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HomeMy WebLinkAbout01-05281a~: F ~. IN THE COURT OF COMMON PLEAS Kirsten R. Snell. Plaintiff VERSUS Defendant No. 01 DEGREE IN S~A1 DIVORCE AND NOW, ~e.c.a., ~+/ ,Z[ ~ 00/ IT IS ORDERED AND DECREED THAT Ki rs1-en R_ Rnell PLAINTIFF, AND Thomas J. Snell , 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; The "Separation Agreement and Property Settlement" of November 17, 2001 Divorce. BY THE COURT: ATTE ! ~• PROTHONOTARY OF CUMBERLAND COUNTY STATE OF ~ PENNA. -;`_ ~_ x x ~, U /~1 .~/ /~ KIRSTEN R. SNELL, Plaintiff v. THOMAS J. SNELL, Defendant . , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-5281 CIVIL TERM CIVIL ACTION -LAW IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information to the court for entry of a Divorce Decree: 1. Ground for divorce: irretrievable breakdown under §3301 (c) §3301 (d) of the Divorce Code. 2. Date and manner of service of the complaint: First Class Mail, postage paid on September 10, 2001. 3. Date of execution of the Affidavit of Consent required by §3301(c) of the Divorce Code. By Plaintiff: December 15, 2001 By Defendant: December 17, 2001 4. Related claims pending. None 5. Date the Waiver of Notice in §3301(c) divorce was filed with the Prothonotary: By Plaintiff: December 19, 2001 By Defendant: December 19, 2001 ~, ~~~ ~~ 'Glen R. Waltz, Esquir Attorney for Plaintiff u __ b > (~.I ~~ __ TiI'~. ear: ~_. _, f f ~ ¢'• <n . ~_ -- `~~~= .. - - f' ,, n s KIRSTEN R. SNELL, Plaintiff v. THOMAS J. SNELL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-5281 IN DIVORCE SEPARATION AGREEMENT AND PROPERTY SETTLEM'~ENT This Agreement, made and entered into this i~~ day of -~JOVEma°.~~2 2001, between Kirsten R. Snell, of Carlisle, Cumberland County, Pennsylvania, hereinafter referred to as "Wife",and Thomas J. Snell, of Carlisle, Cumberland County, Pennsylvania, hereinafter referred to as "Husband". WHEREAS, the parties hereto are now Husband and Wife, having been lawfully married to each other on November 3, 1984 in New London, Connecticut; WHEREAS, there have been no children born of this marriage between Husband and Wife, to wit: li WHEREAS, the parties hereto are now living separate and apart and desire to enter'.. into an Agreement respecting their property rights, regardless of the actual separation or other character thereof and their other rights, including the Wife's or Husband's right to support and maintenance; i WHEREAS, both and each of the parties hereto have been advised of their legal rights and the implications of this Agreement and the legal consequences that may and will ensue from the execution hereof, and each has had the opportunity to consult with his or her own competent legal counsel independent of each other; WHEREAS, each party warrants, as part of the consideration of this Agreement, that each has fully and completely disclosed all information of a financial nature requested by the other, and that no information of such nature has been subject to distortion or in any manner being misrepresented; and Y J WHEREAS, other than as set forth herein, Wife desires finally and forever to relinquish all of her rights to be supported by the Husband and all of her right of dower, rights as heir or surviving spouse or otherwise, actual, currently existing, or inchoate, in and to the real and personal property of the Husband, now owned by him or which in the future may be owned by him, and all rights to alimony, alimony pendente lite, counsel fees, or expenses and, other than as set forth herein, Husband likewise wishes to relinquish all his rights of curtsey, rights as heir or surviving spouse or otherwise, actual and currently existing or inchoate in and to the real and personal estate of the Wife, currently owned by her or which she may own in the future as well as all rights to alimony, alimony pendente lite, counsel fees or expenses; NOW, THEREFORE, the parties hereto intending to be legally bound do hereby mutually agree as follows: 1. Separation. Husband and Wife do hereby mutually agree and consent to live separate and apart and do further agree that it shall be lawful for the Husband and Wife at all times hereafter to live separate and apart from each other, and to reside, from time to time, at such place or places as they respectfully shall deem fit, free from any control or restraint or interference, direct or indirect, by each other. 2. No Molestation, Harassment or Interference. Neither party shall molest, harass or interfere with the other or compel or endeavor to compel the other to cohabit or dwell with him or her by any means whatsoever. 3. Mutual Property and Estate Waiver. Except as otherwise expressly set forth herein, in which event such express provision shall take precedence over this paragraph, the parties hereto intend that from and after the date of this Agreement, neither shall have any spouse's rights in the property or estate of the other, and to that end both parties waive, relinquish, and forbear the rights of dower or curtsey, rights to inherit, rights to claim or take the Husband's, Wife's or family exemption or allowance, to be vested with 2 . _- letters of administration or letters testamentary, or to take against any will ofthe other, and each agrees with the other if either should die intestate, his or her share shall descend to vest in his or her heirs at law, personal representatives, and next of kin, excluding the other as though he or she had died a widow or widower. And each further agrees that should the other die testate, his or her property shall descend to and vest in those persons set forth in the other's Last Will and Testament as though the spouse so designated as beneficiary had predeceased the testator. The parties further agree that they may and can hereafter, as though unmarried, without anyjoinder by him or her, sell, convey, transferor encumber any and all real estate and personal property which either of them now or hereafter own or possess and further agree that the recording of this Agreement shall be conclusive evidence to all of his or her right to do so. The said Husband and Wife do hereby irrevocably grant, each to the other, should the exercise of this power hereby given be necessary, the right and the power to appoint one or more times any person or persons whom the Husband or Wife shall designate to be the attorney-in-fact for the other, in their name and in their stead, to execute and acknowledge any deed or deeds, releases, quit claims, or satisfactions, under seal or otherwise, to enable either party hereto to alienate his or her real or personal property, but without any power to impose personal liability for breach of warranty or otherwise. Each of the parties hereto further waives any right of election contained in Chapter 22 of the Pennsylvania Probate Estates and Fiduciaries Code, and any right to seek or have an equitable distribution of married property ordered by the Court subsequent to Section 3502 of the Divorce Code. Each of the parties hereto further agrees that neither shall hereafter be under any legal obligations to support the other, pay any expenses for maintenance, funeral, burial, or otherwise for the other, and to that end each of the parties hereto does hereby waive any right to receive support, alimony, alimony pendente lite, counsel fees, expenses, oranytype of financial assistance whatsoever from the other, except as otherwise expressly provided for herein. 3 4. Distribution of Marital Assets. a. The parties agree that the items of personal property have been satisfactorily distributed pursuant to a written appended distribution document [Exhibit "A"] that is incorporated herein as if full set forth and shall be the sole and exclusive property of the recipient Husband/Wife. All other personal property obtained by the parties during the marriage shall be the sole and exclusive property of the possessor of that property. Henceforth, each of the parties shall own, have and enjoy, independently of any claim of right of the other party, all items of personal property of every kind, nature and description and wheresoever situated which are now owned or held by or which may hereinafter belong to the Husband or Wife respectively, with full power to the Husband or Wife to dispose of the same as fully and effectually in all respects and for all purposes as if he or she were unmarried. b. The parties agree that each motor vehicle in Husband and Wife's possession shall remain in the respective party's possession; each spouse shall execute the appropriate documents transferring the title registration of the vehicle into the possessing spouse's name. Each party shall be solely and independently liable for their respective motor vehicle insurance and any subsequent respective vehicle indebtedness. Wife agrees to accept all loan indebtedness for Husband's 1998 Dodge Dakota Truck. c. Personal effects. All items of personal effect such as but not limited to jewelry, luggage, sports equipment, hobby collections and books but not including furniture or any other property, personal or otherwise specifically disposed of pursuant to this agreement shall become the absolute and sole property ofthe party who has had the principal use thereof or to whom the property was given or from whom it was purchased, and each party hereby surrenders any interest he or she may have in such tangible personal property of the other. Wife agrees to allow Husband to store personal property at her residence, gratis; however, upon 90 days i written notice to remove said personal effects from Wife to Husband, Husband shall' 4 remove the property within 30 days of the request and if the property is not removed in a timely fashion, Wife reserves the right to dispose of the property in accordance with any governing statutes or law existing within the state of Wife's residence. Husband shall give wife 90 days written notice of Husband's intent to remove his property from the Wife's possession; the removal of property by the Husband shall be within 30 days (before the 120 day of receipt of the notice of intent to remove property) after the expiration of the aforesaid 90 day. d. Member's First Savings and Checking Account No. 151511, although in joint names, shall be dedicated to Husband; Member's First Savings Account Nos. 152746, 178316 and 204632 shall be dedicated to Wife. Husband and Wife waive all interest in the other party's Member's First Savings Accounts. Member's First Checking Account Nos.152746, 178316 and 204632 shall be dedicated to Wife; Husband waives all interest to the Member's First Checking Account No's. 152746, 178316 and 204632. e. Stocks and Bonds shall be provided to Husband by Wife in the following manner: 5 shares of AT&T valued at $90.00 ($18.00/share); 5 shares of Lucent Technologies valued at $35.00 ($7.00/share); 2 shares of Central Hudson Energy Group valued at $80.00 ($40.00/share); and 10 shares of Public Works of New Mexico valued at $250.00 ($25.00/share). 5. Health Insurance. Wife agrees to maintain Husband on her employer's health insurance during the pendency of the divorce; Husband agrees to reimburse Wife forthe amount charged to maintain Husband on the Health Insurance from the date offiling of the divorce complaint to the date of filing of the final divorce decree at which time Husband agrees to waive any claim for the Wife's Health Insurance and furthermore, Husband shall secure Health Insurance independently orthrough his employer. Husband's, reimbursement rate to Wife for Health Insurance is $46.65 bi-weekly and shall beset off by the amount listed at paragraph 4 (e) above and herein. 5 6. Debts. Wife shall assume all liability for credit card indebtedness occurring prior to September 10, 2001. Henceforth from September 10, 2001, the parties are individually responsible for their own credit cards and the parties agree that they will each be responsible for their respective credit card debts occurring after September 10, 2001. Subsequent to September 10, 2001, neither party shall be liable forthe other parties credit card debt. Wife shall also assume any debt pre-existing September 10, 2001 relative to the Husband's 1998 Dodge Dakota Truck. 7. Future Debts. The parties agree that neither will incur any debts for which the other maybe held liable, and if either party incurs a debt forwhich the other will be liable, the party incurring such debt will hold the other harmless from any and all liability thereof. 8. Net Worth. The parties agree that theirjoint net worth, excluding pensions, stocks and bonds and personalty is $15,283.49. 9. Real Property. The parties agree that the real property located at 1914 Sterretts Gap Avenue, Carlisle, Cumberland County, Pennsylvania, shall be titled in the name of the Wife. The first mortgage with GMAC, Account Number 450270673 with an approximate balance of $85,136.95 and the Members First Credit Union Account Number 151511-03 with an approximate balance of $5,590.46 and Account No. 204632-01 with an approximate balance of $6,995.00 shall be assumed entirely by Wife. Wife agrees to pay to Husband Seven Thousand Six Hundred Forty-two ($7,642.00) Dollars, representing one- half of their net worth, and $455.00 representing the value of the Stocks and Bonds listed at paragraph 4 (e) above minus the cost ($46.65 x 6 = $279.90) of maintaining health insurance for Husband during the pendency of the divorce and upon the execution and filing of the Deed and all other documents designed to provide Wife with the sole title and mortgages to the 1914 Sterretts Gap Avenue property. Both parties agree to execute any and all future documents reasonably related to the transfer of title to the Wife. Husband' 6 transfers, assigns, and conveys to Wife, as Wife's sole and separate property, all of his right, title, and interest in the real property located at 1914 Sterretts Gap Avenue, Carlisle, Cumberland County, more particularly described within the Deed recorded at the Recorder of Deeds Office, Cumberland County at Book 131, Page345 on November21, 1995. The property will be transferred subject to a first lien of indebtedness in the amount of $85,136.95 secured by a first mortgage on the property. The Wife agrees to indemnify and hold harmless the Husband from any and all claims and liabilities that Husband may suffer or may be required to pay on account of such indebtedness, encumbrances, or liens. The Husband will in no manner assume liability, either personal or otherwise, for the above-mentioned lien against the property. 10. Waiver of Alimony. In consideration of the mutual agreement of the parties voluntarily to live separate and apart and the provisions contained herein for the respective benefit of the parties and other good and valuable consideration, the parties agree to waive any and all claims for any alimony, support, and alimony pendente lite. 11. Pension. Both parties agree to waive any claims they may have to all pension or employment benefits of any kind, earned during the marriage, by the other party. 12. Counsel Fees and Court Costs. Each party agrees to pay their own attorney fees and cost incurred in the preparation of this document as well as the preparation and filing of the divorce action captioned at No. 01-5281 Civil Action-Law in Divorce. If either party incurs any other legal fees or court costs, those costs will be borne by the incurring party exclusively. 13. Divorce. The parties acknowledge that an action between them has been filed by Wife and is presently pending divorce between them in the Court of Common Pleas of Cumberland County to the caption Kirsten R. Snell, Plaintiff v. Thomas J. Snell, 7 u Defendant, No. 01-5281 Civil Action-Law In Divorce. The parties acknowledge their intention and agreement to proceed in said action to obtain a final decree in divorce by mutual consent on the grounds that their marriage is irretrievably broken, and to settle amicably and fully hereby all claims raised by either party in the divorce action. The parties acknowledge that they will execute the necessary Affidavits of Consent for the entry of a final divorce decree in this action. 14. Breach. In the event that either party breaches any provision of this Separation and Property Settlement Agreement, he or she shall be responsible for any and all costs incurred to enforce the terms hereof, including, but not limited to, court costs and reasonable counsel fees of the other party. In the event of breach, the other party shall have the right, at his or her election, to sue for damages for such breach or to seek such other and additional remedies as may be available to him or her. 15. Enforcement. The parties agree that this separation agreement and property settlement or any part or parts hereof may be enforced in any court of competent jurisdiction. 16. Applicable Law and Execution. The parties hereto agree that this separation agreement and property settlement shall be construed under the laws of the Commonwealth of Pennsylvania and shall bind the parties hereto and their respective heirs, executors and assigns. This document shall be executed as original and multiple copies. 17. The Entire Agreement. The parties acknowledge and agree that this separation agreement and property settlement contains the entire understanding of the parties and supersedes any prior agreement between them. There are no other, 8 i representations, warranties, promises, covenants or understandings between the parties other than those expressly set forth herein. 18. Additional Instruments. Each of the parties shall on demand or within a reasonable period thereafter, execute and deliver any and all other documents and do or cause to be done any other act or thing that may be necessary or desirable to effectuate the provisions and purposes of this Agreement. If either party fails on demand to comply with this provision, that party shall pay to the other all attorney's fees, costs, and other expenses reasonably incurred as a result of such failure. IN WITNESS WHEREOF, the parties have set their hands and seals the day and year first written above. WITNESS: rste .Snell ~wW Thomas J. S ell 9 9 Nov 2001 Snell Household Property Distribution upon divorce will be as follows: Kirsten R Snell will retain possession oi: Asset Room Queen size bed & frame Back Bed Room Night stand Back Bed Room Brass lamp Back Bed Room Lampert Painting -Mountain 09-082929 Back Bed Room Frigidaire Air conditioner Back Bed Room Chest of drawers Back Bed Room Bureau and mirror Back Bed Room Dk brown bureau with attached mirror Back Bed Room Binoculars Back Bed Room Tan hassock Basement Glass ball lamp Basement Nathan Tondo -brown barn w/ brown frame 15-274214 Basement Nathan Tondo -blue barn w/ oriental frame 15-295546 Basement Kenmore Dehumidifier Basement Kenmore washing machine Basement Morse sewing machine w/ cabinet Basement Tool Bench Basement Book case Computer Room Black rocking chair Computer Room Table and Chairs Dining Room Polish Pottery Collection Dining Room Paper Shredder Dining Room Bread Machine Doling Room Bookcase w/ doors Front Bed Room Woodville Painting -Butterflies 63-064045 Front Bed Room Singer sewing machine w/ cabinet Front Bed Room Cedar chest Front Bed Room Plastic filing cabinets (2) Front Bed Room old brown card table Front Bed Room Helgeson Painting -blue butterfly 5&063491 Front Bed Room Double bed wJ head/foot boards Pront Bed Room lock box Front Bed Room Kenmore Vacuum Cleaner Front Bed Room Hanging Curio Clock Hallway Swarovski Crystal Hallway Iron & ironing board Hallway Refrigerator Kitchen Stove Kitchen Coffee Pot ]Kitchen Toaster Oven Kitchen Electric Wok .Kitchen Electric Skillet Kitchen Waffle Maker Kitchen Blender :Kitchen EXHIBIT ~- Crock Pot Kitchen Dehydrator Kitchen Electric Hand Mixer Kitchen ChopChop Food Processor Kitchen Remington Beach Painting 12-370230 Living Room Tan Lamps (2) Living Room Tan Chair Living Room Night Stand Living Room Gold Recliner Living Room Tan Couch Living Room Oak coffee table Living Room Magazine rack Living Room Teak stereo/TV unit Living Room Technics receiver Living Room Mazantz turntable Living Room Teac cassette player/recorder Living Room Kenwood CD player Living Room Radio Shack speakers (2) Living Room Sharp VCR Living Room JCP TV Living Room Dry Sink Living Room Gas grill Porch various yard/gardening tools Porch Lawn mower Porch Weed Wacker Porch Wheel barrow Porch Scott's Seed spreader Porch Thomas J. Snell will retain possession of Asset Room Moore Painting -snow 06-074164 Back Bed Room Hazmon Painting -snow 01-047269 Back Bed Room Hitachi TV Back Bed Room Red couch Basement Red chair Basement Bar with 4 stools Basement Wheaton bottle collection Basement Weight;ju3i Basement Rowjn$ t~tine Basement Basement Rou~r ~c#able Basement various power tools Basement various hand tools Basement Double-size bed w/ frame Computer Room Computer, pXi~tter & accessories Computer Room Desk & chair Computer Room Filing cabinet Computer Room Hummel Collection Dining Room Hanging Plate Dining Room Open bookcase Front Bed Room __ .. ~ _ ~ ~_~ white bookcase Pink'pot' ]amps (2) Large pink lamp Cazson Painting -Eagle 43-050846 Minolta camera & accessories Nathan Tondo Painting -Ducks w/ sunset 44-384824 Barnboazd Paintings (2) Nathan Tondo Painting -Blue Ducks 44-432931 Alford Beach Painting 12-296472 Freeman Ship Painting 40-261097 Crompton Ship Painting 40-286163 Beach watercolor Painting Black Vinal Recliner Blue cazd table Video storage cabinets (2) Hariging wicker light Round table Front Bed Room Front Bed Room Front Bed Room Hallway Hallway Living Room Living Room Living Room Living Room Living Room Living Room Living Room Living Room Living Room Living Room Living Room Porch _ .., , .~ea...,: E. ~t~~ aa~~s,:.a.,r:w~st a tn9.a+. aw.= , se w ~..:~,wa'3. ce~z-wirrisser~rsuw~'~Y~.ssdl~MS ' { i C:. °_ -i J ~i._ sG v ,' , ~ i .. _ m .;7 ! ~` -~. s KIRSTEN R. SNELL, Plaintiff v. THOMAS J. SNELL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01- 5z 81 CIVIL TERM CIVIL ACTION -LAW IN DIVORCE 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 will proceed without you and a decree in divorce or annulment may 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 OfFce of the Prothonotary at the First Floor, Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL PROPERTY, LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE 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 2 Liberty Avenue Carlisle, PA 17013 (717)249-3166 1 KIRSTEN R. SNELL, plaintiff v. THOMAS J. SNELL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01- 5 a &1 CIVIL TERM CIVIL ACTION -LAW IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301 (c) 1. Plaintiff is Kirsten R. Snell, an adult individual, currently residing at 1914 Sterretts Gap Avenue, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Thomas J. Snell, an adult individual, currently residing at 1914 Sterretts Gap Avenue, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant are bonafide residents of the Commonwealth of Pennsylvania and have been so for at least six months immediately previous to the filing of this complaint. 4. Plaintiff and Defendant were married on November 3, 1984 in New London, Connecticut. ii 5. There have been no prior actions for divorce or annulment between the parties. 6. The Defendant is not a member of the Armed Forces of the United States of America, or its Allies. 7. The Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, the Plaintiff does not desire that the Court require the parties to participate in !, counseling. ~, 8. The parties have lived separate and apart since April 2001 and continue to live separate and apart as of the date of this Complaint regardless that they reside at ~ the same mailing address. ~ 9. The parties' marriage is irretrievably broken. I 10. Plaintiff desires a divorce based upon the belief that Defendant will, after ninety days from the date of the filing of this Complaint, consent to this divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a decree in divorce. ,h/b ~oo~ at 28 South Pitt Stree€ Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff ii Respectfully Submitted TORO LAW OFFICES VERIFICATION I verify that the statements made in the foregoing Divorce Complaint are true and correct. I understand that false statements herein made are subject to the penalties of Pa.C.S. §4904 relating to unsworn falsification to authorities. /L9 fIX LJ(J~ 2~ ]~ iC!/~%G~C_X Da e ~rsten R. Snell CERTIFICQ-TE OF SERVICE I hereby certify that I served a true and correct copy of the Divorce Complaint upon Thomas J. Snell by depositing samei in the United States Mail, first class, postage pre-paid on the Jm ~~ day of ?~~., d , 2001, from Carlisle, Pennsylvania, addressed as follows: Thomas J. Snell 1914 Sterretts Gap Avenue Carlisle, PA 17013 TURD LAW OFFICES ~n R. Waltz, Esc 28 South Pitt Streetr Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff ~ ~ `'-~ G ~' v - ... . ;;, ~ ~. 'te r '` ~ ~ -'±~. Y`,I ~ - . =_a, u' ~ G ~ _} ~ `O 'N ~ ~ ~~ < ~~ KIRSTEN R. SNELL, Plaintiff v. THOMAS J. SNELL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01- ~Etl CIVIL TERM CIVIL ACTION -LAW IN DIVORCE AFFIDAVIT OF SERVICE I HEREBY CERTIFY THAT I served a true and correct copy of the Divorce Complaint filed in the above captioned case upon Thomas J. Snell, by certified mail, return receipt requested on September 10, 2001 addressed to: Thomas J. Snell 1914 Sterretts Gap Avenue Carlisle, PA 17013 and did thereafter receive same as evidenced by the attached Post Office receipt card dated September 11, 2001. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT OF SERVICE ACRE TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE, INFORMATION AND BELIEF, I UNDERSTAND THAT FALSE STATEMENTS HEREIN MADE ARE SUBJECT TO THE PENALTIES OF 18 PA.C.S. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. TURO LAW OFFICES ~ ~o Dat ~r1 r/ ~/I '~~% Robert J. Iderig, Esquire 28 South itt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff p~ O varr~Co~~'~i ~ Z 452 4i6 335 I/S POStaI $eNICB Receipt for Certified Mai! No Insurance Coverage Provided. Do not use for International Mail See revevse Sent to- ~ ~ Sv~~~ Stre 8 m I'1 Post Ofg~S)ete, 81Z~f Cade .-sh r S i vv ~ Postage Cenified Fee se Speda! Delivery Fee Resoicted De5very Fee ~ , ~ O Return Receipt Showing to 1Yhom 8 Date Delivered Return Receipt Showalg fa Whom, pate,BAddrmsea'sAddresr TOTAL Postage 8 Fees $ ! `~ PosMerk or Datne /n/ LL ~I` ~~V a .a SENDER: I also wish to receive the follow- m o Complete items tand/or 2 far adtlilional services. Ing SBNICES (fOr en eMra fee): '_, ` Complete items 3, 4a, and 4b. _ ^ Print year name antl address on the reverse of this form so that we can return this carQ to ou. t ee's Aggress ptAttach this krm to the front of the mailpiece, or on the back it space tlces not pertnN. Restricted-De tvery v Write 'Return Receipt Requested" on the mailpiece helow the adicle numb,~r. p The Ralum Receipt Will show to whom the article was tlelWeretl antl the date deliveretl. ~~ - -. Article Addressed to: 4a. Article Number ` (. ~~,.)~~- ~~ F nV 6Q ~ ~ ~~p ~ ~ 4b. Service Type ~/1~~V""~J 1C(iLf]r,/,~f~l/J ,l~ ,_ ^Registered ~'~Certifled M ~/ C/.~.LI-C!)IY~~t ~ ~D ~ U~Ytlt"K`/, ~ Express Mail a"Insured ~~~ l~ 0!,/"J ~Fetum Receipt for Merchandise ^COD ' 7. Dat~pf livery ( fee is paid) N .; .., o- ',yggp. _ td-awat~a ,..:.. -_rnReoeipt PS Fong 38, ,~ .: f F C~ ~ -~ =i ~. ~ O __ __ ` ~~'~ f- ~- ~ ` `'.J _ ~ €3 , ~7 C.~J n -~ l0 =C KIRSTEN R. SNELL, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 01-5281 CIVIL TERM THOMAS J. SNELL, :CIVIL ACTION -LAW Defendant : IN DIVORCE AFFIDAVIT OF CONSIENT 1. A Complaint in Divorce under §3301 (c) of the Divorce Code was filed on September 10, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of the final Decree in Divorce after service of Notice of Intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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. ~w.~ Date thomas J. Hell r~ ,_; ..~. ~' _-_ - ~.~ _ ;~~~ : , ~. KIRSTEN R. SNELL, Plaintiff v. THOMAS J. SNELL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-5281 CIVIL TERM CIVIL ACTION -LAW IN DIVORCE WAIVER OF INTENTION TO REQUEST 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 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 THE FOREGOING 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. ~d: t7. ~~r Date F ~~~ Q Iu~-d~ f Thomas J. Sn II KIRSTEN R. SNELL, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 01-5281 CIVIL TERM THOMAS J. SNELL, :CIVIL ACTION -LAW Defendant : IN DIVORCE AFFIDAVIT OF CONSO=NT 1. A Complaint in Divorce under §3301 (c) of the Divorce Code was filed on September 10, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of the final Decree in Divorce after service of Notice of Intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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. lei ~ 5 ,,~uo~ ~~~ Date rsten R. Sne I ~~ .~~ ~ 4 - p~k!las`-._~k~-,e~v sru~arwnd ~2t;'~- ~iYi~WNR~BNRYn h KIRSTEN R. SNELL, Plaintiff v. THOMAS J. SNELL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.01-5281 CIVIL TERM CIVIL ACTION -LAW IN DIVORCE WAIVER OF INTENTION TO REQUEST 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 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 THE FOREGOING 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. r~.,~L~~ Date ~~ Kifsten R. Snell ,. Y~ ~ pt$~Lx*9.i~`SA FnEnrxAA.piNL~ NM&~~i4YS~n~`4 4