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HomeMy WebLinkAbout07-4097., ~a IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA FAMILY DIVISION Ryan L. Fleagle Plaintiff Angela N. Fleagle . Defendant DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS 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, property or other rights important to you, including the right to demand marriage counseling. When the ground for divorce is indignities of irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the OfFice of the Prothonotary for Cumberland County: uwr-~ar tc~-~nd Co win ~ ~o~.,r~Fkou~Q 1 ~~ HbY.32 Sio . c~r1~51~ ~a ~~e I ~ IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS ENTERED, 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: Cumberland County Bar Association Lawyer Referral Service Adams Co., Gettysburg: (717) 334-6781 Allegheny Co., Pittsburgh: (412) 261-0518 Armstrong Co., Kittanning: 724-548-3251 Beaver Co., Beaver: (412) 728-4888 Bedford Co., Bedford: 81423-4833 Barks Co., Reading: (610) 375-4591 Blair Co., Hollidaysburg: (814) 693-3090 Bradford Co., Towanda: (570) 265-1705 Bucks Co., Doylestown: (215) 348-9413 Butler Co., Butler: (724) 284-5214 Cambria Co., Ebensburg: (814) 472-1636 Cameron Co., Emporium: (814) 468-3355 Lackawanna Co., Scranton: (570) 969-9600 Lancaster Co., Lancaster: (717) 393-0737 Lawrence Co., New Castle: (724) 656-2143 Lebanon Co., Lebanon: (717) 274-2801 Lehigh Co., Allentown: {610) 433-7094 Luzeme Co., Wilkes-Barre: (717) 822-6712 Lycoming Co., Williamsport: (570) 327-2251 McKean Co., Smethport: (814) 887-3270 Mercer Co., Mercer: (724) 342-3111 Mifflin Co., Lewistown: (717) 248-8146 Monroe Co., Stroudsburg: (570) 424-7288 Montgomery Co., Norristown: (610) 279-9660 ~ `1 Carbon Co., Jim Thorpe: (570) 325-2481 Centre Co., Bellefonte: (814) 355-6796 Chester Co., West Chester: (610) 429-1500 Clarion Co., Clarion: (814) 226-1119 Clearfield Co., Clearfield: (814) 765-2641 Clinton Co., Loch Haven: (570) 893-4007 Columbia Co., Bloomsburg: (570) 389-5600 Crawford Co., Media: (814) 333-7324 Cumberland Co., Carlisle: (717) 249-3166 Dauphin Co., Harrisburg,: (717) 232-7536 Delaware Co., Media: (610) 566-&625 Elk Co., Ridgway: (814) 776-5344 Erie Co., Erie: (814) 459-4411 Fayette Co., Uniontown: (724) 430-1272 Forest Co., Tionesta: (814) 755-3526 Franklin Co., Chambersburg: (717} 261-3858 Fulton Co., McConnellsburg: (717) 485-4212 Greene Co., Waynesburg: (724) 852-5289 Huntingdon Co., Huntingdon: (814) 643-1610 Indiana Co., Indiana: (724) 465-3855 Jefferson Co., Brookville: (814) 849-1606 Juniata Co., Mifftintown: (717) 436-7715 Montour Co., Danville: (570) 271-3010 Northampton Co., Easton: (610) 258333 Northumberland Co., Sunbury: (570) 988-4151 Perry Co., New Bloomfield: (717) 582-2131 Philadelphia Co., Philadelphia: (215) 238-1701 Pike Co., Milford: (570) 296-7231 Potter Co., Coudersport: (814) 274-9740 Schuylkill Co., Pottsville: (570) 628-1270 Snyder Co., Middleburg: (570) 837-4202 Somerset Co., Somerset: (814) 445-1428 Sullivan Co., Laporte: (570) 946-7351 Susquehanna Co., Montrose: (570) 278-4600 Tioga Co., Wellsboro: (570) 724-9281 Union Co., Lewisburg: (570) 524-8751 Venango Co., Franklin: (814) 432-9577 Warren Co., Warren: (814) 728-3440 Washington Co., Washington: (724) 225-6710 Wayne Co., Honesdale: (570) 253-5970 Westmoreland Co., Greensburg: (724) 834-8490 Wyoming Co., Tunkhannock: (570) 253-5970 York Co., York: (717) 854-8755 • IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA FAMILY DIVISION Ryan L. Fleagle , Plaintiff Angela N. Fleagle ' Defendant ' DIVORCE COMPLAINT UNDER SECTION 3301(cl OF THE DIVORCE CODE 1. The Plaintiff is Ryan L. Fleagle, who currently resides at 621 E. Orange St., Shippensburg, Pennsylvania 17257. He has resided at this address at least since March 2005. 2. The Defendant is Angela N. Fleagle, who currently resides at 621 E. Orange St., Shippensburg, Pennsylvania 17257. She has resided at this address at least since July 2005. 3. Both the Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on July 16, 2005, at The Shippensburg First Church of God ,Shippensburg, Pennsylvania, County of Cumberland. 5. Neither the Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Servicemember's Civil Relief Act of 2003 and its amendments. 6. There have been no prior actions of divorce or for annulment instituted by either of the parties in this or any other jurisdiction. 7. The Plaintiff is aware of the availability of counseling and of the right to request that the Court require the parties to participate in counseling. 8. The marriage is irretrievably broken. 9. An original copy of the marriage certificate is attached. 10. After ninety (90) days have elapsed from the date of filing of this Complaint, the Plaintiff intends to file an affidavit consenting to a divorce. The Plaintiff believes that the Defendant will also file such an affidavit. WHEREFORE, if both parties file affidavits consenting to a divorce after ninety (90) days have elapsed from the date of the filing of this Complaint, the Plaintiff respectfully requests the Court to enter a decree of divorce pursuant to §3301 (c) of the Divorce Code. a_. • 0 3 ~, m ~' ro 3 0 m ~? ~ ~ n m Oa "~ c . h :..~ 0. K m °n ~ . , z~ ~ • v ci ~ o '~ ;~. O ~ ~ fi T ~ ~ O ~, :~ n ~ ~ c 3 ~~ : $ :~ t7 ~ ~ =z •as o o Q ~d ~. ' g m m c. _ rn O~`~ a~~ A ~~'1{,~ ~ 4~~ ~ -t ~ ~~. 'F1 w© ©~~. o' ,~ Z ~ 'C o°n -~ cn Z o -~ ~. ,~ ~- a m S ~_ F tTl Q1 ~J °, D Sao ~« m p '~ k w o. n. < .,._ 0 O ,~, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA FAMILY DIVISION Ryan L. Fleagle Plaintiff Angela N. Fleagle vs' No. ~~- ~f o97 C~ Ja ~ 'I~~n.~- Defendant ' DIVORCE VERIFICATION I verify that the statements made in this complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are subject to the penalties of 18 PA. C.S., §4094, relating to unswom falsification to authorities. iD 06 , Date PI 'tiff 1. COUNSELING NOTICE UNDER Pa R C P RULE 1920.45(a)*(1) The Divorce Code of Pennsylvania requires that you be notified of the availability of counseling where a divorce is sought under any of the following grounds: Section 3301(a)(6) Indignities Section 3301 (c) Irretrievable Breakdown Mutual Consent Section 3301(d) Irretrievable Breakdown Two-Year Separation where the court determines that there is not a reasonable prospect of reconciliation. A list of qualified professionals is available for inspection in the Prothonotary Office of the Cumberland County court. ~_ l / fI b~~l~ C. v tur,~ G wr i ~~,.ri- ~o ~gnsa C~1 ti g`~. ~t'QI ~--~-?~-. r ~ a.• IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA FAMILY DIVISION Ryan L. Fleagle Plaintiff vs. ~ No. ~ 7_ yo 9 ~ U ~e ~ ~ er.~ Angela N. Fleagle ' Defendant ' DIVORCE AFFIDAVIT OF NON-MILITARY SERVICE Personally appeared before me the undersigned, a Notary Public in and for said County and State, Ryan L. Fleagle, for the Plaintiff and duly authorized to execute this Affidavit, and states that the Affiant knows of his or her own knowledge that the Defendant Angela N. Fleagle herein is not in the military service as defined in the Servicemembers' Civil Relief Act of 2003 and its Amendments thereto, for the following reasons: At no time during our marriage have I ever witnessed my spouse report to or make contact with military personnel. Affiant further says that the obligation sought to be enforced in this suit is not an obligation against a surety guarantor, endorser, or other person liable, primarily or secondarily, for a party in the military service. IN WITNESS THEREOF, I have hereunto set my Dated: ~~ /b ~ p~~ 0 and seal. 1 NOTARY PUBLIC COMMONiNEAI('F! ~F PENNSYLVANIA NOTARIAL SEAL DAWN M. CAREY, Notary Public Boro of Carlisle, Cumberland Coun ~My Commission Expires Nov. 213, 2A1 C".3 ~ 7 -rye-'- = ~ ; ~ - ~_ _ W ' ._.. ~ tom-, 1 ~ ~ © 7~- ~t~o~ r7 ~. _;~ f l 1 CC ' v'1 _ ~ ~.~, \ ®~ ~ ~{ `~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Ryan L. Fleagle, ) Civil Action -Law Plaintiff, ) vs. ) No. F.R. 07-4097 Angela N. Fleagle, ) Defendant, ) In Divorce a v.m. NOTICE TO PLEAD To: Ryan L. Fleagle c/o Steven Howell, Esquire Howell Law Firm 619 Bridge Street New Cumberland, PA 17070 You are hereby notified to file a written response to the attached Counterclaim within twenty (20) days from service hereof or a judgment may be entered against you. By: G S z nne M. Trinh, Esquire At orney for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY I Ryan L. Fleagle, vs. Angela N. Fleagle, Civil Action -Law Plaintiff, ) No. F.R. 07-4097 Defendant, ) In Divorce a v.m. COUNTERCLAIM The Defendant, Angela N. Fleagle, makes the following counterclaim against the Plaintiff, Ryan L. Fleagle. COUNT ONE ALIMONY PENDENTE LITE, COUNSEL FEES AND EXPENSES 1. The Plaintiff has refused to enter into any reasonable and fair Property and Separation Agreement, and Defendant will incur substantial legal fees in that regard. 2. Furthermore, the resolution of the issues raised by this Counterclaim will require Defendant to incur considerable additional expenses and costs. ~, 3. The Defendant is without sufficient means to adequately support herself and to meet '! the costs and expenses of this litigation and is unable to maintain herself during the pendency of this action. 4. The Plaintiff is presently employed as a project manager for Brooke's Painting with an estimated gross annual income in excess of $90,000 with a net weekly take-home pay of approximately $1,300. 5. The Defendant is presently employed as a Commercial Lending Assistant with Orrstown Bank and has a gross annual income of approximately $30,000 and net bi-weekly take-home pay of approximately $763.00. WHEREFORE, pursuant to Section 3702, et. seq., of the Divorce Code, "Alimony Pendente Lite, Counsel Fees and Expenses", Defendant respectfully requests your Honorable Court to Order Plaintiff to file within thirty days of service of this Counterclaim upon Plaintiff, a complete income and expense statement, and to require the scheduling of a hearing to determine Defendant's entitlement to alimony pendente lite, counsel fees and expenses, and if so, the amount. SHARPE & SHARPE, LLP By. Gl S z nne M. Trinh, Esquire A orney for Defendant 257 Lincoln Way East Chambersburg, PA 17201 (717) 263-8447 (717) 263-0279 (fax) Pa. Bar I.D. No. 92747 I verify that the statements made in this Counterclaim are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa C.S. 4904, relating to unsworn falsification to authorities. Date: I~c~nH~ 2t, 200 gels N. Fleagle ~ ~ c:~ t l r ~ V ~ ~ C. ~' . '~'! ~ .. ~"' - , y ""I ~. ~ ~ ~ , ~ ~3 f ~1 ~- ' 1 ~', ~ ~ d ~ _? C~~ ~ ~~ ~.. ' ~ - - . ~ ~ ; t ~ 1 ~ : ~ ~~" ~c?~ ~r RYAN L. FLEAGLE, PLAINTIFF VS. ANGELA N. FLEAGLE, DEFENDANT PRAECIPE TO ENTER AND WITHDRAW APPEARANCE ON BEHALF OF THE PLAINTIFF RYAN L. FLEAGLE To the Prothonotary: Please WITHDRAW the appearance of Harold S. Irwin, III, Esquire on behalf of the Plaintiff in this matter. Please ENTER the appearance of Steven Howell, Esquire as IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA N0.2007 - 4097 CIVIL TERM CIVIL ACTION -DIVORCE Plaintiff s new counsel of record. BY: BY: Sowell Law Firm 619 Bridge Street New Cumberland, PA 17070 Supreme Court ID 62063 (717) 770-1277 Harold S. Irwin, III Esquire Irwin Law Office 64 South Pitt Street Carlisle, PA 17013 Supreme Court ID Z~~ 4 m ~~' r Q : '' t ~~ /.% _ ~ . _~ r-r= ~_: .s--- 4., .; ~ ~~ 1~ ti ~. ;' ~ ~? ,,~ ~~ ~ "~7a ,~ ~". f:71 „C IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Ryan L. Fleagle, Civil Action -Law Plaintiff v. No. F.R. 07-4097 Angela N. Fleagle, Defendant In Divorce a.v.m. i j ACCEPTANCE OF SERVICE i -` NOW, this ~R day of >ecaJ , 2007, I, Steven Howell, Esquire hereby accept service of the Counterclaim filed in the above case pursuant to Pa. R.C.P. 402(b) on behalf of the Plaintiff above and certify that I am authorized to do sa,~~' i Date: /2 / ' , 2007 ~~ 6ao63 r ~. F ,~ ~i ~ ~~ ~~~~ ~~ ~~~ ~a~Z ~t1b'tG~~~~;~-f ~ ~::.'d ~,^11.,1Jiyt_~~~~ ~ ~Q RYAN L. FLEAGLE, IN THE COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 2007 - 4097 CIVIL TERM ANGELA N. FLEAGLE, DEFENDANT CIVIL ACTION -DIVORCE PLAINTIFF'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301 (c) AND §3301 (d) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. Date: -D o BY: d Ry L. Fleagle ~. ;) ~ ~~ ^T1 ~ ^~ tzr, ' ! ~ t C' 1_ ~Y .c 9 4. ,~ r ~~~ ., ~ ^~'. µ,",~ C:i RYAN L. FLEAGLE, IN THE COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA VS. NO.2007 - 4097 CIVIL TERM ANGELA N. FLEAGLE, DEFENDANT CIVIL ACTION -DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A complaint in divorce under §3301 (c) of the Divorce Code was filed on July 10, 2007. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. BY: Ry L. Fleagle Date: ~ 1010$ 3 C c~ _ n c" t ~ ~'~ -ts _, -. RYAN L. FLEAGLE, IN THE COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA VS. : N0.2007 - 4097 CIVIL TERM ANGELA N. FLEAGLE, DEFENDANT CIVIL ACTION -DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT 1. A complaint in divorce under §3301 (c) of the Divorce Code was fled on July 10, 2007. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. BY: Date: VU1ar~ t b 206°f rMa ~ ~~ _,.;' ~,:.. < , ~~ _ ti~1t C~ : ~~ j' ~;. .. ._;.s '1 RYAN L. FLEAGLE, PLAINTIFF VS. ANGELA N. FLEAGLE, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA N0.2007 - 4097 CIVIL TERM CIVIL ACTION -DIVORCE. DEFENDANT'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301 (c) AND §3301 (d) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. BY: Date: ~at ~ ~ So 2~6°~ ~_.~ C~ ~ ~ Q _.r. - i', "G7 - . ~ ~ F`Yl F ~t ++ ~~d ~~ ~~ RYAN L. FLEAGLE, IN THE COURT OF COMMON PLEAS PLAINTIFF OF CUMBERLAND COUNTY, PENNSYLVANIA VS. N0.2007 - 4097 CIVIL TERM ANGELA N. FLEAGLE, DEFENDANT CIVIL ACTION -DIVORCE AFFIDAVIT OF SERVICE I hereby certify that based upon information received from the Plaintiff and the United States Postal Service on July 14, 2007 the Defendant Angela N. Fleagle was served with a Complaint in Divorce endorsed with a Notice to Defend by U.S. first class mail, postage prepaid, certified, return receipt requested (7006 2150 0004 0467 7021) as shown on Exhibit "A" (copy of signature page of return receipt) and a printout (Exhibit "B") from the United States Postal Service website confirming delivery on July 14, 2007. Respectfully submitted, BY: ~"9 Bridge Street New Cumberland, PA 17070 (717) 770-1277 Supreme Court I.D. 62063 Attorney for Plaintiff Date: March 30, 2009 a ~ O~ D Addn« ( m C. Deb Ot1M D. to eddrserr d Ibrsnt tis ,item t? O Na MYE3, sntn drtMNvery rdcsraa babes: 3. 3ervfce lype O C«anse Mdl O ~ bha O R.piebrea O Rdun Rea(pttaMarche?~v. O -neurod nan O ao.o. a, wetr+~xea ~ ~ Owe 2 Arpd.N„mber 7006 2150 0004 0467 7021 (Ilaambr nom asru PS rwrm 3811. Pebnrery 2004 o«r~b Flaarn ,o2ees.as~,sw b Comple0e Mama f ~ 2, arfd 3. Abo rrornpbGtt . Item 4 if ReatrlcESd DNhroty b deviled. ^ Print yam name and eddreaa on the reverse .:i so that we can return the card to you. ' 1 Attach thb sand to the back of the matipbce, or on the fra,t h space pennita. 1. Ardcls Add,aeed tio: r~/ Z\ Jr (~Q C ~-i ~~ ~ ~- ~ 7Z ~ 7 USPS -Track & Confirm Page 1 of 1 •• f~ Home I Help Track 8 Confirm Yr'8~k ~t ~tlli~ttt~! $e~lr~h Rea~ufts Label/Receipt Number; 7006 2150 0004 0467 7021 -----------°----°~------ Associated t.abel/Receipt: Trek ~ ~'~ Detailed Results: Enter Label/Receipt Number. • Delivered, July 14, 2007, 12:13 pm, SHIPPENSBURG, PA 17257 • Notice Left, July 11, 2007, 3:16 pm, SHIPPENSBURG, PA 17257 • Acceptance, July 10, 2007, 5:26 pm, SHIPPENSBURG, PA 17257 -~ ~ ~ BecAr R~ ~ Ub`~PS.ear<rr Homt s ite lea Contact Us Forms Gov't Services Jobs Priva~Policv Terms of Use National 8 Premier Accounts hr CopyHght©1999-2007 USPS. All Rights Reserved. No FEAR Act EEO Data FOIA , http://trkcnfrml .smi.asps.com/PTSInternetWeb/InterLabelDetail.do 3/31/2009 .~ ~ ~ ?} ~ ~-3> ~ L~ ~ ~ , 4:% C ~ s -v p y C"'C^ ~ ~y W RYAN L. FLEAGLE, IN THE COURT OF COMMON PLEAS PLAINTIFF OF CUMBERLAND COUNTY, PENNSYLVANIA VS. • N0.2007 - 4097 CIVIL TERM ANGELA N. FLEAGLE, DEFENDANT CIVIL ACTION -DIVORCE PRAECIPE TO TRANSMIT THE RECORD TO THE PROTHONOTARY: Please transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground for Divorce: Irretrievable breakdown and mutual consent under § 3301 (c) of the Divorce Code. 2. Date and manner of service of the complaint: Original Divorce Complaint filed on July 10, 2007 and served upon the Defendant Angela N. Fleagle by United States Mail, Certified, Return Receipt Requested 70062150000404677021 on July 1 d, 2007 as described in an Affidavit oJService which includes a copy of the Return Receipt bearing the Defendknt'~ signature and a printout from the LISPS website confirming delivery. 3. Date of Execution of the Affidavit of Consent required by § 3301 (c) of the Divorce Code; by Plaintiff July 10, 2008 [Filed July 15, 2008]; by Defendant: March 16, 2009 [Filed March 20, 2009]. 4. Related claims pending: None. 5. Date Plaintiff s Waiver of Notice in Section 3301 (c) Divorce was filed with the Prothonotary: July 15, 2008. Date Defendant's Waiver of Notice in § 3301 (c) Divorce was filed with the Prothonotary: March 20, 2009. Defendant's documents were executed on March 16, 2009. Plaintiff's documents were executed on July 10, 2009. Respectfully submitted, BY: ~ven ~owell, Esquire 619 Bridge Street New Cumberland, PA 17070 (717) 770-1277 Supreme Court I.D. 62063 Attorney for Plaintiff Date: March 30, 2009 ~' "~ ~; r~ ~'r 'Rs C„r ~ ,.. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA. Ryan L. Fleagle, Plaintiff, ) Defendant, ) Civil Action -Law vs. Angela N. Fleagle, No. 2007- 4097 Civil Term In Divorce a v.m. NOTICE O>i+' INT`I'IN ~'IO~,T TO RESL~IE PRIOR :FAME Notice is hereby given that the Defendant in the above-captioned matter, hereby elects to retake and hereafter use her previous name of Angela N. Tatum prior to the entry of a Final Decree in Divorce and gives this written notice avowing her intention in accordance with the provisions of 54 P.S. § 704, as amended. ., nge>i~tN. Fleagle ~ ; ~' T~; lie known ~s: J,, ~ ~ ~ _ ~. ~ ~~ Angela. Tatum COMMONWEALTH OF PENNSYLVANIA ) SS: COUNTY OF l~F~13~1 ~',~. s vwa e ` 1 t1.4;~t ) On the ~..~,~day of ~'~G~ ~k1 2009, before me, a Notary Public, personally appeared Angela N. Fleagle known to me to be the person whose name is subscribed to the within document and acknowledged that she executed the foregoing for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and notarial seal. COMMON! ;~r;~ s o < <_;r ^~N8'YLVANIA SHARPE ~ SHARPE, LLP ~ rilindy a)olh~n, ~lnt~ f~ublic ,~~ ,. `~ ATTORNEYS AT LAW ty Mechanicsi7~sr Ba ~, ta~rr~F~etjand County ~ ` ~ ~I ~~~~.-~~ s 257 Lincoln Way East ~ Chambersburg, PA 17201 ~ My CO-rtmisskzn L. ";i ~+„~pg. 5, 2011 ` NOtary Pub11C (717) 263-8447 ~'smbG~~, Pennsr~ ~ ~ ~.~~irm ±~f NCt3ries ~ ~~~rTG ZOD9 APR -Z P~ 1 ~ k 9 ~~,. ~~.i~,'rv~ ~'~.1r`,'du~ . r 4. ob P A A Trt`~ ~~ ~~a89~ It~~.a8 { aa3 r 5? 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RYAN L. FLEAGLE V. ANGELA N. FLEAGLE NO. 2047-4097 DIVORCE DECREE AND NOW, ~ ~~', 7 ~ ~~ , it is ordered and decreed that RYAN L. FLEAGLE ,plaintiff, and ANGELA N. FLEAGLE ,defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pedente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (if no claims remain indicate "None.") NONE By the Court, Attest: J. rothonotary .AF`" ~-, ~. ~ •D`~ ~ ~ ~ `~~ ~~ 12~~" ~t~l `~'~ ~, t ~ Y ` ~~~ y . y~~