The URL can be used to link to this page

Home My WebLink About07-4133• GENEVIEVE LORENCE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW : NO. 6rj_ /.E133 Civi I Trm MICHAEL LORENCE, 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, FL6I~VER & JctP~DSAY S~IDIS, LINDSAY ~:tAW 26 West High Street Cazlisle, PA Carol J. Lindsay. s~ Attorney Id. 44 i 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff GENEVIEVE LORENCE, Plaintiff v. MICHAEL LORENCE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. ~~' y13.3 IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) or (d) OF THE DIVORCE CODE 1. The Plaintiff is Genevieve Lorence, an adult individual, residing at 62 East Pomfret Street, Carlisle, Cumberland County, Pennsylvania. 2. The Defendant is Michael Lorence, an adult individual, residing at 21 Graystone Road, Carlisle, Cumberland County, Pennsylvania. 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 29, 2003 in Carlisle, SAIDIS, FLOWER Sz LINDSAY uw 26 West High Street Carlisle, PA Cumberland County, Pennsylvania. 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. WHEREFORE, Plaintiff requests entry of a divorce decree in her favor in accordance SAIDIS, FLOWER ~ LINDSAY 26 West High Street Cazlisle, PA with §3301 of the Pennsylvania Divorce Code. Dated: ~ !0/ Respectfully submitted, SAIDIS, FLOWER & LI Y Carol J. Lindsay, E quire Attorney Id. 44 93 26 West High et Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff ~i 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. ~~ p~j(~.C,rL~.e_,, `Genevieve Lorence Date: ~ Z~ ~U SAIDIS, FIAWER Sz LIlVDSAY ~•uw 2G West High Street Cazlisle, PA ~"1 c ~ ~' C7 -~' _.., c.... ~ ~ ~ ~ ` A ~ ~ "~J -~-- _Yt ~ ~ D - c=J GENEVIEVE LORENCE, Plaintiff v. MICHAEL LORENCE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 07-4133 IN DIVORCE AFFIDAVIT OF SERVICE SAIDIS, FIAWER ~ LINDSAY n~notweis..n:uw 26 West High Street Carlisle, PA I, Carol J. Lindsay, Esquire, being duly sworn according to law, hereby deposes and says that on July 20, 2007, she served a true and correct copy of the Divorce Complaint upon i Michael Lorence, Defendant, by mailing those documents to the his address at 21 Greystone Road, Carlisle, PA 17013, 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, Michael Lorence. Respectfully submitted, SAIDIS/,, FLOWE & LIN Y / / ,~ . Dated: July 24, 2007 Carol J. Lindsay, ,~~ Attorney Id. 446,83 26 West High S~tr~ Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff ^ Complete Rams 1, 2, and 3. Also complete Nsnt 4 ff Restricted Delivery Is desired. ^ r+rlnt your name and address on the reverse ao mat we can return the card to you. ^ 1M~h this card to the back of the mailpiece, a on frnrrt if space permits. 1. `reseed to: ?~ ~' h cue. i for en e~.. d t re Ys-kor~e~j oQCt- I r~/e, ~t ~ ~'7 0 ~3 C. Dais of is"de~Nary ad(irees dererent born iEeem ~ 7 ^ Yes H YES, enter delivery address below: ~ No 3. Service Type ~CertMed Mail D Express Mail ^ Registered ^ Return Receipt for Mercher~ss ^ Insured Mail ^ C.O.D. 4. Resbicted Dalhrery'1(Exba Fee) 2. 1lrtirie lMxrlber ~„r,.~ar,r„r,1e.r„~e~ 7Q(74 135Q 0003 7284 729Q PS Form 3811, Febrwry 2004 Dorrwekic Fiaturn RsoMpt ~oaasaos-ti+-~sao ~ FLOWER ~S~ 26 West High Street Carlisle, PA ~~~ ~~ ~" C ~ ~. a ...; ~. -r: -r.3r c__ ~L { { ~ ^~ Cf~a ~- ~ .. n-* t F~ -- . C c. ~ . i t . , tw GENEVIEVE LORENCE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW NO.07-4133 MICHAEL LORENCE, Defendant IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on July 12, 2007. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and ser/ice of the Complaint. 3. I 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 ~ ~ 4 ~ ~inlv-~,~cv't.- Genevieve Lorence PLAINTIFF'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 3301 Ic) 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 de not claim them hefore a divnrr..e is granted. 3. I understand that I will not be divorced until a Divorce Decree is entered by the Court FLOWER ~ LINDSAY 2G West High Street Carlisle, PA 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. !understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. Date: ~~ (.cam ~ ~ Zvf1 Z ~r~t~c1-i,+,~.Q. Genevieve Lorence ~~~ 2 2 20Q7 v ~ ~~' a ~ : t t ~lz .~ E,, ~ ~ --, u, ~.~, " ~.:: a ~ L -~; ~. `~~ t~ ,~ GENEVIEVE LORENCE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW NO. 07-4133 MICHAEL LORENCE, Defendant IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on July 12, 2007. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the dare of filing a^d seraiee of tie CcmY!aint. 3. I 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: Q Michael orence DEFENDANT'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 3301 (c) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree of Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if i do not c!uim them before a dwerce is grantQd. 3. I understand that I will not be divorced until a Divorce Decree is entered by the Court SAIDIS, F7AWER ~ LINDSAY nnoiav~~s.,+r uw 26 West High Street Carlisle, PA 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: Mic ael Loren e ~~ ~ ~ ~~~ r..~ ~~ ,,.~,: `^ t i ~~ P.~6~ .t,~a±w f .... _ . , ,. i,~ . ~ 4~i`R ' .~. .~._E ~,T i «..,. t~. ..~~ GENEVIEVE LORENCE, Plaintiff v. MICHAEL LORENCE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 07-4133 IN DIVORCE PROPERTY SETTLEMENT AND SEPARATION AGREEMENT r0~.. THIS AGREEMENT made this ,~_ day of 2007, between GENEVIEVE LORENCE, of 62 East Pomfret Street, Carlisle, Cumberland County, Pennsylvania, hereinafter referred to as Wife, and MICHAEL LORENCE, of 21 Greystone Road, Carlisle, Cumberland County, Pennsylvania, hereinafter referred to as Husband. RECITALS: R.1: The parties hereto are husband and wife, having been joined in marriage on March 29, 2003 in Carlisle, Cumberland County, Pennsylvania; and R.2: A Complaint for Divorce has been filed in the Court of Common Pleas of Cumberland County, Commonwealth of Pennsylvania, to Number 07-4133, 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 life, 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 (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 dwe(i 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, and will execute and file the necessary documents to finalize the divorce after the expiration of ninety (90) days of the service of the Complaint and Wife shall move for the entry of the divorce decree at that time. (3j REAL PROPERTY: The parties are the owners of certain real estate with improvements thereon erected and known and numbered as 62 East Pomfret Street, Carlisle, Pennsylvania. The house is encumbered by a mortgage in favor of SunTrust. The parties acknowledge that the house was Wife's separate property prior to their marriage. On the same day as the execution of this Agreement, Husband will execute a special warranty deed to transfer back to Wife all his right, title and interest in the marital home. Wife will be exclusively responsible for the payment of the mortgage and any other charges related to the house including taxes, homeowner's insurance and utilities. Within ninety (90) days of the date of this Agreement, Wife will sell the house, refinance it or obtain a release of Husband's obligation on the mortgage to SunTrust. With regard to the charges related to the marital home, Wife will indemnify and hold Husband harmless against any loss. 2 (4) DEBT: A. Marital Debt: Husband and Wife acknowledge and agree that there are no other outstanding debts and obligations which are marital or for which the other might be liable except for the mortgage on the marital home. B: Post Separation Debt: In the event that either party contracted or incurred any debt since the date of separation on June 29, 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. The parties acknowledge that the vehicles which they drive were purchased by them prior to marriage. They are titled in the name of the party who will be retaining them. (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 aH such property presently in his 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. (7) INTANGIBLE PERSONAL PROPERTY: Each party hereby relinquishes any right, 3 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. Husband will retain his United States Savings Bonds, his Citizens Bank IRA, his PPG stock and his PPG pension and 401(k). Wife will retain her PSERS pension. With regard to the parties' joint checking account at Commerce, as soon as the parties can arrange for their payroll checks to be deposited into their separate account, the parties will close the joint Commerce account and equally divide the balance remaining therein provided, however, that Wife will be exclusively responsible for the mortgage payment commencing July 1 and any other checks she has written on the account after July 1 and will reimburse Husband for any she wrote on the account subsequent to June 29, 2007 from her half share of the remaining account proceeds. (8) 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. (9) 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. Wife is represented by Carol J. Lindsay, Esquire and Husband has been advised that he may be represented by counsel of choice. 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 4 improper or illegal agreement or agreements. Husband will share with Wife the cost of preparation of a Complaint in Divorce, a Marital Settlement Agreement and the filing fees required by the Court by authorizing Wife to pay those expenses up to $800.00 from the joint checking account. Any attorney's fees or costs incurred by Wife in excess of $800.00 shall be her own separate responsibility. (10) 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. (11) INCOME TAX: 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 solely and entirely by the individual who is finally determined to be the cause of the misrepresentations or failures to disclose the nature and extent of his or her separate income on the aforesaid joint returns. (12) 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 5 into. (13) 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. (14) 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. (15) 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. (16) 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 6 expenses or demands whatsoever in law or in equity; B. Ali 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; (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. Aii 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; i. All rights, claims, demands, liabilities and obligations each party now has, or may hereafter have, against or with respect to the other. (17) 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. (18) 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. (19) BREACH: In the event that either party breaches any provision of this Agreement, he or she shall be responsible for 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. (20} 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. (21) 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. TNESS: J n.~c~a ~` ~f~ o D ~Pi~wUwrc~ oC.~~`~ Genevieve Lorence -~ ,' G~- Michael Lorence R• s ~-, r~~ ' -~-ate "i 3 ' - ~ ; r t..~(~! a __ , t -p„ i ' r _~ , ~`~,) . `~ -; . CJl ----- "~: GENEVIEVE LORENCE, Plaintiff v. MICHAEL LORENCE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. ~.~ - ~~ 3 3 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: Divorce Code. Grounds for Divorce: Irretrievable breakdown under Section 3301(c) of the 2. Date and manner of service of the Complaint: Defendant accepted service of the Complaint on July 20, 2007, via certified mail. Proof of service was filed with the Court on July 24, 2007. 3. Date Affidavit of Consent required under Section 3301(c) of the Divorce Code was executed: By Plaintiff: October 20, 2007 and filed with Prothonotary on October 21, 2007. By Defendant: October 26, 2007 and filed with Prothonotary contemporaneously herewith. SAID-IS, FLOWER ~ LINDSAY ~.,~.~W 26 West High Street Carlisle, PA 4. Related claims pending: The terms of the Property Settlement and Separation Agreement dated July 23, 2007 are incorporated, but not merged, into the Decree in Divorce. 5. Date Waiver of Notice under Section 3301(c) of the Divorce Code was executed: By Plaintiff: October 20, 2007 and filed with Prothonotary on October 21, 2007. By Defendant: October 26, 2007 and filed with Prothonotary contemporaneously herewith. SAIDIS, FLOWER & LINDSAY Carol J. Linds`ay`, utre - ` Supreme Co ~ I No. 44693 26 West Hig eet Carlisle, PA 17013 717-243-6222 GENEVIEVE LORENCE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW NO. 07-4133 MICHAEL LORENCE, Defendant IN DIVORCE NOTICE OF INTENTION TO RESUME PRIOR NAME NOTICE IS HEREBY GIVEN that Genevieve M. Lorence, the Plaintiff in the above matter, having filed a Complaint in Divorce on July 12, 2007, hereby intends to resume and hereafter use the previous name of GENEVIEVE M. GEARHART, 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. `Genevieve M. Lorence TO BE KNOWN AS: SAIDIS, FIAWER ~ LINDSAY nrtoxi~s•,-ruw 26 West High Street Carlisle, PA Genevieve M. Gearhart COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ss. ON this, the (~" day of , 2007, before me, a Notary Public, personally appeared Genevieve M. Lorence, also known as, Genevieve M. Gearhart ,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. CAB. ~~ Notary Public C>r~1s Bever ~j~ q X011 ~~ C~ ~" ' ~ ;..3 ` ~ r ' a. ~7 -~._ C7 ~ ~ `~ rr7 ~ ! ~+ " ~ f ; ~ry pp rV A. (~+ . Y ~~ . ~ ... ~ r~`' ~ _.i ~~ 3 ',~ ~/ ~ ' ~w ~...ti r '4R~~ *+'.y i ~ '~ "'+~, I N THE COURT OF COMMON PLEAS + OFCUMBERLAND COUNTY STATE OF PENNA. GENEVIEVE LORENCE -~~' '~~` 07-4133 NO. + VERSUS MICHAEL LORENCE DECREE IN + DIVORCE + + AND NOW ~ IT IS ORDERED AND GENEVIEVE LORENCE + DECREED THAT PLAINTIFF, AND MICHAEL LORENCE DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF REC R IN T IS ACTION FOR WHICH A FINAL ORDER HAS NOT + YET BEEN ENTERED; + The terms of the Separation and Property Settlement Agreement dated July 23, 2007 are incorporated, but not merged, into this Decree in Divorce. - ~. BY THE CO RT: + + ATTEST: -~ ~ ~ PROTHONOTARY t~ ~, ~ ~.- + + ~. ~ /~».'~' ~ p. ~ - ~~ LQ - ~ - I,~ .~ -