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HomeMy WebLinkAbout01-06803 "~ - . . . . ,~Pry<r !m, - - . . . . . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF . . . . STANLEY L. NYE VERSUS DEBRA L. NYE . . . . . . . . . PENNA. . . . . . . CiviL,Action - Divorce. . No. 01-6803 DECREE IN DIVORCE . AND NOW, VV1? VI '1 \ ,1.60 2 , IT IS ORDERED AND . DECREED THAT STANLEY L. NYE , PLAINTIFF, . . . . AND DEBRA L. NYE , 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; . . . . . . . . . . . ~. - ,- , ""~~"'l ' - By THE COURT: AT PROTHONOTARY . . . . . . . . . . ~,' - - ,. -"'"- , _ f" ~ .. " ~- . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J. . . . . . . . . . I', i~~~r;-~~~>;::.i~'i\lif..",-f}i;JOMgf"~"!i:\'&"'~<l1;"'!.'~'-~ ,~ .':""_c, '.. JLlll!l!l!1~11l - ",', .,~,.,., /.1 S'a; ,.5 ., .t?';; /:1 -,"--" - ~ "'"'''''' .- .', ~,...~'-"";~ llIilillIi. ' ~," c M-~~'h~ ~ ~~~Z;~. . I ~ ~ ,. .'~ 1_, ';'" STANLEY L. NYE, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLANDCOUNT~ PENNSYL VANIA : v. 01-6803 Civil Term DEBRA L. NYE, Defendant CIVIL ACTION - DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the court for entry of a divorce decree: L Ground for divorce: irretrievable breakdown under g330l(c) ofthe Divorce Code. 2. Date and manner of service of the complaint: Certified Mail, Return Receipt. December 3, 2001 (see Attached). 3. Date of execution of the affidavit of consent required by g330l(c) ofthe Divorce Code: by Plaintiff: April 25, 2002; by Defendant: April 22, 2002. 4. There are no related claims pending. 5, Date of execution ofthe waiver of notice required by g330l( c) of the Divorce Code: by; Plaintiff: April 25, 2002; by Defendant: April 22, 2002. 4'd6.Dd Robert S. Mirin. Esquire, Attorney for Plaintiff ""'1Wl)~ _ -,'" _~" ': ,,'7_'.' "_ -"'"""~ -":'," '"('.,-",,.- "'I" -",-- "':~ ," " ~~~-~ "" ~,,!,:.!t;. '."" ') ~ "> i'~~'-' ":'~"*:'" o..1"-<"'2c:"".., ""1"">'_"1''J',.:f.:~~"l)~L C." ,~ "_," - -',' , '.ff'''.'~,''''',,"' - -.. "'~. ,~ o s~ ;~t.~:' :z( l.i~ _' ::$ ...~- ~~;." J> ''/ ~.:...:: ;::;1 .. '-'liiflU'OOII'1'l"''''f C.:: f"- -~ :':C',t ~;; ',-; h) ~.~, '"";""!<"'\.lV" "' I. "~' ' ~, - )~~~;5'.Jff:w:"~,;,,,~~"'~,j";;~1"#O~'T'~:;W~,,~TftW:'ii'~F'",~p,ii'.i.;i~f!.!jlj~~~l~~~h~:; ,-~,,'~-' ' -, .\ 01- (..ft::8 C!eo ~ L ~AGESETTLEMENTAGREEMENT THIS AGREEMENT. made this ;)'d.,) day of ~ 2002, by and between, Stanley L. Nye of Gardners, Cwnberland County, Pennsylvania, hereinafter referred to as "Husband," and Debra L. Nye of Gardners, Cwnberland County, Pennsylvania, hereinafter referred to as "Wife." WIT N E SSE T H: WHEREAS. Husband and Wife were lawfully married on May 7, 1999, and WHEREAS, differences have arisen between Husband and Wife in consequence of which they intend to live separate and apart of each other; and WHEREAS, Husband and Wife have made a full disclosure of their assets to each other; and WHEREAS, Husband and Wife desire to settle and determine their rights and obligations with respect to each other, including the disposition and distribution of property rights and interests between them. NOW, THEREFORE, in consideration of the mutual promises, covenants and undertakings hereinafter set forth and for other good and valuable consideration. receipt of which is hereby acknowledged by each of the Parties hereto, Wife and Husband, each intending to be legally bound hereby, covenant and agree as follows: -';~r-: ~.",'_ ...", ,~ . 'r', ~,. 1. ADVICE OF COUNSEL. The provisions of this Agreement and their legal effect have been fully explained to the Parties by their respective counsel, Robert S. Mirin, Esquire, for Husband, and Ruby D. Weeks, Esquire, for Wife. The Parties acknowledge that they have received independent legal advice from counsel oftheir selection and that they fully understand the facts and have been informed as to their legal rights and obligations and they acknowledge and accept that this Agreement is. in the circumstance fair and equitable and that it is being entered into freely and voluntarily, after having received such advice and with such knowledge and that execution of this Agreement is not the result of any duress or undue influence and that it is not the result of any collusion or improper or illegal agreement or agreements, 2. SEPARATION, It shall be lawful for each Party at all times hereafter to continue to live separate and apart from the other Party. The foregoing provisions shall not be taken as an admission on the part of either Party of the lawfulness or unlawfulness ofthe causes leading to their living apart. 3, AGREEMENT TO BE INCORPORATED IN DIVORCE DECREE. The Parties agree that the terms of this Agreement shall be incorporated into any Divorce Decree that may be entered with respect to them at the request of either Party. The Parties agree that the Court of Common Pleas of Cumberland County, Pennsylvania. shall retain continuing jurisdiction over the Parties and this Agreement for the purposes of enforcement of any of the provisions thereof. "t'~',~1-c1.~",,_, . , , ,'- - ~ " '.' 'I' --" -, ~~ - .,0 ',' it. ~,,~..~" ~ ,~~-.' .~ The Parties agree that unless otherwise specifically provided herein, if a Decree is entered divorcing the Parties, although this Agreement shall be incorporated into said Decree. this Agreement shall not merge with, but shall continue in full force and effect after such time as a Final Decree in Divorce may be entered with respect to the Parties and may be enforced in an action independent of the Divorce Decree. The Parties agree and it is the intent of each of them that even though this Agreement may be enforced either under the provisions of the Pennsylvania Divorce Code or in an action independent ofthe Divorce Decree in accordance with Section 3502 of the Pennsylvania Divorce Code, the provisions of this Agreement regarding the disposition of existing property rights and interests between the Parties, alimony, alimony pendente lite, cOUhsel fees and expenses shall not be subject to modification by any Court, 4. SUBSEQUENT DIVORCE. The Parties hereby acknowledge and express their agreement that the marriage is irretrievably broken, and the Parties agree to cooperate in any necessary way to obtain a mutual consent. no-fault divorce. pursuant to Section 3301(c) of the Pennsylvania Divorce Code. 5. INTERFERENCE. Each Party shall be free from interference, authority, and contact by the other, as fully as ifhe or she were single and unmarried, except as may be necessary to carry out the provisions of this Agreement. Neither Party shall molest the other or attempt to molest the other, nor compel the other to cohabit with the other. or in '""FA'''<?W~~,~ _.,.> _ ';_''':1', . ""--1- - , , . ~ ~"""-,,,.>.,_,,,,"~ 0' "_""'" "'''_~~''d' ,~,,' ,_, .-.~~ any way harass or malign the other. nor in any way interfere with the peaceful existence, separate and apart from the other. 6. WIFE'S DEBTS. Wife represents and warrants to Husband that she will not contract or incur any debt or liability for which Husband or his estate might be responsible and she shall indemnify and save harmless Husband from any and all claims or demands made against him by reason of debts or obligations incurred by her. 7. HUSBAND'S DEBTS. Husband represents and warrants to Wife that he will not contract or incur any debts or liability for which Wife or her estate might be responsible, and he shall indemnify and save hannless Wife from any and all claims or demands made against her by reason of debts or obligations incurred by him. 8. MUTUAL RELEASE. Subject to the provisions of this Agreement, each Party has released and discharged, and by this Agreement. does for himself or herself, and his or her heirs, legal representatives, executors, administrators and assigns, release and discharge the other of and from all causes of action. claims. rights, or demands, whatsoever in law or equity, which either ofthe Parties had or now has against the other, except for any and all causes of action for divorce and except for any and all causes of action for breach of any provisions of this Agreement 9. DISCLOSURE OF PROPERTY. Husband and Wife acknowledge and agree that they have made a full and complete disclosure to the other of all information "g'imJl"fi,~, - - '~I Tl ." ,----..._~".., ,~<~"',- " ~ ,~ - .,- ~ ~ ~u. ' pertaining to the Parties' separate and marital property owned. possessed and/or controlled by the other at the time of the separation of the Parties and. further, that the Husband and Wife voluntarily and intelligently agree to waive any rights which they may have to receive an Inventory and Appraisement of all property owned or possessed by them, either jointly or individually, at the time of the delivery of this Agreement or of the commencement of any action of divorce. 10. EQUITABLE DISTRIBUTION. Husband and Wife acknowledge and agree that the provisions of this Agreement with respect to the distribution and division of marital and separate property are fair, equitable and satisfactory to them based on the length of their marriage and other relevant factors that have been taken into consideration by the Parties. a. REAL PROPERTY. The Parties agree that the marital residence, shall be sold. Husband shall retain 60% of the net proceeds. Wife shall retain 40% of the net proceeds from the sale of the marital residence. Husband shall assume sole financial responsibility for the costs associated with this property, including but not limited to mortgages, taxes, insurance, utilities, repairs and improvements. Husband shall indemnify Wife and hold her harmless for any claim made against her relative to the marital residence. , """ll"'~""""\,~ , "', "''''''' . -''''1''',- , .--,-' ,,".,,~ ':" " ,~ ~ "~.' , .. ~,-- ., b. PERSONAL PROPERTY. The following properties shall become the sole and exclusive properties of Husband: 1. Refrigerator 2. Freezer 3. Gas Grill 4. Garden Tractor 5. Snow Blower Any of these properties in the possession of Wife shall be transferred to Husband by Wife contemporaneously with the granting of the divorce decree. The following properties shall become the sole and exclusive properties of Wife: 1. Washer 2. Dryer 3. Stove 4. Push Mover Any of these properties in the possession of Husband shall be transferred to Wife by Husband contemporaneously with the granting of the divorce decree. Neither Party shall make any claim to any other item of tangible personal property whether said items are marital property or said items are separate personal property of either Party. '-,-q'l&"'~~'S~",_, ,_ _ ,_ .' - ,~" ,~.~. ",r, 'I' ' ,"~-r' c, EMPLOYMENT-RELATED BENEFITS. Wife hereby relinquishes any claim to Husband's retirement. 401K plan or any other retirement plans that Husband may have. Husband hereby relinquishes any claim to Wife's retirement plans, SEPS, Roth IRA or any other retirement plans that Wife may have. d. LIFE INSURANCE POLICIES. Wife hereby relinquishes any claim to Husband's life insurance policies. Husband hereby relinquishes any claim to Wife's life insurance policies e. HEALTH INSURANCE. Both parties agree to acquire health insurance through their respective employers. f. 2001 and 2002 INCOME TAX RETURNS. Both parties have agreed to cooperate with the filing of Fiscal Year 2001 and Fiscal Year 2002 Income Tax Returns in order to minimize liability or maximize monies returned from the Internal Revenue Service. Any tax savings will be split 50/50 between the parties. g. ABF FREIGHTLINES. Wife hereby relinquishes any and all rights to any settlement or award of damages in connection with Husband's lawsuit involving ABF Freightlines. ,"'$."""~", , "";._0::> '___,'"",",,", '"'.' - "~-"1 ,~ ,~ -","--' ""~-.; I:"" ' , '! ~ < ,- -. f"~" --,~~"~ ~,~ M__, 0" -~- h. CAPITAL GAINS AND EXPENSES FROM THE SALE OF ASSETS. Any capital gains from the sale of marital residence under this agreement shall be shared 60% by Husband and 40% by Wife. Any capital gains from the sale of any other property shall be borne solely by the selling party. i. MOTOR VEHICLES. With respect to the vehicles owned by the Parties, Husband shall keep the vehicle in his possession, Wife shall keep the vehicle in her possession.. Both parties shall be responsible to pay their own auto insurance. 11. SPOUSAL SUPPORT, ALIMONY, ALIMONY PENDENTE LITE, COUNSEL FEES AND EXPENSES, Wife hereby agrees not to file for spousal support and will withdraw her pending petition. Each Party shall be responsible for its own counsel fees. 12. WAIVER OF CLAIMS AGAINST ESTATE. Except as herein otherwise provided, each Party may dispose of his or her property in any way. and each Party hereby waives and relinquishes any and all rights he or she may now or hereafter acquire, under the present or future laws of any jurisdiction, to share in the property or the estate of the other as a result of the marital relationship, including, without limitation, dower, courtesy, statutory allowance, widows allowance, right to take property under equitable distribution, right to take in intestacy. right to take against the will of the other's estate, and who will, at the request ofthe other, execute, acknowledge and deliver any and all ""h~'~~1T~I, ," .'"-, '1' "..," , . ,- ~ 1 H ,'-" :.:<; '11"1 r Jlij n-_ - rlrr I'-'~ ~-~ --"-' .-. . instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interests, rights and claims. 13. BREACH. If either Party breaches any provision of this Agreement, the other Party shall have the right, at his or her election. to sue for damages for such breach or seek such other remedies or relief as may be advisable to him or her, and the Party breaching this Contract shall be responsible for payment oflegal fees and costs incurred by the other in enforcing their rights under this Agreement. 14. ENTIRE AGREEMENT. This Agreement contains the entire understanding of the Parties and there are no representations, warranties, covenants or undertakings other than those expressly set forth herein. 15. MODIFICATION AND WAIVER. The modification or waiver of any of the provisions of this Agreement shall be effective only if made in writing and executed with the same formality as this Agreement. The failure of either Party to insist upon strict performance of any of the provisions of this Agreement shall not be construed as a waiver of any subsequent default of the same or similar nature. 16. DESCRIPTIVE HEADINGS. The descriptive headings used herein are for convenience only. They shall have no effect whatsoever in determining the rights or obligations of the Parties. "M'p~'\, ,__$,~__ , "';' ~~~"' ". "_ 1':-, ~- "_.. >. ~, , -,". 17, INDEPENDENT SEPARATE COVENANT. It is specifically understood and agreed by and between the Parties hereto that each paragraph hereof shall be deemed to be a separate and independent covenant and agreement. 18. APPLICABLE LAW. This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania. 19. VOLUNTARY EXECUTION. Husband and Wife acknowledge and represent that the provisions of this Agreement are fully understood by both Parties and each Party acknowledges that this Agreement is in all respects fair and equitable, that it is being entered into voluntarily and knowingly, and that it is not the result of any duress, undue influence, collusion or improper or illegal agreement or agreements. IN WITNESS WHEREOF. the Parties have hereunto set their hands and seals the , .. ~ 1- Phr- " tanley lJ. Nye O~1r4c, Debra L. Nye --- RUb~ ~,,~ ,~--'" - ")l~ ~ -~, " 0 ,,,,",'" ,~" 0-"" '. ,,-,'-.'-" "'~,' ~-., ~-"-, 'H''''',_'' -"~-1" ,,- 0 ' ---~! ,-, r " 'T; '-- ;;",," >[) ;"':'--: 1'-1 '1'1 " .;., ) (/; " t.::1 -<: -- --- , " -'nlIJ]I-'r~Y ,'Ii'" [;5 BI! i~ r_tlilrrer~I,1:l: rro_1tJ! J. _j_,,_=~_ ',,',o',,)-r~~ '?"')Ji'jJjr~~:",-;.~,~i"~W~'\1l\;\'i'!M\ii1!)~,~jtT~9r'M11t~';f,'t)'n":<i<:i&"';'W';~-q~,'<E","" ''-''';"c ;B(~~!@~~}lS-5LW:J*~','1''''''''i#'?~fj",!l'',~:'9~,!l~H!~,~ <' ., ...~ ,~ . STANLEY L. NYE, :IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, :PENNSYL VANIA Plaintiff v. DEBRA L. NYE, : CIVIL ACTION - DIVORCE D\ - ~f03 C;u~lJ-~ Defendant NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages. you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and judgement may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim of relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Court Administrator 1 Courthouse Square Carlisle, P A 17013 717-240-6200 - t:J ORIGINAL ,\",,,,~_,,,,,';;E;I~ . ..~, ." , " ' ~. -, ~.r"" . , ~ ,~ ~~ - .~, ;'-T--tr:-.cn~~- - ~---, ~r. STANLEY L. NYE, :IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, :PENNSYL VANIA Plaintiff v. DEBRA L. NYE, : CIVIL ACTION - DlVO~CIt ; 01- t.,.poJ C,~LT~ Defendant NOTICE Le han demando a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene vienta (20) dias de plazo al partir de al fecha de la demanda y la notificacion. Usted debe presebntar uuuna apariencia escrita 0 en persona a por abobgado y archivar en la corte en forma escrita sus defensas 0 sus objectiones alas demandas en contra de su persona. Dea avisado que si usted no se defiended. la corte tomara medidas y puede una orden contra usted sin previo aviso 0 notificacion y por cualquier queja 0 aquvui que es pedido en la peticion de demanda. Usted puedo parder dinero 0 sus propiedades 0 otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDlATAMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE EL DlNERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAMA POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABOJO PARA AVERIGUAR DONDE SE PUEDE CONSIGUIA ASISTENCIA LEGAL. Cumberland County Court Administrator 1 Courthouse Square Carlisle, P A 17013 717-240-6200 """C'''0~:<J:~ 11I1 ,~ 1- " . ~, , ,-- :o.:.,~_f STANLEY L. NYE :IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, :PENNSYL V ANIA Plaintiff v. Defendant : CIVIL ACTION - DIVORCE DI- {.",iO.3 Qv~l y~ DEBRA L. NYE, AND NOW comes Plaintiff, Stanley L. Nye, by and through counsel, Robert S. Mirin, Esquire, herewith files this action seeking divorce and in support of that Complaint avers as follows: PARTIES 1. This marriage was celebrated by District Justice Helen B. Schullenberg on May 7, 1998 in Cumberland County, Newville, Pennsylvania. 1. The marriage is the second for Stanley L. Nye and the third for Debra L. Nye. 2. Neither party is a member ofthe Armed Forces of the United States. 3. The parties have resided at 742 Torway Road, Gardners. P A 17324. Currently both parties are still residing in the house. 4. There are no children from this marriage, however, Plaintiff Stanley L. Nye has a support obligation for a daughter, Amy Elizabeth Nye, age 16, date of birth 7/31/85. -"l'-'"~ :'. '"' , -, ~_.. 5. The marriage is irretrievably broken. 6. Both parties have 401K retirement plans. COUNT I WHEREFORE, Plaintiff, Stanley L. Nye respectfully requests that the Court issue a decree of divorce, dissolving said marriage, and the bonds of matrimony. Robert S. Mirin, Esq. AHMAD & MIRlN 8150 Derry Street Harrisburg, P A 17111 (717) 909-4343 -"'!-'''1;!<'~'",*~..~ "._ , ~ "' I - ~ " "~ , .?T.'I"l!!!; ~__, ~_c ~", "i"""_W""'-~.",~_Iii_"?"",, ~_~._ VERIFICATION Subject to the penalties of 18 Pa.C.SA 34904 relating to unsworn falsification to authorities, I hereby certify that that the facts set forth in the foregoing complaint are true and correct to the best of my information and belief. Dated: /6 I 3 J I a ) J ~" '-I ~-i~ - Stanley L. Nye -' I ~... . ~~ - ;;~;'~w:-"f - <-r' h_"" ',,~ CERTIFICATE OF SERVICE I, Monica Bender, hereby certify that a copy of the foregoing Complaint has been hand delivered to the following: Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 Debra Nye 740 Torway Road Gardners, P A 17324 Dated: //!:J1k . O?f~x:~ Monica R. Bender, Legal Assistant 8150 Derry Street, Suite A Harrisburg, P A 17111 (717) 909-4343 "'0"'~_ - ~ :--1' " < --; ~, "" I' .. 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Service Type ~ertified Mail 0 Express Mail o Registered 0 Return Receipt for Merchandise o Insured Mail 0 C.O.D. 4. Restricted Delivery? (Extra Fee) 0 Yes , 2. Article NU":1ber, (Copy from s~e~ice labeO _ , . _ . /1 '~.;f'~",'.~'isr.~.'tj{i,!" rfJ,~~~: . ' . ", .Il'fWj, J., 199 . i.' . .1IIM.rn 1'l."lpt :t '~: " i_/ ms95.ae.M'6llSl! . , ':1 .' t. - ii;: o c <" "'oi::; ~g:; ~ ~~~~-, ~c... ~~~ :.~ " -, " ~ -7~,~r : ; 1: :' ' :i' 'il; i :i/;:: ;' .'~ o r", ""- "0 ;::0 W o ;r~7" :,,;) (,., ~ ~~ ~,- STANLEY L. NYE , Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. 01-6803 Civil Term DEBRA L. NYE, Defendant CIVIL ACTION - DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under ~330l(c) of the Divorce Code was filed on November 29, 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 divorce after service of notice of intention to request entry ofthe 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 19 Pa.C.S. ~4904 relating to unsworn falsification to authorities. Date: ~. d? . 00. ~: 10y --'C"Nh"""-~iili,J ,_"., -H"'- , ~,' .-. "-,~I_( ~ " - ,~-~ ~, . , ~'Y1,~ " ~~""_ !i!iJIIJf,i",,,c'- I!i'Jt!ilfMl,< .,< "-'-" ",,"-', _oj; t,~,,,,~_,,., ~, -.;:;[-,=, rnr--;--; z:::-:; 2~C ~~: :;::,: ~~E e $i-f .. o C' ..- ~ ~ 111111 " c; 1''0 1~) .::.rl ::.') t-:; '..---.) (}'"\ l!i"lle~!l'lliWl'jf"l~~~il!l\tll:lil!a,~~J~1i:-IWI,q,;?;'-'i!'!0'""''';--~(-"'\9_+-"-!';'7CY-'",, ,:of-;";::=:';-""'F~,'-"iFi"'''-i_'h0t''''_''fk'i'''l''''i.~_lf''~--'o",,,,'f;"1<~,ff-'Wliif-M~~~!f)1~? STANLEY L. NYE , Plaintiff IN THE COURT OF COMMON PLEAS CbMBERLAND COUNTY, PENNSYL VANIA v. 01-6803 Civil Term DEBRA L. NYE, Defendant CIVIL ACTION - DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER !i3301(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 ifI do not claim them before a divorce decree 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 19 Pa.C.S. 94904 relating to unsworn falsification to authorities. Date: <'(.61?'C6- btif~ ~'j';""_,i'\;W:f~r;P"l ',_ ,",_" ' __, ~ _, ~ -" I - ~ -,~ , '-"'''',,,,,.j, ~,' "",,"""'d~"""'''- ,~' ---"~ ',~ ~1p!lil_:llr_:::'",~o~~~l_~J1i.nF: ~r ijJJl~~'l':~!'ll~~M:jl,'""j';if'(\';"%"b"i1oi"V' .. -, 0 f''''':; S ""'Ol.:'2 ~~t'~- ::,,,,) 3 - c' . - -- c, ,- ~ :i,) :.i;:: 0, .....< FS /3)} 1I1L111'~lrrll "" , Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STANLEY L. NYE, VB. CIVIL ACTION - LAW IN DIVORCE DEBRA L. NYE, Defendant #01-6803 CIVIL TERM AFFIDAVIT OF CONSENT 1. A complaint in Divorce under Section 330l(c) of the Divorce Code was filed on Novemeber 29, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. I verify that the statements made in this Affidavit are true and correct. I underst~nd that false statements herein are made subject to the penalties of 18 Pa. C.S. ~4904 relating to unsworn falsi Dated: J-j-:J:J .();!;l ion to authorities. Sworn and subscribe~to befor~this ~ day. of J..P , 20 V:;2 . - NOTAlllAl SEAL CAllOI. A.. MORRow, N'*"r f'ub!lc My~=:: ~= Counly --'''.,......,,',.,''~_~. :l8, 2003 ~~ fJfi/7J 1/ ~~&tJ Notary Public "~~.", "-, " -~ '---I" oOu, ?'.-' ~ ", ",,', . o l.:: <" d"i~~; ~t-; S2~~' !~;;::> ~g :..~ -.< c:.: :_v tj'J :'0 .-< F.s: B4 .... __ u~'_"',~~~"''''."!i-,',_' /;-->, Jc~, ie'') _"-'~~;-_~_ ',,> ,,_,~J~H~"'W\~'\l~'<W~iW~'%l'~'B'mifi;?~iJ;~'i;WN!.'t'~1'~:if;j'@H~~W~~~~--: __!,,~-~-qJ~: ~; . . Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STANLEY L. NYE, VB. CIVIL ACTION - LAW IN DIVORCE DEBRA L. NYE, Defendant #01-6803 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER S 3301 (0) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. S 4904 relating to unswor ification to authorities. 1- (1) /()?- JJ<M Date: RA L. NYE, D ,,~'WI""'iff:"""'_~ _" ',--' -.'" T -- F'C"'- ~, ': ,,-'. ~-=~ -- ,,_,e ,"" ~,.~L ,It!!!ll__..""e'.......,'~d..,.....' ".-- p 1.,., '-.-",~,,-"'~~-'-'~;-'>" , . n '2 vt~-: rnh:" -.,..-;c, ~~j~~- -<. c: ~:2 ..<- =2 . Ii r' ~-~ i"'...; ~ t::~ ,~, ;:'",] c::/ :..-'-) er, B's fY/ ,rm~:~~,.:,;! ~~;";';T,~W';;<Y0""-':",t1!ffl~;~.J,~~~_"A _~11~Ufr~.JJJiJ!J \-_,~l~mJ_~~~~ ,,,-,,,,~~,Jf, , _ , , ,",:" _ ,----" -J "'-"', ",_,;',,"c,l,-,,-, . . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA STANLEY L. NYE Plaintiff CIVIL ACTION - DIVORCE NO. 01-6803 Civil Term v. DEBRA L. NYE Defendant ENTRY OF APPEARANCE I, Robert S. Mirin, enter my appearance as counsel for the Plaintiff in the above captioned matter. , - Robert S. Mirin, sq. 8150 Derry Street Suite A Harrisburg, P A 17111 (717) 909-4343 I;), ORIGINAL ',"""_f*~H_.i:.!"i~~ , ~~'""'1""'I' ," - --", ~~ - - , 14" .. CERTIFICATE OF SERVICE I, Monica Bender, hereby certify that a copy ofthe foregoing Entry of Appearance was served via first class mail to the following: Ruby Weeks, Esquire 10 West High Street Carlisle, PA 17103 ~A,' yG_~ Monica R. Bender, Paralegal AHMAD & MIRlN 8150 Derry Street, Suite A Harrisburg, P A 17111 (717) 909-4343 DATED: / h/;;:A ""-';"'),*~,\;1ll>W0"~ ~""~, "" ~ ''"I ~.~ - ~'".- ~"'~ ~ "~- <~, ,~"'~ ^~., ,," ~~" '1'- ~.,.>-- ~ ~-~~ ,-".. '" " 1" ,. , 0 0 C'; C N -'{- , '.:';.:~ '- " C' CO:=: ;:..'" m~r, d~ "71...;--, Zf-- ~r.~ --.,,0 GC-- '" :-- ~t~~ -"-'" L~} )>c': ~'j oS ::0 --< 0 -< Es B1 ~.- _ "H_.r.nJ;U",~,,..,,w~ ~""^ffR'41r~~~-,:-4.,,,,,,,J~Jf1:~~i!!W"'~_"',,,,''i;!'''~J.~j!-'''''''Sf'c~:'"!--;>'-'iF:':'''''f~<t:;-'J~~~;:{~A~~~~~~~J!\l:;~~)f- Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STANLEY L. NYE, vs. CIVIL ACTION - LAW IN DIVORCE DEBRA 1. NYE, Defendant #01-6803 CIVIL TERM NOTICE OF ELECTION TO RETAKE MAIDEN NAME Notice is hereby given that the Defendant in the above matter, hereby elects to retake and hereafter use her De ra L. ~ ~L. COMMONWEALTH OF PENNSYLVANIA ss COUNTY OF CUMBERLAND On the 17th day of April, 2002, before me a Notary Public, personally appeared Debra Nye to be Debra Rhoads known to me to be the person whose name is subscribed to the within document and acknowledged that she executed the foregoing for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. ~ A. NOrAll1At SEAL .~..C"rl""!.q",,,~, ~ 'c..,",',. ~nd~ "'~" -"_'~:"~__':::~?~'~:~~:,,~8{,~~ ~~~ 2003 -'-"""", (j~ 1/, If OJVlohZ) Notary Public '~:' "",~ -::_~",y,~ c.-; . >";!'1"'", ,"y', "_-_"c " ^" , ~ ",' =~: , !~"- "_ _ .,~,c ~~P'J-'. ,."-_O{!, _~___~ ~-,_~,,__:>.'_,..,-,~, ~"~- ~ ....... ).j \1', --c: -f::: -1...\ 0> ~ ,>-) ----, (;"' a ~',.c,' """","'~O^ ~~ ,_"<. ~ ~ ~ ~ ~ U; o Q \"-" ~;, --0"'" r-n\\\ 'Z-:r: f') ~~'.. p ;:% ~ - ..:;... ";t::i: -'- cs 61~ 'R .? 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