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HomeMy WebLinkAbout99-03212 i e u e i i i i i 6 0 to+:s cs; c?•. ? .• as , ? „r•: ? ?: •:eta :e•_ ? W• :?•<s ;e; IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. .... AARON.. F. - MCLAUGHL IN ..................... ............... ..... II No .....9.9-a.ziz .... ................. 19 ..... pl ' t•ff aan..1 ....... ................. ............. i Versus it ..... NOBLE..LEE..MCLAUGHLIN,._. ..... ........ ._ _.........Defendant_.. i DE CRE E IN D1 V 0 I R C E AND NOW, ..........Q.ua.v?.. •Z •r ' , • , 14 P7. • . , it is ordered and decreed that ........... ....... AARON F. MCLAUGHLIN plaintiff, and .................... ........ NPSLE. L• U. NG4AUGNLIN..... ..... defendant, are divorced from the bonds of matrimony. The court retains jurisdiction of the following claims which have o been raised of record in this action for which a final order has not yet been entered; The parties hereby incorporate their. Marriage Settlement Agreement. dated. October. 12,.1999 ....................... fly Th C,"/ / Atle.st: - 1 Prothonotary ff 1• r?. /i 5 9P y/? ?Av .Z le/ MARRIAGE S .TT MFNT AGREEMENT THIS AGREEMENT, made this L,2, day of L 6 6 r- , 1999, by and between NOBLE LEE MCLAUGHLIN, hereinafter referred to as Wife, and AARON F. MCLAUGHLIN, hereinafter referred to as Husband, WITNESSETH: WHEREAS, the parties hereto are Husband and Wife, having been married on May 21, 1983, in Carlisle, Cumberland County, Pennsylvania; and WHEREAS, there have been two children born of this marriage, namely, Jeremiah A. McLaughlin, born October 2, 1985, and Casey W. McLaughlin, born August 24, 1989; and WHEREAS, diverse unhappy differences, disputes, misunderstandings and difficulties have arisen between the parties as a result of which they are living separately and apart. WHEREAS, the parties desire to confirm their separation and make arrangements in connection therewith, including the settling of their property rights and other rights and obligations growing out of their marriage; and WHEREAS, it is the desire of the parties to effect a complete and full settlement with respect to any and all claims, obligations, rights, duties and responsibilities of the parties with respect to the marriage;-'including but not limited to financial and property rights and obligations betweeir tach other, in accordance with the provisions of the Divorce Code. NOW, THEREFORE, considering the above conditions and circumstances, and in consideration of the covenants and promises hereinafter to be mutually kept and performed by each party, as well as for other good and valuable consideration, and intending to be legally bound hereby, it is agreed as follows: 1. It shall be lawful for each party at all times hereafter to live separate and apart from the other party, at such place or places as he or she from time to time may choose or deem frt. 2. Each party shall be free from interference, authority and control, direct or indirect, by the other as fully as if he or she were single and unmarried. Neither shall molest the other or compel or endeavor to compel the other to cohabitate or dwell with him or her. 3. Wife relinquishes her inchoate intestate right in the estate of Husband, and Husband relinquishes his inchoate intestate right in the estate of Wife, 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 a matter or thing done, omitted or suffered to be done by said party prior to and including the date hereof, except that this release shall in no way affect any cause of action in any absolute divorce which either party may have against the other, nor shall this release affect any cause of action which either party may have against the other of whatever nature, arising or which may arise, under this Agreement or for the breach of any provision thereof. 4. It is understood and agreed by the parties hereto that Husband has filed an action in divorce in the Court of Common Pleas of Cumberland County in which he has alleged that the marriage is irretrievably under Section 3301(c) of the Pennsylvania Divorce Code. Both parties further understand and agree that Husband shall continue to pursue said divorce on said grounds and that both parties will file the necessary affidavits of consent and all other petitions and documents necessary to effectuate the divorce. In any event, the parties shall be bound by all the terms and provisions of this agreement and this agreement may be submitted to the Court for approval pursuant to the Pennsylvania Divorce Code with a request that it be incorporated into the final decree but in any event, this agreement shall survive any divorce decree, 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 continue to be enforceable in accordance with the terms. 5. The parties have attempted to distribute their marital property in a manner which conforms to the criteria set forth in Section 3502 of the Pennsylvania Divorce Code, and have taken into account all considerations set forth therein. The division of existing marital property is not intended by the parties to constitute in any way a sale or exchange of assets, and a division is being effected without the introduction of outside funds or property not constituting marital property. The division of property under this Agreement shall be in full satisfaction of all marital rights and any other rights of the parties. 6. Except as otherwise specifically set forth herein the parties have divided between them to their mutual satisfaction the personal effects, household furniture and furnishings, and all other articles of personal property which have heretofore been used by them in common, and neither will make any claim to any such items which are now in the possession or control of the other. This Agreement shall have the effect of an assignment or bill of sale from each party to the other for such property as may be in the individual possession of each of the parties hereto, and should it become necessary, the parties each agree to sign any titles or documents necessary to give effect to this paragraph upon request. 4 7. The parties hereto are owners as tenants by the entirety of real estate situate at 525 South Spring Garden Street, Carlisle, Cumberland County, Pennsylvania, more particularly described in Deed Book 172, Page 1057. Wife shall convey to Husband her interest in said real property and agrees that she will have no further claim to any right, title or interest in said property and Wife shall sign any and all documents necessary to give effect to the provisions of this paragraph including but not limited to a special warranty deed for the property which deed shall be prepared by Husband's attorney. It is understood and agreed that Wife shall execute and deliver such special warranty deed for the property at the time of the execution of this Agreement. On and after the date of the execution of this Agreement, Husband herein shall assume and be responsible for all obligations on the property including but not limited to the existing Mortgage at Associates Home Equity, all real estate taxes, repairs, utilities, maintenance and insurance. Husband agrees to indemnify and save and hold harmless Wife from any and all liability and/or claims and/or damages and /or expense that `:'i,c may sustain or for which she may become liable in any way whatsoever with regard to the mortgage and mortgage payments, and/or any other expense relating to the property referred to herein. 8. The Parties have divided between them to their mutual satisfaction all savings and checking accounts heretofore used by them during their marriage. 9. The 1996'6eo Tracker currently titled in both names shall become the absolute property of Wife and Husband relinquishes any and all right, title and interest he may have in said vehicle. Wife shall assume the responsibility for the payment of the loan on said vehicle at Dauphin Deposit Hank and Trust Company until such time as that loan is paid, in full. Wife agrees to indemnify and save and hold harmless Husband from any and all liability and/or 5 claims and/or damages and /or expense that Husband may sustain or for which he may become liable in any way whatsoever with the regard to the automobile loan referred to herein. At such time as the Dauphin Deposit loan is paid in full and the title is released to Wife, Husband agrees that he will execute any and all documents that may be deemed necessary in order to transfer legal title for the vehicle to Wife. 10. The 1972 Chevrolet Pick Up truck and the 1985 Harley Davidson motorcycle both currently titled in Husband's name shall remain the sole and absolute property of Husband and Wife relinquishes any and all right, title and interest she may have in either vehicle. 11. Wife shall assume and be responsible for the payment of the outstanding balances due on the J.C. Penney account and the Bon Ton account and Wife shall indemnify and hold harmless Husband for any and all liability and/or claims and/or damages and/or expense that Husband may sustain or for which he may become liable in any way whatsoever in regard to these debts and obligations. 12. Husband shall assume and be responsible for the payment of the outstanding balances due on the Sears account, the Gordons account, PNC Bank and Norwest Financial and Husband shall indemnify and hold harmless Wife for any and all liability and/or claims and/or damages and/or expense that Wife may sustain or for which she may become liable in any way whatsoever*m regard to these debts and obligations. 13. Both parties relinquish and waive all right, title, claim or interest either may have in the employee benefits of the other including but not limited to retirement plans, pension . plans, IRA's and deferred compensation plans. Both parties agree to sign any releases that 6 may be required to effect his or her renunciation of any interest in the other parties' pension or retirement plan. 14. Husband shall have primary physical custody of the minor children bom of this marriage, with Wife to have liberal partial custody and visitation with said children as the parties may mutually agree. The liberal partial custody that Wife shall be entitled to under the terms of this agreement shall include overnight stays with Wife, holidays and vacations upon reasonable notice being given by Wife to Husband. The parties shall have shared legal custody, care and charge of the children born of this marriage as provided for in 23 Pa. C.S.A. 5301 et. seq. Both parties acknowledge that it is in the best interests of the children to remain close to both parents and the parties shall confer with each other on all important matters pertaining to the children's health, welfare, education and maintenance with a view toward obtaining and following a harmonious policy in the children's best interests and shall keep each other informed of the progress of the children's health, education and social adjustments. 15. In lieu of child support payments made through the Domestic Relations Office of Cumberland County, Wife agrees that she will be responsible for and pay to Husband or in the alternative, directly for the benefit of the children one-half of all of the children's expenses. Should Wife fail to contribute to the children's expenses as provided for herein Husband shall retain the option of filing to obtain a support order in accordance with the law in effect at that time. 16, Wife agrees to provide medical and hospitalization insurance, dental insurance and vision insurance for the benefit of said children through her employment and so long as said children are elligible for said coverage. 17. Each of the parties shall hereafter own and enjoy, independently of any claims or rights of the other, all real property and all items of personal property, tangible or intangible, acquired after the date of separation of the parties or hereafter acquired by him or her, with full power in him or her to dispose of the same as fully and effectively, in all respects and for all purposes, as though he or she were unmarried. 18. Except as otherwise specifically provided for herein, both parties specifically waive any and all rights they may have at present or hereafter may have for spousal support and further waive any and all rights they may have at present or hereafter may have for alimony, alimony pendente lite or separate maintenance and support as provided in Section 3701 and Section 3702 of the Divorce Code. 19. Each party shall be individually responsible for the payment of his or her own respective attorneys' fees and costs both for the negotiation and preparation of this Agreement and also for the divorce action previously filed by Husband. 20. Except for any debt or obligation of either party to the other under this Agreement, each party hereby agrees to save and hold the other harmless from all personal debts and obligations incurred by him or her from the date hereof. 8 21. Each parry represents and warrants to the other that he or she has not incurred any debt, obligation or other liability other than described in this Agreement on which the other party is or may be liable. Each party covenants and agrees that if any claim, action or proceeding is hereinafter instituted seeking to hold the other party liable for any other debts, obligations, liability, act or omission of such party, such party will, at his or her sole expense, defend the other against any such claim or demand, whether or not well-founded, and that he or she will indemnify and hold harmless the other party in respect to all damages resulting therefrom. Each party hereby releases the other from all claims, liabilities, debts, obligations, actions and causes of action of every kind that have been or will be incurred relating to or arising from the marriage between the parties. However, neither party is relieved or discharged from any obligation under this Agreement, or under any instrument or document executed pursuant to this Agreement. 22. Neither party shall contract any debt or liability for which the other party or his or her property or estate might be responsible, and shall indemnify and save the other harmless from any and all claims and demands made against him or her by reason of the debts or obligations incurred by the other party. 23. If either party breaches any provisions 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 available to him or her, and the party breaching this contract shall be responsible f'or payment of reasonable legal fees and costs incurred by the other in enforcing his or her rights under this Agreement. 9 24. Each party acknowledges that he or she has received or has had the opportunity to receive independent legal advice from counsel of his or her selection, and each fully understands the facts and has been fully informed as to his or her legal rights and obligations, and each party acknowledges and accepts that this Agreement is, under the circumstances, fair and equitable, and that it is being entered into freely and voluntarily after having received such advice and with such knowledge, and that the 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 agreements. 25. Each party shall, from time to time, at the request of the other, execute, acknowledge and deliver to the other party any and all further instruments which may be reasonably required to give full force and effect to the provisions of this Agreement. 26. 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. 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 which have been taken into consideration by the parties. Both parties hereby accept the provisions of this Agreement with'respect to the division of property in lieu of and in full and final settlement and satisfaction of all claims and demands that they may now have or hereafter may have against the other for equitable distribution of their property by any court of competent jurisdiction pursuant to Section 3502 of the Divorce code or any other laws. Husband and Wife each voluntarily and intelligently waive and relinquish any right to seek a court-ordered 10 determination and distribution of marital property, but nothing herein contained shall constitute a waiver by either party of any rights to seek relief of any court for the purpose of enforcing the provisions of this Agreement. 27. A 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 the 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. 28. This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania. 29. If any term, condition or clause or provision of this Agreement shall be determined or declared to be void or invalid in law or otherwise, then only that term, condition, clause or provision shall be stricken from this Agreement, and in all other respects this Agreement shall be valid and continue in full force, operation and effect. 30. This Agreement shall be binding and shall inure to the benefit of the parties hereto and to their respective heirs, executors, administrators, successors and assigns. IN WITNESS WHEREOF, the parties hereto, intending to be legally bound hereby, have hereunto set their hands and seals the day and year first above written. Aaron F. McLaughlin(-' v l? oa /?/ColaHy'n-(SEAL) Noble Lee McLaughlin ` II COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND ) SS. On this, the day of -?? , 1999, before me, the undersigned officer, personalty appeared NOBLE LEE MCLAUGHLIN, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purposes therein contained. NOTARIAL SEAL SHELLY SEXTON, NOTARY PUBLIC CARLISLE BORO, CUMBERLAND COUNTY MY COMMISSION EXPIRES APRIL 28, 200 Iem0er, Pennsylvania Ass,ulation of Notaries Notary COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND ) SS. On this, the day of OCk0 1999, before me, the undersigned officer, personally appeared AARON F. MCLAUGHLIN, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that tit: executed the same for the purposes therein contained. `? NOTAflY PUBLIC IkI ME L SEAL /? (SEAL) BERLAND COUNTY iRES APRIL 28, 2003 Notar bliC r^c:zuon or Notaries ti Cy C J- I) .= r C\j . IyJ L.- CU ... ?1 ? alt: 1--- ? ? I Ji 1.1 U (D cr% J a1 fj AARON F. MCLAUGHLIN, Plaintiff V. NOBLE LEE MCLAUGHLIN Defendant TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-3212 CIVIL TERM IN DIVORCE Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code. 2 Date and manner of service of the complaint: May 28. 1999, restricted certified mail return receipt requested 3. (a) Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by the Plaintiff October 22. 1999; by Defendant October 12. 1999. 4. Related claims pending: NONE 5. Date Plaintiffs Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: i??Zz?; ANDREWS & JOHNSON Date: October 22, 1999 Ronald E.Johnso , q.' 78 West Pomfret eet Carlisle, PA 17013 (717) 243-0123 Supreme Court ID No. 16453 11'` U`c _ Jty C: r J J n.: C\j N r cif;; 1-. ?.• -• V co L;1LJ .. 4 L? O ? , J v r? II Q h? 1 n? V '^ / ' X Z ¢ M x .? cn o fn 0 ¢ u ?z° . 3Cd Uv A? L t ? I 11 11 1 AARON F. MCLAUGHLIN, V. NOBLE LEE MCLAUGHLIN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW :NO. 99- 310-- CIVIL TERM Defendant : IN DIVORCE 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, High and Hanover Streets, Carlisle. 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, PA 17013 Phone: (717) 249-3166 AARON F. MCLAUGHLIN, V. : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA NOBLE LEE MCLAUGHLIN, Defendant CIVIL ACTION - LAW NO. 99- ,3.RI.X,, CIVIL TERM IN DIVORCE COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE 1. Plaintiff is AARON F. MCLAUGHLIN, who currently resides at 525 South Spring Garden Street, Cumberland County, Pennsylvania, since June 1993. 2. Defendant is NOBLE LEE MCLAUGHLIN, who currently resides at 145 West Pomfret Street, 2nd Floor, Carlisle, Cumberland County, Pennsylvania, since May 1999. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on May 21, 1983, at Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. 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. 8. Plaintiff requests the Court to enter a Decree of Divorce. 1 I verify that the statements made in this Complaint are true and correct. 1 understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworn falsification to authorities. Date: S 14-4ffl - 2 k; 2) Z&2 n -- Aaron McLaughlin, Plain f ANDREWS & JOHNSON Ronald E. Johns n, Attorneys for ai 78 W. Pomfre tree Carlisle, PA 17013 (717) 243-0123 AARON F. MCLAUGHLIN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW NOBLE LEE MCLAUGHLIN : NO. 99-3212 CIVIL TERM Defendant : IN DIVORCE 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on May 27, 1999. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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:_ IU z?lc?g Aaron F. McLaughlin, flaintiff C'4 N N `L 7'c = n mac: w e N .. N t= o , a rn v AARON F. MCLAUGHLIN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW NOBLE LEE MCLAUGHLIN NO. 99-3212 CIVIL TERM Defendant IN DIVORCE 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on May 27, 1999. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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 unworn falsification to authorities. Date:. /d,/l 2/5? Inc Noble Lee McLaughlin, Defendant CV 4 F- Uci J (L F' o ? U AARON F. MCLAUGHLIN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NOBLE LEE MCLAUGHLIN NO. 99-3212 CIVIL TERM Defendant 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 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. c Date: _ /0 ?.2 2 /9 q O ??i?,r Aaron F. McLaughlin, ainti y _o CJ-- ("" 1 5 (If J O J !; CL CT U AARON F. MCLAUGHLIN, Plaintiff V. NOBLE LEE MCLAUGHLIN Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 99-3212 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(c) OF THE DIVORCE CODE 1. 1 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. §4904, relating to unsworn falsification to authorities. Date: /Db,2 Noble Lee McLaughlin, Defertda . t!J cC O cn v C\j N n V iil C...) (.l] p_ cn J cn v AARON F. MCLAUGHLIN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW NOBLE LEE MCLAUGHLIN, : NO. 99-?;a(2 CIVIL TERM Defendant : IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND AND NOW, this _2nd_, day of June, 1999, I, Ronald E. Johnson, Esquire, attorney for Aaron F. McLaughlin, Plaintiff in the above-captioned action, hereby swear that I have served a true copy of the Complaint in Divorce, with Notice to Defend and Claim Rights, executed by the Plaintiff in the above-captioned matter, upon the Defendant at her residence at 145 West Pomfret Street, by depositing the same in the U.S. Mail, postage prepaid, certified, deliver to addressee only, return receipt requested. A copy of the return receipt card signed by the Defendant on May 28, 1999, indicating service was effected, is marked Exhibit "A", attached hereto and made a part hereof. ANDREWS & JOHNSON By: U vv I Ronald E. Johff so Attorney for Pl?i tiff Swom and subscribed to before me this _2nd_ day of June, 1999. 1 Not y 'ub? c NOTARIAL SEAL SHELLY SEXTON, NOTARY PUBLIC CARLISLE BORO, CUMBERLAND COUNTY MY COMMISSION EXPIRES APRIL 26, 2003 Member, Pennsylvania Association of Notaries i Y SENDER: •CorryNNe Neme 1 enNa 21or a0dlbrwl eorriwe. 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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, / PENNSYLVANIA Plaintiff Vs File No. Qa IN DIVORCE cJPOr/ ,?• //Linen/iZ , Defendant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff / defendant in the above matter, [select one by marking "x"] prior to the entry of a Final Decree in Divorce, or y after the entry o) a FinaJl )ccree in Divorce dated a•' a / od• dao ? ( f6u.<n' .? hereby elects to resume the prior s mame of Wt'&1'e'4 and gives this written notice avowing his / her intention pursuant to the rov. 'o o£5 S. 704. Date: .?'o270.? C[!1 iGic ature Signature of name being resumed COIVMIONW LTH OF PENNSYLVANIA ) COUNTY O urn. On th day of , 201L?, before me, the Prothonotary or the IT- notary public, personally appeared the above af6ant known to me to be the person whose name is subscribed to the within document and acknowledged that he / 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. c? `v = U . cv 75 U cam. C j Q? .Edd. n QLJ Crw J /