HomeMy WebLinkAbout99-03549
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF PENNA.
DEBRA A. HUBER STOLTZFUS,
.Plaintiff..
Versus
JONATHAN D. STOLTZFUS,
Defendant
No. 99-3549 CIVIL TERM 19
CIVIL ACTION - LAW
IN DIVORCE
DECREE IN
DII VORCEt-3tI tAd
AND NOW, r/. A.. 20.. , ..... , , -11940.., it is ordered and
decreed that . . . . . . . . . DEBRA A. HUBER. STOLTZFUS plaintiff,
....
and ..................JONATHAN, D.• STOLTZFUS............ ......, defendant,
are divorced from the bonds of matrimony.
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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;
NONE
.....................................................
ZB T ^et
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rothonotary
ter.. ta. ,?. ,,?..?;..e:..;?. ;?..r..;?..:e:• ce: tes <e: •:?• :?:• :?> <r.• <?:: _?cr.• c%? ?ce:• •s• ca:• ??> :a ?:?•_c?i. ?a
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DEBRA A. HUBER STOLTZFUS,
Plaintiff
V.
JONATHAN D. STOLTZFUS,
Defendant
IN'1 HE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
99-3549 CIVIL TERM
IN 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:
1. Ground for Divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code.
2. Date and manner of service of complaint: A certified copy of the Complaint in Divorce was served upon
the defendant, Jonathan D. Stoltzfus, on June 14, 1999, by certified, restricted delivery mail, addressed to him at
RRN 1, Box 298, Loysville, Perry County, Pennsylvania 17047, with Return Receipt Number Z 013 345 964.
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: February 25, 2000; by defendant: February 22, 2000.
(b)(1) Date of execution of the affidavit required by Section 3301(d) of the Divorce Code:
(b)(2) Date of filing and service of the plaintiffs affidavit upon the defendant:
4. Related claims pending: NONE.
5. Complete either (a) or (b).
(a) Date and manner of service of the Notice of Intention to file Praecipe to Transmit Record,
a copy of which is attached:
(b) Date plaintiffs Waiver of Notice in Section 3301(c) Divorce was filed with the
Prothonotary: February 29, 2000.
Date defendant's Waiver of Notice in Section 3 (c) Dy?rce was filed with the
Prothonotary: February 29, 2000.
Marcus A. c night, III, Esquire
Attorney fo aintiff
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DEBRA A. HUBER STOLTZFUS IN THE COURT OF COMMON PLEAS OF
Plaintiff
CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
99-3549 CIVIL TERM
JONATHAN D. STOLTZFUS,
Defendant IN DIVORCE
PLAINTIFF'S AFFIDAVIT OF CONSENT
1. A complaint in divorce under Section 3301(c) and 3301(a)(6) of the Divorce Code was
filed on June 10, 1999.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have
elapsed from the date of the filing of the complaint.
3. I consent to the entry of a final decree in divorce.
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 understand that
false statements herein made are subject to the penalties of IS Pa. C. S. Section 4904 relating to
unsworn falsification to authorities.
Date: 2-5 I eOpruAcy 2000
A. ILL st6bL
DEBRA A. HUBER STOLT S
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DEBRA A. HUBER STOLTZFUS,
Plaintiff IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
CIVIL ACTION - LAW
JONATHAN D. STOLTZFUS, 99-3549 CIVIL TERM
Defendant
' IN DIVORCE
DEFENDANT'S AFFIDAVIT OF CONSENT
1. A complaint in divorce under Sections 3301(c) and 3301(a)(6) of the Divorce Code
was filed on June 10, 1999.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have
elapsed from the date of the filing of the complaint.
3. 1 consent to the entry of a final decree in divorce.
4. 1 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 understand that
false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to
unsworn falsification to authorities.
Date: "tea , 2000
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DEBRA A. HUBER STOLTZFUS
Plaintiff
V.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
99-3549 CIVIL TERM
JONATHAN D. STOLTZFUS,
Defendant IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301(c) OF THE DIVORCE CODE
1. I consent to the entry of a final Decree of Divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses 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 made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unswom falsification to authorities.
Date: Z5 F?L;ru ?v , 2000
DEBRA A. HUBER STO FUS
Plaintiff
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DEBRA A. HUBER STOLTZFUS
Plaintiff
V.
JONATHAN D. STOLTZFUS,
Defendant
IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
99-3549 CIVIL TERM
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301 (e) 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 made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unswom falsification to authorities.
Date: ,2 - a-cf?od) 2000
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JONATHAN D.ST TZFUS
Defendant
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DEBRA A. HUBER STOLTZFUS,
Plaintiff
V.
JONATHAN D. STOLTZFUS,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
:99-3549 CIVIL TERM
: IN DIVORCE
AFFIDAVIT OF SERVICE OF COMPLAINT
PURSUANT TO PA. R C P RULE NO 1920.4 (a)(1)(i)
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
. SS:
AND NOW, Marcus A. McKnight, III, Esquire, being duly swom according to law, does
depose and state:
divorce. 1. That he is a competent adult and attorney for the plaintiff in the captioned action in
vorce.
2. That he served a certified copy of the Complaint in Divorce upon the defendant on
June 14, 1999, by certified mail, "restricted delivery" addressed to him at RR# 1, Box 298,
Loysville, Perry County, Pennsylvania 17047, with Return Receipt No. Z 013 345 964.
hereof. 3. That the said receipt for certified mail is signed and is attached hereto and made a part
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa. C. S. Section 4904, relating to
unswom falsification to authorities.
Date: December 23, 1999
Marcus A. N
Attorney for
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Z 013 345 964
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No Insurance Coverage Provided.
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DEBRA A. HUBER STOLTZFUS
Plaintiff
V.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
JONATHAN D. STOLTZFUS,
Defendant
99-3549 CIVIL TERM
IN DIVORCE
DEFENDANT'S MARRIAGE COUNSELING AFFIDAVIT
The defendant, being duly swom according to law, deposes and says:
1. I have been advised of the availability of marriage counseling and understand that I
may request that the court require that my spouse and I participate in counseling.
2. I understand that the court maintains a list of marriage counselors in the Prothonotary's
Office, which list is available to me upon request.
3. Being so advised, I do not request that the court require that my spouse and I
participate in counseling prior to a divorce decree being handed down.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unswom falsification to authorities.
Date:- , 2000
JONATHAN STOLTZFUS
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DEBRA A. HUBER STOLTZFUS,
Petition er/Plaintiff
v.
JONATHAN D. STOLTZFUS,
Respondent/Defendant
CIVIL ACTION - LAW
NO. 99-3549 CIVIL TERM
IN DIVORCE
PETITION FOR ECONOMIC RELIEF
AND NOW, this. 12th day of November, 1999, comes the petitioner, Debra A. Huber
Stoltzfus, by her attorneys, Irwin, McKnight & Hughes, and makes the following Petition for
Economic Relief against the respondent, Jonathan D. Stoltzfus, as follows:
The petitioner is Debra A. Huber Stoltzfus who is the plaintiff in a divorce action filed at
99-3547 in Cumberland County, Pennsylvania. Her address is 100 West Yellow Breeches Road,
Carlisle, Cumberland County, Pennsylvania 17013.
2.
The respondent is Jonathan D. Stoltzfus who is the defendant in this divorce action. His
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
address is R. D. #1, Box 298, Loysville, Perry County, Pennsylvania 17047.
3.
The plaintiff seeks the following relief from the Court:
a. Equitable distribution ofthe marital assets;
b. Alimony pendente lite;
C. Alimony;
d. Costs and expenses; and
e. Counsel fees.
WHEREFORE, the petitioner, Debra A. Huber Stoltzfus, requests the relief set forth
above.
Respectfully submitted,
IRWIN, McKNIGHT & HUGHES
By: ?wa 1.?• ?`/ N ??
Marcus A. McKnight, , Esquir
Attorney for the Plain 'ff/Petitio
pef
Debra A. Huber Sto s
West Pomfret Professional Building
60 West Pomfret Street
Carlisle, Pennsylvania 17013-3222
717-249-2353
Supreme Court I.D. No. 25476
Date: November 12 , 1999
2
VERIFICATION
The foregoing Petition for Economic Relief is based upon information which has
been gathered by counsel and myself in the preparation of this action. I have read the
statements made in this document and they are true and correct to the best of my
knowledge, information and belief. I understand that false statements herein made are
subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to
authorities.
DEBRA A. HUBER STOLTZF
Date: 11 1 9
DEBRA A. HUBER STOLTZFUS,
Petitioner/Plaintiff
V.
JONATHAN D. STOLTZFUS,
Respondent/Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99-3549 CIVIL TERM
IN DIVORCE
CERTIFICATE OF SERVICE
I, Marcus A. McKnight, III, Esquire, hereby certify that a copy of attached Petition for
Economic Relief was served upon the following by depositing a true and correct copy of the
same in the United States mail, First Class, postage prepaid in Carlisle, Pennsylvania,
on the date referenced below and addressed as follows:
Mr. Jonothan D. Stoltzfus
R. D. #I, Box 298
Loysville, PA 17047
IRWIN, McKNIGHT & HUGHES
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77
By: Marcus A. Mc ght, I[, Esquire
60 West Pomfret St e
Carlisle, PA 17013
(717) 249-2353
Supreme Court I.D. No. 25476
Date: November 15, 1999
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PMSYLVANIA
DEBRA A. HUBER STOLTZFUS
Plaintiff
CIVIL ACTION - LAW
IN DIVORCE
Vs.
JONATHAN D. STOLTZFUS
Defendant
NO. 99 - 3549 19
:LOTION FOR APPOIN=IE IT OF MASTER
DEBRA A. HUBER STOLTZFUS (Plaintiff) ( gCat)L, moves the court to appoint
a master with respect to the following claims:
(% ) Divorce (R ) Distribution of Property
( ) Annulment ( ) Support
(A) Alimony (R ) Counsel Fees
(R) Alimony Pendente Lite (x ) Costs and Fxpenses
and in support of the motion states:
(1) Discovery is complete as to the claims(s) for which the
appointment of a master is requested.
(2) The defendant AZ1W (has not) appeared in the action (personally)
(by his attorney, Esquire).
(3) The statutory ground(s) for divorce (is) (are)
3301(6) AND 3301(A)(6)
(4) Delete the inapplicable paragraph(s):
(a) The action is not contested.
(b) An agreement has been reached with respect to the
following claims:
(c) The action is contested with respect to the following
claims: DIVORCE, ALIMONY, ALIMONY PENDENTE LITE, DIST. OF PROPERTY: COUNSEL FEES 6 COSTS.
(5) The action (involves) (does not involve) complex issues of law
or fact.
(6) The hearing is expected to tak
(7) Additional information, if any
Date: DECEMBER 23, 1999
?,??(jj ORDE
A ND NOW ?' 1 ,1
is appointed master with-respect
(dayA).
to t):e motion:
By , e
?? J
DEBRA A. HUBER STOLTZFUS, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
Vs. NO. 99 - 3599 CIVIL
JONATHAN D. STOLTZFUS,
Defendant IN DIVORCE
ORDER OF COURT "
AND NOW, this day of
2000, the economic claims raised in the proceedings having
been resolved in accordance with a marriage settlement
agreement dated February 22, 2000, the appointment of the
Master is vacated and counsel can file a praecipe
transmitting the record to the Court requesting a final
decree in divorce.
BY, THE COURT,
J
cc: Marcus A. McKnight, III
Attorney for Plaintiff
Robert L. O'Brien
Attorney for Defendant
?George E.
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OF THc..:?,C,,?'0"';J PRY
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CUTI6ERLa:J t;GUJ y
FENNS`(Lv9lA
4
MARRIAGE SETTLEMENT AGREEMENT
THIS AGREEMENT made this Z 2. day of February 2000, by and between
DEBRA A. HUBER STOLTZFUS, (hereinafter referred to as "WIFE") and JONATHAN D.
STOLTZFUS, (hereinafter referred to as "HUSBAND").
WITNESSETH:
WHEREAS, HUSBAND and WIFE were lawfully married on March 26, 1994, in
Lancaster, Pennsylvania, and were separated on March 25, 1999. WIFE filed a Divorce Action
in Cumberland County, Pennsylvania, on June 10, 1999, at 99-3549 Civil Term.
The parties hereto agree and covenant as follows:
The parties intend to maintain separate and permanent domiciles and to live apart from
each other. It is the intent and purpose of this Agreement to set forth the respective rights and
duties of the parties while they continue to live apart from each other.
2.
The parties have attempted to divide their matrimonial property in a manner which
conforms to a just and right standard, with due regard to the rights of each parry. It is the intent
of the parties that such division shall be final and shall forever determine their respective rights.
The division of existing marital property is not intended by the parties to constitute in any way a
sale or exchange of assets.
3.
Further, the parties agree to continue living separately and apart from the other at any
place or places that he or she may select as they have heretofore been doing. Neither party shall
molest, harass, annoy, injure, threaten or interfere with the other party in any matter whatsoever.
Each party may cant' on and engage in any employment, profession, business or other activity as
he or she may deem advisable for his or her sole use and benefit. Neither party shall interfere
with the uses, ownership, enjoyment or disposition of any property now owned and not specified
herein or property hereafter acquired by the other.
4.
The consideration for this contract and agreement is the mutual benefit to be obtained by
both of the parties hereto and the covenants and agreements of each of the parties to the other.
The adequacy of the consideration for all agreements herein contained is stipulated, confessed,
and admitted by the parties, and the parties intend to be legally bound hereby.
Each party to the Agreement acknowledges and declares that he or she, respectively:
(1) is represented by counsel of his or her own choosing;
(2) is fully and completely informed of the facts relating to the subject matter of
this Agreement and of the rights and liabilities of the parties;
(3) enters into this Agreement voluntarily after receiving the advice of counsel;
(4) has given careful and mature thought to the making of this Agreement;
(5) has carefully read each provision of this Agreement; and
(6) fully and completely understands each provision of this Agreement, both as to
the subject matter and legal effect.
This Agreement shall become effective immediately as of the date of execution.
5.
It is the purpose and intent of this Agreement to settle forever and completely the interest
and obligations of the parties in all property that they own separately, and all property that would
qualify as marital property under the Pennsylvania Divorce Code, Title 23, Section 401(e), and
that is referred to in this Agreement as "Marital Property", as between themselves, their heirs and
assigns. The parties have attempted to divide their Marital Property in a manner that conforms to
a just and fair standard, with due regard to the rights of each Party. The division of existing
Marital Property is not intended by the parties to constitute in any way a sale or exchange of
assets, and the division is being effected without the introduction of outside funds or other
property not constituting a part of the marital estate.
It is the further purpose of this Agreement to settle forever and completely any obligation
under the Pennsylvania Divorce Code relating to spousal support or alimony.
6.
Each party represents and warrants that he or she has made a full and fair disclosure to the
other of all of his or her property interests of any nature, including any mortgage, pledge, lien,
charge, security interest, encumbrance, or restriction to which any property is subject. Each party
further represents that he or she has made a full and fair disclosure of all debts and obligations of
any nature for which he or she is currently liable or may become liable. Each further represents
and warrants that he or she has not made any gifts or transfers for inadequate consideration of
Marital Property without the prior consent of the other.
Each Party acknowledges that, to the extent desired, he or she has had access to all joint
and separate State and Federal Tax Returns filed by or on behalf of either or both Parties during
marriage.
7.
REAL ESTATE: The parties agree that HUSBAND will convey to WIFE his interest in
the real estate situate in Perry County, Pennsylvania. WIFE will prepare the Deed required to
convey said property to her.
8.
SUPPORT: The parties agree that neither party will seek spousal support or alimony
following the entry of a Divorce Decree from the other party.
9.
PERSONAL PROPERTY: The parties agree that the personal property shall be divided
as follows:
HUSBAND shall receive the following items:
a. The personal property in his possession;
b. His bank accounts;
C. Any Life Insurance Policy;
d. His IRA retirement accounts with Mennonite Mutual; and
e. The farm equipment and the crops situate in Perry County, Pennsylvania.
4
WIFE shall receive the following items:
a. The personal property in her current possession;
b. Her bank accounts;
C. The personal belongings she has at the marital residence;
d. Her retirement account with Mennonite Mutual; and
e. HUSBAND agrees to pay to WIFE the sum of Twenty Eight Thousand
Five Hundred and no/100 ($28,500.00) Dollars of which Three Thousand
Five Hundred and no/100 ($3,500.00) Dollars has already been received
with the balance paid upon the execution of this Agreement.
The WIFE hereby waives all right and title which she may have in any personal property
of the HUSBAND. HUSBAND likewise waives any interest which he has in the personal
property of the WIFE. Henceforth, each of the parties shall own, have and enjoy independently
of any claim or right of the other party, all items of personal property of every kind, nature and
description and wherever situated, which are then owned or held by or which may hereafter
belong to the HUSBAND or WIFE with full power to the HUSBAND or the WIFE to dispose
of same as fully and effectually, in all respects and for all purposes as if he/she were unmarried.
Each party agrees that neither will incur obligations, liens or liabilities on account of the
other and that from the date of this Agreement, neither party shall contract or incur obligations,
liens or any liability whatsoever on account of the other.
10.
AUTOMOBILES:
a. WIFE agrees to waive any and all interest which she may have in HUSBAND's
motor vehicles.
b. HUSBAND agrees to waive any and all interest which he may have in WIFE's
vehicle
5
MARITAL DEBTS & BANKRUPTCY: Each party will be responsible for their own
debt incurred after the date of separation. HUSBAND will be solely responsible for all
outstanding state, local and federal taxes and agrees to hold WIFE harmless and indemnifies
after the date of separation. HUSBAND will be solely responsible for all outstanding state, local
and federal taxes and agrees to hold WIFE harmless and indemnifies her for any claims
regarding the outstanding income taxes. It is hereby understood and agreed by and between the
parties that their obligations pursuant to this agreement shall not be affected by any bankruptcy
proceeding and shall not be deemed to constitute or be a dischargeable debt of a bankruptcy.
Both parties warrant that he/she has not heretofore instituted any proceeding pursuant to the
bankruptcy laws nor are there any such proceedings pending with respect to him/her which have
been initiated by others.
12.
INSURANCE AND EMPLOYEE BENEFITS: The parties agree that any life
insurance policies except as otherwise stated herein on the life of HUSBAND or any other
employee benefits, including but not limited to retirement, profit sharing or medical benefits of
either party, shall be his own. WIFE waives all right, title and claim to HUSBAND's employee
benefits. HUSBAND agrees to maintain the WIFE on his health coverage including dental and
vision coverage at his expense after the entry of a Divorce Decree for a period of six (6) months.
If a new coverage is required, HUSBAND agrees to pay for a period of six (6) months following
the entry of the Divorce Decree.
6
13.
BENEFITS. BANK ACCOUNTS and 1999 INCOME TAX RETURN: WIFE agrees
to waive all right, title and interest which she may have in the savings or checking or any other
bank accounts of the HUSBAND. The HUSBAND agrees to waive all interest which he has in
?D
Dpk+
the bank accounts of the WIFE. WIFE at hiF* a agrees to eeASi the filing of a joint
income tax return for 1999 with HUSBAND. HUSBAND agrees to pay WIFE upon the signing
of said joint return an amount equal to the refund that WIFE would have received if she had filed
married filing single for 1999.
14.
DIVORCE: The parties both agree to cooperate with each other in obtaining a final
divorce of the marriage. It is agreed that the parties will execute and file the consents necessary
to obtain the divorce. Any party who fails to cooperate with obtaining the Divorce shall pay all
the costs and legal fees of the party who is seeking the divorce.
15.
BREACH: 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 should
be responsible for payment of legal fees and costs incurred by the other in enforcing their rights
under this Agreement.
16.
ADDITIONAL INSTRUMENTS: Each of the parties shall from time to time, at the
request of the other, execute, acknowledge and deliver to the other party any and all further
7
instruments that may be reasonably required to give full force and effect to the provisions of this
Agreement.
17.
VOLUNTARY EXECUTION: The provisions of this Agreement and their legal effect
have been fully explained to the parties by their respective counsel, and each party acknowledges
that the Agreement is fair and equitable, and that it is being entered into voluntarily, and that it is
not the result of any duress or undue influence.
The provisions of this Agreement are fully understood by both parties and each party
acknowledges that the Agreement is fair and equitable, that it is being entered into voluntarily,
and that it is not the result of any duress or undue influence.
18.
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.
19.
APPLICABLE LAW: This Agreement shall be construed under the Laws of the
Commonwealth of Pennsylvania.
20.
PRIOR AGREEMENTS: It is understood and agreed that any and all property
settlement agreements which may or have been executed prior to the date and time of this
Agreement are null and void and of no effect.
8
21.
PAYMENT OF COSTS: The parties agree to pay for their own costs required to obtain
and complete the divorce.
22
WAIVER OF CLAIMS AGAINST ESTATES: 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, dower, curtesy, statutory allowance, widow's
allowance, right to take in intestacy, right to take against the Will of the other, and right to act as
administrator or executor of the other's estate, and each will, at the request of the other, execute,
acknowledge and deliver any and all instruments which may be necessary or advisable to cant'
into effect this mutual waiver and relinquishment of all such interests, rights and claims.
IN WITNESS WHEREOF, the parties hereunto have set their hands and seals the day
and year first above written.
4. (SEAL)
DEBRA A. HUBER STOLT r S
?t t?^ (SEAL)
JONATHAN D. STO ZFUS
ax Ti MVicece.
COMMONWEALTH OF PENNSYLVANIA
: SS:
COUNTY OF CUMBERLAND
PERSONALLY APPEARED BEFORE ME, this day of
2000, a Notary Public, in and for the Commonwealth of Pennsylvania and County of
Cumberland, DEBRA A. HUBER STOLTZFUS, known to me (or satisfactorily proven) to be
the person whose name is subscribed to the within Marriage Settlement Agreement, and
acknowledges that she executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and official seal.
. Notanat Seal
D.._: •• Morrison., N,, r -,., io i
CadisL 9oro. Sum^'; no Counm
My Comm,- for Ezoir. DGe.15.2000 i
(viamher, Prarmvitmni- tssc^i4r : c%`• . 91e?
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF
SS:
PERSONALLY APPEARED BEFORE ME, this aA day of`&?2-p?
2000, a Notary Public, in and for the Commonwealth of Pennsylvania and County of
Cumberland, JONATHAN D. STOLTZFUS, known to me (or satisfactorily proven) to be the
person whose name is subscribed to the within Marriage Settlement Agreement , and
acknowledges that he executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and official seal.
Notarial Sr:.l ^
Jonnirer S. l.ineaay. Pu'
Cadislc P.om, Cumout?ana
My Commission E%plres Nov,
Mcmfxr, F'Cnn9dv,vu9 M^.orr:"., r- t!-
10
DEBRA A. HUBER STOLTZFUS IN THE COURT OF COMMON PLEAS OF
Plaintiff
CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
3S'19
99- CIVIL TERM
JONATHAN D. STOLTZFUS,
Defendant IN DIVORCE
NOTICE
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 in 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 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, Cumberland County Courthouse, 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
2 Liberty Avenue
Carlisle, Pennsylvania 17013
717-249-3166
1-800-990-9108
AMERICANS WITH DISABILITIES
ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with
the Americans with Disabilities Act of 1990. For information about accessible facilities and
reasonable accommodations available to disabled individuals having business before the court,
please contact our office. All arrangements must be made at least 72 hours prior to any hearing
or business before the court. You must attend the scheduling conference or hearing.
DEBRA A. HUBER STOLTZFUS
Plaintiff
V.
: IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
99- CIVIL TERM
JONATHAN D.STOLTZFUS,
Defendant
IN DIVORCE
COMPLAINT IN DIVORCE PURSUANT
TO SECTIONS 3301(c) AND 3301(a)(6)
OF THE DIVORCE CODE
NOW comes the plaintiff, Debra A. Huber Stoltzfus, by her attorney, Marcus A.
McKnight, III, Esquire, and files this complaint in divorce against the defendant, Jonathan D.
Stoltzfus, representing as follows:
1. The plaintiff is Debra A. Huber Stoltzfus, an adult individual residing at 100 West
Yellow Breeches Road, Carlisle, Cumberland County, Pennsylvania 17013.
2. The defendant is Jonathan D. Stoltzfus, an adult individual residing at R.R. #1, Box
298, Loysville, Perry County, Pennsylvania 17047.
3. The plaintiff has been a resident of the Commonwealth of Pennsylvania at least six
months prior to the filing of this action in divorce.
4. The plaintiff and the defendant were married on March 26, 1994 in Lancaster,
Pennsylvania and separated on or about March 25, 1999.
5. There were no children bom to this marriage.
6. Pursuant to the Divorce Code, Section 3301(c), the plaintiff avers as the grounds upon
which this action is based that the marriage between the parties is irretrievably broken.
7. There have been no prior actions of divorce or for annulment between the parties.
8. Pursuant to the Divorce Code, Section 3301(a)(6), the plaintiff avers as the grounds
upon which this action is based that the plaintiff is the injured spouse and that the defendant has
offered such indignities to her as to render her condition intolerable and life burdensome.
9. The plaintiff avers that she has been advised of the availability of counseling and that
said party has the right to request that the court require the parties to participate in counseling.
WHEREFORE, the plaintiffdemands judgment
a. Dissolving the marriage between the two parties;
b. Equitably distributing all property, both personal and real,
owned by the parties; and
c. for such further relief as your Honorable Court may deem
equitable and just.
By:
Respectfully submitted,
IRWIN, McKNIGHT & HUGHES
for Plaintiff
We omfret Professions Building
60 West Street
Carlisle, Pennsylvania 17013
(717) 249-2353
Supreme Court I.D. No. 25476
III, Esquire
Date: June 11 1999
VERIFICATION
The foregoing Complaint in Divorce is based upon information which has been gathered
by my counsel and me in the preparation of this action. I have read the statements made in this
Complaint and they are true and correct to the best of my knowledge, information and belief. I
understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section
4904, relating to unsworn falsification to authorities.
" A. I U
DEBRA A. HUBER STOLT S
Date: June--7. 1999
DEBRA A. HUBER STOLTZFUS,
Plaintiff
V.
JONATHAN D. STOLTZFUS,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
99- CIVIL TERM
IN DIVORCE
PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT
The Plaintiff, being duly sworn according to law, deposes and says:
1. I have been advised of the availability of marriage counseling and understand that I
may request that the court require that my spouse and I participate in counseling.
2. 1 understand that the court maintains a list of marriage counselors in the Prothonotary's
Office, which list is available to me upon request.
3. Being so advised, I do not request that the court require that my spouse and I
participate in counseling prior to a divorce decree being handed down.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unworn falsification to authorities.
Date: June .1999 ? A ( 4
DEBRA A. HUBER STO FUS
LAW OFFICES
IRWIN MCKNIGHT & HUGHES
ROGER R. IRII'IN
MARCUSA. McKNIGHT, II1
JAMES D. BUGHES
REBECCA R. RUCHES
MARK D..SCIIIIARr7.
DOUGLAS G. MILLER
WEST POMFRET PROFESSIONAL BUILDING
60 WEST POMFRET STREET
CARLISLE, PENNSYLVANIA 17013.3222
(717) 249-2353
FAX (717) 249.6354
E-MAIL: IMHLAWO SUPERNET COM
If. IR011) S. IR IYIN (19.17.1977)
11AROU)S,IRN'IKJR. (1914-1986)
IRWI,V/RIVINSIRIVIA' (1916-1986)
IRWIN, IRIITN& AIcAl IQ- 11986-1994)
/R N'LV, 6fcRh7CillT&llU(illES /1441- /
March 1, 2000
E. Robert Elicker, 11, Divorce Master
13 North Hanover Street
Carlisle, PA 17013
Re: Debra A. Huber Stoltzfus v. Jonathan D. Stoltzfus
Dear Bob:
The parties have resolved this case. 1 have enclosed a copy of the Marriage Settlement
Agreement. Please vacate your appointment.
Very truly yours,
IRWIN, McKNICMT & HUGHES
A.
MAM/min
Encl.
cc: Robert L. O'Brien, Esq.
Ms. Debra A. Huber Stoltzfus
I
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Vs. I?
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 9?, CIVIL 19
IN DIVORCE I!
STATUS SHEET
DATE: ACTIVITIES:
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DEBRA A. HUBER STOLTZFUS, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. NO. 99 - 3599 CIVIL
JONATHAN D. STOLTZFUS,
Defendant IN DIVORCE
TO: Marcus A. McKnight Attorney for Plaintiff
Jonathan D. Stoltzfus Defendant
DATE: Tuesday, January 9, 2000
CERTIFICATION
I certify that discovery is complete as to the claims
for which the Master has been appointed.
OR IF DISCOVERY IS NOT COMPLETE:
(a) Outline what information is required that is not
complete in order to prepare the case for trial
and indicate whether there are any outstanding
interrogatories or discovery motions.
(b) Provide approximate date when discovery will be
complete and indicate what action is being taken
to complete discovery.
DATE COUNSEL FOR PLAINTIFF ( )
COUNSEL FOR DEFENDANT ( )
NOTE: PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE
FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE
CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE
AT THE MASTER'S DISCRETION.
AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL
OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY
COUNSEL, INDICATING THAT DISCOVERY IS NOT
COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL
STATEMENTS WILL BE ISSUED AT THE MASTER'S
DISCRETION. HOWEVER, IF BOTH COUNSEL, OR A
PARTY NOT REPRESENTED, CERTIFY THAT DISCOVERY
IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL
STATEMENTS WILL BE ISSUED IKMEDIATELY.
THE CERTIFICATION DOCUMENT SHOULD BE RETURNED
TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF
THE DATE SHOWN ON THE DOCUMENT.
cc: Arthur K. Dils, Esquire
IN THE COURT OF COMMON PLEAS OF CUMBFtiRj.AND COUNTY. PENNSYLVANIA
DOMESTIC RELATIONS SECTION
DEBRA A. STOLTZEFtc
OBLIGEE
9 ?-,?S-41?
APL NO. G
JONATHAN D. STOLTZFUA
OBLIGOR
Fa c. Se.s -4* '1 *810171o'Z
APPEAL OF COURT ORDER
DATE OF ORDER not received
AMOUNT OF ORDER $600.00 FOR THE SUPPORT OF
DEBRA -A. STOLTZPUq
DATE OF APPEAL JANUARY F_ 2nnn
REASON FOR APPEAL AMOUNT IS EXCESSIVE
NAME OF OBLIGOR/OBLIGEE REQUESTING APPEAL JONATHAN D. STOLTZFUS
SIGNATURE. OF ATTORNEY OR OBLIGOR/OBLIGEE
#497
F" Wil Pennsylvania State Collection and Disbursement Unit (PA SCDU)
IMPORTANT INFORMATION
1. Remit a signed check or money order payable to PA SCDU. DO NOT ENCLOSE CASH OR CORRESPONDENCE.
Write the Member ID on the check or money order. Remit coupon with payment.
2. Print the amount paid In the field marked "AMOUNT ENCLOSED
3. If the address is no longer valid, mark the CHANGE OF ADDRESS box and indicate the changes
on the PAYMENT COUPON.
4. Please use the envelopes and coupons provided to remit support payments. DISCARD ANY UNUSED COUPONS.
P. If you have any questions regarding this bill, contact your Domestic Relations Section.
III III I,,,III.,.,I„II.,, I I,I,.I,III ,II„I,,,ll11..1„1„I, I,I
JONATHAN D STOLTZFUS 14
RR 1 BOX 298
LOYSVILLE PA 17047-9767
pay-try-phone, contact the PA SCDU
If you would like Information on additional
payment options via credit card payments,
recurring automatic withdrawals, or
Customer Service Unit at 1.1177-PASSCDU.
MONTHLY STATEMENT OF ACCOUNT
;pol-762.1
PAYER MEMBERID: 1654100436 SSN: 164-56-6616
AS OF: 12/27/1999 AMOUNTDUE: $600.00
CASE ID # CURRENT AMOUNT ARREARS BALANCE
788101762 $600.00 $1,100.00
Pennsylvania State Collection and Disbursement Unit (PA SCDU) - 1-877-PAS-SCDU
PAYMENT COUPON
u i-'
r
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n
SOCIAL SECURITY INFORMATION SHEET
PURSUANT TO 23 Pa.C.S.A. SECTION 4304.1 (a) (3) ALL DIVORCES MUST
INCLUDE THE PARTIES SOCIAL SECURITY NUMBER ?-
PLEASE FILL IN THE APPROPRIATE INFORMATION AND RETURN TO THE
PROTHONOTARY'S OFFICE
DATE: February 28, 2000
DOCKET NUMBER: 99-3549 Civil Term
PLAINTIFF SS# 203-48-5953
NAME: Debra A. Huber Stoltzfus
DEFENDANTS SS # 164-56-6616
NAME: Jonathan D. Stoltzfus
...:?
l..
l?? J
IN
DEBRA A. HUBER STOLTZFUS,
Plaintiff/Pctitioncr
DR 29,212
PACSES ID 788101762
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
VS. DOMESTIC RELATIONS SECTION
CIVIL ACTION - LAW
JONATHAN D. STOLT/,FUS,
Defendant/Respondcnt NO. 99-3549 CIVIL TERM
ORDER OF COURT
AND NOW, this 27'h day of December, 1999, based upon the Court's determination that
Petitioner's monthly net income/earning capacity is $954.97 per month and Respondent's monthly net
income/earning capacity is $3,253.98 per month, it is hereby Ordered that the Respondent pay to the
Pennsylvania State Collection and Disbursement Unit, $600.00 a month payable monthly as follows;
$550.00 a month for alimony pendente lite and $50.00 a month on arrears. First payment due on or
before January 10, 2000 and on or before the 10th day of each month thereafter. Arrears set at
$1,100.00 as of December 27, 1999. The effective date of the order is November 15, 1999.
Husband is to maintain medical insurance coverage on wife until wife can obtain medical
insurance at a reasonable cost.
Failure to make each payment on time and in full will cause all arrears to become subject to
immediate collection by all of the means as provided by 23 Pa.C.S.§ 3703. Further, if the Court finds,
after hearing, that the Respondent has willfully failed to comply with this Order, it may declare the
Respondent in civil contempt of Court and its discretion make an appropriate Order, including, but not
limited to, commitment of the Respondent to prison for a period not to exceed six months.
Said money to be turned over by the PA SCDU to: Debra A. Huber Stoltzfus. Payments must
be made by check or money order. All checks and money orders must be made payable to PA SCDU
and mailed to:
PA SCDU
P.O. Box 69110
Harrisburg, PA 17106-91 10
Payments must include the defendant's PACSES Member Number or Social Security Number in order
to be processed. Do not send cash by mail.
Unreimbursed medical expenses that exceed $250.00 annually are to be paid 0% by the
respondent and 100% by petitioner. The plaintiff is responsible to pay the first $250.00 annually in
unreimbursed medical expenses. Respondent to provide medical insurance coverage. Within thirty
(30) days after the entry of this order, the Respondent shall submit written proof that medical
insurance coverage has been obtained or that application for coverage has been made. Proof of
coverage shall consist, at a minimum, of: 1) the name of the health care coverage provider(s); 2) any
applicable identification numbers; 3) any cards evidencing coverage; 4) the address to which claims
should be made; 5) a description of any restrictions on usage, such as prior approval for hospital
admissions, and the manner of obtaining approval; 6) a copy of the benefit booklet or coverage
contract; 7) a description of all deductibles and co-payments; and 8) five copies of any claim forms.
This Order shall become final ten days after the mailing of the notice of the entry of the Order
to the parties unless either party files a written demand with the Prothonotary for a hearing de novo
before the Court.
DRO: R. J. Shadday BY THE COURT,
Mailed copies on Petitioner
/--3-co to: < Respondent
Marcus McKnight, III, Esquire
`? zr'?52Z
J. /Wesley Oler, J . J.
4:
.If
DEBRA A. HUBER STOLTZFUS,
Plaintiff/Petitioner
VS.
JONATHAN D. STOLTZFUS,
Defendant/Respondent
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - DIVORCE
NO.99-3549 CIVILTERM
IN DIVORCE
DR# 29,212
Pacses# 788101762
ORDER OF COURT
AND NOW, this 7u' day of December, 1999, upon consideration of the attached Petition for
Alimony Pendenle Lite and/or counsel fees, it is hereby directed that the parties and their respective
counsel appear before R.J. Shad dav on December 21, 1999 at 9.00 A.M for a conference, at 13 N.
Hanover St., Carlisle, PA 17013, after which the conference officer may recommend that an Order for
Alimony Pendenle Lite be entered.
YOU are further ordered to bring to the conference
(1) a true copy of your most recent Federal Income Tax Return, including W-2's as filed
(2) your pay stubs for the preceding six (6) months
(3) the Income and Expense Statement attached to this order, completed as required by Rule
1910.110
(4) verification of child care expenses
(5) proof of medical coverage which you may have, or may have available to you
IF you fail to appear for the conference or bring the required documents, the Court may issue a
warrant for your arrest.
BY THE COURT,
George E. Hoffer, President Judge
Mail Copies on Petitioner
t2=7 99 W ` < Respondent
Marcus McKnight, Esquire
Date of Order: December 7. 1999
R. J. adday, Conference OOicer
YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND
REPRESENT YOU. 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 MAY GET
LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVE.
CARLISLE, PENNSYLVANIA 17013
(717) 249-3166
;`3 DrC -9 i ; 4; In
DEBRA A. HUBER STOLTZFUS,
Petitioner/Plaintiff
V.
JONATHAN D. STOLTZFUS,
Respondent/Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99-3549 CIVIL TERM
IN DIVORCE
PETITION FOR ALIMONY PENDENTE LITE
AND NOW, this 12 th day of November, 1999, comes Debra A. Huber Stoltzfus, by and
through her attorneys, IRWIN, McKNIGHT & HUGHES, and petitions this Honorable Court as
follows:
The petitioner/plaintiff is Debra A. Huber Stoltzfus who currently resides at
100 West Yellow Breeches Road, Carlisle, Pennsylvania 17013.
2.
The respondent/defendant herein is Jonathan D. Stoltzfus who currently resides at R. D. #1, Box
298, Loysville, Pennsylvania 17047.
3.
Petitioner and respondent were married on March 26, 1994, in Lancaster County,
Pennsylvania, and were separated on or about March 25, 1999.
4.
WHEREFORE, petitioner, Debra A. Huber Stoltzfus, respectfully requests that this
Honorable Court order alimony pendente lite in an amount equal to the Pennsylvania State
Support Guidelines.
Respectfully submitted,
IRWIN, MANIGHT & HUGHES
Marcus A. Me
"d *9 ?t, II, Es i
60 West Pomfret 'treet
Carlisle, PA 17013
Supreme Court I.D. No: 25476
(717) 249-2353
Attorney for the Petitioner/Plaintiff
Debra A. Huber Stoltzfus
Date: November 12, 1999
2
VERIFICATION
The foregoing Petition for Alimony Pendente Lite is based upon information
which has been gathered by counsel and myself in the preparation of this action. I have
read the statements made in this document and they are true and correct to the best of my
knowledge, information and belief. I understand that false statements herein made are
subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unswom falsification to
authorities.
4t--
DEBRA A. HUBER STO ' FUS
Date: /1
DEBRA A. HUBER STOLTZFUS,
Petitioner/Plaintiff
V.
JONATHAN D. STOLTZFUS,
Respondent/Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99-3549 CIVIL TERM
IN DIVORCE
CERTIFICATE OF SERVICE
I, Marcus A. McKnight, III, Esquire, hereby certify that a copy of attached Petition for
Alimony Pendente Lite was served upon the following by depositing a true and correct copy of
the same in the United States mail, First Class, postage prepaid in Carlisle, Pennsylvania,
on the date referenced below and addressed as follows:
Mr. Jonothan D. Stoltzfus
R. D. #I, Box 298
Loysville, PA 17047
IRWIN, McKNIGHT & HUGHES
By: Marcus A. McK
60 West Pomfret
Carlisle, PA 17013
(717) 249-2353
Supreme Court I.D. No. 25476
Date: November 15, 1999
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In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
DEBRA A. HUBER STOLTZFUS ) Docket Numher
99-3549 CIVIL
Plaintiff )
VS. ) PACSES Case Number 788101762/0,)-/a
JONATHAN D. STOLTZFUS )
Defendant j Other State ID Number
Order
AND NOW to wit, this MARCH 3, 2000 it is hereby Ordered
that:
THE ABOVE CAPTIONED ORDER OF ALIMONY PENDENTE LITE IS TERMINATED, EFFECTIVE
FEBRUARY 25, 2000, WITH A BALANCE OF $1,239.66. SAID BALANCE IS TO BE PAID
IN FULL WITHIN THIRTY (30) DAYS UPON RECEIPT OF THIS ORDER.
BY THE COURT:
DRO: RJ Shadday
xc: pla.intiff
defendant
Marcus McKnight, Esquire
Fn .r. R+O
N, e
Service Type M
UM
Form OE-001
Worker ID 21005
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f:)
DEBRA A. HUBER STOLTZFUS,
Plaintiff
V.
JONATHAN D. STOLTZFUS,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
99-3549 CIVIL TERM
IN DIVORCE
NOTICE OF INTENTION TO
RETAKE AND USE PRIOR NAME
1, DEBRA A. HUBER STOLTZFUS, hereby give notice, avowing my intention to
resume and hereafter use my prior surname, to wit: DEBRA A. HUBER, in accordance with the
provisions of the Act of December 16, 1982, P.L. 1309, No. 295, Section 704(a) (54 Pa. C.S.A.
704(a) ). My divorce, docketed to 99-3549 Civil Term, was granted on March 20
2000.
1 verify that the statements made in this document are true and correct. 1 understand that
false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unworn falsification to authorities.
IN WITNESS WHEREOF, I have hereunto set my hand and seal this 21st day of
March 2000.
WITNESSED:
:?),L , a' L' e--., / U I
e._(SEAL)
DEBRA A. HUBER STOLTZF
TO BE KNOWN AS:
)P LLLI_(SEAL)
DEBRA A. HUBER
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