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HomeMy WebLinkAbout07-3795REBECCA J. PETTIT, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW ANDREW K. PETTIT, NO 0 7' 3 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, FLOWEFr&'?LIPMAY FLONVERR ? U DS" 26 West High Street Carlisle, PA Carol J. Lindsey, squire Attorney Id. 469 26 West High reet Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff REBECCA J. PETTIT, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW ANDREW K. PETTIT, ; NO 67 ' 3-)q!5- C1 rd fclN Defendant IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) or (d) OF THE DIVORCE CODE 1. The Plaintiff is Rebecca J. Pettit, an adult individual, residing at 12 Darrin Avenue, Newburg, Cumberland County, Pennsylvania 17247. 2. The Defendant is Andrew K. Pettit, an adult individual, residing at 12 Darrin Avenue, Newburg, Cumberland County, Pennsylvania 17247 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 March 16, 1991 in Corvallis, FIAWERR & LINDSAY 26 West High Street Carlisle, PA Oregon. 5. There have been no prior actions of divorce or for annulment between the 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. I' WHEREFORE, Plaintiff requests entry of a divorce decree in her favor in accordance with §3301 of the Pennsylvania Divorce Code. SAIDIS, FWVVERR & LINDSAY 26 West High Street Carlisle, PA Dated: Respectfully submitted, SAIDIS, FLOWER & LIND Carol J. Lindsay, V Attorney Id. 4463 26 West High Sfk w Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff 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. C G? Re cca J. PeIg/ Date: & - j q _ p 11 _ w r-n +wj REBECCA J. PETTIT, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 07- 3?q5' ANDREW K. PETTIT, Defendant IN DIVORCE I, Thomas D. Gould, Esquire, attorney for Andrew K. Pettit, accept service of the Complaint in Divorce in the above-captioned matter and certify that I am authorized to do so. LOU 26 2 00 to Thomas D. Gould, Esquire 2 East Main Street Shiremanstown, PA 17011 Attorney for Defendant SAIDIS, FLOWER & LINDSAY 26 West High Street Carlisle, PA UN % S Z0W r N ,7 ? REBECCA J. PETTIT, Plaintiff V. ANDREW K. PETTIT, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07-3795 CIVIL 2007 IN DIVORCE PROPERTY SETTLEMENT AND SEPARATION AGREEMENT THIS AGREEMENT made this 714 day of ' , 2008, between REBECCA J. PETTIT, of 100 North Prince Street, Shippensburg, Cumberland County, Pennsylvania, hereinafter referred to as Rebecca, and ANDREW K. PETTIT, of 12 Darren Avenue, Newburg, Cumberland County, Pennsylvania, hereinafter referred to as Andrew. RECITALS: R.1: The parties hereto are husband and wife, having been joined in marriage on March 16, 1991, in Corvallis; and R.2: The parties have participated in the collaborative law process in order to negotiate the terms of this Agreement ; and R.3: A Complaint for Divorce has been filed in the Court of Common Pleas of Cumberland County, Commonwealth of Pennsylvania, to Number 07-3795, Civil Term; and RA: 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. R5: The parties also desire to settle their issues of custody of their minor children, Grayson Ward Pettit, born September 11, 1995, and Anna Elizabeth Pettit, born March 19, 1999, 1 counsel fees and costs, and the settling of any and all claims and possible claims against the other or against their respective estates. 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: The parties acknowledge that the marriage is irretrievably broken and that they will secure a mutual consent no-fault divorce decree in the above-captioned divorce action. Upon the execution of this agreement, the parties shall execute and file Affidavits of Consent and Waivers of Notice Forms, necessary to finalize the divorce. (3) REAL PROPERTY: The parties are the owners of certain real estate with improvements thereon erected and known and numbered as 12 Darren Avenue, Newburg, Cumberland County, Pennsylvania. Rebecca hereby releases all her right, title and interest in the marital home. Within thirty (30) days of the date of this Agreement, Rebecca will execute a special warranty deed transferring the marital home to Andrew. The marital home is encumbered by two mortgages, a first mortgage with a payoff of approximately $92,000.00 and a second mortgage with a payoff of approximately $13,000.00. Andrew has checked and has determined that he qualifies for a refinance of the marital home and has made application for such refinance. 2 He and Rebecca anticipate that the refinance can take place by April 1, 2008. Pending the refinance, he will pay all household expenses including, but not limited to, the mortgages and liens of record, utility bills, insurance and real estate taxes in connection with said property. With regard to all such expenses, Andrew will indemnify and hold Rebecca harmless and indemnify her from any loss thereon. Nevertheless, Rebecca will continue to pay the first and second mortgages through March 30, 2008 and Andrew will continue to assist with those costs by giving Rebecca $200.00 in February and March 2008 as they have in the past. The parties are owners of two timeshares which shall become Rebecca's sole and separate property and she will be solely responsible for any costs associated with the maintenance of the timeshares annually. (4) DEBT: A. Marital Debt: Andrew and Rebecca acknowledge and agree that there are no other outstanding debts and obligations which are marital or for which the other might be liable incurred prior to the signing of this Agreement, except as follows: i. PSECU loan, approximately $9,000.00 ii. American Express credit card, approximately $20,000.00 iii. Chase credit card number -9417, approximately $20,000.00 iv. Chase credit card number -- , approximately $15,000.00 V. Discover card, approximately $4,000.00 Rebecca shall pay the obligations set out above by making timely monthly payments in at least the minimum amount required by the creditors until paid in full. With regard to all such obligations, she will indemnify and hold Andrew harmless against any loss relating to the marital debt set out in this subparagraph. 3 B: Post Separation Debt: In the event that either party contracted or incurred any debt since the date of separation in May 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, provided, however, that Rebecca accepts the debt incurred post-separation and charged to one or more of the credit cards set out above. 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. Within ten days of the date of this agreement each party shall execute any documents necessary to have said vehicles properly registered in the other party's name with the Pennsylvania Department of Transportation. Each party shall assume full responsibility of any encumbrance on the motor vehicle received by said party, and shall hold harmless and indemnify the other party from any loss thereon. Specifically, Rebecca has traded in a 2006 Honda CRV subsequent to separation and purchased a 2008 Honda Fit, the obligation for which will be her sole and separate property. Andrew shall retain the parties' Dodge Caravan. Rebecca and Andrew will immediately separate their automobile insurance policies so that each is responsible for insurance on the vehicle he or she drives. (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 4 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. Notwithstanding the above, Rebecca and Andrew will separate their family photographs as they can agree and, they will have duplicates made of any photograph both wishes to retain and equally share the cost of the duplication. (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. Rebecca will retain her TIAA-CREF retirement plan and also her Public Employee Retirement System Plan for the State of Oregon. Andrew will retain his Lincoln annuity and Rebecca will cash out $977.00 from the Sharebuilder account and provide that money to Andrew. Further, Andrew may retain the balances in the joint Orrstown account. The parties will close that account. (8) PARENTING OF CHILDREN: The parties agree that they will share legal and physical custody of their minor children, Grayson Ward Pettit, born September 11, 1995, and Anna Elizabeth Pettit, born March 19, 1999, with both parties having the right to make major parenting decisions affecting the children's health, education and welfare. During the school year, Rebecca will have the children each Friday after school until she returns them to school on Monday morning. She will also have the children after school each day until Andrew picks them up after his work at approximately 4:30 PM. Andrew will then have the children the balance of the school week until Friday after school. Rebecca and Andrew agree that from time to time, they can exchange times so that Andrew has some parenting time on the weekend and Rebecca has some 5 midweek parenting time. During the summer months, the parties have agreed to work an alternating week schedule with the exchanges taking place on Sunday evenings. They will each have a midweek contact in the other's week, to be arranged between Rebecca and Andrew, with or without an overnight option as they can agree. The parties have agreed to be flexible with regard to time with the children on holidays which they intend to share. Each has given to the other the "right of first refusal" so that they agree to offer the first opportunity to watch the children if they cannot do so personally. If the other parent is unavailable, the parent will then be responsible for ensuring supervision of the children. Rebecca and Andrew have agreed to discuss regularly, either in person, by telephone or email, concerns about the children and their school and activity schedules, especially as they relate to the parents' work schedules. In the event that the parties cannot reach an agreement on a matter of substantial importance for the children, they will use a neutral professional, such as a mediator, to work through parenting concerns. The parties have agreed to flexibility in order to adjust to changes or conflicts which may arise into the future. (9) HOUSEHOLD SUPPORT: Rebecca agrees to pay to Andrew each month, the sum of five hundred ($500.00 ) Dollars until Anna attains 18 years of age and graduates from high school. (10) WAIVER OF ALIMONY: The parties acknowledge that each has income and assets satisfactory to his and her own reasonable needs. Each party waives any claim he or she may have one against the other for alimony, spousal support or alimony and alimony pendente lite. 6 (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. Rebecca is represented by Carol J. Lindsay and Andrew 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: A: The parties have heretofore filed joint Federal and State Tax returns. Both parties agree that in the event any deficiency in Federal, state or local income tax is proposed, or assessment of any such tax is made against either of them, each will indemnify and hold harmless the other from and against any loss or liability for any such tax deficiency or assessment and any interest, penalty and expense incurred in connection therewith. Such tax, interest, penalty or expense shall be paid equally by the parties. B: The parties agree that they will each take an exemption for one of the parties' children so long as two exemptions are available to them. When there is only one exemption, the parties will alternate the exemption, from year to year. Andrew agrees, upon the 7 request of Rebecca, to join in the filing of the 2007 joint Federal and Pennsylvania income tax returns. (14) PAYMENT OF ADDITIONAL TAX AND REFUNDS: In the event that the parties receive a refund for any jointly filed tax return for 2007, or in the event that Federal income tax must be paid, the parties will split the refund or pay the tax in the same proportion as their individual gross annual income for the applicable tax year is to their combined gross annual income. (15) BANKRUPTCY: The parties hereby agree that the provisions of this Agreement shall not be dischargeable in Bankruptcy and expressly agree to reaffirm any and all obligations contained herein. In the event a party files such bankruptcy and pursuant thereto obtains a discharge of any obligations assumed hereunder, the other party shall have the right to declare this Agreement to be null and void and to terminate this Agreement in which event the division of the parties' marital assets and all other rights determined by this Agreement including alimony shall be subject to court determination the same as if this Agreement had never been entered into. (16) 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 entire assets, liabilities, income and expenses and any further enumeration or statement thereof in this Agreement is specifically waived. (17) RIGHTS AND RESPONSIBILITIES: Andrew and Rebecca acknowledge that each of them has read and understand his and her rights and responsibilities under this Agreement and 8 that they have executed this Agreement under no compulsion to do so but as a voluntary act. (18) 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. (19) RELEASE OF ALL CLAIMS: Except as may be otherwise specifically provided in this Agreement, Andrew and Rebecca, 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 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; 9 (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. (20) 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. (21) 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 final judgment or decree of absolute divorce and shall be entirely independent thereof. 10 (22) DISPUTE REGARDING THE AGREEMENT: In the event that a dispute arises as to a party's obligation pursuant to the terms of this Agreement, or in the event that events regarding the parenting of children or the payment of support arise, the parties agree to commit themselves to an effort at out of court resolution through mediation or through the collaborative law process prior to initiating court intervention. However, in the event those efforts should fail and one party is found to be in breach of the terms of this Agreement, the other party would have the right, at his or her election, to seek damages for such breach or to seek such other and additional remedies as may be available to him or her. (23) 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. (24) 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: i VV-11t11CeA--/ Re ecca J P r Andrew K. Pettit 11 r-.) ^ t:;:3 ? `9} , e.': JJ .. '? . " ^T? ? ?T-] ? ,r' ?-?. ` ply t..._ r-? ??? ?. y :. REBECCA J. PETTIT, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 07-3795 CIVIL 2007 ANDREW K. PETTIT, Defendant IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed June 25, 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: -31,214-01? ?" C- R ecca J.,P-ttit PLAINTIFF'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER6 3301 (c) OF THE DIVORCE CODE I consent to the entry of a final Decree of Divorce without notice. SAMIS, FLOWER &. LINDSAY AAA RAW 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-,-;?q -off C Cam Xe-e&i Rebecca J. F?q-t it V F5 F':w REBECCA J. PETTIT, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 07-3795 CIVIL 2007 ANDREW K. PETTIT, Defendant IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed June 25, 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 author' ' s. Date: Andrew K. Pettit I consent to the entry of a final Decree of Divorce without notice. SAMIS, FLOWER &. LINDSAY ATTURNEWS-APLAW 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: ? ?' Andrew K. Pettit (? r. c; ?' ?.:? ?._, n _ ? .?.. ?? M?1 •"'7 471 .. ...., f`'k) ? . _ ,. a - C '? 4'? . ?? ??: '? r REBECCA J. PETTIT, Plaintiff V. ANDREW K. PETTIT, Defendant 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 26, 2007. An Acceptance of Service was filed with the Court on June 28, 2007. 3. Date Affidavit of Consent required under Section 3301(c) of the Divorce Code was signed: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07-3795 CIVIL 2007 IN DIVORCE 25, 2008. By Defendant: March 24, 2008 and filed with the Prothonotary on March 25, 2008. By Plaintiff: March 24, 2008 and filed with the Prothonotary on March 4. Related claims pending: The terms of the Property Settlement and Separation Agreement dated March 24, 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 24, 2008 and filed with the Prothonotary on March 25, 2008. By Defendant: March 24, 2008 and filed with the Prothonotary on March 25, 2008. SAIDIS, FLOWER & LINDSAY 26 West High Street Carlisle, PA SAIDIS, FLOWER & L Carol J. Lindsay;-s4 ire Supreme Court W. 44693 26 West High Street Carlisle, PA 17013 717-243-6222 f°?J !C-_ ? `i 7 ..; _-1 V ? _ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. REBECCA J. PETTIT No. 07-4154 VERSUS ANDREW K. PETTIT DECREE IN DIVORCE AND NOW, 0 ,I -? , 200Y, IT IS ORDERED AND REBECCA J. PETTIT DECREED THAT AND ANDREW K. PETTIT ARE DIVORCED FROM THE BONDS OF MATRIMONY. , PLAINTIFF, ,DEFENDANT, THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; The terms of the Separation and Property Settlement Agreement dated March 24, 2008 are incorporated, but not merged, into this Decree in Divorce. BY THE COURT: A J. PROTHONOTARY r• a REBECCA J. PETTIT, Plaintiff V. ANDREW K. PETTIT, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07-4154 CIVIL TERM AMENDED ORDER OF COURT AND NOW, this 14th day of April, 2008, it is ordered and directed that Decree in Divorce signed in the above matter on April 3, 2008, is hereby amended to reflect that the correct docket number of this matter is No. 07-3795 Civil Term. In all other respects, the divorce decree shall remain as signed. ? Carol J. Lindsay, Esq. 26 West High Street Carlisle, PA 17013 Attorney for Plaintiff ? Thomas D. Gould, Esq. 2 East Main Street Shiremanstown, PA 17011 Attorney for Defendant :rc BY THE COURT, VFfj Soo, G ( ? - 3HI ?v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. REBECCA J. PETTIT N O. 07-3795 CIVIL TERM VERSUS ANDREW K. PETTIT AMENDED DECREE IN DIVORCE AND NOW, APRIL 3 f 2008 , IT IS ORDERED AND DECREED THAT REBECCA J. PETTIT , PLAINTIFF, AND ANDREW K. PETTIT ARE DIVORCED FROM THE BONDS OF MATRIMONY. ,DEFENDANT, 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 dated March 24, 2008 are incorporated, but not merged, into this Decree in Divorce. BY THE COURT: AT?JST: U J. JJ ? PROTHONOTARY REBECCA J. PETTIT, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 07-3795 CIVIL 2007 ANDREW K. PETTIT, Defendant IN DIVORCE NOTICE OF INTENTION TO RESUME PRIOR NAME NOTICE IS HEREBY GIVEN that Rebecca J. Pettit, the Plaintiff in the above matter, having been granted a final decree in divorce on April 3, 2008, hereby intends to resume and hereafter use the previous name of REBECCA J. WARD, 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. Rebecca J. Petti TO BE KNOWN AS: CCa-- - ?? RE ECCA J.1Dd RD tr SAMIS, FLOWER & LINDSAY ATTORNM-AT.IAW 26 West High Street Carlisle, PA COMMONWEALTH OF PENNSYLVANIA ?'? ss. COUNTY OF l_ r' Lj b(-t'/C0k(L : ON this, the j (P ?- A day of f) _'2008, before me, a Notary Public, personally appeared Rebecca J. Pettit, a/k/a REB A J. WARD, 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. BARBARA E. STEEL, Notary Publie Public Carlisle Boro, Cumberland County, PA Notary PuIIC My Commission Expires lone 7, 2011