HomeMy WebLinkAbout07-5842,,
PAMELA L. HAMILTON, IN THE COURT OF COMMON PLEAS OF
Plaintiff, :CUMBERLAND COUNTY, PENNSYLVANIA
v. CIVIL ACTION -LAW
2007 - Si'`~z-CIVIL TERM
THOMAS A. HAMILTON,
Defendant. IN DIVORCE
NOTICE
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 in 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 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, 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
32 South Bedford Street
Carlisle, Pennsylvania 17013
717-249-3166
1-800-990-9108
AMERICANS WITH DISABILITIES
ACT OF 1990
The Court of Common Pleas of Cumberland 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. All arrangements must be made at
least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or
hearing.
PAMELA L. HAMILTON,
Plaintiff,
v.
THOMAS A. HAMILTON,
Defendant.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
2007 - S~~y2~CIVIL TERM
IN DIVORCE
COMPLAINT IN DIVORCE PURSUANT TO
SECTIONS 3301(0) AND ~ OF THE DIVORCE CODE
AND NOW, comes the Plaintiff, Pamela L. Hamilton, by and through her attorneys,
Irwin, & McKnight, and files this Complaint in Divorce against the Defendant, Thomas A.
Hamilton, representing as follows:
1. The Plaintiff is Pamela L. Hamilton, an adult individual residing at 735 West
Louther Street, Carlisle, Cumberland County, Pennsylvania 17013.
2. The Defendant is Thomas A. Hamilton, an adult individual currently residing at
847 West North Street, Carlisle, Cumberland County, Pennsylvania 17013.
3. The Plaintiff and Defendant have been residents of the Commonwealth of
Pennsylvania at least six months prior to the filing of this action in divorce.
4. The Plaintiff and the Defendant were married on December 20, 1986, in Carlisle,
Cumberland. County, Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the parties.
6. Pursuant to the Divorce Code, Sections 3301(c) and 3301(d), the Plaintiff avers as
the grounds upon which this action is based that the marriage between the parties is irretrievably
broken.
7. The Plaintiff avers that she has been advised of the availability of counseling and
that said party has the right to request that the court require the parties to participate in
counseling.
WHEREFORE, the Plaintiff respectfully requests judgment dissolving the marriage
between the two parties.
Respectfully submitted,
IRWIN & McKNIGHT
sy:
Marcus
~me'Court LD. No. 254
est Pomfret Professional F
i West Pomfret Street /
Car i vania 17013-3222
(717) 249-2353
Date: September 28, 2007
VERIFICATION
The foregoing Complaint in Divorce is based upon information which has been gathered
by counsel and myself in the preparation of this action. I have read the statements made in this
document and they are true and correct to the best of my knowledge, information and belief. I
understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section
4904, relating to unsworn falsification to authorities.
~~~~~~Q~,~~rh~~
PAMELA L. HAMILTON
Date: September 28, 2007
PAMELA L. HAMILTON,
Plaintiff,
v.
THOMAS A. HAMILTON,
Defendant.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
2007 - ~ y~ CIVIL TERM
IN DIVORCE
PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT
The plaintiff, being duly sworn according to law, deposes and says:
1. 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
Prothonotary's Office, 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.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
-~~-mom ~~~~~~~n,
PAMELA L. HAMILTON
Date: September 28, 2007
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PAMELA L. HAMILTON,
Plaintiff,
v.
THOMAS A. HAMILTON,
Defendant.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
b?• 5 I'Y.z~ CIVIL TERM
IN DIVORCE
NOTICE TO THE DEFENDANT
If you wish to deny any of the statements set forth in this affidavit, you must file acounter-
affidavit within twenty (20) days after this affidavit has been served on you or the statements will
be admitted.
PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d)
OF THE DIVORCE CODE
1.
The parties to this action separated on or about May 27, 1999, and have continued to live
separate and apart for a period of at least two years.
The marriage is irretrievably broken.
2.
3.
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.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein aze made subject to the penalties of 18 Pa. C.S. of 4904 relating to
unsworn falsification to authorities.
Date: September 28, 2007 `~~ ~
PAMELA L. HAM T N
Plaintiff
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MARRIAGE SETTLEMENT AGREEMENT
THIS AGREEMENT made this 28th day of September, 2007 by and between
PAMELA L. HAMILTON, (hereinafter referred to as "WIFE") and THOMAS A.
HAMILTON, hereinafter referred to as "HUSBAND").
WITNESSETH:
WHEREAS, HUSBAND and WIFE were lawfully man-ied on December 20, 1986, in
Cumberland County, Pennsylvania and were were sepazated on May 27, 1999. The parties hereto
agree and covenant as follows:
The parties intend to maintain sepazate and permanent domiciles and to live apart from
each other. It is the intent and purpose of this Agreement to set forth the respective rights and
duties of the parties while they continue to live apart from each other.
2.
The parties have attempted to divide their matrimonial property in a manner which
conforms to a just and right standazd, with due regard to the rights of each party. It is the intent
of the parties that such division shall be final and shall forever determine their respective rights.
The division of existing marital property is not intended by the parties to constitute in any way a
sale or exchange of assets.
3.
Further, the parties agree to continue living separately and apart from the other at any
place or places that he or she may select as they have heretofore been doing. Neither party shall
molest, harass, annoy, injure, threaten or interfere with the other party in any matter whatsoever.
Each party may carry on and engage in any employment, profession, business or other
activity as he or she may deem advisable for his or her sole use and benefit. Neither party shall
interfere with the uses, ownership, enjoyment or disposition of any property now owned and not
specified herein nor property hereafter acquired by the other.
4.
The consideration for this contract and agreement is the mutual benefit to be obtained by
both of the parties hereto and the covenants and agreements of each of the parties to the other.
The adequacy of the consideration for all agreements herein contained is stipulated, confessed,
and admitted by the parties, and the parties intend to be legally bound hereby.
Each party to the Agreement acknowledges and declares that he or she, respectively:
a. is represented by counsel of his or her own choosing;
b. is fully and completely informed of the facts relating to the subject
matter of this Agreement and of the rights and liabilities of the parties;
c. enters into this Agreement voluntarily after receiving advice of counsel;
d. has given careful and mature thought to the making of this Agreement;
e. has carefully read each provision of this Agreement; and
f. fully and completely understands each provision of this Agreement,
both as to the subject matter and legal effect.
This Agreement shall become effective immediately as of the date of execution.
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5.
It is the purpose and intent of this Agreement to settle forever and completely the interest
and obligations of the parties in all property that they own sepazately, and all property that would
qualify as marital property under the Pennsylvania Divorce Code, Title 23, Section 401(e), and
that is referred to in this Agreement as "Marital Property", as between themselves, their heirs and
assigns. The parties have attempted to divide their Marital Property in a manner that conforms to
a just and fair standazd, with due regazd to the rights of each Party. The division of existing
Marital Property is not intended by the parties to constitute in any way a sale or exchange of
assets, and the division is being effected without the introduction of outside funds or other
property not constituting a part of the marital estate.
It is the further purpose of this Agreement to settle forever and completely any obligation
under the Pennsylvania Divorce Code relating to spousal support or alimony.
6.
Each party represents that they have reached an agreement without full disclosure of all of
his or her property interests of any nature, including any mortgage, pledge, lien, charge, security
interest, encumbrance, or restriction to which any property is subject. Each party represents that
that no debt or obligations of any nature for which he or she is currently liable or may become
liable will obligate the other party. Each Party acknowledges that, to the extent desired, he or she
has had access to all joint and separate State and Federal Tax Returns filed by or on behalf of
either or both Parties during while they were living together.
7.
REAL ESTATE: The parties own the property known as 735 West L.outher Street,
Carlisle, Pennsylvania 17013 and 847 West North Street, Carlisle, Pennsylvania 17013. WIFE
agrees to convey her right, title and interest in the property located at 847 West North Street to
HUSBAND. HUSBAND agrees to convey the property located at 735 West Louther Street to
WIFE.
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8.
DEBTS: HUSBAND will be solely responsible for his own debts. WIFE will be solely
responsible for her debts. HUSBAND will indemnify and hold harmless WIFE from all
obligation related to his debts. WIFE will be solely responsible and will indemnify and hold
harmless HUSBAND from any claim made against him related to her debts.
9.
SPOUSAL SUPPORT/ALIMONY: Both parties waive all right to seek spousal
support, alimony, or alimony pendente lite from the other.
10.
PERSONAL PROPERTY: The parties agree to the following division:
HUSBAND shall receive the following items:
a. The personal property in his possession;
b. His bank accounts;
c. Any life insurance policy;
d. His employee benefits including all his retirement plan with the Church of God
Home and Cumberland and Cumberland County;
e. The real estate at 847 West North Street, Carlisle, Pennsylvania;
f. One half (1/2) the shares of the remaining Orrstown and PP&L securities;
g. Husband will convey the Sovereign Bank Certificate of Deposit Account
Number 1695541696 to Sarah Hamilton;
h. The sum of Twenty Thousand and no/100 ($20,000.00) Dollazs payable
within ten (10) days of Husband's signing the Marriage Settlement Agreement
and the deeds conveying the real estate; and
j. The dining room table and chairs in Wife's possession along with buffet, china
cabinet and other dining room furniture.
WIFE shall receive the following items:
a. The personal property in her current possession;
b. Her bank accounts;
c. The real estate located at 735 West Louther Street, Carlisle, Pennsylvania;
d. One half (1/2) the shazes of the remaining Orrstown and PP&L securities; and
e. Wife will convey the account for David Hamilton in the amount of approximately
$8,000.00 when David Hamilton attains 18 years of age.
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The WIFE hereby waives all right and title which she may have in any personal property
of the HUSBAND. HUSBAND likewise waives any interest which he has in the personal
property of the WIFE. Henceforth, each of the parties shall own, have and enjoy independently
of any claim or right of the other party, all items of personal property of every kind, nature and
description and wherever situated, which are then owned or held by or which may hereafter
belong to the HUSBAND or WIFE with full power to the HUSBAND or the WIFE to dispose
of same as fully and effectually, in all respects and for all purposes as if he or she were
unmarried. Each party agrees that neither will incur obligations, liens or liabilities on account of
the other and that from the date of this Agreement; neither party shall contract or incur
obligations, liens or any liability whatsoever on account of the other. WIFE will give possession
of the dining room table and chairs and other dining room furniture to HUSBAND within ten
(10) days of the date of this Agreement. HUSBAND may remove tools from WIFE's garage
until October 8, 2007. This does not include the lawn mower or other power tools of WIFE.
11.
AUTOMOBILES:
a. HUSBAND agrees to waive any and all interest which he may
have in the automobiles in possession of the WIFE.
b. WIFE agrees to waive any and all interest which she
may have in the automobiles in possession of the HUSBAND.
They each waive any claim which they have in any automobile owned by the other party.
12.
INSURANCE. EMPLOYEE BENEFITS: The parties agree that any life insurance
policies on the life of HUSBAND or WIFE or any other employee benefits, including but not
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limited to retirement, profit sharing or medical benefits of either party, shall be their own. WIFE
waives all right, title and claim to HUSBAND'S employee benefits, and HUSBAND waives all
right, title, and claim to any of WIFE'S employee benefits. Following the divorce becoming
final, WIFE will secure her own insurance coverage. HUSBAND will maintain all three (3)
children on his healthcare coverage as long as each child is eligible for said coverage, provided
WIFE does not seek child support. If WIFE seeks child support, the obligation for the costs of
health insurance for the children shall be allocated between the parties in proportion of their net
income.
13.
BENEFITS. BANK ACCOUNTS AND LIFE INSURANCE: WIFE agrees to waive
all right, title and interest which she may have in the savings or checking or any other bank
accounts of the HUSBAND. The HUSBAND agrees to waive all interest which he may have in
the savings or checking or any other bank accounts of the WIFE. HUSBAND owns life .
insurance policies on the lives of David, Sarah, and Kristen Hamilton. HUSBAND agrees to pay
the premiums on those policies and not permit them to lapse until such time as he transfers
ownership of the policies to the child insured.
14.
DIVORCE: The parties both agree to cooperate with each other in obtaining a final
divorce of the marriage. Within ten (10) days of the date of this Agreement, WIFE will file a
Complaint in Divorce under section 3301(d) Affidavit and HUSBAND will provide aCounter-
Affidavit. Any party who fails to cooperate with obtaining the Divorce shall pay all the costs and
legal fees of the party who is seeking the divorce. WIFE will file a Praecipe to Transmit the
record as soon as HUSBAND files his Counter-Affidavit.
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15.
BREACH: If either party breaches any provisions of this Agreement, the other party
should have the right, at his or her election, to sue for damages for such breach or seek such other
remedies or relief as may be available to him or her, and the party breaching this contract will be
responsible for payment of legal fees and costs incurred by the other in enforcing their rights
under this Agreement.
16.
INCOME TAX EXEMPTIONS: The parties agrees that HUSBAND will take
DAVID HAMILTON as his income tax exemption on his Federal income tax returns filed each
year. The parties also agree that WIFE will take KRISTEN HAMILTON and SARAH
HAMILTON as her income tax exemptions on her Federal income tax returns filed each year.
If primary custody of the children changes, the income tax exemption for said children will be
assigned to the parent of said children with primary physical custody.
17.
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 maybe reasonably required to give full force and effect to the provisions of this
Agreement.
18.
VOLUNTARY EXECUTION: The provisions of this Agreement and their legal effect
have been fully explained to the parties by their respective counsel, and each party
acknowledges that the Agreement is fair and equitable, and that it is being entered into
voluntarily, and that it is not the result of any duress or undue influence. The provisions of this
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Agreement are fully understood by both parties and each party acknowledges that the 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.
19.
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.
20.
APPLICABLE LAW: This Agreement shall be construed under the Laws of the
Commonwealth of Pennsylvania.
21.
PRIOR AGREEMENTS: It is understood and agreed that any and all property
settlement agreements which may or have been executed prior to the date and time of this
Agreement are null and void and of no effect.
22.
PAYMENT OF COSTS AND LEGAL FEES: The parties agree to pay for their own
costs and legal fees required to obtain and complete the divorce.
23.
WAIVER OF CLAIMS AGAINST ESTATES: 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 now have or hereafter acquire, under the present or
future 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, courtesy, statutory allowance, widow's
allowance, right to take in intestacy, right to take against the Will of the other, and right to act as
administrator or executor of the other's estate, and each will, at the request of the other, execute,
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IN WITNESS WHEREOF, the parties hereunto have set their hands and seals the day
and year first above written.
~~~' SEAL)
PAMELA L. HAMILTON
..~"
(SEAL)
THOMAS A. HAMILTON
COMMONWEALTH OF PENNSYLVANIA
. SS:
COUNTY OF CUMBERLAND
~~
PERSONALLY APPEARED BEFORE ME, this .,~ day a€~, 2007, a Notary
Public, in and for the Commonwealth of Pennsylvania and County of Cumberland, PAMELA L.
HAMILTON, known to me (or satisfactorily proven) to be the person whose name is subscribed
to the within Marriage Settlement Agreement, and acknowledges that she executed the same for
the purposes therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and official seal.
TH OF PENNSYLVANIA
Notarial Seal
Mara L Noel, Notary- PubNc
C.atlrle Bao, QmDetlartd CouXY
tiAy Oormtfeeion Ekes Sept 18, 2011
A~lember, Pennsylvania Assoeiatlon of Notatfes
COMMONWEALTH OF PENNSYLVANIA
. SS:
COUNTY OF CUMBERLAND
~/
PERSONALLY APPEARED BEFORE ME, this .'S ~ day of ~~~~..~iX. 2007, a
Notary Public, in and for the Commonwealth of Pennsylvania and County of Cumberland,
THOMAS A. HAMILTON, known to me (or satisfactorily proven) to be the person whose
name is subscribed to the within Marriage Settlement Agreement, and acknowledges that he
executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and official seal.
Cu~lisle BHa14rllil~
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PAMELA L. HAMILTON, :COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
v. :CIVIL ACTION -LAW
'.NO. 2007-5842 CIVIL TERM
THOMAS A. HAMILTON,
Defendant IN DIVORCE
ACCEPTANCE OF SERVICE
I, Carol J. Lindsay, Esquire, accept service of the Complaint in Divorce on behalf of
Defendant in the above-captioned matter and state that I am authorized to do so.
Vc.~o~w f ~ 740 ~ -
Date ~ Carol J. n , Esquir
Supre a Cou ID No. 4 693
26 Wes Street
Carlisle, PA 17013
717-243-6222
~~AWERIS~SZ
LINDSAY
26 West High Street
Carlisle, PA
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PAMELA L. HAMILTON, IN THE COURT OF COMMON PLEAS OF
Plaintiff, :CUMBERLAND COUNTY, PENNSYLVANIA
~, CIVIL ACTION -LAW
. 2007-5842 CIVIL TERM
THOMAS A. HAMILTON,
Defendant. IN DIVORCE
To the Prothonotary:
PRAECIPE TO TRANSMIT RECORD
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 3301(c) and or (d) of the Divorce Code.
2. Date and manner of service of complaint: A certified copy of the Complaint in Divorce was served upon the
defendant, Thomas A. Hamilton, on or about October 4, 2007, by personal service to Defendant's counsel, Cazol Lindsay,
Esq., 26 West High Street, Cazlisle, Pennsylvania, 17013. A copy of the Acceptance of Service is attached hereto.
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: by defendant:
(b}(1) Date of execution of the affidavit required by Section 3301(d) of the Divorce Code:
September 28, 2007.
(b)(2) Date of and service of the plaintiffs affidavit upon the defendant:
Filing -October 3, 2007 and Service -October 4, 2007
4. Related claims pending: NONE.
5. Complete either (a) or (b).
(a) Date and manner of service of the Notice of Intention to file Praecipe to Transmit Record, a copy
of which is attached: Service made by personal service to Defendant's counsel, Carol Lindsay, Esq., 26 West High
Street, Carlisle, Pennsylvania 17013 on or about October 4, 2007.
(b) Date plaintiff s Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary:
Date defendant's Waiver of Notice in Section 3301(c~Divorce was filed with the Prothonotary:
A. ght, III, Esquire
v for P 'tiff
Date: October 19, 2007
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PAMELA L. HAMILTON,
Plaintiff
v.
THOMAS A. HAMILTON,
Defendant
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
NO. 1999-3206
IN DIVORCE
DEFENDANT'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A
DIVORCE DECREE UNDER$ 3301 (d) OF THE DIVORCE CODE
~ ~ tiv".'~erE{ t~ the cntn~ of ? f!-l~;i fln..ra-~ r1f iljynri^~a Ullth!11.1{ !?Qt1C?.
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 to the best of
SAIDIS,
rZAVVER Sz
LINDSAY
~now~vs..v uw
26 West High Street
Cazlisle, PA
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.
Dated: ~0~-x-0`1 ~~
hornas A. Hamilton
p~~ fl 9 2001
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PAMELA L. HAMILTON,
Plaintiff
v.
THOMAS A. HAMILTON,
Defendant
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
NO. 1999-3206
IN DIVORCE
COUNTER-AFFIDAVIT UNDER ~3301(d) OF THE DIVORCE CODE
1. Check either (a) or (b):
(a) ~ I do not oppose the entry of a divorce decree.
(b) I oppose the entry of a divorce decree because (check (i), (it j or both)
(i) The parties to this action have not lived separate and apart for
a period of at least two years.
(ii) The marriage is not irretrievably broken.
2. Check either (a) or (b):
(a) ~ I do not wish to make any claims for economic relief. 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.
(b) I wish to claim economic relief which may include alimony, division of
property, lawyer's fees or expenses or other important rights.
I understand that in addition to checking (b) above, I must also file all of my
economic claims with the Prothonotary in writing and serve them on the other party. If I fail
to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the
ui~~':~rvi: ~~'-..r.'EE :'luy u.~.. E.'nt.^-r.^.d ~.vitho;.~t fu~~-;t-;e;- r;c'~ce tc rr,e, °^~± ! sha!! ho ~,:n3hla thcrpaftcr
to file any economic claims.
I verify that the statements made in this counter-affidavit are true and correct. I
SAIDIS,
FLOWER Sz
LINDSAY
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26 West High Street
Carlisle, PA
understand that false statements herein are made subject to the penalties of 18 Pa.C.S.
§4904, relating to unsworn falsification to authorities.
Dated: J p - q - ~ ~ ~ J¢ jl
Thomas A. Hamilton
NOTICE: If you do not wish to oppose the entry of a divorce decree and you do not
wish to make any claim for economic relief, you should not file this counter-affidavit.
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I N THE COUR`T' OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF ~~ PENNA.
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PAMELA L. HAMILTON
PLAINTIFF
N O. 2007-5842 CIVIL TERM
VERSUS
THOMAS A. HAMILTON,
DEFENDANT
DECREE IN
DIVORCE
AND NOW,~OVtvu.lDc.r ~ ~~~~, IT IS ORDERED AND
DECREED THAT PAMELA L. HAMILTON PLAINTIFF,
AND -THOMAS A. HAMILTON DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
THE COURT RETAINS JURiSDiCT10N OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED;
The Marriage Settlement Agreement dated September 28, 2007 and signed by the
parties is hereby incorporated into this Divorce Decree, but not merged.
BY THE COURT:
ATTEST: J.
PROTHONOTARY
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