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HomeMy WebLinkAbout99-06493 q ZS y .F' ! f - J ti- Y4 ,SSN 4 a e 4,1' T s w t . e,? ?5d `? ? v YY 16?a It ) a ?' S 1 } F. f X s r ? A mIIi. I T y ` \. r *i ;,r yj 'NS ?9 i A § '?. i ? x ro t!? ?K Y M1 W ? F 7; ? ? , , SC44 ) t _ ' wi GA K I X sin • (.iNw tl c+y ' 4a ' t as ... ...'? o d. ? r 1 DECREE IN IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. JAMES W. LINGLE, Plaintiff N O. 99-6493 CIVIL TERM VERSUS PATRICIA M. LINGLE, Defendant DIVORCE APID NOW, 2000 IT IS ORDERED AND TAMP.C W T.TMr T.R DECREED THAT AND PATRICIA M. LINGLE ARE DIVORCED FROM THE BONDS OF MATRIMONY. , PLAINTIFF, , DEFENDANT, THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HASNOT YET BEEN ENTERED; The attached Property Settlement Agreement dated August 16, 2000 PROTHONOTARY shall be incorporated into this Decree in Divorce. THIS AGREEMENT, made this Q-13- day of 2000, by and between JAMES W. LINGLE, residing at 1437 Apple Circle, Mec nicsburg, Cumberland County, Pennsylvania, hereinafter referred to as "HUSBAND," and PATRICIA M. LINGLE, residing at 4225 Roth Lane, Mechanicsburg, Cumberland County, Pennsylvania, hereinafter referred to as "WIFE." WITNESSETH. WHEREAS, the parties were lawfully married on September 29, 1990, in Camp Hill, Cumberland County, Pennsylvania; 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. Se matton. 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 govem all past, present, and/or future claims for alimony, 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 except as set forth hereinafter. 3. Divorce. A Complaint in Divorce was riled by HUSBAND In Cumberland County, Pennsylvania on or about October 25, 1999, which action is docketed to No. 99-6493. Simultaneously with the execution of this Agreement, the parties agree to sign all documents necessary to finalize the divorce action, including but not limited to Affidavits of Consent, Waivers of Marriage Counseling and any other such final divorce document. The parties acknowledge that all final divorce documents shall be immediately filed with the Court and that a Decree in Divorce shall be forthcoming in the immediate future. The parties intend that this Agreement shall be incorporated but shall not merge into any forthcoming Decree in Divorce. The parties understand that upon the entry of a Decree in Divorce, they may need to obtain Independent health and medical insurance coverage if they have not already done so, as they will no longer be eligible for coverage under the other party's insurance plan. 4. Real Property. The parties acknowledge that there is no real property that can be considered marital property subject to equitable distribution. 5. Personal Property. The parties have acquired certain personal property during the course of their marriage, all of which has been divided to the parties mutual satisfaction. It is agreed that each party shall retain all items of tangible personal property currently in their possession as if it were their sole and separate property. Neither party shall make any claim to any such items of marital property, or of the separate personal property of either party which are now in the possession or under the control of the other. Furthermore, each party agrees to waive any right, title, and/or interest they may have to the property in the possession of the other, and not specifically referenced above. Should it become necessary, the parties each agree to sign upon request, any titles or documents necessary to give effect to this paragraph. 6. Automobl/es. Each party shall retain their Individual automobile as their sole and separate property, free and clear of any right, claim, title and/or Interest of the other party. More specifically, WIFE will retain sole and exclusive possession of the 1998 Chevy Malibu, subject to any and all liens and/or encumbrances for which she shall bear sole responsibility. HUSBAND will retain sole and exclusive possession of the 1996 Chevy Truck, subject to any and all liens and/or encumbrances for which he shall bear sole responsibility. Furthermore, each party agrees to waive any right, title or interest he or she may have in the vehicle of the other, and cooperate with the signing of any and all documents necessary to effectuate the provisions of this paragraph. HUSBAND'S daughter Jamie, shall retain sole and exclusive possession of the 1997 Ford Escort. This vehicle is jointly financed in both HUSBAND and WIFE'S names, however the parties intend that Jamie shall bear sole financial responsibility for this debt. In the event that Jamie is able to refinance this vehicle into her name individually, she shall do so immediately. If however, she is unable to obtain such financing, then the debt shall remain jointly titled until the vehicle is paid in full. Jamie agrees to Indemnify both HUSBAND and WIFE with respect to any non-payment or non-performance on her part of the financing obligations, and understands that In the event she is unable to make timely payments on this vehicle, either HUSBAND or WIFE may have the option to repossess the vehicle. Once the vehicle is paid in full, or in the event Jamie can secure individual financing, whichever happens first, the parties agree that title to this vehicle shall be transferred Into Jamie's name individually. W. ING PATRICIA M. LINGLE ° o JAMIE M. LINGL? E 7. Cemetarv Plots. The parties jointly own rive (5) cemetery plots at Rolling Green Cemetery, which are paid in full. The parties agree that HUSBAND shall receive these plots as his sole and separate property, free of any right, claim, title and/or interest of WIFE. WIFE agrees to sign whatever documentation needed to transfer title of these assets to HUSBAND either simultaneously with the execution of this Agreement if possible, or imme liately thereafter. 8. Proceeds from Sale of Marital Home. The parties jointly owed the marital home located at 434 Orrs Bridge Road, Camp Hill, Cumberland County, Pennsylvania. The home has been sold and there are net proceeds (which also Include insurance reimbursements) in the amount of Seven Thousand, Two Hundred and Thirty Seven ($7,237.78) Dollars and Seventy Eight Cents, as of June 30, 2000. These proceeds have been held in an interest bearing account with HUSBAND'S counsel upon the direction of both parties since the marital home was sold. The parties agree that HUSBAND shall be entitled to Immediately receive the entire balance referenced above, plus any Interest earned since June 30, 2000, as his sole and separate property, free and clear of any right, claim, title and/or interest of WIFE. HUSBAND shall also receive as his sole and separate property, any Pennsylvania homeowner's refund which will be in the amount of One Hundred ($100.00) Dollars. WIFE hereby specifically waives any right she may have to the above, and agrees to promptly sign any and all documentation needed to facilitate the above, either simultaneously with the execution of this Agreement if possible, or immediately thereafter. 9. Employee, Pension and Retirement Benefits. Each party shall retain as his or her 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), whether vested or non-vested. The above shall specifically Include a waiver of any spousal annuity benefits and/or beneficiary designations thereunder. More specifically, WIFE shall retain as her sole and separate property, her PA State Employes' Retirement System Retirement which has a value for equitable distribution purposes of Sixteen Thousand, Seven Hundred and Fifty Three ($16,753.52) Dollars and Fifty Two Cents. Against his counsel's advice, HUSBAND waives any and all right, claim, title and/or interest he may have to these funds. The parties acknowledge they have the right to engage in formal discovery, however specifically waive that right and acknowledge and agree that they are satisfied with all financial disclosures that have been made. 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 the other party. 10. Credit Card Debt. There are no joint credit cards in existence. Each party shall assume sole responsibility for his or her individual credit card debt, regardless of when that debt was Incurred. Any other credit card debt shall be the sole and separate responsibility of the party who incurred it. 11. Spousal SuRnort/Alimony Pendente Lite / Apmony. Neither party shall make any claim against the other for past, present and/or future, spousal support, alimony pendente lite, or alimony. Furthermore, each party specifically waives any past, present or future claim for spousal support, alimony pendente lite and/or alimony against the other party. 12. Bank Accounts. Any and all joint bank accounts have been divided to the parties mutual satisfaction. There are no joint bank accounts remaining in existence. Furthermore, each party agrees to waive any right, title or interest he or she may have in the individual bank account of the other. 13. Miscellaneous Debt. Any debt not specifically listed in this Agreement shall be the sole and separate responsibility of the party who Incurred it. 14. Agreement Executed Voluntarily 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; 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. 15. 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. 16. Holding Other Parhr Free and Hannless. 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. 17. 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. 18. Full Disclosure. The respective parties do hereby warrant, represent, and declare, and do acknowledge and agree that each is satisfied with the financial disclosures made from the other. The parties acknowledge that although within their right to request, no formal discovery was done in this case, and that they are satisfied with and cognizant of the wealth, income, real and/or personal property, whether jointly or individually titled, estate and assets of the other, 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. The parties specifically acknowledge that they have been advised by their individual counsel of their right to seek such discovery, however have elected to waive the same. Further, both parties waive their right to have the inventory or financial disclosure statement of the other attached hereto, and understand that this Agreement shall not be subject to modification by the Court. 19. Ronresentation of the Parties. HUSBAND is represented by Johnson, Duffle, Stewart & Weidner, in connection with the negotiation and preparation of this Agreement. WIFE is represented by Bryan S. Walk, Esquire in connection with the negotiation and preparation of this Agreement. 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. 20. Waiver of Rights to Other Partv's Es(M. Except as provided for herein, in the event that the parties divorce, 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. In the event the parties are not divorced at the time of their death, they understand the survivor will be considered a surviving spouse, and will therefore receive any and all benefits available to a surviving spouse. 21. 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. 22. Partial Invalidity. 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. 23. Effect of Reconciliation. Cohabitation or Divorce Decree. 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. 24. Modification. 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. 25. No Waiver of Defautt. 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. 26. Attorneys Fees and Ex eases. Each party shall be responsible for their own attorneys fees and expenses. In the event that one party breaches the terms of this Agreement, the non-breaching party shall be entitled to collect from the breaching party, any and all attorney's fees, Including costs, fees and expenses reasonably related to the enforcement of this Agreement. 27. Mutual Cooperation. Each of the parties shall, on demand, execute and deliver to the other, 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. 28. Bankruntcv. Each of the parties acknowledges and agrees that with respect to the liabilities each is required to assume and pay under 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 States 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. 29. Law of Pennsylvania Applicab This Agreement shall be construed in accordance with the laws of the Commonwealth of Pennsylvania. 30. 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. 31. Successors and Assigns. 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 dale and year first above written. WITNESS: Dale 40 Date r' MES W. LINGL ATRICIA M. LINGLE :137201 ? r' e' r - r G JAMES W. LINGLE, Plaintiff VS. PATRICIA M. LINGLE, IN THE COURT OF COMMON PLEAS OF CU-SERLAND COUNTY, PENNSYLVANIA NO. 99-6493 CIVIL TERM Defendant PRAECIPE TO TRANSMIT RECORD c To the Prothonotary: Transmit the record, together with the following information; tothe court for entry of a divorce decree: 1. Grounds for divorce: irretrievable breakdown under Section 3301(cf> ''. 27KK) WQW of the Divorce Code. (Strike out inapplicable section) 2. Date and manner of service of the complaint: Certified mail, restricted delivery to the Defendant on October 28, 1999 and received by Defendant on October 30, 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 August 9, 2000 by the defendant August 15, 2000 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: The Property Settlement Agreement dated August 16, 2000 shall be incorporated into the Decree in Divorce. 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 wider Section 3301 (d)(1)(i) of the Divorce Code Waivers of Notice filed concurrently herewith and signed by Plaintiff on August 9, 2000 and by Defendant on August 15, 2000 ( ,gal.. jk Attorney for Plaintiff/Defendant Keirsten W. Davidson Atty ID #78243 Johnson, Duffle, Stewart & Weidner By: Kcirstcn W. Davidson I.D. No. 78243 301 Market Strcct P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 JAMES W. LINGLE, V. Plaintiff PATRICIA M. LINGLE, Defendant Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99- (o(jV CIVIL TERM CIVIL ACTION - LAW 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: Keirstcn W. Davidson I.D. No. 78243 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 JAMES W. LINGLE, Plaintiff V. PATRICIA M. LINGLE, Defendant CIVIL ACTION - LAW IN DIVORCE AND NOW, comes the Plaintiff, James W. Lingle, by and through his attorneys, Johnson, Duffle, Stewart & Weidner, and files the following Divorce Complaint against the Defendant, Patricia M. Lingle: 1. The Plaintiff Is James W. Lingle, an adult Individual, residing at 434 Orr's Bridge Road, Camp Hill, Cumberland County, Pennsylvania 17011. 2. The Defendant Is Patricia M. Lingle, an adult Individual, who is currently residing at 4225 Roth Lane, #114, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. The Plaintiff and Defendant were married on September 29, 1990, in Camp Hill, 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 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99- 4.119,,3 CIVIL TERM 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) of the Divorce Code. 8. Plaintiff Incorporates herein by reference, the allegations set forth in Paragraphs 1 through 7 Inclusive, of the Complaint as if the same were set forth herein at length. 9. Plaintiff and Defendant have legally and beneficially acquired certain real and personal property during their marriage. WHEREFORE, the Plaintiff respectfully requests that your Honorable Court equitably divide all marital property. JOHNSON, DUFFIE, STEWART & WEIDNER By: e. Davidson :120209 VMRCAT/ON 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 §4914, relating to unswom falsification to authorities. I Date: ID-1WI'99 James W. i gl 61 R l: qp a'X f ii rt •- Johnson, Duffle, Stewart & Weidner By: Keirstcn W. Davidson I.D. No. 78243 301 Market Street P. 0. Box 109 Lcmoync, Pennsylvania 17043-0109 (717) 761-4540 JAMES W. LINGLE, Plaintiff V. PATRICIA M. LINGLE, Defendant IN DIVORCE JAMES W. LINGLE, 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 Prothonotarys 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. 1 understand that false statements heroin are made subject to the penalties of 18 Pa.C.S. §4904, relating to unswom falsification to authorities. Date: 4 James W.1(461 61 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVILTERM CIVIL ACTION - LAW T; % Al Johnson, Duffle, Stewart & Weidner By: Kcirstcn W. Davidson I.D. No. 78243 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attomcys for Plaintiff JAMES W. LINGLE, Plaintiff V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-6493 CIVIL TERM CIVIL ACTION - LAW PATRICIA M. LINGLE, Defendant IN DIVORCE hereby certify that on the 28" day of October, 1999, 1 served a true and correct copy of the foregoing Complaint in Divorce upon the Defendant, Patricia M. Lingle, by certified mall, restricted delivery, to her mailing address at 4225 Roth Lane, #114, Mechanicsburg, PA 17055, return receipt requested, attached hereto and made a part hereof. Respectfully submitted, JOHNSON, DUFFIE, STEWART & WEIDNER By: 4?? ck g Q?X' Keirsten W. Davidson :120209.0 uaPc.W 026 626 955 Recelptjo Cenlfl"o i^,,,, mo ed Mall e ^a uM" for w.`No ProwGtl. i BENDER: .OoTpa• Mnr t rNbN b. •OalorW MrN•M. ?, t also wish to roc*m ft •Ortiir• i. u4 rxl M , nwa . bkwkV wvlmt (for an •rr • uOnM •Md YOV?uiw?. a M IMrM of IMSbrm so IM we can tram pis gxtm 1N : •AUM 1rrbmb Wd kW a" nW 4 p 00, Of m pr b" M pw 6M na t. C3 Aftooss sAftems 0" ft RSOp w1 ff o i w'?` fi RNhktW pMvMy • ? w •fww 0 %ft ft w arM 2. P w wfid del :a r a rM °r" B " Cantl/1 DWL'IWbf ttX too. 4L rUM• unr»r t??lC l i ?nll?C(!t l)? 955 . :6.?U . . I loll 1W6 14I1c /li,VC ,o.. c o Rpbbnd IN G? , ?l(?.?r lr?, ht r??s? <<, b a ma o ?w••• o Ranp4p 13 coo 7. to nr ., y1 , y , r e. rN.N. fad u Sind /N b altQ ! P f p J P8 P ae11, Do wntmr 1 nnws•rsot>o merit c etum ann of ipK ... L C`? +J 1 Johnson, Duffle, Stewart & Weidner By: Kcirsicn W. Davidson I.D. No. 78243 301 Market Street P. 0. BOX 109 Lemoyne, Pennsylvania 17043.0109 (717) 761-4540 JAMES W. LINGLE, Plaintiff V. PATRICIA M, LINGLE, Defendant Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-6493 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE 1. A Complaint In divorce under Section 3301(c) of the Divorce Code was filed on October 25, 1099. 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. Ict Date: 0 Q' ed 67 James W. Lingl , Plamti :1]rJ02 u A ? ? CL U y aAYt .t v? Johnson, Duffle, Stewart & Weidner By: Keirstcn W. Davidson I.D. No. 78243 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 JAMES W. LINGLE, Atlomcys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. PATRICIA M. LINGLE, Defendant NO. 99-6493 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE 1. I consent to the entry of a final decree in divorce without notice. 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. 1 verify that the statements made in this Waiver 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: hl-owe - James W. Ling lali ff :137302.2 r' rj" h t?? N 1 f? !3 . .:Fyn: Johnson, Duffle, Stewart & Weidner By: Kcirstcn W. Davidson I.D. No. 78243 301 Market Strecl P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 JAMES W. LINGLE, Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. PATRICIA M. LINGLE, NO. 99-6493 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE Defendant 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on October 25, 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 1 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.p ( )? Date: 0 ?J 'ICJ ! f. ?' Patricia M. Lingle, Defendant :137302.3 !1J? N 1 G: ? i jly O G U Johnson, Duffle, Stewart & Weidner By: Kcirstcn W. Davidson I.D. No. 78243 301 Market Street P. O. Box 109 Lemoyne, Pennsylvania 17043-0109 (717) 761-4540 Attorneys for Plaintiff JAMES W. LINGLE, Plaintiff V. PATRICIA M. LINGLE, 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, lawyers 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. verify that the statements made in this Waiver 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. l dv Date: E 16, Patricia M. Lingle, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-6493 CIVIL TERM CIVIL ACTION - LAW :137302.4 fl' CO , r(l nl r7 757 y, ? t?.i..: N - rq r.. I:. r n Cl xe:.? I {{ . }yyyy 'r 6? n v i a? )f fA ? Y n of a IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL, ACTION - LAW ?f}IIIPS ly. L//V ?L ? Plaintiff vs. ?gTRIC//? A L /N (aG? Defendant File No. % / (?7/, IN DIVORCE NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff/Defendant in the above matter, having been granted a day of?eq?, 2VDQ- prior surname of R'6y4d pursuant to the this written H- - DATE::-- ----._.- Final Final Decree in Divorce on the hereby elects to resume the , and gives provisions of 54 P.S. S 704. Signature U Sigqgaturc of name being resumed A1, 99VA1q COMMONWEALTH OF PENNSYLVANIA: SS. COUNTY OF CUMBERLAND On the _f day of c em6er" abefore me, a Notary Public, Personally appe:creVI t:he above affiant known to me to be the person whose name in subscribed to the within document and acknowledged that he/she executed the foregoing for the purpose therein contained. In WiLneus Whereof, I have hercunLo set my hand and official seal. Notary Pu c SEAL ENotary Public of Carlisle, Cumberland County ommission E¦ nos Nov. 8. 2000 G? 4 ?' ?r r? U N ?4 . !? ; y?. ??? Ll J '? ? J? i 1 ? ?J? ? f Y? u °o v :' i 2.. o' P O ?'