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HomeMy WebLinkAbout01-0394 FXIN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. RANDY E. STEPHENSON N O. 01-394 CIVIL TERM VERSUS KIM J. STEPHENSON DECREE IN DIVORCE AND NOW, ?` " _ ' ? 2001 , IT IS ORDERED AND DECREED THAT RANDY E. STEPHENSON , PLAINTIFF, AND KIM J. STEPHENSON DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; NONE.. See Marital Settlement Agreement attached as Exhibit A to be incorporated but not merged into the final divorce decree. OTHONOTARY eu 1l G ey MARITAL SETTLEMENT AGREEMENT THIS AGREEMENT, made this day of 2001, by and between Randy E. Stephenson (hereinafter "Husband") of Mechanicsburg, Cum erland County, Pennsylvania and Kim J. Stephenson (hereinafter "Wife") of Kintnersville, Bucks County, Pennsylvania. WITNESSETH: WHEREAS, the parties are Husband and Wife, married on June 30,1998 in Jamaica; and WHEREAS, two children were born of the marriage, Ryan Neil Stephenson (d.o.b. 12/29/86) and R. Craig Stephenson (d.o.b. 6/24/89); and WHEREAS, unhappy differences and difficulties have arisen between the parties, in consequence of which the parties intend to live separate and apart for the rest of their natural lives; and WHEREAS, Husband and Wife are the Plaintiff and Defendant, respectively in a divorce action filed in the Court of Common Pleas of Cumberland County, Pennsylvania, to No. 01-394; and WHEREAS, the parties desire to settle fully and finally their respective financial and property rights and obligations as between each other, including but not limited to the ownership and equitable distribution of real and personal property; past, present and future support, alimony and/or maintenance; and any and all claims which either party has, or may have, against the other or the other's estate; and WHEREAS, the parties desire to provide for the custody and support of their minor children; Document k: 197053.1 NOW, THEREFORE, in consideration of the mutual promises, covenants and undertakings hereinafter set forth and for other good and valuable consideration, receipt of which the parties acknowledge, Husband and Wife, each intending to be legally bound, hereby covenant and agree as follows: SEPARATION Each party shall have the right to live separate and apart from the other party, free from the other party's interference, authority and control. Neither party shall interfere with the other or attempt to interfere with the other, nor compel the parties' cohabitation. 2. HUSBAND'S AND WIFE'S DEBTS Except as otherwise set forth in this Agreement, the parties represent and warrant to each other that they have not incurred and will not contract or incur any debt or liability for which the other or the other's estate might be responsible. Each party shall indemnify and save harmless the other party from any and all claims or demands made against the other by reason of debts or obligations incurred by that party. 3. WAIVER OF RIGHTS AND MUTUAL RELEASES Except as provided in this Agreement, both parties absolutely and unconditionally release and forever discharge each other and their heirs, executors, administrators, assigns, property and estate from any and all rights, claims, demands or obligations arising out of or by virtue of the marital relationship, whether such claims exist now or arise in the future. This release shall be effective regardless of whether such claims arise out of former or future acts, contracts, Document # 135035 -2- engagements or liabilities of the parties or by way of dower, curtesy, widow's rights, family exemption or similar allowance, or under the intestate laws, or the right to take against the spouse's will, or the right to treat a lifetime conveyance by the other as testamentary, or all other rights of a surviving spouse to participate in a deceased spouse's estate, whether arising under the laws of Pennsylvania, any state, commonwealth or territory of the United States, or other country. Except for any cause of action for divorce which either party may have or claim to have, and except for the obligations of the parties contained in this Agreement, each party gives to the other an absolute and unconditional release and discharge from all causes of action, claims, rights or demands whatsoever, in law or in equity, which either party ever had or now has against the other, including but not limited to alimony, alimony pendente lite, spousal support, equitable distribution of marital property, counsel fees or expenses. 4. REAL ESTATE a. House. The parties own as tenants by the entireties improved real estate situated on 66 Beverly Drive, Kintnersville, Pennsylvania 18930. Within ninety (90) days upon execution of this Agreement, Wife shall obtain refinancing and shall assume sole responsibility for the mortgage on said property and agrees to indemnify husband therefor. Wife shall assume sole responsibility for the taxes and insurance on said property and agrees to indemnify Husband therefor. In the event that Wife does not obtain refinancing to remove Husband's name from the mortgage, the property shall be sold. In the event the property must be sold due to the inability of Wife to obtain refinancing, all proceeds from the sale of the property shall go to Wife. b. Time Share. The parties own as tenants by the entireties a time share with Document It 135035 -3- Epic Vacations. Husband shall assume sole responsibility for the payments on said property and agrees to indemnify Wife therefor. In the event the time share is sold, the proceeds will go to husband. DIVISION OF PERSONAL PROPERTY Each parry will retain any and all assets owned by them individually prior to the date of marriage. Except as otherwise provided herein, all personal property acquired by the parties during the marriage shall be the sole and separate property of Wife. Those items listed on Exhibit "A" shall be the sole and separate property of Husband. Wife agrees to provide Husband with the items listed on Exhibit "A" thirty (30) days after execution of this Agreement. 6. MOTOR VEHICLES Husband shall retain sole and exclusive ownership of the 2000 Ford F350 vehicle in his possession and agrees to assume sole responsibility for all outstanding encumbrances, if any. Wife shall retain sole and exclusive ownership of the 2001 Monte Carlo vehicle in her possession and agrees to assume sole responsibility for all outstanding encumbrances, if any. Wife shall be responsible for removing husband's name from the title and loan of this vehicle. Both parties agree to execute, within five (5) days of the date of this Agreement, any and all forms, titles and documents necessary to transfer the aforesaid vehicles from joint ownership to individual ownership, as specified herein. Document N 135035 -4- 7. JOINT DEBTS The parties acknowledge that they have no debts which were jointly incurred during their marriage with the exception of the following: ACCOUNT Homeside Lending Epic Vacations CommonwealthBank Husband agrees to assume full and sole responsibility for the payment of the following debts and agrees to indemnify Wife for any loss sustained as a result of his failure to do so: CommonwealthBank Loan Epic Vacations Time Share Wife agrees to assume full and sole responsibility for the payment of the following debts and agrees to indemnify Husband for any loss sustained as a result of his failure to do so: Homeside Lending Mortgage 8. RETIREMENT BENEFITS AND IRAs Both parties waive, release, renounce and forever abandon all of their right, title, interest or claim, whatever it may be in any individual retirement account/investment account of the other Document # 135035 -5- parry, if any. 9. DIVISION OF BANK ACCOUNTS Husband and Wife acknowledge that all joint bank accounts have been closed or divided to their mutual satisfaction prior to the execution of this Agreement. 10. AFTER-ACOUIREDPROPERTY Each of the parties shall own and enjoy, independently of any claims or rights of the other, all real property and all items of personal property, tangible or intangible, hereafter acquired, with full power to dispose of the same as fully and effectively as though he or she were unmarried. Any property so acquired shall be owned solely by that party and the other party shall have no claim to that property. 11. SPOUSAL SUPPORT, ALIMONY PENDENTE LITE, AND ALIMONY Husband and Wife waive and relinquish all rights, if any, to spousal support, alimony pendente lite, and alimony. Any transfer of monies between the parties pursuant to any term of this Agreement shall not constitute alimony but is made as part of the parties' equitable distribution settlement. 12. TAX MATTERS The parties have negotiated this Agreement with the understanding and intention to divide their marital property. The parties have determined that such division conforms to a right and just standard with regard to the rights of each party. The division of existing marital property is not, except as may be otherwise expressly provided herein, intended by the parties to constitute in any Document # 135035 -6- way a sale or exchange of assets. It is understood that the property transfers described in this Agreement fall within the provisions of section 1041 of the Internal Revenue Code, and as such will not result in the recognition of any gain or loss upon the transfer by the transferor. Wife shall be entitled to claim the dependency exemption for Ryan on all applicable tax returns and Husband agrees to take all necessary steps and sign all required documents to effectuate Wife's claiming the exemption. Husband shall be entitled to claim the dependency exemption for Craig on all applicable tax returns and Wife agrees to take all necessary steps and sign all required documents to effectuate Husband's claiming the exemption. 13. CUSTODY a. The parties shall share joint legal custody of the minor children. b. The parties shall share joint physical custody of the minor children. C. Custody and visitation shall be arranged by agreement between the parties. d. Both parties shall utilize their best efforts to encourage a loving and nurturing relationship between the children and both parents, e. Both parties will refrain from making any negative or derogatory comments regarding the other party to or in the presence of the children. f. Neither party will move the children outside the state of Pennsylvania without at least sixty (60) days written notice to the other parent and either the written consent of that parent or a court order permitting said removal. Document # 135035 -7- 14. HEALTH INSURANCE Wife agrees to pay for continued coverage under Wife's employer provided health insurance for the minor children, unless otherwise agreed by both parties. 15. COUNSEL FEES AND EXPENSES Except as otherwise specified herein, each party shall be responsible for payment of his/her own counsel fees and expenses. 16. ADVICE OF COUNSEL The parties acknowledge that each has received or has had the opportunity to receive independent legal advice from counsel of their selection and that they have been informed fully as to their legal rights and obligations, including all rights available to them under the Pennsylvania Divorce Code of 1980 as amended, and other applicable laws. Each party confirms that he/she understands fully the terms, conditions, and provisions of this Agreement and believes them to be fair, just, adequate and reasonable under the existing circumstances. The parties further confirm that each is entering into this Agreement freely and voluntarily and that the execution of this Agreement is not the result of any duress, undue influence, collusion, or improper or illegal agreement. 17. AFFIDAVITS OF CONSENT Each party agrees to execute an Affidavit of Consent for the obtaining of a no-fault divorce under the provisions of the Divorce Code of 1980, as amended. Document # 134035 -8- 18. EFFECT OF DIVORCE DECREE ON AGREEMENT Either party may enforce this Agreement as provided in section 3105(a) of -the Divorce Code, as amend As provided in section 3105(c), provisions of this Agreement regarding equitable distribution, alimony, alimony pendente lite, counsel fees or expenses shall not be subject to modification by the court. 19. DATE OF EXECUTION The "date of execution", "date of this agreement" or "execution date" of this Agreement is the date upon which it is signed by the parties if they sign the Agreement on the same date. Otherwise, the "date of execution", "date of this agreement" or "execution date" shall be the date on which the last party signed this Agreement. 20. HEADINGS NOT PART OF AGREEMENT The descriptive headings preceding the paragraphs are for convenience and shall not affect the meaning, construction or effect of this Agreement. 21. SEVERABILITYAND INDEPENDENT AND SEPARATE COVENANTS Each separate obligation shall be deemed to be a separate and independent covenant and agreement. If any term, condition, clause or provision of this Agreement shall be determined or declared to be void or invalid in law or otherwise, then only that tern, condition, clause or provision shall be stricken from this Agreement and in all other respects this Agreement shall be Document H 135035 -9- valid and continue in full force, effect and operation. 22. AGREEMENT BINDING ON HEIRS This Agreement shall be binding on and shall ensure to the benefit of the parties and their respective heirs, executors, administrators, successors, and assigns. 23. INTEGRATION This Agreement constitutes the entire understanding of the parties and supersedes any and all prior agreements and negotiations between them. There are no representations, warranties, covenants or promises other than those expressly set forth in this Agreement. 24. MODIFICATION OR WAIVER TO BE IN WRITING No modification or waiver of any term of this Agreement shall be valid unless in writing and signed by both parties. 25. NO WAIVER OF DEFAULT The failure of either parry to insist upon strict performance of any term of this Agreement shall in no way affect the right of such party hereafter to enforce the term. 26. VOLUNTARY EXECUTION The parties acknowledge that this Agreement is fair and equitable, and that they have reached this Agreement freely and voluntarily, without any duress, undue influence, collusion or improper or illegal agreements. 27. APPLICABLELAW This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania and more specifically under the Divorce Code of 1980, as amended. Document # 135035 -10- 28. ATTORNEYS' FEES FOR ENFORCEMENT If either party breaches any provision of this Agreement, the breaching party shall pay all reasonable legal fees and costs incurred by the other in enforcing this Agreement, providing that the enforcing party is successful in establishing that a breach has occurred. IN WITNESS WHEREOF, the parties have set their hands and seals the day and year first written above. WITNESS: Document# 135035 -11- SCHEDULE"A" Any and all of Randy's personal items. 2. Randy'stools. Document N: 197053.1 s10'k W /a wa ss COUNTY OF iUl(CCCC?L/ On this, the May of 2001, before me, the undersigned officer, personally appeared RANDY E. STEPHENSON known tome or satisfactorily proven to be the person whose name is subscribed to in the foregoing Marital Settlement Agreement, and acknowledge that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. MyCoi nissionExpires: M-Ab-00-11 COMMONWEALTH OF PENNSYLVANIA ss COUNTYOF OC/CZ On this, the ?? day of ?y , 2001, before me, the undersigned officer, 5 personally appeared KIM J. STEPHENSON known to me or satisfactorily proven to be the person whose name is subscribed to in the foregoing Marital Settlement Agreement, and acknowledge that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal i C3o t. My Commission Expires: Notarial seal L-Baabara Demasi, Notary Public kertown Boro, Bucks County mmission Expires Aug. 8, 2002 -13- C> o C7 - ?_ ? 1 va T2 C^ N ?. i'n RANDY E. STEPHENSON : IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. Ql - 29X ?lU?l l" " 1 KIM J. STEPHENSON, CIVIL ACTION -LAW Defendant COMPLAINT IN DIVORCE NOTICE TO: KIM J. STEPHENSON, Defendant 66 Beverly Drive Kintnersville,PA 18930 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 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, I Courthouse Square, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Lawyer Referral Service 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 Document #: 194824.1 RANDY E. STEPHENSON : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. O/- 31rY & Q -rze,_ KIM J. STEPHENSON, CIVIL ACTION -LAW Defendant COMPLAINT IN DIVORCE COMPLAINT IN DIVORCE 1. The Plaintiff is Randy E. Stephenson, an adult individual residing at 4184 Cove Court, #110, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. The Defendant is Kim J. Stephenson, an adult individual residing at 66 Beverly Drive, Kintnersville, Bucks County, Pennsylvania 18930. 3. Plaintiff and Defendant have been a bona fide residents of the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on June 30,1998 in Jamaica. 5. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Rights Act of the Congress of 1940 and its amendments. 6. Plaintiff's social security number is 456-41-7927 and Defendant's social security number is 158-64-7136. 7. There have been no prior actions of divorce or for annulment betweenthe parties. 8. 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. Document #: 194824.1 9. The Plaintiff and Defendant are the parents of two children. Name Date of Birth Ryan Neil Stephenson 12/29/86 R. Craig Stephenson 6/24/89 COUNTI Divorce 10. The averments of paragraphs 1-9 hereof are incorporated herein by reference. 11. The marriage is irretrievably broken. 12. The parties have been living separate and apart since July 31, 2000. 13. Plaintiff requests the Court to enter a Decree in Divorce divorcing Plaintiff and Defendant. COUNT II Equitable Distribution 14. The averments of paragraph 1-13 are incorporated herein by reference. 15. During the marriage the parties acquired marital property, assets, and debts which Plaintiffrequests the Court equitably distribute and assign. Document #: 194824.1 WHEREFORE, Plaintiff requests that this Court enter a Decree in Divorce, enter an Order equitably distributing marital property and enter such other Orders as are appropriate and just. METZGER, WICKERSHAM, KNAUSS & ERB By Melissa L. Stickel, Esquire Attorney I.D. 85869 Attorneys for Plaintiff 3211 North Front Street Date: ID I Harrisburg, PA 17110-0300 J/ l rl Document k: 194824.1 VERIFICATION I, Randy E. Stephenson hereby certify that the facts set forth in the foregoing Complaint in Divorce are true and correct to the best of my knowledge, information and belief, and that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unswom falsification to authorities. Date: Document #: 194814.1 .9 d 4D 8 Cam, ? ?? 10:b .1 1 RANDY E. STEPHENSON Plaintiff V. KIM J. STEPHENSON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-394 CIVIL TERM CIVIL ACTION - LAW COMPLAINT IN DIVORCE AFFIDAVIT OF SERVICE I, Melissa L. Stickel, counsel for Plaintiff, Randy E. Stephenson, hereby certify that a true and correct copy of the Complaint in Divorce was served upon the following, by certified mail, return receipt on February 3, 2001. Attached hereto, marked as Exhibit "A" and incorporated herein by reference is a copy of the return receipt card indicating service upon: Kim J. Stephenson 66 Beverly Drive Kintersville, PA 18930 METZGER, WICKERSHAM, KNAUSS & ERB, P.C. Ca J2?&l Melissa L. Stickel, Esquire I.D. No. 85869 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorney for Plaintiff Date: c'l ?L¢ ?d 1 Document #: 196839.1 RANDY E. STEPHENSON Plaintiff V. KIM J. STEPHENSON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-394 CIVILTERM CIVIL ACTION - LAW COMPLAINT IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Kindly transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of Complaint: A Complaint in Divorce was filed on January 19, 2001, and served on Defendant by certified mail on February 3, 2001. Affidavit of Service was filed February 8, 2001. 3. Complete either paragraph (a) or (b): (a) Date of execution of Plaintiffs and Defendant's Affidavits of Consent required by Section 3301(c) of the Divorce Code: Plaintiff- August 6, 2001, and filed August 7, 2001 Defendant- August 3, 2001, and filed August 7, 2001 (b)(1) Date of execution of Plaintiffs affidavit required by Section 3301(d) of the Divorce Code: N/A (2) Date of service of the Plaintiffs affidavit upon the defendant: N/A 4. Complete the appropriate paragraphs: (a) Related claims pending: None Document 4. 213743.1 (b) Claims withdrawn: None (c) Claims settled by agreement of the parties: N/A (d) State whether any written agreement is to be incorporated into the Divorce Decree. Yes, Attached hereto as Exhibit "D". (a) Date and manner of service of the Notice of Intention to File Praecipe to transmit record, a copy of which is attached, if the decree is to be entered under section 3301(d)(1)(i) of the Divorce Code: N/A (b) Date Plaintiffs Waiver of Notice in §3301(c) Divorce was filed with the prothonotary: August 7, 2001 Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the prothonotary: August 7, 2001 METZGER, WICKERSHAM, KNAUSS & ERB, P.C. By Melissa L. Stickel, Esquire Attorney I.D. No. 85869 3211 N. Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for Plaintiff Dated: ' I I'do 1 Document #: 213743.1 T.:. +? a?< w: _ ¦ Complete-Items 1, 2, end 3: Also complete hem 4 N Restricted Delivery Is desired. ¦ Mt your name and address on the Mersa so that we can return the card to you. ¦ Attach We card to the back of the mallPiece, or on the front if space permits. 1, Article Addressed to: Kim;j• Stephenson 66 Bj? erly Drive KinEersville, PA 18930 Y A 1Yn?-FMhro&6YV ter ?^?rl C. Sig re X r °Ad?t ? Addre: D. Is delivery address different from Rem 19 0 Yes R YES, enter delivery address below: ? No 3. Swvlce Type - M Certified Mail 1] Express Mail f7 Registered ? Return Receipt for Merv wdk I7 Insured Mail ? C.O.D. 4. Restricted DdVeryl (Exire fee) ® Yes 2. ArticleNumber(CopyfromswvkeAdmo 7099 3400 0014 1833 7023 PS Form 3811, July 1999 Domestic Return Receipt UNITED STATES POSTAL SERVICE ?T K f • Sender: Please print your name; address, and ZIP±4 in this box • ,_I , .__-_ First-Class MaR- Paslage & Fees Paid USPS Permit No. G-10 RANDY E. STEPHENSON : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 01-394 CIVIL TERM KIM J. STEPHENSON, : CIVIL ACTION -LAW Defendant : COMPLAINT IN DIVORCE CERTIFICATE OF SERVICE I, Melissa L. Stickel, Esquire, do hereby certify that I served a copy of the Affidavit of Service upon the Plaintiff and Defendant by mailing a copy to them, regular first class mail, on the 6th day of February, 2001, at: Randy E. Stephenson 4184 Cove Court, No. 110 Mechanicsburg, PA 17055 Kim J. Stephenson 66 Beverly Drive Kintnersville, PA 18930 METZGER, WICKERSHAM, KNAUSS & ERB, P.C. Melissa L. Stickel, Esquire I.D. No. 85869 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorney for Plaintiff Date: a 1(0 I Q Document #: 196839.1 BARBARA A. GOODLING, Plaintiff V. BRIAN A. GOODLING, Defendant : IN THE COURT OF COMMON PLEAS : OF THE 41ST JUDICIAL DISTRICT OF PENNSYLVANIA PERRY COUNTY BRANCH CIVIL ACTION - LAW 2001- 394 CIVIL TERM IN DIVORCE ACCEPTANCE OF SERVICE I, Michael J. Hanft, Esquire, attorney for the Defendant in the above-captioned matter, hereby agree on behalf of my client to accept service of the Complaint in Divorce, which was filed on May 3, 2001. &Y?* Michael J. Hanft, Esquire AT" i A 579'76 Law Offices of Michael J. Hanft 19 Brookwood Avenue Carlisle, PA 17013 Attorney for Defendant Date: t4" I Y 2001 ('1 A S ? CS i,? N ?L,i - t RANDY E. STEPHENSON : IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 01-394 CIVILTERM KIM J. STEPHENSON, CIVIL ACTION -LAW Defendant COMPLAINT IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on January 19, 2001 and served upon Defendant on February 3, 2001. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of 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. § 4904 relating to unworn falsification to authorities. Date: O Document k 211450.1 l t'?'afr cz - ?- zee, G =? C'7r f I RANDY E. STEPHENSON Plaintiff V. KIM J. STEPHENSON, Defendant .R IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-394 CIVILTERM CIVIL ACTION - LAW COMPLAINT IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE UNDER § 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 are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unworn falsification to authorities. Date: Q & I 01 Domwn: #: 211450.1 r, r r> c ?c ZC' DQ a C) ^G Ti jJ RANDY E. STEPHENSON : IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 01-394 CIVILTERM KIM J. STEPHENSON, CIVIL ACTION -LAW Defendant COMPLAINT IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on January 19, 2001 and served upon Defendant on February 3, 2001. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of 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. § 4904 relating to unworn falsificationto authorities. Date: 44i? J. Document N: 211450.1 Ir - . RANDY E. STEPHENSON Plaintiff V. KIM J.STEPHENSON, Defendant .F IN IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-394 CIVIL TERM CIVIL ACTION - LAW COMPLAINT IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE UNDER § 3301(c) OF TB E 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 are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unworn falsification to authorities. Date: J? cGs?l K' J. Step non Document#:211450.1 w A. a ' '1 C ['? "'f "'? L.J S RANDY E. STEPHENSON : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 01-394 CIVIL TERM KIM J. STEPHENSON, : CIVIL ACTION -LAW Defendant : COMPLAINT IN DIVORCE AFFIDAVIT OF SERVICE I, Melissa L. Stickel, counsel for Plaintiff, Randy E. Stephenson, hereby certify that a true and correct copy of the Complaint in Divorce was served upon the following, by certified mail, return receipt on February 3, 2001. Attached hereto, marked as Exhibit "A" and incorporated herein by reference is a copy of the return receipt card indicating service upon: Kim J. Stephenson 66 Beverly Drive Kintersville, PA 18930 Date: a/(B l o/ METZGER, WICKERSHAM, KNAUSS & ERB, P.C. Lru Melissa L. Stickel, Esquire I.D. No. 85869 3211 North Front Street r, P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 [ Attorney for Plaintiff r, Document #: 196839.1 ...µr.,..4 .::/ 1 . .. DER: COMPLETE THIS SECTION IN Complete ltetns 1, 2, and s: Also complete ..: item 4It Restricted Delivery is desired. ¦ Prim your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mallpiece, or on the front N space perks. 1. Anicle Addressed to: Kim ;1. Stephenson 66 Overly Drive Kintersville, PA 18930 UNITED STATES POSTAL SERVICE / ?? 6 %y?? 2. ArtldeNwnWtt``QWftmservicekW 7099 3400 0.014 1833:7023: ., PS Form 3811, July 1999 Domestic Return Receipt 1o2sgg da 6th 4i COMPL • &e ETE ..,. ,THIS dP) a. Data Of Do itn 5dv? -3-0 C. Si Sig n aadk& 0 w^-? n Agent X MA D. is derway address W mnt from Rem 1? n Yes N YFS, enter delivery address below: n No 3. S&VIWType M Certified Mail n Express Mail 0 Registered ? Retum Receipt for M&dwx re n §lsured Mall O O.O.D. 4. Resalcted Dellvaty? Pdra Fee) ® Yes _.. First-0le & F? aid f Pdstag USPS Permit 1Jo. G-10 • Sender: Please print xour pame, address, and ZIP±4 in this box •-L.. __,_ I MELISSA L. STICKEL, ESQUIRE METZGER WICKERSHAM KNAUSS & ERB PC 3211 N. FRONT STREET PO BOB 5300 HARRISBURG, PA 17110-0300 RANDY E. STEPHENSON : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 01-394 CIVIL TERM KIM J. STEPHENSON, : CIVIL ACTION -LAW Defendant : COMPLAINT IN DIVORCE CERTIFICATE OF SERVICE I, Melissa L. Stickel, Esquire, do hereby certify that I served a copy of the Affidavit of Service upon the Plaintiff and Defendant by mailing a copy to them, regular first class mail, on the 6"' day of February, 2001, at: Randy E. Stephenson 4184 Cove Court, No. 110 Mechanicsburg, PA 17055 Kim J. Stephenson 66 Beverly Drive Kinmersville, PA 18930 METZGER, WICKERSHAM, KNAUSS & ERB, P.C. Melissa L. Stickel, Esquire I.D. No. 85869 3211 North Front Street P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorney for Plaintiff Date: a I (p 10 l Document #: 196839.1 RANDY E. STEPHENSON IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 01-394 CIVILTERM n r, KIM J. STEPHENSON, CIVIL ACTION -LAW Defendant COMPLAINT IN DIVORCE z -G . AFFIDAVIT OF CONSENT s; ra < 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on January 19, 2001 and served upon Defendant on February 3, 2001. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of 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. § 4904 relating to unworn falsification to authorities. Date: "I i t- .1 o Document 9 : 211450.1 krv. RANDY E. STEPHENSON IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 01-394 CIVIL TERM c> t= - KIM J. STEPHENSON, CIVIL ACTION -LAW C; Defendant COMPLAINT IN DIVORCE c . m i-' Cn AFFIDAVIT OF CONSENT ?. 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on January 19, 2001 and served upon Defendant on February 3, 2001. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of 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. § 4904 relating to unworn falsificationto authorities. Date: S [? J. Do men( #: 111450.1 RANDY E. STEPHENSON : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 01-394 CIVILTERM KIM J. STEPHENSON, CIVIL ACTION -LAW Defendant COMPLAINT IN DIVORCE ' n 5.- co G' WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE UNDER § 3301(c) OF THE DIVORCE CODE i 2. I consent to the entry of a final decree of divorce without notice. i I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unworn falsification to authorities. Date: g 6 10 1 Doevment #: 211450.1 RANDY E. STEPHENSON Plaintiff V. KIM J. STEPHENSON, Defendant 1 2 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-394 CIVILTERM CIVIL ACTION - LAW COMPLAINT IN DIVORCE C? C -- U r t WAIVER OF NOTICE OF INTENTION TO REQUEST I consent to the entry of a final decree of divorce without nonce. 0 c :- -! (Xl I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unworn falsification to authorities. Date: 3 D 1 Ki J. Steph non Document N: 211450.1 MARITAL SETTLEMENT AGREEMENT THIS AGREEMENT, made this day of ?{ 1 1200 1, by and between Randy E. Stephenson (hereinafter "Husband") of Mechanicsburg, Cumberland County, Pennsylvania and Kim J. Stephenson (hereinafter "Wife") of Kintnersville, Bucks County, Pennsylvania. WITNESSETH: WHEREAS, the parties are Husband and Wife, married on June 30, 1998 in Jamaica; and WHEREAS, two children were born of the marriage, Ryan Neil Stephenson (d.o.b. 12/29/86) and R. Craig Stephenson (d.o.b. 6/24/89); and WHEREAS, unhappy differences and difficulties have arisen between the parties, in consequence of which the parties intend to live separate and apart for the rest of their natural lives; and WHEREAS, Husband and Wife are the Plaintiff and Defendant, respectively in a divorce action filed in the Court of Common Pleas of Cumberland County, Pennsylvania, to No. 01-394; and WHEREAS, the parties desire to settle fully and finally their respective financial and property rights and obligations as between each other, including but not limited to the ownership and equitable distribution of real and personal property; past, present and future support, alimony and/or maintenance; and any and all claims which either party has, or may have, against the other or the other's estate; and WHEREAS, the parties desire to provide for the custody and support of their minor children; Document N: 177053.1 NOW, THEREFORE, in consideration of the mutual promises, covenants and undertakings hereinafter set forth and for other good and valuable consideration, receipt of which the parties acknowledge, Husband and Wife, each intending to be legally bound, hereby covenant and agree as follows: 1. SEPARATION Each party shall have the right to live separate and apart from the other party, free from the other party's interference, authority and control. Neither party shall interfere with the other or attempt to interfere with the other, nor compel the parties' cohabitation. 2. HUSBAND'S AND WIFE'S DEBTS Except as otherwise set forth in this Agreement, the parties represent and warrant to each other that they have not incurred and will not contract or incur any debt or liability for which the other or the other's estate might be responsible. Each party shall indemnify and save harmless the other party from any and all claims or demands made against the other by reason of debts or obligations incurred by that party. 3. WAIVER OF RIGHTS AND MUTUAL RELEASES Except as provided in this Agreement, both parties absolutely and unconditionally release and forever discharge each other and their heirs, executors, administrators, assigns, property and estate from any and all rights, claims, demands or obligations arising out of or by virtue of the marital relationship, whether such claims exist now or arise in the future. This release shall be effective regardless of whether such claims arise out of former or future acts, contracts, Document N 135035 -2- engagements or liabilities of the parties or by way of dower, curtesy, widow's rights, family exemption or similar allowance, or under the intestate laws, or the right to take against the spouse's will, or the right to treat a lifetime conveyance by the other as testamentary, or all other rights of a surviving spouse to participate in a deceased spouse's estate, whether arising under the laws of Pennsylvania, any state, commonwealth or territory of the United States, or other country. Except for any cause of action for divorce which either party may have or claim to have, and except for the obligations of the parties contained in this Agreement, each party gives to the other an absolute and unconditional release and discharge from all causes of action, claims, rights or demands whatsoever, in law or in equity, which either party ever had or now has against the other, including but not limited to alimony, alimony pendente lite, spousal support, equitable distribution of marital property, counsel fees or expenses. 4. REAL ESTATE a. House. The parties own as tenants by the entireties improved real estate situated on 66 Beverly Drive, Kintnersville, Pennsylvania 18930. Within ninety (90) days upon execution of this Agreement, Wife shall obtain refinancing and shall assume sole responsibility for the mortgage on said property and agrees to indemnify husband therefor. Wife shall assume sole responsibility for the taxes and insurance on said property and agrees to indemnify Husband therefor. In the event that Wife does not obtain refinancing to remove Husband's name from the mortgage, the property shall be sold. In the event the property must be sold due to the inability of Wife to obtain refinancing, all proceeds from the sale of the property shall go to Wife. b. Time Share. The parties own as tenants by the entireties a time share with Document N 135035 -3- Epic Vacations. Husband shall assume sole responsibility for the payments on said property and agrees to indemnify Wife therefor. In the event the time share is sold, the proceeds will go to husband. 5. DIVISION OF PERSONAL PROPERTY Each parry will retain any and all assets owned by them individually prior to the date of marriage. Except as otherwise provided herein, all personal property acquired by the parties during the marriage shall be the sole and separate property of Wife. Those items listed on Exhibit "A" shall be the sole and separate property of Husband. Wife agrees to provide Husband with the items listed on Exhibit "A" thirty (30) days after execution of this Agreement. 6. MOTOR VEHICLES Husband shall retain sole and exclusive ownership of the 2000 Ford F350 vehicle in his possession and agrees to assume sole responsibility for all outstanding encumbrances, if any. Wife shall retain sole and exclusive ownership of the 2001 Monte Carlo vehicle in her possession and agrees to assume sole responsibility for all outstanding encumbrances, if any. Wife shall be responsible for removing husband's name from the title and loan of this vehicle. Both parties agree to execute, within five (5) days of the date of this Agreement, any and all forms, titles and documents necessary to transfer the aforesaid vehicles from joint ownership to individual ownership, as specified herein. Documen( N 135035 -4- 7. JOINT DEBTS The parties acknowledge that they have no debts which were jointly incurred during their marriage with the exception of the following: ACCOUNT Homeside Lending Epic Vacations Commonwealth Bank Husband agrees to assume full and sole responsibility for the payment of the following debts and agrees to indemnify Wife for any loss sustained as a result of his failure to do so: Commonwealth Bank Loan Epic Vacations Time Share Wife agrees to assume full and sole responsibility for the payment of the following debts and agrees to indemnify Husband for any loss sustained as a result of his failure to do so: Homeside Lending Mortgage 8. RETIREMENT BENEFITS AND IRAs Both parties waive, release, renounce and forever abandon all of their right, title, interest or claim, whatever it may be in any individual retirement account/investment account of the other Documew #135035 -5- parry, if any. 9. DIVISION OF BANK ACCOUNTS Husband and Wife acknowledge that all joint bank accounts have been closed or divided to their mutual satisfaction prior to the execution of this Agreement. 10. AFTER-ACOUIREDPROPERTY Each of the parties shall own and enjoy, independently of any claims or rights of the other, all real property and all items of personal property, tangible or intangible, hereafter acquired, with full power to dispose of the same as fully and effectively as though he or she were unmarried. Any property so acquired shall be owned solely by that party and the other party shall have no claim to that property. 11. SPOUSAL SUPPORT, ALIMONY PENDENTE LITE, AND ALIMONY Husband and Wife waive and relinquish all rights, if any, to spousal support, alimony enp dente lite, and alimony. Any transfer of monies between the parties pursuant to any term of this Agreement shall not constitute alimony but is made as part of the parties' equitable distribution settlement. 12. TAX MATTERS The parties have negotiated this Agreement with the understanding and intention to divide their marital property. The parties have determined that such division conforms to a right and just standard with regard to the rights of each party. The division of existing marital property is not, except as may be otherwise expressly provided herein, intended by the parties to constitute in any Document 9/35035 -6- way a sale or exchange of assets. It is understood that the property transfers described in this Agreement fall within the provisions of section 1041 of the Internal Revenue Code, and as such will not result in the recognition of any gain or loss upon the transfer by the transferor. Wife shall be entitled to claim the dependency exemption for Ryan on all applicable tax returns and Husband agrees to take all necessary steps and sign all required documents to effectuate Wife's claiming the exemption. Husband shall be entitled to claim the dependency exemption for Craig on all applicable tax returns and Wife agrees to take all necessary steps and sign all required documents to effectuate Husband's claiming the exemption. 13. CUSTODY a. The parties shall share joint legal custody of the minor children. b. The parties shall share joint physical custody of the minor children. C. Custody and visitation shall be arranged by agreement between the parties. d. Both parties shall utilize their best efforts to encourage a loving and nurturing relationship between the children and both parents. e. Both parties will refrain from making any negative or derogatory comments regarding the other party to or in the presence of the children. f. Neither party will move the children outside the state of Pennsylvania without at least sixty (60) days written notice to the other parent and either the written consent of that parent or a court order permitting said removal. Document N 135035 -7- 14. HEALTH INSURANCE Wife agrees to pay for continued coverage under Wife's employer provided health insurance for the minor children, unless otherwise agreed by both parties. 15. COUNSEL FEES AND EXPENSES Except as otherwise specified herein, each party shall be responsible for payment of his/her own counsel fees and expenses. 16. ADVICE OF COUNSEL The parties acknowledge that each has received or has had the opportunity to receive independent legal advice from counsel of their selection and that they have been informed fully as to their legal rights and obligations, including all rights available to them under the Pennsylvania Divorce Code of 1980 as amended, and other applicable laws. Each party confirms that he/she understands fully the terms, conditions, and provisions of this Agreement and believes them to be fair, just, adequate and reasonable under the existing circumstances. The parties further confirm that each is entering into this Agreement freely and voluntarily and that the execution of this Agreement is not the result of any duress, undue influence, collusion, or improper or illegal agreement. 17. AFFIDAVITS OF CONSENT Each party agrees to execute an Affidavit of Consent for the obtaining of a no-fault divorce under the provisions of the Divorce Code of 1980, as amended. Document 4135035 -8- 18. EFFECT OF DIVORCE DECREE ON AGREEMENT Either party may enforce this Agreement as provided in section 3105(a) of the Divorce Code, as amended. As provided in section 3105(c), provisions of this Agreement regarding equitable distribution, alimony, alimony pendente lite, counsel fees or expenses shall not be subject to modification by the court. 19. DATE OF EXECUTION The "date of execution", "date of this agreement" or "execution date" of this Agreement is the date upon which it is signed by the parties if they sign the Agreement on the same date. Otherwise, the "date of execution", "date of this agreement" or "execution date" shall be the date on which the last party signed this Agreement. 20. HEADINGS NOT PART OF AGREEMENT The descriptive headings preceding the paragraphs are for convenience and shall not affect the meaning, construction or effect of this Agreement. 21. SEVERABILITYAND INDEPENDENT AND SEPARATE COVENANTS Each separate obligation shall be deemed to be a separate and independent covenant and agreement. If any term, condition, clause or provision of this Agreement shall be determined or declared to be void or invalid in law or otherwise, then only that term, condition, clause or provision shall be stricken from this Agreement and in all other respects this Agreement shall be Document N 135035 -9- valid and continue in full force, effect and operation. 22. AGREEMENT BINDING ON HEIRS This Agreement shall be binding on and shall ensure to the benefit of the parties and their respective heirs, executors, administrators, successors, and assigns. 23. INTEGRATION This Agreement constitutes the entire understanding of the parties and supersedes any and all prior agreements and negotiations between them. There are no representations, warranties, covenants or promises other than those expressly set forth in this Agreement. 24. MODIFICATION OR WAIVER TO BE IN WRITING No modification or waiver of any term of this Agreement shall be valid unless in writing and signed by both parties. 25. NO WAIVER OF DEFAULT The failure of either party to insist upon strict performance of any term of this Agreement shall in no way affect the right of such parry hereafter to enforce the term. 26. VOLUNTARY EXECUTION The parties acknowledge that this Agreement is fair and equitable, and that they have reached this Agreement freely and voluntarily, without any duress, undue influence, collusion or improper or illegal agreements. 27. APPLICABLE LAW This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania and more specifically under the Divorce Code of 1980, as amended. Document # 135035 -10- 28. ATTORNEYS' FEES FOR ENFORCEMENT If either parry breaches any provision of this Agreement, the breaching party shall pay all reasonable legal fees and costs incurred by the other in enforcing this Agreement, providing that the enforcing party is successful in establishing that a breach has occurred. IN WITNESS WHEREOF, the parties have set their hands and seals the day and year first written above. WITNESS: Documew #/35035 -11- SCHEDULE "A" Any and all of Randy's personal items. 2. Randy'stools. Do umenl 4 : 197053.1 S-a e W ka uq CO ?E , , -PENNSYLVANIA- COUNTY OF ?(L? of ss On this, the May of j1,?, 2001, before me, the undersigned officer, personally appeared RANDY E. STEPHENSON known to me or satisfactorily proven to be the person whose name is subscribed to in the foregoing Marital Settlement Agreement, and acknowledge that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. My Co issionExpires: r?-2Lo-ca-, COMMONWEALTH OF PENNSYLVANIA COUNTY OF &uC/CZ On this, the /&. day of 2001, ss before me, the undersigned officer, personally appeared KIM J. STEPHENSON known to me or satisfactorily proven to be the person whose name is subscribed to in the foregoing Marital Settlement Agreement, and acknowledge that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal{ t? i \ My Commission Expires: r Notarial Seal Barbara nemasi, Notary Public Quakertown Burp, Bucks County P,•;? Commission Expires Aug. 8, 2002 -13- ,t, , RANDY E. STEPHENSON Plaintiff V. KIM J. STEPHENSON, Defendant ' ' . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-394 CIVILTERM CIVIL ACTION - LAW COMPLAINT IN DIVORCE CERTIFICATE OF SERVICE AND NOW, this of 2001, I, Melissa L. Stickel, Esquire, of Metzger, Wickersham, Knauss & Erb, attorneys for Plaintiff, Randy E. Stephenson, hereby certify that I served a copy of the Praecipe to Transmit Record this day by depositing the same in the United States mail, postage prepaid, at Harrisburg, Pennsylvania, addressed to: Kim J. Stephenson 66 Beverly Drive Kitnersville, PA 18930 METZGER, WICKERSHAM, KNAUSS & ERB, P.C. By: Melissa L. Stickel Document #: 213743.1