HomeMy WebLinkAbout01-06414
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY.
STATE OF
PENNA.
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"Jam ~1. MORGAN
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No.
0(1,-6414 ,lTvn
VERSUS
:ERBEBT R. 110RGAN
DECREE IN
DIVORCE
AND NOW,
JI.!.I\C <.,
2.00 2 , IT IS ORDERED AND
DECREED THAT ~9DI I'!. 110RGAN
, PLAINTIFF,
AND
J.-IEKBER'r R. :'vIOaG-.AN
, DEFENDANT,
ARE DIVORCE;D 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 ENTE;RED;
NONE.. COSj'S '1'0 BE PAID BY PLH-liiJ:H'F.
BY THE COURT: /
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PROTHONOTARY
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
NO.
o {-tOY I L/ CIVIL TERM
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the following information to the court for entry of a divorce decree:
1. Ground for divorce:---'--
Irretrievable breakdown und~;301 (~
JJQ1(G1)(1}-ofthe Divorce C~
(Strike out inapplicable section).
2. Date and manner of service of the complaint: No'-lemopr l ~ F 200 \
LAS ?os{o..l {;evv) Qe } Cerb-Fr ltd Letter
3. Complete either paragraph (a) or (b).
(a) Date of execution ~f the rffidavit of consent required by ~3301 ~ of the Divorce Code:
by plaintiff ~ I ;]1[ LOl ; by defendant b (:2/ 02
(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:
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: Z .- ~ 1 ~ 0 L
Date defendant's Waiver of Notice in ~3301 (c) Divorce was filed with
the Prothonotary: ct:P 5 7 3 I /6 2-
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Jodi M. Morgan,
PLAINTIFF,
v.
(IN THE COURT OF COMMON PLEAS OF
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(CUMBERLAND COUNTy, PENNSYLV ANlA
(
(CIVIL DIVISION
~ NO: a 1- (g 414
Herbert R. Morgan,
DEFENDANT,
AFFIDAVIT OF CONSENT
1. A cOffi\llaint in Divorce under Section 3301(c) of the Divorce Code was filed on
jJoveYY\Oer loth ,2ooL
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days
have elapsed from the date of filing and Complaint.
3. I consent to the entry of a fmal decree of Divorce aft-:Jf service of notice of
intention to request entry of the decree.
WAIVER OF NOTICE OF INTENTION TO REOUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 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 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:1l.~ ~ ~OO~ t.~1L~~
. - / / uefc;ndant, Herbert R. Morgan, Pro e
I, Herbert R. Morgan, certify that a copy of the foregoing Affidavit of Consent
was forwarded by US Mail, postage prepaid, on this date, to the Plaintiff, Jodi M.
Morgan, at her address of record.
Date: ~):ZCO~
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Herbert Morgan
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Jodi M. Morgan,
PLAINTIFF,
(IN THE COURT OF COMMON PLEAS OF
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(CUMBERLAND COUNTY, PENNSYLVANIA
(
(CIVIL DIVISION
~ NO: 6/- to 41 q
v.
Herbert R. Morgan,
DEFENDANT,
ACCEPTANCE OF SERVICE
TO THE PROTHONOTARY:
I, Herbert R. Morgan, Defendant in the above-captioned matter, hereby
acknowledge receipt of the Comphint in Divorce and Notice to Defend and Claim Rights
inthe matter of Jodi M. Morgan v. Herbert R. Morgan, Civil Division NO:~
and I hereby waive formalities of service and any objections to defects thereto.
DATE~;:?20CP, 1"~1t~
:/ Herbert R. Morgan, Defendant ~
1219 13th Ave.
Altoona, PA 16601
(814) 943-4903
I, Herbert R. Morgan, certify that a copy of the foregoing Acceptance of Service
has been forwarded on this date by US Mail, postage prepaid, to the Plaintiff, Jodi M.
Morgan, at her address of record.
Date:I/;t~~ ~OO~
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Jodi M. Morgan,
PLAINTIFF,
(IN THE COURT OF COMMON PLEAS OF
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(CUMBERLAND COUNTY, PENNSYLVANIA
(
(CNIL DIVISION
~NO: 0 / -(g~ ILl
v.
Herbert R. Morgan,
DEFENDANT,
MARITAL PROPERTY SETTLEMENT AGREEMENT
THIS AGREEMENT, made this JL day oflliemmr::- 2001, between
PLAINTIFF, Jodi M. Morgan (Wife), residing at 195 Thorny Grove Lane, Shippensburg,
PA, 17257, and DEFENDANT, Herbert R. Morgan (Husband), residing at 1219 13th
Ave., Altoona, PA 16601.
WITNESSETH
1. The parties were married on October 30,1999;
2. The parties filed for 3301(c) Divorce on:~, 200L;
3. The parties hereto desire to settle their property rights;
4. Both parties agree to relinquish any and all claims which either may have
against any property now owned or belonging to the other or which may hereinafter be
acquired by either of them by purchase, gift, devise, bequest, inheritance, or otherwise,
except as to the obligations, covenants, and agreements contained herein; and
5. Both parties have had an opportunity to seek the benefit of competent and
independent legal and fmancial advice by separate counsel.
THEREFORE, the parties, agree and stipulate at follows:
1. INCORPORATION OF RECITALS
The recitals set forth above are incorporated herein as if set forth in full.
2. SEVERABILITY
Each paragraph contained herein shall be determined to be a separate and
independent agreement. In the event that any portion of this agreement is deemed to be
illegal or unenforceable, said determination shall not affect the enforceability of any other
paragraph.
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3. APPLICABLE LAW
Agreement shall be construed under the laws of the Commonwealth of
Pennsylvania.
4. PROPERTY DIVISION
A. Property to be awarded to Wife:
Except as is otherwise stated herein, Wife shall retain any and all property in her
possession free and clear of any right, title or interest of Husband. This award shall
include, without limitation, Wife's personal clothing and effects, her furniture and
furnishings, the vehicle in her possession, her bank accounts, her retirement funds, and
such other property she may hold as of the date of this agreement.
R Property to be awarded to Husband:
Except as is otherwise stated herein, Husband shall retain any and all property in
his possession free and clear of any right, title or interest of Wife. This award shall
include, without limitation, Husband's personal clothing and effects, his furniture and
furnishings, the vehicle in his possession, his bank accounts, his retirement funds, and
such other property he may hold as of the date of this agreement.
5. DISTRIBUTION OF DEBT.
The parties agree that they do not have any jointly owed debts. Each party shall
be solely responsible for any and all debts standing in his or her name alone and shall
hold the other party harmless thereon.
6. REALESTATE
The parties have no jointly held real estate. Wife has real property located at 195
Thorny Grove Lane, Shippensburg, Cumberland County, Commonwealth of
Pennsylvania, which shall remain her sole property free and clear of any right, title or
interest of Husband.
70 ALIMONY, SPOUSAL SUPPORT, AND SEPARATE EXPENSES.
Each party hereto waives any present and future claims to alimony, temporary
alimony, and spousal support
8. JOINT DEBTS
Husband and Wife each certify that there are no joint marital obligations.
9. DIVORCE
Husband and Wife agree that the marriage is irretrievably broken and will proceed
with said Divorce under 23 Pa. c.A. Section 3301(c).
10. LEGAL ADVICE
Husband and Wife declare that each has had the opportunity to obtain
independent legal advice by counsel of his or her own selection and to obtain financial
advice, and that any failure of either party to obtain independent legal or financial advice
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has been of his or her own choosing and not based on any representation or suggestion to
the contrary, and that each has read the stipulation and believes it to be fair, just and
equitable, and that each signs the stipulation freely and voluntarily.
IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the
day and year first above written.
Witness
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Witness
Plai ff, Jodi M. Morgan, Pr e
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'Defendant, Her ert R. Morgan, ro Se
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND )
On this _ day of , 200_, before me, a Notary Public, the
undersigned officer, personally appeared Jodi M. Morgan, known to me to be the person
whose name is subscribed to the written instrument, and acknowledges that she executed
the same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
Notary Public
COMMONWEALTH OF PENNSYLVANIA )
COUNTY OF BLAIR )
On this ~ day of ly,~ e ...,ht"f , 200-1-, before me, a Notary Public, the
undersigned officer, personally appeared Herbert R. Morgan, known to me to be the
person whose name is subscribed to the written instrument, and acknowledges that he
executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
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Notary Public
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
NO.
ol-~YIY
CIVIL TERM
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the following information to the court for entry of a divorce decree:
1. Ground for divorce:
Irretrievable breakdown under ~3301 (c)
-S~Q1 (el)(1) of the Divorce Code.
(Strike out inapplicable section).
2. Date and manner of service of the complaint: ~~
0ex-'h~ad tf!;~
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3. Complete either paragraph (a) or (b).
(a) Date of execution f th affidavit of consent required by ~3301 (c) 0 the ivorce Code:
by plaintiff ; by defendant
(b) (1) Date of execution of the affidavit required by 93301 (d)
of the Divorce Code:
(2) Date of filing and service of the plaintiff's affidavit upon the respondent:
4. Related claims pending: (\One,
5. Complete either (a) or (b).
~ Date and m~nner of,service of the notice of intention to file praecipe to transmit record, a
copy of which is attached: ----i' 'I ' ".. ., ". ,
(b) Date of plaintiff's Waiver of Notice in 93301 (c) Divorce was filed with
the Prothonotary: J ~ ~ ~ "b ~ 0 I
Date defendant's Waiver of Notice in 93301 (c) Divorce was filed with
JI'\-~q-ol
the Prothonotary: _ Q\ 0\ 0
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Jodi M. Morgan,
PLAINTIFF,
(IN THE COURT OF COMMON PLEAS OF
(
(CUMBERLAND COUNTY, PENNSYL VANIA
(
(CIVIL DIVISION
(
(No:;ffOI- Co 4/4 (!rv-!/
v.
Herbert R. Morgan,
DEFENDANT,
NOTICE TO DEFEND AND CLAIM RIGHTS
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 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.
WHEN THE GROUND FOR THE DIVORCE ARE INDIGNITIES OR
IRRETRIEVABLE BREAKDOWN OF THE MARRIAGE, YOU MAY REQUEST
MARRIAGE COUNSELING. A LIST OF MARRIAGE COUNSELORS IS AVAILABLE IN
THE OFFICE OF THE PROTHONOTARY AT 1 COURTHOUSE SQUARE, CARLISLE,
PENNSYLVANIA, 17013. THE TELEPHONE NUMBER IS (717) 240-6195.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYERS FEES, OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED,
YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE TIDS 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.
LAWYERS REFERRAL SERVICE
2 Liberty Ave.
Carlisle, PA 17013
(717) 249-3166
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Jodi . Morgan, Pro Se
195 Thorny Grove Lane
Shippensburg, P A 17257
(717) 530-0850
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Jodi M. Morgan,
PLAINTIFF,
(IN THE COURT OF COMMON PLEAS OF
(
(CUMBERLAND COUNTY, PENNSYLVANIA
(
(CIVIL DIVISION
~NO: 61-('p t.fl4 Cwq
v.
Herbert R Morgan,
DEFENDANT,
COMPLAINT IN DIVORCE
AND NOW COMES the Plaintiff, Jodi M. Morgan, by FILING PRO SE, who
files this Complaint in Divorce a statement of which is as follows:
I, The Plaintiff is Jodi M. Morgan, an adult individual currently residing at 195 Thorny
Grove Lane, Shippensburg, County of Cumberland, Pennsylvania, 17257,
2, The Defendant is Herbert R. Morgan, an adult individual currently residing at 1219
13th Ave" Altoona, County of Blair, Pennsylvania, 16601.
3. The Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for
a period of approximately fifteen (15) years.
4, The Plaintiff and Defendant were married on October 30, 1999 in Las Vegas, in the
State of Nevada.
5. There are no children born or adopted of this marriage and Plaintiff is not pregnant.
6. Neither party is a member of any branch of the military.
7. The marriage is irretrievably broken.
8. The Plaintiff, Jodi M. Morgan, respectfully requests this Honorable Court to grant
this divorce pursuant to Section 3301 (c), or in the alternative, Section 3301 (d) of the
Divorce Code,
Respectfully submitted:
Jodi , Morgan, Pro Se
195 Thorny Grove Lane
Shippensburg,P A 17257
(717) 530-0850
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I verify that the statements made in the Complaint are true and correct. I
understand that false statements made herein are subject to penalties of 18 Pa. C.S.A.
Section 4904, relating to unsworn falsification to authorities.
Date:r}rru. f ~ ~()O/ fJ(!)(;.
Jo M. Morgan, Pro Se
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Jodi M. Morgan,
PLAINTIFF,
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Herbert R. Morgan,
DEFENDANT,
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(IN THE COURT OF COMMON PLEAS OF
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(CUMBERLAND COUNTY, PENNSYLVANIA
(
(CIVIL DIVISION
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(NO: ()/-Gi-! llt-
AFFIDAVIT
COMMONWEALTH OF PENNSYL VANIA )
) ss:
COUNTY OF CUMBERLAND )
Before me, the subscriber, a Notary Public in and for said Commonwealth and
County, personally appeared Jodi M. Morgan, who being du1y sworn according to law,
deposes and says that the facts contained within the foregoing Complaint in Divorce are
true and correct to the best of her knowledge, information, and belief, and that she is
authorized to make this Affidavit.
Sworn to and subscribed before me thiJ:!2 Day of NovemW, ~CO / .
Notary Public
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Jodi M. Morgan,
PLAINTIFF,
(IN THE COURT OF COMMON PLEAS OF
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(CUMBERLAND COUNTY, PENNSYL VANIA
(
(CIVIL DIVISION
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(NO: (3 I-(Jf{ I Lf
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CERTIFICATE OF SERVICE
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Herbert R. Morgan,
DEFENDANT,
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PLAINTIFF, Jodi M. Morgan, of the Commonwealth of Pennsylvania, hereby
affirms the following statement under penalty of peIjury:
1. I am the plaintiff in this action, I hereby certif'y that on 11JV J3,a(JJ!, I
caused a copy of the attached:
Complaint in Divorce
to be served upon Defendant Herbert R. Morgan
1219 13th Ave.
Altoona, P A 16601
by depositing a true copy of the same enclosed in a post-paid addressed envelope, in a
depository under the exclusive care and custody of the U.S. Postal Service within the
Commonwealth of Pennsylvania.
Date:
. m01 .WIIL-
Jodi . Morgan, Plaintiff, Pro Se
195 Thorny Grove Lane
Shippensburg, P A 17257
(717) 530-0850
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Ite!", 4 if Restricled DeliverY is ~ complete
. Pnnt your name and dd eSlred.
so that we can return ~h ress don the reverse
. Attach this card to th e ca, to you. .
or on the front 'f e back of the mailpiece
. I space permits. '
1. Artic.'e AddreSse'd to:
3. ~jce Type
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Jodi M. Morgan,
PLAINTIFF,
v.
Herbert R. Morgan,
DEFENDANT,
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(IN THE COURT OF COMMON PLEAS OF
(
(CUMBERLAND COUNTY, PENNSYL VANIA
(
(CIVIL DIVISION
iNO: :Jt () J,(o y I~
ACCEPTANCE OF SERVICE
TO THE PROTHONOTARY:
I, Herbert R. Morgan, Defendant in the above-captioned matter, hereby
acknowledge receipt of the Complaint in Divorce and Notice to Defend and Claim Rights
in the matter of Jodi M. Morgan v. Herbert R. Morgan, Civil Division NO:~
and I hereby waive formalities of service and any objections to defects thereto.
DATE:jJ J2C l{ A DO (
J1J?fI-fJ-~
Herbert R. Morgan, Defendant
1219 13th Ave.
Altoona, PA 16601
(814) 943-4903
I, Herbert R. Morgan, certify that a copy of the foregoing Acceptance of Service
has been forwarded on this date by US Mail, postage prepaid, to the Plaintiff, Jodi M.
Morgan, at her address of record.
Date: ~ L(. :J..00(
U/~ Ykt ~
Herbert R. Morgan ~
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Jodi M. Morgan,
PLAINTIFF,
(IN THE COURT OF COMMON PLEAS OF
(
(CUMBERLAND COUNTY, PENNSYLVANIA
(
(CIVIL DIVISION
(
(NO:
v.
Herbert R. Morgan,
DEFENDANT,
AFFIDAVIT OF CONSENT
1. ~.c. plaint in Divorce under Section 3301(c) of the Divorce Code was filed on
~ 13 ,200L.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days
have elapsed from the date of filing and 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.
WAIVER OF NOTICE OF INTENTION TO REOUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301(c) OF THE DIVORCE CODE
I. 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 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.
Sectio~4 relating to unsworn falsification to authOljties.
Date: lJ.J!.f If f J(XJ (
I, Jodi M. Morgan, certify that a copy of the foregoing Affidavit of Consent was
forwarded by US Mail, postage prepaid, on this date, to the Defendant, Herbert R.
Morgan, at his address of record.
Date:~1(JM1 JOd9~n rYe ~
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Jodi M. Morgan,
(IN THE COURT OF COMMON PLEAS OF
(
(CUMBERLAND COUNTY, PENNSYLVANIA
(
(CIVIL DIVISION
(
(NO:
PLAINTIFF,
v.
Herbert R. Morgan,
DEFENDANT,
AFFIDAVIT OF CONSENT
1.
Mmplaintbn Divorce under Section 3301(c) of the Divorce Code was filed on
()Vem er I~ ,200L
2.
The marriage of Plaintiff and Defendant is irretrievably broken and ninety days
have elapsed from the date of filing and 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.
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 of Divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property,
lawyer's fees, or expenses in 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 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.
1)dtOli-~ ~
tDefendant, Herbert R. MO~
DatrtJ~, l{ / 2c:o /
I, Herbert R. Morgan, certify that a copy of the foregoing Affidavit of Consent
was forwarded by US Mail, postage prepaid, on this date, to the Plaintiff, Jodi M.
Morgan, at her address of record.
Date~"ec. t1 / :( au I
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\~erbe(\: e. Mor3dn
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
NO.
()1-(P41~
CIVIL TERM
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the following information to the court for entry of a divorce decree:
1. Ground for divorce:
Irretrievable breakdown under ~3301 (c)
3361 (d)( I j of the Divorce Code.
(Strike out inapplicable section).
2. Date and manner of service of the complaint: [1- 2B-OI US Posh'
~ ervi ~e (Jerl;f-;rLd Lef-/e-r.
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 2 - A to - 0 L.. ; by defendant \ 7_ - l../ - 0 (
(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: Y\b()e.
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: 2.. /26:, J 0 L US filA I L
. I
(b)
the Prothonotary:
Date of plaintiff's Waiver of Notice in 3301 (c) Divorce was filed with
'dol Od-.
Date defendant's Waiver of 1$1 (c) Divorce was filed with
the Prothonotary: /C).. ~ 0
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Jodi M. Morgan,
PLAINTIFF,
(IN THE COURT OF COMMON PLEAS OF
(
(CUMBERLAND COUNTY, PENNSYLVANIA
(
(CIVIL DIVISION
( -
(NO: C) I -(Q Lf (4
v.
Herbert R. Morgan,
DEFENDANT,
NOTICE OF INTENT TO FILE PRAECIPE TO TRANSMIT
To. Herbert R. Morgan:
You are hereby given notice that five days following the mailing of this notice, a
Praecipe to Transmit Record, together with a proposed Final Decree in Divorce, will be
filed in this matter with the Appointment Clerk's Office, I Courthouse Square, Carlisle,
PA, 17013. Exact copies of the Praecipe and the proposed Final Decree in Divorce are
enclosed herewitho
After the Praecipe and proposed Final Decree in Divorce are filed, you will have a
period of ten days during which you may file objections to the entry of the Final Decree
in Divorce based upon this Praecipe. If you dispute any of the information on the
Praecipe or Final Decree in Divorce, you must act within that ten-day period. Any
objections must be filed in writing with the Appointment Clerk's Office, 1 Courthouse
Square, Carlisle, P A, 17013. If no objections are filed before the expiration of the ten-
day period, this case will be submitted to the Court for entry of the Final Decree.
Date: f) ~Le)Ol Jodi~,P~~'~
195 Thorny Grove Lane
Shippensburg, PA 17257
(717) 530-0850
....-
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Jodi M. Morgan,
PLAINTIFF,
v.
Herbert R. Morgan,
DEFENDANT,
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-,'~,M;'ii~ifMliW' ,
(IN THE COURT OF COMMON PLEAS OF
(
(CUMBERLAND COUNTY, PENNSYLVANIA
(
(CIVIL DIVISION
(
(NO: 0 I - (Q L( ( Lf
DECREE OF DIVORCE
AND NOW, this day of " it is hereby
ORDERED, ADJUDGED, and DECREED, that Jodi M. Morgan and Herbert R. Morgan
are divorced from the bonds of matrimony, and that the parties' Marital Property
Settlement Agreement is approved and incorporated herein.
J.
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Jodi M. Morgan,
PLAINTIFF,
(IN THE COURT OF COMMON PLEAS OF
(
(CUMBERLAND COUNTY, PENNSYL VANIA
(
(CML DIVISION
~ NO: 0 \ - Co It I ~
v.
Herbert R. Morgan,
DEFENDANT,
ACKNOWLEDGMENT
a\ 1,_ .,~.~.~plaint in Divorce under Section 3301(c) of the Divorce Code was filed on
~ 2ooL. I agree that the marriage of the Plaintiff and Defendant is
irretrievably broken and ninety days have elapsed from the date of filing the Complaint.
All information contained within the attached documentation is true and correct to the
best of my knowledge, information, and belief.
It is my desire to file with the Cumberland County Court of Common Pleas the
attached Marital Property Settlement Agreement and to be bound Cully and completely by
the terms and conditions set forth within the said Marital Property Settlement Agreement
documentation.
IN WITNESS WHEREOF, I set my han.d and seal this 1 day of fYIcu.t--,
200.a...
!Ii:IA~tg(/~
efendlmt, H rt. Morgan, 0 Se
On this ~ day, of IY\ll~ ' 200.b before me, a Notary Public, the
undersigned officer, personally ppcared Herbert R. Morgan, known to me to be the
person whose name is subscribed to the written instrument, and acknowledged that he
executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
.J~ tv\ .~.c
Notary Public
NOTAlQAI. seAL
SONDRA Mo GESSER, No\BIY PublIc
AItoona. 8Illlr COUnty
fN CammI88lon EllpInra Sap!. 8. 2004
, I
'--"C"'O:~J
.~
~
Jodi M. Morgan,
PLAINTIFF,
(IN THE COURT OF COMMON PLEAS OF
(
(CUMBERLAND COUNTY, PENNSYL VANIA
(
(CIVIL DIVISION
~ NO: 0 I - Co 4/ Y
v.
Herbert R Morgan,
DEFENDANT,
MARITAL PROPERTY SETTLEMENT AGREEMENT
TmS AGREEMENT, made this ~ day of M~ ' 200~ between
PLAINTIFF, Jodi M Morgan (Wife), residing at 195 Thorny Grove Lane, Sbippensburg,
fA, 17257, and DEFENDANT, Herbert R. Morgan (Husband), residing at 1219 13th
Ave., Altoona, PA 16601.
WITNESSETH
1. The parties were married on October 30,1999;
2. The parties filed for 3301(c) Divorce on: ~.eMW)3, 200t;
3. The parties hereto desire to settle their property rights;
4. Both parties agree to relinquish any and all claims which either may have
against any property now owned or belonging to the other or which may hereinafter be
acquired by either of them by purchase, gift, devise, bequest, inheritance, or otherwise,
except as to the obligations, covenants, and agreements contained herein; and
5. Both parties have had an opportunity to seek the benefit of competent and
independent legal and financial advice by separate counsel.
THEREFORE, the parties, agree and stipulate at follows:
1. INCORPORATION OF RECITALS
The recitals set forth above are incorporated herein as if set forth in full.
2. SEVERABILITY
Each paragraph contained herein shall be determined to be a separate and
independent agreement. In the event that any portion of this agreement is deemed to be
illegal or unenforceable, said determination shall not affect the enforceability of any other
paragraph.
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3. APPUCABLE LAW
Agreement shall be construed under the laws of the Commonwealth of
Pennsylvania.
4. PROPERTY DMSION
A. Property to be awarded to Wire:
Except as is otherwise stated herein, Wife shall fetain any and all property in her
possession free and clear of any right, title or interest of Husband. This award shall
include, without limitation, Wife's personal clothing and effects, her furniture and
furnishings, the vehicle in her possession, her bank accounts, her retirement funds, and
such other property she may hold as of the date of this agreement.
B. Property to be awarded to Husband:
Except as is otherwise stated herein, Husband shall retain any and all property in
his possession free and clear of any right, title or interest of Wife. This award shall
include, without limitation, Husband's personal clothing and effects, his furniture and
furnishings, the vehicle in his possession, his bank accounts, his retirement funds, and
such other property he may hold as of the date of this agreement.
5. DISTRIBUTION OF DEBT.
The parties agree that they do not have any jointly owed debtso Each party shall
be solely fesponsible fOf any and all debts standing in his Of her name alone and shall
hold the other party harmless thereon.
6. REALESTATE
The parties have no jointly held real estate. Wife has real property located at 195
Thorny Grove Lane, Shippensburg, Cumberland County, Commonweahh of
Pennsylvania, which shall remain her sole property free and clear of any right, title or
interest of Husband.
7. ALIMONY, SPOUSAL SUPPORT, AND SEPARATE EXPENSES.
Each party hereto waives any present and future claims to alimony, tempofary
alimony, and spousal support
8. JOINT DEBTS
Husband and Wife each certify that there are no joint marital obligations.
9. DIVORCE
Husband and Wife agree that the marriage is irretrievably broken and will proceed
with said Divorce under 23 Pa. C.A. Section 3301(c).
10. LEGAL ADVICE
Husband and Wife declare that each has had the opportunity to obtain
independent legal advice by counsel of his Of hef own selection and to obtain financial
advice, and that any failure of eithef party to obtain independent legal or financial advice
ill
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has been ofhis or her own choosing and not based on any representation or suggestion to
the contrary, and that each has read the stipulation and believes it to be fair, just and
equitable, and that each signs the stipulation freely and voluntarily.
IN WIlNESS WHEREOF, the parties have hereunto set their hands and seals the
day and year first above written.
. >4/~-fJ,~
[:, 8~ ~.~ ,
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND )
On this _ day of , 200-, before me, a Notary Public, the
undersigned officer, personally appeared Jodi M. Morgan, known to me to be the person
whose name is subscribed to the written instrument, and acknowledges that she executed
the same for the purposes therein contained.
IN WIlNESS WHEREOF, I hereunto set my hand and official seal.
Notary Public
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF BLAIR )
On this ~ day of lY\D...'-\ , 200 ~ before me, a Notary Public, the
undersigned officer, personally appealed Herbert R. Morgan, known to me to be the
person whose name is subscribed to the written instrument, and acknowledges that he
executed the same fur the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and OffiC.UU se)
~Cfl"IdA Q- ~ 1\.11 0 r
NOTARIAL SEAL Notary Public
SONORA'" GESSER. NaIaIy PublIt
AlIoorla;81a1r ClllJnty .
My CcmmIliallln__1tapl. 6, 2004 .
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Jodi M. Morgan,
PLAINTIFF,
(IN THE COURT OF COMMON PLEAS OF
(
(CUMBERLAND COUNTY, PENNSYLVANIA
(
(CIVIL DIVISION
~NO:*O 1-'(14 (4
v.
Herbert R. Morgan,
DEFENDANT,
AFFIDAVIT OF CONSENT
1. ^.. <fmplaint in Divorce under Section 3301(c) of the Divorce Code was filed on
~vefY\ be-r 13 ,2001--
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days
have elapsed from the date of filing and Complaint.
3. I consent to the entry of a fmal decree of Divorce after service of notice of
intention to request entry of the decree.
,.,--'
WAIVER OF NOTICE OF INTENTION TOREOUEST
. ENTRY OF :A DIVORCE DECREE UNDER
SECTION 3301(c) OF THE DIVORCE CODE
I. 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 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: ~ / () Le / 01- PIge M!!1r~aal~
I, Jodi M. Morgan, certify that a copy of the foregoing Affidavit of Consent was
forwarded by US Mail, postage prepaid, on this date, to the Defendant, Herbert R.
Morgan, at his address of record. ,
Date: :; / ~ it j 02- Jog:!:::u rr}. rr;~~
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Jodi M. Morgan,
PLAINTIFF,
(IN THE COURT OF COMMON PLEAS OF
(
(CUMBERLAND COUNTY, PENNSYLVANIA
(
(CIVIL DIVISION
(
(NO: 0 I -" (p 41 Lf
v.
Herbert R. Morgan,
DEFENDANT,
MARITAL PROPERTY SETILEMENT AGREEMENT
THIS AGREEMENT, made this ill day of r:e~ ' 200b between
PLAINTIFF, Jodi M. Morgan (Wife), residing at 195 Thorny Grov Lane, Shippensburg,
PA, 17257, and DEFENDANT, Herbert R. Morgan (Husband), residing at 1219 13th
Ave., Altoona, PA 16601.
WITNESSETH
1. The parties were married on October 30, 1999;
2. The parties filed for 3301(c) Divorce on: _NoVeMber (3,200L
3. The parties hereto desire to settle their property rights;
4. Both parties agree to relinquish any and all claims which either may have
against any property now owned or belonging to the other or which may hereinafter be
acquired by either of them by purchase, gift, devise, bequest, inheritance, or otherwise,
except as to the obligations, covenants, and agreements contained herein; and
S. Both parties have bad an opportunity to seek the benefit of competent and
independent legal and financial advice by separate counsel.
THEREFORE, the parties, agree and stipulate at follows:
1. INCORPORATION OF RECITALS
The recitals set forth above are incorporated herein as if set forth in fulL
2. SEVERABILITY
Each paragraph contained herein shall be determined to be a separate and
independent agreement. In the event that any portion of this agreement is deemed to be
illegal or unenforceable, said determination shall not affect the enforceability of any other
paragraph.
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3. APPLICABLE LAW
Agreement shall be construed under the laws of the Commonwealth of
Pennsylvania.
4. PROPERTY DIVISION
A. Property to be awarded to Wife:
Except as is otherwise stated herein, Wife shall retain any and all property in her
possession free and clear of any right, title or interest of Husband. This award shall
include, without limitation, Wife's personal clothing and effects, her furniture and
furnishings, the vehicle in her possession, her bank accounts, her retirement funds, and
such other property she may hold as of the date of this agreement.
B. Property to be awarded to Husband:
Except as is otherwise stated herein, Husband shall retain any and all property in
his possession free and clear of any right, title or interest of Wifeo This award shall
include, without limitation, Husband's personal clothing and effects, his furniture and
furnishings, the vehicle in his possession, his bank accounts, his retirement funds, and
such other property he may hold as of the date of this agreement.
5. DISTRIBUTION OF DEBT.
The parties agree that they do not have any jointly owed debts. Each party shall
be solely responsible for any and all debts standing in his or her name alone and shall
hold the other party harmless thereon.
6. REAL ESTATE
The parties have no jointly held real estateo Wife has real property located at 195
Thoruy Grove Lane, Shippensburg, Cumberland County, Commonwealth of
Pennsylvania, which shall remain her sole property free and clear of any right, title or
interest of Husband.
7. ALIMONY, SPOUSAL SUPPORT, AND SEPARATE EXPENSES.
Each party hereto waives any present and future claims to alimony, temporary
alimony, and spousal support
8. JOINT DEBTS
Husband and Wife each certify that there are no joint marital obligations.
9. DIVORCE
Husband and Wife agree that the marriage is irretrievably broken and will proceed
~ with said Divorce under 23 Pa. C.A. SectiOD 3301(c).
10. LEGAL ADVICE
Husband and Wife declare that each has had the opportunity to obtain
independent legal advice by counsel of his or her own selection and to obtain financial
advice, and that any failure of either party to obtain independent legal or financial advice
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has been of his or her own choosing and not based on any representation or suggestion to
the contrary, and that each has read the stipulation and believes it to be fair, just and
equitable, and that each signs the stipulation freely and voluntarily.
IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the
day and year first above written.
(L~ t,~j~
Witness
/L,,\
odi M. Morgan, Pro Se
Defendant, Herbert R. Morgan, Pro Se
C ONWEALTH OF PENNSYL V ANlA)
COUNTY OF CUMBERLAND )
On this ~ 7 day of ~~ ' 200!S.> before me, a Notary Public, the
undersigned officer, personally ap Jodi M. Morgan, known to me to be the person
whose name is subscribed to the written instrument, and acknowledges that she executed
the same for the purposes therein containedo
IN WITNESS WHEREOF, I hereunto set my band and official s
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Notary Public
OTARIAL SEAL
AR AND, Notary Public
, berland County
My Commission Expires Aug. 11, :?-003
COMMONWEALTH OF PENNSYL V ANlA)
COUNTY OF BLAIR )
On this _ day of , 200 ~ before me, a Notary Public, the
undersigned officer, personally appeared Herbert R. Morgan, known to me to be the
person whose name is subscribed to the written instrument, and acknowledges that he
executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
Notary Public
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Jodi M. Morgan,
PLAINTIFF,
(IN THE COURT OF COMMON PLEAS OF
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(CUMBERLAND COUNTY, PENNSYLVANIA
(
(CIVIL DIVISION
~ NO: * 01-- & LJ I L)
v.
Herbert R. Morgan,
DEFENDANT,
ACKNOWLEDGMENT
N A com~aint in Divorce under Section 3301(c) of the Divorce Code was filed on
OVfJYJbPr 200-L. I agree that the marriage of the Plaintiff and Defendant is
irretrievably broken and ninety days have elapsed from the date of filing the Complaint.
All information contained within the attached documentation is true and correct to the
best of my knowledge, information, and belief.
It is my desire to file with the Cumberland County Court of Common Pleas the
attached Marital Property Settlement Agreement and to be bound fully and completely by
the terms and conditions set forth within the said Marital Property Settlement Agreement
documentation.
/) IN WITNESS WHEREOF, I set my hand and seal this 21- day of r~(\,(p.n/
2000'
f\~ fY} _ !Y} ff1 arJ/t.1.
PI~ Jodi M. Morgan, Pro S~- 0 -- ~
On this 01 '7 day, of lL/.. , 200d.., before me, a Notary Public, the
undersigned officer, personally appeared Jodi Mo Morgan, known to me to be the person
. whose name is subscribed to the written instrument, and acknowledged that she executed
the same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
(l~e,
Notary Public
NOTARIAL SEAL -I
CARETH E. MARSLAND. Notary Public I'
Borough of Carlisle. Cumberland County
My Commission Expires Aug. 11, 2003
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NOTICE TO FILE SOCIAL SECURITY NUMBERS
PURSUANT TO THE 23 P.S. SECTION 4304.1(aX3) PARTffiS TO A DIVORCE ARE
REQUIRED TO PROVIDE THEIR SOCIAL SECURITY NUMBERS TO THE
COURT. PLEASE SUBMIT THE SOCIAL SECURITY NUMBERS OF THE PARTIES
TO YOUR DIVORCE TO THE PROTHONOTARY.
PLEASE FILL IN THE APPROPRIATE INFORMATION AND RETURN TO THE
PROTHONOTARY OFFICE - THESE INFORMATION SHEETS WILL BE KEPT IN
A SEP ARA TE FILE.
DATE: J)cc'exY\b~Y- ?-~I ;f-ool
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DOCKET NUMBER: 0 I - ~ Y ( Lf
PLAlNTlFF/PETmONER SS#: 175-48-5634
NAME: Jodi M. Morl!an
DEFENDANTIRESPONDENT SS#: 200-54-0235
NAME: Herbert R. Morgan
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DIVORCE INFORMATION SHEET
PURSUANT TO ACT 2001-82, VITAL STATISTIC FORMS ARE NOT
REQUIRED BY THE STATE EFFECTIVE JANUARY 1, 2002. THE
PROTHONOTARY IS REQUESTING THIS INFORMATION IN LIEU OF
THE VITAL STATISTICS FORM.
PLEASE FILL IN THE APPROPRIATE INFORMATION AND RETURN
TO THE PROTHONOTARY'S OFFICE.
DOCKET NUMBER:
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DATE OF MARRIAGE:
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Jodi M. Morgan,
PLAINTIFF,
(IN THE COURT OF COMMON PLEAS OF
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(CUMBERLAND COUNTY, PENNSYLVANIA
(
(CIVIL DIVISION
~ NO: 0 f - (P L( i Y
v.
Herbert R. Morgan,
DEFENDANT,
ACKNOWLEDGMENT
,A I A complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
lVOV~be..r4?;,200L. I agree that the marriage of the Plaintiff and Defendant is
irretrievably broken and ninety days have elapsed from the date of filing the Complaint.
All information contained within the attached documentation is true and correct to the
best of my knowledge, information, and belief.
It is my desire to file with the Cumberland County Court of Common Pleas the
attached Marital Property Settlement Agreement and to be bound fully and completely by
the terms and conditions set forth within the said Marital Property Settlement Agreement
documentation.
IN WITNESS WHEREOF, I set my hand and seal this ~ day of Dee-,
200L ,
Pla9fOf::M!!2g~fJkf~
On this ~ day, of Dee... , 200_, before me, a Notary Public, the
undersigned officer, personally appeared Jodi M. Morgan, known to me to be the person
whose name is subscribed to the written instrument, and acknowledged that she executed
the same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
Notary Public
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Jodi M. Morgan,
PLAINTIFF,
(IN THE COURT OF COMMON PLEAS OF
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(
(CIVIL DIVISION
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(NO: 0 f-(o~ ) Lf
v.
Herbert R. Morgan,
DEFENDANT,
ACKNOWLEDGMENT
NI. ,...b-.~ cW .1 plaint in Divorce under Section 3301(c) of the Divorce Code was filed on
~, 200 L. I agree that the marriage of the Plaintiff and Defendant is
irretrievably broken and ninety days have elapsed from the date of filing the Complaint.
All information contained within the attached documentation is true and correct to the
best of my knowledge, information, and belief.
It is my desire to file with the Cumberland County Court of Common Pleas the
attached Marital Property Settlement Agreement and to be bound fully and completely by
the terms and conditions set forth within the said Marital Property Settlement Agreement
documentation.
IN WITNESS WHEREOF, I set my hand and seal this --.:L day of k,
200 I.
~~~2Sor~::rt
On this ~ day, of ~~",I:lef , 200~ before me, a Notary Public, the
undersigned officer, personally appeared Herbert R. Morgan, known to me to be the
person whose name is subscribed to the written instrument, and acknowledged that he
executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
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Notary Public
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f SONnRAM. GESSER, Nolnrl P.JllHG.
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JODI M. MORGAN,
Plaintiff
v.
HERBERT R. MORGAN, :
Defendant
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AND NOW, this 6th day of March, 2002, upon consideration of Plaintiffs pro se
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
CIVIL ACTION - LAW
NO. 01-6414 CIVIL TERM
ORDER OF COURT
Praecipe To Transmit Record, and it appearing that Defendant's affidavit of consent was
not executed "ninety days or more after both filing and service of the complaint,"! a
divorce decree will not be entered at this time, without prejudice to the parties' right to
correct the deficiency and file a new praecipe to transmit record.
~i M. Morgan
195 Thorny Grove Lane
Shippensburg, P A 17257
Plaintiff, Pro Se :;7
~R.MOrgan
1219 13th Avenue
Altoona, P A 1660 I
Defendant, Pro Se
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1 See Pa. R.C.P. 1920A2(b)(l).
BY THE COURT,
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