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Home My WebLink About03-4822 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRIAN E. RABENA, Plaintiff NO. 03 - "p~ Ciu~CT~.., Ys. CIVIL ACTION - LAW CYNTHIA A RABENA, Defendant IN 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 relief requested in these papers by the Plaintiff You may lose money or property or other rights important to you. When the grounds 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 17013, IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A 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 ASSISTANCE. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Telephone: (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRIAN E. RABENA, Plaintiff NO. 0.3 - it?:>., C'u~C'-r~ vs. CIVIL ACTION - LAW CYNTHIA A. RABENA, Defendant IN DIVORCE AVISO PARA DEFENDER Y RECLAMAR DERECHOS USED HA SIDO DEMANDADO EN LA CORTE. Si desea defederse de las quejuas expuestas en las paginas siquientes, debe tomar accion con prontitud. Se Ie avisa que si not se defiende, el caso puede pro ceder sin usted y decreta de divorcio 0 anulamiento puede ser emitido en su contra por la Corte. Una decision puede tambien ser emitida en su contra por cualquier otra queja 0 compensacion rec1amados por el demandante. Usted puede perder dinero, 0 propiedades y otros derechos importantes para usted. Cuando la base para el divorcio es indignidades 0 rompimiento irreparable del matrimonio, usted puede solicitar consejo matrimonial, Una lista de consejeros matrimoniales esta disponible en la oficina del Prothonotary, en la Cumberland County Court House, Carlisle, Pennsylvania 17013. SI USTED NO RECLAMA PENSION ALIMENTICIA, PROPIEDAD MARITAL, HONORARIOS DE ABOGADO Y OTROS GASTOS ANTES DE QUE EL DECRETO FINAL DE DIVORCIO 0 ANULAMIENTO SEA EMITIDO, USED PUEDE PERDER EL DERECHO A RECLAMAR CUALQUIERA DE ELLOS. USTED DEBE LLEVAR ESTE PAPEL A UN ABOGADO DE INMEDIATO. SI NO TIENE 0 NO PUEDE PAGAR UN ABOGADO, VAYA 0 LLAME A LA OFICINA INDICADA ABAJO PARA AVERIGUAR DONDE PUEDE OBTENER ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Telefano: (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRIAN E. RABENA, Plaintiff NO. 03 - J.{J'J~ C.'UJ.. '-r~ vs. CIVIL ACTION - LAW CYNTHIA A. RABENA, Defendant IN DIVORCE AFFIDAVIT OF MARRIAGE COUNSELING Brian E. Rabena, being duly sworn according to law, deposes and says: I. 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. 2. I understand that the court maintains a list of marriage counselors in the Office of the Prothonotary, which list is available to me upon request. 3. Being so advised, I do not 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 understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date: q / II /03 B~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRIAN E. RABENA, Plaintiff NO. 63 -~p;).~ C,." ;(...~D<-"1 vs. CIVIL ACTION - LAW CYNTHIA A. RABENA, Defendant IN DIVORCE COMPLAINT IN DIVORCE AND NOW, this 5th day of September, 2003, comes the Plaintiff, Brian E. Rabena, by his attorney, G, Patrick O'Connor, Esquire, Office ofG. Patrick O'Connor, Esquire, and files the following Complaint in Divorce whereof the following is a statement: I. The Plaintiff, Brian E. Rabena, is an adult individual who currently resides at 21 Long Street Drive, Carlisle, Cumberland County, PA 17013. 2. The Defendant, Cynthia A. Rabena, is an adult individual who currently resides at 619 Ceejay Drive, Etters, York County, PA 17319. 3. The Plaintiff and Defendant were married on or about May 19, 1979, and separated on or about June I, 2003. 4. The Defendant has been a bona fide resident of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 5. There have been no prior actions of divorce or annulment between the parties. 6. The Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. 7. Both the Plaintiff and Defendant are sui juris and are citizens of the United States. 8. The Plaintiff avers as the grounds upon which this action is based is that the marriage between the parties hereto is irretrievably broken. WHEREFORE, the Plaintiff requests your Honorable Court to enter a decree divorcing the Plaintiff and Defendant absolutely Respectfully submitted, ~~~~ , G. Patrick O'Connor, Esquire 3105 Old Gettysburg Road CarnpHill,PA 17011 (717) 737-7760 ID No. 64720 Attorney for the Plaintiff VERIFICATION I, BRIAN E. RABENA, state that I am the PLAINTIFF in the above-captioned case and that the facts set forth in the foregoing are true and correct to the best of my knowledge, information, and belief. I realize that false statements herein are subject to the penalties for unsworn falsification to authorities under 18 Pa.C.S, Sec. 4904. ~~~ Brian E. Rabena Date: q 1'1/0' 3 ~ AJ ~ ~ fi '1 .() "-> ~. ~ v "-' ~ :U ~ ~ p:: ~ ~ '------<~ r c,) (:l 8 -',., 1" ._;] r~ !...) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRIAN E. RABENA Plaintiff No, 03-4822 Civil Term vs. CYNTHIA A. RABENA Defendant In Divorce MOTION FOR CHANGE OF VENUE Comes now, the Defendant, Cynthia A. Rabena, by and through her attorneys, Blakey, Yost, Bupp & Rausch, LLP, and presents this Motion for Change of Venue, whereof the fol1owing is a statement: 1. Petitioner herein is the Defendant in the above Divorce Action, 2. Respondent herein is the Plaintiff in the above Divorce Action, which was filed on September 14,2003, 3. Petitioner is a resident of York County, Pennsylvania. 4. The marital residence of the parties for the past] 1 years is located at 619 Ceejay Drive, Etters, York County, and the Petitioner continues to live in lhat residence. 5. There is presently an Action for Support pending In York County, docketed to No. 02090 SA 2003, which was filed on August 8, 2003, prior to the filing ofthe Divorce Complaint. 6. The real estate and personal property of the parties which will eventual1y be the subject of equitable distribution is located in York County. 7. The parties have a minor child who may be tht: subject of a custody action, which must be determined in York County, since she has never lived in Cumberland County. 8. It win be more convenient to the parties and witnesses to have this case heard in York County. 9. For the above reasons, York County would be the proper venue in which this action should be litigated. WHEREFORE, Petitioner requests your Honorable Court to transfer venue of the within case from Cumberland County to York County, Pennsylvania. Respectfully submitted, BLAKEY, YOST, BUPP & RAUSCH, LLP B~~ Supreme Ct. J.D. #18061 17 East Market Street York, Pennsylvania 1740 I Telephone (717) 845-3674 Fax No. (717) 854-7839 Counsel for Defendant VERlFICA nON I HEREBY VERIFY that the information set forth in the foregoing Motion for Change of Venue is true and correct to the best of my knowledge, information and belief. I understand that any false statements contained herein are subject to the penalti(:s of 18 Pa. C.S. 4904, relating to unsworn falsification to authorities. Date: YiAY. / Z 01. 0 () 3 ~~O,~~ Cynthia A. Rabena CERTIFICATE OF NON-CONCURRENCE Counsel for the Plaintiff, G. Patrick O'Connor, Esquire, does not concur with this Motion. BLAKEY, YOST, BUPP & RAUSCH, LLP By:00~ Donald B. Hoyt, Esquire Attorney for the Ddendant Dated: AI /2 ~(; 3 . / ' CERTIFICATE OF SERVIC~ I hereby certifY that I am this day causing a copy of the foregoing Motion for Change of Venue to be served on the following person in the manner indi<:ated: By First Class United States Mail on: G. Patrick O'Connor, Esquire 3105 Old Gettysburg Road Camp HilI, P A 17011-7208 BLAKEY, YOST, BUPP & RAUSCH, LLP Dated: 1~03 By: Norma M. Doll, Paralegal arket Street York,PA 17401 ,,~.?Qe~ e a ~ w ~ '-::. :~ -C1U1 ." -~.- -..... 52ft:' .;.-') ~"~ ...~. 'I-~ .~ I ."l? tiS,: w :y -<..~: ~.;:{o kCJ -0 ,': :tJ ~o ::x ,",,2~ 0 :::- Oi >>c ~ z :<. c:n -,I '\ D~4 2003 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRIAN E. RABENA Plaintiff No. 03-4822 Civil Term Ys. CYNTHIA A. RABENA Defendant In Divorce ORDER AND NOW, this S-r1J day of lli .-bYYL!A-f./l..'/ , 2003, upon consideration of Defendant's Motion for Change of Venue, hearing on the matter is set for the 6'X day of C"b /V1 I J ad:i;i ,/!fP.. 't, . at 9.' A-> I A . C L/ f h ~-7 2.Oe:r. -. uv /-r-.M.,m ourtRoomNo.--+--o t e Cumberland County Court House, Carlisle, Pennsylvania. BY THE COURT, ."J J. '1INV^l).,SNN3d JJ.NnOO O~.IVl>f:l8V'1n() S'l:Z ~;d S- JJQ 80 ^L"'lO,I'Yl~: "~::I ,'; :10 OV. 1.......[ ,............,'.,.: .' '.... 381:.::1CHJ:i"fj :j IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRIAN E. RABENA Plaintiff No. 03-4822 Civil Term vs. CYNTHIA A. RABENA Defendant In Divorce PETITION TO ATTACH EXBmITS TO MOTION To the Prothonotary: Please attach the within Exhibits to Defendant's Motion for Change of Venue. Respectfully submitted, BLAKEY, YOST, BUPP & RAUSCH, LLP BY:~ 0?onald B. yt, E quir Supreme Ct. l.D. # 61 Penny V. Ayers, Esquire Supreme Ct.1.D. #84751 17 East Market Street York, Pennsylvania 17401 Tdephone (717) 845-3674 Fax No. (717) 854-7839 Counsel for Defendant 1 CERTIFICATE OF SERVICE I hereby certifY that I am this day causing a copy of the foregoing Petition to Attach Exhibits to Motion to be served on the fol1owing person in the manner indicated: By First Class United States Mail and facsimile on: G. Patrick O'Connor, Esquire 3105 Old Gettysburg Road Camp Hi11, P A 17011-7208 Fax: (801) 457-4132 BLAKEY, YOST, BUPp & RAUSCH, LLP P Dated: J? 131/O?J By: 2 In the Court of Common Pleas of York County, Pennsylvania CYNTHIA ANN RABENA Plaintiff vs. ) Dock:: N umbe: ) ) PACSES CJse :-.Iumhe: ) ) Orh:: Scate ID Numb:: BRIAN EDWARD RABENA Defendant Comolaim for Suooon 1. Plaintiff resides at 619 Ceejay Drive Etters, PA 17319 York Coumy. . Plaintiffs Social Security Number is 179-50-5115 and date of birch is 11 / 2 6 /56 2. Defendant resides at E 0 BQx 751 Cgm~ H~ll E8 17001701" ~r 1'; r.~nastrep.t'Driv;. >~~rii"lp. EA L__~ Cumberland Coumy. Defendant's Social Security Number is 191-46-1862and date of birrh is 8112/56 " (a) Plaintiff and Defendam were married on May 19, 1979 ~. at NPow ("'llmhp-rl t=lnn . . PA- (b) Plaimiff and Defendam were separated on June 1, 2003 (c) Plaintiff and Defendant were divorced on N/A a[ <1 Plaintiff and Defendant are the parents of the following children: Name Birth Date Ag;e Born of [he Marriag;e ~ - Y = Yes. N = No " Joseph Rabena 07/15/84 Residence: 619 Deeiav Drive Etters. PA 17319 :~ Y , Residence: Julia Rabena 619 Ceeiav Drive Etters. . PA 173.1q. 12/16/88 1.L ..Y. - .~- - - -. Scr...it.:.:' TYPt: v. PACSES Case NuoJber: Residence: Residence: Residence: Rt:sidence: 5. Plaimiff seeks suPPOrt for rhe following persons: Plaintiff Julia Rabena, daughter 6. (a) Plaintiff 0 is @ is nO[ receiving public assistance in the amount of 5 per month for the sUPPOrt of: N/A (b) Plaintiff is receiving additional income in the amount of 5 1347 biweekPrllm: r em 10 men~ at West Shore School District 7. A previous sUPPOrt order was emered against the Defendant on aCtion at S for the suPPOrt of: N/A In an in [he amoull[ uf -. ..--.- . ~h_ "0 Service Type Page 2 of 3 Form 1N.o05 Worker 1D v, P.~CSES C;1',c,' .\illlllnC,T There 0 are 0 are no arrears in the amount of S --1:!./ A The order 0 has 0 has not been terminated. 8. Plaint'iff last received SUPpOrt from the Defendant in the amoum of $ 2,300.00 on 7/28/03 WHEREFORE, Plaintiff requests that an order be emered against Defendam and in favor of the Plaintiff and the aforementioned chiJd(ren) for reasonable SUppOrt and medical coverage. I verify that the statements made in this Complaint are true and Correct. I understand that false Statements herein are made. subject to penalties of 18 Pa. C.S. S 4904, relating to unsworn falsification [0 authorities. ~"~"-I1. ~--A! Plaintiff ' :\'OTICE Guideline~ for child and spousal suPPOrt. and for alimony pendente lite, have been prepared by the COUrt of Common Pleas and are available for inspection in the Office of the DOrT1e~[ic Relations Section: - , I Service Type P'ge3 00 Fnml IN-005 Worker ID F:',c, , "- ~ ~" : CGt-:::S(;i; r: SEei ;'~'i'j ''''1 J ,\ ~~ (- 'j ."U " , , : ...:i I, ";1 ,- In the Court of Common Pleas of YORK County, Pennsylvania DOMESTIC RELATIONS SECTION CYNTHIA A. RABENA ) Docket Number 02090 SA 2003 Plaintiff ) vs. ) PACSES Case Number 869105704 BRIAN E. RABENA ) Defendant ) Other State ID Number ORDER OF COURT - RESCHEDULE A CONFERENCE You, CYNTHIA A. RABENA plaintiff/~t of 619 CEEJAY DR, ETTERS, PA. 17319-8922-19 are ordered to appear at YORK COUNTY DOMESTIC RELATIONS 100 W. MARKET ST., SUITE 101, YORK, PA. 17401 before a conference officer of the Domestic Relations Section, on the 17TH DAY OF FEBRUARY, 2004 at 1: OOPM for a conference, after which the conference officer may recommend that an order be entered. This date replaces the prior conference date of NOVEMBER 14, 2003 You are further required to bring to the conference: I. a true copy of your most recent Federal Income Tax Return, including W-Zs, as filed, 2. your pay stubs for the preceding six (6) months, 3. the Income and Expense Statement attached to this order as required by Rule 1910.11 ( c). 4. verification of child care expenses, and 5. proof of medical coverage which you may have, or may have available to you 6. infonnation relating to professiona1licenses 7. other: Conference Officer 1s Christine D. Allen DRO# 80609 PC: Atty. Donald B. Hovt Service Type M Form CM.$13 WotkerID 67609 RABENA V. RABENA PACSES Case Nwnber: 869105704 If you fail to appear for the conferencelhearing or to bring the required documents, the court may issue a warrant for your arrest or enter an order in your absence. If paternity is an issue, the court may enter an order establishing paternity. The appropriate court officer may enter an order against either party based upon the evidence presented without regard to which party initiated the support action. BY THE COURT: Date of Order: NOVEMBER 13, 2003 PER CURIAM JUDGE YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND REPRESENT YOU. 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 MAY GET LEGAL HELP: LAWYER REFERRAL SERVICE YORK COUNTY BAR ASSOC 137 E MARKET ST YORK PA 17401-1221-37 (717) 854-8755 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of YORK County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office at: (717) 771-9605. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference. Service Type M Form CM_513 Worker lD 67609 IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYL VANIA CIVIL ACTION - LAW CYNTHIA ANN RABENA Petitioner No.2003-SU_ () 3"'~:J ~()Y Ys. BRIAN EDWARD RABENA Respondent PETITION FOR EMERGENCY RELIEF 1. Petitioner is Cynthia Ann Rabena, residing at 619 Ceejay Drive, Etters, York County, Pennsylvania 17319. 2. Respondent is Brian Edward Rabena, residing at P. O. Box 751, Camp Hi1!, Cumberland County, Pennsylvania 17001. 3. The parties are the parents of two children, Joseph Rabena, age 19, and Julia Rabena, age 14. 4. The parties' son, Joseph Rabena graduated high school in June, 2003, and applied for acceptance at Shippensburg Col1ege. 5. Joseph Rabena was advised by the col1ege that his application has been accepted. 6. The Respondent moved from the marital residence on June 1,2003, without making any provision for payment of support or for his son's education at Shippensburg Col1ege. 7. Petitioner is without the funds necessary to pay for her son's college education. 8. Petitioner has contacted the college regarding financial aid for her son and was informed that in order to process any application for financial aid they would require a copy of the parties' most recent Federal Tax Return. 7. Respondent prepared the 2002 tax return and did not give a copy of the filed return to the Petitioner. 8. Petitioner has been unable to convince Respondent to supply the tax return or to copy it, and the deadline for tuition payment is August 15th. WHEREFORE, Petitioner requests your Honorable Court to issue an Order on the Respondent to provide Petitioner with a copy of the parties~ joint Federal Tax Return for the year 2002. Respectfully submitted, BLAKEY, YOST, BUPP & RAUSCH, LLP ~' y: 7~ " naldB. oyt,~e Counsel for Petitioner 17 East Market Street York,PA 17401 (717) 845-3674 Supreme Ct. LD. #18061 VERIFICATION 1 verify that the foregoing facts are true, upon my personal knowledge or information and belief. This verification is made subject to the penalties of 18 Pa. C.S. 94904 relating to unsworn falsification to authorities. Dated: tf;l;jo_"'> . ~~~ Cynthia Ann Rabena CERTIFICATION OF NOTICE 1, Donald B. Hoyt, Esquire, attomey for the Petitioner, hereby certifY that more than seventy-two (72) hours advance notice was given to all parties listed on the Certificate of Service as to the presentation of the Petition for Emergency Relief at current business. BLAKEY, YOST, BUPP & RAUSCH, LLP .Q~~ Donald B. Hoyt, E q re S. Ct. LD. #18061 17 East Market Street York,PA 17401 Telephone (717) 845-3674 Fax No. (717) 854-7839 Dated: tit, /0.3 I ' CERTIFICATE OF SERVICE I hereby certify that I have this day caused as copy of the Petition for Emergency Relief to be served on the Respondent by First Class United States Mail, postage prepaid as follows: Brian Edward Rabena P. O. Box 751 Camp Hill, PA 17001 and Brian Edward Rabena 19 Longstreet Drive Carlisle, P A 17013 t1~ ,1 Copy of the Petition was also delivered by fax transmission ~e to the Respondent at (717) 761-5308 Dated: August 12,2003 BLAKEY, YOST, BUPP & RAUSCH, LLP By ~_.~. dJ..., ;Norma M. Doll, p gal/ ~. arket Street York, Pennsylvania 17401 Telephone (717) 845-3674 -----. IN THE COURT OF COMMON PLEAS OF YORK COUNTY, PENNSYLV ANlA CIVIL ACTION - LAW CYNTHIA ANN RABENA o ';'; W -n g en n ,~ ~;:O m """J("") co :~r'l1 ,~< .."" .0 Petitioner ,::-'} _ ::v) -~,- s:~~) ~~ ;~ p ::x a ., No.2003-SU-03753-08 ~ Ys. BRIAN EDWARD RABENA Respondent - r.) MOTION TO WITHDRAW PETITION FOR EMERGENCY RELIEF AND REMOVE CASE FROM BUSINESS COURT LIST 1. Petitioner is Cynthia Ann Rabena, residing at 619 Ceejay Drive, Etters, York County, Pennsylvania 17319. 2. Respondent is Brian Edward Rabena, residing at P. O. Box 751, Camp Hill, Cumberland County, Pennsylvania 1700 I, 3. On August 12,2003, a Petition for Emergency Relief was filed in the above action, and listed for presentation at Business Court before Judge Gregory M. Snyder on Monday, August 18th. 4. The Petition requested an Order directing the Respondent to furnish a copy of the parties' 2002 Federal Tax Return which was necessary for their son to receive funding for his 2003/2004 term at Shippensburg College. 5. Petitioner was able to obtain a transcript of that Return from the Internal Revenue Service. 6. The said transcript will suffice for the purpose of college admittance. WHEREFORE, Petitioner requests your Honorable Court to issue an Order granting Petitioner's Motion to withdraw her Petition for Emergency Relief and remove the case from the Business Court list. Respectfully submitted, BLAKEY, YOST, BUPP & RAUSCH, LLP B~~ Donald B. Hoyt, squire Counsel for Petitioner 17 East Market Street York,PA 17401 (717) 845-3674 Supreme Ct. LD. #18061 . VERIFICATION I, Donald B. Hoyt, Esquire, do hereby verify that I am the attorney of record for the Plaintiffs herein, and that the facts set forth in the foregoing pleading are true to the best of my knowledge, information and belief, upon information supplied by the Petitioner. I am making this verification on behalf of my client because her verification cannot be obtained within the time for filing this pleading. I understand that false statements made herein are made subject to the penalties of 18 Pa. C.S-^. 14904 reWing" _om "'.ifi"tioo" '"~ Donald B. Hoyt, Esquire Dated: August 18,2003 CERTI~CATEOFSERVICE 1 hereby certify that I have this day caused as copy of the foregoing Motion to be served on the Respondent by First Class United States Mail, postage prepaid as follows: Brian Edward Rabena P. O. Box 751 Camp Hill, PAl 700 1 and Brian Edward Rabena 19 Longstreet Drive Carlisle, PA 17013 Copy of the Petition was also delivered by fax transmission this date to the Respondent at (717) 761-5308 Dated: August 18, 2003 ::~~~~us~: NoIina~lI, p~ I i'rEiiSt Market Street York, Pennsylvania 17401 Telephone (717) 845-3674 .I - ~ 6703. ~ a~5 . ********************************************************************** ESTATE NAME: Betty R. Rabena a/k/a Betty Romaine Rabens Warrington Twp. BRADLEY C. JACOBS, REGISTER OF WILLS and CLERK OF ORPHANS' COURT 0.0.0. 2/15/03 TWP. I BORO : DOCUMENT INITIALS I FILED FILE NO. DOCUMENT INITIALS I FILED FILE NO. Certificate of Notice Y 2/24/03 2/28/03 ,,&'1 ~ Pet. Ltrs. Testament Last Will & Testamen ax Recei t 5/8/03 (,.C{,'b &'1. 023090110'078 REV-1162 EXt11-961 COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF REVENue BU"EA\J OF INDIVIDUAL TAXES DEPT. 280601 ~ HARRISBURG, PI>. 17,:j:a.0601 ~. I' ... , RECEIVED FROM: PENNSYLVANIA INHERITANCE AND ESTATE TAX OFFICIAL RECEIPT NO. YK 004942 MYERS ROBERT E 100 YORK RD NEW CUMBERLAND, PA 17070 ACN ASSESSMENT CONTROL NUMBER AMOUNT ESTATE INFORMATION: SSN: 161-20-0228 FILE NUMBER: 6703-0285 DECEDENT NAME: RABENA BETTY R DATE OF PAYMENT: 05/08/2003 POSTMARK DATE: 05/08/2003 . COUNTY: YORK DATE OF DEATH: 02/15/2003 101 I $12,183.75 I I I I I I I I -.--- fold TOTAL AMOUNT PAID: $12,183.75 REMARKS: ROBERT E MYERS ESQUIRE CHECK# 1014 INITIALS: CAI RECEIVED BY: BRADLEY C JACOBS REGISTER OF WILLS SEAL REGISTER OF WILLS __ ._..__...._._ _..__ _____..__..__ ________________________ .._..._.,.___. __ _.~ _ _"___'___ _ __,__ __..._.. __ .__.~.._.,...._,_._c...-_.-....-..--.-,....- ._...._,._.. _,_,._._..._,_._m_ ._..____d_.'_.__ , ..~ - ~. ~ CERTIFICATION OF NOTICE ~~ER RULE S5.6(a) Name of DecedeTIt: Betty R. Rabena, a/k/a Betty Romaine Rabena Date of Death: 2-15-03 will No. 6703-00285 To the Register: I cerrtify that notice of beneficial interest required by Rule 5.6 (a) of the Orphans Court was served on or mailed to the fc!lowing beneficiaries of the above captioned estate of Betty R. Rabena, a/k/a Betty Romaine Rabena Name: Brian E. Rabena Address: 619 Cae Jay Drive, Etters, PA 17319 Karen B. Miller 17339 463 Old Stage Rd., Lewisberry,PA Notice has now been Rule 5.6(a) except: None given to all persons entitled thereto under Date: -;;1..,;t(.,.-03 ~ si ature Name: Robert E. Myers Address: 100 York Road New Cumberland, PA 17070 Telephone No. 717-774-3163 x Personal Representative Counsel for Personal Representative Capacity: Vd "' "'0' -"c,c'1J" "n,n'J' . "" i1u 1\ .:l':',i..n..1-0 IL- bE :\\ 'if ! 8Z 93.:1 EnOl 023090 110m l-'llP 1'0-""] 1 C';',"i'J'! S IjJ~\ .:P (J...d. ,~11 J -;'" ,", ;." , ,-~ ,... -;"~..f , , .. . ~ ., . .. . () ....., ~ <=> c <= <:"" ...., -;) i~;J c::> ...... ITlr"n 1"'1 rn:n ;(7.1 n , 71'"'" -/"")m ~~~jf:,~ (.0> :iJt;:> ~,':.~' ;~- . 8() -U I=R ...'0' f-':~'(:5 ::-~: !'.J C),'i1 :;;1 I (," :q -< 0) ~, BRIAN E, RABENA, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW 03-4822 CIVIL IN DIVORCE CYNTHIA A. RABENA, Defendant IN RE: MOTION FOR CHANGE OF VENUE ORDER AND NOW, this '" day of January, 2004, following argument thereon, the motion of the defendant for change of venue is DENIED. BY THE COURT, vI>enny V. Ayers, Esquire For the Defendant - ./ ~ ~ Ol-O'?,-O~ .A~ /(}. Patrick O'Connor, Esquire For the Plaintiff :r\m V';t\j~;'>\1;\S>~~,J3d 11~1'~"V'-'."""-'''nl''\ 1\..\.1 ii :l).i !' ,.:. '.., "::,-Hhi V 92 :2 I~d L - NVr ~noz J,:'tlII'iNO:"!lO'''d ::JHl ~o ''-'''.'..'-' j ti::ll .... 30IHr0311:J IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRIAN E. RABENA, Plaintiff NO. 03-4822 CIVIL TERM vs. CIVIL ACTION - LAW CYNTHlAA. RABENA, Defendant IN DIVORCE AFFIDAVIT OF SERVICE BY MAIL PURSUANT TO PA. R. CIY.P. 1920.4 G. Patrick O'Connor, Esquire, being duly sworn according to law, deposes and says that he mailed a copy of the Complaint in Divorce filed in this matter by certified mail, return receipt requested, addressee only, to the Defendant at 619 Ceejay Drive, Etters, PA 17319. The return receipt signed by the Defendant is evidence of delivery to him and is attached as Exhibit "A". Patrick O'Connor, Esquire LD. No. 64720 3105 Old Gettysburg Road Camp HiIl, PA 17011 Phone 717-737-7760 Attorney for Plaintiff If "" K~, 2.__ ~ ~ 7002 04bO 0000 97b1 8220 ~. - 1 ~ 1111 JI )J/v. T --- .--- _..._..~-,-----_.~--~---_.-.~_.- 'r lit'... EXHIBIT" A" Q .... ~ = c. = s:: "" ~:!J ".. -0 (f] c:: mfr. G"> ~~ Z~T.' ~~,:_" 0"\ ,<:1....' ".. ~-n 2?:c ::z: o~ .z:c 6 5>C' - ~ Z .- ~ s:- .0 '< IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRIAN E. RABENA, Plaintiff NO. 03-4822 CIVIL TERM vs. CIVIL ACTION - LAW CYNTHIA A. RABENA, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 12, 2003, and service completed on September 27, 2003. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the dates 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. Section 4904 relating to unsworn falsification to authorities. DATE: f'j/ /J~ L~ Brian E. Rabena, Plaintiff E ~. -0...,' mr' z,:!. zr UJ. J" ""';c 12.' ')">C", Zb yc: ~ ~ ~ ~ c-> ~ ~jg ~~ ~:d %~ ::::\ s:- ~ u:> - c:1' ~ - - .' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRIAN E. RABENA, Plaintiff NO. 03-4822 CIVIL TERM vs. CIVIL ACTION - LAW CYNTHIA A. RABENA, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE I. 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! 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 the foregoing 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 unsworn falsification to authorities. DATE: &>;/1 ft~ (') c: -? S. "\Jcr: md~ ~{!c' U) ~1. :-0- (~ ';Zt"J "PC: ~ ,...., ~ d' ~ G> ~ ~:'J - ~~ Cf' ::c S'?, (:)::tl ~ z?f. :::: ~ ;. ~ v:> IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRIAN E. RABENA, Plaintiff NO. 03-4822 CIVIL TERM vs. CIVIL ACTION - LAW CYNTHIA A. RABENA, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 12,2003, and service completed on September 27,2003. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the dates 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. Section 4904 relating to unsworn falsification to authorities. DATE: f/7/o6 . ~()~ Cynthia A. Rabena, Defendant (') ...., = 0 c = TI -- <:7' ~... ". ~ "Um rJ:.tfT c:: nl::!J ...::,.,_1 G") r- 2~ [HO "U~ (0 ~~ ~ -<....: 0"\ :;:J. i<t; ~E'; > ,'- -d ::!l: 'J- z~ PC: O. Z ~ ~ .- \D -< IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRIAN E. RABENA, Plaintiff NO. 03-4822 CIVIL TERM vs. CIVIL ACTION - LAW CYNTHIA A. RABENA, Defendant iN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE I. 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! 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 the foregoing 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 unsworn falsification to authorities. DATE: rP/7fit ~a~ Cynthia A. Rabena, Defendant o c. s:: -ocv n'lt'T" 7'.J ~~;:::~ r" <: b~ ;;-=("', )>c: Z ::.2 ...., :s ..,.. t; ...., ~ ~~ ~~ 0" '~::r4 05 ~ 2m := ~ ;. ~ U3 MARITAL SETTLEMENT AGREEMENT THIS AGREEMENT, made this ~ day of a-a J. A I' 2006, by and between CYNTmA A. RABENA hereinafter referred to as ife", and BRIAN E. RABENA, hereinafter referred to as "Husband", both of York County, Pennsylvania. WITNESSETH: WHEREAS, Husband and Wife are lawfuUy married, but differences have arisen between them in consequence of which they are living separate and apart; and WHEREAS, two children were born as the result of this marriage, to wit, Joseph A. Rabena, born July 15, 1984, and Julia C. Rabena, born December 16, 1988; and WHEREAS, Husband and Wife desire to settle and determine finaUy and for all time their mutual rights with respect to money and property; and WHEREAS, Husband and Wife have reached an agreement with respect to all marital assets, obligations or responsibilities as hereinafter set forth; and WHEREAS, Husband and Wife each acknowledge that he or she is fuUy cognizant of the assets, the value of said assets, the liabilities and the general financial condition of the parties jointly and of each other individually, and both parties are of full and complete understanding that they have the right to seek the advice of separate legal counsel with respect to this Agreement. NOW, THEREFORE, the parties intending to be legally bound hereby do covenant and agree as follows: I. WAIVER OF STATUTORY RlGHTS. Both parties hereby waive and relinquish any and aU rights they each may have to spousal support, alimony pendente lite, alimony, counsel fees, costs and expenses, from now until the end of time, except as specifically set forth herein. The parties each acknowledge that they are fuUy aware of the income, earning capacities and separate assets of the other, and that the waiver made herein is made freely and voluntarily with full knowledge ofthe consequences thereof. C#- [1;1 2. ALIMONY. Husband and wife mutually waive any present or future right to alimony. 3. RIGHT TO COUNSEL. This Agreement was prepared by Donald B. Hoyt, Esquire, as attorney for Wife. Husband is represented in this matter by G. Patrick O'Connor, Esquire. 4. DISTRIBUTION OF MARITAL ASSETS. A. Wife shall receive or retain sole and exclusive right and title to the following items of property: a. The 2004 Kia Optima automobile. b. All retirement, pension, IRA, and 40 I (k) plans titled in her name. e. All real estate titled in her name, individual1y or jointly with someone other than Husband. d. All financial accounts titled in her name, individually or jointly with someone other than Husband. e. All marital household furnishings and other personal property as previously mutual1y divided by the parties. B. Husband shal1 receive or retain sole and exclusive right and title to the following items of property: a. The 1987 Chevrolet Blazer vehicle. b. The 1998 26' Crownline Boat. c. His father's burial flag and presentation case. d. All retirement, pension, IRA, and 401(k) plans titled in his name. e. All financial accounts titled in his name, individual1y or jointly with someone other than Wife. 2 C4t2- ~rt f. All real estate titled in his name, individually or jointly with someone other than Wife. g. All marital household furnishings and other personal property as previously mutually divided by the parties. Within ten days of the execution of this Agreement, Wife will execute all documents necessary to transfer title to the Crownline Boat to Husband. All payments on the boat including, but not limited to, installment payments, maintenance, licensing, etc., shall be the sole obligation of Husband. 5. DEBTS. The parties have mutually agreed as to the obligation of each with regard to any outstanding debts of the parties either jointly or individually. All payments on the 1998 Crownline Boat shall be the sole obligation of Husband. Each party shall defend, hold harmless and indemnify the other for any payment, collection or other enforcement action regarding all debts for which he or she is individually and exclusively obligated. 6. MEDICAL INSURANCE COVERAGE. Husband and Wife will each maintain separate insurance coverage for their own use as each may see fit, with full power of disposition as ifhe or she were not married. Wife shall continue to provide medical insurance coverage for Julia Rabena unless said medical insurance becomes unavailable due to a change of employment or other circumstance. In the event that Wife should no longer be able to provide medical coverage for Julia through her employer, Husband shall provide medical coverage through his employment as long as Julia remains eligible to be covered under the terms of Husband's policy. While Julia remains covered under the policy of either Husband or Wife, Husband and Wife agree to share equally the out-of-pocket costs for Julia's health care, including co- pays and deductibles. C4fz dtt 3 7. PURCHASE OF CAR/CAR INSURANCE FOR JULIA RABENA. When Julia Rabena has obtained a learner's permit and is added as an occasional driver on Wife's car insurance policy, Husband will pay fifty percent (50"10) of the extra cost of covering Julia on Wife's insurance policy, as long as Julia continues to have the status of occasional operator on Wife's insurance policy. At such time as Julia becomes either a principal operator or reaches the age of nineteen (19) years, whichever occurs first, Husband will pay twenty-five percent (25%) of Julia's automobile insurance premium until such time as Julia attains the age of twenty (20) years. 8. ADDITIONAL CHILD SUPPORT. Commencing from the time that Julia Rabena graduates from high school, Husband shall pay support for Julia at the rate of three hundred dollars ($300) per month until Julia attains the age of twenty (20) years. In the event that Julia discontinues living with wife, Husband's obligation to make said payments shall also be discontinued. 9. CHILDREN'S EDUCATION EXPENSE. Husband will contribute $1,000 to Joseph's education expenses to fulfill his undergraduate degree during his senior year at Shippensburg University. After the fall of 2007, if Julia chooses to pursue higher education, Husband will pay one-half of the cost of tuition, room and board, books and supplies, remaining after available grants, loans made by Julia, aid and Julia's income have been applied. This contribution will continue until Julia reaches the age of 22 years in June, 20 II. 10. BREACH. A. If either party breaches any provision of this Agreement, the other shall have the right, at his or her election, either to sue for specific performance of this Agreement or to sue for damages premised upon said breach. In such proceedings, the only issue shall be whether one or both of the parties has breached the Agreement and in no event shall either Husband or Wife, their attorneys or legal representatives, have the right to question any of the provisions of this Agreement. 041e- 8ft 4 B. In the event that either party must bring an action based upon the breach of the other for any of the terms and conditions of this Agreement, the party having so breached the Agreement (the responsibility for breaching the Agreement to be determined by a Court of competent jurisdiction), agrees to be responsible not only for the damages sustained by the non-breaching party, but also to reimburse the non-breaching party for any and all attorney's fees and Court costs incurred because of the breach of this Agreement. 11. DATE OF EXECUTION. The "date of execution" or "execution date" of this Agreement shall be defmed as the date upon which it is executed by the parties if they have executed this Agreement on the same date. Otherwise, the "date of execution" or "execution date" of this Agreement shall be defined as the date of execution by the party last executing this Agreement. 12. W AlVER OF OTHER ECONOMIC RIGHTS. Except as herein otherwise provided, each party may dispose of his or her property in any way, and each party hereby waives and relinquishes any and all rights he or she may have or hereafter acquire, under the present or future laws of any jurisdiction to share in the property or estate of the other as a result of the marital relationship, including without limitation dower, thirds, curtesy, equitable distribution, allowance, widow's al1owance, homestead rights, right to take in intestacy, right to take against the wil1 of the other, and right to act as administrator or executor of the other's estate, and each party will at the request of the other execute, acknowledge and deliver any and al1 instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of an such interests, rights and claims. Each of the parties hereto by these presents, for himself, herself, his or her heirs, executors, administrators or assigns, does remise, release, quitclaim and forever discharge the other party hereto, his or her heirs, executors, administrators or assigns, or any of them of any and all claims, demands, damages, actions, causes of action, or suits at law or in equity, of whatever kind or nature, for or because of any matter or thing done, omitted or suffered to be done by said other party prior to and including the date hereof; except that Husband or Wife may entertain now or at a later date. 13. ADDITIONAL INSTRUMENTS. Each of the parties shan, from time to time, at the request of the other, execute, acknowledge and deliver to the other party any and an instruments that may be reasonably required to give full force and effect to the provisions of this Agreement. 5 G4tL If!- 14. VOLUNTARY EXECUTION. The provisions of this Agreement and their legal effect have been frilly explained to the parties by their respective counsel, and each party acknowledges ~ this Agreement is fair and equitable, that it is being entered into voluntarily, and that it is not the result of any duress or undue influence. 15. ENTIRE AGREEMENT. The parties do hereby covenant and warrant that this Agreement contains all of the representations, promises and agreements made by either of them to the other for the purposes set forth hereinabove; that there are no claims, promises or representations not herein contained, either oral or written and signed by both of the parties hereto. 16. MODIFICATION AND WAIVER. A modification or waiver of any of the provisions of this Agreement shall be effective only if made in writing and executed with the same formality as this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall not be construed as a waiver of any subsequent default of the same or similar nature. 17. DlSCHARGEABILlTY OF OBLIGATIONS IN BANKRUPTCY. The obligations and duties of the parties under this Agreement, including the provisions relative to property distribution, payment of marital debts and/or payment of counsel fees, costs and expenses of this litigation, as applicable, shall not be dischargeable in any bankruptcy proceedings. 18. ACKNOWLEDGMENT. Each party to this Agreement acknowledges and declares that he or she respectively: A. is fully and completely informed as to the facts relating to the subject mailer of this Agreement and as to the rights and liabilities of both parties; B. enters into this Agreement voluntarily and intelligently after receiving the advice of independent counsel, or after having had the opportunity to seek the advice of independent counsel, or after having been fully notified of the advisability of seeking the advice of independent counsel, free from fraud, duress, undue influence, or coercion of any kind; C. has given careful and mature thought to the making of this Agreement; 6 C41z.- IJ{L D. has carefully read each provision of this Agreement; B. fully and completely understands each provision of this Agreement; F. agrees that the provisions of this Agreement are fair, adequate, equitable and satisfactory and executed by both parties in, as and for final settlement and satisfaction of all claims and demands of any nature whatsoever, and after a full and fair disclosure by the parties of all facts bearing upon and pertaining to the provisions of this Agreement, including the parties' assets, incomes and net worth; G. agrees that in the event he or she were to breach any portion of this Agreement that the party so aggrieved may bring suit in contempt against him or her and the party, if successful in proving such breach, shall be entitled to the payment of counsel fees andlor court costs as deemed appropriate by the Court upon judgment. 19. SEVERABILITY. If any term, condition, clause 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 obligations under anyone or more of the paragraphs herein, with the exception of the satisfaction of the conditions precedent, shall in no way void or alter the remaining obligations of the parties. 20. INCORPORATION. In the event that an action for divorce is instituted or consummated at any time hereafter by either party against the other in this or any other jurisdiction, the parties agree that they shall be bound by all of the terms of this Agreement and that this Agreement shall not be merged in any decree or judgment that may be granted in such action, but shall survive the same and shall be forever binding and conclusive on the parties, their heirs, executors and assigns, unless specified otherwise herein. However, nothing herein shall be construed to prevent the decree of divorce in such action from incorporating in full or in substance the terms of this Agreement. 21. LAW OF PENNSYLVANIA APPLICABLE. This Agreement shall be construed in accordance with the laws of the Commonwealth of Pennsylvania as they exist at the date of the execution of this Agreement. 7 C4t IJfL IN WITNESS WHEREOF, the parties have hereunto executed this Agreement the day and year first above written. Witness: &:O&e- ~~ ~'O.~ Cynthia A. Rabena ~a Brian E. Rabena / 8 . COMMONWEALTH OF PENNSYLVANIA) : SS. COUNTY OF YORK ) On this, the ~ day ~jff. 2006, before me, a Notary Public in and for the state and county aforesaid, the dersigned officer, personally appeared CYNTHIA A. RABENA, known to me (or satisfactorily proven) to be the person described in the foregoing instrument, and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. COMMONWEALTH 0"" ANIA NOTARIAL SEAL ILEEN S. KRONE. Notary Public City of YorI<. YorI< County M Commission Expires March 28, 2009 l%JiI.Jfm ) Notary Pu c (SEAL) COMMONWEALTH OF PENNSYLVANIA) : SS. COUNTY OF CUMBERLAND ) On this, the z7#V day of ~~, 2006, before me, a Notary Public in and for the state and county aforesaid, the un ersigned officer, personally appeared BRIAN E. RABENA, known to me (or satisfactorily proven) to be the person described in the foregoing instrument, and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. NOTARIAL SEAL G. Palrick O'Connor, Notary Public Lower Allen Twp., Cumberland County My commission expires October 28, 2007 " ) "... IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRIAN E. RABENA, Plaintiff NO. 03-4822 vs. CIVIL ACTION - LAW CYNTHIAA. RABENA, Defendant IN DIVORCE PRAECIPE TO TRANSMIT THE RECORD Grounds for divorce: ./ Section 3301(c) of the Divorce Code Section 3301(d) of the Divorce Code (a) Date complaint filed: 9/12/03 (b) Date of service of the complaint: 9/23/03 (c) If service 30 days after date of filing, date complaint reinstated: (d) Manner of service of the complaint: ./ Certified mail, restricted delivery to and return receipt signed by defendant First-class mail-not returned, certified mail refused, 15 days have elapsed Date of mailing: Date certified mail refused: Personal service by Sheriff andlor Deputy Sheriff Personal service by competent adult other than Sheriff (Affidavit attached) Acceptance of service (Copy attached) By publication pursuant to Order of Court (Copy of Order attached) , ' . , ... (a) Affidavit of consent required by Section 3301(c) of the Divorce Code: Date of execution: plaintiff: 8/1106 defendant: 817106 Date of filing: plaintiff: contemporarilv herewith defendant: contemporarilv herewith (b) Plaintiff's affisdavit required by Section 3301(d) of the Divorce Code: Date of execution: Date of filing: Date of service upon defendant: Manner of service: Related claims pending: (a) Date of service of the notice of intention to file praecipe to transmit, a copy of which is attached: Manner of service: (b) Date waiver of notice to file praecipe to transmit was filed with the Prothonotary: By plaintiff: contemporarilv herewith By defendant: contemporarilv herewith VERIFICATION I verifY that the statements made in this praecipe 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: 8'}'i/()!;' 0. Patrick O'Connor, Esquire Attorney for Plaintiff '2 -~ '" -0 l"f' ('f1rT' '-7 '.T_ ~\~,:._: -S"', l/C> ~:P ,'" ';;;C' 7C ~ ,r . ~ ~ ~ '" ~ ~~ a; a~ ~4"i _~-t"I ~ ~~ ::;. g ;. ~ ..t:) .' . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ... :+.:f.:f.:f. :+. :+.:+. <+' :+.:+::+::+: ;+;~:+.:+.+.:+.:+.:+.:+.+.:+. +:+.;+:+~+++ . . . . . . . . . . . . . . . . .. .. :+.+.:t::+. :+.+.+ :+. .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PEN NA. BRIAN E. RABENA No. 03-4822 CIVIL Plaintiff VERSUS CYNTHIA A. RABENA Defendant DECREE IN DIVORCE AND NOW, (2.utvnr I ZOO... IT IS ORDERED AND :i<- Y. DECREED THAT BRIAN E. RABENA , PLAI NTI FF, CYNTHIA A. RABENA , DEFENDANT, AND 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; None. The Marital Settlement Agreement entered into by the parties on August 9, 2006 shall be incorporated but not merged into this decree. By THE OURT: PROTHONOTARY Of:+. '*':+:t' 'i':+ 'I' . +' +' +' Of :+. ~:+:+:+.+ ++ +++++.:+.:+? . :+.:+.:+.:+. Of 'Ii:+' Of. 'f Of '+;!' '+ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J. . . . . . . . . . . . . . . . . . . . . . . . ~Jr 1~ ~ 10. ~' ~ c? fr ~ I'll' 16, f"J '1'1 ~ b . . .. .' --~- "