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HomeMy WebLinkAbout07-2382Crystal V. Danner, :1N THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW v NO. /~ ~ r ~ '3 b ~ C?~ v o l ~"GTn. .. .._ llustin A. Danner, U Defendant IN DIVORCE NOTICE 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 eniered agains~ yuu by ~iiC 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 at the Cumberland County Court House, High and Hanover Streets, Carlisle. 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 32 South Bedford Street Carlisle, PA 17013 Phone: (717) 249-3166 ~b~o~~~u-yl~a AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. l;rystal V. llanner, : IN ~1~H~ C;OUKT Or' CUMMUN PLLAS U~ Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW v. No. ~, D -~ , 1 3 ~~ c : ,~ ~ I t~r,~. Dustin A. Danner, Defendant IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Crystal V. Danner, who currently resides at 1555 Centerville Road, Newville, Cumberland County, Pennsylvania, 17241. 2. Defendant is Dustin A. Danner, who currently resides at 1555 Centerville Road, Newville, Cumberland County, Pennsylvania, 17241. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on June 20, 2003, in Carlisle, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available, and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 8. Plaintiff requests the Court to enter a Decree in Divorce. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree in Divorce and such other Orders as may be just and appropriate. Date: ~ ~l~.'~ .1 ~ ~Gp, Respectfully submitted, ROMINGER & ASSOCIATES Karl E. Rominger, Esquire Attorney for Plaintiff 155 South Hanover Street Carlisle, PA 17013 Supreme Court I.D. #81924 (717) 241-6070 VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworn falsification to authorities. Date: ~ l°~5 ~ Y . -~ C stal V. Danner, Plaintiff Crystal V. Danner, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW v. No. Dustin A. Danner, Defendant IN DIVORCE CERTIFICATE OF SERVICE I, Karl E. Rominger, Esquire, attorney for Plaintiff, Crystal V. Danner, do hereby certify that I this day served a copy of the Divorce Complaint upon the following by depositing same in the United States mail, First Class Mail, Certified, Restricted and Return Receipt Requested, postage paid, at Carlisle, Pennsylvania, addressed as follows: Dustin A. Danner 1555 Centerville Road Newville, Pa 17241 Date:(/ l/1 ~ Z.f Zo~~ ~_ Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, Pa 17013 (717) 241-6070 Court Id. No. 81924 Attorney for Plaintiff C7 ~' ^~ Q ~i i~_~ `J- ~- ~- ~ ~ ; - N G7 _ 1~ ~ ~ ~ ~ "' ~ C.3 .~ ~ ~ t~ -C"le CRYSTAL V. DANKER, IN THE COURT OF COMMON PLEAS OF plaintiff, :CUMBERLAND COUNTY, PENNSYLVANIA ~, : CIVII, ACTION -LAW 2007-2382 CIVIL TERM DUSTIN A. DANKER, . Defendant. : IN DIVORCE ACCEPTANCE OF SERVICE I, Douglas G. Miller, Esquire, attorney for the Defendant in the above-captioned matter, hereby agree on behalf of my client, Daniel A. Danner, to accept service of the Complaint which was filed on April 25, 2007. Douce G. er, Eagdire - Irwin, Mc ght & Hughes 60 West Pomfret Street Carlisle, PA 17013 Attorney for Defendant Date: ~ - ~V , 2007 a ~ ~ ~~ nom' . -r3 ~ . <-- r= ~ ` N cl'ti ,s. ~ ,,~ ~~~ f-rte J 'sue "~. ~.,, CRYSTAL V. DANKER, Plaintiff, v. DUSTIN A. DANKER, Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW 2007-2382 CIVIL TERM IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on April 25, 2007. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the complaint. 3. I consent to the entry of a final decree in divorce. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. (-.,~ \ ` Date: `"1 '~~~~ Y CRYS L V. DANK Plaintiff ~"~ __ r~~ _ .J . _~ , , . ' u 'r ~S;w-_t ha C7 r,> " _ - V ~ .. .. CRYSTAL V. DANNER, Plaintiff, v. DUSTIN A. DANNER, Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW 2007-2382 CIVIL TERM IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on April 25, 2007. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the complaint. 3. I consent to the entry of a final decree in divorce. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. ~~ ~ ~~ Date: ~ ~ (` ~? ~ DUSTIN A. DANNER Defendant ~"'~ ~ ~") = c~ t, .. .,._a .--t ~..~~;~- ;~,J C -' ' ( 7 .7 =Y1 ,_ ,~ ~'._ ~~ CRYSTAL V. DANNER, Plaintiff, v. DUSTIN A. DANNER, Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW 2007-2382 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. I consent to the entry of a final Decree of Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: ~ " ~'~ `~ ~ 1 J ~ 1' ' CRYST V. DAN R Plaintiff C-- -~~ `. } "'+"i _ f f+Y ~~ t _ ~ ^ i ~~ '"'_ .? ~~'_ _ -, ~ ._ -- ~'S ,, ~. F ~/4~ CRYSTAL V. DANNER, Plaintiff, v. DUSTIN A. DANNER, Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW 2007-2382 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(cZOF THE DIVORCE CODE 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 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 made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. .-~.. ~ '. Date: ~ ~ ,~ ~ _ CJ~ DUSTIN A. DANNER Defendant t' S ~) ~~f ~^ `~~ ~{~ ~~ `~ v ~Y T` } ~ ..~ ' 4T 4r..+ - ", ~ ~ ~~ ~°'..% ~ ~l.v. 47_ ~3~~ MARRIAGE SETTLEMENT AGREEMENT THIS AGREEMENT made this csL ~`Sfi day of ~~(~}-{ ~~ ~}'; 2007, by and between CRYSTAL V. DANNER, (hereinafter referred to as "WIFE") and DUSTIN A. DANNER, (hereinafter referred to as "HUSBAND"). WITNESSETH: WHEREAS, HUSBAND and WIFE were lawfully married on June 20, 2003, and separated on or about Apri128, 2007; and WHEREAS, diverse, unhappy differences, disputes and difficulties have arisen between the parties and it is the intention of HUSBAND and WIFE to live separate and apart for the rest of their natural lives, and the parties hereto are desirous of settling fully and finally their respective financial and property rights and obligations as between each other, including, but not limited to the settling of all matters between them relating to the ownership and equitable distribution of real and personal property, the settling of all claims and possible claims by one against the other or against their respective estates, and the equitable distribution of property and alimony for each party. The parties hereto agree and covenant as follows: 1. The parties intend to maintain separate and permanent domiciles and to live apart from each other. It is the intent and purpose of this Agreement to set forth the respective rights and duties of the parties while they continue to live apart from each other. 2. The parties have attempted to divide their matrimonial property in a manner which conforms to a just and right standard, with due regard to the rights of each party. It is the intent of the parties that such division shall be final and shall forever determine their respective rights. The division of existing marital property is not intended by the parties to constitute in any way a sale or exchange of assets. 3. Further, the parties agree to continue living separately and apart from the other at any place or places that he or she may select as they have heretofore been doing. Neither party shall molest, harass, annoy, injure, threaten or interfere with the other party in any matter whatsoever. Each party may carry on and engage in any employment, profession, business or other activity as he or she may deem advisable for his or her sole use and benefit. Neither party shall interfere with the uses, ownership, enjoyment or disposition of any property now owned and not specified herein or property hereafter acquired by the other. 4. The consideration for this contract and agreement is the mutual benefit 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, and the parties intend to be legally bound hereby. Each party to the Agreement acknowledges and declares that he or she, respectively: (1) Is represented by counsel of his or her own choosing, or if not represented by counsel, understands that he or she has the right to counsel: HUSBAND is represented by Douglas G. Miller, Esquire of Irwin & McKnight; WIFE was formerly represented by Karl E. Rominger, Esquire of Rominger & Associates, and now chooses not to be represented by counsel, and !y 'nitialing this page acknowledges her right to be represented by counsel V ; (2) Is fully and completely informed of the facts relating to the subject matter of this Agreement and of the rights and liabilities of the parties; 2 (3) Is entering into this Agreement voluntarily after receiving the advice of counsel or after choosing not to consult an attorney; (4) Has given careful and mature thought to the making of this Agreement; (5) Has carefully read each provision of this Agreement; and (6) Fully and completely understands each provision of this Agreement, both as to the subject matter and legal effect of each provision. This Agreement shall become effective immediately as of the date of execution. 5. It is the purpose and intent of this Agreement to settle forever and completely the interest and obligations of the parties in all property that they own separately, and all property that would qualify as marital property under the Pennsylvania Divorce Code, Title 23, Section 401(e), and that is referred to in this Agreement as "Marital Property", as between themselves, their heirs and assigns. The parties have attempted to divide their Marital Property in a manner that conforms to a just and fair standard, with due regard to the rights of each party. The division of existing Marital Property is not intended by the parties to constitute in any way a sale or exchange of assets, and the division is being effected without the introduction of outside funds or other property not constituting a part of the marital estate. It is the further purpose of this Agreement to settle forever and completely any obligation under the Pennsylvania Divorce Code. relating to spousal support or alimony. 6. 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, including any mortgage, pledge, lien, charge, security interest, encumbrance, or restriction to which any property is subject. Each party further represents that he or she has made a full and fair disclosure of all debts and obligations of any nature for which he or she is currently liable or may become liable. Each 3 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. Each Party acknowledges that, to the extent desired, he or she has had access to all joint and separate State and Federal Tax Returns filed by or on behalf of either or both Parties during marriage. 7. REAL ESTATE: WIFE agrees to transfer all right, title and interest which he may have in that marital property located at 1555 Centerville Road, Newville, Cumberland County, Pennsylvania, 17241, and any improvements thereon, to HUSBAND and releases all claims which she may have regarding said real estate in accordance with this paragraph. HUSBAND agrees to pay any outstanding payments on any mortgages on said property, as well as all real estate taxes, insurance, and any maintenance and repair costs, and hold WIFE harmless from any obligations on said payments and indemnify him if any claim is made against her. In furtherance of the transfer of all right, title and interest in said real estate, WIFE hereby agrees to execute a Deed conveying her interest in the property to HUSBAND. Said Deed shall be held in escrow by the law firm of Irwin & McKnight until such time that HUSBAND refinances, assumes, or satisfies the outstanding mortgage liens, in order to remove WIFE from the outstanding mortgages on said property, which shall occur within six (6) months of the signing of this Agreement. Upon completion of the refinancing or assumption of the mortgages against the property by HUSBAND, the Deed shall be filed of record with the Cumberland County Recorder of Deeds. 8. SUPPORT: It is the mutual desire of the parties that HUSBAND will not be required to pay spousal support, alimony, alimony pendente lite, or any other financial support to WIFE, and that WIFE will not be required to pay spousal support, alimony, alimony pendente lite, or 4 any other financial support to HUSBAND. 'The parties thereby waive any rights they have to receive spousal support, alimony or alimony pendente lite payments from the other either prior to or following the entry of the Divorce Decree in this matter. 9. PERSONAL PROPERTY: The parties agree that the personal property has been divided to the parties' mutual satisfaction. WIFE hereby waives all right, title and interest which she may have in any personal property in the possession of HUSBAND. HUSBAND likewise waives any right, title and interest which he has in any personal property in the possession of WIFE. Henceforth, each of the parties shall own, have and enjoy independently of any claim or right of the other party, all items of personal property of every kind, nature and description and wherever situated, which are then owned or held by or which may hereafter belong to HUSBAND or WIFE with full power to HUSBAND or WIFE to dispose of the same as fully and effectually, in all respects and for all purposes as if he or she were unmarried. 10. AUTOMOBILES: WIFE hereby waives all right, title and interest in any vehicle that HUSBAND currently owns or may own in the future, and specifically waives all right, title and interest to the 2005 Ford 500 currently used by HUSBAND and titled in his name. HUSBAND shall hold WIFE harmless for any and all liability associated with the use and purchase of any vehicle he may own, and shall be solely responsible for all insurance, loans, and other financial responsibility associated with said vehicles. Likewise, HUSBAND hereby waives all right, title and interest in any vehicle that WIFE currently owns or may own in the future, and specifically waives all right, title and interest to the Ford Expedition currently used by WIFE. WIFE shall hold HUSBAND harmless for any and all liability associated with the use and purchase of any vehicle she may own, and shall be solely 5 responsible for all insurance, loans, and other financial responsibility associated with said vehicles. 11. MARITAL DEBTS: It is the understanding of the parties that, other than the mortgages secured by the marital residence addressed in Paragraph Seven above, there are no longer any loans, debts, credit cards, or similar obligations for which they are jointly responsible. The parties specifically acknowledge that a home equity loan was obtained in 2007 in order to satisfy the balance of several credit cards of the parties, which home equity loan is be assumed by HUSBAND in accordance with Paragraph 7 above. Nevertheless and in addition thereto, HUSBAND hereby agrees to remove WIFE'S name from any and all other joint accounts within sixty (60) days of the execution of this Agreement or upon discovery of any such joint obligations. WIFE also hereby agrees to remove HUSBAND'S name from any and all other joint accounts within sixty (64) days of the execution of this Agreement or upon discovery of any such joint obligations. The parties agree to pay any such debts according to the party who incurred any said obligation and hold harmless the other party from any obligations on said payments and indemnify the other if any claim is made against him or her. Furthermore, it is mutually agreed by and between the parties that WIFE shall assume all liability for and pay and indemnify the HUSBAND against all debts incurred by WIFE after the date of separation. WIFE represents and warrants to HUSBAND that since the parties' marital separation she has not contracted or incurred any debt or liability for which HUSBAND or his estate might be responsible and WIFE further represents and warrants to HUSBAND that she will not contract or incur any debt or liability after the execution of this Agreement, for which HUSBAND or his estate might be responsible. WIFE shall indemnify and hold HUSBAND harmless from any and all claims or demands made against him by reason of debts or obligations incurred by her. 6 HUSBAND shall similarly assume all liability for and pay and indemnify WIFE against all debts incurred by HUSBAND after the date of separation. HUSBAND represents and warrants to WIFE that since the parties' marital separation he has not contracted or incurred any debt or liability for which WIFE or her estate might be responsible and HUSBAND further represents and warrants to WIFE that he will not contract or incur any debt or liability after the execution of this Agreement, for which WIFE or her estate might be responsible. HUSBAND shall indemnify and hold WIFE harmless from any and all claims or demands made against her by reason of debts or obligations incurred by him. 12. INSURANCE AND EMPLOYEE BENEFITS: The parties agree that any life insurance policies on the life of HUSBAND or WIFE, as well as any employee benefits, including but not limited to retirement, profit sharing or medical benefits of either party, shall be their own. WIFE waives all right, title, and claim to HUSBAND'S employee benefits, and HUSBAND waives all right, title, and claim to any of WIFE'S employee benefits. 13. BENEFITS AND BANK ACCOUNTS: WIFE agrees to waive all right, title and interest which she may have in the savings or checking or any other bank accounts of HUSBAND and likewise HUSBAND agrees to waive all right, title and interest which he may have in the savings or checking or any other bank accounts of WIFE. In the event any joint bank accounts currently exist, the parties agree that the funds in any said account shall be divided equally between the parties, and the account closed with thirty (30) days. 7 14. DIVORCE: The parties both agree to cooperate with each other in obtaining a final divorce of the marriage. It is agreed that the parties will execute and file the consents necessary to obtain the divorce. Any party who fails to cooperate with obtaining the Divorce shall pay all the costs and legal fees of the party who is seeking the divorce. 15. BREACH: If either party breaches any provisions of this Agreement, the other party shall have the right, at his or her election, to sue for damages for such breach or seek such other remedies or relief as may be available to him or her, and the party breaching this contract shall be responsible for payment of legal fees and costs incurred by the other in enforcing their rights under this Agreement. 16. ADDITIONAL INSTRUMENTS: Each of the parties shall from time to time, at the request of the other, execute, acknowledge and deliver to the other party any and all further instruments that may be reasonably required to give full force and effect to the provisions of this Agreement. 17. VOLUNTARY EXECUTION: The provisions of this Agreement and their legal effect have been fully explained to the parties by their respective counsel, are fully understood by both parties, and each party acknowledges that the Agreement is fair and equitable, that it is being entered into voluntarily, and that it is not the result of any duress or undue influence. It is the parties' intent that this Agreement does not merge with the Divorce Decree, but rather shall continue to have independent contractual significance. Each party maintains his or her contractual remedies or any other remedies provided by law or statute. Those remedies shall 8 include, but not be limited to, damages resulting from breach of this Agreement, specific enforcement of this Agreement and remedies pertaining to failure to comply with an order of court or agreement pertaining to equitable distribution, alimony, alimony pendente lite, counsel fees and costs as set forth in the Pennsylvania Divorce Code or other similar statutes now in effect and as amended or hereafter enacted. 1 S. ENTIRE AGREEMENT: This Agreement contains the entire understanding of the parties and there are no representations, warranties, covenants or undertakings other than those expressly set forth herein. 19. APPLICABLE LAW: This Agreement shall be construed under the Laws of the Commonwealth of Pennsylvania. 20. PRIOR AGREEMENTS: It is understood and agreed that any and all property settlement agreements which may or have been executed prior to the date and time of this Agreement are null and void and of no effect. 21. WAIVER OF CLAIMS AGAINST ESTATES: Except as herein otherwise provided, each party may dispose of his or her property in any way, and each party hereby waives and relinquishes any and all rights he or she may now have or hereafter acquire, under the present or future laws of any jurisdiction, to share in the property or the estate of the other as a result of the marital relationship, including without limitation, dower, curtesy, statutory allowance, widow's allowance, right to take in intestacy, right to take against the Will of the other, and right to act as administrator or executor of the other's estate, and each will, at the request of the other, execute, 9 acknowledge and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interests, rights and claims. IN WITNESS WHEREOF, the parties hereunto have set their hands and seals the day and year first above written. WITNESSES: ~c~c, h ~ R ST V. DAN L ,',, ~ ~ DUST N A. DANNER COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND . SS: PERSONALLY APPEARED BEFORE ME, this ~ day of ~ J YY1~~ 2007, CRYSTAL V. DANNER, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Marriage Settlement Agreement, and acknowledges that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and o~s,}al seal. COMMONWEALTH OF PE NSY VANIA Notarial Seel Martha L Noel, Notary PubNc CarNale Bao, Ambariard Cflunty My Carrnisaion E~ires Sept 16.2011 Member, PermsylveMa Assoc{eNon of gotartea Notary 10 r COMMONWEALTH OF PENNSYLVANIA . SS: COUNTY OF CUMBERLAND PERSONALLY APPEARED BEFORE ME, this ~~day of„r~ j; 2007, DUSTIN A. DANNER, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Marriage Settlement Agreement, and acknowledges that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. CONMAONWEALTH OF PENNSYLVANIA Notadel Seel Mettle L Noel, Notary PubMc CatAsie eo% (?unbeAard Caur~ly My Qantrissiat E~N'ee Sept 18, 2011 Member, PermsyFvaMa Assoderbn of Notaries 11 t') n~ c -_, _ a t~ r~ ~ f.~ ~~ ,;.r ! X41 -Tr `.4f ~i,i ~3 j , CRYSTAL V. DANNER, Plaintiff, v. DUSTIN A. DANNER, Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW 2007-2382 CIVIL TERM IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: decree: Code. Transmit the record, together with the following information, to the court for entry of a divorce 1. Ground for Divorce: irretrievable breakdown under Section 3301(c) and/or (d) of the Divorce 2. Date and manner of service of complaint: A certified copy of the Complaint in Divorce was served upon defendant, Dustin A. Danner, on or about Apri130, 2007. The Acceptance of Service of Service was filed with the Prothontoary on or about September 25, 2007. 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by plaintiff: September 21, 2007 by defendant: September 21, 2007 Code: (b)(1) Date of execution of the affidavit required by Section 3301(d) of the Divorce (b)(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 plaintiffs Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: September 28, 2007 Date defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: September 28, 2007 Douglas Miller, Esquire Attorney r Plaintiff Date: September 28, 2007 " Iv ) F ~~ C: J ,, . C,' a " .~~ . i , t_ ~ ; F'~' - , ~. .. -~ ^~.) ~ i ~'3 ":s ; ~-, `~ ~ ~ • _«; !t C J _ ,. 1 N T'H E COURT' OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. .:~ ., CRYSTAL O. DANKER, Plaintiff VERSUS DIISTIN A. DANKER Defendant AND NOW, ~ O , 2007-2382 DECREE IN DIVORCE o~.+ a ~ ~O ~, IT IS ORDERED AND DECREED THAT CRYSTAL O. DANKER PLAINTIFF, AND DIISTIN A. DANKER ,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 Marriage Settlement Agreement dated September 21, 2007, and signed by the parties is hereby incorporated i decree but not merged. T: ATTEST: J , PROTHONOTARY ~~~ ,~ - ~ ~~ ~ ~~' a ,! 4