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HomeMy WebLinkAbout03-2232Plaintiff DENNIS L. HAIR, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW · NO. ~5>J~ ,,~&3.XCIVIL TERM : IN DIVORCE NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the 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 the Cumberland County Court House, High and Hanover Streets, Carlisle. 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 THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Phone: (717) 249-3166 Plaintiff DENNIS L. HAIR, Defendant · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA · CIVIL ACTION - LAW · NO O~q- ,2 3,.3 x- CIVIL TERM · IN DIVORCE COMPLAINT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Sandra K. Hair, who currently resides at 11 Winchester Gardens, Carlisle, Cumberland County, Pennsylvania, since 1991. 2. Defendant is Dennis L. Hair, who currently resides at 244 Walnut Bottom Road, Carlisle, Cumberland County, Pennsylvania, since approximately June 0£2000. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on June 28, 1991, in Newville, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 6. The marriage is irretrievably broken· 7. 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. 8. Plaintiff requests the Court to enter a Decree in Divorce· Respectfully submitted, ROMINGER & BAYLEY Michael J. W-hare, Esq.~ Attorney for Plaintiff 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Date: May 7, 2003 Plaintiff DENNIS L. HAIR, Defendant · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA · CIVIL ACTION - LAW · NO. · IN DIVORCE CIVIL TERM VERIFICATION 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. Sandra K. Hair, Plaintiff Plaintiff DENNIS L. HAIR, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 6>.3- .1..}, 3',~-CIVIL TERM : IN DIVORCE NOTICE ffyou wish to deny any of the statements set forth in this Affidavit, you must file a counter-affidavit within twenty (20) days after this Affidavit has been served on you or the statements will be admitted. AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on June 10, 2000, and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. I understand that I may lose fights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 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. ~'~dra K. Hair, Plaintiff ' SANDRA K. HAIR, DENNIS L. HAIR, Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY~ PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 03 - 2232 CIVIL TERM : IN CUSTODY COMPLAINT FOR CUSTODY NOW comes the plaintiff, by her attorney, Harold S. Irwin, III Esquire, and files this complaint and agreement for custody, representing as follows: 1. The plaintiff, Sandra K. Hair, is an adult individual residing at 25 Buckthorn Drive, Carlisle, Cumberland County, Pennsylvania 1701:3. 2. The defendant, Dennis L. Hair, is an adult individual residing at 244 Walnut Bottom Road, Carlisle, Cumberland County, Pennsylvania 17013. 3. The parties are the natural parents of a minor child, namely Ethan Tyler Hair (born April 4, 1991, age 12 years). 4. The child resided with both of the parties from the birth of the child until the parties' separation on June 10, 2000. The child has resided with each party at their respective residences on a mutually agreeable joint custody basis since the parties' separation. 5. The plaintiff has not participated as a party, witness or in any other capacity in other litigation concerning the custody of the child in this or another court. 6. The plaintiff has no information regarding any other custody proceeding concerning the child pending in a court of this Commonwealth. 7. The plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 8. The plaintiff believes and therefore avers that the best interests and permanent welfare of the child require that the parties have joint legal custody of the child and that the parties shall share physical custody of the child in accordance with their mutual agreement as provided below. 9. Both parties, as evidenced by their joint execution of this complaint, have mutually agreed upon an amicable arrangement for the legal, physical and temporary custody of the child and request that the Court enter an order as follows without the necessity of a hearing: A. The parties shall have joint legal custody of their son, ETHAN TYLER HAiR (born April 4, 1991, age 12). B. The Mother shall have primary physical custody of the child, subject to periods of temporary physical custody and visitation with the Father as the parties may mutually agree from time to time. C. The Father shall always have the child on Father's Day and the Mother shall always have the child on Mother's Day. The parties shall share time with the child on his birthday and on holidays on as much an equal basis as reasonably possible. D. Each party shall be entitled to uninterrupted extended time with the child during the Summer for vacation periods, upon notice to each other by May 1st of each year. E. The parties shall have reasonable telephone contact with the child while the child is in the other's custody. F. The parties shall keep each other advised immediately relative to any emergencies concerning the child and shall further take any necessary steps to insure that the health, welfare and well being of the child is protected. G. The parties shall do nothing that may estrange the child from the other parties or hinder the natural development of the child's love or affection for the other parties. H. Any modification or waiver of any of the provisions of the agreement of the parties shall be effective only if made in writing and only if executed with the same formality of the agreement of the parties. I. In the event of the breach of the agreement of the parties by any party, the nonbreaching party shall have the right to file a petition for contempt of court and to seek specific performance of the terms of the agreement of the parties. All costs, expenses and reasonable attorney fees incurred by the successful party in any litigation to obtain an order of contempt or specific performance of this agreement shall be recoverable as part of the judgment entered by the court. J. The parties agree that in making this agreement there has been no fraud, concealment, overreaching, coercion or other unfair dealing on the part of the other. K. The parties desire that this agreement be made an order of Court through the Court of Common Pleas of Cumberland County without the necessity for a hearing or other proceeding thereon, and further acknowledge that the Court of Common Pleas of Cumberland County has jurisdiction over these issues and shall retain such jurisdiction should circumstances change and any party desire further or require further modification of said Order. WHEREFORE, the plaintiff respectfully requests that the court enter an order providing for the legal and physical custody of the child as aforesaid. 35 East High Street Carlisle, Pennsylvania 17013 (717) 243-6090 Supreme Court I.D. No. 29920 VERIFICATION AND CONFIRMATION OF AGREEMENT We do hereby verify that the acts set forth in this complaint are true and correct. We understand that false statements herein ara made subject to the penalties of 18 Pa.C.S.A. § 4904, ralating to unsworn falsification to authorities. Furthermore, by the execution of this Confirmation, we do each unequivocally exprass our mutual and voluntary agraement to the amicable custody arrangement provided above and request that the terms thereof be entered as an Order of Court without the necessity of a custody conciliation, hearing or other proceeding. Date: Date: .(SEAL) SANDRA K. HAIR DENNIS L. HAIR Mayi23-03 01:22P I~-win Law Office 7]7+243+9200 P.13 VERIFICATI AND CONFIRMATION F AGR E ENT We do hereby verify that the acts set forth in this complaint are tree and correct. We understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. § 4904, relating to unswom falsification to authorities. Furthermore, by the execution of this Confirmation, we do each unequivocally ()xpress our mutual and voluntary agreement to the amicable custody arrangement provided above and request that the terms thereof be entered as an Order of Court without the necessity of a custody conciliation, hearing or other proceeding. Da~: Date: SANDRA K. HAIR ~_ ~,.~,~,~.,,4 /~/~ (SEAL) DENNIS L. HAIR COMMONWEALTH OF PENNSYLVANIA ) ) SS: COUNTY OF CUMBERLAND ) On this, the .~ day of J,~ r~ ~ ,2003, before me the undersigned officer; personally appeared Michael J. Whare, Esquire, known to me to be a member of the bar of the highest court of the said Commonwealth, Supreme Corn1: ID Number 89028 and a subscribing witness to the within instrument, and certify that he was personally present when whose name is subscribed to the within instrument executed the same; and that said person acknowledged that he executed the same for the purposes therein contained. WITNESS my hand and seal the day and year aforesaid. Notary Public COMMONWEALTH OF PENNSYLVANIA : :SS: COUNTY OF CUMBERLAND : On this, the day of ,2003, before me, the undersigned officer, personally appeare~ S,~,NDRA K. HAIR, knc~wn to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument and acknowledged that she executed same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. Notary Public .(SEAL) COMMONWEALTH OF PENNSYLVANIA ::SS: COUNTY OF CUMBERLAND : P~. ~ ,2003, me, On this, the'~ . day of ~ _ . before the undersigned officer, personally appeared DENNIS L. HAIR, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument and acknowledged that he executed same for the purposes therein contained. IN WITNESS WHEREOF, I hereun~l~ ~,e~Y hand and official seal. / ,(,,/ . _ NOTARIAL SF.N. JUN U6 ZOO3 ~ HAROLD S. IRWIN~ III, ESQUIRE ATTORNEY ID NO. 29920 35 EAST HIGH STREET CARLISLE PA 17013 (7t7) 243'8090 ATTORNEY FOR PLAINTIFF SANDRA K. HAIR, DENNIS L. HAIR, Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION. LAW NO. 03 - 2232 CIVIL TERM IN CUSTODY ORDER OF COURT AND NOW, this ~0~ day of ~'~J~C._ ,2003 upon presentation and consideration of the within complaint and the stipulation and agreement incorporated therein, and upon agreement of the parties, it is hereby ordered and decreed as follows: A. The parties shall have joint legal custody of their son, ETHAN TYLER HAIR (born April 4, 1991, age 12). B. The Mother shall have primary physical custody of the child, subject to periods of temporary physical custody and visitation with the Father as the parties may mutually agree from time to time. C. The Father shall always have the child on Father's Day and the Mother shall always have the child on Mother's Day. The parties shall share time with the child on his birthday and on holidays on as much an equal basis as reasonably possible. D. Each party shall be entitled to uninterrupted extended time with the child during the Summer for vacation periods, upon notice to each other by May I st of each year. E. The parties shall have reasonable telephone contact with the child while the child is in the other's custody. F. The parties shall keep each other advised immediately relative to any emergencies concerning the child and shall further take any necessary steps to insure that the health, welfare and well being of the child is protected. G. The parties shall do nothing that may estrange the child from the other parties or hinder the natural development of the child's love or affection for the other parties. H. Any modification or waiver of any of the provisions of the agreement of the parties shall be effective only if made in writing and only if executed with the same formality of the agreement of the parties. I. In the event of the breach of the agreement of the parties by any party, the nonbreaching party shall have the right to file a petition for contempt of court and to seek specific performance of the terms of the agreement of the parties. All costs, expenses and reasonable attorney fees incurred by the successful party in any litigation to obtain an order of contempt or specific performance of this agreement shall be recoverable as part of the judgment entered by the court. J. The Court of Common Pleas of Cumberland County has jurisdiction over these issues and shall retain such jurisdiction should cimumstances change and any party desire further or require further modification of said Order. BY THE COURT, J. SANDRA K. HAIR, Plaintiff DENNIS L. HAIR, Defendant : IN THE COURT OF COMMON PLEAS OF : CLrMBERLAND ,COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 03-2232 CIVIL TERM : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(d) OF THE DIVORCE CODE 1. I consent to the entry ora final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyers fees or expenses ifI do not claim them before a divome is grantexl. 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 tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unswom falsification to authorities. Sandra K. Hair, Plaintiff Plaintiff DENNIS L. HAIR, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 03-2232 CIVIL TERM : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(d) 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 ifI 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 a_~er it is filed with the Prothonotary. I verify that the statements made in this Affidavit are tree 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. Dennis L, Hair, I~efendant MARRIAGE SETTLEMENT AGREEMENT ~z_~da) THIS AGREEMENT made this , of /t.y./~ between DENNIS L. HAIR, hereinafter referred to as "HUSBAND") HAIR, (hereinafter referred to as "WIFE"). ,2003 by and and SANDRA K. WITNESSETH: WHEREAS, HUSBAND and WIFE were lawfully married on June 28, 1991; and WHEREAS, diverse, unhappy differences, disputes and difficulties have arisen between the parties and it is the intention of HUSBAND and WiFE to live separate and apart for the rest of their natural lives, and the parties hereto are desirous of settling fully and finally their respective financial and property rights and obligations as between each other, including, without limitation by specification; the settling of all matters between them relating to the ownership and equitable distribution of real and personal property; the settling of all claims and possible claims by one against the other or against their respective estates and equitable distribution of property and alimony for each party. NOW, THEREFORE, in consideration of the promises and the mutual promises, covenants and undertakings hereinafter set forth and for other good and valuable consideration, receipt of which is hereby acknowledged by each of the parties hereto, HUSBAND and WIFE, each intending to be legally bound, hereby covenant and agree as follows: 1. The parties intend to maintain separate and permanent domiciles and to live apart from each other. It is the intention and purpose of this agreement to set forth the respective rights and duties of the parties while they continue to live apart from each other. 2. The parties have attempted to divide their matrimonial property in a manner that conforms to a just and right standard, with due regard to the rights of each party. It is the intention of the parties that such division shall be final and shall forever determine their respective rights. The division of existing marital property is not intended by the parties to constitute in any way a sale or exchange of assets. 3. Further, the parties agree to continue living separately and apart from each other at any place or places that he or she may select. Neither party shall molest, harass, annoy, injure, threaten or interfere with the other party in any manner whatsoever. Each party may carry on and engage in any employment, profession, business or other activity as he or she may deem advisable for his or her sole use and benefit. Neither party shall interfere with the uses, ownership, enjoyment or disposition of any property now owned and not specified herein or property hereafter acquired by the other. 4. The consideration for this contract and agreement is the mutual benefits to be obtained by both of the parties hereto and the covenants and agreements of each of the parties to the other. The adequacy of the consideration for all agreements herein contained is stipulated, confessed, and admitted by the parties, and the parties intend to be legally bound hereby. 5. DEBTS: It is further mutually agreed by and between the parties that the debts be paid as follows: A. The HUSBAND shall assume all liability for and pay and indemnify the WIFE against any of his individual debts. B. The WIFE shall assume all liability for and pay and indemnify the HUSBAND against any of her individual debts. C. The parties acknowledge and confirm that they have no joint debts or obligations. 6. PROPERTY: Except as herein provided, the parties agree that they have previously divided their personal property to their mutual satisfaction. No payment shall be made by either party to the other as a result of the division of property contained herein. The parties agree that this division is fair and equitable, and is voluntary and made without duress by or upon either party. The parties further agree that henceforth, each of the parties shall own, have and enjoy independently of any claim or right of the other party, all items of personal property of every kind, nature and description and wherever situated, which are now owned or held by or which may hereafter belong to the HUSBAND or WIFE, with full power to the HUSBAND or the WIFE to dispose of same as fully and effectually, in all respects and for all purposes as if he or she were unmarried. 7. INCOME TAX RETURNS: All income tax returns for the current and future tax years will be filed separately and the parties will each retain any refund due to them. 8. SUPPORT AND ALIMONY: Both parties hereby waive and forego all financial and material spousal support from each other and agree not to request or seek to obtain alimony, alimony pendente lite or spousal support before or after any divorce which may be granted. 9. DIVORCE: The parties both agree to cooperate with each other in obtaining a final divorce of the marriage. It is agreed that the marriage is irretrievably broken and that the parties have been separated since June 10, 2000. Both parties will execute whatever final documents are necessary to obtain the divorce as soon as possible after the execution of this agreement. Both parties will be responsible for their own legal costs and fees incurred in this divorce. 10. BREACH: in the event of the breach of this agreement by either party, the nonbreaching party shall have the right to seek monetary damages for such breach, where such damages are ascertainable, and/or to seek specific performance of the terms of this agreement, where such damages are not ascertainable. All costs, expenses and reasonable attorney fees incurred by the successful party in any litigation to obtain monetary damages and/or specific performance of this agreement shall be recoverable as part of the judgment entered by the court. 11. 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 fome and effect to the provisions of this agreement. 12. VOLUNTARY EXECUTION: The provisions of this agreement and their legal effect have been fully explained to the parties and its provisions are fully understood. Both parties agree that they are executing this agreement freely and voluntarily. HUSBAND's legal counsel is Harold S. Irwin, III, Esquire. WIFE's legal counsel is Michael J. Whare, Esquire. 13. ENTIRE AGREEMENT: Thi~ agreement contains the entire understanding of the parties and there are no representations, warranties, covenants or undertakings other than those expressly set forth herein. 14. APPLICABLE LAW: This agreement shall be construed under the laws of the Commonwealth of Pennsylvania. 15. PRIOR AGREEMENTS: It is understood and agreed that any and all property settlement agreements which may or have been executed or verbally discussed prior to the date and time of this agreement are null and void and of no effect. 16. WAIVER OF CLAIMS AGAINST THE ESTATES: Except as otherwise provided herein, 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, curtesy, statutory allowance, widow's allowance, right to take in intestacy, right to take against the Will of the other, and right to act as administrator or executor of the other's estate, and each 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. IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the day and year first above written. WITNESSES: DENNIS L. HA~IR (SEAL) (SEAL) SANDRA K. HAIR May:23-03 01:1BP Irwin Law Office 717+243+9200 P.05 16. WAIVER OF CLAIMS AGAINST THE ESTATES: Except as otherwise provided herein, each pady 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, urnder 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, curtesy, statutory allowance, widow's allowance, right to take in intestacy, right to. take against the Will of the other, and right to act as administrator or executor of the other"s estate, and each 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. IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the day and year first above written. Wn'NESSES: , (SEAL) SANDRA K. HAIR ~ ~\~ C~. - (SEAL) COMMONWEALTH OF PENNSYLVANIA : :SS: COUNTY OF CUMBERLAND : PERSONALLY APPEARED BEFORE ME, a notary public for Cumberland County, Pennsylvania, this ~V~-day of ~/"-~ ,2003, DENNIS L. HAIR, 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 official seal. H - NOTARIALsEAL - AROLD 8, IRWIN, III, NOTARY PUBUC C.A_R.L?.LE ~0ROUGH, ~ OF CUI~ERLANOl MY [;0MMISSION EXPIRES 0(~0BER 22, 2006 COMMONWEALTH OF PENNSYLVANIA : :SS: COUNTY OF CUMBERLAND : PERSONALLY APPEARED BEFORE ME, a notary public for Cumberland County, Pennsylvania, this __ day of ,2003, SANDRA K. HAIR, 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 official seal. Notary Public COMMONWEALTH OF PENNSYLVANIA ) ) SS: COUNTY OF CUMBERLAND ) On this, the __:~ day of ~)'~ ~ ,2003, before me the undersigned officer; personally appeared Michael J. Whare, Esquire, known to me to be a member of the bar of the highest court of the said Commonwealth, Supreme Court ID Number 89028 and a subscribing witness to the within instrument, and certify that he was personally present when whose name is subscribed to the within instrument executed the same; and that said person acknowledged that he executed the same for the purposes therein contained. WITNESS my band and seal the day and year aforesaid. Notary Public Sandra K. Hair, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Dennis L. Hair, : Defendant : NO. 03-2232 : in Divorce CIVIL TERM 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: 3301(d)(1) of the Divorce Code. 2. Date and manner of service of the Complaint: May 7, 2003, by Process Server. 3. (Complete either paragraph (a) or (b)) (a) [)ate of execution of the affidavit of consent required by § 3301 (c) or The Divorce Code: by the Plaintiff ; by the Defendant -. (b) (I) Date of execution of the Plaintiffs Affidavit required by §3301 (d) of the Divorce Code: 5/9/2003; (2) Date of filing and service of the Plaintiffs Affidavit upon the Respondent: Filing 5/22/2003 and Service 5/16/2003. 4. Related claims pending: ~none Complete either (a) or (b). (a) Date and manner of service of the notice of intention to file praecipe to Co) transmit record, a copy of which is attached: Waiver of notice on 7/2/02 by Dennis Hair, and 6/6/03 by Sandra Hair. Date Plaintiffs Waiver of Notice in §3301(c) Divorce was filed with the iProthonotary: Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: ,2003 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID No. 89028 IN THE COURT OF COMMON OF CUMBERLAND COUNTY STATE OF ~. PENNA. Sandra K. Hair N O. 03-2232 PLEAS VERSUS DeDD±S L. Halr DECREE IN DIVORCE AND NOW, , ~ IT IS ORDERED AND DECREED THAT Sandra K. Hair __, PLAINTIFF, AND DenDis L. Hair ,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 ENTEr~:-'D; None. The Marital Settlement is incorporated into but not merged with the Divorce Decree. BY THE COURT: / ATT : J.