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HomeMy WebLinkAbout07-3606LAURIE J. SCHENHALS, I.N THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. D7- 3?bCo L NORBERT W. SCHENHALS, Defendant IN DIVORCE NOTICE TO DEFEND 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 at the 'Cumberland County Court House, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DECREE OF 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 (717) 249-3166 or 800-990-9108 SAIDIS, FWVVER^INQSAY SAIDIS, FLOWER & LINDSAY 26 West High Street Carlisle, PA Attorney Id. 44693 26 West High . tre Carlisle, PA 3 (717) 243-6222 Counsel for Plaintiff LAURIE J. SCHENHALS, Plaintiff V. NORBERT W. SCHENHALS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. O 7- 3404 IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) or (d) OF THE DIVORCE CODE 1. The Plaintiff is Laurie J. Schenhals, an adult individual, residing at 123 Hope Drive, Boiling Springs, Cumberland County, Pennsylvania 17007. 2. The Defendant is Norbert W. S-chenhals, an adult individual, residing at 123 Hope Drive, Boiling Springs, Cumberland County, Pennsylvania 17007. 3. The Plaintiff and Defendant both have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on June 6, 1987, in Princeton, New Jersey. 5. There have been no prior actions of divorce or for annulment between the SAIDIS, FLOWER & LINDSAY 31 Fxqpu.w 26 West High Street Carlisle, PA parties in this or in any other jurisdiction. 6. The Plaintiff has been advised that counseling is available and that she has the right to request that the court require the parties to participate in counseling. 7. The marriage is irretrievably broken. WHEREFORE, Plaintiff requests entry of a divorce decree in her favor in accordance with §3301 of the Pennsylvania Divorce Code. SAII)IS, FLOWER & LINDSAY 26 West High Street Carlisle, PA Dated: I07 Respectfully submitted, SAIDDIIS, WER I/I Caro(J. LindW, quire Attorney Id. 4693 26 West Hi et Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff Y VERIFICATION I verify that the statements made in the foregoing document 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 falsifications to authorities. Laurie J. Sche als Date: 61y17 r - C ?J Li Its C LAURIE J. SCHENHALS, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 07-3606 CIVIL NORBERT W. SCHENHALS, Defendant IN DIVORCE ACCEPTANCE OF SERVICE I, Thomas D. Gould, Esquire, attorney for Norbert W. Schenhals, accept service of the Complaint in Divorce in the above-captioned matter and certify that I am authorized to do so. 6/zS-/a7 Date Thomas D. Gould, Esquire 2 East Main Street Shiremanstown, PA 17011 Attorney for Defendant SAWIS, FLOWER & LINDSAY 26 West High Street Carlisle, PA JUN 2 7 2007 ° o ?7 N LAURIE J. SCHENHALS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW NO. 07-3606 CIVIL NORBERT W. SCHENHALS, Defendant IN DIVORCE PROPERTY SETTLEMENT AND SEPARATION AGREEMENT THIS AGREEMENT made this day of c/1, 2008, between LAURIE J. SCHENHALS, of 123 Hope Drive, Boiling Springs, Cumberland County, Pennsylvania 17007, hereinafter referred to as Laurie, and NORBERT W. SCHENHALS, of 507 West Main Street, Apt. 1-F, Mechanicsburg, Cumberland County, Pennsylvania 17055, hereinafter referred to as Norbert. RECITALS: RA: The parties hereto are husband and wife, having been joined in marriage on June 6, 1987, in Princeton, New Jersey; and R.2: A Complaint for Divorce has been filed in the Court of Common Pleas of Cumberland County, Commonwealth of Pennsylvania, to Number 07-3606, Civil Term; and R.3: The parties hereto desire to settle fully and finally their respective financial and property rights and obligations including, but not limited, of all matters between them relating to the ownership of real and personal property, claims for spousal support, alimony, alimony pendente lite. RA: The parties also desire to settle their issues of custody of their minor children, Erica Schenhals, age 17, and Julie Schenhals, age 15, counsel fees and costs, and the settling of any and all claims and possible claims against the other or against their respective estates. R.5: Laurie and Norbert have participated in the collaborative law process by which they have reached an Agreement. 1 NOW THEREFORE, in consideration of the covenants and promises hereinafter to be mutually kept and performed by each party, as well as for other good and valuable consideration and intending to be legally bound, it is agreed as follows: (1) SEPARATION: It shall be lawful for each party at all times hereafter to live separate and apart from the other party at such place or places as he or she from time to time may choose or deem fit, free from any control, restraint or interference from the other. Neither party will molest the other or endeavor to compel the other to cohabit or dwell with him or her by any legal or other proceeding. Each party shall be free of the interference, authority or contact by the other as if he or she was single and unmarried except as maybe necessary to carry out the terms of this agreement. (2) DIVORCE: Laurie has filed a Complaint in Divorce and Norbert, through his attorney, has accepted service of the Complaint. On the same day as they sign this Agreement, the parties will execute and file Affidavits of Consent and Waivers of Notice. Laurie's counsel will then file the necessary documents to secure a Decree in Divorce which will incorporate but not merge this Marital Settlement Agreement. (3) REAL PROPERTY: The parties are the owners of certain real estate located at 123 Hope Drive, Boiling Springs, Cumberland County, Pennsylvania 17007. The property is subject to mortgage foreclosure sale. Pending the sale, Laurie will remain residing in the marital home. (4) DEBT: A. Marital Debt: The parties have incurred substantial marital debt including, but not limited to, a joint Federal income tax obligation for 2000 and 2001 and Norbert's individual tax obligation for 2002, 2003 and 2004. In addition, the parties have substantial credit card debt, most of which is in Norbert's name, but three accounts of which are either in Laurie's name individually or in joint names. 2 The parties intend each to file individually petitions in bankruptcy to discharge all debt. In the event that any pre-separation debt for which Laurie is liable cannot be discharged in bankruptcy despite her best efforts to do so, Norbert will indemnify and hold her harmless on account of said debt and will make arrangements with the creditor to pay the debt exclusively. B: Post Separation Debt: In the event that either party contracted or incurred any debt since the date of separation on June 27, 2007, the party who incurred said debt shall be responsible for the payment thereof regardless of the name in which the debt may have been incurred. C: Future Debt: From the date of this agreement neither party shall contract or incur any debt or liability for which the other party or his or her property or estate might be responsible and shall indemnify and save the other party harmless from any and all claims or demands made against him or her by reason of debts or obligations incurred by the other party (5) MOTOR VEHICLES: Each party relinquishes any right, title and interest he or she may have to any and all motor vehicles currently in possession of the other party. Specifically, Norbert will retain the 1992 Ford Taurus which is encumbered by a lien in favor of Capital One. The lien is in joint names and Laurie will discharge her obligation with regard to the lien in bankruptcy. Norbert will be fully responsible for any obligation as a result of the Capital One car loan. Laurie will execute a Power of Attorney in Norbert's favor with regard to the 1992 Taurus so that when he receives the title to the vehicle, he can transfer it into his name only. Laurie will retain the 2003 Buick La Sabre. Norbert has transferred to her all his right, title and interest in that vehicle. (6) TANGIBLE PERSONAL PROPERTY: The parties hereto mutually agree that they have effected a satisfactory division of the furniture, household furnishings, appliances, tools and other household personal property between them, and they mutually agree that each party shall from and after the date hereof be the sole and separate owner of all such property presently in his 3 or her possession whether said property was heretofore owned jointly or individually by the parties hereto. This agreement shall have the effect of an assignment or bill of sale from each party to the other for such property as may be in the individual possession of each of the parties hereto. Nevertheless, there are certain items at the marital home which Norbert has segregated which will be his sole and separate property. Furthermore, before Laurie leaves the property, Norbert will walk through the house with her and the parties will agree on other items of personal property which shall be Norbert's. (7) INTANGIBLE PERSONAL PROPERTY: Each party hereby relinquishes any right, title or interest he or she may have in or to any intangible personal property currently titled in the name of or in the possession of the other party, including, but not limited to, stocks, bonds, insurance, bank accounts, individual retirement accounts, employment benefits including retirement accounts, savings plans, pension plans, stock plans, 401 K plans and the like. Specifically, Norbert will retain his Assemblies of God 403(b) plan through Financial Solutions with a value on December 31, 2007 of $19,491.39. That 403(b) plan is subject to a loan with a balance on December 31, 2007 of $1,005.13, which Norbert will repay. Laurie will retain her Messiah College TIAA-CREF account with a value on June 30, 2007, of $11,520.78. The parties will close their joint Wachovia checking account. (8) PARENTING OF CHILDREN: Norbert and Laurie agree that their children, Erica and Julie, will reside primarily with Laurie, but Laurie and Norbert will have joint legal custody of the girls and that the girls will spend such time with Norbert as they and the parties can agree. Laurie and Norbert confirm, one to the other, that they will say nothing or do nothing to injure the good reputation and love which their daughters have for the both of them and that they will do everything in their power to encourage a warm relationship between the girls and both parents. (9) SUPPORT OF FAMILY: Norbert will pay for the support of Laurie and the girls $2,450.00 per month commencing the month following the date this Agreement is signed. The 4 monthly payment will be made in bi-weekly installments of $1,130.77 by electronic transfer from Norbert's account to Laurie's. The monthly payment shall be allocated as $800.00 in alimony and the balance of each monthly payment as child support. The alimony portion of the payment shall continue at least until August 31, 2015. The monthly payments of child support shall continue so long as at least one of the girls is enrolled in high school or college full time or on a temporary leave from high school or college for vacation periods, mission work, some other alternative educational experience, health reasons or other necessary or advisable break from full time study, so long as the child has an intention to return to school. The intention of the parties is to permit Laurie to maintain a home for one or both girls until both complete post-secondary education and the parties acknowledge and agree that a brief hiatus in pursuing an education shall not terminate Norbert's payments of support. However, Norbert's payment of child support shall reduce by $300.00 when one of the parties' children shall complete the college education or indicate a fixed unwillingness to complete a college education. The obligation for child support and alimony may be modified upon the showing of a substantial change in circumstances, which shall not include any voluntary reduction in income or unwillingness, if involuntarily terminated, to actively seek equivalent income. The obligation for alimony shall terminate upon the death of either party or Laurie's cohabitation with a member of the opposite sex within the degrees of consanguinity or her remarriage. After August 31, 2015, Norbert's obligation for alimony shall continue commencing September 1, 2015 in the amount of $1,000.00 per month, each and every month, until August 31, 2020. All payments will be made directly by Norbert to Laurie, but if Norbert does not make the payments as set out, Laurie may seek enforcement of this Agreement through the Office of Domestic Relations of Cumberland County, Pennsylvania. 5 (10) TAX CONSEQUENCES: The parties acknowledge that alimony may be reportable by Laurie as income and deductible by Norbert for Federal income taxes. However, the parties agree that Laurie will not report alimony payments as income to her and that Norbert will not take a deduction on his tax returns for the amounts of alimony which he pays to Laurie. (11) ADVICE OF COUNSEL: The parties hereto acknowledge that each has been notified of his or her right to consult with counsel of his or her choice, and have been provided a copy of this agreement with which to consult with counsel. Laurie is represented by Carol J. Lindsay, Esquire and Norbert is represented by Thomas D. Gould, Esquire. Each party acknowledges and accepts that this agreement is, under the circumstances, fair and equitable, and that it is being entered into freely and voluntarily after having received such advice and with such knowledge as each has sought from counsel, and the execution of this agreement is not the result of any duress or undue influence, and that it is not the result of any improper or illegal agreement or agreements. Each party shall pay his or her own attorney for all legal services rendered or to be rendered on his or her behalf. (12) 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. (13) INCOME TAX: Laurie and Norbert have filed separate income tax returns for the tax years ending December 31, 2002 through the present. For 2007 and continuing forward, the parties will file separate Federal income tax returns. For so long as they are able to claim the children as dependents, Laurie will claim the exemption for Julie and Norbert will claim the exemption for Erica. For 2007, the parties acknowledge that they have mortgage interest expense of $6,000.00 and that they also may claim real estate taxes paid in 2007. The parties will equally divide the two deductions for use on their 2007 Federal income tax returns if they both 6 decide that it is in their interest to itemize their deductions. If one person wishes to use a standard deduction and the other person wishes to itemize, the person who itemizes may use the entire mortgage interest expense and taxes on his or her return. Before they file their 2007 Federal income tax returns, the parties will agree on the method of taking deductions they will use. (14) LIFE INSURANCE: Norbert presently is the owner of a life insurance policy with a death benefit of $200,000.00 through Lafayette. His insurance is a term policy which he is entitled to maintain so long as he is qualified through the Assemblies of God. Laurie has two life insurance policies, one in the amount of $35,000.00 which she has purchased as an employee of Messiah College and another privately purchased term policy with a death benefit of $100,000.00. The parties will maintain their life insurance by making the premiums as they become due for so long as they can be maintained at a reasonable cost. Further, they will obtain substitute policies if they change their employment or become disqualified from maintaining present insurance, so long as the substitute policy can be obtained for a reasonable cost. The parties will maintain the policies set out above, or their substitutes, until the youngest of their children attains 25 years of age. Each child will have an equal interest in the trust. Each party will appoint a Trustee for the children. Laurie will appoint Cheryl Patterson and Norbert will appoint Helga Oles. Each Trustee will manage the Trust proceeds for the benefit of the children and will pay to each child her share of the Trust when she attains 22 years of age. Upon the request of one or the other of them, each will provide to the other a copy of the trust provision in his or her Will or separate trust. (15) COMPLETE DISCLOSURE: The parties do hereby warrant, represent, acknowledge and agree that each is fully and completely informed of, and is familiar with, the wealth, real and personal property, estate and assets, earnings and income of the other and has made any inquiry he or she desires into the income or estate of the other and received any such information requested. Each has made a full and complete disclosure to the other of his and her 7 entire assets, liabilities, income and expenses and any further enumeration or statement thereof in this Agreement is specifically waived. (16) RIGHTS AND RESPONSIBILITIES: Husband and Wife acknowledge that each of them has read and understand his and her rights and responsibilities under this Agreement and that they have executed this Agreement under no compulsion to do so but as a voluntary act. (17) FULL SETTLEMENT: Except as herein otherwise provided, each party hereby releases the other from any and all claims, or demands up to the date of execution hereof. It is further specifically understood and agreed by and between the parties hereto that each party accepts the provisions herein made in lieu of and in full settlement and satisfaction of any and all of said party's rights against the other for past, present and future claims on account of support, maintenance, alimony, alimony pendente lite, counsel fees, costs and expenses, equitable distribution of marital property and any other claims of the party, including all claims which have been raised or may be raised in an action for divorce. (18) RELEASE OF ALL CLAIMS: Except as may be otherwise specifically provided in this Agreement, Husband and Wife, for themselves, their heirs, representatives and assigns, each hereby forever releases, remises, discharges and quitclaims the other, and such other's heirs, representatives, assigns and estate, from and with respect to the following: A. All liability, claims, causes of action, damages, costs, contributions and expenses or demands whatsoever in law or in equity; B. All rights, title, interest or claims in or to any property of the other, whether real, personal or mixed and whether now owned or hereafter acquired; C. All rights of courtesy and dower and all claims or rights in the nature of courtesy and dower; D. All widow or widower's rights; E. All right, title, interest or claim in or to the other's estate, whether now 8 owned or hereafter acquired, including but not limited to all rights or claims: (1) to take against the other's will; (2) under the laws of intestacy; (3) to a family exemption or similar allowance; and (4) all other rights or authority to participate or intervene in a deceased spouse's estate in any way, whether arising under the laws of Pennsylvania or any other country, territory, state or political subdivision. F. All rights or claims to any accounting; G. All rights, claims, demands, liabilities and obligations arising out of or in connection with the marital relationship or the joint ownership of property, whether real, personal or mixed; H. All rights, claims, demands, liabilities and obligations arising under the provisions of the Pennsylvania Divorce Code, as the same may be amended from time to time, and under the provisions of any similar statute enacted by any other country, state, territory or political subdivision; 1. All rights, claims, demands, liabilities and obligations each party now has, or may hereafter have, against or with respect to the other. (19) GOVERNING LAW: This Agreement shall be construed under the law of the Commonwealth of Pennsylvania. If any provision of this Agreement is determined to be invalid or unenforceable, all other provisions shall continue in full force and effect. (20) INCORPORATION INTO DECREE: In the event that either of the parties shall recover a final judgment or decree of absolute divorce against the other in a court of competent jurisdiction, the provisions of this Agreement may be incorporated by reference or in substance but shall not be merged into such judgment or decree and this Agreement shall survive any such 9 final judgment or decree of absolute divorce and shall be entirely independent thereof. (21) RESOLUTION OF FUTURE ISSUES: In the event that a dispute arises with regard to the implementation of this Marital Settlement Agreement or if a dispute arises as to a matter not determined by this Agreement, the parties will cooperate to engage in an alternative dispute resolution process such as mediation or collaborative law before they seek court intervention. In the event all such attempts to resolve matters fail and either Laurie or Norbert avers that the other has breached any provision of this Agreement, he or she may enforce the Agreement through the Court system and any and all costs incurred to enforce the Agreement, including, but not limited to, court cost and counsel fees of the other party. In the event of breach, the other party shall have the right, at his or her election; to sue for damages for such breach or to seek such other and additional remedies as may be available to him or her. (22) ENTIRE UNDERSTANDING: This Agreement constitutes the entire understanding between the parties and there are no covenants, conditions, representations, or agreements, oral or written, of any nature whatsoever, other than those herein contained. (23) AGREEMENT BINDING ON PARTIES AND HEIRS: This Agreement shall bind the parties hereto, their respective heirs, executors and assigns. IN WITNESS WHEREOF, the parties hereto intending to be legally bound have hereunto set their hands and seals the day and year first written above. WITNESS: 0 curie J. Sch hats Norbert W. Schenhals 10 P..7 ?M! ff" ?.? --?? ,- ?, ._ ,_? .: ? .. -_? -?:. 1r .'s? -?.C LAURIE J. SCHENHALS, Plaintiff V. NORBERT W. SCHENHALS, Defendant PLAINTIFF'S AFFIDAVIT OF CONSENT SAWIS, FLOWER & LINDSAY 26 West High Street Carlisle, PA 2007. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed June 18, 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. 1 consent to the entry of a final Decree in 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 to the best of my knowledge, information and belief. 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: Z 1 'D IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07-3606 CIVIL IN DIVORCE J /1 J'l SI/I 10 Laurie J. S nhals PLAINTIFF'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER& 3301 (C) OF THE DIVORCE CODE I consent to the entry of a final Decree of Divorce without notice. 2. 1 understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. 1 understand that I will not be divorced until a Divorce Decree is entered by the Court and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information and belief. 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: ??! ®S/ ?--7? - JCA4-%.el? Laurie J. Sc nhals ' - •L3 Y7 LAURIE J. SCHENHALS, Plaintiff V. NORBERT W. SCHENHALS, Defendant DEFENDANT'S AFFIDAVIT OF CONSENT A Complaint in Divorce under § 3301(c) of the Divorce Code was filed June 18, 2007. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. 1 consent to the entry of a final Decree in 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 to the best of my knowledge, information and belief. 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: 3 ?o IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07-3606 CIVIL IN DIVORCE Norbert W. Schenhals DEFENDANT'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER$ 3301 (c) OF THE DIVORCE CODE I consent to the entry of a final Decree of Divorce without notice. SAWIS, FLOWER & SAN LE14D .n ruw 26 West High Street Carlisle, PA 2. 1 understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. 1 understand that I will not be divorced until a Divorce Decree is entered by the Court and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information and belief. 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. 3( f g- Al, ?11 Norbert W. Schenhals L' ;1 > C? Do r,ryat Cri t ° `" LAURIE J. SCHENHALS, Plaintiff V. NORBERT W. SCHENHALS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07-3606 CIVIL 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 Decree in Divorce: 1. Grounds for Divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Defendant's counsel accepted service of the Complaint on June 25, 2007. An Acceptance of Service was filed with the Court on June 27, 2007. 3. Date Affidavit of Consent required under Section 3301(c) of the Divorce Code was signed: By Plaintiff: March 21, 2008 and filed with the Prothonotary on March 24, 2008. By Defendant: March 21, 2008 and filed with the Prothonotary on March 24, 2008. 4. Related claims pending: The terms of the Property Settlement and Separation Agreement dated March 21, 2008 are incorporated, but not merged, into the Decree in Divorce. 5. Date Waiver of Notice under Section 3301(c) of the Divorce Code was signed: By Plaintiff: March 21, 2008 and filed with the Prothonotary on March 24, 2008. By Defendant: March 21, 2008 and filed with the Prothonotary on March 24, 2008. SAIDIS, FLOWER & LINDSAY 26 West High Street Carlisle, PA SAIDIS, FLOWER & LINDSAY Carol J. Lin ay, sgdir&-\ Supreme C No. 44693 26 West High Street Carlisle, PA 17013 717-243-6222 Attorney for Plaintiff Gam, fJ3 ? ? (qtr-, tl,, ? i? .,}rt - F3 -1 LAURIE J. SCHENHALS, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 07-3606 CIVIL NORBERT W. SCHENHALS, Defendant IN DIVORCE NOTICE OF INTENTION TO RESUME PRIOR NAME NOTICE IS HEREBY GIVEN that Laurie J. Schenhals, the Plaintiff in the above matter, having filed a Complaint in Divorce on June 18, 2007, hereby intends to resume and hereafter use the previous name of LAURIE J. OWENS and gives this written notice avowing her intention in accordance with the provisions of the Act of April 2, 1980, P.L., 23 P.S. 702, effective July 1, 1980. 6&we- L11 Laurie J. Sc enhals TO BE KNOWN AS: SAIDIS, FLOWER & LRSDSAY 26 West High Street Carlisle, PA Laurie J. ens COMMONWEALTH OF PENNSYLVANIA COUNTY OF 0-cuL bcr t(-&-OL ss. ON this, the A 16- day of ?'QLA A _, 2008, before me, a Notary Public, personally appeared Laurie J. Schenhals, a/k/a Laurie J. Owens, known to me or satisfactory proven to be the person whose name is subscribed to the within instrument and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. N tary Public =STEEL, BAPublic Carlty, PA My , 2011 ?:i? f's ` n\1 J ?S. 1..1 r ? ? c? ? ? ma ? t "lt ti - y. ? .?,t ?z ,.,,.,. ?4 ?'l ~, t. ?$? ?. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. LAURIE J. SCHENHALS VERSUS NORBERT W. SCHENHALS DECREE IN DIVORCE 07-3606 AND NOW,s s l ZOQ?, IT IS ORDERED AND LAURIE J. SCHENHALS DECREED THAT , PLAINTIFF, AND NORBERT W. SCHENHALS DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; The terms of the Separation and Property Settlement Agreement dated March 21, 2008 are incorporated, but not merged, into this Decree in Divorce. BY THE COURT: ATTF?$T: ? J. PROTHONOTARY NO. 4:?P? iv -f- /T?? 4V i--kp :--V- L :// -L -/' ;IV RHONDA L. REINFORD AND R. TIMOTHY REINFORD, PLAINTIFFS V. VALERIE LAIR, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 07-3609 CIVIL TERM IN RE: MOTION OF DEFENDANT FOR PARTIAL SUMMARY JUDGMENT BEFORE BAYLEY, J. AND EBERT J ORDER OF COURT AND NOW, this a day of May, 2008, the motion of defendant for partial summary judgment, IS DENIED. By the Richard A. 4503 North Harrisburg, For Plaintiff Sadlock, Esquire Front Street PA 17110-1708 ZMichael B. Scheib, Esquire David E. Cook, Esquire 110 S. Northern Way York, PA 17402 For Defendant sal (2o?1"e.s M?ttLj' Edgar Bayley, J. 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