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Home My WebLink About01-03904 - "~ 'd ,--~ ,'-- " -<,'"" ~ H -. , JI";J-~,,,-, ,j-"" "-, ",-, >" '~ " . . . . . . . "'''' "';Ii "';Ii "'''' Of. ;Ii'" :I; :1;"'''' ;to;~t . . . . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY . PENNA. . . . . STATE OF . .. Kirnberlea Conrad NO.01-3904 CIVIL TERM . VERSUS . Maynard S. Markel . . . . . DECREE IN DIVORCE . . . . . AND NOW, \'.'\{)V, 4 .ll~vol, IT IS ORDERED AND . . . DECREED THAT Kimberlea Conrad PLAINTIFF, AND Maynard S. Markel , 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 . VEl BEEN ENTERED; ~ It is further ordered and decreed, pursuant to Pennsylvania Divorce ~ Code, Section 23 Pa.C.S.A. ~3101 et seq.and Pa.R.C.P. 1920.1 et seq.' that. Lit", L"'LlIL::; dud cOIldltions of a certain Agreement made oe1:ween th parties and dated October 1, 2001 , and attach hereto and made a part hereof. in accordance with Paraqraph 16. page 3, shall be incorporated into, but shall not be merged with, a Decre in Divorce between the parties. By THE COURT: . J. . . ATTE ~~ PROTHONOTARY '" '" "';Ii '" ",,,,,,,;Ii;to;:f. '" '" '" '" '" .<--'''-'~~''1 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ",' ~ , ~ 'i I, ii " ;1 ,! n :',- 0] S] ~.<,~- ,." , ,'< II- 1.!I-tJ/ II- lilc.y I"" "-~ ~" , . ,"'O_,~,___~.",._~' ~~ __, "I-r" - , ~ 1- ~"M, ,~ \ '{ ,,-'; ,4" '. tY. 6?;' ~ ~ a:f~ '71t?'ttv /M;JJ/ ~ ~- ,..,.,~~"'IJI'I"IR!I'!\'f!!limi!Ji!;j'1!$i,,,~illiW--i',~!,i:'Il':!e!\" ' - ~jWI"'i'!',~""l~ ,,",,',~J!lM!lliIl!il~~.... ,'~~ , , -;1_ _l ~-"_""'= ~_ ~ '" ;,'" :-4i~; '. AGREEMENT THIS AGREEMENT made this (...c! day of <' r::::~ J ~~. , 2.. 0 0 J by and between MAYNARD S. MARKEL, hereinafter referred to as HUSBAND, and KIMBERLEA CONRAD, hereinafter referred to as WIFE. WITNESSETH: WHEREAS, the parties hereto are husband and wife; and WHEREAS, certain differences have arisen between them, as a consequence of which the said parties are living separate and apart and therefore' desire to enter into an agreement for the final settlement of their property and affairs; and WHEREAS, the parties, being fully advised as to their respective rights, duties and obligations growing out of their marital status, have come to an agreement as to each and all of their said matters of property and relations; and WHEREAS, WIFE has entered suit for absolute divorce from HUSBAND, NOW, THEREFORE, in consideration of the covenants and promises 'hereinafter mutually to be kept and performed by each party, as well as for other good and valuable consideration, it is agreed as follows: I. SEPARATION: It shall be lawful for HUSBAND and WIFE to live separate and apart from each other and to reside from time to time at such place or places as they shall respectively deem fit. 2. INTERFERENCE: Each party shall be free from interference, authority and contact by the other, except as may be necessary to carry out the provisions of this Agreement. Neither party shall molest the other nor attempt to endeavor to molest the other nor in any way harass or malign the other, nor in any way interfere with the peaceful existence, separate and apart from the other. 3. NAMES: It is understood that the terms HUSBAND and WIFE are used throughout this Agreement solely as the method of identifYing the parties and such words shall not be construed to have any special meaning or purpose for their use, and are not dependent on their marital status with each other. 4. DIVORCE: WIFE has filed an action for divorce in Cumberland County, Pennsylvania. The parties agree that upon the passage of the ninety day waiting period after service of the divorce complaint, they will both execute affidavits of consent so that the divorce action can be completed. This Agreement shall remain in full force arid effect regardless of any change in the marital status of the parties. 1 < "I^A -,<^ ~,",~, ,,' ';- 'W_ , . 5. 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 other than those debts assumed by the HUSBAND as a consequence of the Agreement herein. 6. HUSBAND'S DEBTS: HUSBAND represents and warrants to WIFE that he will not contract or incur any debt or liability for which WIFE or her estate might be responsible other than those debts assumed by the WIFE as a consequence of the Agreement herein. 7. MUTUAL RELEASES: Subject to the provisions of this Agreement, each party has released and discharged, and by this Agreementdoes 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 of the parties ever had or now has against the other except any or all causes of action for divorce and except any or all causes of action for the breach of any provisions of this Agreement or property rights created and maintained in this Agreement. 8. WAIVER OF CLAIMS AGAINST ESTATE: HUSBAND relinquishes his inchoate intestate right in the estate of WIFE, and WIFE relinquishes her inchoate intestate right in the estate of HUSBAND, and each of the parties hereto by these presents for himself or herself, his or her heirs, executors, administrators, or assigns, does remise, release, quit- claim, and forever discharge the other party hereto, his or her heirs, executors, administrators or assigns, or any of them, of any and all claims, demands, damages, actions, causes of action, or suits at law, or in equity, of whatsoever kind or nature, for or because of any manner of thing done, omitted, or suffered to be done by said other party prior to and including the date hereof. 9, REAL ESTATE: The parties had been the owners ofa tract of improved real estate located in Lower Allen Township, Cumberland County, Pennsylvania, and known and numbered as 1728 Main Street Lisbum, Mechanicsburg, Pennsylvania. HUSB~D has previously conveyed all of his right, title and interest in this tract of real estate to WIFE, and the deed evidencing such conveyance has been recorded in the Recorder of Deeds Office for Cumberland County, Pennsylvania. HUSBAND waives and relinquishes any right, title or interest that he previously had in said tract of real estate and confirms that it is the sole and separate property of WIFE. 10. CASH PAYMENT: WIFE agrees to pay to HUSBAND the sum of One Thousand Five Hundred ($1,500.00) Dollars. Additionally, the parties agree that WIFE shall receive the IRS refund check in the amount of $600.00 which they anticipate receiving from the Internal Revenue Service. II. RETIREMENT PLANS: WIFE has 401(k) plans witlt,Fleet Financial Group and with Equity One. She shall retain these assets as her sole and separate property, and HUSBAND waives any claim which he may have thereto. 2 ~I ~" ~~ ,0, ".0_, ~ " . ,~ J~i';,} . , HUSBAND has a 40 1 (k) plan with S & W Petroleum. He shall retain this asset as his sole and separate property and WIFE waives any claim which she may have thereto. 12. DIVISION OF PERSONAL PROPERTY: WIFE agrees to give.toHUSBAND the breadmaker. HUSBAND shall re~ain the breadmaker as his sole and separate property and WIFBwaives any claim which she may have thereto. In regard to all otheritems of personal property, the parties acknowledge that they have heretofore divided up between them all of their p~rsonal property to their mutual satisfaction. All the personal property currently under the custody and control of the WIFE shall belong to the WIFE and all the personal property curreIlitly under the custody and control of the HUSBAND shall belong to the HUSBAND. Henceforth each of them shall own, have and enjoy , independently of any claim or right of the other, all items of personal property of every kind, now or hereafter owned or held by him or her, with full power to dispose of the same as fully and effectually, in all respects and for all purposes, as ifhe or she were unmarried. 13. SUPPORT: Each party hereby agrees not to claim or demand any support for himself or herself, alimony Pendente Lite, permanent alimony, counsel fees or expenses from the other party, except as specifically provided for in this Agreement. 14. WAIVER OF APPRAISEMENTAND INVENTORY: The parties acknowledge and agree that they have had an opportunity to value or have appraised any and all marital property, and they do hereby waive a formal appraisal and inventory of same, and no statement or representation by either party as to value shall be deem~d a misstatement or misrepresentation to the other or be deemed fraudulent. 15. EXECUTION OF DOCUMENTS: The parties hereto agree to execute any and all documents necessary to effect the terms of this Agreement. 16. INCORPORATION: This Agreement may be incorporated into, but shall not be merged with, a Decree in Divorce between the parties. 17. LAW OF AGREEMENT: This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania. 18. ENTIRE AGREEMENT: This Agreement contains the entire understanding between the parties. There are no representations, warranties, covenants or understandings other than as expressly set forth herein. 19. LEGAL ADVICE: The within Agreement has been prepared by WIFE's attorney, Joel O. Sechrist. HUSBAND has been advised of his right to have an attorney of his choice to review the Agreement and to advise him prior to signing th~ Agreement. The parties to this Agreement hereby acknowledge that they have carefully examined its contents and that they are satisfied that they understand the Agreement and further that the Agreement is, under the 3 , ~ , " ~ -" '- ~~ ~" ( , , circumstances, fair and equitable and that it is being entered into freely and voluntarily and that it is not entered into as a result of any collusion or improper or illegal agreement or agreements. IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the date first above written. WITNESSES: :fi/ eJ. ~ (SEAL) ~Ar,) 4 ~ " " ".";.~j, II ,J 'k_ "~', . , , ~-- > '0' -- '",~ ':.wr_ " I. ;. .' COMMONWEALTH OF PENNSYLVANIA ~ COUNTY OF YORK ON THIS, the day f ST of Ocro f:,erL , 200 I, before me, a Notary Public, the undersigned officer, personally appeared 1< l m &"/:2..1..~ Co tJ RAi) , known to me (or satisfactorily proven) to be the person whose name I ~ subscribed to the within instrument, and acknowledged that S' 11 ~ executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. ~~tf'~~ Notarial Seal Linda J. MoDaniel, Notary Publio Fairview Twp,. York County My Commission Expires Feb, 23, 2003 Member, Pennsylvania Association at Notaries COMMONWEALTH OF PENNSYLVANIA COUNTY OF '/O(f.r( ~ ON THIS, the day /<;,7 of OCT1J~.a<. ,2001, before me, a Notary Public, the undersigned officer, personally appeared #f lJ-yP! ~jZ 1) J', tf'I(f p- k t L. , known to me (or satisfactorily proven) to be the person whose name IS subscribed to the within instrument, and acknowledged that ~I , executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. ~~.~~ . 5 Notarial Seal Linda J. MoDanlel, Notary Publio Fairview Twp., York County My Commission Expires Feb. 23, 2003 Member, Pennsylvania Association of Notaries . ,"~:<JiNIH"~~o;mi-~ihl1l!hllll.1-~~~M~~ffw~'!.~-J,;,~!il"\1.;"I"~'''"c -"h_G,;:",;'t~,~i fui"'~;~""'-'-"~~~~llllI;'jli1.l~~~'-~~~~'~ IiiliU_J ,~~lJ - ~< . ' 0 Cd 0 0 C .'Tl S a '-\ u cC' CJ -on rn n--; ...... 0 ;- Ii -" W , " .--'~; " + u, a :- -< /' Cd ~:l.) -~---l w ~8 2::: :,-:,----"'1 0- ..--,~ ',-0 )>c-:: cc :~jnl ---l C)o Z -t-~+ ~ "TJ 0 =< C) t [S OJ ''''~''\'N'''~'_' 4,-' '<~'1"",_~~. n~"~~'~~. ~~_" ..I~L~ ,.' ,_., ..c,~' "",-7';""',~",<",,, "', ~~ e," ,~~, ^'.. ,,", y" -~-" ,~~ J: ~~ ,., li ~,,~m-' IN mE COURT OF COMMON PLEAS KIMBERLEA CONRAD VS. CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MAYNARD S. MARKEL NO. 01-3904 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: I. Ground for divorce: Irretrievable breakdown under Section (3301(c) (JJ(JI(d)(I)) of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the Complaint: Certified Mail- June 28. 2001 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by Plaintiff Oct:ober c,l 2001 ; by Defendant October. 1 2001 (h) (1) Dal~of GACGut;vu vftl..~Plaintlfr ~Affida"lt"~'iu;..Gd by S~~l;vuJJel(J:)vftllGD;"vl{'G Cud". , (2) Dc.et~ vf Ll;"..g afld 6~.." ;~~ vf tll" Plailil;ff' ~ Afl1da,,;l upvu th" D~r~udat"'L. 4. Related claims pending: Economic issues which were raised in the within action were all settled bv written Agreement between the parties dated October 1, 7.001 5. Complete either paragraph (a) or (b). (.l) Dal~ and Inan.UGJ of SGl" kG vrr~vG~~ vf th~ Ink.ut;vn tv bIG pU,CGlp" tv l..an~nJ;t IGGOld, Cl '-"UP] uf "hiGh is attached. (b) s W 'ver of Notice in g3301(c) Divorce was filed with the Prothonotary: _ .r 0 Date Defendjt's iiver of Notice in g3301(c) Divorce was filed with the Prothonotary: I ~ ";_0 I ~ / _ 1 e . Sechrist, Esqu re orney for Plaintiff Supreme Court IV 15609 ~;;l!~-i'i>'B"-"';*"'<_O!'d.-4h&'?1i'."t!.,iIi~~n))),ii;,,,!;<,,,,.'H "'~;' ',_;' ,~"" _\i;;jd,;1k;''''_o1"?c,,,,,~~lw\IWiO..;!f_illll!l>.~_- 119 "TJ S2 <::) r- , , 0 :;;- -7': ED IT~ C) C""") ',", 0 '--1 [''''- "'--,--'-, f'> Zc-" '-J --i + ~~;:~ a \.,.: (;J r~::c, c~;) Zr-, -" ~? ~~; C> Li:" _c,:, )>rd co 25fT; ~ ~z: ,::;) ~ 00 =< "'- \0 :r:J ---. () --C >. ~ <:5- cd " J~ ,_,,,"~.. ~."__.. ~_<,,=~" ,~__'" 'H~ ~,__, 'W' < ",. 7r~ I, ,,~ ~ n ! ... ~-- , '1....1...= ,~- --:nf:if~'~._'r'.'~,%' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NOTICE TO DEFEND AND CLAIM RIGHTS MANDATED BY R.C.P. 1920.71 KlMBERLEA CONRAD Civil Action - Law MAYNARD S. MARKEL Action in Divorce G~~(~~ VS. No. Dl- J901f NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claIms set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree 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, including custody or visitation of your children. When the ground for the 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 Court House, 1 Courthouse Square, Carlisle, Pennsylvania, 17013. 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 Lawyer Referral Service 2 Liberty Avenue Carlisle PA 17013 717249-3166 800 990-9108 ~ ~ ,,' L _.-, 1..1,_., ~, -' ~Iii-''''b'-'~~f_ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NOTICE TO DEFEND AND CLAIM RIGHTS MANDATED BY R.C.P. 1920.71 KIMBERLEA CONRAD Civil Action - Law VS. No. MAYNARD S. MARKEL Action in Divorce A VISO PARA DEFENDER Y RECLAMAR DERECHOS USTED BA SIDO DEMANDADO EN LA CORTE. Si desea defenderse de las quejas expuestas en las paginas siguientes, debe tomar accion con prontitud. Se Ie avisa que si no se defiende, el caso puede proceder sin usted y decreto de divorcio 0 anulamiento puede ser emitido en su contra por la Corte. Una decision puede tambien ser emitidaen su contra por cualquier otra queja 0 compensacion reclamados por el demandante. Usted puede perder dinero, 0 propiedades u otros derechos importantes para usted. Cuando la base para el divorcio es indignidades 0 rompimiento irreparable del matrimonio, usted puede solicitar consejo matrimonial. Una lista de consejeros matrimoniales esta disponible en la oficina del Prothonotary, en la Cumberland County Court of Common Pleas, 1 Courthouse Square, Carlisle, Pennsylvania. SI USTED NO RECLAMAPENSION ALIMENTICIA, PROPIEDAD MARITAL, HONORARIOS DE ABOGADO U OTROS GASTOS ANTES DE QUE EL DECRETO FIN4 DE DIVORCIO 0 ANULAMIENTO SEA EMITIDO, USTED PUEDE PERDER EL DERECiIo A RECLAMAR CUALQUIERA DE ELLOS. USTED DEBE LLEV AR ESTE PAPEL A UN ABOGADO DE lNMEDIATO. SI NO TIENE 0 NO PUEDE P AGAR UN ABOGADO, VA Y A 0 LLAME A LA OFICINA INDICADA ABAJO PARA A VERIGUAR DONDE PUEDE OBTENER ASISTENCIA LEGAL. Cumberland County Bar Association Lawyer Referral Service 2 Liberty Avenue Carlisle P A 17013 717 249-3166 800990-9108 " ~,~'"~ . l~"" " ,~ ~, i-l!ilI~~", IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLV ANIA KIMBERLEA CONRAD Civil Action - Law VS. No. 01-390'1 d.;J I.J.M- MAYNARD S. MARKEL Action in Divorce COMPLAINT 1. Plaintiff is Kimberlea Conrad, an adult individual, who currently resides at1728 Main Street Lisburn, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. Defendant is Maynard S. Markel, an adult individual, who currently resides at 1783 Mountain View Road, Middletown, Pennsylvania, 17057. 3. The Parties have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and the defendant were married on April 2, 1988 at Apopka, Florida. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. The Parties separated May 12, 2001, and have continued to live separate and apart continuously since that date. 8. The Plaintiff has been advised of the availability of counseling and that the Plaintiff may have the right to request that the court require the parties to participate in counseling. 9. el O. Sechrist upreme Court I.D. #15609 568 Old York Road EttersPA 17319 Attorney for Plaintiff ,'- , 'I -I . ~.~_ _ ~,,~ ,'--- - .lill' ",~-'% I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. g4904 relating to unsworn falsification to authorities. DATE: ~ial ~~ Kimberlea Conrad, Plaintiff , .-. -'>' 1,,1 ,'",,," '~ - -, ; -'- - " ,---{." .." ,~ '-;, "'jij;, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA KlMBERLEA CONRAD CIVIL ACTION - LAW VS. NO.01-3904 CIVIL TERM MAYNARD S. MARKEL ACTION IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYL VANIA s COUNTY OF YORK Personally appeared before me, the undersigned officer, a Notary Public in and for said County and Commonwealth, Joel O. Sechrist, Esquire, who, being duly sworn according to law, doth depose and say that he caused a true and correct copy of the Complaint in the above cited case to be served upon the defendant, , by delivering same to the United States Post Office at Lewisbeny, Pennsylvania, on June 27, 2001, and mailing said Complaint by certified mail number 70993400000680030199, copies of the receipt for certified mail and return receipt card being attached hereto. SWORN to and SUBSCRIBED before me this t;( (., 71~ day of ~trrf)e,RL..- ,?Po 1 ~l)0c~ Notarial Seal Unda J. McDaniel, Notary Public Fairview Twp" York County My Cortlmission Expires Feb. 23, 2003 Member, Pennsyhiania Association at Notaries . , ~",~iM11!,JlP;~~d..,;!It~.1:""'\t'ik\i1i,;w~~.td'Il~""""'_'_-''-''''':'dl.~t."J'.l['''''',;<"";",_"~",..ii'-'*&'h,,,,,~iUWlWl~~,;>"'i~.hWlOi'''''r ~'" "' ,~'1~h'11'll1~ I..J:>.... <"b~_ e_ ,~_ ,~.HW_"' .>_~<_"" ,~~"~ ,,_ .Ie" , ~ _ ~,,-.,_ r~'" ,~, ~,"> ___~ ~",>, , ~, "~ " C> C) ;~'ir: ,,<-~ ~,~ ",,.-'," ~c p: ~;; o r> -r <3 ...l;:) (;; o ~ :s , -, . c.:) f-'_::) ~--) ,....-j (=i :C'" ~c:I c:) o fa , 'LL H i;i, ~ ~ 'I ;01 1 ~ il ~ Ii ;'1 I, 'I I 1 , 'I :ij Iii 1'1 " ! ~ !! :j I 'I !I' 'I I , 'I ':1 :1 " ,I . . ' , ' I " ! " , " , ~ -' ' - , , " , . Complete ite:ms 1; 2, and 3. Also compil;!te item 4 if Restricted Delivery is desired. . Print your name and address on the reverse so that we p~n return the card to you. . Attach this c'ard to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: ( delivery address different from item 11 If YES, enter delivery address below: o Agent o Ad'dressee DYes o No tnA'1 tJAteD S. fnPrR.l<./a Jig 3 Moo tJmlt.J \I1-ez.<.' /lit IOOL.l?'W v.)N PA I~S1 3. Service Type IJf Certified Mail o Registered o Insured Mail o Express Mail ',If Return Receipt for Merchandise 00,0,0, 4. Restricted Delivery? (Extra Fee) Ves 2. Article Number (Copy from service label) 7 () "0/ J'f I') 0 000 , PS Form 31311, ~~Iy 1999 ", "'j' -' " t!-l'J 03 DI N . . Dqmestic Retum:Receipt 102595-99-M-17S9 U.S. Posta! Service CERTIFIED MAIL RECEIPT (Domestic Mail Only; No Insurance Coverage Jr Jr M Cl Article Sent To: MIDDLETO~N PA i7057 m; Cl Cl CO Postage $ $0.34 $1.90 Jr Jr Cl l'- $1.50 Certified Fee Return Receipt Fee -CI (Endorsement Required) Cl o Restricted Delivery Fee 1::1 (Endorsement Required) Cl Total Postage & Fees $ $6. N Cl =r m $3.20 ~I " L - -" , ~,'I, _I , ,,"" "A< - ,",~ ,;' ',_-,; , - ~-rr IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KlMBERLEA CONRAD CIVIL ACTION - LAW VS. NO.OI-3904 CIVIL TERM MAYNARD S. MARKEL ACTION IN DIVORCE AFFlDA VIT OF CONSENT 1. A Complaint in Divorce under ~3301 (c) of the Divorce Code was filed on June 26, 2001. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verifY that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.~4904, relating to unsworn falsification to authorities. (}~d- DATE: )0); Jv } Plaintiff ~~~-.l;;~M,;""-"'J~r.;!>LiliIir~;"'cj.i:ll41,h'%;;!Mi:;-S'i~~;'.i'," ""._""",""o"l;[~;::~'i<4~"'1I!tl;@~~~iBH.!lliiiilllil.~.- ~ ""'I . ~ ~ -~" (") (;:) C> C s... ':::> ri{ ,[~~: :~ z" 0 -~ ('\ ~~ c T ~~ r:'r~;, .,...' , :>l=' '\::'l ch zrS )o'c: ~ :-.) VI -- 3 - ~j ,I 'I 1,1 II c.s cO "!.~..._._">,,c.,,L ~"L1!"."__ __ "~,~~^'_" __ ~ ~JU!rU[JDl~, "Jt~l}";~_~"",!,J\:~~~l",-,,!!~L~,, ",X,,:-::IiL'''H'~-- J ~ ',' ','~ "~_"."',>_'~ _~,Y-". "".," ," ~.-~,'~-, " ,"''<'':','_'--.~,''"--'''' -" ,_;~, '+~'""'~;" ,,''C'''__' n_-~_ -',,'"^-,,,,It'_",,,, ," _,~ "'<<"" ,,'" ,," ',_.', ._, ~ .~~. , ~' .~, '" ~,-. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA KIMBERLEA CONRAD CIVIL ACTION - LAW VS. NO.Ol-3904 CIVIL TERM MAYNARD S. MARKEL ACTION IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that! may lose rights concerning alimony, division of property, lawyer's fees or expenses if! do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~4904, relating to unsworn falsification to authorities. DATE: /oJy JDj ~Oervu;t~ Plaintiff if--' ~ ';"-"'":,~""-~ ~~llI_!<illWd;~jU~"""ll.~~;,*'--;'H~' ",,.,,:.-n.n,"'-ii""tj'>iJ.~;,,..,'.'!I:t4'iiiM~~jlli:imlar"Uill\~iiiJi!iI1lt!I"~---- U r: I'" ,~: 'I'!.' :e II.;',.....', ': " , ,,' ~': : ~:~, ~-'; f' !' I' I:, ii:'! h: 1..'1 1'1 0 ~~ C) ,,--~,' \3 c: -1'1 <C 0 tJr:2 C'') 0 [pn "-1 .G.._...,_ ,., :Z:C I -r U)..l--:' C..rl -<;::- V'1 KC~' -CO ~t; ~^ .PC -' ;-:::;: ~,-i W ~,...-,~ =2 5:; tN -< ~ " :; r1 1,'1 Ii:,! i~,j n I: I": 1,:1 ii " ili ,) i'] Ii] I c'J- G ~ >-~ .._~ ~_ _ ,.d".",I,,,,,,~,_, '" '""""'!?"~"_'"~'"'',,''''''''''' !)'h,,"_~_,_,A-,' '7~.. . _. .,"" . , ,,. ,,,.,, .., ",'-~ ,if' ;,', -,_"g--_,~l~'_~':;,:-\;:~",,-_, ,~!"'_ ,_J'" . . .,".,.l~""...,JIlVJI~LIf.JlIIU., '. l~r "" ........ "' ~-- '..~ ,.' " " =~iJi"-~k_ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA KlMBERLEA CONRAD CIVIL ACTION - LAW VS. NO.01-3904 CIVIL TERM MAYNARD S. MARKEL ACTION IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under ~330l (c) of the Divorce Code was filed on June 26, 2001. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verifY that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.~4904, relating to unsworn falsification to authorities. DATE: /Y/t!J I ~/f~J ~ 'n ant ~llIiliJ'i';;""''''''~~,U~i:';~;",i",,''ili'il!;Jl,>!i.$41W!M;ER",,:~f'''!'-'''!'~r';J!\,,'~i"b'iiii;!";;:"o",fu',';'roi.*;,;i!'~~lif.iQli'\M~tiljj i ~ ~ "-~ ~_J - k'l h, '1 ',""'1 , f,l I \:'1 l.; I' , I I; Ii 'I II II II n c) !I 0 c ;1 ~- ~J II yf~: '--') C> fller- -, I " 2_., 'I Le- I, ""t" (j) _.::: () II ~;< Vi ~_i....'_, 11 .- .,_J ~~: )>~: I, '1 - 'I :< ' , I..-l ~- i -- I ..., "5 I I I " I C} (J "",.,. , 0' __',", ~_, ~ ,~~=__~"~~,,~=, ~,,,,,,,",b_ J,"","""_,,,.,^~~,~ ,~" '-, "-7, ,_'o,~,-. '"" elf-_ {'.-' I,,",, . ,'~, " ," ,0,; "_"" ''',- ,,1 _,_C~ ~, _,,,-,,4,,,_,~"_,,~,,,"_,,,,' "'__,J""""',' ,~ -"'-, '~-,r"'--. > ~ .."ion __ ,~ ,,' -"'<1 - "_~,=,__ " , ..I j , '-'" -iI" . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA KIMBERLEA CONRAD CIVIL ACTION - LAW VS. NO.OI-3904 CIVIL TERM MAYNARD S. MARKEL ACTION IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~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 1 will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the prothonotary. I verifY that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~4904, relating to unsworn falsification to authorities. ~j.J~ endant DATE: 11(<7/ ~~W<jOiM"lil!'>iiI_~~im~l,;jO"'ffN\""_-~rt'ih"";~~~f",g!'l1~~lNii,~ilI!l;~~_ii6~" ,. ""<---<"-" ~~--, ~~ ~_"""c""",~~I~r"Ii"jr~~"'~I.-~_01'",,;_ ~"', "',,", ,_T"M_ "''''''' C:_~C" ',,'"i"!'",1_'~"'_,,~,,~,_, ',"~___~_','c '1"--" ~""~W"'~~' ~ ~ ~~=" , (") C,;::. C. c ~! D ',,-) 0 ,._~ " -r u <C' , '- l.I\ ~C ) --f-( "'h"""" -'C ~ Z '.v IJJ =< ::.0 ~ ~ Cr cO r (' , i I. I i I , I I f f': I r:; li H "I I:! " I' ,[ II 11 !i 't"", " -" ..,,,, ,'~T."^';7'-- ,~, __ "", " H_,"~' ""f',~o>-_,~"';7 9,...,'_-..."r"."~:>,-'" ,~"""","'''!;\<,' '''"~,"-', ,__ -, ",,,~~,,,;:t,:~