HomeMy WebLinkAbout99-07017s
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF PENNA.
Deborah Hadley-Bush Jy''
N o. 99-7017
Plaintiff
VERSUS
Gerald K. Bush
Defendant
DECREE IN
DIVORCE
AND NOW, r) O ID e l 3 DO , IT IS ORDERED AND
DECREED THAT Deborah Hadley-Bush PLAINTIFF,
Gerald K. Bush
AND DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED;
The parties' Marital Settlement agreement dated August 23, 2002 is
incorporated herein and the Court has jurisdiction over no other claims.
A
BY THE COURT: 17
CA L.) C?
A ST: i
ROTHONOTARY
m °,I
/O?fc? li
DEBORAH HADLEY-BUSH,
Plaintiff
V.
GERALD K. BUSH,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY,PENNSYLVANIA
CIVIL ACTION - LAW
NO.C(? CIVIL l0
IN DIVORCE
MARRIAGE SETTLEMENT AGREEMENT
ARTICLE I
STATUS OF PARTIES
1.01 Marriage. The parties were married on November 20, 1976, in Amherst, Erie
THIS AGREEMENT is made this ?) 3 `1 day of 2002, between
DEBORAH J. HADLEY-BUSH, of Norfolk County, Massachusetts, hereinafter referred
to as "Wife", and GERALD K. BUSH, of Cumberland County, Pennsylvania, hereinafter
referred to as "Husband".
In consideration of the mutual undertakings herein contained, and intending to be legally
bound hereby, the parties agree as follows:
County, New York, and ever since that date have been, and are now, husband and wife.
1.02 Separation The parties are now living separate and apart, and consider
September 4,1999 as the "Date of Separation". The Wife presently resides in Brockton,
Norfolk County, Massachusetts and the Husband presently resides in Camp Hill,
Cumberland County, Pennsylvania.
P. _I
1.03 Interference Each party shall be free from interference, authority and control
of the other as fatly as if he or she were single or unmarried, except as may be necessary
to carry out the provisions of this Agreement. Neither party shall molest or attempt to
endeavor to molest the other, or compel the other to cohabit with the other or in any way
harass or malign the other, or in any other way interfere with their peaceful existence,
separate and apart from the other.
1.04 Children The parties have two children born of their marriage, Jeremy M.
Bush, born 03-22-83 and Kyle A. Bush, born 05.21-94.
ARTICLE 11
CONSIDERATION AND PURPOSES
2.01 Consideration The consideration for this Agreement is the mutual benefits to
be obtained by both of the parties hereto and the covenants and agreements of each of the
parties to the other. The adequacy of the consideration for all agreements herein
contained is stipulated, confessed, and admitted by the parties.
2.02 Settlement of Pronerty It is the purpose and intent of this Agreement to settle
forever and completely the interests and obligations of the parties in all separate and
marital property as between themselves, their heirs and assigns. The parties have
attempted to allocate and divide the marital property in a manner which conforms to a
just and fair standard. As used herein, the term "marital property" shall include all
property so defined by Section 3501 of the Pennsylvania Divorce Code.
ARTICLE III
PROPERTY SETTLEMENT
3.01 Real Pronerty. The parties own no real property.
3.02 Personal Property Division. (a) The parties have divided to their mutual
satisfaction all tangible items of personal property with the exception of those items
reflected at Exhibit A which are presently in the possession of Husband and which will
be transferred on or before the date of this Agreement to the Wife.
(b) Subject to this agreement, upon and after the date of execution of this Agreement,
Husband shall own, have and enjoy as his separate property, all that personal property,
including motor vehicles, in his possession, and Wife shall own, have and enjoy as her
separate property, all that personal property, including motor vehicles, in her possession.
Each party shall assume all debts and insurance obligations for their respective motor
vehicles.
3.03 Debts and Obligations. Each of the parties shall assume all debts and
obligations presently in their individual names, and shall indemnify and hold the other
harmless from said debts and obligations. Each party hereby agrees to pay and hereby
agrees to hold the other harmless from any and all personal debts and obligations incurred
by him or her on or after the date of separation. If any claim, action or proceeding is
hereafter brought, seeking to hold the other party liable on account of any such debts and
obligations, such party will at his or her sole expense defend the other party against any
such claim, action or proceeding whether or not well-founded, and indemnify the other
party against any loss resulting therefrom.
3.04 After Acquired Personal Property. Except as provided in this Agreement,
each of the parties hereafter own and enjoy, independently of any claims or right of the
other, all items of personal property, tangible or intangible, acquired after September 4,
1999, or hereafter acquired by him or her, with fill power in him or her to dispose of the
same as filly and effectively, in all respects and for all purposes, as though he or she were
unmarried.
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3.05 Full Disclosure. Each party represents and warrants that he or she has made a
full and fair disclosure to the other of all of his or her property interests of any nature
whatsoever and that such property is subject to no mortgage, pledge, lien, charge,
security interest, encumbrance, or restriction, except those which are disclosed herein.
Each party further represents and warrants that he or she has not made any gifts or
transfers for inadequate consideration of marital property without the prior consent of the
other.
3.06 Fair Division of Property. By this Agreement the parties have intended to
effect a fair division of their marital property. The parties have determined that the
division of such property hereunder conforms to a just and fair standard with due regard
to the rights of each party. The parties agree that the division of property herein is proper
and complete division of their marital property under Chapter 35 of the Pennsylvania
Divorce Code, and each party hereto renounces and waives the right to bring before any
court in any jurisdiction the matter of division of their marital property, except as
provided in this Agreement. The parties agree to cooperate in executing any documents
or taking any steps necessary to effectuate a transfer of title to said property.
3.07 Pensions. Each party agrees that the other party shall retain sole ownership,
possession and interest of any and all retirement, pension, profit-sharing or similar finds
or accounts standing solely in his or her name. Each party shall have the right to borrow,
cash in policies, change beneficiaries, and otherwise exercise any other incidents of
ownership of his or her respective accounts, funds, or policies, free of any right or claim
by the other party. Each party agrees to sign any documents necessary to transfer
ownership or ownership interest in such funds, accounts or policies to the respective party
who presently owns such.
4
ARTICLE, IV
ALIMONY
4.01 Alimony. The parties hereby agree that each waives all rights and entitlement
to alimony, alimony pendite lite and/or spousal support from the other.
ARTICLE V
CUSTODY
5.01 Custody. The parties hereby agree that all issues relating to child custody
shall be handled separately in the current proceedings presently active in Cumberland
County.
ARTICLE VI
CHILD SUPPORT
6.01 Child Support. The parties hereby agree that all issues relating to child
support shall be handled separately in the current proceedings presently active in
Cumberland County.
6.02 Life Insurance. Each party hereby agrees to maintain the life insurance
currently in full force and effect and to name Jeremy M. Bush and Kyle A. Bush as
beneficiaries until the youngest of the said children graduates from college or becomes
otherwise emancipated, or until either Husband or Wife remarry, whichever occurs first.
ARTICLE VII
TAXES OF HUSBAND AND WIFE
7.01 Federal Income Tax Returns. Husband and Wife each concur that they have
filed individual income tax returns for the year 1999 and will continue to do so
subsequently. Any tax owing or refund due because of any such return shall be the sole
obligation of or property of the party filing said return. For all individual lax returns filed
for the tax years 1999 and subsequently, the Husband shall be entitled to take Jeremy M.
Bush as a dependency deduction until the time that Jeremy graduates from college or any
other post-high school education program or becomes otherwise emancipated. For tax
years 1999 and 2000, the Wife shall be entitled to take Kyle A. Bush as a dependency
deduction. Commencing in tax year 2001, the Husband shall claim Kyle A. Bush in the
odd tax years and the Wife shall claim Kyle A. Bush in the even tax years. This alternate
year deduction between Husband and Wife shall continue until Kyle A. Bush reaches the
age of 18 or becomes otherwise emancipated. Husband and Wife agree to execute within
one week of request all forms required by the Internal Revenue Service or other taxing
authorities to carry out the terms of this paragraph.
ARTICLE VIII
FEES AND COSTS
8.01 Attorney's Fees and Other Costs. It is agreed that each party shall be responsible for
their own attorney's fees and any other costs incurred in connection with their separation,
divorce, division of property and any related matters.
ARTICLE IX
GENERAL PROVISIONS
9.01 Approval by Court. This Agreement may be submitted to a court of
appropriate jurisdiction in any action for the divorce of the parties, with the request by
either party for its approval and for its inclusion as part of the Decree of Divorce granting
said divorce. Said inclusion shall not constitute a merger with the Divorce Decree, but
shall be entered as an Order for enforcement purposes only.
9.02 Agreement Voluntary and Clearly Understood. Each party acknowledges and
declares that he or she respectively:
(a) Is 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 after receiving the advice of
independent counsel;
(c) Has given careful and mature thought to the making of this Agreement;
(d),Has carefully read each provision of this Agreement; and
(e) Fully and completely understands each provision of this Agreement, both as to
the subject matter and legal effect.
9.03 Release of All Claims. Each party hereto releases the other from all claims
liabilities, debts, obligations, actions and causes of action of every kind that have been
incurred relating to or arising from the marriage between the parties, whether under the
Pennsylvania Divorce Code or otherwise. However, neither party is relieved or
discharged from any obligation under this Agreement or under any instrument or
document executed pursuant to this Agreement.
9.04 Indemnification. Each party represents and warrants to the other that he or
she has not incurred any debt, obligation or other liability, other than those described in
this Agreement, on which the other party is or may be liable. Each party covenants and
agrees that if any claim, action or proceeding is hereafter initiated seeking to hold the
other party liable for any such other debt, obligation, liability, act or omission of such
party, such party will, at his or her sole expense, defend the other against any such claim
or demand, whether or not well-founded, and that he or she will indemnify and hold
harmless the other party in respect of all damages resulting therefrom. Damages, as used
herein, shall include any claim, action, demand, loss, cost, expense, liability (joint or
several), penalty and other damage, including without limitation counsel fees and other
costs and expenses reasonably incurred in investigating or in attempting to avoid same or
oppose the imposition thereof or in enforcing this indemnity, resulting to Husband and
Wife from (a) any inaccurate representation made by or on behalf of either Husband or
Wife to the other in or pursuant to this Agreement; or (b) breach of any of the warranties
made by or on behalf of Husband or Wife in or pursuant to this Agreement. Husband and
Wife shall reimburse the other on demand for any payment made by such party at any
time after the execution of this Agreement, based on the judgment of any court of
competent jurisdiction or pursuant to a bona fide compromise or settlement of claims,
demands, or actions, in respect of any damages to which the foregoing indemnity relates.
Husband or Wife agrees to give the other prompt written notice of any litigation
threatened or instituted against either party which might constitute the basis of a claim for
indemnity by either Husband or Wife against the other pursuant to the terms of this
Agreement.
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9.05 Waiver of Rights to Other Party's Estate. Husband and Wife each hereby
renounces and waive any and all right:
(a) To inherit any part of the estate of the other at his or her death, unless
bequeathed or devised pursuant to a Will or codicil.
(b) To receive property from the estate of the other by bequest or devise,
including rights under a testamentary trust, except under a Will or codicil.
(c) To elect an elective share in the estate or other property or income of the other,
whether under Chapter 22 of the Pennsylvania Probate Estates and Fiduciaries Code or
otherwise under the laws of any other jurisdiction.
(d) To act as a personal representative of the estate of the other on intestacy,
unless nominated by another party legally entitled so to act.
(e) To act as a personal representative under the Will of the other, unless so
nominated by a Will or codicil.
(f) To receive proceeds of insurance on the life of the other, if the insured at death
had the right to change the beneficiary, except pursuant to a beneficiary designation
jurisdiction or pursuant to a bona fide compromise or settlement of claims, demands, or
actions, in respect of any damages to which the foregoing indemnity relates. Husband or
Wife agrees to give the other prompt written notice of any litigation threatened or
instituted against either party which might constitute the basis of a claim for indemnity by
either Husband or Wife against the other pursuant to the terms of this Agreement.
9.06 Representation of Parties by Counsel. Wife has been represented by Joanne
Harrison Clough, Esquire and Husband has been represented by Jacqueline M. Verney,
Esquire in connection with the negotiation, preparation and review of this Agreement.
This Agreement has been fully explained to each party. Each party has carefully read this
Agreement and is completely aware, not only of its contents, but also of its legal effect.
9.07 Interpretation of Agreement. This Agreement should be interpreted fairly and
impartially and not strictly for or against either of the parties.
9.08 Execution of Other Documents. Each of the parties shall on demand execute
and deliver to the other any deeds, bills of sale, assignments, consents to change of
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beneficiaries of insurance policies, tax returns, and other documents, a Stipulation for a
Qualified Domestic Relations Order and do or cause to be done any other acts and 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, including but not limited to those reasonably incurred to enforce
compliance.
9.10 Entire Agreement. 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.
9.11 Partial Invalidity. If any provision of this Agreement is held by a court of
competent jurisdiction to be invalid, void or unenforceable, the remaining provisions
shall nevertheless continue in fill force and effect without being impaired or invalidated
in any way.
9.12 Waiver of Breach. The waiver by one party of any breach of this Agreement
by the other party shall not be deemed a waiver of the same or of any other provision of
this Agreement.
9.13 Amendment or Modification. The provisions of this Agreement may be
amended or modified only by a written instrument signed by both parties.
9.14 Successors and Assigns. This Agreement shall be binding on and shall inure
to the benefit of the respective legatees, devisees, heirs, executors, administrators,
assigns and successors in interest of the parties.
9.15 Law Governing Agreement. This Agreement shall be governed by and shall
be construed in accordance with the laws of the Commonwealth of Pennsylvania.
IN WITNESS WHEREOF, the parties hereto have set their hands on the date and
year first above written, intending to be legally bound hereby.
WITNESS:
COMMONWEALTH OF MASSACHUSETTS:
DEBO AH J. HADL - -BUSH
C?
,ERALD K. BUST
COUNTY OF NORFOLK
On this, the, day of r 2002, before me, the
undersigned officer, personally appae ed?s DEBORAH J. HADLEY-BUSH, known to me
to be the person whose name is subscribed to the foregoing document and acknowledged
that she executed the foregoing for the purpose therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and notarial seal.
Notary Public
460? MY COMMiSSION E,\r-iPES
MAY 2, 2000
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
On this, the a A ^-? day of??_. 2002, before me, the
undersigned officer, personally app red GERALD K. BUSH, known tome to be the
person whose name is subscribed to the foregoing document and acknowledged that he
executed the foregoing for the purpose therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and notarial seal.
Notary Public
Notarial Seal
Mary J. Millovich, Notary Public
Camp Hill Boro, Cumberland County
My Commission Expires Feb. 16. 2004
Member, Pennsylvania Association at NotadeS
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EXHIBIT A
The liillowing personal property is in the Husband's possession and shall be transferred
to the Wife:
1. Bell collection
2. "Cello" and "Last Supper" needlepoint rendered by the Wife
3. All needlepoint and materials rendered by the Wife
4. Large watercolor Painting hanging in the Husband's living room
5. The remaining books and files belong to Wife
6. Cross country skis, poles and boots
7. Vegetable bin
8. Dry sink
9. Teacups given to Wife by her grandmother
10. Cherry table currently stored in the basement
11. Painting, pen & ink drawings rendered by the Wife's grandfather and aunt with
the exception of the paintings in the boys' bedrooms (2 sailboat and 1 lighthouse)
12. Piano stool which belonged to Wife's grandmother
13. Cappuccino machine
It is further noted that the piano, a family item, currently in the Husband's basement shall
not be sold, given away, or disposed of without mutual agreement from the Wife.
EXHIBIT B
The following marital debts incurred by both the Wife and the Husband during their
marriage from November 20, 1976 until their separation on September 4, 1999 will be
the responsibility of the Wife:
1. ECMC (NYHESC)
2.NYHESC
3. David/Catherine Hadley
3. Factory Finance*
4. Capital One*
5. Providian Bank*
Student loans 1976-1981 $18,972.04
Student loan SUNYAB 1997 6,200.00
Personal Loan 10,000.00
Car loan (1990 Buick LeSabre) 625.00
Credit Card 708.00
Credit Card 2622.36
*Discharged through Chapter 7 Bankruptcy Filing. Case number 1-01-03661
represented by Matthew Eshelman 2108 Market Street Camp Hill, PA 17011
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DEBORAH HADLEY-BUSH,
Plaintiff
V.
GERALD K. BUSH,
Defendant
To the Prothonotary:
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,PENNSYLVANIA
CIVIL ACTION
NO. 99-7017 CIVIL TERM
IN DIVORCE
PI2AECIPE TO TRANSMIT RECORD
Transmit the record, together with the following information to the court
for entry of a divorce decree:
1. Grounds for divorce: irretrievable breakdown under Section 3301 (c), 3301
(d)(1) of the Divorce Code. (Strike out inapplicable section).
I Date and manner of service of the Complaint: Sheriff's service dated
December 1, 1999.
3. Complete either paragraph (a) or (b).
(a) Date of execution of the affidavit of consent required by sec. 3301 (c ) of
the Divorce Code: by plaintiff September 16, 2002; by defendant
September 16,M.
(b) (1) Date of execution of the affidavit required by sec. 3301 (d) of the
Divorce Code:
(2) Date of filing and service
of the plaintiff's affidavit upon the defendant
4. Related claims pending: None
5. Complete either(a) or (b).
(a) Date and manner of service of the Notice of Intention to file Praecipe to
transmit record, a copy of which is attached
(b) Date plaintiff's Waiver of Notice in sec. 3301 (c) Divorce was filed with
the Prothonotary: September 25, 2002•
Date defendant's Waiver of Notice in sec. 3301 (c) Divorce was filed with
the Prothonotary: September 25,
q y? _? y (Attorney for Defendant
Jacqueline M. Verney, Esquire
44 South Hanover Street
Carlisle, PA 17013
(717) 243-9190
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DEBORAH HADLEY-BUSH, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
V. No. 'i - 70 7 CIVIL
GERALD K. BUSH,
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, Dauphin County Courthouse, Harrisburg, PA.
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 LAWYER REFERRAL SERVICE
Court Administrator
Cumberland County Courthouse
Carlisle, PA 17013
(717) 240-6200
DEBORAH HADLEY-BUSH, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
V. : NO. CIVIL
GERALD K. BUSH,
Defendant : IN DIVORCE
N TI IA
Le han demandado a usted en la corte. Si usted guiere defenderse de estas demandas
expuestas en ]as paginas siguientes, usted tiene viente (20) dies de plazo a] partir de la fecha de la
demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por
abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en
contra de su persona. Sea avisado que si usted no se defiende, la sin previo aviso o notificacion y
por cualquier queja o alivio que es pedido en la peticion de demanda. Usted puede perder dinero
o sus propiedades o otros derechos importantes para usted.
LLEVE ESTA DEMANDA A UN ABODAGO MAIEDIATAMENTE. SI NO TIENE
ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO,
VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE
ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR
ASSISTENCIA LEGAL.
CUMBERLAND COUNTY LAWYER REFERRAL SERVICE
Court Administrator
Cumberland County Courthouse
Carlisle, PA 17013
(717) 240-6200
DEBORAH HADLEY-BUSH, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
V. : NO.9 4 - 7 v i•7 CIVIL
GERALD K. BUSH,
Defendant : IN DIVORCE
COMPLAINT
Plaintiff is Deborah Hadley-Bush, an adult individual who currently resides at
4173 Grouse Court, Apartment 102, Mechanicsburg, Cumberland County, Pennsylvania 17055
2. Defendant is Gerald K. Bush, an adult individual who currently resides at 4
Hunter Lane, East Pennsboro Township, Cumberland County, Pennsylvania 17011.
3. The Plaintiff has been a bona fide resident in the Commonwealth of Pennsylvania
for at least six (6) months immediately previous to the filing of this Complaint.
4. Plaintiff and Defendant were married on November 20, 1976 in Amherst, Erie
County, New York.
5. There have been no prior actions for divorce or annulment filed by either of the
parties hereto.
6. The marriage is irretrievably broken.
Plaintiff has been advised of the availability of counseling and that Plaintiff has the
right to request that the Court require the parties to participate in counseling.
8. Defendant in this action is not presently a member of the United States Armed
Forces or any of its allies.
9. Plaintiff requests the Court to enter a decree of divorce.
COUNTI
COMPLAINT UNDER SECTION 3301(c) OR
3301 M OF THE DIVORCE CODE - NO FAULT
10. The averments of the preceding Paragraphs are incorporated herein by reference as
if set forth again in full.
WHEREFORE, Plaintiff respectfully requests the Court to enter a Decree of Divorce,
pursuant to Section 3301 (c) or 3301(d) of the Divorce Code.
COUNT II
EQUITABLE DISTRIBUTION OF MARITAL PROPERTY
11. During the course of the marriage, the parties have acquired various items of both
real and personal property which are subject to equitable distribution by the court.
WHEREFORE, Plaintiff prays this Court to equitably distribute the marital property
pursuant to 23 Pa.C.S. §3502.
COUNT III
COUNSEL FEES. COSTS AND EXPENSES
12. Plaintiff is without sufficient funds to support herself and to pay counsel fees and
the costs and expenses incidental to this divorce action.
WHEREFORE, Plaintiff prays this court will award costs, counsel fees and expenses as
may be incurred in pursuit of this action, pursuant to 23 Pa.C.S. §3702 and any other further relief
this Court may decree.
Respectfully submitted,
W &
Date: I I I 1
Dither E. Mllspaw, Jr., Esquire
Attorney ID # 19226
130 State Street, P.O. Box 946
Harrisburg, PA 17108
(717) 236-0781TAX (717) 236-0791
Attorneys for Plaintiff
DEBORAH HADLEY-BUSH, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
V. : NO. CIVIL
GERALD K. BUSH,
Defendant : IN DIVORCE
VERIFICATION
I, the undersigned Plaintiff , Deborah Hadley-Bush, verify that the statements made in this
Complaint in Divorce 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: &hayx' w
Deborah Hadley-Bush
,.A
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SHERIFF'S RETURN - REGULAR
CASE NO: 1999-07017 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
HADLEY-BUSH DEBORAH
VS.
BUSH GERALD
CPL. MICHAEL BARRICK , Sheriff or Deputy Sheriff of
CUMBERLAND County, Pennsylvania, who being duly sworn according
to law, says, the within COMPLAINT - DIVORCE was served
upon BUSH GERALD K the
defendant, at 12:05 HOURS, on the 1st day of December
1999 at 30 HUNTER LANE
CAMP HILL, PA 17011 CUMBERLAND
County, Pennsylvania, by handing to GERALD K. BUSH
a true and attested copy of the COMPLAINT - DIVORCE
together with NOTICE
and at the same time directing His attention to the contents thereof.
Sheriff's Costs: So answers:
Docketing 18.00
Service 9.30
Affidavit .00 /
Surcharge 8.00 II?? R-1 omas ine, 5 eri
X12/06.A199gBESHORE
by
epu'y b ri
Sworn and subscribed to before me
this ivy day of /?« Gw
19 /iq A.D.? y-
y"'f ??ro ono r
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DEBORAH HADLEY-BUSH,
Plaintiff
V.
GERALD K. BUSH,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
:NO. 99-7017 CIVIL TERM
: IN DIVORCE
AFFIDAVIT OF CONSENT
A Complaint in Divorce under Section 3301 (c) of the Divorce Code was
filed on November 19, 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.
I consent to the entry of a final decree of divorce after service of notice of
intention to request entry of the decree.
I verify that the statements made in this Affidavit are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S.
section 4904, relating to unswom falsification to authorities.
Date: OG !'N G2 '
DeboHa ey-Bush, P 'tiff
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DEBORAH HADLEY-BUSH,
Plaintiff
V.
GERALD K. BUSH,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: NO. 99-7017 CIVIL TERM
: IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE
DECREE UNDER SECTION 3301 (C) OF THE DIVORCE CODE
I. I consent to the entry ofa 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. section 4904
relating to unswom falsification to authorities.
Date ?jD ?2 (? hlfY{?l (!Q (l
Deborah Ftad(dy-Bush aintiff
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DEBORAH HADLEY-BUSH,
Plaintiff
V.
GERALD K. BUSH,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION-LAW
:NO. 99-7017 CIVIL TERM
: IN DIVORCE
AFFIDAVIT OF CONSENT
A Complaint in Divorce under Section 3301 (c) of the Divorce Code was
filed on November 19, 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.
I verify that the statements made in this Affidavit are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S.
section 4904, relating to unsvvom falsification to authorities.
Date: Z* p.7 era K. Bush, Defe tt
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V O U
DEBORAH HADLEY-BUSI1,
Plaintiff
V.
GERALD K. BUSH,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: NO. 99-7017 CIVIL TERM
: IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE
DECREE UNDER SECTION 3301 (C) OF THE DIVORCE CODE
1. 1 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. 1 understand that I will not be divorced until a divorce decree is entered by the Court
and that a copy of the decree will be sent to me immediately after it is filed with the
prothonotary.
I verify that the statements made in this affidavit are true and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa.C.S. section 4904
relating to unsworn falsification to authorities.
Date: /b Oy ?r?
er< K. Bush, Defe ant
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In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
DEBORAH J. HADLEY-BUSH ) Docket Number 99-70017 CIVI
Plaintiff ) D30636
VS. ) PACSES Case Number 356103416/D30636
GERALD K. BUSH )
Defendant ) Other State ID Number
ORDER
AND NOW, to wit on this 31ST DAY OF JULY, 2001 IT IS HEREBY
ORDERED that the O Complaint for Support or Q Petition to Modify or ® Other
filed on APRIL 26, 2001 in the above captioned
ALIMONY PENDENTE LITE
matter is dismissed without prejudice due to:
AN AGREEMENT OF THE PARTIES.
O The Complaint or Petition may be reinstated upon written application of the plaintiff
petitioner.
BY THE COURT:
DRO: R.l ShaddaY
xc: plaintiff
defendant
,7oanre Harrison Clough, Esquire
Jacqueline Verney, Esquire
?21"?3?2n Edgar B. GE
Service Type M
(? CVVC\
Form OE-506
Worker ID 21005
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