HomeMy WebLinkAbout01-04095.~ ~.~
IN THE COURT OF COMMON PLEAS
MICHAEL C. LANE, JR.
Plaintiff
N O. 01-4095
VERSUS
AMY N. LANE,
Defendant
DECREE IN
DIVORCE
AND NOW, /{,G+-u G.ti7 ~y~ tGC2, IT IS ORDERED AND
DECREED THAT MT('AAFT (' TANF.~ I$ , PLAINTIFF,
AND AMY N. LANE , 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; NONE
This Agreement of January 11, 2002 is hereby incorporated into the
final Divorce Decree.
BY THE COURT:
ATTE~: ', A~ ,J,
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AGREEMENT
THIS AGREEMENT, made this f~ day of ~~~~G,n~ ~00~
by and between MICHAEL C. LANE, JR., of Dauphin Cot~.nty,
Pennsylvania (hereinafter referred to as HIISSAND), and AMY tn~. LANE
of Cumberland County, Pennsylvania (hereinafter referred to as
WIFE),
WHEREAS, HIISBAND and WIFE were lawfully married o
December 31, 1994 in Passaic County, New Jersey, and;
WHEREAS, one child born of this marriage, to wi*_:
Dylan Lane, born May 3, 1999
WHEREAS, diverse, unhappy differences, disput2~ and
difficulties have arisen between the parties and it _~_s the
intention of wIFE and SIISBAND.to live separate and apart f~:.s- the
rest of their natural lives, and the parties hereto are desirous of
settling fully and finally their respective financial and prc~aerty
rights and obligations as between each other, including ~,~irnout
limitation by specification: the settling of all matters b~=r..aeen
them relating to the ownership and equitable distribution ~_f real
and personal property; settling of all matters betwee*: them
relating to the past, present and future support, and alimony; and
or maintenance of the child; the implementation of custody and
visitation arrangements for the minor child of the parties; anal in
general, the settling of any and all claims by one agains~. the
other or against their respective estates.
NOW, THEREFORE, in consideration the premises and c the
mutual promises, covenants and undertakings hereinafter see i`,~rth
h.
hereby acknowledged by each of the parties hereto, :,~~s~_ and
HITSBAND, each intending to be legally bound, hereby cover_~nt and
agree as follows:
1. SEPARATION: It shall be lawful for each part~r~ ~.t all
times hereafter to live separate and apart from the othe±- r,?_rts' at
such place as he or she may from time to time chose or de~:^1 rit.
The foregoing provisions shall not be taken as an admiss..ox: cr: the
part of either party of the lawfulness or unlawfulness ~_ ;:he
causes leading to their living apart.
2. INTERFERENCE: Bach party shall be f:-s~ ~=rom
interference, authority, and contact by the other, as fully <_~ if
he or she were single and unmarried, except as may be necesw.>V~,, to
carry out the provisions of this Agreement. Neither party ehall
molest the other or attempt to endeavor to molest the c`re~_. nor
compel the other to cohabit with the other, or in any wa_r i;a.~=ass
or malign the other, nor in any way interfere with their r~,=.c=fu1
existence, separate and apart and they agree that neither s~;a~_-i do
or say anything to the child of the parties at any time wl?i~~'` ,N=.ght
in any way influence the child adversely against the other _c.=.rty..
3. SUBSEQIIENT DIVORCE: The parties hereby ac'.~__~c~*_.edge
that HUSBAND has filed a Complaint in Divorce in Cumberlan;~n-~nty
to docket number 01-4095 claiming that the marr:.-z.;~ is
irretrievably broken under the no-fault mutual consent pro~•i~io^ of
Section 3301 (c) of the Pennsylvania Divorce Code. WIFE hereby
expresses her agreement that the marriage is irretrievab7._r h=oken
and expresses her intent to execute any and all affidavits :~,- ::•ther
2
~.
documents necessary for the parties to obtain an absolute 3~•.orce
pursuant t4 Section (c) of the Divorce Code after January "!, :'x002.
The parties hereby waive alI rights to request Court-ordered
counseling under the Divorce Code. It is further specir._cally
understood and agreed by the parties that the provisions ~f this
Agreement as to equitable distribution of property of the n:~=ties
are accepted by each party as a final settlement for all p•~~-roses
whatsoever, as contemplated by the Pennsylvania Divorce Ccde.
Should a decree, judgment or order of separatic~ or
divorce be obtained by either of the parties in this or ama ether
state, country or jurisdiction, each of the parties hereby co:~sents
and agrees that this Agreement and all of its covenants ~~~__:. be
not affected in any way by any such separation or divorce; and chat
nothing in any such decree, judgment, order or further modii_c%-~*_ion
or revisign thereof shall alter, amend or vary any terms c•:t'. _.nis
Agreement, whether or not either or both of the parties small
remarry. It is specifically agreed, that a copy of this Av:~eement
or the substance of the provisions thereof,-may be incorporaved by
reference but not merged into any divorce, judgment or dec-re-_ It
is the specific intent of the parties to permit this Agreemer_~: to
survive any judgment and to be forever binding and conclusi*: e', upon
the parties.
4. DATE OF EXECIITION: The "date Of executio^.' or
"execution date" of this agreement shall be defined as the date
upon which it is executed by the parties if they have each exr~.Lted
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the agreement on the same date. Otherwise the "date of ea::=_c::.::ion"
or "execution date" of this agreement shall be defined as ~`_~e date
of execution by the party last executing this agreement.
5. DISTRTBUTSON DATE: The transfer of propert«, `~:~-;ds
and/or documents provided for herein, shall only take place. ~*_-: the
"distribution date" which shall be defined as specified h=:-e'=.
6. MIITIIAL RELEASE: HUSBAND and PiIFE each de :^.~:r~by
mutually remise, release, quitclaim and forever discharge th= ^`=_°.r
and the estate of such other, for all time to come, and ti:.. ail
purposes whatsoever, of and from any and all rights, til~ >nd
interests, or claims in or against the property (including a.r.come
and gain from property hereafter accruing) of the other or =a~inst
the estate of such other, of whatever nature and why-rest wer
situation, which he or she now has or at any time heresf;v=~ ;gay
have against the other, the estate of such other or a~?•,> dart
thereof, whether arising out of any former acts, cor.~:::•:~`s,
engagements or liabilities of such other or by way of coe<z-:_- cr
curtest', or claims in the nature of dower or curtest' or widaa-'~a or
widower's rights, family exemption or similar allowance, c_~ :izder
the intestate laws, or the right to take against the spouse's F;i_i-
or the right to treat a lifetime conveyance by the o~~e° as
testamentary, or all other rights of a surviving Gpon.=. to
participate in a deceased spouse's estate, whether arise.^:= vr3er
the laws of (a) Pennsylvania, (b) any State, Commonwea".'~ or
territory of the United States, or (c) any country, or ar_v r;rhts
which either party may have or at any time hereafter shall ~=v= for
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f:
past, present or future support or maintenance, alimony, 'i..n!ony
pendente lite, counsel fees, property division, costs or exile-!ses,
whether arising as a result of the marital relations or other~.vise,
except, all rights and agreements and obligations of whatsoever
nature arising or which may arise under this Agreement or f~ the
breach of any provisions thereof. It is the intention of >w".?B3AND
and WIFE to give to each other by the execution of this Agreement
a full, complete and general release with respect to any and all
property of any kind or nature, real, personal or mixed, wl.=_oh the
other now owns or may hereafter acquire, except and only exce~a':. all
rights and agreements and obligations of whatsoever nature prising
or which may arise under this Agreement or for the breach c±~' any
provision thereof. It is further agreed that this Agreement W:-!all
be and constitute a full and final resolution of any and all Maims
.which each of the parties may have against the other for eq~~.itable
division of property, alimony, counsel fees and expenses, ?~_z!ony
pendente lite or any other claims pursuant to the Pennsviv:,nia
Divorce Code or the divorce laws of any other jurisdiction.
7. ADVICE OF CODNSEL: The provisions of this Aaresment
and their legal effect have been fully explained to the parties by
JUDITH A. CALKIN, ESQUIRE, counsel for HUSBAND and MIC~?L~=~?l~ S.
TRAVIS, ESQUIRE, counsel for WIFE.
HIISBAND and WIFE accept that this Agreement is, *! the
circumstances, fair and equitable and that it is being entered into
freely and voluntarily and that execution of this Agreement i} not
the result of any duress or undue influence and that it is ~n~r the
5
result of any collusion or improper or illegal agreemr=.n~ or
agreements. The parties further acknowledge that they have each
made to the other a full accounting of their respective asse*:=,
estate, liabilities, and sources of income and that they waive any
specific enumeration thereof for the purpose of this Agree~ent.
Each party agrees that he and she shall not at any future ~:!~.~?
raise as a defense or otherwise the lack of such disclosure i:= ar_~r
legal proceeding, involving this Agreement, with the exceptic.~ of
disclosure that may have been fraudulently withheld.
8. WARRANTY AS TO SICISTING OBLIGATIONS: Each par~t•
represents that they have not heretofore incurred or contracted ~6r
any debt or liability or obligation for which the estate of t.%=
other party may be responsible or liable except as may be pro~~~_c~~.
for in this Agreement. Each party agrees to indemnify and holes r_'rk
other party harmless for and against any and all such debts,
liabilities or obligations of every kind which may have heretc.o,-e
been incurred by them, including those for necessities, excep~ -.~,_.
the obligations arising out of this Agreement.
9. WARRANTY AS TO FDTUR$ OBLIGATIONS: WIFPs and HUS4:'~?~'??
each covenant, warrant, represent and agree that with the exce~ti.^=~
of obligations set forth in this Agreement, neither of them ss:,=~i.
hereafter incur any liability whatsoever for which the esterte :._
the other may be liable. Each party shall indemnify and hoi,~.
harmless the other party for and against any and all debts, cha:cs,^
and liabilities incurred by the other after the execution dare ~:
this Agreement, except as may be otherwise specifically provire=9
6
for by the terms of this Agreement.
10. PERSONAL PROPERTY. The parties hereto have div;.~:?~=
between themselves, to their mutual satisfaction, all item.=, ._
tangible and intangible marital property. HUSBAND shall be the srl=
owner of the property listed in Exhibit "A". WIFE shall he ~....:
sole owner of all other property located in the marital "^,_-_:~..
Neither party shall make any claim to any other such iter.:. c-
marital property, or to the separate personal property of e__`.-~
party, which are now in the possession and/or under the contro~ r,~
the other. Should it become necessary, the parties each agre= -c,
sign, upon request, any titles or documents necessary to ciV=:
effect to this paragraph. Property shall be deemed to be iY_ -.i-:=
possession or under the control of either party if, in the case _-
tangible personal property, the item is physically i~; _._-.
possession or control of the party at the time of the signing or
this Agreement, and in the case of intangible personal property ~T:
any physical or written evidence of ownership, such as pass'~~.~~;:,
checkbook, policy or certificate of insurance or other sir~~_a
writing is in the possession or control of the party. HVSSAN,~ =r_'
WIFE shall be deemed to be solely and individually in ce
possession, control and ownership of any pension or other emp?^;===
benefit plans or other employee benefits of any nature to ~.-=.~.-ii
either party may have a vested or contingent right or inte*_-=s:,
apart from the provisions of the Divorce Code, at the time er `r_=
signing of this Agreement.
11. MOTOR VEHICLES: WIFE shall become the sole a^~'
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exclusive owner of the 1998 Honda and HUSBAND shall become the sole
and exclusive owner of the 1999 Honda. Each will be solely liable
for the payments of the liens on their individual vehicles.
12. REAL ESTATE: The parties. own by the entireties a
home located at 2190 Brunswick Avenue, Mechanicsburg, Cumberland
County, Pennsylvania. The home is currently on the market for
sale. After the home is sold WIFE will receive all of the proceeo.~
should there be a deficit after the sale it will be shared ecua.l-r
by the parties. Pending the sale WIFE will have sole posses;.^~^
of the home and she will be solely liable for the payments of vhe
expenses on said home, including, but not limited to, the pa~m.:e~?.t
of the mortgage.
13. AFTER ACQIIiRED PERSONAL PROPERTY: Each o= `_^.~
parties shall hereafter own and enjoy, independently of any clams
or right of the other, all items of personal property, tangibl or
intangible, hereafter acquired by him or her, with full power ~:z
him or her to dispose of the same as fully and effectively, i:? ~1=
respects and for all purposes, as though he or she were unmarried.
14. APPLICABILITY OF TAX LAW TO PROPERTY TRANSFER:
The parties hereby agree and express their intent that any tray:-:`=r
of property pursuant to this Agreement shall be within the sccpe
and applicability of the Deficit Reduction Act of 1984 (here--in =__
"Act"), specifically, the provisions of said Act pertainin7 to
transfers of property between spouses or former spouses. "~'~.
parties agree to sign and cause to be filed any elections or eta=r
documents required by the Internal Revenue Service to render :-~^-=
8
Act applicable to the transfers set forth in this Agreement wit'.~out
recognition of gain on such transfer and subject to the carry-over
basis provisions of said Act.'
15. The parties agree to file a joint IRS return; nor
2001. WIFE shall receive any refund due the parties.
16. WAIVER OF ALIMONY PENDENTE LITE AND LEGAL "r'~:°~:
Each party hereby waives any right to alimony pendente lite. '''he
parties agree to be responsible for their own attorney's fees..
17. FIILL DISCLOSIIRE: Each party asserts that she cr he
has made a full and complete disclosure of all the real ?.nd
personal property of whatsoever nature and wheresoever loc~r_~d
belonging in any way to each of them, of all debts and encumbra;-~ces
incurred in any manner whatsoever by each of them, of all sourc~a
and amounts of income received or receivable by each of parties,
and of every other fact relating in any way to the subject m~tt_r
of this Agreement. These disclosures are part of the considera:c~cn
made by each party for entering into this Agreement.
18. WAIVER OF ALIMONY: The parties herein acknowledge
that by this Agreement they have respectively secured wnd
maintained a substantial and adequate fund with which to provide
for themselves sufficient financial resources to provide for th=.iLL
comfort, maintenance and support, in the station of life to wh,~cr
they are accustomed, WIFE and HIISBAND do hereby waive, release
and give up any rights they may respectively have against the other
for alimony, spousal support or maintenance. It shall be fraTM the
execution of this Agreement the sole responsibility of each e_ the
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respective parties to sustain themselves without seeking any
support from the other party.
19. BANKRUPTCY OR REORGANIZATION PROCEEDINGS: In the
event that either party becomes a debtor in any bankruptc~~ or
financial reorganization proceedings of any kind while any
obligations remain to be performed by that party for the benef.t e±.
the other party pursuant to the provisions of this Agreement, the
debtor spouse hereby waives, releases and relinquishes any right to
claim any exemption (whether granted under State or Federal la~~~) to
any property remaining in the debtor as a defense to any claim ~^ade
pursuant hereto by the creditor-spouse as set forth he.rei.~.,
including all attorney fees and costs incurred in the enforcement
of this paragraph or any other provisions of this Agreement. No
obligation created by this Agreement shall be discharged or
dischargeable, regardless of Federal or State law to the contra•~-1•,
and each party waives any and all right to assert that obligai_i.~,~
hereunder is discharged or dischargeable.
The parties mutually agree that in the event.-. of
bankruptcy or financial reorganization proceedings by either „~„-~y
in the future, any monies to be paid to the other party, or ~c a
third party, pursuant to the terms of this Agreement sh~.l1
constitute support and maintenance and shall not be discharge; in
bankruptcy.
20. INCOME TAX PRIOR RETURNS: The parties have
heretofore filed joint federal and state-tax returns. Both parties
agree that in the event any deficiency in federal, state or 'e^al
10
income ta~c is proposed, or any assessment of any such tax is made
against either of them, each will indemnify and hold harmle-5 the
other frgm and against any loss or liability for any su:.r tax
deficiency or assessment and any interest, penalty and e:.-pense
incurred in connection therewith. Such tax, interest, penal'~y or
expense shall be paid solely and entirely by the individual ;rho is
finally determined to be the cause of the misrepresentations or
failures to disclose the nature and extent of his or her seYa.rate
income on the aforesaid joint returns.
21. .CHILD SIIPPORT: Child support has been established
by the Court of Common Pleas of Cumberland County, Pennsylvania; at
PACSES Case Number 16503642.
22. LIFE INSURANCE: Each party agrees tO maintain a
minimum of $150,000.00 life insurance on their life naming their
son as irrevocable beneficiary until their son reaches the age of
twenty-two (22). Each will provide the other yearly verification
of this insurance coverage.
23. CUSTODY: Custody has been established by Oder
docketed in case number Cumberland County, Penny=v~-.nia.
24. WAIVER OR D2ODIFICATION TO BE IN WRITING: No
modification or waiver of any of the terms hereof shall be s•rlid
unless in writing and signed by both parties and no waiver of any
breach hereof or default hereunder shall be deemed a waiver of any
subsequent default of the same or similar nature.
25. MUTIIAL COOPERATION: Each party shall, at any time
and from time to time hereafter, take any and all steps and
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execute, acknowledge and deliver to the other party any a~zn all
further instruments and/or documents that the other pa.*:y may
reasonably require for the purpose of giving full force and e*_~ect
to the provisions of this Agreement.
26. APPLICABLE LAW: This Agreement shall be conr.t.=•ued
in accordance with the laws of the Commonwealth of Pennsylvania
which are in effect as of the date of execution of this Agrec-ment.
27. AGREED~NT BINDING ON HEIRS: This Agreement shall be
binding and shall inure to the benefit of the parties here±-.e and
their respective heirs, executors, administrators, successors and
assigns.
28. INTEGRATION: This Agreement constitutes the 2z:tire
understanding of the parties and supersedes any and all ~:rior
agreements and negotiations between them. There ~rF no
representations or warranties other than those expressly set forth
herein.
29. OTHER DOCIIImiNTATION: WIFE and HUSBAND covenar;t and
agree that they will forthwith execute any and all ~r~_~:~_.ten
instruments, assignments, releases, satisfactions, deeds, no.~", or
such other writings as may be necessary or desirable for the proper
effectuation of this Agreement.
30. NO WAIVER ON DEFAULT: This Agreement shall ~einain
in Eull force and effect unless and until terminated urr<_.,~ and
pursuant to the terms of this Agreement. The failure of either
party to insist upon strict performance of any of the provisions of
this Agreement shall in no way affect the right of sucYx ua.rty
12
hereafter to enforce the same, nor shall the waiver of any 3~;'=ult
or breach of any provisions hereof be construed as a waiver c:` any
subsequent default or breach of the same or similar nature; nor
shall it be construed as a waiver of strict performance ~>>~ any
other obligations herein.
31. SEVSRAHILITY: If any term, condition, claim or
provision of this Agreement shall be determined or declared ~o be
void or invalid in law or otherwise, then only that term,
condition, clause or provision shall be stricken from this
Agreement and in all other respects this Agreement shall be valid
and continue in full force, effect and operation. Likewise, the
failure of any party to meet her or his obligation under any ore or
more of the paragraphs herein, with the exception c~= the
satisfaction of the conditions precedent, shall in no way avcid or
alter the remaining obligations of the parties.
32. BREACH: If either party breaches any provisi:+r~s of
this Agreement, the other party shall have the right, at his cr her
election, to sue for damages for such breach or seek such ctizer
remedies or relief as may be available to him or her, and th.e~~arty
breaching this contract shall be responsible for paymer.*_ of
reasonable legal fees and costs incurred by the other in enforcing
their rights under this agreement.
33. HEADINGS NOT PART OF AGREEMENT: Any heading
preceding the text of the several paragraphs and subparagraphs
hereof are inserted solely for convenience of reference ar_r'. shall
not affect its meaning, construction or effect.
13
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IN WITNESS WHEREOF, the parties hereto have Sew their
hands and seals this day and year first alppue written.
14
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Amy ~ Lane
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MICHAEL C. LANE, JR.,
Plaintiff
Vs.
AMY N. LANE,
To the Prothonotary:
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
llo, 01-4095
CIVIL ACTION- LN DLVOxcE
PRAECIPE TO TRANSMIT RECORD
Transmit the record, together with the following information, to the Court for entry of a divorce decree:
1. Ground for divorce: irretrievable breakdown under Section (X) 3301 C ( ) 3301 ID of the
Divorce Code. (Check applicable code )
2. Date and manner of service of the
Certified-Restricted delivery 7/7/01
3. (Complete either paragraph (A) or (B) .)
(A) Date of execution of the affidavit of consent required by Section 3301 (C) of the divorce code:
By plaintiff 1/11/02 ;by defendant 1/23/02
(B) (1) Date of execution of the plaintiff s affidavit required by Section 3301 (D) of the
Divorce Code:
(2) Date of filing and service of the plaintiff s affidavit upon the respondent
4. Related claims pending:
NONE
5. (Complete either (a) or (b).)
(A) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy
of which is attached:
(B) Date glaintiff s Waiver of Notice in § 3301(c) Divorce was filed with the Prothonotary:
2/5/02
Date defendant's Wavier of Notice in § 3301 (c) Divorce was filed with the Prothonotary:
2/05/02
Prothort-09
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Attorney for (x) Plaintiff
( )Defendant
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MICHAEL C. LANE, JR.,
Plaintiff
vs.
AMY N. LANE,
Defendant
IN TH8 COURT OF CONNON PLEAS
. CIIMBERLAND COUNTY, PEN/N~.SYLVA~NI-7A-'
IN DIVORCE t
NOTICE TO DEFEND AND CLAIM RIGHTS
YOU HAVE BEEN SUED IN COURT. If you wish to defend against
the claims set forth in the following pages, you must take prompt
action.
You are warned that if you fail to do so, the case may
proceed without you and a decree of divorce or annulment may be
entered against you by the Court. A judgment may also be entered
against you for any other claim or relief requested in these
papers by the Plaintiff. You may lose money or property or other
rights important to you, including custody or visitation of your
children.
When the ground for the divorce is indignities ox
irretrievable breakdown of the marriage, you may request marriage
counseling. A list of marriage counselors is available in the
Court Administrator's Office, Cumberland County Courthouse, Carlisle,
PA.
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 TEE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
MICHAEL C. LANE, JR.,
Plaintiff
vs.
AMY N. LANE,
Defendant
IN TH8 COURT OF COMMON PLEAS
CUM88RLAND COUNTY, PENNSYLVANIA
IN DIVORCE
COMPLAINT IN DIVORCE
3301(c)
1. Plaintiff is MICHAEL C. LANE, JR., whose mailing add:resa
is 423 Walnut Street, #314, Harrisburg, Dauphin County, Pennsylvania.
Plaintiff's social security number is # 072-66-7841.
2. Defendant is AMY N. LANE, who resides at 2190 Brunswick
Avenue, Mechanicsburg, Cumberland County, Pennsylvania. Defendant's
social security number is 139-82-5325.
3. Plaintiff has been a bona fide resident in the
Commonwealth for at least six months immediately previous to
the filing of this Complaint.
4. The Plaintiff and Defendant were married on December 31,
1994 in Passaic County, New Jersey.
5. There has been no prior action for divorce ar for
annulment between the parties.
6. The Defendant is not a member of the Armed Forces.
7. The marriage is irretrievably broken.
8. Plaintiff has been advised of the availabilitg~ of
marriage counseling and that he may have the right to request the
Court to require the parties to participate in such counsel:i.ng.
Being so advised, Plaintiff does not request that the Court
require the parties to participate in counseling prior to a Divorce
Decree being handed down by the Court.
WHEREFORE, the plaintiff prays your Honorable Court to
enter a Decree in Divorce from the bonds of matrimony.
Respectfully submitted:
~C
Ju h A. Calkin, Esquire
A rney for Plaintiff
2201 North Second Street
Harrisburg, PA 17110
(717) 238-2312
Commonwealth of Pennsylvania:
ss.
County of Dauphin
I verify that the statements made in this 3301 (c) Divorce
Complaint are true and correct. I understand that false statements
herein are made subject to the penalties of 18 Pa.C.S. Section 4904,
relating to unsworn falsification to
Date:
Sworn and Subscribed
befoTre me this ~~ @ay
of V U 1~/~G 2001.
Notary Public
NOTARIAL SEAL
ELLEN ROSENBLOOM, Notary Public
~r of Harrisburg Dauphin County
COmnussion Expires May 8, 2003 0
orities.
C.
chael C. Lan
°'._~ °~
• ,
CERTIFICATE OF SERVICE
I, Judith A. Calkin, do hereby certify that a true and correct
copy of the within 3301 (c) Divorce Complaint was mailed at Harrisburg,
PA., certified-restricted delivery, postage pre-paid to the following
person:
Amy N. Lane
2190 Brunswick Avenue
Mechanicsburg, PA 17055
Date:
,.~~
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IN THE COURT OF COMMON PLEAS
CUMBERLAND CO., PENNSYLVANIA
NO. 01-4095
IN DIVORCE
AFFIDAVIT OF SERVICE
I, Judith A. Calkin, Esquire, deposes and says:
1. That she is an adult individual residing in Dauphin
MICHAEL C. LANE, JR.,
Plaintiff
vs.
AMY N. LANE
Defendant
County, Pennsylvania.
2. That on July 6, 2001, she sent by ce*tified-
restricted delivery, requested from Harrisburg, Pennsylvar~=a, No.
7099 3220 0009 4715 4596 and, if applicable, the Divorce Complaint
in the above-captioned case to:
Amy Lane
2090 Brunswick Avenue
Mechanicsburg, PA 17055
3. That on July 7, 2001, Amy Lane signed the receiM~ No.
7099 3220 0009 4715 4596 and it is aCttacheid~ ~to~t~hi/s~Iaf/f/~iidav_-.
Date: 1/18/01 `\~1~L4'ivWV V'~ 1~
dith A. Calkin, Esgei-~=
Attorney for Plaintif:=
2201 North Second St_~=:~~
Harrisburg, PA 17110
(717) 238-2312
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MICHAEL C. LANE, JR.,
Plaintiff
vs.
AMY W. LANE,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND CO., PENNSYLVANIA
NO. 01-4095 Civil Term
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301 (c) of the
Divorce Code was filed on July 2, 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 in Divorce
after service of notice of intention to request entry of the
decree.
I understand that false statements herein are made
subject to the penalties of 18 Pa.C.S. Section 4904, relating to
unsworn falsification to authorities.
Date: (`I~Io2.
Micha 1 C. Lane, r.
SS# No. p~Z•b6-7
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MICHAEL C. LANE, JR., IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND CO., PENNSYLVANIA
vs. NO. 01-4095 Civil Term
IN DIVORCE
AMY W. LANE,
Defendant
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER SSCTION
3301 (C) OF THE DIVORCE CODE
1. I consent to entry of a final Decree of Divorce
without notice.
2. I understand that I may lose rights concerning
alimony, division of property, lawyers 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
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.
4. I verify that the statement made in this Waiver are
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true and correct. I understand that false statements herein are
made subject to the penalties of 18 Pa.C.S. Section 4904, relating
to unsworn falsification to authorities.
-DATE: ll~l`O?i' ~ ( II~Ip~
Micha 1 C. Lane, J .
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In the Court of Common Pleas of Cumberland County,
Pennsylvania
MICHAEL C. LANE, JR.,
Plaintiff, )
vs. ) No. 2001- 4095
AMY W. LANE, ) CIVIL TERM
Defendant. ) IN DIVORCE
AFFIDAVIT OF CONSENT
1. A complaint in divorce under § 3301(c) of the Divorce Code was filed on July 2,
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 fmal 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.
DATED: a3 O~ ~JLA'YU.~1_ C~J ~A-
Amy W. L e, De dant
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In the Court of Common Pleas of Cumberland County,
Pennsylvania
MICHAEL C. LANE, JR.,
Plaintiff, )
vs. ) No. 2001- 4095
AMY W. LANE, ) CIVIL TERM
Defendant. ) IN DIVORCE
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.
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: i,a3~0a
~' I W,{- V V ~1-FN ~-
Amy W. ne, endant
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MICHAEL C. LANE, JR.,
Plaintiff
vs.
AMY N. LANE,
To the Prothonotary:
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 01-4095 CIVIL TERM
IN DIVORCE
Entry of Appearance
Please enter my appearance on behalf of the Defendant, Amy Lane, in the above
captioned matter.
Date: ~ /a p~
ichael S. Travis
Attorney for Defendant, Amy Lane
I
MICHAEL C. LANE, JR.,
Plaintiff
vs.
AMY N. LANE,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. 01-4095 CIVIL TERM
IN DIVORCE
CERTIFICATE OF SERVICE
I, Michael S. Travis, certify that I have this day served a true and correct copy of the
foregoing document by first class mail, postage prepaid, on the following person, addressed as
follows:
Dated: ~ /~ 6,/
Judith A. Catkin, Esquire
2201 North Second Street
Harrisburg, PA 17110
Attorney for Defendant
ID No. 77399
4076 Market Street, Suite 209
Camp Hill, PA 17011
(717)731-9502
Fax 731-9511
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'_2/'_0/2004 08:51 7172406573 PROTHONOTARY C LONG PAGE 01/01
[N'X'HE COURT OIa COMMON PLEAS OF CUMBERLAND COUNTX,
PENNSXLVAjNIA
M i chaxl L.- Lame, J r .
Plaintiff
vs Pile No: ~ l - 4~ °I 5
. IN DIVORCE
Amu N lar~
Defendant
NOTICE TO RESUME PRIOR SURNAI4II;
Notice is hereby given that the Plaintiff! defendant i~,a the above matter,
[select one by marking "x"]
prior to the entry of a Pinai Decree in Divorce,
or ~ at}et the entry of a Final Decree in Divorce dated a 14 Oct. ,
hereby elects to resume the prior surname of 0'711'1 U N _ W i ~ )i a YY15 and gives this
written notice avowing his /her intention pursuaut t the provi$i s of 54 P.S. 704.
Date: ia~ia~oy
ature
Signa~re of name heirAg presumed
~~~~
COMMONWE TH OF ]
COUNTY OF~~
On the ~(~~day of P , 200 before tne, the kxothonotary or the
notary public, per$onally appeared the above want known to me to be the person whose
name is subscribed to the witfa~ document and acknowledged that he /she executed the
foregoing for the purpose therein contained.
In Witness Whereof, I have hereunto set my hand h tt to set tpy harxd and o~oal
seal. ~ ~ ~ A
keotltonotaty or Notary Public
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