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HomeMy WebLinkAbout99-06155 AWN ! ?-c lip IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. G t71 4 MINDY L. STOVER, ?._: Plaintiff VERSUS No. 99-6155 MAMILV RICHARD GARDNER STOVER, Defendant DECREE IN DIVORCE , AND NOW, _02'm. IT IS ORDERED AND DECREED THAT Mindy L. Stov PLAINTIFF, AND Matthew Richard Gardner Stover -,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; None BY ATT4s I I 0 J. -- ROTHONOTARY ;, • , ti , 4 MINDY L. STOVER, Plaintiff v. 111ATTHF\V RICHARD GARDNER STOVER, Dofendanl r ! : IN THE COUIt'r OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99,665 IVIL TERM IN DIVORCF• MARITAL SETTLEMENT AGREEMENT THIS AGREEMENT is made this L day of n'•-A; '1999, by and between MINDY L. STOVER, ("Wife") and MATTHEW RICHARD GARDNER STOVER ("Husband"). WHEREAS, the parties were married on November 19, 1994, and have remained married since that time; and WHEREAS, certain differences have arisen between the parties and, as a consequence, they are living separate and apart from each other; and WHEREAS the parties wish to set forth certain covenants and understandings regarding their separation and their respective property rights; NOW THEREFORE, in consideration of the mutual promises and undertakings contained herein, the parties hereto, intending to be legally bound, covenant and agree as follows: 1. VOLUNTARY AGREEMENT: It is acknowledged by the parties that this Agreement is entered into voluntarily and after due deliberation by each of them. Wife is represented by Samuel W. A4ilkes, Jacobsen & Alilkes and Husband is not represented at this time. 2. SEPARATION AND NON-INTERFERENCE: It shall be lawful for Wife and Husband at all times hereafter to live separate and apart from each other and to reside from time to time at such place or places as they shall respectively deem fit, free from any control, restraint, harassment or interference, indirect or direct, from each other. The foregoing provisions shall not be taken to be an admission on the part of either party of the lawfulness or unlawfulness of the causes leading them to live apart. 3. DIVORCE ACTION: The parties acknowledge that an action for divorce between them has been filed by Wife in the Court of Common Pleas of Cumberland County, Pennsylvania, Stover u. Stover, No. 99.6155 Civil Term. The parties hereby acknowledge their intention and agreement to proceed in said action to obtain a final decree in divorce by mutual consent on the grounds that their marriage is irretrievably broken, and to settle, amicably and fully hereby, all claims which might be raised by either party in the divorce action. The parties acknowledge that they will execute, after the passage of ninety days from filing and service of the Divorce Complaint, the necessary Affidavits of Consent for the entry of a final divorce decree in the pending action. 4. LEGAL ADVICE: The parties acknowledge that Wife has been represented by Samuel W. Milkes, Esq. JACOBSEN & MILKES, as counsel in this matter, and that Husband has not been represented counsel in this matter. Wife and Husband each acknowledge that they have received, or have had the opportunity to receive independent legal advice from counsel of her or his selection prior to the execution of this Agreement. Each party agrees that she or he each fully understands the facts surrounding this divorce, and each has had the opportunity to be fully informed as to her or his legal rights and obligations. Each party acknowledges and 7 accepts that this Agreement is, under the circumstances, fair and equitable, and that it is being entered into freely and voluntarily after Wife's consultation with her attorney and Husband's opportunity to consult with his attorney. The execution of the Agreement is not the result of any duress or undue influence, and it is not the result of any collusion or improper illegal agreement or agreements. The parties acknowledge that each has been fully informed of, or is familiar with, the wealth, property, state, and income of the other, and each party is hereby satisfied that such information is true and correct. 5. PERSONAL PROPERTY: The parties have divided all personal property and each is full owner of the personal property now in his or her possession. At the time of signing of Affidavits of Consent, allowing for it divorce decree to be entered, or at the time of signing of it deed, conveying Wife's interest in the marital home to Husband, whichever date is earlier, Husband shall pay to Wife the amount of $3,000 plus one half of the attorney fees and costs incurred to pursue the divorce. Husband's share of the attorney fees and costs shall not exceed $400.00 and Wife shall not be responsible for payment of any attorney fees incurred by Husband. These fees include out of pocket costs, including the filing fee for the divorce and the certified mail fee. In the event that the marital home is sold and should the $3,000 advance on the distribution from sale to Wife be in excess of her share of the net proceeds pursuant to paragraph 7, Wife shall reimburse Husband so that the net proceeds or costs are split equally. 6. MISCELLANEOUS: Upon expiration of ninety (90) days from the filing of the divorce complaint each party agrees to sign an Affidavit consenting to the divorce. 7. MARITAL HOME: Husband agrees to refinance the marital home, located at 35 H Street, Carlisle, PA. This may be done either by an outright refinancing or by 1 an assumption of mortgage. Upon Husband obtaining such refinancing, Wife Shall convey, by decd, all of her interest in the marital home. If Husband is not able to refinance or assume this debt, in a manner that releases Wife from the debt, by the time ninety (90) days have elapsed from the filing of the divorce action, the property shall instead be listed for sale. The parties shall split equally the net proceeds on the sale of the home. 8. PENSION, CHECKING, AND SAVINGS ACCOUNTS: The parties agree that any pension, retirement, military retirement, 401(k) plan, IRA plan, investment plan, or any similar retirement type of plan or benefit, tiling with any checking, savings, or other cash assets are fully owned by each party in whose name they are currently held and they agree to execute tiny documents necessary to reflect this fact. 9. ALIMONY AND HEALTH INSURANCE: The parties agree there is no alimony or spousal support to be paid by either. The parties further agree that neither has any obligation to provide the other with any health insurance coverage, at the present time, or in the future. 10. VEHICLES: Wife shall transfer to Husband her ownership in the 1996 Chevrolet Monte Carlo vehicle and Husband shall assume sole responsibility for continuing payments on this vehicle. Husband shall make all reasonable efforts to immediately refinance the vehicle in his own name, if he can do so at or below the current interest rate that is being paid, or to assume the debt financing obligation currently in effect. The convenience of title shall take place at the time that Husband obtains refinancing, assumes the current debt, or it the time the debt has been completely satisfied, whichever occurs earlier. In the event Husband is unable to refinance or assume this debt, he shall continue to make regular monthly payments 4 under the current financing, fund he shall indemnify and hold Wife harmless in the event his failure to meet this obligation causes Wife to be financially harmed in any way. Failure to keep these payments current shall be considered it breach of this Agreement, subject to the enforcement provisions set forth below. Wife shall sell the 1997 Chevrolet truck, currently titled in Husband's name. In connection with this sale, the parties agree to execute tiny title documents necessary to effect the sale and to apply the proceeds of the sale toward the payoff of the loan. In the event that any additional funds are received out of the sale of this truck, beyond that necessary to payoff the loan, Wife shall retain these funds. The parties agree that Wife may immediately begin to market the sale of this truck. 11. RESIDENCE AT HOME: During the time leading up to the finalization of this divorce, the parties agree that Husband shall have exclusive possession of the marital residence located at 35 H Street, Carlisle, Pennsylvania. In connection with this right, Husband shall be exclusively responsible for payments of the mortgage, beginning with the payment due November 1, 1999 and, immediately, he is exclusively responsible for all utilities, taxes, insurance, and other costs connected to the maintenance and ownership of this home. Husband agrees to hold Wife harmless and to reimburse her for any liability incurred on her part, due to Husband's failure to pay any of these amounts In the event that any late fees, mortgage payments, or other costs accrue because of Husband's failure to pay on these costs, an in the event that the home is sold under the terms of this agreement, any amounts which should have been paid by Husband will be offset against the portion of the distribution which would otherwise be made to Husband. 5 f 12. JOINT TAX RETURN: The parties agree to file a joint marital tax return for 1999 and in connection with that filing, to split equally tiny refund which might be received and to be jointly obligated, equally, on any taxes which may be due. 13. DEBTS OF THE PARTIES: Each party is solely liable for any and all debt in his or her name, and agrees to hold the other party harmless for tiny debt which may accrue to the non-liable party, as a result of his or her indebtedness. The parties agree that they will not in the future contract or incur any debt or liability for which the other party, his or tier property or estate, might be responsible and each further agrees to indemnify and save harmless the other party against tiny claims that may be asserted by anyone against the other party by reason thereof. 14. NON-MERGER IN DIVORCE DECREE: The parties agree that in the event of absolute divorce between them, they shall nonetheless continue to be bound by all the terms of this Agreement, and neither this Agreement, nor the terms hereof, shall be deemed to have been merged in any decree or judgment granted in the divorce action, but shall survive and be forever binding upon the parties. lb. EXECUTION OF DOCUMENTS: Each of the parties shall, from time to time at the request of each other, execute, acknowledge and deliver to the other party any and all further instruments that may reasonably be required in order to give full force and effect to the provisions of this Agreement. 16. MUTUAL RELEASE AND COUNSEL FEES: Except its provided for in this Agreement, the parties hereby remise, release, quitclaim and forever discharge each other and the estate of each other, for all time to come, and for all purposes whatsoever, from tiny and every claim, including alimony, alimony pendente lite, spousal support, equitable distribution of marital property, counsel fees or costs under the Divorce Reform Act, or otherwise, that they make or hereafter make in and 6 s to or against each other's estates or tiny parts thereof, whether by way or dower or curtesy, or under the intestate laws, or the right to take or elect against the other's will, except only such rights as accrue pursuant to this Agreement. 6. NON-WAIVER: The failure of either party to insist in any one or more instances upon the strict performance of any of the terms hereof in this Agreement shall not he construed as it waiver or relinquishment of such term or terms in the future. 7. RECONCILIATION: The parties agree that in the event of it reconciliation between them, this Agreement shall continue in full force and effect unless terminated by mutual written consent. 8. BREACH: In the event that either party breaches any provision of this Agreement, he or she shall be responsible for any and all costs incurred to enforce the Agreement, including, but not limited to, court costs and counsel fees of the other party. In the event of breach, the other party shall have the right, at his or her election, to sue for damages for such breach or to seek such other and additional remedies its may be available to him or her, including equitable enforcement of the Agreement. 20. ENFORCEMENT: The parties agree that this Agreement or any part or parts hereof may he enforced in tiny court of competent jurisdiction. 29. APPLICABLE LAW AND EXECUTION: The parties hereto agree that this Agreement shall he construed under the laws of the Commonwealth of Pennsylvania, and shall hind the parties hereto, and their respective heirs, executors and assigns. This Agreement shall he executed as original in quadruplicate. 22. ENTIRE AGREEMENT: The parties acknowledge and agree that this Agreement contains the entire understanding of the parties and supersedes tiny prior agreement between them. There are no other representations, warranties, premises, covenants or understandings between the parties other than those expressly set forth herein. 23. INCORPORATION IN JUDGMENT FOR DIVORCE: In the event that either Wife or Husband tit tiny time hereafter obtain it divorce, this Agreement and all of its provisions shall be incorporated into any such judgment for divorce, either directly or by reference. The court, on entry of judgment for divorce shall retain the right to enforce the provisions and the terms of the Agreement. IN WITNESS WHEREOF, the parties hereto have set their hands and seals as of the day and year first above written. INDY L I MATTHEW RICHARD GARDNER COMMONWEALTH OF PENNSYLVANIA : SS: COUNTY OF CUMBERLAND On this, the day of rrt?u, 1999, before me, it Notary Public in and for the aforesaid Commonwealth and County, personally appeared MINDY STOVER, known to me, or satisfactorily proven, to be the person whose name is subscribed to the within instrument and acknowledged that lie executed the same for tile J)utl)ose therein contained. IN WITNESS WHEREOF F/I her 1 nto set my band and official seal. NOTARY PUBLIC W)TAft" ttAL VMRL W. UWCK 1 AW ru?Uo My Commission Expires: OAALJW80rO,CUYSMAW OQ.,M r COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND : SS: On this, the 1 day of 1999, before me, it Notary Public in and for the aforesaid Commonwealth and County, personally appeared MATTHEW RICHARD GARDNER STOVER, known to me, or satisfactorily proven, to be the person whose name is subscribed to the within instrument and acknowledged that she executed the same for the purpose therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. NOTARY PUBLIC My Commission Expires: IWtlMa?'??,M Y CL) Y ^ \_ f 7 ?1 t C7 c? (7 9U i.: ? ut?. t ? ii7 f (Jr , Il ..:L y U. !•1 c3 4? In MINDY L. STOVER, v. Plaintiff MATTHEW RICHARD GARDNER STOVER, Defendant To the Prothonotary: : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99. 6166 CIVIL TERM IN DIVORCE Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for the divorce is irretrievable breakdown under Section of 3301(c) of the Divorce Code. 2. Defendant was served with the Divorce Complaint by certified mail, return receipt, and the return receipt card was signed by the Defendant on October 12, 1999. 3. Plaintiffs Affidavit required by Section 3301(c) of the Divorce Code was executed by the Plaintiff on January 20, 2000. 4. Defendant's Affidavit required by Section 3301(c) of the Divorce Code was executed by the Defendant on January 23,2000 5. There are no related claims pending. The parties agree to the entry of the Marital Settlement Agreement dated November 19, 1999, to be Incorporated into the final Decree of Divorce between them. Respectfully submitted, .000, "?Ooe SAMUEL W. MINES, Esquire JACOBSEN & MILKES 52 E. High Street Carlisle, PA 17013 (717) 249-6427 Attorney for Plaintiff r. ?n cl, Fl ?...-.. r .... ..w.,u.. s«, r_... -.... ++.,aa. .,.._? -__. ,..... .. .. + ,. ? ?•..xrrr.....o..a.-..-?....r'*yt,kaiM+t1.T.!7E1M1?71 MINDY L. STOVER, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. MATTHEW RICHARD GARDNER STOVER, Defendant NO.99-&ISS CIVIL TERM IN DIVORCE TTrF TO nFFF.Nn ANTI CT.ATM RTf7HTfi 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, 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, PA 17013 (717) 249-3166 MINDY L. STOVER, V. Plaintiff MATTHEIV RICHARD GARDNER STOVER, Defendant • ? J : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99- CIVIL TERM IN DIVORCE COUNT I - DIVORCE 1. Plaintiff is MINDY L. STOVER, presently residing at 55 F Street, Carlisle, Cumberland County, Pennsylvania, 17013. 2. Defendant is 1NIATTHEW RICHARD GARDNER STOVER, presently residing at 35 H Street, Carlisle, Cumberland County, Pennsylvania, 17013. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on November 19, 1994. 5. There have been no prior actions of divorce or for annulment between the parties in this or any other jurisdiction. 6. Neither party to this action in divorce is currently a member of the Armed Forces of the United States of America. 7. Plaintiff has been advised that counseling is available and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling. 8. The marriage between the parties hereto is irretrievably broken. 9. Plaintiff requests the Court to enter a decree of divorce. WHEREFORE, the Plaintiff requests this Court to: 7, U,-- I + a. Enter a final Decree of Divorce divorcing the Plaintiff from the Defendant; and b. Grant such further relief as it shall deem proper and just. Respectfully submitted, 'BY: Samuel W. Milkes JACOBSEN & MILKES 62 E. High Street Carlisle, PA 17013 (717) 249.6427 (717) 249.8427 • Fax Attorney No. 30130 I I hereby verify that the statements made in the foregoing 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 unsworn falsification to authorities. Dated: IL, 17 /c/c, MINDY L. TCM 4 C? u.t ,. c? r? r f I Cl nN ,..; 1 Q tV 3 Z' \ 4? MINDY L. STOVER, V. Plaintiff MATTHEW RICHARD GARDNER STOVER, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO.00- 0166 CIVIL TERM IN DIVORCE I, Deborah R. Clark, hereby certify that a true and correct copy of the Complaint in Divorce in the above referenced matter was duly served upon Matthew Richard Gardner Stover, by depositing it in the U.S. Mail, registered, return receipt requested, on October 8, 1999, addressed as follows: Matthew Stover 35 H Street Carlisle, PA 17013 The return receipt card was signed on the 121h of October, 1999. The return receipt card is attached as Exhibit "A." I hereby verify that the statements made in the foregoing are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 9904, relating to unsworn falsification to authorities. Dated: October 19, 1999 Qeborah R. Clark Z 452 480 260 US Postal SWACe Receipt for Certified Mail NoIawrarcw:.- Provided. Do not use for Intematwnal Map See reverse mthew Stover rY I"sYenP t?° 17013 ° SI1 55CtxWW F« ' I LID STover'v.'STover i rpe2wtW w Om atbmm"dtlsamwwwe twccorm I of ft ae OO^ s on h pet a WM dow n°t thew Stover H. Street lisle, PA 17013 December 1994 I IwoswWttomwntto ; wlwwq wrvbn (tor an W*a Iw): + 1.0 Ad*n*Ws Addna ` fM RuUMW D*Mry i C'mmn Poebmter for fm 260 We 0 FMpbtered KA Mad ; O Evrees Md 0 ' 0 Ran RKWformo rdw OF f i7. Dw w o•w.ry e. Addrenee's (t7nD ; end hs is pow m*amm Domestic Retum Recelpt ' v MINDY L. STOVER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA :NO. 99-b/Sf CIVIL TERM IN DIVORCE V. MATTHEW RICHARD GARDNER STOVER, Defendant WAIVER OF COUNSELING Plaintiff, MINDY L. STOVER, herein, hereby states and certifies as follows: 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 Domestic Relations 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 understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Dated: 1y) , 1, _ I MIN Y L. S' 0 - I L}. C> (-{ C MINDY L. STOVER, V. Plaintiff MATTHEW RICHARD GARDNER STOVER, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA :NO. 99- 6166 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under the Divorce Code under Section 3301(c) was filed on October 7, 1999 on the grounds that the marriage of the parties is irretrievably broken. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. 1 consent to the entry of a final decree of divorce after service of notice of intention to request entry of divorce decree. 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 the Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. Date: IZpI 1 f - , MINDY L. 8 ER ., ? ? ?? ?, ? ,?, ?t?c?i f r, . u?? tom. ;?i? tl:?i' "x ' i7? W' ?:.. > (_? -7 s -` ,, i.: . ,. r ,__ MINDY L. STOVER, Plaintiff V. MATTHEW RICHARD GARDNER STOVER, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO.99- 6155 CIVIL TERM IN DIVORCE 1. 1 consent to the entry of a final decree of divorce without notice. 2. I understand that 1 may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a decree 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. 1 verify that the statements made in the Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. Date: J `z p 12- - 1 MINDY L. T SR 1 ? I .. Ir t? ?i . t ? I I I MINDY L. STOVER, V. Plaintiff MATTHEW RICHARD GARDNER STOVER, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA :NO. 99- 6155 CIVIL TERM IN DIVORCE 1. A Complaint in Divurce under the Di•.urcc Codc under Section 3301(c) was filed on October 7, 1999 on the grounds that the marriage of the parties is irretrievably broken. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of divorce decree. 4. I understand that I may lose tights 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 the Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. Date: //-:? 140 MATTHEW RICHA ARD STOVER 4,; d Syr. ?«t tw LL- w °-' iS tl r MINDY L. STOVER, V. Plaintiff MATTHEW RICHARD GARDNER STOVER, Defondant ,. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99- 6166 CIVIL TERM IN DIVORCE 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 decree is granted. 3. I understand that 1 will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the prothonotary. I verify that the statements made in the Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unworn falsification to authorities. Date:,,/ V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V fimq L Plaintiff vs. 11(lcu?. h?u ? ? ?ch>2?I ?d?s?,?? Defendant File No. 99 -('I'r5 IN DIVORCE NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff/Defendant in the above matter, having been granted a Final Decree in Divorce on the q day of jtJ;QLL&LQe_, 407-COO, hereby elects to resume the prior surname o Mina) L,MCKI11( p , and gives this written notice pursuant t he provisions of S 704. DATE: L2'T0 ll?l1ll &QIli S ature 'J Signature o ame being re umed COMMONWEALTH OF PENNSYLVANIA: . SS. COUNTY OF CUMBERLAND On the 11W day of 6216-5 , kg,'?70 , before me, a Notary Public, personally appeared se above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he/she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand and official seal. Notary Public NOTARIAL SEAL PATRICIA A SHATTO, Notary Public Carlisle ODI07 Cemburlan9 County My COM613L0n Frpires December 17, 2001