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HomeMy WebLinkAbout03-2763 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SAUNDRA 1. KOONTZ, Defendant CIVIL ACTION - LAW . LL.,. NO. 03 - ~7W CtCJ~ /~ IN DIVORCE v. WILLIAM K. KOONTZ, Jr., NOTICE TO DEFEND AND CLAIM RIGHTS TO: William K. Koontz, Jr. P.O. Box 643 Carlisle, P A 17013 YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a Decree 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 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 at the Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, Pennsylvania 17013-3387 PHONE: (717) 249-3166 281289-1 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SAUNDRA L KOONTZ, Defendant CIVIL ACTION - LA W/J. . ('-- NO. 03-27(.3 \':'01,. I~ IN DIVORCE v. WILLIAM K. KOONTZ, Jr., COMPLAINT IN DIVORCE 1. The Plaintiff, Saundra L Koontz, is an adult individual currently residing at 492 Furnace Hollow Road, Shippensburg, Cumberland County, Pennsylvania, 17257. 2. The Defendant, William K. Koontz, Jr., is an adult individual currently residing at P.O. Box 643, Carlisle, Cumberland County, Pennsylvania 17013. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on May 23, 1998, in Franklin County, Pennsylvania. 5. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provision of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 6. Plaintiff's Social Security Number is 163-44-0004 and Defendant's Social Security Number is 202-38-9537. 7. There have been no prior actions of divorce or for annulment between the parties. 8. 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, 9. There were no children born of this marriage. 281289-1 COUNT I DIVORCE 10. The averments of Paragraph 1 through 9 hereof are incorporated herein by reference, 11. The marriage is irretrievably broken. 12. The parties have been living separate and apart since May 6, 2003. 13. Defendant has offered such indignities to Plaintiff, the innocent and injured spouse, has rendered Plaintiffs condition intolerable and life burdensome. 14. Plaintiff requests the Court to enter a decree of divorce, divorcing Plaintiff and Defendant. COUNT II EOUlTABLE DISTRIBUTION 15. The averments of Paragraph 1 through 14 hereof are incorporated herein by reference. 16. During the marriage the parties acquired marital property, assets and debts which Plaintiff requests the court equitably distribute and assign, COUNT III SUPPORT, ALIMONY and ALIMONY PENDENTE LITE 17 . Averments of Paragraphs 1 through 16 hereof are incorporated herein by reference. 18. Plaintiff requires reasonable support and or alimony pendente lite to adequately sustain herself within the standard ofliving established during the marriage and to properly and adequately maintain the within action for divorce. 281289-1 WHEREFORE, Plaintiff requests that this Court enter a decree in divorce, enter an order equitably distributing marital property, award Plaintiff support, alimony and alimony pendente lite, and enter any such other Orders as are appropriate and just. METZGER, WICKERSHAM, KNAUSS & ERB, P.c. By CJ. -- Andrew C, Spears, Esquire Attorney LD. No. 87737 P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for Plaintiff Dated: \~-q-()~ 281289-1 VERIFICATION I, Saundra L. Koontz, hereby certify that the facts set forth in the foregoing Complaint in Divorce are true and correct to the best of my knowledge, information and belief, and that false statements herein are made subject to the penalties of 18 Pa. C.S.A. S4904 relating to unsworn falsification to authorities. ~1~ aundra L. Koontz . ~ Date: ~-s -03 - , 281289-1 A:>f-) it ~ ~ ~ ~ C\ ~ tAJ ~ t ~ It." "-..0 (), cf () ~ Co ~ () C' , j ~~ J~ ,....... ~ '--, i) (') (:) -\", f=..-." - L-: '."1:11, ". :'/ < C\ . ~.~, e; ',' 1.0 SAUNDRA L. KOONTZ, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Defendant CIVIL ACTION - LAW NO. .o3--.;27&-.3 &;J IN DIVORCE v. WILLIAM K. KOONTZ, Jr., AFFIDAVIT OF SERVICE I, Andrew C. Spears, Esquire, counsel for Plaintiff, Saundra L. Koontz, in the above captioned action, hereby certify that a true and correct copy of the Complaint in Divorce was served upon Defendant, William K. Koontz, Jr., via regular mail and certified, return receipt restricted mail on July 11,2003. Attached hereto, marked as Exhibit "A", and incorporated herein by reference is a copy of the return receipt card for said service. METZGER, WICKERSHAM, KNAUSS & ERB, P.C. By c.- ------ Andrew C. Spears, Esquire Attorney J.D. No. 87737 P.O. Box 5300 3211 North Front Street Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for Plaintiff Dated: July 25, 2003 285207-1 , p '<" ::!'l{f, :i!" ~( is :~~ Jit: -<:c j); (~, !;' ~ ~~~~7~ I?'cf, E1 ~ r;;:: ~) 'I :i! '- 1.1) .u.'-:, .;:,,,--. \..)c:- <:~; ',-r; of!! );! ~ f\.> <:0 ~ ~ t:- ;r:: SAUNDRA L. KOONTZ, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CNIL ACTION - LAW NO. 0.2 - J 7 (p 3 tIV/ L iE"fI/Y) WILLIAM K. KOONTZ, Jr., Defendant IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS TO: William K. Koontz, Jr. 492 Furnace Hollow Road Shippensburg, P A 17257 YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must talce prompt action. You are wamed 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 divorce is indignities or irretrievable brealcdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the office of the Prothonotary at the Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, Pennsylvania 17013-3387 PHONE: (717) 249-3166 281289-1 SAUNDRA L. KOONTZ, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. CNIL ACTION - LAW NO. 03 - 2763 CIVIL TE/UYJ IN DIVORCE WILLIAM K. KOONTZ, Jr., Defendant AMENDED COMPLAINT IN DIVORCE UNDER SECTION 3301 OF THE DIVORCE I. The Plaintiff, Saundra L. Koontz, is an adult individual currently residing at 492 Furnace Hollow Road, Shippensburg, Cumberland County, Pennsylvania, 17257. 2. The Defendant, William K. Koontz, Jr., is an adult individual currently residing at 492 Furnace Hollow Road, Shippensburg, Cumberland County, Pennsylvania, 17257. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing ofthis Amended Complaint. 4. Plaintiff and Defendant were married on May 23, 1998, in Franklin County, Pennsylvania. 5. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provision of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 281289-1 6. Plaintiffs Social Security Number is 163-44-0004 and Defendant's Social Security Number is 202-38-9537. 7. There have been no prior actions of divorce or for annulment between the parties. 8. 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. 9. There were no children born ofthis marriage. COUNT I REQUEST FOR A NO-FAULT DIVORCE UNDER & 3301(c) OF THE DIVORCE CODE 10. The averments of Paragraph I through 9 hereof are incorporated herein by reference. II. The marriage ofthe parties is irretrievably broken. 12. After ninety (90) days have elapsed from the date of the filing and service of this Amended Complaint, Plaintiff intends to file an Affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an Affidavit. WHEREFORE, if both parties file Affidavits consenting to a divorce after ninety (90) days have elapsed from the filing and service of this Amended Complaint, Plaintiffrespectfully requests the Court to enter a decree of divorce pursuant to S 3301(c) of the Divorce Code. 281289-1 COUNT II REQUEST FOR A NO-FAULT DIVORCE UNDER & 3301(d) OF THE DIVORCE CODE 13. The prior paragraphs of this Amended Complaint are incorporated herein by reference thereto. 14. The marriage ofthe parties is irretrievably broken. 15. The parties are living separate and apart; and at the appropriate time, Plaintiff will submit an Affidavit alleging that the parties have lived separate and apart for at least two years as specified in S 3301(d) of the Divorce Code. WHEREFORE, Plaintiff respectfully requests the Court to enter a decree of divorce pursuant to S 330l(d) of the Divorce Code. COUNT III REQUEST FOR FAULT DIVORCE UNDER SECTION 3301(a) OF THE DIVORCE CODE 16. The prior paragraphs of this Amended Complaint are incorporated herein by reference thereto. 17. Defendant has offered such indignities to Plaintiff: the innocent and injured spouse, as to render Plaintiffs condition intolerable and life burdensome. WHEREFORE, Plaintiff respectfully requests the Court to enter a Decree in Divorce pursuant to S 3301(a) ofthe Divorce Code to Plaintiff, the innocent and injured spouse. 281289-1 COUNT IV EOUlTABLE DISTRIBUTION 18. The prior paragraphs of this Amended Complaint are incorporated herein by reference thereto. 19. During the marriage the parties acquired marital property, assets and debts which Plaintiff requests the court equitably distribute and assign. METZGER, WICKERSHAM, KNAUSS & ERB, P.C. By (~ Andrew C. Spears, Esquire Attorney J.D. No. 87737 P.O. Box 5300 Harrisburg, P A 1711 0-0300 (717) 238-8187 Attorneys for Plaintiff Dated: \ ~ ) ~ _ tlL-L 281289-1 VERIFICATION I, Saundra L. Koontz, hereby certify that the facts set forth in the foregoing Amended Complaint in Divorce are true and correct to the best of my knowledge, information and belief, and that false statements herein are made subject to the penalties of 18 Pa. C.S.A. S4904 relating to unsworn falsification to authorities. Sa dra L. Koontz Date: f /d-.- 7 / () i { I 281289-1 r/-Cd:S-e.. --E:-h~ .q)(f~tlri: G - /r..~ IS" /s """ Vi iV/ol wa. r i/f F/ fo LON.... / () c: \}f.~c1 r:-"iffl ~t~~ U}...~ -/ .' r~rl ~:: ...~ /,~: (-} "'::::f-:) )S- C:: ~ ~ ~ ...:- .." :C ~ il ~ ~ (.) ~ \D SAUNDRA L. KOONTZ, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANlA v. CNIL ACTION - LAW NO. 03-2763 CNIL TERM WILLIAM K. KOONTZ, Jr., Defendant IN DNORCE AFFIDAVIT OF SERVICE. I, Andrew C. Spears, Esquire, counsel for Plaintiff, Saundra L. Koontz, in the above captioned action, hereby certify that a true and correct copy of the Amended Complaint in Divorce was served upon Defendant, William K. Koontz, Jr., via regular mail and certified, return receipt restricted mail on February 9, 2004. Attached hereto, marked as Exhibit "A", and incorporated herein by reference is a copy of the return receipt Gard for said service. METZGER, WICKERSHAM, KNAUSS & ERB, P.C. By Cr Andrew C. Spears, Esquire Attorney J.D. No. 87737 P.O. Box 5300 3211 North Front Street Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for Plainliff Dated: May 7, 2004 285207-1 7002 3150 ~~I~~: 7725 2.~~~~ :jf; '1";,,), , ~,,;~~:., . C) ....., c; = 0 c;:;';) -""" .,., I :~ -- :2 J,::p. -< fl1:!J r- -arn CJ 65: _.....(..1 ~J ~r::n ( ::1:: :::'2:(''-\ ~~ t:? (~jm ..-"\ :2 f'-' ?i) I" -< IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SAUNDRA 1. KOONTZ, Plaintiff v. CNIL ACTION - LAW No. 03~nt n~ WILLIAM K. KOONTZ, JR., Defendant PRAECIPE TO ENTER APPEARANCE To the Prothonotary: Please enter my appearance on behalf of the Defendant, Wmiam K. Koontz, Jr., in the above- captioned matter. Respectfully submitted, HANFT & KNIGHT, P.C. Dated: May ~, 2004 /~~/}f-;f Michael J. Hanft, squire Attorney J.D. No. 57976 19 Brookwood Avenue, Suite 106 Carlisle, Pennsylvania 17013-9142 (717) 249-5373 Attorney for Defendant F,IUser FolderlFirm DocsIGelldocs200413580_Jpraecipe,emerwpd IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SAUNDRA L. KOONTZ, Plaintiff v. CIVIL ACTION - LAW No. 03-2768 WILLIAM K. KOONTZ, JR., Defendant CERTIFICATE OF SERVICE AND NOW, this20'tt-day of May, 2004, I, Michael J. Hanft, Esquire, hereby certify that I have this day served the following person with a copy ofthe foregoing Praecipe to Enter Appearance by first class, United States Mail, postage pre-paid, addressed as follows: Andrew C. Spears, Esquire PO Box 5300 3211 North Front Street Harrisburg, Pennsylvania 17110-0300 Attorney for Plaintiff HANFT & KNIGHT, P.C. Mi< 'II Hmft, ~17j.J- Attorney J.D. No. 57976 19 Brookwood AVI~nue, Suite 106 Carlisle, Pennsylvania 17013-9142 (717) 249-5373 Attorneys for Defendant F:\User Folder\Finn DocslGendocs2004\35S0_lpraecipe,enterwpd ....' a; ;='-; Ule,,-! ~1~(,2 lj_ _.L_ 0';: 1 (,... or;: UjU- =-.:!u.\ U---r i=: lL o . c:> "J o <'J >- 'n'_. -"" C-::'l ~'::1 ,..... ....:"': =--j U SAUNDRA L. KOONTZ, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO, 03 - 2763 CIVIL WILLIAM K. KOONTZ, JR., Defendant IN DIVORCE ORDER OF COURT AND NOW, this ~d day of ~ 2004, the parties and counsel having entered into an agreement and stipulation resolving the economic issues on November 1, 2004, the date set for a four-party conference, the agreement and stipulation having been transcribed, and subsequently signed by the parties and counsel, the appointment of the Master is vacated and counsel can conclude the proceedings by the filing of a praecipe to transmit the record with the affidavits of consent of the parties so that a final decree in divorce can be entered, BY ~~HE COURT, .J. cc: ~ndrew C. Spears Attorney for Plaintiff ......sean M. Shultz Attorney for Defendant > 11- 03 -21 \:f;hl~'il\-:), [:~;\..t'J~~r~ I 'J t('~"';' :"',T' ;;... ',:--:-:, .:.:;::: ,.,1"''\1} 10. \;I;l,',.} j . ,~. ~'-'-:.:t'~~iv 6S :Z HJ 8- 'ION'iGUZ AbV1GNOnlOOd 3Hl:lO 381:BCX1311:l SAUNDRA L. KOONTZ, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERL1\ND COUNTY, PENNSYLVANIA vs. NO. 03 - 2763 CIVIL WILLIAM K. KOONTZ, JR., Defendant IN DIVORCE THE MASTER: Today is Monday, November 1, 2004. This is the date set for a conference with counsel and the parties. Present in the conference room are the Plaintiff, Saundra L. Koontz, and her counsel Andrew C. Spears, and the Defendant, William K. Koontz, Jr., and his attorney Sean M. Shultz. A complaint in divorce was filed on June 12, 2003, raising grounds for divorce of irretrievable breakdown of the marriage and indignities. An amended complaint was filed following a period of reconciliation. The amended complaint was filed on February 2, 2004, raising grounds for divorce under 3301(d) and 3301(a) (6). The original complaint raised economic claims of equitable distribution, alimony, and alimony pendente lite. No claims were raised for counsel fees. The amended complaint raised a claim for equitable distribution. In any event, pending before the Master are claims of equitable distribution and alimony. The Master has been advised that after discussion today the parties have reached an agreement with 1 respect to the outstanding economic issues. The agreement is going to be placed on the record in the presence of the parties. The agreement as placed on the record will be considered the substantive agreement of the parties not subject to any changes or modifications except for correction of typographical errors which may be made during the transcription. The agreement is going to be provided to the parties and counsel later this afternoon to review for typographical errors, any corrections can be made and then the parties will be asked to affix their signatures affirming the terms of settlement as stated on the record. In any event, the parties are bound by the terms of settlement as stated on the record when they leave the hearing room today. Upon receipt by Master of a completed, agreement, the Master will prepare an order vacating his appointment and counsel can then file a praecipe transmitting the record to the Court requesting a final decree in divorce. Mr. Spears. MR. SPEARS: 1. During the marriage the parties acquired the marital residence located at 492 Furnace Hollow Road, Shippensburg, Cumberland County, Pennsylvania 17257. The parties have agreed that the marital residence will be listed for sale with Matthew Hurley located in Greencastle, Pennsylvania. All proceeds after expenses from the sale will be divided 50/50 between the parties. The parties have further agreed that William K. Koontz, Jr., who is currently residing in 2 the marital residence, will relocate by December 15, 2004. If the house is not sold by the time Mr. Koontz relocates, the parties will split the mortgage and living expenses, including utilities, oil, etc., 50/50 until time of sale. Both parties will cooperate with Matthew Hurley and sign all necessary paperwork to enable the sale of the marital residence. 2. During the marriage the parties have acquired various items of tangible personal property. The parties have distributed to the best of their knowledge the tangible personal property. This will be incorporated on Exhibit A which will be attached to this agreement. With the exception of Exhibit A, all tangible personal property in the possession of Saundra L. Koontz will remain hers and all tangible personal property in possession of William K. Koontz, Jr., will remain his. 3. Both Parties further agree to waive all claims regarding alimony, spousal support, and alimony pendente lite. 4. During the marriage William K. Koontz, Jr., acquired a retirement account through the federal government (FERS). Saundra L. Koontz waives any interest in William K. Koontz, Jr., retirement. At the time of the signing of this agreement, Saundra L. Koontz will sign the retirement plan beneficiary designation change form. 5. 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 have 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, statutory allowance, widow's allowance, right of intestacy, right to take against the will of the other, and right to act as administrator or executor in the other's estate. Each will at the request of the other execute, acknowledge, and deliver any and all instruments which may be necessary or advisable to carry into effect this mu~ual waiver and relinquishment of all such interest, rights, and claims. THE MASTER: Mrs. Koontz, you have been 3 present during the statement of the agreement on the record? MRS. KOONTZ: Yes. THE MASTER: Do you understand it? MRS. KOONTZ: Yes, I do. THE MASTER: Do you have any questions about it? MRS. KOONTZ: No, I don't. THE MASTER: Do you ur.derstand that when you leave the hearing room you are bound by this agreement? MRS. KOONTZ: Absolutely. THE MASTER: You understand that you are going to return later today, however, to review it and then affix your signature affirming the settlement? MRS. KOONTZ: Correct. THE MASTER: Mr. Koont z, have you been present during the recitation of the agreement? MR. KOONTZ: Yes. I understand. THE MASTER: Do you understand it? MR. KOONTZ: Yes. THE MASTER: Do you have any questions about it? MR. KOONTZ: No. THE MASTER: You underst.and that you are 4 going to come back and review for typographical errors and then sign affirming the settlement but that you are bound by this settlement when you leave the hearing room today? MR. KOONTZ: Yes. I acknowledge that I have read the above stipulation and agreement, that I understand the terms of settlement as set forth herein, and that by signing below I ratify and affirm the agreement previously made and intend to bind myself to the settlement as a contract obligating myself to the terms of settlement and subjecting myself to the methods and procedures of enforcement which may be imposed by law and in particular Section 3105 of the Domestic Relations Code. WITNESS: DATE: ~ ~-- ~. An rew C. Spears Attorney for Plaintiff ,~ Sean M. Shultz Attorney for Defendant II- / - () V . ~K II-I vO '{ w~~~fL 5 cx.h.,.b.'-t- A 5t\..U~Jr4 koo,,+"t.- I) CKk:. ~/c. ;A i/.~,~ ~ z.) vJ,'~ blt..Jc.. c.h.t4."y" :>) OltlJ ~V\ Y} t:t t hcc)c.. c~ u..:> 5) L" 'Z - e i>>, c.~"r tJ) ~r~-e. tV, ;/1. GI'~f ~ i) Pf..~ Jt--z.'S~f d"sh~s ~ t;..:fu.. drot.s.s.q- of- ~/rrdY" ~) W ~btts tA Wrd(J1'h JO) Le..--flS ;>"1 beolrc>oV1--.,...~ el5RwMr..e... I j) 'K.ovv-d hbCA..A ~,..oc::>--.. J,J /f'V.. h b&. do it.. s 12.) K;.j.dtt,Vl dock. 13) ~~r"o~ c..1cJc. ,~ b<'~H+ Jp Virt/~ r~t)_ "jAr f;'..x.~,...e. IS") ~ Lo'~ ~'~hovt , ,) W~ shoe,,- ~ l:Y'jeY' n) z.l'lk~,i1~'-t.+ ~krs J:" I/II/~ YOOIIk 1lj/f1d. lof-+- I ~ S~ fj" lit ~ ( co lJ (....1-, 11) flDor Iv' WI,'I- A".d Vc.R. z..o) t..""",e.. rJ~ ;/\ Jo~t- z.~ Tl/A"..+.,. tll. I,'vhr.~ (jetr,ius. bJ/II/.../A.. ~JIt+-~ !) Chr.:,h..oc5 b~lA.+- w,~ iA5c..r:ph't:1>-..: .. tJ,'JI/~_ '0/03 C, z) B1vc- ,,~ c.Ye..:I-1.-.. cd r'Y"d kw / 3) aI..At::.~ '4tlAJ~j/'~ b~ t.J I y) ~J- c./ovk 5) Z~ tA--f?t!\5S t) Old. tx/ Y\ I", "1fe.YV1 7) v.J/)~~ Sc)J"Y' hC/~-f- 8) -rkV'-o.s ~/l $:;.vnJr..'<:;, sloYa..,~ 4\:.) gird C-41,.-e- b) ht'c.jd..t... Q ;f/)e,kl ~t""'S ,A,) Tool,:> to) Ckj p"t:, ~) bv,'ld//t, J4-L~-Je,.;~ I j) Mw cJj/f()~ Wt'-1ekw ~) ~,,:+-; i) ReA T:"V J) L~{ p<rlo'l" sh V'~ q) Ji,.;o DD, Wt!>ocR. ff(ijZ..;:, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, ~?f: PENNS~VANIA ~~. Vs : File No. U)I)fJ~~ 7ra;;~6, D fenda c;- ()3-::l70~ IN DIVORCE NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff I defendant in the above matter, [select one by marking "x"] prior to the entry of a Final Decree in Divorce, or ~ after the entry of a Final Decree in Divorce dated~.::]j!. Of hereby elects to resume the prior surname of 'f./t.&u ,and gives this written notice avowing his I her intention pursuant to the provisions of 54,S, 704, Date: 5 c2 - 6-'0 Signature ..~k?j<r~~ ~ame being resumed - COMMONW~LTH b: PENNSKL VANIA COUNTY OF.lUYJ 11 O}nd On the ,?YJC(daYOf MOfJ V-- ) , 20~ before me, the Prothonotary or the notary public, personally appeared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he I she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand hereunto set my hand and official seal. ----.--.,-.-.-..---.---,--"; /1 ' / l I Q--< l..oUC- f1u.e,J/.xti.<./ . P""tl.on~r Notary Public ,'WT.... Jd. SEAl. I ~_ ~',-,':.'it\ / E::;END.AKr=1l ~WTMl\' PUBLIC ! CH:j:~;e Sore. Curn~er:and CQunty ; My C01T:iT::jS,Qr, :-./.~';ie~ !qJril ~, 2n05 .----.--.--......--- ---.-'--'-.' 1- -<q -0 \) "- () ll'- '- iV )J w r- ----.::z -u 1; f) S ~?I ::l!' ~ ?'J , N :r;:<' :,l\: ....9' r" CG- .. Plaintiff IN THE COURT OF COMMON PL AS OF CUMBERLAND COUNTY, PENN YL VANIA SAUNDRA L. KOONTZ, v, CNIL ACTION - LAW NO. 03 - 2763 CIVIL WILLIAM K. KOONTZ, JR., Defendant IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Kindly transmit the record, together with the following information, to the Court for e try of a Divorce Decree: 1. Ground for divorce: Irretrievable brealcdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of Complaint: A Complaint in Divorce was fi ed on February 2,2004, and served on Defendant on February 9, 2004. 3. Complete either paragraph (a) or (b): (a) Date of execution of Plaintiffs and Defendant's Affidavits of C nsent required by Section 3301(c) of the Divorce Code: Plaintiff: Defendant: Executed July 16,2004; filed July 20,2004 Executed July 16,2004; filed July 20,2004 (b)(I) Date of execution of Plaintiffs Affidavit required by Section 3301(d) fthe Divorce Code: NA (2) Date of filing and service of the Plaintiffs Affidavit upon the responden : Filing: NA Service: NA 315653-1 .. 4. Complete the appropriate paragraphs: (a) Related claims pending: None (b) Claims withdrawn: None (c) Claims settled by agreement ofthe parties: All (d) State whether any written agreement is to be incorporated into the Di rce Decree: Marital Settlement Agreement placed on record in Divorce aster Elicker's Office on November 1,2004. 5. (a) Date and manner of service of the Notice of Intention to File Praecipe 0 Transmit Record, a copy of which is attached, if the Decree is to be en ered under Section 3301 (d)(1)(i) of the Divorce Code: Service: NA (b) Date Plaintiffs Waiver of Notice in ~3301(c) Divorce was filed with e Prothonotary: July 20, 2004 Date Defendant's Waiver of Notice in S3301(c) Divorce was filed wit Prothonotary: July 20, 2004 METZGER, WICKERSHAM, KNAUSS & ERB, P.C By Andrew C. Spears, quire Attorney J.D. No. 87737 P.O, Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for Plaintiff Dated: \ \ - \ '\. -Ql-\ 315653-1 Plaintiff IN THE COURT OF COMMON PL AS OF CUMBERLAND COUNTY, PENN LV ANIA SAUNDRA L. KOONTZ, v. CIVIL ACTION -- LAW NO. 03 - 2763 CNIL WILLIAM K. KOONTZ, JR., Defendant IN DIVORCE CERTIFICATE OF SERVICE AND NOW, this -t'l_'\'lay of Nwv-. _ , 2004, I, Andrew C, Spears, Esq ire, of Metzger, Wickersham, Knauss & Erb, P.C., attorneys for Plaintiff, Saundra L. Koontz, ereby certify that I served a copy of the Praecipe to Transmit Record this day by depositing the s me in the United States mail, postage prepaid, at Harrisburg, Pennsylvania, addressed to: Sean M. Shultz, Esquire Hanft & Knight, P.c. 19 Brookwood Avenue, Suite 106 Carlisle, Pa 17013-9142 METZGER, WICKERSHAM, KNAUSS & ERB, P.C. By: \_9.. ~ ~ AndTew C. Spears 315653-} r-' .. .\ 1...'-..'-' ..,., t. ~.. F-'- C~) - . , . . , , . . . . . . . . . . . " . . " . . . . . . . , . " . . . " . " . . " . " . " . . . . . . . . " , , " " , . . . , . , , , " . " . , , " . , . . . , , , . . , " " + . + + . + + + . + " ++:f:+ + + " .. .. '" ;+;:+. +:+:,.:+:'1'+++.++ +'I'+;+''Ii+++;+;++:+:+ +++:f.'f:+:++.:+:+:+;+ '1':+:++ ++:to+"" :+: +++:lo:+.+.++:+ + " . + " " , . " IN THE COURT OF COMMON PLEA OF CUMBERLAND COUNTY , STATE OF PENNA. SAUNDRA L. KOONTZ, No. 03 - 2763 CIVIL PLAINTIFF VERSUS WILLIAM K. KOONTZ, JR., DEFENDANT DECREE IN DIVORCE AND NOW, Klov~ ~l;;, .. ) , IT IS ORDERE AND 2004 2'-1 DECREED THAT SAUNDRA L. KOONTZ , PLAINTIFF, AND WILLIAM K. KOONTZ, JR. , DEFENDAN , 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 HA YET BEEN ENTERED; NOT The Marital Settlement A reement between the laced on the rec rd arties on November 1, 2004 is incor orated but not mer e herein. By THE COURT: ATTE T: ROTHONOT RY . ++++++.++++'1'++'1'++++++++++++++++++++++ , , , . . " " . " + . + + . + + . + . . . " " " " " " " . " . " " . " . . . + + . . + " . " . " . " . . " . . " " . " " " " " " + + . + " + " " + " " + " + + . + . + . " . + " " + . +++.+~f J. ~ih .Ill \fl.' II ~2,.,-?'~ ~rt? rt- ~7Y'.4 '<'~- 1'i' / ,lie - __-....; 4!w p9hO <It II ~f/? 'P''f/ - . ------- -