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HomeMy WebLinkAbout01-4706AUDREY J. FINGERHOOD, Plaintiff VS. ELLIOTT FINGERHOOD, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2001- 4/?Ok CIVIL TERM : CiVIL ACTION - LAW : 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 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 marriage, you must request marriage counseling. A list of marriage counselors is avail- able in the Office of the Prothonotary at CUMBERLAND COUNTY COURTHOUSE 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 HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA ,l,7013 MAX~J). ~I~l ~uire" Attorney for Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 AUDREY J. FINGERHOOD, Plaintiff VS. ELLIOTT FINGERHOOD, Defendant 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001- qTO& ClVm TERM CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE AND NOW comes the Plaintiff, AUDREY J. FINGERHOOD, by her attorney, MAX J. SMITH, JR., Esquire, and seeks to obtain a Decree in Divorce upon the grounds hereinafter more fully set forth: 1. The Plaintiff, AUDREY J. FINGERHOOD, is an adult individual and citizen of the United States of America, who resides at 618 Allenview Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. The Defendant, ELLIOTT FINGERHOOD, is an adult individual and citizen of the United States of America, who resides at 618 Allenview Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on or about May 13, 2000, in Duncaunon, Pennsylvania. 5. Plaintiff avers that there are no children of the parties under the age of 18. Services. Neither Plaintiff nor Defendant is a member of the United States Armed 7. Plaintiff and Defendant have both been advised of the availability of marital counseling and that each may have the right to request that the court require the parties to participate in counseling. 8. Plaintiff avers that there has been no prior action for divorce or annulment of the marriage filed by either party in this or any other jurisdiction. 9. Plaintiff avers that the marriage is irretrievably broken. WHEREFORE, Plaintiff prays your Honorable Court to enter a Decree of Divorce from the bonds of matrimony. Dated: August 7, 2001 A~X~J!S~/M~ M quire James, Smith, Durkin & Connelly ~ P.O. Box 650 Hershey, PA 17033 (717) 533-3280 I verify that the statements made in this Complaint are true and correct. I under- stand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. .%'4 Cumberland VFrAL RECORDS RECORD OF I DIVORCE OR 'ANN ENT [] (CHECK ONE) U~M STATE RLENUMBER STATE F}LE DATE HUSBAND Elliott Fin~erhood BlaH 06 20 1942 618 Allenview Drive, Mechanicsburg, Cumberland, OF Pennsylvania OF THIS WHITE BLACK O~ER (S~i~) Log i S t i C S MARRIAGE 3 ~ [] [] Management WIFE 8. MAIDEN NAME (Fkst) (Middle) (Last) 9. DATE (MonA) Travitz Audrey J. Fingerhood OF B.RT. 04 618 Allenview Drive, Mechanicsburg, Cumberland, PA B?~. 12 1942 Pennsylvania 12. NUMBER ~3. RACE 14. USUAL OCCUPATION OF THIS ! WHITE BLACK OTHER (S~O~) A S S t. A c t i V i t i e s MARRIAGE 3 [] [] ~ D i r e c t o r 15. PLACE OF (County) (State o;Fo~eEln Country) ]6. DATE OF (MO~H1) (Day) (Year) "~RR.^GE Perry Pennsylvania t TH,s MA~R,^GE 05 13 2000 I?A. NUMBER OF I7B' NUMBER OF DEPENDENT ' HUBB WIFE OTHER (Spec~y) OTHER (S~eci~) CHILDREN THiS CHIkDRSN UNDER 18, lS PLAINTIFF 9. DECREE GRANTE~ TO CUSTO~¥OF N/A [] [] [] [] Irretrievable breakdown AUDREY J. FINGERHOOD, Plaintiff ELLIOTT FINGERHOOD, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2001-4706 : : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF COUNSELING 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on August 8, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken, .and ninety days have elapsed since the date of filing and service of the Complaint. 3. I consent to the entry of a Final Decree of Divorce after service of notice of intention to request entry of the decree. 4. I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling. I further understand that the Court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a decree being handed down by the Court. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relat'mg to unswom falsification to authorities. Date: Nov. 9t 2001 AUDREY J. FINGERHOOD, Plaintiff ELLIOTT FINGERHOOD, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2001-4706 : : CIVIL ACTION - LAW : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(C) OF THE DIVORCE CODE i. I consent to the entry of a Final Decree of Divorce without further 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 dntered 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 tme 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: AUDREY J. FINGERHOOD, Plaintiff ELLIOTT FINGERHOOD, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001-4706 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF COUNSELING 1. A Complaint in Divorce under Section 3301(c) of the Divome Code was filed on August 8, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken, and ninety days have elapsed since the date of filing and service of the Complaint. 3. I consent to the entry of a Final Decree of Divorce after service of notice of intention to request entry of the decree. 4. I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling. I further understand that the Court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a decree being handed down by the Court. I verify that the statements made in this Affidavit are tree 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. Dam: Nov. 9, 2001 ELUO-- qGERHOOD AUDREY J. FINGERHOOD, Plaintiff ELLIOTT FINGERHOOD, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001-4706 CIVIL ACTION - LAW IN DIVORCE 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 ftmher 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. Section 4904, relating to unswom falsification to authorities. Date: Nov. 9, 2001 ELLIOTT FINGERHOOD AUDREY J. FINGERHOOD, Plaintiff V. ELLIOTT FINGERI-IOOD, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2001-4706 : : CIVIL ACTION - LAW : IN DIVORCE CERTIFICATE OF SERVICE AND NOW, this 9th day of August, 2001, I, MAX J. SMITH, JR., Esquire, Attorney for Plaintiff, hereby certify that I have this day sent a copy of Complaint in Divorce by depositing a certified copy of the same in the United States mail, postage prepaid, certified mail #7000 1670 0011 1697 9395 at Hershey, Pennsylvania, addressed to: Elliott Fingerhood 618 Allenview Drive Mechanicsburg, PA 17050 Mailing and return receipt cards attached hereto. I.D. No. 32114 JAMES, SMITH, DURKIN & CONNELLY LLV P.O. Box 650 Hershey, PA 17033 (717) 533-3280 Postm~k E, Attk31e Numl~' (Copy from ~tv/ce/abe/) D. leCC.¢a-~aGG.,M, I? ~Yee , PS Form 3811, July 1999 D°meatlc Retum Receipt ' IOE~eS-OO-M.O~ AUDREY J. FINGERHOOD, Plaintiff ELLIOTT FINGERHOOD, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2001-4706 : : CIVIL ACTION- LAW : 1N DIVORCE Social Security numbers of the parties are: Audrey: 206-32-1226 Elliott: 166-34-8346 MARITA~L SETTLEMENT _AGREEMENVF THIS AGREEMENT, made this/214___~~ day of ,2001, by and between AUDREY J. FINGERHOOD (hereinafter called "Wife") and ELLIOTT H. FINGERHOOD (hereinafter called "Husband"). WITNESSETH: WHEREAS, Husband and Wife were married on May 13, 2000; and WHEREAS, There have been no children bom of this marriage; and WHEREAS, the parties hereto desire to fix and determine by this Marital Settlement Agreement the rights and claims that have accrued to each of them in the estate and real and personal property of the other by reason of the marriage, and all economic rights of every kind and description arising from the marital relationship, including but not limited to present and future rights of inheritance, support, maintenance, alimony, payment of counsel fees and equitable distribution and to accept the provisions of this Agreement in lieu of and in full discharge, settlement and satisfaction of all such rights and claims. NOW, THEREFORE, in consideration of the premises and of the marriage, and in further consideration of the mutual promises and undertakings hereinafter set forth, each intending to be legally bound hereby, the parties agree as follows: 1. S~EPARATION. It shall be lawful for each party at all times hereafter to live separate and apart from the other party at such place as he or she may from time to time choose or deem fit. The foregoing provisions shall not be taken as an admission on the part of either party of the lawfulness or unlawfulness of the causes leading to their living apart. 2. INTERFERENCE. Each party shall be free from interference, authority and contact by the other, as fully as if he or she were single and unmarried except as may be necessary to carry out the provisions of this Agreement. 3. WIFE'S DEBTS. Wife represents and warrants to Husband that as of the date of separation she has not incurred, and in the future she will n6t contract or incur, any debts or liability for which Husband or his estate might be responsible and shall indemnify and save harmless Husband from any and all claims or demands made against him by reason of debts or obligations incurred by her. Any and al/loans, and/or debts and charge accounts presently in Wife's name alone shall be Wife's sole and separate responsibility for payment thereof, and Wife agrees to indemnify and save harmless Husband from any loss he may sustain, including attorney fees, as a result of any default in payment by Wife. 4. H_HUSBA_ND'S D_EBTS. Husband represents and warrants to Wife that as of the date of the separation he has not incurred, and in the future he will not contract or incur, any debt or liability for which Wife or her estate might be responsible and shall indemnify and save harmless Wife from any and all claims or demands made against her by reason of debts or obligations incurred by him. Any and all loans, and/or debts and charge accounts, presently in Husband's name alone shall be Husband's sole and separate responsibility for payment thereof, and Husband agrees to indemnify and save harmless Wife from any loss she may sustain, including attorney fees, as a result of any default in payment by Husband. 5. JOINT DEBTS. Husband shall be solely responsible for paymen, t and satisfaction of the following jointly incurred liabilities, to the extent of the respective approximate balances listed: Capital One (Gold) - $2,300 First USA - $2,456 Bank of America - $1,893.18 US Bank - 2,959 Exxon/Mobile gas card Husband agrees to indemnify and save harmless Wife from any loss she may sustain, including attorney fees, as a result of any default in payment by Husband. 6. EOUITABLE DISTRIBUTION. Husband and Wife acknowledge and agree that the provisions of this Agreement with respect to the distribution and division of marital and separate property are fair, equitable and satisfactory to thembased on the length of their marriage and other relevant factors which have been taken into consideration by the parties. Both parties hereby accept the provisions of this Agreement with respect to division of property in lieu of and in full and final settlement and satisfaction of all claims and demands that they may now have or hereafter have against the other for the equitable distribution of their property by any court of competent jurisdiction pursuant to Section 3502 of The Divorce Code or any other laws. Husband and Wife voluntarily and intelligently waive and relinquish any right ti} seek a court ordered determination and distribution of marital property, but nothing herein contained shall constitute a waiver by either party of any rights to seek the relief of any court for the purpose of enforcing the provisions of this Agreement. 6. REAL ESTATE. The parties agree that Husband shall grant, transfer, relinquish and convey to Wife all of his right, title and interest in the marital residence located at 618 Allenview Drive, Mechanicsburg, Cumberland County, Pennsylvania. Husband shall execute a deed so transferring his equitable interest in the said premises to Wife contemporaneously with the execution of this Agreement. To the extent any additional documents may be required in connection with Wife's sale of the Allenview Drive premises, Husband shall agree to execute same upon request. It is specifically understood and agreed that Wife hereby assumes sole responsibility for payment of the current mortgage obligation thereon. Wife shall further be responsible for payment of all other real estate-related expenses and household expenses, including but not limit- ed to taxes, insurance and utilities. Wife shall indemnify and save harm/ess Husband from any loss he may sustain, including attorney fees, as a result of any default in payment of the aforesaid obligations by Wife. 7. DIVISION OF PERSONAL PROPERTY ACCOUN'FS AND VEHICLES. The parties have divided between them, to their mutual satisfaction, the personal effects, bank accounts, household furniture and furnishings and all other articles of personal property which have heretofore been used by them in common. The parties expressly agree that Wife shall be entitled to exclusive owne}ship of the 1994 Geo Prizm currently in her possession, and that Husband shall ~elinquish any and all interest he may have in same. Wife agrees to be solely responsible for payment of any and all encumbrances, and all other expenses affecting such vehicle. Wife agrees to indemnify and save harmless Husband from any loss he may sustain, including attorney fees, as a result of any default in payment by Wife. The parties agree that the 1995 Lexus, currently in Husband's possession, shall be sold, and Wife shall relinquish any and all interest she may have in same. Husband agrees to be solely responsible for payment of any and all encumbrances, until said vehicle is sold, and all other expenses affecting such vehicle. Husband agrees to indemnify and save harmless Wife from any loss she may sustain, including attorney fees, as a result of any default in payment by Husband. The parties further agree to execute any vehicle titles, Powers of Attorney or other documents necessary to give this Paragraph full force and effect, upon request. 8. PENSIONS AND EMPLOYMENT BENEFIT~,;. Husband and Wife are the owners of certain pension plans and/or retirement plans and/or employee stock or savings plans, which they have accumulated during the course of their past and/or present employment. It is hereby specifically agreed that Husband and Wife each shall forever relinquish to the other his or her right, title and interest in said pension plans and/or retirement plans and/or employee stock or savings plans, as well as all other employment benefits, of the other. The parties agree to execute any and all documentation necessary to effectuate the terms herein contained. 9. ALIMONY. Both parties agree to make no claim for alimony or alimony pendente lite now or at any future time, or in connection with the pending divorce action between the parties. 10. COUNSEL FEES. Husband and Wife agree to be solely responsible for payment of his or her attorney fees in connection with this Agreement and the pending divorce action between the parties. 11. 2_001 INCOME TAX FILING. The parties agree to file a joint income tax return for tax year 2001. Wife shall retain any refund resulting the-re;om. Husband shall be responsible for any tax liability resulting therefrom. Commencing 2002, separate income tax returns shall be filed by the parties. 12. .FINANCIAL DISCLOSURE. The parties have disclosed to each other and they are aware of the extent of each other's income, assets, liabilities, holdings and estates. Husband and Wife confirm that by executing this Agreement each forever waives any future right to set aside said Agreement, or to defend against its enforcement or any portion thereof based upon the absence of such a disclosure by the other party, or based upon any claim that it is inequitable, unconscionable or does not make a reasonable provision for one or the other of them. 13. SUBSEQUENT DIVORCE. Nothing herein contained shall be deemed to prevent either of the parties from maintaining a suit for absolute divorce against the other in any jurisdiction, nor to bar the other from demanding any such suit. 14: ~NOTFAULT DIVORCE. Both parties agree to execute an Affidavit of Consent and Waiver of Notice of Intention to Request Entry of a Divorce Decree to facilitate entry of a divome decree pursuant to Section 3301(c) of the Divorce Code at the expiration of ninety (90) days from the date of service of the divorce Complaint instituted by Wife docketed to No. 2001- 4706, Court of Common Pleas of Cumberland County, Pennsylvania. However, the parties agree to refrain from concluding the divorce until January 1, 2002. 15. BREACH. If either party breaches any provisions of this Agreement, the other party shall have the right, at his or her election, to sue for damages, including atiomey fees, for such breach, or seek such remedies or relief as may be available to him or her respectively. 16. 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, including Deeds and other real estate-related documents, titles, pension documents, or other documents that may be reasonably required to give full force and effect to the provisions of this Agreement. 17. _VOLUNTARY EXECUTION. The provisions of this Agreement and their legal effect have been fully explained to Wife by Max J. Smith, Jr., Esquire, attorney ~or Wife, and each party acknowledges that the Agreement is fair and equitable, that full disclosure has been made by each respective party to the other, that it is being entered into voluntarily, and that it is not the result of any duress or undue influence. Wife and Husband acknowledge that they have been furnished with all information relating to the financial affairs of the other, which has been requested by them respectively. Husband has been advised of his fight to retain independent legal counsel to advise him concerning this Agreement and the pending divorce action between the parties, and acknowledges that he has waived such fight. 18. WAIVER OF CLAIMS AGAINST ESTATE. 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 fights he or she may now or hereafter acquire, under the present or~uture laws of any jurisdiction, to share in the property or the estate of the other as a result of the marital relationship, including, without limitation, dower, curtesy, siatutory allowance, widow's allowance, right to take property against the Will of the other, and the right to act as administrator or executor of the other's estate, and each will, at the request of the other, execute, acknowledge and deliver any and all instmrnents which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interest, rights and claims. 19. INCORPORATION OF AGREEMENT FOR ENFORCEMENT. This Agreement shall bind the parties hereto and their respective heirs, executors, administrators, legal representatives and assigns. This Agreement shall survive a decree of divorce between the parties in any jurisdiction and any other order which may be entered in accordance with this Agreement. In the event that a Decree of Divorce is entered in the Court of Common Pleas of Cumberland County, Pennsylvania or in the event that a Decree in Divorce is entered in any other jurisdiction, the parties agree to incorporate this Agreement in the Divorce Decree for purposes of enforcement. It is the specific intent of the parties to be bound by the provisions hereof in lieu of any other claim or order of support, maintenance, alimony, equitable distribution, counsel fees, costs, maintenance of insurance, equitable relief or property settlement or with regard to any other provision hereof. In the event that any final order of court is entered in any jurisdiction with respect to the parties hereto which is contrary to the provisions hereof, then the rights and responsibilities of each of the parties hereto shall be relieved or adjusted to the extent necessary to conform to this Agreement. 20. ENTIRE AGREEMENT. This Agreement contains the entire understanding of the parties, and there are no representations, warranties, covenants or undertakings other than those expressly set forth herein. 21. 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 or any subsequent default of the same or similar nature. 22. DESCRIPTIVE HEADINGS. The descriptive headings used herein are for convenience only. They shall have no effect whatsoever in determining the rights or obligations of the parties. 23. IRREVOCAB/LITY. It is understood and agreed to by and between the respective parties hereto that the property division-distribution effected by the h~rein Agreement is IRREVOCABLE and that such division-distribution shall not be affected by any future change in circumstances of the respective parties OR by other statutory or judicial alternatives which may be available to the respective parties under prior, current or future laws of the Commonwealth of Pennsylvania or any other jurisdiction. The parties hereby waive any respective rights to financial support and/or alimony and/or pension or future expectancies each may respectively have under prior, current or future laws or case decisions. IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the day and ye~ first above written. wIT ss o~ ~ ~ ,-.d~_,, WITNESS AUDR] ELLI05 8 AUDREY J. FINGERHOOD, Plaintiff ELLIOTT FINGERHOOD, Defendant : 1N THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2001-4706 : : CIVIL ACTION- LAW : IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section (X) 3301 (c) ( ) 3301 (d) of the Divorce Code. (Check applicable section). 2. Date and manner of service of the complaint: By certified mail on August 10, 2001. Divorce Code: Defendant: 4. 3. (Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by Section 3301 (C) of the Divorce Code: by Plaintiff November 9, 2001 ; by Defendant November 9, 2001 (b)(1) Date of execution of the Plaintiffs affidavit required by Section 3301 (d) of the ; (2) date of service of the Plaintiff's affidavit upon the Related claims pending: None Attomey~ ( ) Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW t ~ D~fendant File No. IN DIVORCE NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff/Defendant in the above matter, having been granted a Final Decree in Divorce on the /~ day of ~~ ~O~, , here~l~elects to resume the · /~h~/ ~ -~ r , j and iv prior surname of (~_~/~{._~.~ ~z~--}/.~ /~ , g es this written notice pursuan~to the provisions of 54 P.S. ~ 704. DATE: --~--,/~ ~ 0~,00~ ~_~z," <2~Signat,ure~~J ~}gn~t~ of name being resumed COMMONWEALTH OF PENNSYLVANIA: : SS. COUNTY OF CUMBERLAND : On the ~ day of Notary Public, personally appeared the above be the person whose name is subscribed to the within document and acknowledged that be/she executed the foregoing for the purpose therein contained. 2~ before me, a affiant known to me to seal. In Witness Wbereof, I have hc~reunto set my baad and official Notary Publ ~,c NoTAalAL SEAL CLAUDIA A, RREWBAKER,, NOTARY PUBLIC Carlisle Bom, Guml3erland County ,My Commission Expires April 4, 2005