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HomeMy WebLinkAbout07-3806v JILLIAN PARSON, Plaintiff v DANIEL PARSON, JR. Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. p`7 -38-D( 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 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 Respectfully submitted, SAIDIS, FLOWER & LINDSAY 26 West High Street Carlisle, PA SAIDIS, FLOWER & LINDSAY By } M u Matas, squire Supreme Court ID # 84919 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff Ap, JILLIAN PARSON, Plaintiff vi. DANIEL PARSON, JR. Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 67- 3 ko IN DIVORCE COMPLAINT IN DIVORCE NO FAULT 1. Plaintiff is Jillian Parson, an adult individual currently residing at 2854 Enola Road, Carlisle, Cumberland County, Pennsylvania 17015. 2. Defendant is Daniel Parson, Jr.,. an adult individual currently residing at 2854 Enola Road, Carlisle, Cumberland'County, Pennsylvania 17015. 3. Plaintiff is a bonafide resident of the Commonwealth of Pennsylvania and has been so for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on May 14, 2005, in Cumberland County, Pennsylvania. 5. There has been no other prior action for divorce or annulment between the parties. 6. Neither the Plaintiff nor the Defendant are members of the United States Armed Forces or its Allies. 7. Plaintiff has been advised of the availability of counseling and the right to request SAMIS, FLOWER & LINDSAY 26 West High Street Carlisle, PA that the Court require the parties to participate in counseling. Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling. 8. Plaintiff and Defendant are citizens of the United States of America. 9. The parties' marriage is irretrievably broken. 10. Plaintiff desires a divorce based upon the belief that the Defendant will, ninety (90) days from the date of service of this Complaint, consent to this divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a divorce pursuant to 23 P.S. Section 3301 (c) of the Domestic Relations Code. Respectfully submitted, n r Mary atas, Es e Attorn No. 84919 Attorney for Plaintiff 26 West High Street Carlisle, PA 17013 (717) 243-6222 SAIIIDIS, FLOWER & LINDSAY 26 West High Street Carlisle, PA r VERIFICATION I verify that the statements made in the foregoing document are true and correct. SAIDIS, FLOWER & LINDSAY 26 West High Street Carlisle, PA understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsifications to authorities. DATE: td?i-k 7 d-A?L?A' ??? Jill an Parson, Plaintiff ? N C-n -oFTi W rn ? u l C ? 0-1 A- JILLIAN PARSON, Plaintiff DANIEL PARSON, JR. Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07-3806 IN DIVORCE AFFIDAVIT OF SERVICE I, Marylou Matas, Esquire, being duly sworn according to law, hereby deposes and says that on June 29, 2007 1 served a true and correct copy of a Divorce Complaint upon Daniel Parson, Jr., by mailing those documents to his address at 2854 Enola Road, Carlisle, PA 17015 by Certified U.S. Mail, Restricted Delivery, Return Receipt Requested, as evidenced by the attached U.S. Postal Service Form 3811, Domestic Return Receipt, the latter of which is signed by the recipient, Daniel Parson, Jr. Respectfully submitted, SAIDIS, FLOWER & LINDSAY -1- MaAz? Al/ j -)da '4/2 Dated: 7116107- SAIDIS, FLOWER & LINDSAY ATIONN MAT uw 26 West High Street Carlisle, PA MaryM tas, Esqui ID No. 84919 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff ¦ Complete items 1, 2, and 3. Also complete Item 4 if Restricted DeWery is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed o: 17R?ie ` ?Arsof?jS2, a: d 5 y ? oo I P+ SZo I?eQ Cp,r??S?E ill 17015' A. A. :rrb Agent 0 Addressee B. Racal C. Date of Delivery D. Is delivery from item 1? 0 Yes If YES, enter d6fivery address-below: 0 No 3. Service Type ], Certifled Mail 0 Express Matt 0 Registered 0 Return Receipt for Merchandise 0 Insured Mail 0 C.O.D. 4. Restricted Delivery? (Extra Feel ® Yes 2. AticleNumber 7004 1350 0003 7285 9682 Mansfer from service label) PS Form 3811, February 2004 Domestic Return Receipt 102595-02-M-1540 tV C=2 O G Jillian Parson, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. Daniel Parson, Jr., Defendant CIVIL ACTION LAW No. 07-3806 : IN DIVORCE PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Please enter my appearance on behalf of the Defendant in the above captioned Divorce case. Respectfully submitted, ROMINGER & ASSOCIATES Date: August 30, 2007 Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 81924 Attorney for Plaintiff Q C ? -n CS1 W rn ?; p rl) JILLIAN PARSON, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07-3806 DANIEL PARSON, JR. Defendant IN DIVORCE NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff in the above matter, Jillian Parson, (select one by marking "x"] X prior to the entry of a Final Decree in Divorce, or after the entry of a Final Decree in Divorce dated hereby elects to resume the prior surname of Jillian M. Forrest and gives this written notice avowing her intention pursuant to the provisions of 54 P.S. 704. -AW,441 - / Date: rc??l! ?D7 Signature Signature of name being resumed COMMONWEALTH OF PENNSYLVANIA COUNTY OF On the / i day of y« <.•. 6? , 200 7, before me, the SAMIS, FLONVER & LINDSAY 26 West High Street Carlisle, PA Prothonotary or the notary public, personally appeared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he/she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand and Official Seal. Prothonotary or Notary Public COMUONWE'ALTH 0RMNSYLVANIA "Tiffany M. Weak!and, Notary Public Mechaniosburg axo, Cumberland County My C, :)mmission Expires Jan. 10, 2009 Member. F'n3?sYiv<,nia Associufion of Notaries c rs Q -n m c-s M33 am JILLIAN PARSON, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07-3806 DANIEL PARSON, JR. Defendant IN DIVORCE PRAECIPE TO WITHDRAW OF APPEARANCE TO THE PROTHONOTARY: Kindly withdraw my appearance on behalf of the Plaintiff, Jillian Parson, in the above- captioned matter. Respectfully Submitted, Marylo atas, Esquire Dated: Counsel for Plaintiff 26 West High Street Carlisle, PA 17013 ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance on behalf of the Plaintiff, Jillian Parson, in the above- FLOWER & LINDSAY 26 West High Street Carlisle, PA captioned matter. Respectfully Submitted, Sean Shultz, Esquire 11 Roadway Drive Carlisle, PA 17013 Dated: J /11 /,Pg Counsel for Plaintiff ?-' ? Q ?- 4:.:3 T C'37 .?_, ?? ? _ ? ?-. - .?' ?."} 1'"" _. T` ri3 Y'?'T `, 'Y '? ? _ ?'?= ' ? a ? ' ? ,. rn y r? .. ? ...? - ? ?,, :.? i , V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA JILLIAN PARSON, Plaintiff V. DANIEL PARSON, JR., Defendant No. 2007- 3806 In Divorce Civil Action - Law PRAECIPE TO TAIL PROTHONOTARY: Please change the Plaintiff's name in the above-captioned matter to Jillian Forrest. Mrs. Parson has retaken her maiden name of Forrest. Date: April 28, 2008 Respectfully submitted, KNIGHT & ASSOCIATES, P.C. Sean M. Shultz, squire Attorney ID No. 90946 11 Roadway Drive, Suite B Carlisle, Pennsylvania 17015 (717) 249-5373 Attorneys for Plaintiff F-\User Folder\Firm DocsThenls Files\3431 2 - AhM Forrest\Docnments\praecipe. l.wpd ?I IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA JILLIAN PARSON, No. 2007- 3806 Plaintiff In Divorce V. ; Civil Action - Law DANIEL PARSON, JR., Defendant CERTIFICATE OF SERVICE AND NOW, this 28`h day of April, 2008, I, Sean M. Shultz, Esquire, hereby certify that I have this day served the following with a copy of the foregoing Praecipe by first class, United States Mail, addressed as follows: Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, Pennsylvania 17013 Attorney for Defendant Respectfully submitted, KNIGHT & ASSOCIATES Sean M. Shultz, Esquire Attorney I.D. No. 90946 11 Roadway Drive, Suite B Carlisle, Pennsylvania 17013 (717) 249-5373 Attorneys for Plaintiff :? I: ..1 ..... .. a i ,... S IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA JILLIAN PARSON, Plaintiff No. 36@x- 3806 In Divorce V. DANIEL PARSON, JR., Defendant Civil Action - Law MARRIAGE SETTLEMENT AGREEMENT THIS AGREEMENT, made this 9 day of , ;008, by and between DANIEL PARSON, JR., of 233 Allen Road, Carlisle, P nnsylvania, (hereinafter referred to as "Husband") and JILLIAN FORREST, f/k/a JILLIAN PARSON, of 1814 Pine Road, Newville, Pennsylvania, hereafter referred to as "Wife." WITNESSETH: WHEREAS, Husband and Wife were married on May 14, 2005 in Carlisle, Cumberland County, Pennsylvania; and WHEREAS, Husband and Wife have been living separate and apart from each other since May of 2007; and WHEREAS, the parties are residents of the Commonwealth of Pennsylvania and have been so for at least the past six (6) months; and WHEREAS, certain diverse, unhappy differences have arisen between the parties hereto which have made them desirous of living separate and apart from one another; and WHEREAS, Husband and Wife desire to settle and determine certain of their marital rights and obligations, and make an equitable distribution of their marital property; and WHEREAS, it is the intention and purpose of this Agreement to set forth the respective rights and duties of the parties while they continue to live apart from each Other and to settle all financial and property rights between them; and WHEREAS, the parties hereto have mutually entered into agreement for the division of their jointly owned assets, the provisions for the liabilities they owe, any provisions for the resolution of their mutual differences, after both have had full and amble 'o portunity to consult with their respective attorneys, and the parties now wish to have that a eement reduced to writing. Page 1 of 7 i NOW, THEREFORE, the parties hereto in consideration of the mutually made and to be kept promises set forth herein and for other good and valuable consideration, intending to be legally bound and to legally bind heirs, successors, assigns, and perso al representatives, do hereby covenant, promise and agree as follows: ARTICLE I: SEPARATION 1.1 It shall be lawful for Husband and Wife at all times hereafter to live separate and apart from each other and to reside from time to time at such place or places as they shall deem fit free from any control, restrain, or interference, direct or indirect, by each other. Neither party shall molest the other or compel or endeavor to compel the other to cohabit or dwell with him or her by any legal or other proceedings. The foregoing provision shall not be taken to be an admission on the part of either Husband or Wife of the lawfulness of the causes leading to them living separate and apart. ARTICLE II: DIVORCE 2.1 This Agreement is not predicated on divorce. It is specifically understood and agreed by and between the parties hereto and each of the said parties does hereby warrant and represent to the other that the execution and delivery of this Agreement is not predicated upon nor made subject to any agreement for institution, prosecution, defense, or for the no 01-prosecution or non- defense of any action for divorce; provided, however, that nothing contained in this Agreement shall prevent or preclude either of the parties hereto from commencing, instituting or prosecuting any action or action for divorce. Husband and Wife do each hereby warrant, covenant and agree that, in any possible event he and she are and ever shall be estopped from asserting any illegality or unenforceability as to all or any part of this Agreement. 2.2 It is further specifically understood and agreed that the provision of this Agreement relating to the equitable distribution of property of the parties are accepted by each party as a final settlement for all purposes whatsoever. Should either of the parties obtain a decree, judgment or order of separation or divorce in any other state, county, or jurisdiction, each of the parties to this Agreement hereby consents and agrees that this Agreement and all its covenants shall not be effected in any way by any such separation or divorce; and that nothing in any such decree, judgment, order or further modification or revision thereof shall alter, amend or vary any term of this Agreement, whether or not either or both of the parties should remarry, it being understood by and between the parties that this Agreement shall survive and shall not be merged into any decree, judgment or order of divorce or separation. 2.3 It is specifically agreed that a copy of this Agreement may be inco orated by reference into any divorce judgment or decree if or whenever sought by any of the arties hereto. It is understood by the parties that a Divorce Complaint has been filed in the Co of Common Pleas Page 2 of 7 of Cumberland County at Docket Number 07-3806. Such incorporation, however, shall not be regarded a merger, it being the intent of the parties to permit Agreeme?t to survive any such agreements. ARTICLE III: EOUITABLE DISTRIBUTION OF MARITAL ftOPERTY 3.1 The parties have attempted to divide their marital property in a manner which conforms to the criteria set forth in Section 3502 of the Pennsylvania Domestic Relations Code, and taking into account the following considerations: the length of the marriage; the prior marriages of the parties; the age, health, station, amount and sources of income, vocational) skills, employability, estate, liabilities, and need for each of the parties; the contribution of one arty to the education, training or increased earning power of the other party; the opportunity of each parry for future acquisition of capital assets and income; the sources of income of both p es, including, but not limited to medical, retirement, insurance or other benefits; the contribution of dissipation of each party in the acquisition, preservation, depreciation, or appreciation of maxi al property, including the contribution of a party as a homemaker; the value of the property set a art to each party; the standard of living of the parties established during their marriage. 3.2 The parties shall retain sole and exclusive right, title and possession of all personal property currently in their possession. Except as provided for herein, Husband shall make no claim whatsoever for any personal property in Wife's possession. Ad ' ditionally, except as provided for herein, Wife shall make no claim whatsoever for any personal property in Husband's possession. Should it be necessary for either party to execute any documents to convey title to any such personal property in the other party's possession, they shall do so within thirty (30) days of the execution of this Agreement or within thirty (30) days of the request from the opposing party. Should it be necessary to transfer possession of any personal property per this order, the parties shall transfer the property within thirty (30) days of the execution of this Agreement. 3.3 Wife agrees to execute the check for the proceeds of the sale of property situate at 373 Old State Road, Gardners, Pennsylvania. The proceeds from the sale of the parties' marital real estate situate at 2854 Enola Road, Carlisle, Pennsylvania ("Marital Residence") and sale of their tractor totaling $15,203.47 are presently held in escrow by Knight & Associates, P.C. Husband shall receive the sum of Five Thousand Five Hundred Dollars ($5,500.00) representing his share of the proceeds from the sale of the parties' Marital Residence and the tractor, and Wife shall receive the balance of the proceeds. 3.4 Except as provided herein, Wife waives any right or interest she ma have in Husband's employment benefits, including any pension benefits, retirement plan, st ck option purchase Page 3 of 7 plan, or profit sharing plan in connection with his employment with th Borough of Carlisle Police Department. Except as provided herein, Husband waives any rit or interest he may have in Wife's employment benefits, including any pension benefits, etirement plan, stock option purchase plan, or profit sharing plan in connection with here ployment with New Harrisburg Truck and Body Company. Wife waives any right or interest she may have in Husband' right or interest in litigation regarding malpractice by the rehabilitation center in Michigan which Husband attended during the parties' marriage. Husband agrees not to call Wife as a witness in any such litigation regarding said malpractice. 3.5 Husband and Wife agree to waive and relinquish any and all right at he or she may now have or hereafter acquire in any real or tangible personal property subseq ently acquired by the other party. Husband and Wife specifically agree to waive and relinquish any right in such property that may arise as a result of the marriage relationship. ARTICLE IV: 4.1 The parties herein acknowledge that by this Agreement they have respectively secured and maintained a substantial and adequate fund with which to provide themselves sufficient resources to provide for their comfort, maintenance, and support in the st tion of life in which they are accustomed. Husband and Wife do hereby waive, release and gi a up any rights they may respectively have against the other for alimony pendente lite, spousal support, or maintenance. Husband and Wife specifically waive, release and give up y rights for alimony that they may be entitled to pursuant to Chapter 37 of the Pennsylvani Domestic Relations Code. ARTICLE V: DEBTS OF THE PARTIES 5.1 Each party represents to the other that except as otherwise specifically set forth herein, there are no major outstanding obligations of the parties, of which the parties have not made each other aware, that since the separation neither party has contracted for any debts for which the other will be responsible and each party indemnifies and holds harmless the other for all obligations separately incurred or assumed under this Agreement. The parties agree to indemnify and hold each other harmless from liability in connection with said marital debts. In the event either party conti any debts since the date of separation, the party who incurred said debt sha the payment thereof regardless of the name in which the account may have as otherwise specifically set forth herein. any and all loss or acted for or incurred Il be responsible for been charged except Page 4 of 7 5.2 Each parry relinquishes any right, title and interest he or she may have to any and all motor vehicles currently in the possession of the other party. Wife shall be responsible for and shall indemnify and hold Husban harmless for any tax liability in regard to her family trust. Husband shall be responsible for d indemnify and hold Wife harmless from any tax liability regarding any and all of his Scott Trad accounts. ARTICLE VI: MISCELLANEOUS PROVISIONS II 6.1 The provisions of this Agreement and their legal effect have been fully explained to the parties by their respective counsel or the parties have waived their right to have legal advice regarding the meaning and implication of this Agreement. The parties a ee and consent to the fact that Sean M. Shultz, Esquire, of Knight & Associates, P.C., reps sents Wife and Karl Rominger, Esquire represents Husband. The parties acknowledge d accept that this Agreement is, in the circumstances, fair and equitable, that it is being a tered into freely and voluntarily, after having received such advice and with such knowledge at execution of this Agreement is not the result of any duress or undue influence and that it i not the result of any collusion or improper or illegal agreement or agreements. 6.2 Husband and Wife do hereby mutually remise, release, quitclaim, 'And forever discharge the other and the estate of the other, for all times to come and for all pure( s whatsoever, of and from any and all legal right, title and interest, or claims in or against the pr perty of the other or against the estate of the other, of whatever nature and wheresoever situate, Ilwhich he or she now has or at any time hereafter may have against such other. 6.3 Each party represents that they have not heretofore incurred or contracted for any debt or liability or obligation for which the estate of the other party may be respon ible or liable, except as may be provided for in this Agreement. Each party agrees to indemnify and hold the other party harmless from and against any and all such debts, liabilities or obligations of each of them, including those for necessities, except for the obligations arising out of this Agreement. Husband and Wife each warrant, covenant, represent and agree that each ,will, now and at all times hereafter, save harmless and keep the other indemnified from all debts, charges, and liabilities incurred by the other after the execution date of this Agreement, except as is otherwise specifically provided herein. 6.4 No waiver or modification of any of the terms of this Agreement shall be valid unless in writing and signed by both parties and no waiver of any breach hereof or de ault hereunder shall be deemed a waiver of any subsequent default of the same or similar nature. Page 5 of 7 6.5 This Agreement shall be construed in accordance with the laws of the Commonwealth of Pennsylvania which are in effect as of the date of this Agreement. 6.6 This Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective heirs, executors, administrators, successors and assigns. 6.7 This Agreement constitutes the entire understanding of the parti s and supersedes any and all prior agreements and negotiations between them. There are o representations or warranties other than those expressly set forth herein. 6.8 If any term, condition, clause, section, 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 valid and continue in full force, effect, and operation. ? Likewise, the failure of any party to meet his or her obligation under any one or more of the articles and sections herein shall in no way void or alter the remaining obligations of the parties. 6.9 The parties warrant and represent that they have made full disclosure of all assets prior to the execution of this Agreement. Each parry represents and warrants that he or she has made a full and fair disclosure to the other of all of his or her personal property interests of any nature, including any mortgage, pledge, lien, charge, security interest, encumbr ce, or restriction to which any property is subject. Each party further represents that he or sh has made a full and fair disclosure of all debts and obligations of any nature for which he or sh is currently liable or may become liable. Each further represents and warrants that he or she has of made any gifts or transfers for inadequate consideration of Marital Property without the prior consent of the other. Each further warrants, represents, and declares that each is and has been fully and completely informed of and is familiar with and is cognizant of the wealth, real and/or personal property, estate and assets, earnings and income of the other and that each has made a full and complete disclosure to the other of his and her entire assets and liabilities and any further enumeration or statement thereof in this Agreement is specifically waived. Each party acknowledges that, to the extent desired, he or she has head access to all joint and separate State and Federal Tax Returns (including supporting documentation) filed by or on behalf of either or both Parties during marriage. 6.10 In the event either party to this Agreement shall breach any to, covenant or other obligation herein, the non-breaching party shall be entitled, in addition t all other remedies available at law or in equity, to recover from the breaching party all c sts which the non- Page 6 of 7 forever be binding and conclusive on the parties; and any independent action may be brought, either at law or in equity, to enforce the terms of this Agreement by either usband or Wife until it shall have been fully satisfied and performed. The consideration for s Agreement is the mutual benefits to be obtained by both of the parties hereto and the coven t's and agreements of each of the parties to the other. The adequacy of the consideration for all agreements herein contained is stipulated, confessed, and admitted by the parties, and they parties intend to be legally bound hereby. breaching party may incur, including but not limited to filing fees and ttorney's fees, in any action or proceeding to enforce the terms of this Agreement. 6.11 This Agreement shall survive any action for divorce and decree) of divorce and shall 6.12 The parties both agree to cooperate with each other in obtaining Oi final divorce of the marriage. It is agreed that the parties will execute and file the consents necessary to obtain the divorce. Any party who fails to cooperate with obtaining the Divorce shall pay all the costs and legal fees, including attorney's fees, of the party who is seeking the divorce. IN WITNESS WHEREOF, the parties have set their hands and seals the day and year first above written. WITNESS D BY: KarRominger, Esquire Counsel for Husband ean M. Shultz, Esquire Counsel for Wife Page 7 of 7 IN" 4 dips Jig, SEC, 0 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA JILLIAN FORREST, Plaintiff V. No. 2007- 3806 In Divorce Civil Action - Law DANIEL PARSON, JR., Defendant AFFIDAVIT OF CONSENT STATE OF PENNSYLVANIA SS. COUNTY OF CUMBERLAND 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on 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. I consent to the entry of a final Decree of Divorce after service of notice of intention to request entry of the Decree. 4. I have been advised of the availability of marriage counseling d understand that I may request that the Court require that my spouse and I participate in counseling prior to a Divorce Decree being handed down by the Court. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S., Section 4904 relating to unworn falsification to authorities. Date: , 2008 U 6 Jilli orrest Sw to and su cribed before me this day of t-J , 2008. TI/ /, , M 144JA k#111 -1 t " AM -1 Notary Pu li FAUser FoldetlFirm Docs\aiews FHes\3431.2 - Misn Forrest\DocumeMs\aff.consent.wpd m D* K ay W/?, ?,&W Mode w Wp., 0jv" My ooeln wm E*" a ? ?f: - ? o ? '? ? ? ? ? ? IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA JILLIAN FORREST, No. 2007- 3806 Plaintiff In Divorce V. : Civil Action - Law DANIEL PARSON, JR., : Defendant I . I consent to the entry of a final decree of divorce without 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. Ilunderstand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unworn falsification to authorities. Date: +13du Jilli Forrest V '6 FAUser Folder\Firm Docs\Cliems Fdcs\3431.2 - Alban Forrest\Documems\waiver.notice.wpd ?3 zy- -mac t ? ? C3's rx? IN THE COURT OF COMMON PLEAS CUMBERLAND COUN'T'Y, PENNSYLVANIA JILLIAN FORREST, Plaintiff V. DANIEL PARSON, JR., Defendant No. 2007- 3806 In Divorce Civil Action - Law AFFIDAVIT OF CONSENT STATE OF PENNSYLVANIA SS. COUNTY OF CUMBERLAND ) 1. A Complaint in divorce under Section 3301 (c) of Divorce () ode was filed on 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. I consent to the entry of a final Decree of Divorce after service of notice of intention to request entry of the Decree. 4. I have been advised of the availability of marriage counseling ?and understand that I may request that the Court require that my spouse and I participate in counseling prior to a Divorce Decree being handed down by the Court. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S., Section 490 relating to unsworn falsification to authorities. Date: q(!4 IOf .2008 StPu-9day nd subscribed before me this t of 2008. bc c COMMONWEALTH OF PENNSYLVANIA Nodal Seal Tan MI8 L. Peters, Notary Pubic CannN*n Esm Sept 9, 2011 Msmber, Permaylvanle Assmaw OI Notshes ® r, ??- om' ? -ter <3 t ?.? h ? 4 ? C l IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA JILLIAN FORREST, Plaintiff V. DANIEL PARSON, JR., Defendant No. 2007- 3806 In Divorce Civil Action - Law 1. I consent to the entry of a final decree of divorce without 2. I understand that I may lose rights concerning alimony, divisio 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 i entered by the Court and that a copy of the decree will be sent to me immediately after it is filed th the Prothonotary. I verify that the statements made in this Affidavit are true and correct. I statements herein are made subject to the penalties of 18 Pa. C.S. §4904 falsification to authorities. 2f Date: V 3 understand that false relating to unsworn C') cep "? ? + t ? ; ? ?? ? d --i C) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA JILLIAN FORREST, No. 2007- 3806 Plaintiff' In Divorce V. Civil Action - Law DANIEL PARSON, JR., Defendant PRAECIPE TO TRANSNM RECORD To the Prothonotary: Please transmit the record, together with the following information, tc a Divorce Decree: 1. Ground for divorce: irretrievable breakdown under Section 3 Court for entry of 1(c) of the Divorce Code. 2. Date and manner of service of the Complaint: mailed to Defendant by United States Certified, Return Receipt Requested, Restricted Delivery Mail and accepted by Defendant on June 29, 2007. 3. Date of execution of the Plaintiffs Affidavit of Consent required by Section 3301 (c) of the Divorce Code: April 30, 2008; by the Defendant: April 30, 2008. 4. Related claims pending: None. 5. Date Plaintiffs Waiver ofNotice in §3301(c) Divorce was filed with the Prothonotary: May 6, 2008. Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: May 8, 2008. KNIGHT & ASSOCIATES, P Date: May 5, 2008 Sean M. Shultz, Esquire Attorney I.D. No. 9094, 11 Roadway Drive, Sui Carlisle, Pennsylvania l (717) 249-5373 Attorneys for Plaintiff :e B 7015 N camr z c .SIR + I N THE COURT OF COMMON PLEAS + + OF CUMBERLAND COUNTY + + + STATE OF PENNA. + + t 1W, + + + J=IAN FoRRES`r, + + N 2007-3806 + Plaintiff VERSUS I+DANIEL PARSON, JR., Defendant t + DECREE IN + + + + DIVORCE + + + + + AND NOW, IY1 LH S 2008 IT IS ORDERED AND + + DECREED THAT =IAN FORREST PLAINTIFF, + + AND DANIEL' PARSON, JR. DEFENDANT, + ARE DIVORCED FROM THE BONDS OF MATRIMONY. + + + THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; + The Marriage Settlement Aqreement dated April 24, 2008 is incorporated x + + by rofer - + + + BY THE COURT: . Aik"Ic. + V c_'? tp I + ATTES J + I - r- ?/ PROTHONOTARY 3. o"A p? ?AI4101' 17? 4k