depositing the same in the United States mail on June 8, 2001, pursuant to Rule 1920.4 of the Amendments to the Pennsylvania Rules of Civil Procedure relating to the Divorce Code. As indicated by the green return receipt card attached hereto, the Complaint was received by the Defendant on June 19,2001. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa. c.s. 94904 relating to unsworn > 4 ic~ael s. Trav;s 4076 Market Street, Suite 209 Camp Hill, PA 17011 (717) 731-9502 falsification to authorities. '"., "<. <'.,"W'" ,--~ '^ '<,- r-r'l , ~ (-, - ,'-' ,," , 'C" . "' <~ . .'JIfI ,t. ~" .~ _, 0 C~ /", C ~~ :s: CJ l.iCG iYl mffT (J Z-n :z: r- Gj ej) :::t--~ -<2- !<C,! .v ~o :J:J:: ;<;:2 i::;; Z <:::> ::;! (JO [S Eo , . ,r".~- ""'" ~ . . _~ ","",~~~~~Wl;I\1'i':!f~~;m!I)~~~~~MI~j~I~!i'!i!1IIQ _ ~_ ~_-':-"'77-""--'\T1lfl!