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HomeMy WebLinkAbout99-03849 1 A s W a; al Z V 1 i i i i?: i a r is IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. FA • PAUL J. BALDARI, 99-3849 CIVIL TERM _ Plaintiff `u. Vci:,us TAMMY A. BALDARI, Defendant DECREE IN DIVORCE AND NOW, ..........61L.s0 ¢.? .., z-7.7.• 19.99..., it is ordered and PAUL J. BALDARI decreed that .................................................. plaintiff, and . . . . . . . . . . . . . . . . . TAM . MY .. A. .BALDARI ..... , defendant, ....................... are divorced from the bonds of matrimony. The court retains jurisdiction of the following claims which have been raised of record in this action for which a final order has not yet been entered; The attached Property Settlement Agreenent dated October 11, 1999 is .................................................... hereby incorporated into this Decree Divorce. ......... ......................in. ................................. D y T c C o u r t Attes ^ J. 0 Prothonotary +i:• {??•s:•?w• +ar.• c?> cis •:?> :?:• •w> :?• :c• ;e: ;?> :?:• :?::?: <?:• c?: •:?:.. 6r. s:. :e:• W. •:o: :V: <s• cV• te. O i r ii i y 0 i i i .01 aw THIS AGREEMENT, made this day of?w,G? 1999, by and between PAUL J. BALDARI, residing at 37 Drexel Place, New Cumberland, Cumberland County, Pennsylvania, hereinafter referred to as "HUSBAND," and TAMMY A. BALDARI, residing at 806 Hummel Avenue, Lemoyne, Cumberland County, Pennsylvania, hereinafter referred to as "WIFE." WITNESSETH: WHEREAS, the parties were lawfully married on July 27, 1980, in Mifflin County, Pennsylvania and separated on or about June 1, 1999; and WHEREAS, the parties are the natural parents of three minor children, JOHNATHAN S. BALDARI, age 16, whose date of birth is December 5, 1982; MARY CATHERINE BALDARI, age 12, whose date of birth is December 27, 1986; and NATHANIEL J. BALDARI, age 2, whose date of birth is April 29, 1997; and WHEREAS, in consequence of disputes and unhappy difficulties, the parties have agreed to live separate and apart during their natural lives; and WHEREAS, the parties are desirous of settling their existing property rights including an amicable equitable distribution, assignment and division of their property, which property is considered to be "marital property" as defined in the Divorce Code known as Act 26 of 1980, and amendments thereto enacted into law on February 12, 1988; and NOW THEREFORE, in consideration of the promises and the mutual undertaking herein contained and for other good and valuable consideration, the parties, intending to be legally bound, agree as follows: 1. Separation. The parties shall hereinafter live separate and apart. Each shall be free from interference, authority, and control, direct and indirect, by the other as if he or she were single and unmarried. 2. Control of Agreement. The provisions of this Property Settlement Agreement shall govern all past, present and/or future claims for alimony, spousal support, counsel fees and costs, alimony pendente lite, equitable distribution, or other property rights, and all other claims which the WIFE or HUSBAND has or might have against the other. 3. Divorce. A Complaint in Divorce was filed by HUSBAND in Cumberland County on or about June 24, 1999, which Complaint is docketed to No. 99-3849. The Complaint in Divorce was served upon WIFE on or about July 7, 1999, via certified mail, restricted delivery. Upon the expiration of 90 days from July 7, 1999, the parties agree to sign any and all documents necessary to obtain a Divorce Decree under Section 3301(c) of the Pennsylvania Divorce Code, including but not limited to, Affidavits of Consent, Affidavits Waiving Marriage Counseling, and Waivers of Notice of Intent to Seek Divorce under Section 3301(c) of the Divorce Code. In the event that either parry refuses to sign the above documents within ten (10) days of the above referenced period, that party shall have breached this Agreement and the non- breaching party shall be entitled to collect any and all attorneys fees and costs in connection with enforcing this Agreement. In that event, this Agreement shall remain in full force and effect, and shall not be affacted by such breach. The parties intend that this Agreement shall be incorporated into any forthcoming Decree in Divorce. 4. Real Property. The parties acknowledge that they are the owners as tenants by the entirety of real property located at 806 Hummel Avenue, Lemoyne, Cumberland County, Pennsylvania. Simultaneously with the execution of this Agreement, HUSBAND shall convey all of his right, title, and interest in and to the marital residence to WIFE, and HUSBAND shall immediately execute now and in the future, any and all deeds, documents, or papers necessary to effect such transfer of title upon request. WIFE agrees to assume and timely pay in full the remaining balance of the mortgage with Countrywide Mortgage Company, and/or any other mortgage company to which the parties loan is assigned, and further agrees to indemnify and hold HUSBAND harmless from any and all liability as a result of her non-payment or non-performance of the mortgage obligations. Said transfer shall be effective immediately upon WIFE's execution of this Agreement. WIFE shall also remain solely responsible for all bills in connection with the marital home including but not limited to taxes, insurance, utilities and general maintenance. 5. Custody. The parties are the natural parents of three (3) minor children; JOHNATHAN S. BALDARI, age 16, whose date of birth is December 5,1982; MARY CATHERINE BALDARI, age 12, whose date of birth Is December 27, 1986; and NATHANIEL J. BALDARI, age 2, whose date of birth is April 29, 1997. The parties agree that the children shall reside on a primary basis with WIFE, and that HUSBAND shall be entitled to liberal periods of partial custody as per the parties mutual agreement. 6. Personal E=eerty. The parties have acquired certain personal property during the course of their marriage and hereby acknowledge and represent that such personal property, including household furnishings and other similar property, has been divided to their mutual satisfaction. Neither party shall make any claim to any items in the other person's possession or items under the other person's control. Furthermore, each party agrees to waive any right, title, and/or interest he or she may have in and to the property belonging to the other. Should it become necessary, the parties each agree to sign upon request, any titles or documents necessary to give effect to this paragraph. 7. Automobiles. The parties are the joint owners of a 1994 Plymouth Voyager which shall become the sole and separate property of WIFE, subject to any liens and/or encumbrances. WIFE agrees to indemnify and hold HUSBAND harmless with respect to any such encumbrance on the above vehicle. There is a 1988 Honda Civic which shall become the sole and separate property of HUSBAND, subject to any liens and/or encumbrances. HUSBAND agrees to indemnify and hold WIFE harmless with respect to any such encumbrance on the above vehicle. The titles to the above motor vehicles shall be executed by the parties, if appropriate, for effecting the transfers as herein provided, on the date of execution of this Agreement if the title is in possession of one or the other party. In the event that either or all of the documents of title to the said vehicles shall be in the hands of a bank or other holder of the lien or encumbrance upon said vehicle, the parties agree to advise such bank or holder as to the transfer of title set forth herein, and they further agree to execute whatever documents may be required to transfer said title within thirty (30) days of the execution of this Agreement. Each party agrees to waive any right, title or interest he or she may have in the vehicle of the other, and promptly sign any and all documents necessary to effectuate the above referenced transfers. 8. Child Si port. HUSBAND shall pay to WIFE, the sum of One Thousand Four Hundred ($1,400.00) Dollars per month for the support of the parties three (3) minor children until they reach the age of eighteen (18) or graduate from high school, whichever event occurs later. The child support amount shall be allocated Four Hundred and Sixty Six ($466.66) Dollars and Sixty Six Cents per child. Payments shall be made directly to WIFE and no wage attachment shall occur. Furthermore, HUSBAND agrees to continue to provide health and medical insurance for the minor children as is made available through his present employer. 9. Pension and Retirement Benefits. Each party shall retain as their sole and separate property any individual retirement account, and/or retirement benefit plan (including but not limited to pension or profit sharing plans, deferred compensation plans, defined benefit plans, 401(k) plans, employee savings and thrift plans, IRA's, or other similar benefits) now titled in their respective names, whether vested or non-vested. The above shall specifically include a waiver of any spousal annuity benefits and/or beneficiary designations thereunder. The parties represent that they are aware of the values in each others retirement accounts and/or specifically waive the right to request any further documentation thereon. Furthermore, each party shall be and remain the sole owner of any other asset in his or her control not specifically covered by other provisions of this Agreement. Should it become necessary, each party agrees to sign any other title or documents necessary to give effect to this section upon request of either party. 10. Checking and/or Savings Accounts. There is a joint checking and savings account with PSECU in the approximate amount of One Thousand Three Hundred ($1,300.00) Dollars, which shall be equally divided between the parties immediately. All other checking and/or savings accounts have been divided to the parties' mutual satisfaction. 11. Other Investment Accounts. The parties acknowledge and represent that there are no other Investment Accounts of any kind that can be considered marital property. 12. Alimonv Spousal Support Alimony Pendente r u< Counsel Fees Cost and Emens; S. Each party specifically waives any and all claims against the other party for past, present or future alimony, spousal support, APL, counsel fees, and costs and expenses. 13. Credit Card Debt. approximated Three Thousand Six Hundred ($3,600.00) and which was comprised of the following: MASTERCARD = $2,000.00 VISA = $1,300.00 AMOCO = $ 300.0 0 $3,600.00 The consolidation loan is in WIFE'S name alone and is with Z-Al U S The parties agree that HUSBAND shall pay to WIFE, the sum of One Hundred and Fifty ($150.00) Dollars per month for 12 months from the date of this Agreement in order to satisfy his portion of the marital debt. There is no other joint credit card debt or other debt that could be considered marital in existence. Any other credit card debt in either parties name shall be the sole responsibility of the person who incurred it. 14. focal/aneous Debt. Any debt not specifically listed in this Agreement and/or incurred after the date of this Agreement shall be the sole and separate responsibility of the party who incurred it. 15. Agreement Executed Voluntari/y and Clearly Understood. Each party to this Agreement acknowledges and declares that he or she respectively: A. If fully and completely informed as to the facts relating to the subject matter of this Agreement, and as to the rights and liabilities of both parties; B. Enters into this Agreement voluntarily, free from fraud, undue influence, coercion or duress of any kind; C. Has given careful and mature thought to the making of this Agreement; D. Has carefully read each provision of this Agreement; The parties recently consolidated their marital credit card debt which E. Acknowledges that there has been a full and fair financial disclosure by both parties, and fully and completely understands each provision of this Agreement. 16. Release of All Claims. Each party releases the other from all claims, liabilities, debts, obligations, actions and causes of action of every kind that have been or will be incurred. Moreover, neither party is relieved or discharged from any obligation under this Agreement or any instrument or document executed pursuant to this Agreement. 17. Holding Other Party Free and Harmless. HUSBAND hereby warrants to WIFE that he has not incurred and he hereby agrees that he will not hereafter incur any liability or obligation on which she is or may be liable. If any claim or action is brought attempting to hold WIFE liable for any such liability or obligation, HUSBAND shall, at his sole expense, defend WIFE against any such claim or action whether or not founded, and he shall hold her free and harmless therefrom. WIFE hereby warrants to HUSBAND that she has not incurred and she hereby agrees that she will not hereafter incur any liability or obligation on which he is or may be liable. If any claim or action is brought attempting to hold HUSBAND liable for any such liability or obligation, WIFE shall, at her sole expense, defend HUSBAND against any such claim or action whether or not founded, and she shall hold him free and harmless therefrom. 18. Additional Instruments. The parties shall, on demand, execute and deliver to the other, any document, and do or cause to be done, any other act or thing that may be necessary or desirable to effectuate the provisions and purposes of this Agreement. If either party fails, on demand, to comply with this provision, that party shall pay to the other, all attorney's fees, costs and other expenses reasonably incurred as a result of such failure. 19. Full Disclosure. The respective parties do hereby warrant, represent, and declare, and do acknowledge and agree that each is and has been fully and completely informed of, and is familiar with and cognizant of the wealth, income, real and/or personal property, whether jointly or individually titled, estate and assets of the other, and that each has made a full and complete disclosure to the other of his and her entire assets and liabilities, and any further enumeration or statement thereof in this Agreement is hereby specifically waived. The parties do not wish to make or append hereto any further enumeration or statement. Each of the parties hereto further covenants and agrees for himself or herself that his or her heirs, personal representatives and assigns, that he or she will never at any time hereafter sue the other or his or her heirs, personal representatives or assigns, in any action or contention, direct or indirect, that there was any absence or lack of full and proper disclosure. Further, both parties waive their right to have the inventory or financial disclosure statement of the other attached hereto. 20. Roresentation of the Parties. HUSBAND is represented by Johnson, Duffle, Stewart & Weidner, in connection with the negotiation and preparation of this Agreement. WIFE has been given the opportunity to consult with independent legal counsel of her choice. WIFE understands that Johnson, Duffle, Stewart & Weidner represented HUSBAND only throughout this matter and WIFE further understands that Johnson, Duffle, Stewart & Weidner cannot and did not render any legal advice to WIFE. Each party has carefully read this Agreement and is completely aware not only of its contents but also of its legal effect. Each party acknowledges and accepts that this Agreement, in the circumstances, is fair and equitable, and that it is being entered into freely and voluntarily, 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 improper or illegal Agreement and/or Agreements. 21. Waiver of Rights to Other Party' t te. Except as provided for herein, HUSBAND and WIFE each waive any and all right: A. To inherit any part of the estate of the other at his or her death, except as provided herein; B. To receive property from the estate of the other by bequest or devise except under a Will or Codicil dated subsequently to the effective date of this Agreement; C. To act as personal representative of the estate of the other on intestacy unless nominated by another party legally entitled to so act; D. To act as the personal representative under the Will of the other unless so nominated by a Will or Codicil dated subsequently to the effective date of this Agreement; E. To claim a family allowance in the estate of the other. 22. Containment of Entire Agreement Herein. This Agreement supersedes any and all other Agreements, either oral or in writing, between the parties relating to the rights and liabilities arising out of their marriage. This Agreement contains the entire agreement of the parties. 23. PartialInvalidlty. If any portion of this Agreement is held by a Court of competent jurisdiction to be invalid, void, or unenforceable, the remaining provisions shall, nevertheless, continue in full force and effect without being impaired or invalidated in any way. 24 Effest_of_Reconciliation, Cohabitation.-or. Divorc"-Qsm-e. The terms of this Agreement shall be incorporated into any Divorce Decree which may be entered with respect to the parties. This Agreement shall survive any such final judgment or Decree of Divorce. Both parties shall have all rights and enforcement under applicable law including the Pennsylvania Divorce Code. This Agreement shall also remain in full force and effect even if the parties effect a reconciliation, cohabitate as Husband and Wife, or attempt to effect a reconciliation. 25. M_2dification. This Agreement shall not be subject to modification except as in accordance with Pennsylvania law and with a writing between both parties evidencing their intent to modify the Agreement. 26. No Waite! of Default This Agreement shall remain in full force and effect unless and until terminated under and pursuant to the terms of this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall not be construed as a waiver of any subsequent default of the same or similar nature. 27. Attorneys_Fees_and_Expenses. Each party shall be responsible for their own attorneys fees and expenses. 26. VMulu -operallon. Each of the parties shall, on demand, execute and deliver to the other, pLiCi any deeds, bills of sale, quit claims, assignments, consents, tax returns, and other documents and do or cause to be done any other acts or things as may be necessary or desirable to effectuate the provisions and purposes of this Agreement. If either party fails on demand to comply with this provision, that party shall pay to the other all attorney's fees, costs and other expenses reasonably incurred as a result of such failure. 29. Bankruptcy. Each of the parties acknowledges and agrees that with respect to the liabilities each is required to assume and pay ruder the provisions of this Agreement, each has the ability to fulfill his or her respective obligations from income or property not reasonably necessary to be expended for such party's maintenance and support or for the maintenance and support of such party's dependents. Should either party file a Petition under Title XI of the United Stales Code, or should a petition be filed against either Involuntarily, each party acknowledges and agrees that the discharge of the debtor party's obligations under this Agreement will not result in a benefit to the debtor party that outweighs the detrimental consequence to the non-debtor party or the non-debtor party's child or children. 30. Law of Pennsylvania 11cab/e. This Agreement shall be construed in accordance with the laws of the Commonwealth of Pennsylvania. 31. Date of Agreement. The effective date of this Agreement shall be the date on which the last party executes the Agreement if the parties do not execute the Agreement on the same date. Otherwise, the effective date will be the date that both parties execute the Agreement if they execute on the same date. 32. Successors and AssW . This Agreement, except as otherwise expressly provided herein, shall be binding on and shall inure to the benefit of the respective legatees, devisees, heirs, executors, administrators, assigns and successors and interest of the parties. IN WITNESS WHEREOF, the parties hereby have hereunto set their hands and seals the date and year first above written. WITNESS: e/.r y Date aul J..ari /D Da am A. 4y_ldarri 125165 COMMONWEALTH OF PENNSYLVANIA ss: COUNTY OF (rt r& L 6 4 14 ? On this, the / 4? day of cb b'c ? , 1999, before me the undersigned officer, personally appeared PAUL J. BALDARI known to me or satisfactorily proven to be the person whose name is subscribed to the foregoing instrument and acknowledge that she executed the same for the purposes therein contained. ,,4NV /.TNESS WHEREOF, I hereunto set my hand and official seal. COMMONWEALTH OF PENNSYLVANIA COUNTY OF ss: On this, the01t day of 0C fOie ez , 1999, before me the undersigned officer, personally appeared TAMMY A. BALDARI, known to me or satisfactorily proven to be the person whose name is subscribed to the foregoing instrument and acknowledge that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. Notary Public MOO ; E%71r ozurr ?t MY Commissar EKpves Juy 19.2GuJ . >- T L co ? y I wn ci z ppg ?3 z Ci- U ?zz it;ra U m o PAUL J. BALDARI, Plaintiff VS. TAMY A. BALDARI, Defendant IN THE COURT OF CQ*1ON PLEAS OF CUMBERLAND C JNPY, PENNSYLVANIA gyp. 99-3849 CIVIL 19 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. Grounds for divorce: irretrievable breakdown under Section 3301 (c) o£ the Divorce Code. (Strike out inapplicable section) 2. Date and manner of service of the complaint: Certified mail, restricted delivery to the Defendant on June 28, 1999 and received by Defendant on July 7, 1999. 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 the plaintiff October 11, 1999 by the defendant October 11, 1999 B. (1) Date of execution of the plaintiff's affidavit required by Section 3301 (d) of the Divorce Code: (2) Date of service of the plaintiff's affidavit upon the defendant: 4. Related claims pending: None. 5. Indicate date and manner of service of the notice of intention to file praecipe to transmit record, and attach a copy of said notice under Section 3301 (d)(1)(i) of the Divorce Code Waiver of Notice of Intention to Request Entry of a Divorce Decree signed by Plaintiff on October 11, 1999 and Defendant on tobe 11, 1999. ZiLlb, c Attorr y for Plaintiff /0UPGOONt --t 1- Ceirsten W. Davidson z F aa... d n J V cr, Johnson, Duffle, Stewart & Weidner By: Keirsten W. Davidson I.D. No. 78243 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff PAUL J. BALDARI, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 99- 24q,y CIVIL TERM V. CIVIL ACTION - LAW TAMMY A. BALDARI, 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 pages 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 Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE THE 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 Telephone: (717) 249-3166 Johnson, Duffle, Stewart & Weidner By: Keirsten W. Davidson I.D. No. 78243 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 PAUL J. BALDARI, V. TAMMY A. BALDARI, Plaintiff Defendant Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99- 3 b'V `/ CIVIL TERM CIVIL ACTION - LAW IN DIVORCE AND NOW, comes the Plaintiff, Paul J. Baldari, by and through his attorneys, Johnson, Duffle, Stewart & Weidner, and files the following Divorce Complaint against the Defendant, Tammy A. Baldari: 1. The Plaintiff is Paul J. Baldari, an adult individual, residing at 37 Drexel Place, New Cumberland, Cumberland County, Pennsylvania 17070. 2. The Defendant is Tammy A. Baldari, an adult individual, who is currently residing at 806 Hummel Avenue, Lemoyne, Cumberland County, Pennsylvania 17011-6768. 3. The Plaintiff and Defendant were married on July 27, 1980, in Lewistown, Mifflin County, Pennsylvania. 4. The Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania at least six months immediately prior to the filing of this Complaint. 5. There has been no prior action for divorce or annulment of marriage between the parties in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. The Plaintiff has been advised of the availability of marriage counseling and he may have the right to request that the Court require the parties to participate in counseling. WHEREFORE, the Plaintiff respectfully requests that your Honorable Court enter a decree of divorce under Section 3301(c) or 3301(d) of the Divorce Code. JOHNSON, DUFFIE, STEWART & WEIDNER By: u"l' , , F ;Y?wi? Keirsten W. Davidson :123522 I verify that the statements made in this Divorce Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are made subject to the penalties of 18 Pa. C.S.A §4904, relating to unsworn falsification to authorities. Date: Paul J. Baldari Johnson, Duffle, Stewart & Weidner By: Keirsten W. Davidson I.D. No. 78243 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 PAUL J. BALDARI, V. TAMMY A. BALDARI, Plaintiff Defendant IN DIVORCE PAUL J. BALDARI, being duly sworn according to law, deposes and says: 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 by the court. 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 unswom falsification to authorities. Date: _ - j Paul J. Baldari Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99- CIVIL TERM CIVIL ACTION - LAW ? N Johnson, Duffle, Stewart & Weidner By: Keirsten W. Davidson I.D. No. 78243 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 PAUL J. BALDARI, Plaintiff V. TAMMY A. BALDARI, Defendant Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-3849 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE I hereby certify that on the 28" day of June, 1999, 1 served a true and correct copy of the foregoing Complaint in Divorce upon the Defendant, Tammy A. Baldari, by certified mail, restricted delivery, to her mailing address at 806 Hummel Avenue, Lemoyne, Pennsylvania 17043, return receipt requested, attached hereto and made a part hereof. JOHNSON, DUFFIE, STEWART 8, WEIDNER Date: July 13, 1999 By:? n - [' Keirsten . Davidson 123522-6 t t I 2 i 8 IL N a Z 026 626 900 US Postal Service Receipt for Certified Mail No Insurance Coverage Provided. Do not use for International Mall See rererse Sentto S nrr6A/ d lJ (p Ahe (G?.Y E Pos £stw,in', R /761/3 $ Fee Spedsi Dasrery Fee 1' aaelaed Delvery Fee i^ /?? Whwn a o*,.W ro 3 N 1 ?v f lelen aeLepl9neiy p ynern, dY,6Mdrecesl AEdep TOTAL Postage A Fees S Peeenere or Date Kwp ll7.3?' l . ?m?++=ec«...'^X+a*wT±+?en<...zra,^mran.-w..,:mn?; •..,.;mra!m•X?vR'.'?fTrcseN,. :MWOsfs aims t sMbrft for sdaeaW ssrvloss. I CaaplNeasmsa M andM 1 also wish to ma" dte , , . e?yoyuorunone am sues on au nNres or sW ram so gW" aurrNtm this fobm e?fog) services (for an s sAA?armsrcryYn6mb the (WA ofar"10scs. a m the back a rimes doss not tt,.arM •MOW t. p Addressee's Address slurn RK flrgsrerred'on tlM nt L gyn.. e..._ n???,?.Wq -,. _.__ ._ ? .. alpiese below the mNds rmarlher. 2 flk-RasMCfed DsI1VB B. PS ry Consult postmaster for fee. ' co "' :. Ui_ X41 -? Ci,u LL cn i ?' m u Johnson, Duffle, Stewart & Weidner By: Keirsten W. Davidson I.D. No. 78243 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff PAUL J. BALDARI, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 99-3849 CIVIL TERM V. CIVIL ACTION - LAW TAMMY A. BALDARI, IN DIVORCE Defendant 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on June 24, 1999. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3. 1 consent to the entry of a final decree in divorce after service of notice of intention to request entry of the decree. 4. 1 have been advised of the availability of marriage counseling, understand that the Court maintains a list of marriage counselors and that I may request the Court require my spouse and I to participate in counseling and, being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to the divorce becoming final. 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 unswom falsification to authorities. Date: :127557 ul J. Baldari, Plaintiff ?s c 0- C-3 in CY% Johnson, Duffle, Stewart & Weidner By: Keirsten W. Davidson I.D. No. 78243 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 PAUL J. BALDARI, Plaintiff V. TAMMY A. BALDARI, Defendant 1. I consent to the entry of a final decree in divorce without notice. IN DIVORCE 2. 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. 3. 1 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 unswom falsification to authorities. Date: Pa . Baldari, Plaintiff Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-3849 CIVIL TERM CIVIL ACTION - LAW 127557 ¢} O co g ¢y<< O ¢Z um' Ot ? Johnson, Duffle, Stewart & Weidner By: Keirsten W. Davidson I.D. No. 78243 Attorneys for Plaintiff 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 PAUL J. BALDARI, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. 99-3849 CIVIL TERM V. CIVIL ACTION - LAW TAMMY A. BALDARI, IN DIVORCE Defendant 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on June 24, 1999. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3. 1 consent to the entry of a final decree in divorce after service of notice of intention to request entry of the decree. 4. 1 have been advised of the availability of marriage counseling, understand that the Court maintains a list of marriage counselors and that I may request the Court require my spouse and I to participate in counseling and, being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to the divorce becoming final. 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 unswom falsification to authorities. Date: 0 // T my A. Baldari, Defendant :127557 } in CV) 3 N Ott: L ~ y ? W (1 7 i . C $[ 1 U cm Johnson, Duffle, Stewart & Weidner By: Keirsten W. Davidson I.D. No. 78243 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 PAUL J. BALDARI, Plafntiff V. TAMMY A. BALDARI, Defendant 1. I consent to the entry of a final decree in divorce without notice. IN DIVORCE 2. 1 understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. 1 understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unswom falsification to authorities Date: / ?--- (% ammy A. Baldari, Defendant :127557 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-3849 CIVIL TERM CIVIL ACTION - LAW ?$ ,r?? {3r rn _,?, ,.,. o m ? ?