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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF PENNA.
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Rodney ec it
... 19 99
Nl)..... 4043 ........ .............
Plaintiff,
? } Versus
Lynn Albright Meck,
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Defendant. 'i
DE
D
AND NOW,.. .?c.c.c•:%? ? -
Rodney S.
decreed that ..................
Lynn Albr
and ............................
CREE IN
IVORCE
Z 19V.. , it is ordered and
Meck
............. ................. plaintiff,
fight Meck , , , , 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 s
been entered;
None. The Marital Settlement Agreement executed by. the. parties on December
...............................................................
8t ,1999,,is,igcgrpqXaCed.beteiu,.but.shall. not. be. merged. into. said. Decree.
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• S:\WPOOCS\DOMESTIMMSAImeck.msa.WfJ
November 16, 1999
MARITAL SETTLEMENT AGREEMENT
THIS AGREEMENT, made this day of __, 1999, by and
between RODNEY S. MECK of Virginia Beach, Virginia, (hereinafter "HUSBAND") and
LYNN ALBRIGHT MECK of Ventnor, New Jersey, (hereinafter "WIFE");
WITNESSETH:
WHEREAS, the parties hereto were married on January 4, 1992, in Dauphin County,
Pennsylvania; and
WHEREAS, a divorce action was filed by HUSBAND on or about July 1, 1999, in the
Cumberland County Court of Common Pleas at 99-4043 CIVIL ACTION -LAW; and
WHEREAS, difficulties have arisen between the parties and it is therefore their
intention to live separate and apart for the rest of their lives and the parties are desirous of
settling completely the economic and other rights and obligations between each other,
including, but not limited to: the equitable distribution of the marital property; past, present
and future support; alimony, alimony pendente lite; and, in general, any and all other claims
and possible claims by one against the other or against their respective estates; and
NOW THEREFORE, in consideration of the covenants and promises hereinafter to be
kept and performed by each party and intending to be legally bound hereby, the parties do
hereby agree as follows:
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November 16, 1999.
1. ADVICE OF COUNSEL.
The provisions of this agreement and their legal effect have been fully explained
to the parties by their respective counsel. WIFE is unrepresented. HUSBAND is represented
by Debra Denison Cantor, Esquire.
The parties further declare that each is executing the Agreement freely and
voluntarily having either obtained sufficient knowledge and disclosure of their respective legal
rights and obligations or, if counsel has not been consulted, expressly waiving the right to
obtain such knowledge. The parties each acknowledge that this Agreement is fair and
equitable and is not the result of any fraud, coercion, duress, undue influence or collusion.
2. DIVORCE ACTION.
The parties acknowledge that their marriage is irretrievably broken and that they
shall secure a mutual consent no fault divorce pursuant to § 3301(c) of the Divorce Code. The
parties agree to execute Affidavits of Consent for divorce and Waivers of Notice of Intention to
Request Entry of a Divorce Decree concurrently with the execution of this Agreement.
This Agreement shall remain in full force and effect after such time as a final
decree in divorce may be entered with respect to the parties. The parties agree that the terms
of this agreement shall be incorporated into any Divorce Decree which may be entered with
respect to them and specifically referenced in the Divorce Decree. This Agreement shall not
merge with the divorce decree, but shall continue to have independent contractual significance.
3. DATE OF EXECUTION.
The "date of execution" or "execution date" of this Agreement shall be defined as
the date upon which it is executed by the parties if they have each executed the Agreement on
the same date. Otherwise, the "date of execution" or "execution date" of this Agreement shall
be defined as the date of execution by the party last executing this Agreement.
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November'16,1999,
4. MUTUAL RELEASES.
Each party absolutely and unconditionally releases the other and the estate of the
other from any and all rights and obligations which either may have for past, present, or future
obligations, arising out of the marital relationship or otherwise, including all rights and
benefits under the Pennsylvania Divorce Code of 1980, and amendments except as described
herein.
Each party absolutely and unconditionally releases the other and his or her heirs,
executors and estate from any claims arising by virtue of the marital relationship of the
parties. The above release shall be effective whether such claims arise by way of widow's or
widower's rights, family exemption, or under the intestate laws, or the right to take against
the spouse's will, or the right to treat a lifetime conveyance by the other as testamentary, or
all other rights of a surviving spouse to participate in a deceased spouse's estate, whether
arising under the laws of Pennsylvania, any state, Commonwealth, or territory of the United
States, or any other country.
Except for any cause of action for divorce which either party may have or claim
to have, each party gives to the other by the execution of this Agreement an absolute and
unconditional release from all claims whatsoever, in law or in equity which either party now
has against the other.
5. FINANCIAL AND PROCEDURAL DISCLOSURE.
The parties confirm that each has relied on the accuracy of the financial disclosure
of the other as an inducement to the execution of this Agreement. Each party understands that
he/she had the right to obtain from the other party a complete inventory or list of all property
that either or both parties owned at the time of separation or currently and that each party had
the right to have all such property valued by means of appraisals or otherwise. Both parties
understand that they have a right to have a court hold hearings and make decisions on the
matters covered by this Agreement. Both parties hereby acknowledge that this Agreement is
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Novemberl6, 1999
fair and equitable, and that the terms adequately provide for his or her interests, and that this
Agreement is not a result of fraud, duress or undue influence exercised by either party upon
the other or by any person or persons upon either party.
6. SEPARATION/NON INTERFERENCE.
WIFE and HUSBAND may and shall, at all times hereafter, live separate and
apart. They shall be free from any interference, direct or indirect, by the other in all respects
as fully as if they were unmarried. Each may, for his or her separate use or benefit, conduct,
carry on and engage in any business, occupation, profession or employment which to him or her
may seem advisable. WIFE and HUSBAND shall not harass, disturb or malign each other or
the respective families of each other.
7. REAL PROPERTY.
The parties were the joint owners of real property located at 1004 Baythorne
Drive, Mechanicsburg, Pennsylvania, 17055. Said marital property has been sold and the
proceeds of said sale have been divided by agreement of the parties.
The parties have purchased post-separation real estate. Wife owns real property
located at 2 South Harvard Avenue, Ventnor, New Jersey, 08406. HUSBAND owns real
property located at 2576 Cantwell Road, Virginia Beach, Virginia, 23456. The parties hereby
waive any right, title and interest they may have in the post-separation real property of the
other.
8. DEBTS.
HUSBAND represents and warrants to WIFE that since the separation he has
not, and in the future he will not, contract or incur any debt or liability for which WIFE or her
estate might be responsible, and he shall indemnify and save WIFE harmless from any and all
claims or demands made against her by reason of such debts or obligations incurred by him
since the date of said separation, except as otherwise set forth herein.
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Nevember'16, 1999
WIFE represents and warrants to HUSBAND that, since the separation she has
not, and in the future she will not, contract or incur any debt or liability for which HUSBAND
or his estzte might be responsible, and she shall indemnify and save HUSBAND barr-decs from
any and all claims or demands made against him by reason of such debts or obligations
incurred by her since the date of said separation, except as otherwise set forth herein.
9. RETIREMENT BENEFITS
The parties are the owners of a 401K Plan through their respective employers.
HUSBAND hereby waives his right, title and interest to WIFE's retirement
benefits. WIFE hereby waives her right, title and interest to HUSBAND's retirement benefits.
The parties waive any and all other retirement benefits obtained by the parties
post separation. The individual who holds said benefits shall own the property solely and
individually. Each party waives their right to title and interest to the other party's benefit.
10. BANK ACCOUNTS.
The parties acknowledge that they have divided the marital bank accounts to
their satisfaction. The bank accounts held solely in individual names shall become the sole and
separate property of the party in whose name it is registered. Each party does hereby
specifically waive and release his/her right, title ami interest in the other party's respective
accounts.
11. PERSONAL PROPERTY.
The parties hereto mutually agree that they have divided all furniture, household
furnishings and personal property between them in a manner agreeable to both parties. The
parties mutually agree that each party shall from and after the date of this Agreement be the
sole and separate owner of all tangible personal property in his or her possession.
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November I6, 1999
12. INVESTMENTS
The parties are owners of mutual funds and stocks held in separate names. The
parties acknowledge that they have divided said funds and stocks to their satisfaction and
agreement. The parties agree that the mutual funds and stocks held solely in individual
names shall become the sole and separate property of the party in whose name it is registered.
Each party does hereby specifically waive and release his/her right, title and interest in the
other party's mutual funds and stocks.
13. ALIMONY. SUPPORT. AND ALIMONY PENDENTE LITE
The parties hereby expressly waive, release, discharge and give up any and all
rights or claims which either may now or hereafter have for spousal support, alimony
pendente lite, alimony, or maintenance. The parties further release any rights that they may
have to seek modification of the terms of this Agreement in a court of law or equity, with the
understanding that this Agreement consti?utes a final determination for all time of either
party's obligations to contribute to the support or maintenance of the other.
14. ATTORNEY FEES. COURT COSTS.
Each party hereby agrees to be solely responsible for his or her own counsel fees,
costs and expenses. Neither shall seek any contribution thereto from the other party except
as otherwise expressly provided herein.
15. ATTORNEYS' FEES FOR ENFORCEMENT.
In the event that either party breaches any provision of this Agreement and the
other party retains counsel to assist in enforcing the terms thereof, the breaching party will
pay all reasonable attorneys' fees, court costs and expenses (including interest and travel costs,
if applicable) which are incurred by the other party in enforcing the Agreement, whether
enforcement is ultimately achieved by litigation or by amicable resolution. It is the specific
Agreement and intent of the parties that a breaching or wrongdoing party shall bear the
obligation of any and all costs, expenses and reasonable counsel fees incurred by the
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November'16, 1999.
nonbreaching party in protecting and enforcing his or her rights under this Agreement.
16. WAIVER OF RIGHTS.
Both parties hereby waive the following procedural rights:
(a) The right to obtain an inventory and the appraisement of all
marital and non-marital property;
(b) The right to obtain an income and expense statement of
either party;
(c) The right to have all property identified and appraised;
(d) The right to discovery as provided by the Pennsylvania
Rules of Civil Procedure;
(e) The right to have the court make all determinations
regarding marital and non-marital property, equitable
distribution, spousal support, alimony pendente lite,
alimony, counsel fees and costs and expenses.
17. MUTUAL COOPERATION.
WIFE and HUSBAND shall mutually cooperate with each other in order to carry
through the terms of this Agreement, including but not limited to, the signing of documents.
1S. VOID CLAUSES.
If any term, condition, 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 continu? in full force, effect and operation.
1J. APPLICABLE LAW.
This Agreement shall be construed under the laws of the Commonwealth of
Pennsylvania.
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• November 16, 1999
20. 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.
21. CONTRACT INTERPRETATION
For purposes of contract interpretation and for the purpose in resolving any
ambiguity herein, the parties agree that this Agreement was prepared jointly by the parties.
IN WITNESS WHEREOF, the parties hereto have set their hands and seals of
the day first above written.
This Agreement is executed in duplicate, and in counterparts. WIFE and HUSBAND
acknowledge the receipt of a duly executed 1
Page 8 of 9
N BRI H M CK
Witness
S:\W PDOCS\DOMESTIC\M SA\meck.msa.wQd
November 16, 1999
L ? -7'??I el& [/
COMMONWEALTH
COUNTY OF /? 7L/9
SS.
On the ?A N day of /
in and for the CcT22e?f RE
RODNEY S. MECK, known tome
the foregoing instrument, and she
and deed. z
K , 1999, before me, a Notary Public
the undersigned officer, personally appeared
drily proven) to be one of the parties executing
es the foregoing instrument to be her free act
IN WITNESS ?EOF, I have hereunto se`1my hand and notarial seal the day and
year first above writ
Notary Public
My Commission
COMMONWEALTH 0R6IA
:SS.
COUNTY OF
On the X. N day of 1 eZ55W dE< , 1999, before me, a Notary Public in and for
the 6 V h Pnown va?>$, t?sat?e undersigned officer, personally appeared LYNN
g?? Ltowimeo;r r `(( f
K; tisactorily proven) to be one of the parties executing
ALB EC
the foregoing instrument, and he acknowledges the foregoing instrument to be his free act and
deed.
IN WITNESS WHEREOF, I have hereunto set my hand and notarial seal the day and
year first above written.
Notary Public
My Commission Expires:
CAROL G. RUBQbM
Notary Public- Newj,".
My Comm. EpIres Do tZ .#?Iav
Page 9 of 9
S:IWPDOGSIDOM ESTICIMSAImeck.msa.wpd
December 9, 1999 .
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
SS.
On the 81 day of 1YCr-m ?61 , 1999, before me, a Notary Public
in and for the Commonwealth of Pennsylvania, the undersigned officer, personally appeared
RODNEY S. MECK, known to me (or satisfactorily proven) to be one of the parties executing
the foregoing instrument, and she acknowledges the foregoing instrument to be her free act
and deed.
IN WITNESS WHEREOF, I have hereunto set my hand and notarial seal the day and
year first above written.
?luA G 'k"'I"" t
Notary Public
My Commission Expires:
Notarial Seal
L Lon A. Richard, Not4ry Public
Camp Hill Boro, Cumberland County
My Commission ExpiW4 Oct. 1, 2001
Member. Pennsylvania Assaclallon of Notanas
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RODNEY S. MECK,
Plaintiff,
V.
LYNN ALBRIGHT MECK,
Defendant.
TO THE PROTHONOTARY:
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-4043
CIVIL ACTION - LAW
IN DIVORCE
Transmit the record, together with the following information, to the court for entry of an appropriate
divorce decree:
Ground for divorce: Irretrievable breakdown under Section 3301(c) of the Divorce
Code.
2. Date and manner of service of complaint: The Complaint was filed on July 1, 1999 and
was served on Lynn Albright Meek by certified mail on July 9, 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 Plaintiff December 8,1999; by Defendant November 29, 1999,
(b?L}._Date.of execution.oE SheaffidauitrequestedJi}?.§_1301.(d). uf.theIIisorceLadc
--------------------
{?}-I)eta of- ili{tg-end se iee-e€ tke P}airuuJ s-a€Gclauit 4"P-3he_-respondent;
-------------------
4. Related Economic Claims Pending: There are no economic claims pending as the
distribution of all personal and real property has been settled by agreement of the parties.
5. (Complete either (a) or (b).)
(aj----Data and-tnaixtias o€-semi se e€.tge-netiso- e€+nteatieate.file.prxcipeto.transtnii-
meer$-e-e"r@f-whieh-k-attaehed. --------------------_,
(b) Date Plaintiffs Waiver of Notice in § 3301(c) Divorce was filed with the
Prothonotary: December 14, 1999.
Date Defendant's Waiver of Notice in § 3301(c) Divorce was filed with the
Prothonotary: December 14, 1999.
Respectfully Submitted:
REAGER,$(ADLER, P.C.
Date: December 14, 1999 By:
No. 663
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REAGER & ADLER, PC
BY: DEBRA DENISON CANTOR, ESQUIRE
Attorney I.D. No. 66378
2331 Market Street
Camp Hill, PA 17011
Telephone: (717) 763-1383
Attorneys for Plaintiff
RODNEY S. MECK, : IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
V. NO. 99- ?U Li'
CIVIL ACTION - LAW
LYNN ALBRIGHT MECK,
Defendant IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the
following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed
without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may
also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose
money or property or other rights important to you, including custody or visitation of your children.
When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may
request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Room
101, Cumberland County Courthouse, I Courthouse Square, Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS
GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17043
(717) 249-3166
RODNEY S. MECK, : IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
V. NO.
LYNN ALBRIGI-IT MECK,
CIVIL ACTION - LAW
Defendant IN DIVORCE
AVISO PARA DEFENDER Y RECLAIMAR DERECHOS
USTED HA DISO DEMANDANDO EN LA CORTE. Is desea defenderse de las quejas expuestas
en [as p5ginas siguientes, debar tomar acci6n con prontitud. Se la avisa que is no se deftende, el case purde
proceder sin usted y decreto de divorcio o anulamiento puede ser emitado en su contra for la Corte. Una decision
puede tambier ser emitida en su contra per caulquier otra queja o compensaction reclamados por el demandante.
Usted puede perder dinero, o sus propiedades o otros derechos importantes para usted.
Cuando la base para el divorcio es indignadades o rompimiento irreparable del matrimonio, usted puede
solicitar consejo matrimonial. Una lista de consejeros matrimoniales esta disponible en la oficina del
Prothonotary, en la Cumberland County Court of Common Pleas, Room 101, Cumberland County Courthouse,
I Courthouse Square, Carlisle, Pennsylvania.
SI USTED NO RECLAMA PENSION ALIMENTACIA, PROPIEDAD MARITAL,
HONORARIOS DE ABOGADO U OTROS GASTOS ANTES DE QUE EL DECRETO
FINAL DE DIVORCIO O ANULAMIENTO SEA EMITIDO, USTED PUEDE PERDER
EL DERECHO A RECLAMAR CUALQUIERA DE ELLOS.
USTED DEBE LLEVAR ESTE PAPEL A UN ABOGADO DE INMEDIATO. SI NO
TIENE O NO PUEDO PAGAR UN ABOGADO, VAYA O LLAME A LA OFICINA
INDICADA ABAJO PARA AVERIGUAR DONDESE PUEDE OBTENER ASISTENCIA
LEGAL.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17043
(717) 249-3166
REAGER & ADLER, PC
BY: DEBRA DENISON CANTOR, ESQUIRE
Attorney I.D. No. 66378
2331 Market Street
Camp Hill, PA 17011
Telephone: (717) 763-1383
Attorneys for Plaintiff
RODNEY S. MECK, IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
V. NO. 4?-gOg3 ?wfT?
CIVIL ACTION - LAW
LYNN ALBRIGHT MECK,
Defendant IN DIVORCE
COMPLAINT IN DIVORCE
UNDER Q 3301(C) OR (D) OF THE DIVORCE CODE
Plaintiff is Rodney S. Meek, an adult individual who currently resides at 1004 Baythome Drive,
Mechanicsburg, Cumberland County, Pennsylvania, 17055.
2. Defendant is Lynn Albright Meck, an adult individual who currently resides at 2 South Harvard
Avenue, Ventnor, New Jersey, 08406.
3. Plaintiff has been a bona fide resident in the Commonwealth for at least six (6) months
immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on January 4, 1992 in Dauphin County, Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the parties.
6. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies
within the provisions of the Soldiers' & Sailors' Civil Relief Act of the Congress of 1940 and its amendments.
Plaintiff avers that there are no children of this marriage.
The marriage is irretrievably broken.
9. Plaintiff has been advised that counseling is available and that Defendant may have the right to
request that the tour, require the parties to participate in counseling. Plaintiff declines counseling.
10. After ninety (90) days have elapsed from the date of the filing of this Complaint, Plaintiff intends
to file an Affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an affidavit.
It. In the alternative, Plaintiff will file an Affidavit of Consent and provide the appropriate
notices two (2) years from the date of separation.
WHEREFORE, Plaintiff respectfully requests the Court to enter a decree of divorce pursuant to Section
3301(c) or (d) of the Divorce Code.
COUNTI
EQUITABLE DISTRIBUTION
12. Paragraphs one (1) through eleven (11) of this Complaint are incorporated herein by reference.
13. Plaintiff and Defendant have acquired property, both real and personal, during their matriage.
14. The parties have acquired marital debt during the course of the marriage.
15. In the event the parties are unable to amicably resolve the property issues in this matter,
Plaintiff requests this Court to equitably divide all property and debt.
WHEREFORE, Plaintiff respectfully requests this Honorable Court to equitably divide all marital
property and debt.
Respectfully Submitted,
REAGER # ADLER, PC
Date: June 29, 1999 By:
78
2331 Market Street
Camp Hill, PA 170114642
Telephone No. [7171763-1383
Attorneys for Plaintiff
VERIFICATION
I, RODNEY S. MECK, verify that the statements made in this Complaint are true and correct.
I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904,
relating to unswom falsification to authorities.
Date: & II I
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RODNEY S. MECK,
V.
LYNN ALBRIGHT MECK,
Defendant
: IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-4043
CIVIL ACTION - LAW
IN DIVORCE
1. A Complaint in divorce under section 3301(c) of the Divorce Code was filed on July 1,
1999.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have
elapsed from the date of filing and service of the Complaint.
3. I consent to the entry of a final decree of divorce after service of notice of intention to
request entry of the decree.
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 are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unswom falsification
to authorities.
Dated: t D. 18 I 99
1
Plaintiff
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RODNEY S. MECK,
: IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
V. NO. 99-4043
CIVIL ACTION - LAW
LYNN ALBRIGHT MECK,
Defendant IN DIVORCE
1. A Complaint in divorce under section 3301(c) of the Divorce Code was filed on July 1,
1999.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have
elapsed from the date of filing and service of the Complaint.
3. I consent to the entry of a final decree of divorce after service of notice of intention to
request entry of the decree.
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 are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unswom falsification
to authorities.
Dated: L l t d? f /
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I RODNEY S. MECK,
V
Plaintiff
LYNN ALBRIGHT MECK,
Defendant
: IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-4043
CIVIL ACTION - LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE
UNDER SECTION 3301(C) OF THE DIVORCE CODE
l . 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 unswom falsification
to authorities.
Dated: 19d S M
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RODNEY S. MECK,
V.
Plaintiff
LYNN ALBRIGHT MECK,
Defendant
: IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-4043
CIVIL ACTION - LAW
IN DIVORCE
I. 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 unswom falsification
to authorities.
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REAGER & ADLER, PC
BY: DEBRA DENISON CANTOR, ESQUIRE
Attorney I.U. No. 66378
2331 Market Street
Camp Hill, PA 17011
Telephone: (717) 763-1383
Attorneys for Plaintiff
RODNEY S. MECK,
V.
LYNN ALBRIGHT MECK,
Plaintiff'
Defendant
: IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99 - 4043 Civil
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF SERVICE
COMMONWEALTH OFPENNSYLVANLA
COUNTY OF CUMBERLAND
Before me, the undersigned Notary Public, this day, personally appeared Debra Denison Cantor,
Esquire, attorney for the Plaintiff, to me known, who being duly sworn according to law, deposes the
following:
I, Debra Denison Cantor, Esquire, being duly sworn according to law, depose and state that
service of the Complaint in Divorce in the above-captioned matter was served by Certified
Mail, Return Receipt Requested, on Defendant, Lynn Albright Meck, 2 South Harvard
Avenue, Ventor, New Jersey, 08406 on July 9, 1999. The Certified Receipt is attached
hereto as "Exhibit A."
By
Subscrib and sworn to before me
this _J_ day of JLl I !k , 1999.
Notary Public
Notarial Seal
Lon A Richard Notary Public
Camp Hill Boro. Cumberland County
My Commission Expire: Oct. 1 2001
Member Penrsylvaina Associauun of Plotaries
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hems 3, 4a, and 40. Ing services (for an extra fee):
name and address on the revere of INS form w that we can return this
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form to the front of the mailplece, or on the bark If space does not 1. 11 Addressee's Address
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7. Date of De' ,
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?S Form 3811, December 1994 to2ses•99.13 3
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RODNEY S. MECK, : IN THE COURT OF COMMON PLEAS
Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 99-4043
LYNN ALBRIGHT MECK, CIVIL ACTION - LAW
Defendant. IN DIVORCE
PRAF.CIPR
TO THE PROTHONOTARY:
The Social Security Number of the Plaintiff Rodney S. Meek is: 193-46-4143.
The Social Security Number of the Defendant Lynn Albright Meek is: 163-60-7270.
Respectfully Submitted:
REAGER & ADLER, P.C.
Date: December 13, 1999 By:
Attlrn jSQNqC,AW0R, ESQUIRE
Atfiime . No. G63 8
2331 Market Street
Camp Hill, PA 17011
Telephone Number: (717) 763-1383
Attorneys for Plaintiff
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