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HomeMy WebLinkAbout01-05463i ~ 11 ~ e fi °~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. NENA M. GROSS,-, NO.....-Od-~5~4b3 E;~ivi1Term _._Plaintiff_------------------- Versus ROBRRT D. GROSS, Defendant DECREE IN DIVORCE AND NOW~eS,. ~~(~ .................. . ~. 2tA l , it is ordered and decreed that ....Mena, rt.• •Grog$ ............................. . plaintiff, and .... R.obert..D.. 4;r.oss ................................... . 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 Marriage• .Settlement ,Agreement ,between, the, part;~e,~ .9h~l,l.be incorporated, but shall not merge with the final Decree in Divorce. .........1~~ A~.~~ ................................................ T• IIy T e ourt .•. • - - ~ o _ _--- -- ;. Attes : ' J• :. ll////^^/^••//~ ,A, ----__.-7"~~ - .. ........ . ......... ....__-_ t. Prothonotary a`, "'^'s°~9£M3V0Ytl'tb4N.B§9G I~M5Ta6YU ~.x Yh:.Ne mi~,m -1~'" '~53.Y,.~PY~tl ~Yl~IM14 ~' N ~~ .~ . O/- s~'G3 MATRIMONIAL SETTLEMENT AGREEMENT THIS AGREEMENT is made this ~ G• day of ~C ~O f/ 1 ~ , 2001, by and between Nena M. Gross of 2904 Warren Way, Mechanicsburg, Cumberland County, Pennsylvania, 17050 (herein "Wife") and Robert D. Gross of 1880 Lambs Gap Road, Mechanicsburg, Cumberland County, Pennsylvania, 17050 (herein "Husband"). RECITALS A. The parties hereto, being Husband and Wife, were lawfully mazried on July 11, 1998, in Cumberland County, Pennsylvania. B. Differences have arisen between Husband and Wife in consequence ofwhich they have begun to live sepazate and apart from each other. C. Husband and Wife acknowledge that they both have consulted their attorneys and haue been advised by their attorneys of all of their rights and duties or have had the opportunity to consult independent legal counsel and have wilfully, knowingly and voluntarily waived the right to consult an attorney. WITNESSETH NOW, THEREFORE, in consideration of the mutual promises, covenants and undertakings herein contained, the parties, each INTENDING TO BE LEGALLY BOUND, agree as follows: 1. Recitals. The Recitals set forth above are incorporated herein by reference and specifically made a part of this Agreement. 2. Divorce. It is specifically understood and agreed by and between the parties, and each party does hereby warrant and represent to the other that, as defined in the Pennsylvania Divorce Code, their marriage is irretrievably broken. Wife filed an action in the Court of Common Pleas of Cumberland County, Pennsylvania, to Docket No. 01-5463 on September 7, 2001. Such Complaint was validly served upon Husband on September 27, 2001, via certified mail, return receipt requested and Husband hereby acknowledges such service. The parties agree to take all legal steps (including the timely and prompt submission of all documents and the taking of all actions) necessary to assure that a Divorce pursuant to 23 Pa. C.S.A. § 3301(c) of the Divorce Code is entered as soon as possible. This Agreement and any ancillary or supplemental agreements shall be incorporated by reference and merged into the proposed Divorce Decree presented to the Court. Husband and Wife shall at all times hereafter have the right to live sepazate and apart from each other and to reside from time to time at such place or places as they shall respectively deem fit, free from any control, restraint or interference whatsoever by the other. Neither party shall molest the other in any way whatsoever nor endeavor to compel the other to cohabit or dwell with him or herby any legal or other proceedings. The foregoing provision shall not be taken to be an admission on the part of either Husband or Wife of the lawfulness or unlawfulness ofthe causes leading to their living apart. 2. Marital Property. (a) Personal Property Division. Husband and Wife acknowledge that they have divided all personal property acquired during the marriage to their mutual satisfaction. A separate list of the personal property which Husband shall acquire is attached hereto as Exhibit "A." Husband hereby relinquishes all right, title and interest in Wife's personal property currently in her possession and as set forth on Exhibit "A," and Wife hereby relinquishes all right, title and interest in Husband's personal property currently in his possession, except as provided herein to the contrary. (b) Real Property Division. The parties have agreed to a division of the real property known and numbered as 1880 Lambs Gap Road, Mechanicsburg, Cumberland County, Pennsylvania, 17050 (herein the "Property"). Husband shall, upon execution hereof, make formal application with a lender to refinance the joint mortgages and assume such debt in his own name. Loan approval is agreed to be a contingency for this agreement. The loan terms shall be acceptable to Husband in his sole discretion. There aze currently two (2) mortgages on the property as follows: (1) Waypoint Bank Loan Number 50092024; and (2) Waypoint Bank Loan Number 3251000101. Upon execution of the refinance documentation, Wife shall execute a special warranty Deed conveying all of her right, title and interest in and to the Property to Husband. Husband, shall then, upon disbursement of funds, pay off Wife's automobile loan for the 1997 Chevrolet Blazer, VIN 1GNDT13W1VK171616, to Member's First Credit Union, Loan Number 177525-01. Such loan balance is approximately $9,000.00. Husband shall also tender to Wife the difference between the vehicle loan payoff and the agreed upon cash settlement sum of $23,031.00. (c) Retirement, Pension, 401-K Plan. Each party hereby relinquishes all right, title and interest in the other party's retirement, pension and/or 401-K plan based upon the consideration and representations set forth herein. 3. Debts and Obli ate ions. (a) Individual debts/obligations. Each of the parties shall assume all debts and obligations presently in their individual names and shall indemnify, defend and hold the other harmless from said debts and obligations, whether incurred prior to, during, or subsequent to the marriage. This shall include all personal, individual credit cards and personal individual loans by either party. Each party hereby agrees to pay and hereby agrees to hold the other harmless from any and all personal debts and obligations incurred by him or her on or after the date of this Agreement. If any claim, action or proceeding is hereafter brought seeking to hold the other party liable on account of any such debts and obligations, such party will at his or her sole expense defend the other party against any such claim, action or proceeding, whether or not well-founded, and indemnify the other party against any loss resulting therefrom. (b) Joint debts/obligations. Husband and Wife represent that there no other joint debts or obligations currently outstanding with respect to which either party may incur any liability now or in the future except as set forth herein. 4. Legal Fees. Each party agrees that they shall be responsible for their own legal and other fees incurred by them in connection with this domestic relations matter unless otherwise specified herein or otherwise agreed to by them. 5. Automobiles. Upon execution hereofthe parties agree that the 1988 Pontiac 6000, currently titled to Husband and currently in Husband's possession shall become the sole free and clear property of Husband, and that Husband shall insure and assume all liability therefor. Wife waives any right, title or interest she may have in and to said automobile and shall promptly, at any time necessary, execute any title or transfer documents necessary to firlfill this provision. Upon execution hereof and satisfaction of the terms set forth in section 2(b) above, the parties agree that the 1997 Chevrolet Blazer currently titled to Wife and currently in Wife's possession shall become the sole free and clear property of Wife and that Wife shall insure and assume all liability therefor. Husband waives any right, title or interest he may have in and to said automobile and shall promptly, at any time necessary, execute any title or transfer documents necessary to fixlfill this provision. 6. Other Writings. Each of the parties hereto agrees to promptly execute any and all documents, consents, waivers, bills of sale, tax returns or other writings reasonably necessary to carry out the intent of this Agreement. 7. Further Debt. (a) Wife shall not contract or incur any debt or liability for which Husband or his property or estate might be responsible and shall indemnify and save harmless Husband from any and all claims or demands, including attorneys' fees and costs, made against him by reason of debts or obligations incurred by her. (b) Husband shall not contract or incur any debt or liability for which Wife or her property or estate might be responsible and shall indemnify and save harmless Wife from any and all claims or demands, including attorneys' fees and costs, made against her by reason of debts or obligations incurred by him. 8. Mutual Release. Except as otherwise provided herein and so long as this Agreement is not canceled by subsequent agreement, the parties hereby release and discharge, absolutely and forever, each other from any and all rights, claims and demands, past, present and future, resulting from the marriage relationship, specifically fromthe following: alimony pendente liter alimony; spousal support; division of property; claims or rights of dower and right to live in the House; right to act as executor or administrator in the other's estate; rights as devisee or legatee in the Last Will and Testament of the other; any claim or right as beneficiary in any life insurance policy of the other unless specifically named otherwise or as required herein; and any claim or right in the distributive share or intestate share of the other party's estate, all unless specified to the contrary herein or in a subsequent writing signed by the parties hereto. 9. Tax Return. The parties have elected to continue to file a joint tax return for tax year 2001 and to equally split any tax refirnd which maybe given by any particular taxing authority. In the event there are sums due, each party shall contribute according to their pro-rata income. Thereafter, the parties shall file separate individual income tax returns. Each party shall be solely liable for any and all of their own tax liability and shall indemnify, defend and hold the other harmless from and against any such liability. 10. Medical/HealthInsurance. Upon executionhereof,eachpartyshallberesponsible for their own medical/health insurance and the maintenance thereof, if any. 11. Entire Agreement. This Agreement constitutes the entire understanding between the parties, and there are no covenants, conditions, representations or agreements, oral or written, of any nature whatsoever, other than those herein contained. 12. Lesally Bindine. It is the intent of the parties hereto to be legally bound hereby, and this Agreement shall bind the parties hereto and their respective heirs, executors, administrators and assigns. 13. Full Disclosure. Each party asserts that she or he has fully and completely disclosed all the real and personal property of whatsoever nature and wheresoever located belonging in any way to each of them; of all debts and encumbrances incurred in any manner whatsoever by each of them; of all sources and amounts of income received or receivable by each party; and of every other fact relating in any way to the subject matter of this Agreement. These disclosures are part of the consideration made by each party for entering into this Agreement. 4 14. Costs to Enforce. In the event that either party defaults in the performance of any duties or obligations required by the terms of this Agreement, and legal proceedings aze commenced to enforce such duty or obligations, the party found to be in default shall be liable for all expenses, including reasonable attorneys' fees, incurred as a result of such proceedings. 15. Agreement Voluntary and Clearly Understood. Each party to this Agreement acknowledges and declares that he or she respectively: (a) Is fully and completely informed as to the facts relating to the subject matter of this Agreement and as to the rights and liabilities of both parties; and (b) Enters into this Agreement voluntarily after receiving the advice of independent counselor, having been advised to consult independent counsel, has knowingly and voluntarily chosen to forego such consultation; and (c) Has given careful and mature thought to the making of this Agreement; and (d) Has carefully read each provision of this Agreement; and (e) Fully and completely understands each provision ofthis Agreement, both as to the subject matter and legal affect. 16. Amendment or Modification. This Agreement may be amended or modified only by a written instrument signed by both parties. 17. Aonlicable Law. This Agreement shall be governed, construed and enforced under the statute and case law of the Commonwealth of Pennsylvania. 18. Severabilitv. If any part of this Agreement is determined to be invalid by a court of competent jurisdiction, such determination shall not invalidate the entire document but shall apply only to that phrase, sentence, paragraph or section. The remainder of the sentence, paragraph, section and Agreement shall continue in full force and effect. 19. Counterparts. This Agreement maybe executed in separate counterparts, each counterpart deemed an original and when combined represents the legal binding intent ofthe parties hereto. Signature pages follow this page. 5 IN WITNESS WHEREOF, the parties hereto have executed this Agreement the day and year first written above: WI'T`NESS: WITNESS: ~.e HUSBAND: Robert D. Gross WIFE: i l.~ Nena .Gross COMMONWEALTH OF PENNSYLVANLA COUNTY OF ~~~ ~ SS.: On this, the day of ©CrG ~~_ ~ 2001, before me, a Notary Public, the undersigned officer, personally appeared Robert D. Gross, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument and acknowledged that he executed the same for the purposes herein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. N07ARIAL SEAL Public JOHN R. BEINHAUR, Notary Lower Paxton Twp., Dauphin County M Cammiesion Ex iras Marah 13 2003 Not Public ~ My Commission Expires: (SEAL) COMMONWEALTH OF PENNSYLVANIA COUNTY OF u.,GLGCU{1.l{'~ . SS.. On this, theday of ~('t~~6y~ ~~- , 2001, before me, a Notary Public, the undersigned officer, personally appeared Nena M. Gross, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument and acknowledged that she executed the same for the purposes herein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. Not ry Public My Commission Expires: (SEAL) N01•AJ-3!!aL SEAL RENEE DREtSBACM, Notary Public City of Necrisbur~. Dauphin County MY CommissbrtEzpaes Nov. 30, 2002 EXHIBIT "A" Proposed Divorce Settlement Calculations from Robert D. Gross to Nena M. Gross 27 House Payments @ $783.00 $21,141.00 Kitchen Table and 4 Chairs $200.00 Living Room Table (small green) $20.00 Kitchen Carpet (green) $40.00 Air Hockey Table $50.00 3 6 ft. slider blinds @ $20.00 $60.00 2 bedroom mini-blinds @ $80.00 $160.00 Frigidaire Washer and Dryer set $800.00 Dehumidifier $50.00 Push Lawn Mower $100.00 Gas Grille $120.00 3 -plastic gazage shelves @ $20.00 $60.00 2 payments of $100.00 for tanning bed $200.00 Hose reel $10.00 Shovels and rakes $20.00 Total Cash payout $23,031.00 Computer and accessories Value to Nena (does not $800.00 include current AOL connection) Total Cash and Computer Value $23,831.00 Total Estimated Cash Payout $23,031.00 Full Payoffof 1997 Chev. Blazer loan (Member's $9,000.00- First receives payment and Bob will sign off of loan) Estimated total cash payment to Nena $ ] 4,031.00 ADDENDUM TO MATRIMONIAL SETTLEMENT AGREEMENT THIS ADDENDUM is made this a ! S F day of A}o-v £.nc ~, E Q , 2001, by and between Nena M. Gross of 2904 Warren Way, Mechanicsburg, Cumberland County, Pennsylvania, 17050 (herein "Wife") and Robert D. Gross of 1880 Lambs Gap Road, Mechanicsburg, Cumberland County, Pennsylvania, 17050 (herein "Husband"). RECTTALS WHEREAS, the parties hereto have entered into an Agreement of even date herewith which contains provisions requiring Husband to refinance the jointly owned real estate and the Parties desire to clarify the terms thereof in this Addendum. NOW, THEREFORE, in consideration of the mutual promises, covenants and undertakings herein contained, the parties, each INTENDING TO BE LEGALLY BOUND, agree as follows: 1. Recital. The Recital set forth above is incorporated herein by reference and specifically made a part of this Agreement. 2. Real Estate Matters: The parties have agreed to the following item from the Matrimonial Settlement Agreement: 2(b) Real Pronertv Division. The parties have agreed to a division of the real property known and numbered as 18$0 Lambs Gap Road, Mechanicsburg, Cumberland County, Pemmsylvania, 17050 (herein the "Property'). Husband shall, upon execution hereof, make formal application with a lender to refinance the joint mortgages and assume such debt in his own name. Loan approval is agreed to be a contingency for this agreement. The loan terms shall be acceptable to Husband in his sole discretion. There are currently two (2) mortgages on the property as follows: (1) Waypoint Bank Loan Number 50092024; -and (2) Waypoint Bank Loan Number 3251000101. Upon execution ofthe refinance documentation, Wife shall execute a special warranty Deed conveying all of her right, title and interest in and to the Property to Husband. Husband, shall then, upon disbursement of funds, pay off Wife's automobile loan for the 1997 Chevrolet Blazer, VIN 1GNDT13 W 1 VK171616, to Member's First Credit Union, Loan Number 177525-O1. Such loan balance is approximately $9,000.00. Husband shall also tender to Wife the difference between the vehicle loan payoff and the agreed upon cash settlement sum of $23,031.00. It is understood that the Matrimonial Settlement Agreement and all of the provisions therein are contingent upon Husband obtaining approval for acceptable financing and paying off the referenced mortgages to remove Wife as an obligee thereunder. 3. Ratification and Confirmation. In all other respects not inconsistent with this Addendum, the Matrimonial Settlement Agreement is hereby ratified and confirmed. IN WITNESS WHEREOF, the parties hereto have executed this Addendum the day and year first written above: WITNESS: WITNESS: HUSBAND: ~~~.~~ Robert D. Gross WIFE: I ' Nena M. Gross 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF , On this, the l sFday of ~jQyf ~ ~~ ~ , 2001, before me, a Notary Public, the undersigned officer, personally appeared Robert D. Gross, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument and acknowledged that he executed the same for the purposes herein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. SEAi- JOMN R. ~ -~p Dauphin Coon Notary Public t Oa Pex ton My Commission Expires: (SEAL) COMMONWEALTH OF PENNSYLVANIA SS.: COUNTY OF<f ~ On this, the ay of,/~-~('~.f/)1-~.~ , 2001, before me, a Notary Public, the undersigned officer, personally appeared Nena M. Gross, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument and acknowledged that she executed the same for the purposes herein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. Notary Public My Commission Expires: (SEAL) IYO~ARIAL SEAL RENEE DRESBACH, Notary Publrc Ciry of Hecristrufg. Dauphin County My CommissiortExpues Nov. 3n. 2002 *1'et-"aSUKwwsarw~~tmamnaa~seuats su~kiarerR. r. ~..u .at ~-~-a:.a.aweN3vxsvsv~s?ssaw+i.~ai4~. ,- - uavm~vaxm0~a - _ ~. •a*~""".."-a"•1 .p..' J.P' ~IC'fi ~ ~,~. ~7 ' f Cl i ." _ ... t"i _ ~.__ ~"-) -G ~.. {J~ _ _ _ `l_' - ~' ~ t 2' ~ t) 1 ~ Z +, ; ) CT. _. NENA M. GROSS; Plaintiff VS. ROBERT D. GROSS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NO. 01-5463 CIVIL TERM PRAECIPETOTRANSMIT 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) ~~1r~idl~x~c~~~• (Strike out inapplicable section). 2. Date and manner of service of the complaint: September 27 , 2001 , by certified Mail. 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by §3301 (c) of the Divorce Code: by plaintiff December 27, 2001 by defendant December 28, 2001 (b) (1) Date of execution of the affidavit required by §3301 (d) of the Divorce Code: (2) Date of filing and service of the plaintiff's affidavit upon the respondent: 4. Related Claims pending: The Marriage Settlement Agreement between the parties shall be incorporated, but shall not merge with the final Decree in Divorce. 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 of plaintiff's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: December 28, 2001 Date defendant's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: P4 `••:.:' Whxd4+nevirv~ -em+CSk}.1 a.v.-~:..~:.,: ~~~«-fie i3YE~1tll °Ii91k`~R +veu . ~ 5 ,' u eTaF..Rl.et:YuG4d~n fi,a..k. i .,r .c _._.. m §. E l37 C 1 -'O C.x3 ;,+'1 [:.:) may; ~ - Z :x; i- r,a `; ~u v: ~_ ,a~ ~: ~' -c. `' ~: ( :~ ;~~;. ` ~~c 4? ~: ?r. _; -~ -- NENA M. GROSS, : IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. Defendant NO. Q ~ - Sy`3 ROBERT D. GROSS, 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 may proceed without you and a Decree in 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 divorce is indignities or irretrievable breakdown of marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania. 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 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 TELEPHON$ THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 Telephone: (717) 249-3166 NENA M. GROSS, : IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA ROBERT D. GROSS, :CIVIL ACTION -LAW l Defendant : IN DIVORCE COMPLAINT IN DIVORCE 1. The Plaintiff is Nena M. Gross, an adult individual currently residing at 1880 Lambs Gap Road, Mechanicsburg, Cumberland County, Pennsylvania, 17050. 2. The Defendant is Robert D. Gross, an adult individual residing at 1880 Lambs Gap Road, Mechanicsburg, Cumberland County, Pennsylvania, 17050. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania, for a period in excess of six (6) months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on July 11, 1998, in Cumberland County. 5. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. 6. This action is not collusive. 7. Plaintiff and Defendant separated on or about May 15, 2001. 8. The causes of action and sections of the Divorce Code under which Plaintiffis proceeding are: A. Section 3301(c) -The marriage of the parties is irretrievably broken. B. Section 3301(d) -The marriage of the parties is irretrievably broken. The parties separated on or about May 15, 2001. 9. Plaintiff and Defendant have no children. 10. Plaintiff has been advised of the availability of marriage counseling and understands that she may request that her spouse and she participate in counseling. 11. Plaintiff does not request that the Court require that her spouse and she participate in counseling prior to a divorce decree being handed down by this Court. ~:~~,>., WHEREFORE, Plaintiff respectfully requests this Honorable Court enter a final decree in divorce. Date: Respectfully submitted, THE LAW OFFICES OF SILLIKER & REINH k T. Silliker, Esquire 5922 Linglestown Road Harrisburg, PA 17112 (717)671-1500 LD. Nb. 33671 Attorney for Plaintiff AFFIDAVIT I, Iy2(la woSS ,hereby certify that the aforegoing is tme and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. 4909 relating to unsworn falsifications to authorities. Dated: 4 - LA - O I ~~ ~ ~ ;~ ~ R ~ ~ ~ ~~ oc c> c ut !~~r; ~P f-' ~<J l=~ -<_:,.. ~, ~.~ x ~:~~ _~ ,,-~ _;, 4L ;,; ~~, `~ -~, -= ~,.; NENA M. GROSS, : IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, P$NNSYLVANIA v. NO. 01-5463 CIVIL TERM ROBERT D. GROSS, :CIVIL ACTION -LAW Defendant : IN DIVORCE CERTIFICATE OF SERVICE The undersigned, Renee Dreisbach, hereby certifies that a copy of a Complaint in Divorce was served upon Robert D. Gross, on September 27, 2001, by Certified Mail, return receipt requested, addressed as follows: Robert D. Gross 1880 Lambs Gap Road Mechanicsburg, PA 17050 I hereby certify that the aforegoing is true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: ~ ~ d~.. Renee Dreisbac ~ Complete items 1, 2, and 3. Aiso complete item 4 if Restricted Delivery is desiretl. r Print your name and address on the reverse so that we can return the card to you. '~ Attach this card to the back of the mailpiece, or on She front if space permits. 1. Article Addressed to: ~~~f ~ ~ ~sv (~almbs ~ R~ ~G~ICt.UI ~CS~ LLf'~ 7~ 2. Article Number (Copy from service label) A. X SIB/~-G r~7iT',/ //r~ ^ Age ~.; D. Is tlelivery address different from kem 1? Q Ye: If YES, enter delivery address below: ^ No 3. S ice Type , ert'rfied Mail ^ Express Mail ^ Registered ^ Retum Receipt for Merchandise n ~"sured Mail ^ C.O.D. 4. Fee) PS Form 38'11, July~1999 Dbmestic Return Redeipt - 702565-OO-M-0952 r ='L~M~~Yss~B'r~fiL e~~ss :.1 ~,~,. .. _ ~.. , .~ _ ~.,mi~d ,. . i~t~~f.b~.~x~a~~IJlst~~ x~,~y,a~r~~'4a~t~~}V~~t~§Swa~zf ~ C) C~ - .__ e,' ' ~> ~~ ='~ C .e! Ca Q. I ~...,_ - ~~' G3 ~ `; ~ z y-, =~ ca ~,~ -~ NENA M. GROSS, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 01-5463 CIVIL TERM ROBERT D. GROSS, :CIVIL ACTION -LAW Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 19, 2001. 2. The marriage of the Plaintiff and Defendant is irretrievably broken, and ninety days have elapsed since the date of filing and service of the Complaint. 3. I consent to the entry of a Final Decree in Divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworn falsifications to authorities. ., Date: 4,~~~'1-®I w~ ~ Nen~a .Gross \, t7 ti. :' C' -- ~~~'; ~ 4 l C~.; ";.: . _ T , _ ' il ~: CT -"{ NENA M. GROSS, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. No. 01-5463 CIVIL TERM ROBERT D. GROSS, :CIVIL ACTION -LAW Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 19, 2001. 2. The marriage of the Plaintiff and Defendant is irretrievably broken, and ninety days have elapsed since the date of filing and service of the Complaint. 3: I consent to the entry of a Final Decree in Divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworn falsifications to authorities. Date: /a l.3 S~~/ ~"~'"'~ v~ !~-~ Robert D. Gross C'~ ~~ ~ C; ...... f-~ _~~~ ~ t -~~'~~`'-' ~yf - r- ~_ "~J _ CJ , _? ~, :i? ! ~~~ T.~~ ~ Y71 ~ *~.;, NENA M. GROSS, v. IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA ROBERT D. GROSS, Defendant No. 01-5463 CIVIL TERM CIVIL ACTION -LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 (c) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree in 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 ¢opy 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 aze true and correct. I understand that false statements herein aze made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: /'~ ~~ ~6 / ~~°~ _ Robert D. Gross vANP~. 9et~~'~2%d~'JL11f.AV§" 4.F."YT::2 r. fl ::::_:. : : is _. _ : L~"$H_M]k..~ Mf6~~ffi.~RAL*1k&uY:PK*_'rAV'ID.4a'NS+:z'nae~kiA~Y"r19~kti - .. •, _ •... ... f9 Wr '~~ '~ ~_,~ -!_ 1TiC;. !! L«~ ~" ~ -.. "~Y r~ ? =% ^ ~~V Y - ~C ~ , zr- ~ .,! ''~ .._.......e. - "_u ,~......~~,wLay a.~w~. NENA M. GROSS, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. No. 01-5463 CIVIL TERM ROBERT D. GROSS, :CIVIL ACTION -LAW Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 (c) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree in Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a Divorce Decree is entered by the Court and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. ~~ ~ Date: k~' 01-1- o I "1 ( ~ ~-fj Nen M. Gross 5 'sit 43k N M'J.~-r'ri &h V sd. l~•1 a -._~.. i. _i_~ _...-sue e ~~ 2 C jLL ~LL ~'f '- `J :~~ii ~i ~ ...: ~~.; j t_. ~~~ -V L .s ^` ue _ .1 NENA M. GROSS, Plaintiff v. ROBERT D. GROSS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-5463 CIVIL TERM CIVIL ACTION -LAW IN DIVORCE AFFIDAVIT OF INTENTION TO RESUME PRIOR NAME COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN Nena M. Gross, being duly sworn according to law, deposes and says that she is the Plaintiff in the above suit in which final decree from the bonds of matrimony was entered and she elects to resume her prior name of Nena M. Zeiders, and, therefore, gives this written notice avowing said intention, in accordance with the provisions of the Act of May 25, 1939, P. 192, as amended July 13, 1953 (23 P.S. 98). ~~~ ~ Nen M. Gross to be known as Ne M. Zeider Sworn and subscribed to before me this ~ day of~ .UiA ,rat , ~. Public i~©~A,E:isL S~AI flENEE AAEISBACM, Notary ('ublrc City of Ffecristwsg'. Qauphin County My CommisSiortEzpYres Nov. 30. 2002 -°r~ .n ,, r ~, s .. _ ,_ srs;5~a. a &ska~ .«srru~- .. .e k> >a..~ ax~wa~,: .w ~,m2d€ev~c ctaia .1 (~ ^~ V 4,, ` C ~p [ti r j r_, fJ1~_ fi l- ir t_) ~~ ~ ~' C c:°t . to ~~ -.! l) :.,-) ~i,. ~ ~ns~ `"`/