HomeMy WebLinkAbout01-06341
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF
PENNA.
MICHAEL T. CROFTCHECK,
Plaintiff
No.
"TlTTT.
nl_fii41
VERSUS
JULIE L. CROFTCHECK,
Defendant
DECREE IN
DIVORCE
AND NOW,
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,C>O', IT IS ORDERED AND
DECREED THAT
MICHAEL T. CROFTCHECK
, PLAINTIFF,
AND
JULIE L. CROFTCHECK
, 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;
MARRIAGE SETTLEMENT AGREEMENT INCORPORATED BUT NOT MERGED
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ATTEST:
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PROTHONOTARY
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MARITAL SETTLEMENT AND
PROPERTY DISTRIBUTION AGREEMENT
01_ /'3'11 ~ TLtA-
THIS AGREEMENT is made effective as of the Z..d day of ~H I
, 2002 by and between Julie 1. Croftcheck, who resides at 1133 olumbus
Avenue, Lemoyne, Cumberland County, Pennsylvania, 17043 (hereinafter "Wife"), and
Michael T. Croftcheck, who resides at 38 Gale Road, Camp Hill, Cumberland County,
Pennsylvania 17011 (hereinafter "Husband")(collectively, the "parties").
WITNESSETH
WHEREAS, the pardes herf~to were lawfh!ly mmTid t,) each other on August 8,
1983, in Cumberland County, Pennsylvania;
WHEREAS, there are no minor children of the marriage;
WHEREAS, the parties intend to live separate and apart for the rest of their lives
and are desirous of settling completely and finally the economic and other rights and
obligations between each other; and
WHEREAS, each party has represented to the other and has made fun disclosure
of their assets and income to the other party.
NOW, THEREFORE, in consideration of the premises and the mutual covenants
and conditions hereinafter contained, and intending to be legally bound hereby, the
parties mutually agree as follows:
1. Personal Rights. The parties intend hereafter to live separate and apart.
They shall be free from any control, restraint, interference or authority, direct or indirect,
by the other in all respects as fully as if unmarried. Each may, for his or her separate use
or benefit, conduct, carry on and engage in any business, occupation, profession or
employment which to him or her may seem advisable. They shall not molest, harass,
disturb or malign each other or the respective families nor compel or attempt to compel
the other to cohabit or dwell with him or her.
2. Property Distribution. All personal property which was acquired
separately by each of the parties prior to the man-iage, by gift or inheritance from a third
party, or after separation, shall remain the separate property ofthe party who has
possession or control of it as of the date of execution of this Agreement. Husband and
Wife hereby acknowledge and agree that any and all real or personal property, tangible or
intangible, without limitation by specification, ovmed or acquired by both or either of
them during their marriage has been equitably divided between them. Each party shall
keep and retain sole ownership, control and enjoyment of all property in his or h ,\omff?1n\
possession or control as of the date of execution of this Agreement. Husband ~ ~\\ \ \
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specifically release and waive any and all interest, claim or right that he or she may have
as to the whole or any part of said property that is in the control or possession of the other
party. With respect to this property held separately, each party agrees to indemnify and
hold the other harmless from any liability, cost or expense associated with such separate
property. Should it become necessary, each party agrees to sign any title or documents
necessary to give effect to this paragraph, upon request.
3. Retirement Benefits. Husband and Wife hereby specifically release and
waive any and all interest, claim, or right tllat he or she may have to any and all
retirement benefits (including pension or profit sharing benefits) or other similar benefits
of the other party. The parties further acknowledge and agree that they shall execute any
documents pursuant to the Retirement Equity Act or any similar Act that may be required
from time to time to accomplish the purpose of this Paragraph.
4. Alimony/Support. Husband and Wife represent and acknowledge that they
each have sufficient property to provide for his or her reasonable needs and that each is
able to support himself or herself through appropriate employment. Therefore,
notwithstanding anything to the contrary contained in the Divorce Code, as amended,
Husband and Wife hereby expressly waive, discharge and release any and all rights or
claims which he or she may have now or hereafter by reason of the parties' marriage to
alimony, alimony pendente lite, support and/or maintenance or any other such benefits
resulting from the parties' status as husband and wife.
5. Full Disclosure. Husband and Wife each represent and warrant to the other
that he or she has made a full and complete disclosure to the other of all assets of any
nature whatsoever, and of all other facts relating to the subject matter of this Agreement
to which such party may reasonably require to make an informed decision regarding this
Agreement.
6. Warranty as to Existing and Future Obligations. During the course of
the marriage, Husband and Wife have incurred certain liabilities. Each party represents,
covenants and warrants that, to the best of his or her knowledge, and except as
specifically otherwise provided for by the telms of this Agreement, as of the date of
execution of this Agl'~emeni.: a) no unp@d~iabiJitie:; remain which were incurred by him
or her or on his or her behalf for which the other party may be deemed liable; b) there are
no actions, suits or proceedings pending or threatened against Husband and/or Wife of
affecting any jointly held properties or rights, at law or in equity or before any federal,
state, municipal or other governmental agency, nor is Husband or Wife aware of any facts
which to his or her knowledge might result in such action, suit or proceeding; c) if any
such liabilities, actions, suits or proceedings should be determined to have existed as of
the date of execution of this Agreement or thereafter, the party who incurred that debt
shall exonerate and indemnify the other party against and hold the other party harmless
from any liability or expense, including counsel fees, incurred as a result of those
liabilities; and d) he or she shall not incur any liability whatsoever in the future for which
the other party or the estate of the other party may be liable, and shall exonerate and
indemnify the other party against and hold the other party harmless from any such
Page 2 of7
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damages resulting from such liability, including reasonable counsel fees, incurred by the
other party.
7. Execution of Other Documents. Each of the parties shall on demand execute
and deliver any document and do any 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 fees, costs, and
other expenses reasonably incurred as a result of the failure.
8. Release of All Claims. Except as specifically set forth in this Agreement,
each party to this Agreement releases the other from all claims, liabilities, debts,
obligations and causes of action that have been incurred during the marriage between the
parties.
9. Release of Testamentary Claims. Except as specifically provided for in this
Agreement, the parties hereby mutually waive and release to the other any right to:
(a) inherit from the other any part of the estate of the other at his or her death;
(b) receive property from the estate of the other by bequest or devise, except
under a Will or Codicil dated subsequent to the effective date of this Agreement;
( c) act as a personal representative of the estate of the other on intestacy;
(d) act as executor under the Will of the other, unless nominated by a Will or
Codicil dated subsequent to the effective date of this Agreement.
10. Remedies in the Event of Breach. In the event ofa breach of any of the
provisions of this Agreement by one ofthe parties, the remedies available to the non-
breaching party are cumulative and include all remedies at law and in equity, including
those for breach of contract, under theories of equity, under the Divorce Code, as
amended, and shall not be limited to those remedies specifically referred to in this
Agreement.
In the event either party breaches any provision Ofthis Agreement, the breaching
party shall exonerate and indemnifY the non-breaching party and hold the non-breaching
party harmless for all losses resulting from the breach, including, but not limited to,
counsel fees, and costs relatittgto such breach, whether or not litigation is instituted.
11. Advice of Counsel. The provisions of this Agreement and their legal effect
have been fully explained to the parties by their respective counsel, the Law Offices of
Austin F. Grogan for Husband, and the Law Offices of Richard C. Gaffuey for Wife. The
parties acknowledge that each has received independent legal advice from counsel of
their selection and that they have been fully informed as to their legal rights and
obligations arising out of their marriage and impending divorce, including all rights
available to them under the Pennsylvania Divorce Code of 1980, as amended. Each party
confirms that he or she fully understands the terms, conditions and provisions of this
Agreement and believes them to be fair and reasonable under the circumstances. The
parties further confirm that each is entering into this Agreement freely and voluntarily
Page 3 of7
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and that the execution of this Agreement is not the result of any duress, undue influence,
collusion, or improper or illegal agreement or agreements.
12. Intention with Respect to a Divorce. The parties intend to secure a mutual
consent, no-fault divorce pursuant to the provisions of Section 3301(c) of the Divorce
Code of 1980, as amended. In that regard, Husband has filed a divorce action in the
Court lifCommon Pleas of Cumberland County, Pennsylvania, Civil Term, Docket
Number 01-6341, seeking a divorce pursuant to Sections 330l(c) and (d) of the Divorce
Code.
13. Effect of Divorce Decree. This Agreement shall continue to be effective after
the entry of a final decree in divorce between the parties, and except as otherwise
provided for in this Agreement, this Agreement shall remain in full force and effect even
if no final decree in divorce is entered.
14. Incorporation into Divorce Decree. This Agreement shall be
incorporated into, but not merged with, any divorce decree which may be entered and the
Court of Common Pleas entering the divorce decree shall retain continuing jurisdiction
over the parties and the subject matter of the Agreement for the purpose of enforcement
of any of its provisions.
15. Waiver or Modification to be in Writing. No modification or waiver of any of
the terms of this Agreement shall be valid unless in writing and signed by both parties.
16. No Waiver of Default. This Agreement shall remain in full force and effect
Ullless and until terminated under and pursuant to the terms of this Agreement. No
waiver of any breach or default of this Agreement shall be deemed a waiver of any
subsequent default of the same or similar nature or a waiver of strict performance of any
other obligations pursuant to the terms of this Agreement. The failure of either party to
insist upon strict performance of any of the terms of this Agreement shall in no way
affect the right of such party to enforce those terms in the future.
17. Integration. Except as set forth in this Agreement, this Agreement constitutes
the entire understanding of tlli~ parties and supersedes any and all pilor agreements and
negotiations between them. There are no other express or implied, oral or written
representations, terms, covenants, conditions, agreements or warranties, of any nature
whatsoever, other than those expressly set forth in this Agreement.
18. Severability. If any provision of this Agreement shall be finally determined to
be invalid, then only that provision shall be stricken from this Agreement and in all other
respects this Agreement shall be valid and shall continue in full force and effect. The
failure of any party to meet his or her obligations under any provision of this Agreement,
with the exception of the s~tisfaction of the conditions precedent, shall in no way void or
alter the remaining obligations of the parties.
Page 4 of7
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19. Agreement Binding nn Heirs. The tenns, provisions and conditions of this
Agreement shall be binding upon any and all of the heirs, executO'rs, administratO'rs,
successO'rs O'r assigns of either O'f the respective parties hereto, except as O'therwise herein
prO'vided.
20. Applicable Law. This Agreement shall be governed by and cO'nstrued in
accordance with the laws O'fthe CommO'nwealth O'fPennsylvania.
21. Headings Not Part of Agreement. Any headings preceding the text O'f any O'f
the paragraphs or subparagraphs O'fthis Agreement are inserted sO'lely fO'r convenience O'f
reference, shall not cO'nstitute a part O'f this Agreement and, therefO're, shall nO't affect its
interpretatiO'n.
22. CO'lItract Interpretation. FOi" purposes of contract interpretationa11d fOf the
purpose of resolving any ambiguity in this Agreement, Husband and Wife agree that this
Agreement was prepared by the joint efforts of the respective parti~s.
23. Address of p.arties. As long as any obligations remain to be performed
under this Agreement, each party shall have the affirmative obligation to keep the other
informed of his or her residence address, and shall promptly notifY the O'ther in writing of
any change of address.
Each party has carefully read and fully considered this Agreement and all of the
statements, terms, conditions and provisions thereof prior to signing below.
IN WITNESS WHEREOF, the parties hereto, intending to be legally bound
hereby, have hereunto executed this Agreement the day and year first written above.
Witness:
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L. Croftcheck
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Laura A. Gargi 0, ~r~
Austin F. Grogan, Es
Page 5 of7
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COMMONWEALTH OF PENNSYLVANIA :
ss.
COUNTY OF CUMBERLAND:
On this, the 2rd. day of Ap-\ \ ,2002, before me, a Notary
Public for the Commonwealth of Pennsylvania, residing in the County of Cumberland,
personally appeared Julie 1. Croftcheck, known to me to be the person whose name is
subscribed to the within Agreement and acknowledged that she executed the same for the
purposes therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and official seal.
R-u~ 6 .Gwn~
Notary Public
My'Commission Expires: 0\ r~\ 02-
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COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND:
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On this, the ,;J. 5~ day of ~ , 2002, before me, a Notary
Public for the Commonwealth of Pennsylvania, residing in, the County of Cumberland;
personally appeared Michael T. Croftcheck, known to me to be the person whose nameis
subscribed to the within Agreement and acknowledged that he executed the same for the
purposes therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and official seal.
Page 7 of7
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My Commission
Notarial Seal .
Rhonda D. Rudy, Notary Public
Camp Hili Bom, cumbe:'d ~~~
My Commission expires g. .
Member, Pennsylvania Association of Notaries
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MICHAEL T. CROFTCHECK,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 01-6341 CNIL TERM
JULIE L. CROFTCHECK,
Defendant
IN DNORCE
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the following information, to the court for entry of a
divorce decree:
1. Grounds for divorce: irretrievable breakdown under ~ 330l(c) of the Divorce
Code.
2. Date and manner of service of the complaint:
By certified mail on November 16, 2001.
3. Date of execution of the Affidavit of Consent required by ~ 3301(c) of the Divorce
Code: by Plaintiff March 25, 2002 ; by Defendant April 1, 2002.
4. Related claims pending: All claims raised resolved in Marriage Settlement
Agreement dated April 2, 2002.
5. Date Plaintiff's Waiver of Notice in ~ 330l(c) Divorce was fIled with the
Prothonotary: March 27,2002.
Date Defendant's Waiver of Notice in ~ 330l(c) Divorce was fIled with the
Prothonotary: April 8, 2002.
Date: 5/ fJ"'1~-V
Austin F. Grogan, squir
Attorney for Plaintiff
24 North 32nd Street, Camp Hill, PA 17011
(717) 737-1956
Id # 59020
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
I, Austin F. Grogan, Esquire, hereby certify that I did mail a true and correct copy of the
Praecipe to Transmit the Record in the above-captioned matter to the Defendant, Julie L.
Croftcheck, on May 15, 2002, at:
Laura A. Gargiulo, Esq.
Law Offices of Richard C. Gaffney
2120 Market Street, Suite 101
Camp Hill, PA 17011
which satisfied the requirements of service by mail pursuant to Pa. R.C.P. 403.
I understand that false statements are made herein are made subject to the penalties of
Pa.C.S. ~ 4904, relating to unsworn falsification to authorities.
Date S/ 1>/ ~~
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Attorney for Plaintiff
24 North 320d Street
Camp Hill, PA 17011
(717) 737-1956
ill #59020
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MICHAEL T. CROFTCHECK,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 01 - '-3~ I
C,'oLL y~
JULIE L. CROFTCHECK,
Defendant
IN DNORCE
NOTICE
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claim 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 arnru1ment may be entered against you by
the Court. A judgement 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.
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When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may
request marriage counseling. A list of marriage counselors is available in the Office of the
Prothonotary, Cumberland County Courthouse, Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DMSION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNUlMENT IS GRANTED,
YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE TIllS 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 LmERTY AVENUE
CARLISLE, PENNSYLVANIA 17013
(717) 249-3166
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MICHAEL T. CROFTCHECK,
Plaintiff
IN TIlE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 01 - W4/
Cio.L <-r~
JUilE L. CROFTCHECK,
Defendant
IN DIVORCE
COMPLAINT
1. The Plaintiff is MICHAEL T. CROFTCHECK, Social Security number 208-42-
3884; who currently resides at 38 Gale Road, Camp Hill, Cumberland County, Pennsylvania
17011.
2. The Defendant is JULIE L. CROFTCHECK, Social Security number 196-50-0409,
who currently resides at 10 Boxwood Lane, Camp Hill, Cumberland County, Pennsylvania 170ll.
3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of
Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint.
4. Plaintiff and Defendant were married on August 8, 1983 in Cumberland County,
Pennsylvania
COUNT I - DIVORCE
5. Paragraphs 1 through 4 of this Complaint are incorporated herein by reference as
though set forth in full.
6. There have been no prior actions of divorce or for annulment between the parties.
7. Divorce is sought pursuant to the provisions of the Divorce Code, Sections
3301(c) and 3301(d), in that:
a) The marriage is irretrievably broken.
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b) Plaintiff and Defendant have lived separate and apart smce
September 15, 2001 and continue to do so.
8. The Plaintiff has been advised that counseling is available and that Plaintiff may
have the right to request that the court require the parties to participate in counseling.
Date
9. Defendant is not a member of the armed services.
WHEREFORE, Plaintiff requests this Honorable Court to enter a Decree of Divorce.
Respectfully submitted,
ft/os<fti'
A~J~
24 North 32nd Street
Camp Hill, PA 17011
(717) 737-1956
Attorney for Plaintiff
I.D. #59020
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VERIFICATION
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I, MICHAEL T. CROFTCHECK, verify that the statements made in the foregoing Complaint
are tnte 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 /1/2/0!
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MICHAEL T. CROFTCHECK,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 01-6341 CML TERM
JUUE L. CROFTCHECK,
Defendant
IN DIVORCE
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
Austin F. Grogan, being duly sworn according to law, deposes and says that he is the
attorney for Plaintiff, Michael T. Croftcheck, and that he did mail a true and correct copy of the
Complaint in Divorce in the above matter, by certified mail, return receipt requested, to the
Defendant, Julie L. Croftcheck, on November 7, 2001 at her last known address: 10 Boxwood
Lane, Camp Hill, PA 17011, which satisfied the requirements of service by mail pursuant to
Pa.R.C.P.403. The signed receipt acknowledging receipt on November 16, 2001 is attached hereto
as Exhibit "A".
Date ,\ \,..\. \
Austin F. Grog ,Es u'
24 North 32nd Street
Camp Hill, PA 17011
(717) 737-1956
Attorney for Plaintiff
ill #59020
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item 4 if Restricted Delivery is desired.
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so that we can return the card to you.
. Attach this card to the back of the mail piece,
or on th~ front if space permits.
1, Att,icle Addressed to:
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PS fbrm;38~ 1i,I:Ju'iy 1999 Domestic Return Receipt
EXHIBIT "A"
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MICHAEL T. CROFTCHECK,
Plaintiff
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01-6341 CIVIL TERM
JULIE L. CROFTCHECK,
Defendant
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
November 6, 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 final decree of divorce after service of notice of
intention to request entry of the decree.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa.C.S. ~ 4904 relating to unsworn
falsification to authorities.
Date
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MICHAEL T. CROFTCHECK,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 01-6341 CIVIL TERM
JULIE L. CROFTCHECK,
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 fmal decree of divorce without notice.
2. I understand that I may lose rights concerning alimony, division of
property, lawyer's fees or expenses if! do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by
the Court and that a copy of the decree will be sent to me immediately after it is filed with the
Prothonotary .
I verify that the statements made in this affidavit are true and 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:
3/Js/oL
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MICHAEL T. CROFTCHECK,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 01-6341 CIVIL TERM
JULIE L. CROFTCHECK,
Defendant
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
November 6, 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 final decree of divorce after service of notice of
intention to request entry of the decree.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa.C.S. ~ 4904 relating to unsworn
falsification to authorities.
Date
LJ / II ()~
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JULIE . CROFTCHECK
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MICHAEL T. CROFTCHECK,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 01-6341 CNIL TERM
JULIE L. CROFTCHECK,
Defendant
IN DNORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301(c) OF THE DIVORCE CODE
L I consent to the entry of a fInal decree of divorce without notice.
2. I understand that I may lose rights concerning alimony, division of
property, lawyer's fees or expenses if! do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by
the Court and that a copy of the decree will be sent to me immediately after it is fIled with the
Prothonotary.
I verify that the statements made in this affidavit are true and 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:
Lf4Jo~
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JUL L.CROFTCHECK
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MICHAEL T. CROFTCHECK,
Plaintiff
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IN THE COURT OF COMMON PLEAS OF,
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 01-6341 CIVIL TERM
v.
JULIE L. CROFTCHECK,
Defendant
IN DlVORCE
NOTICE OF INTENTION TO RESUME PRIOR NAME
Notice is hereby given that the defendant in the above-captioned matter, having been
granted a final decree in divorce on the 22nd day of May, 2002, hereby intends to resume and
hereafter use the previous name of Julie L. Cole and gives this written notice avowing her
intention in accordance with the provision of the Act of December 16, 1992, P.L. 1309, 54 Pa.
C.SA S 704.
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Signature of petitioner (married name)
Julie L. Croft~ck
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Signature - Intended (prior surname)
Julie L. Cole
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COMMONWEALTH OF PENNSYL VANIA
SS.
COUNTY OF CUMBERLAND
On th~ay of # 2003, before me, a notary public, personally appeared Julie L.
Croftcheck, know to me to oe the person whose name is subscribed to the within document and
acknowledged that (he or she) executed the foregoing for the purpose therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and seal.
Sworn t~ and subscribed before me
thi~ day ofllfM..J ,2003.
My COlnInission Expires:
Notarial Seal
Headier Y. Flick, Notary Public
Twp.. Cumberland County
My Commission Expires May 31, 2004
MIIllbIIr.Penh~laAuociatlonolNolaJ1ea
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: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 01-6341 CIVIL TERM
MICHAEL T. CROFTCHECK,
Plaintiff
JULIE 1. CROFTCHECK,
Defendant
: IN DIVORCE
ENTRY OF APPEARANCE
To the Prothonotary ofthe Said Court:
Please enter thc appearance of the Law Offices of Richard C. Gaffuey as counsel for the
Defendant, Julie 1. Croftchcck, in the above-captioned matter.
Respectfully submitted,
LA W OFFICES OF RICHARD C. GAFFNEY
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P A Supreme Court ID No. 86128
2120 Market Street, Suite 101
Camp Hill, PA 17011
(717) 975-9033
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MICHAEL T. CROFTCHECK,
Plaintiff
v.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 01-6341 CIVIL TERM
JULIE L. CROFTCHECK,
Defendant
: IN DIVORCE
CERTIFICATE OF SERVICE
I hereby certify that I am this day serving a copy of the foregoing document upon the
persons and in the manner indicated below, which service satisfies the requirements of the
Pennsylvania Rules of Civil Procedure, by mailing a copy of same via the United States Postal
Service, First Class Postage Prepaid addressed as follows:
Austin F. Grogan, Esquire
Law Offices of Austin F. Grogan
24 North 32nd Street
Camp Hill, PA 17011
Date: 1-11' Jo-z....
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