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HomeMy WebLinkAbout07-6072 GRETCHEN L. VARNER, Plaintiff vs. JEFFREY A. VARNER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. Z Y7- GEC Civil Term ACTION 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. Where the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available at the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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 St. Carlisle, Pa. 17013 (717) 249-3166 GRETCHEN L. VARNER, Plaintiff VS. JEFFREY A. VARNER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : No. Civil Term ACTION IN DIVORCE COMPLAINT IN DIVORCE COUNT I - DIVORCE 1. Plaintiff is Gretchen L. Varner, a competent adult individual, who has resided at 50 Baker Drive, Carlisle, Cumberland County, Pennsylvania, 17013, since October 2006. 2. Defendant is Jeffrey A. Varner, a competent adult individual, who resides at 51 Leeds Road, Newville, Cumberland County, Pennsylvania, 17241. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on June 28, 2005 in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Plaintiff has been advised that counseling is available and that plaintiff may have the right to request that the court require the parties to participate in counseling. 7. Plaintiff and Defendant have one child together, namely, Avery Varner, date of birth, September 30, 2003. 8. Plaintiff and Defendant are both citizens of the United States of America. 9. Neither Plaintiff or Defendant are a member of the Armed Forces of the United States of America or any of its allies. 10. The Plaintiff avers that the grounds on which this action is based are: That the marriage is irretrievably broken. WHEREFORE, Plaintiff requests the court to enter a decree in divorce. COUNT II - CUSTODY 11. Sections 1. - 10. are herein incorporated by reference. 12. The parties are the natural parents of Avery Varner, date of birth, 9/30/2003. 13. The parties have been unable to enter a custody stipulation in writing. 14. A custody complaint is being filed contemporaneously with this complaint. WHEREFORE, Plaintiff prays this Honorable Court, to enter a custody Order regarding the child. I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. AVtL a-o? Gretc en L. Varner, Plaintiff Respectfully submitted, Date: /0 /to UNn A dams, Esquire o. 79465 64 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF "?J ?- ?? \? ? " ?. \ J ?? c? C ° m -_.: -r? ?' o r ?. ? ?,? [ Ti F"1'i ? jC. .? ? } ?._, --? "'G W tt? ?-7JG GRETCHEN L. VARNER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 0 7 Civil Term JEFFREY A. VARNER, ACTION IN DIVORCE Defendant CUSTODY COMPLAINT 1. Plaintiff is Gretchen L. Varner, who currently resides at 50 Baker Drive, Carlisle, Pennsylvania, 17013. 2. Defendant is Jeffrey A. Varner, who currently resides at 51 Leeds Road, Newville, Pa. 17241. 3. Plaintiff is the Mother of the following child and seeks a custody order regarding the following child: NAME DOB ADDRESS Avery Varner 9/30/03 50 Baker Drive Carlisle, Pa. 17013 Mother and Father married on June 28, 2005. A divorce complaint has been filed under the above-captioned docket number contemporaneously with this custody complaint. Mother currently has primary physical custody of the child. During the past five years, the child has resided with the following persons and at the following addresses: NAME Gretchen L. Varner Jerry and Susan Cohick (Maternal grandparents) Gretchen L. Varner Jeffrey A. Varner Gretchen L. Varner Jeffrey A. Varner ADDRESSES 50 Baker Drive Carlisle, Pa. 17013 14 N. Orange St. Carlisle, Pa. 17013 225 W. North St. Carlisle, Pa. 17013 DATES Nov. 2006 - present June 2004 - Nov. 2006 May 2003 - June 2004 The mother of the child is Gretchen L. Varner. She currently resides at 50 Baker Drive, Carlisle, Pa. 17013. She is married to Jeffrey A. Varner. The father the child is Jeffrey A. Varner. He currently resides at 51 Leeds Road, Newville, Pa. 17241. He is married to Gretchen L. Varner. 4. The relationship of plaintiff to the child is that of Mother. The plaintiff currently resides with the child and maternal grandparents, Susan and Jerry Cohick. 5. The relationship of defendant to the child is that of Father. The defendant currently lives with his grandparents, Nancy and Bill Varner. 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. Plaintiff does not know of a party to the proceedings who has physical custody of the child or anyone who claims to have custody or visitation rights with respect to the child. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because: The parties separated in October 2006 Since separation. Mother has maintained primary custody regarding the child Mother is requesting a custodv order which would confirm that she has primary physical custody, would provide for shared legal custody, and periods of partial custodv for Father as the parties agree. Mother believes that such an order would be in the best interest of the child because it would provide stability for the child 8. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child has been named as parties to this action. WHEREFORE, Plaintiff requests the court to enter a custody order regarding the child. Date: (O J I S--/0 7 Respectfully submitt, n Adams, Esquire .N0 .79465 64 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF VERIFICATION I verify that the statements made in this Custody Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: /0 - /S1 ?;? Gretc en L. Varner, Plaintiff .J 1 © i GRETCHEN L. VARNER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. JEFFREY A. VARNER DEFENDANT • 2007-6072 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Wednesday, October 24, 2007 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Monday, November 12, 2007 at 10:00 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: Is/ john . Man an r. Es q. Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites 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. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY 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 Telephone (717) 249-3166 C tZ Wd ?Z 130 LOOZ L a- ht° o/ L a'hr. o/ ,? 6 L° O/ j0 J GRETCHEN L. VARNER, Plaintiff vs. JEFFREY A. VARNER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 67,60-7-o%,, Civil Term ACTION IN DIVORCE STIPULATION AND CUSTODY AGREEMENT This Stipulation and Custody Agreement is made this is -bcn day of , 2007, by and between Gretchen L. Varner, (Hereinafter referred to as "Mother"), of Carlisle, Cumberland County, Pennsylvania, and Jeffrey A. Varner, (Hereinafter referred to as "Father"), of Carlisle, Cumberland County, Pennsylvania; WHEREAS, Mother and Father are the natural parents of one child, namely, Avery Varner, date of birth, September 30, 2003; and WHEREAS, Mother and Father have reached an agreement relative to the future care, custody, and visitation of their child, the terms of which agreement both parties desire to set forth in the present Stipulation and Custody Agreement, and; WHEREAS, Mother and Father desire the provisions of the present Stipulation and Custody Agreement be approved by the Honorable Court of Common Pleas of Cumberland County and entered as a Court Order, with the same force and effect as though said Order had been entered after Petition, Notice and Hearing. There is no previous Order of Court concerning the child. NOW THEREFORE, the parties, intending to be legally bound, and in consideration of the mutual promises and agreements contained herein, hereby agree as follows: 1. Legal Custody. Mother and Father shall have joint legal custody of their child. Joint legal custody means both parents have the right to control and share in making of decisions of importance in the life of their child, including educational, medical, and religious decisions. Both parents shall be entitled to equal access to the child's school, medical, dental, and other important records. As soon as practicable after the receipt by a party, copies of a child's school schedules, special events notifications, report cards, and similar items shall be provided to the other party. Each shall notify the other party of any medical, dental, optical and other appointments of a child with healthcare providers, sufficiently in advance thereof so that the other party can attend. Notwithstanding that both parents shall share legal custody, non-major decisions involving the child's day-to-day living shall be made by the parent then having physical custody, consistent with the other provisions of this Agreement and subsequent Order. 2. Physical Custody. Primary Physical Custody of the child, as that term is defined in the custody act, shall be with Mother. 3. Partial Custody. Partial physical custody is the right to take possession of a child away from the custodial parent for a certain period of time. Father shall have liberal periods of partial custody with the child as mutually agreed by the parties, and periods of partial custody as follows: a. On every weekend, from Friday at 5:00 p.m. through Sunday at 7:30 p.m. If Father's work schedule changes, the parties will make efforts to mutually agree on times that father may have the child when he is not working. b. Father shall have additional periods of custody with the child on all major Holidays, as the parties agree. If a holiday falls on a weekend, the parties shall each have an equal period of time with the child on that holiday. c. Mother shall always have the child on Mother's day from 12:00 p.m. to 7:30 p.m. and Father shall always have the child on Father's Day from 12:00 p.m. to 7:30 p.m. d. Father shall have additional periods of physical custody with the child as the parties mutually agree, and the parties may alter the terms of this stipulation by mutual agreement. 4. Transportation and Exchange. The transportation shall be shared equally by the parties, with the parent who is to receive custody at the time of the exchange to provide for transportation from the residence or location of the other parent. At all times, all children shall be secured in appropriate passenger restraints. 5. Ongoing Relationship. Neither party shall attempt to undermine the mutual love and affection that the child may have for the other parent and neither parent shall, in the presence of the child make any disparaging or negative remarks concerning the other parent. Each party shall confer with the other on all matters of importance relating to the child's health, maintenance, and education with a view toward obtaining and following a harmonious policy in the child's education and social adjustment. Each party agrees to keep the other informed of his or her residence and telephone number to facilitate communication concerning the welfare of the child and visitation period. Each party agrees to supply the name, address, and telephone numbers of any person in whose care the child will be in for a period in excess of forty-eight (48) hours, and for each person or entity which may provide daycare for the child. 6. Illness of the Child. Emergency decisions regarding a child shall be made by the parent then having custody. However, in the event of any emergency or serious illness of a child at any time, any party then having custody of the child shall communicate with the other party by telephone or any other means practicable, informing the other party of the nature of the illness or emergency, so the other parent can become involved in the decision making process as soon as possible. The term "serious illness" as used herein shall mean any disability which confines a child to bed for a period in excess of seventy-two (72) hours and which places the child under the direction of a licensed physician. During such illness, each party shall have the right to visit the child as often as he or she desires, consistent with the medical care of the child. 7. Welfare of the Child to be Considered. The welfare and convenience of the child shall be the prime consideration of the parties in any application of the provisions of this Agreement. Both parents are directed to listen carefully and consider the wishes of the children in addressing the custodial schedule, any changes to the schedule, and any other parenting issues. . ` • / 8. Binding Effect and Modification of Order. This Agreement and all of its terms and conditions shall extend to and be binding upon the parties hereto and their respective heirs, personal representatives, and assigns. The parties are free to modify the terms of this Agreement but in order to do so both parties must be in complete agreement to any new terms. That means both parties must consent on what the new terms of the custody arrangement or visitation schedule shall be. 9. Governing Law. This Agreement shall be governed and controlled by the laws of Pennsylvania. 10. Enforcement. The parties agree that this Agreement maybe adopted as an Order of Court without the necessity of a Court hearing. 11. Entire Agreement. This Agreement contains the entire understanding between the parties concerning the subject matter hereof, and no representations, inducements, promises or agreements, oral or otherwise, not embodied herein shall be of any force or effect. This Agreement supersedes any and all prior agreements, written or oral, between the parties hereto relating to the subject matter of this Agreement. IN WITNESS WHEREOF, the parties have hereto duly executed the present Stipulation and Custody Agreement the day and year first above written. WITNESS: Witness rl A.C. Varne V ather Date://, /j '6--) Gretchen L. Varner, Mother Date: l / ' /,;), (Q -) c y N _..T{ d IM 14 200Y/ GRETCHEN L. VARNER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 07 - 6072 Civil Term JEFFREY A. VARNER, ACTION IN DIVORCE Defendant ORDER AND NOW, this (C 11 day of N o 1-. , 2007, having reviewed the attached agreement between the parties, it is hereby ORDERED and DECREED that the stipulation executed by the parties on November 12, 2007 shall be entered as an Order of Court. J. cc: /ffrey A. Varner, father ane Adams, Esquire, for mother J C If LOB q 5 Q ev GRETCHEN L. VARNER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs No. 07 - 6072 Civil Term JEFFREY A. VARNER, ACTION IN DIVORCE Defendant AFFIDAVIT OF CONSENT complaint in divorce under section 3301(6 of the Divorce Code was filed on October 15, 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the tiling and service of the Complaint. 3. 1 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 also understand that false statements herein are made subject to the penalties of' 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. Date: V_ r 4e.. arner, Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 43301(c) AND k3301(d) OF THE DIVORCE CODE 1. 1 consent to entry of a final decree of divorce without notice. Z. 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. 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 tiled NN ith the Prothonotary. 1 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. §4904 relating to unsworn falsificatio o authorities. Date: ge 4,i, ?"' - Jrner, Defendant -;lar1_ ? c._ .-? '-? F ``?? ?.. p^..x,: ^? ... ? ?• J` ,. . ?.: , '?..r :;- ? _ :a GRETCHEN L. VARNER, Plaintiff vs. JEFFREY A. VARNER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : No. 07 - 6072 Civil Term ACTION IN DIVORCE AFFIDAVIT OF SERVICE AND NOW, this March 5, 2009, I, Jane Adams, Esquire, hereby certify the following: 1. On October 16, 2007, 1 sent a copy of the custody and divorce complaint to Jeffrey Varner at 51 Leeds Road, Newville, Pa., 17241 via certified mail. That correspondence was returned. 2. On October 31, 2007, 1 sent a copy of the custody and divorce complaint to Jeffrey Varner at 102 South West St., Apt. 1, Carlisle, Pa. 17013, via regular mail. That correspondence was accepted. A copy of the cover letter is enclosed. 3. Defendant acknowledged receipt of the copy of the divorce complaint. He also signed a custody stipulation, which was sent to the same address, on or about November 11, 2007. A copy of that cover letter is enclosed. The custody stipulation was filed under the above-captioned docket number. 4. Service was completed by regular mail, on or about November 1, 2007. S Jan dams, Esquire 17 South St. C r le, Pa. 17013 (7 ) 245-8508 Sworn to and Subscribed before me this COMMONWEALTH OF PENNSYLVANIA Notarial Seal J?1 (? Jule M. Good, Notary Public day of rC 11 Cadde Bono, CuTibedand Cou* 2009. My Commission E)ires Dec. 6, 2011 Member, Pennsylvania Association of Notaries Not Public Jane Adams ATTORNEY AT LAW 64 SOUTH PITT STREET CARLISLE, PA. 17013 (717) 245-8508 voice (717) 243-9200 fax esaadamsAgmail.com October 31, 2007 Jeffrey Varner 102 South West St. Apt Carlisle, Pa. 17013 Re: Varner v. Varner Dear Jeffrey: Enclosed please find a Complaint in Divorce and Custody Complaint which was filed with the Cumberland County Prothonotary. A custody conciliation date has been set for November 12, 2007 at 10:00 am. If we can agree on a custody arrangement for Avery, the hearing may not be necessary. I could prepare a written stipulation based on your agreement and I would then cancel the conciliation conference. I will be contacting you soon regarding our proposed stipulation. In the meantime, if you have any questions, please feel free to contact me. Very truly yours, fa" 14Jane Adams, Esquire enclosure cc: Gretchen Varner Jane Adams ATTORNEY AT LAW 64 SOUTH PITT STREET CARLISLE, PA. 17013 (717) 245-8508 voice (717) 243-9200 fax esgadams ,gmail.com November 7, 2007 Jeffrey Varner 102 South West St. Apt. 1 Carlisle, Pa. 17013 Re: Varner v. Varner Dear Jeffrey: Enclosed please find a proposed agreement regarding custody. The agreement confirms the current arrangements. We are not seeking to change or take away visits. The stipulation also provides that you share legal custody of Avery with Gretchen. Please review the agreement carefully and if it is acceptable, sign and return it to me. Upon return, I would cancel the custody conciliation conference which is scheduled for Monday, November 12tH In the meantime, if you have any questions, please feel free to contact me. Very truly yours, e4a.#ce .--44w" Jane Adams, Esquire enclosure cc: Gretchen Varner Jane Adams ATTORNEY AT LAW 64 SOUTH PITT STREET CARLISLE, PA. 17013 (717) 245-8508 voice (717) 243-9200 fax esgadamsQmmail.com November 14, 2007 Jeffrey Varner 102 South West St. Apt. 1 Carlisle, Pa. 17013 Re: Varner v. Varner Dear Jeffrey: Enclosed please find a time-stamped copy of the custody stipulation which was filed in the above-captioned matter. A signed order will be forwarded upon signature by the Judge. Thank you for your cooperation regarding this matter. Very truly yours, ?? 1f4W" Jane Adams, Esquire enclosure cc: Gretchen Varner o t7 ry Ac a , ? CA) C--) GRETCHEN L. VARNER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 07 - 6072 Civil Term JEFFREY A. VARNER, ACTION IN DIVORCE Defendant AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on October 15, 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing and service of the Complaint. 3. 1 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. 1 also understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. Date: a .13/ D 4hretceZntL. Varner, Plaintiff WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 43301(c) AND 43301(d) OF THE ORCODE I . I consent to entry of a final decree of divorce without notice. 2. 1 understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if 1 do not claim them before a divorce is granted. 1 l 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. 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. §4904 relating to unsworn falsification to authorities. Date: v? Pr (. Q A?? Gretchen L. Varner, Plamtif rnf_ ? 3wo a f F3 ww co 91 A;P i? GRETCHEN L. VARNER, Plaintiff vs. JEFFREY A. VARNER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 07 - 6072 Civil Term ACTION IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Please accept this request to transmit the record, together with the following information to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under 3301 c of the Divorce Code. 2. Date and manner of the service of the Comp 3. Date of execution of the affidavit of consent required by 3301(c) of the Divorce Code: By Plaintiff: February 23, 2009 By Defendant: December 20, 2009 4. Related claims pending: None. 5. Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: January 14, 2009 Date Plaintiffs Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: March 4, 2009. itted : Date: 3?s?a5 Q- a Adams, Esquire . No. 79465 7 W. South St. Carlisle, Pa. 17013 (717) 245-8508 Attorney for Plaintiff ct IN THE COURT OF COMMON PLEAS OF GRETCHEN L. VARNER CUMBERLAND COUNTY, PENNSYLVANIA V. JEFFREY A. VARNER NO 07 - 6072 Civil Term DIVORCE DECREE AND NOW, A4 2, cI - -T2 1_66 1 , it is ordered and decreed that GRETCHEN L. VARNER plaintiff, and JEFFREY A. VARNER defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") None. ' By the Court, p IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Plaintiff : FILE NO. j?o 20 VS. IN DIVORCE Defendant 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 C''?o.?ch day of \a 2M9--1 hereby elects to resume the prior surname of \-P \-c-\oe0 )-. C&n t Co1L , and gives this written notice pursuant to the provisions of 54 P.S. 704. DATE: 213 D °J LU ya?- Signature Signature ee of name being resumed/ COMMONWEALTH OF PENNSYLVANIA : : SS. COUNTY OF CUMBERLAND On the day of 2( before me, a Notary Public, personally appeared the above a fiant known to me to be the person whose name is subscribed to the within document and acknowledged that he/she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand and official seal. -4?L tary Public NOTARIAL SEAL PROTHONOTARY, NOTARY PUBLIC CARLISLE CUMBERLAND COUNTY COURTHOUSE MY COMMISSION EXPIRES JANUARY 4, 2010 OF THE P 2009 SEP =-3 P 4s: u AAlt- 12-,30/51 ?--