HomeMy WebLinkAbout03-5951
RENEE A. SULLIVAN,
Plaintiff,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 03 - SflS'1
C/oi.l ~EIUY\
MICHAEL J. SULLIVAN,
Defendant.
CIVIL ACTION - LAW
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 the marriage,
you may request marriage counseling. A list of marriage counselors is available in the Office of
the Prothonotary, Cumberland County Courthouse, I Courthouse Square, 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.
LAWYER REFERRAL SERVICE
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY A VENUE
CARLISLE, P A 17013
(800) 990-9108
(717) 249-3166
RENEE A. SULLIVAN,
Plaintiff,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 03 - bq~1
C/u~L~
MICHAEL J. SULLIVAN,
Defendant.
CIVIL ACTION - LAW
DIVORCE
COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE
1. Plaintiff, Renee A. Sullivan, is an adult individual currently residing at 617
Mountain Street, Enola, Cumberland County, Pennsylvania, 17025.
2. Defendant, Michael J. Sullivan, is an adult individual currently residing at 617
Mountain Street, Enola, Cumberland County, Pennsylvania, 17025.
3. Plaintiff has been a bona fide residents of the Commonwealth of Pennsylvania for
at least six months immediately previous to the filing of this Complaint.
4. Plaintiff and Defendant were married on April 25, 1992, in Etters, York County,
Pennsylvania.
5. There has been no prior action of divorce or annulment of marriage between the
parties.
6. Defendant is not a member ofthe Armed Services of the United States of America
or its Allies.
7. The marriage is irretrievably broken.
8 . 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.
9. Plaintiff requests the court to enter a decree of divorce.
WHEREFORE, Plaintiff prays that a Decree be entered divorcing the said Plaintiff and
Defendant from the bonds of matrimony heretofore contracted between them.
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. Section 4904 relating to
unsworn falsifications to authorities.
Date:
If'l-i))
L
JS.-A--
RENEE A. SULLN AN
Respectfully submitted,
TOMASKO & KORANDA, P.c.
219 State Street
Harrisburg, PA 17101
Telephone: (717) 238-1100
BY~ ~/
MICHAE A.KORANDA
PA ID# 58808
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RENEE A. SULLIVAN,
Plaintiff,
vs.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYL V ANlA
NO. 63 ~ S9~1 C,oiL<-rE'fi...~
CIVIL ACTION - LAW
DIVORCE
MICHAEL J. SULLIVAN,
Defendant.
ACCEPTANCE OF SERVICE
I, Michael J. Sullivan, the Defendant in the above-captioned matter, hereby accept service
of the Complaint Under Section 3301(c) of the Divorce Code, and certify that I am authorized to
do so.
Date:
/11/5/05
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MICHAEL J. ShiLIV AN
617 Mountain Road
Enola, PAl 7025
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PROPERTY SETTLEMENT AGREEMENT
THIS AGREEMENT, by and between MICHAEL J. SULLN AN, 617 Mountain Street,
Enola, Cumberland County, Pennsylvania (hereinafter, the "Husband") and RENEE A.
SULLIVAN, of617 Mountain Street, Enola, Cumberland County, Pennsylvania (hereinafter, the
"Wife"), is as follows:
WITNE S SETH:
WHEREAS, Husband and Wife entered into a marriage on or about April 25, 1992, in
Etters, York County, Pennsylvania;
WHEREAS, the Husband and Wife have one child together who was born of the
marriage, namely: Jordan Poe Sullivan, born November 25, 1998 (hereinafter, the "minor
child")
WHEREAS, differences have arisen between Husband and Wife in consequence of which
they desire to live separate and apart from each other;
WHEREAS, Wife filed a Complaint for Divorce on or about November 12, 2003, which
is docketed in the Court of Common Pleas of Cumberland County, Pennsylvania (No. 2003-5951
Civil Term);
WHEREAS, Husband and Wife desire by means ofthe within Agreement to settle and
determine all oftheir rights and obligations to one another under the Divorce Code of 1980, as
amended.
NOW THEREFORE, in consideration of the promises and covenants contained herein,
and intending to be legally bound, it is agreed by and between the parties hereto that:
Page I of 11
1. SeDaration. It shall be lawful for each party at all times hereafter to jive separate
and apart from each other at such place as he or she from time to time shall choose or deem fit.
They shall be free from any interference, direct or indirect, by the other in all respects as fully as
ifthey were unmarried. They shall not harass, disturb or malign each other or the respective
families of each other. The foregoing provision 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. Entrv as Part of Decree. An action seeking the dissolution of the marriage is
pending in a court of competent jurisdiction as above stated. The parties hereby agree to execute
the Affidavits of Consent for divorce and Waivers of Notice ofIntention to Request Entry of a
Divorce Decree at the earliest possible date. The parties acknowledge the availability of
counseling and both parties have waived their right to counseling. It is the intention of the
parties that this Agreement shall survive any action for divorce which may be instituted or
prosecuted by either party and no order, judgment or decree or divorce, temporary, final or
pennanent, shall affect or modify the financial terms of this Agreement. This Agreement shall be
incorporated, but not merged, in any final Decree in Divorce.
3. Mutual Release. Except, and only except, for all rights, agreements and
obligations of whatsoever nature arising under or which may arise under this Agreement or for
the breach of any part of this Agreement, Husband and Wife each do hereby mutually remise,
release, quitclaim, and forever discharge the other and the estate of the other, for all time to
come, and for all purposes whatsoever, of and from any and all rights, title and interest, or claim
in or against the property of the other or against the estate of the other, of whatever nature and
Page 2 of Il
wheresoever situate, which he or she now has or at any time hereafter may have against the other,
the estate of the other or any party thereof Except, and only except, for all rights, agreements
and obligations of whatsoever nature arising under or which may arise under this Agreement or
for the breach of any part ofthis Agreement, it is the intention of Husband and Wife to give to
each other by the execution of this Agreement a full, complete and general release with respect to
any and all property of any kind or nature, whether real, personal or mixed, which the other now
owns or may hereafter acquire.
4. Waiver of Claims under the Divorce Code of 1980. as amended. Includinl!.
but not limited to. Claims for SDousal SUDDort. Alimonv. A.P.L.. Attornev's Fees. etc. Each
party absolutely and unconditionally releases the other and the estate of the other from any and
all rights and obligations which either may have for past, present, and/or future obligations
arising under the Divorce Code of 1980, as amended, including, but not limited to claims for
support for himself or herself, spousal support, alimony pendente lite, temporary andlor
permanent alimony, counsel fees or expenses from the other party.
5. Warrantv of Disclosure. Husband and Wife each represent and warrant to the
other that he or she has made a full and complete disclosure to the other of all assets of any
nature whatsoever in which such party of every type whatsoever and all other facts relating to the
subject matter of this Agreement. The parties waive their respective rights under the Divorce
Code of 1980, as amended, to obtain formal valuations and appraisals and to engage in formal
discovery to identify and value all property owned individually or jointly by a party. Each party
has had ample opportunity to review the financial condition ofthe other and each party agrees
Page 3 of 11
not to challenge the instant Agreement based on an allegation of lack of sufficient disclosure of
assets, debts or income.
6. Dutv of Cooneration. The parties shall mutually cooperate with each other in
order to carry through the terms ofthis Agreement. Within ten (10) days after demand therefore,
a party shall execute and deliver to the other any deeds, bills of sale, assignment, consents to
change of beneficiary on insurance policies, tax returns and other documents and do or cause to
be done in any other act or thing that may be necessary or desirable to the provisions and
purposes of this Agreement.
7. Breach of Al!reement. In the event that either party breaches any provision of
this Agreement, the non-breaching party may seek to enforce this Agreement in a court of law or
equity, and, if a breach of the Agreement is established in a court oflaw or equity, the breaching
party shall pay the non-breaching party damages for said breach, if any, and all reasonable
attorney's fees, court costs and expenses which are incurred by the non-breaching party in
enforcing the Agreement.
8. Personal Pronertv. Husband and Wife have previously agreed to the distribu-
tion of all items of personal property, including, but not limited to, accounts and household
goods. Except as provided herein, Husband agrees that all such property in the possession of
Wife shall be the sole and separate property of Wife and Wife agrees that all such property in the
possession of Husband shall be the sole and separate property of Husband. Each of the parties
does hereby specifically waive, release and renounce any further claims with respect to said
items.
Page 4 of 11
9. Waiver of Ril!ht to Share in Retirement Benefits. The parties hereby waive,
relinquish and release any and all claims and rights either may have or ever had, presently has, or
may in the future acquire, in and to any and all retirement benefits titled in either parties'
individual name, whenever acquired, including, without limitation, any and all pension and profit
sharing plans, Keoughs, 401 (K)'s, I.R.A.s and any and all other assets oflike kind and character,
and any appreciation in the value thereof, whether due to market conditions or the direct or
indirect contributions or efforts of either party.
10. Marital Debts. Except as otherwise provided herein, each party agrees to assume
full responsibility for any and all debts in their individual name, regardless of whether the debt(s)
islare marital or non-marital. Each party agrees to indemnify and hold the other party harmless
from any liability, cost or expense, including attorneys' fees, which are incurred in connection
with such debt(s).
11. Debts. Wife represents and warrants to Husband that since the parties' separation
she has not and in the future she will not contract or incur any debt or liability for which Husband
or his estate might be responsible and shall indemnify and save Husband harmless from any and
all claims or demands made against him by reason of debts or obligations incurred by her.
Husband represents and warrants to Wife that since the parties' separation he has not 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 Wife harmless from any and all claims or demands
made against her by reason of debts or obligations incurred by him.
12. Insurance. Each party will be responsible for obtaining and paying for hislher
Page 5 of Il
own medical, dental and vision insurance.
13. Waivers of Claims Al!ainst Estates. Except as herein otherwise provided, each
party may dispose of his or her property in any way, and each party hereby waives and relin-
quishes 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, curtesy, 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, to the request of the other, execute,
acknowledge and deliver any and all instruments which may be necessary or advisable to carry
into effect this mutual waiver and relinquishment of all such interests, rights and claims.
14. Real PrODertv. Husband and Wife are the owners of certain improved real
property located at 617 Mountain Road, Enola, Cumberland County, Pennsylvania (hereinafter,
the "marital residence"). The parties hereby agree to immediately sell the marital residence (at a
price agreeable to both parties) and divide the net proceeds or net losses from the sale as follows:
55% to Husband and 45% to Wife. Net proceeds from the sale shall constitute the positive
balance remaining after all existing mortgages, liens, real estate broker's commissions and
closing costs on the property are satisfied, and net losses shall constitute the negative balance
remaining after all existing mortgages, liens, real estate broker's commissions and closing costs
on the property are satisfied.
The parties agree that Husband and Wife shall continue to reside in the marital residence
until such time as the property is sold. Husband and Wife shall be jointly responsible for all
Page 6 of 11
own medical, dental and vision insurance.
13. Waivers of Claims Al!ainst Estates. Except as herein otherwise provided, each
party may dispose of his or her property in any way, and each party hereby waives and relin-
quishes 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 ofthe other as a result of the
marital relationship, including without limitation, dower, curtesy, 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 ofthe other's estate, and each will, to the request of the other, execute,
acknowledge and deliver any and all instruments which may be necessary or advisable to carry
into effect this mutual waiver and relinquishment of all such interests, rights and claims.
14. Real Pronerty. Husband and Wife are the owners of certain improved real
property located at 617 Mountain Street, Enola, Cumberland County, Pennsylvania (hereinafter,
the "marital residence"). The parties hereby agree to immediately sell the marital residence (at a
price agreeable to both parties) and divide the net proceeds or net losses from the sale as follows:
55% to Husband and 45% to Wife. Net proceeds from the sale shall constitute the positive
balance remaining after all existing mortgages, liens, real estate broker's commissions and
closing costs on the property are satisfied, and net losses shall constitute the negative balance
remaining after all existing mortgages, liens, real estate broker's commissions and closing costs
on the property are satisfied.
The parties agree that Husband and Wife shall continue to reside in the marital residence
until such time as the property is sold. Husband and Wife shall be jointly responsible for all
Page 6 of 11
costs, expenses or liabilities attributable and/or resulting from the marital residence, including
but not limited to all mortgage payments, real estate taxes, water and sewer rents, gas, electric,
telephone service, insurance, repairs, and routine maintenance, until the marital residence is sold.
15. Motor VehicIes. Wife agrees to transfer to Husband all rights, title, and interest
she may have in the Saturn automobile. Husband agrees to transfer to Wife all rights, title and
interest he may have in the Volkswagen automobile. The party obtaining possession of any
vehicle under this Agreement shall be solely and exclusively responsible for any loan, lease or
encumbrance thereon, and that party agrees to indemnify and hold the other party harmless from
any and all claims, demands, actions or judgments arising therefrom.
16. Advice of Counsel. It is recognized that Wife is being represented by Michael A.
Koranda, Esquire. It is further recognized that Husband is not represented by counsel, although
he understands his right to be represented by an attorney of his choice. The provisions of this
Agreement are fully understood by the parties and the parties acknowledge that this Agreement is
fair and equitable, that it is being entered into freely and voluntarily and that it is not the result of
any duress or undue influence.
17. BankruDtcv. In the event that either party becomes a debtor in any bankruptcy or
financial reorganization proceeding of any kind while any obligations remain to be performed by
that party for the benefit of the other party pursuant to the provisions of this Agreement, the
debtor-spouse hereby waives, releases and relinquishes any right to claim any exemption
(whether granted under State or Federal law) to any property remaining in the debtor as a defense
to any claim made pursuant hereto by the creditor-spouse, and the debtor-spouse hereby assigns,
Page 7 of 11
transfers, and conveys to the creditor-spouse an interest in all of the debtor's exempt property
sufficient to meet all obligations to the creditor-spouse as set forth herein, including all attorney's
fees and costs incurred in the enforcement ofthis paragraph or any other provision of this
Agreement. No obligation created by this Agreement shall be discharged or dischargeable,
regardless of Federal or State law to the contrary, and each party waives any and all right to assert
that any obligation hereunder is discharged or dischargeable.
18. Effective Al!reement. This Agreement shall bind the parties, their heirs,
executors, administrators and assigns.
19. Entire Al!reement. This Agreement contains the entire understanding ofthe
parties, and there are no representations, warranties, covenants or undertakings other than those
expressly set forth herein.
20. Modification and Waiver. Any modification or waiver of any provision of this
Agreement shall be effective only ifmade in writing executed with the same formality as this
Agreement. The failure of either party to insist upon strict performance of any of the provisions
ofthis Agreement shall not be construed as a waiver of any subsequent default ofthe same or
similar nature.
21. Governinl! Law. This Agreement shall be governed by and shall be construed in
accordance with the laws of the Commonwealth of Pennsylvania.
22. Contract Internretation. For purposes of interpretation and for the purpose of
resolving any ambiguity herein, Husband and Wife agree that this Agreement was prepared
jointly by the parties.
Page 8 of 11
23. Custodv of Minor Child. The parties agree to the following with respect to the
aforesaid minor child:
A. Husband and Wife shall have joint (shared) legal custody of the minor
child. Except in the case of an emergency, all major decisions affecting
the minor child's growth and development, including medical treatment,
education, and religion, shall be made jointly by the parties. Neither party
shall, while in the presence of the minor child, make (or allow to be made)
any disparaging or derogatory remarks about the other parent. It shall be
the express duty of each parent to uphold the other parent as one whom the
minor child should respect and love. Each parent shall be entitled to
receive information concerning the minor child, including medical records,
educational records and religious records. Each parent may attend medical
appointments or scholastic conferences and activities.
B. Husband and Wife shall have joint (shared) physical custody of the minor
child.
C. Husband shall have physical custody of the minor child on the following
schedule;
Sunday: 4;00 p.m. to 8:00 p.m.
Monday: 8;00 a.m. to 3:00 p.m.
Tuesday: 8;00 a.m. to 4:00 p.m.
Wednesday: 8:00 a.m. to 4;00 p.m. and 8:00 p.m. to 12:00 a.m.
Page 9 of Il
Thursday: 12:00 a.m. to 4:00 p.m. and 8:00 p.m. to 12:00 a.m.
Friday: 12:00 a.m. to 4:00 p.m. and 8:00 p.m. to 12:00 a.m.
Saturday: 12:00 a.m. to 12:00 p.m.
Mother sh~ll have physical custody of the minor child at such other times.
D. The party beginning hislher period of physical custody shall be responsible
for all transportation.
E. The parties shall have reasonable telephone contact with the minor chil-
dren at all times.
F. Neither party shall move to a residence greater than 40 miles from the
Cumberland County Courthouse unless he or she first provides a written
notice to that effect to the other party at least sixty (60) days prior to any
such move.
G. It is expressly understood that temporary adjustments will be made to the
parties' custody arrangement to accommodate the parties' changing work
schedules. It is also understood that the parties' custody arrangement will
be amended once the minor child begins school on a full time basis to
equalize the periods of physical custody.
H. Notwithstanding the above, the parties shall have physical custody of the
minor child on alternating holidays (the parties' acknowledge the follow-
ing holidays: Easter Sunday; Memorial Day; Independence Day; Labor
Day; Halloween, Thanksgiving Day; Christmas Eve [from December 24th
Page 10 ofIl
at 12:00 noon to December 25th at 12:00 noon]; Christmas Day [from
December 25th at 12:00 noon to December 26th at 12:00 noon], New
Year's Day).
Notwithstanding the above, the parties understand and agree that the custody provisions
contained in this Agreement are subject to modification at any time by a court of competent
jurisdiction.
IN WITNESS WHEREOF, the parties hereto, intending to be legally bound hereby, have
hereunto set their hands and seals on the day and year first above written.
WITNESS:
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Page 11 of 11
COMMONWEALTH OF PENNSYL VANIA
COUNTY OF UM.A-flf-\/ r0
On this, the J lo 1 ~ day of
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Notary Public, personally appeared MICHAEL J. SULLN AN, known to me to be the person
whose name is subscribed to the within Property Settlement Agreement and acknowledged that
he executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
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COMMONWEALTH OF PENNSYL VANIA
COUNTY OF DAUPHIN
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Notary Public, personally appeared RENEE A. SULLlV AN, known to me to be the person
whose name is subscribed to the within Property Settlement Agreement and acknowledged that
she executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
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RENEE A. SULLIVAN,
Plaintiff,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYL V ANlA
vs.
NO. 03-5951 CIVIL TERM
MICHAELJ. SULLIVAN,
Defendant.
CIVIL ACTION - LAW
DIVORCE
WAIVER OF NOTICE OF INTENTION TO
REQUEST ENTRY OF A DIVORCE DECREE
UNDER S 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 this affidavit are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa. C.S. S 4904 relating to
unsworn falsification to authorities.
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MICHAEL J. LIV AN
Date: 2//0/01./
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RENEE A. SULLN AN,
Plaintiff,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYL V ANlA
vs.
NO. 03-5951 CNIL TERM
MICHAEL J. SULLN AN,
Defendant.
CNIL ACTION - LAW
DNORCE
AFFIDAVIT OF CONSENT
I. A complaint in divorce under ~ 330 I (c) of the Divorce Code was filed on November 12,
2003, and served on Defendant on November 15, 2003, as indicated in the Acceptance of Service which
has been filed with the Court.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have
elapsed from 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 ofthe 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 divorce 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. ~ 4904 relating to unsworn falsification
to authorities.
Date: '2 -! /.,;: 0, l{
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RENEE A. SULLIVAN
Plaintiff
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RENEE A. SULLIVAN,
Plaintiff,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 03-5951 CIVIL TERM
MICHAEL J. SULLIVAN,
Defendant.
CIVIL ACTION - LAW
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 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 this affidavit are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa. C.S. S 4904 relating to
unsworn falsification to authorities.
Date: 2,( 6, oy
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RENEE A. SULLIVAN
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RENEE A. SULLIVAN,
Plaintiff,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYL VANIA
vs.
NO. 03-5951 CIVIL TERM
MICHAEL J. SULLIVAN,
Defendant.
CIVIL ACTION - LAW
DIVORCE
AFFIDAVIT OF CONSENT
1. A complaint in divorce under ~ 3301(c) of the Divorce Code was filed on November 12,
2003, and served on Defendant on November 15,2003, as indicated in the Acceptance of Service which
has been filed with the Court.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have
elapsed from 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 divorce 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. ~ 4904 relating to unsworn falsification
to authorities.
~~~
Plaintiff
Date: z/Irp/OC/
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RENEE SULLIVAN,
IN THE COURT OF COMMON PLEAS
Plaintff
VS.
Defendant
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
MICHAEL SULLIVAN,
NO.
03-5951
CIVIL TERM
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 ~3301 (c)
(Strike out inapplicable section).
2. Date and manner of service of the complaint: Acceptance of Service dated November 15, 2003
3. Complete either paragraph (a) or (b).
(a) Date of execution of the affidavit of consent required by ~3301 (c) of the Divorce Code:
by plaintiff February 16, 2004 ; by defendant February 16, 2004
(b) (1) Date of execution of the affidavit required by ~3301 (d)
of the Divorce Code: N / A
(2) Date of filing and service of the plaintiff's affidavit upon the respondent:
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:
(b) Date of plaintiff's Waiver of Notice in ~3301 (c) Divorce was filed with
the Prothonotary: Februarv 18, 2004
Date defendant's Waiver of Notice in ~3301 (c) Divorce was filed with
the Prothonotary: February 18, 2004
~h7//2
Attorney for ~f / Defendant
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IN THE COURT OF COMMON PLEAS
.
OFCUMBERLANDCOUNTY
STATE OF
Renee A. Sullivan
.
VERSUS
Michael J. Sullivan
.
.
.
.
AND NOW,
PENNA.
No.
03-5951 (Civil Term)
.
.
DECREE IN
DIVORCE
.
.
1Iu.-..,
.2-('
, ko'l , IT IS ORDERED AND
DECREED THAT
Renee A. Sullivan
PLAINTIFF,
AND
Michael .T. Sullivan
.
, DEFENDANT,
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;
.
.
The attached Property Settlement Agreement executed by the parties
s ncorporate ut not merge nta t s ecree
BY THE
O;;J
.
.
.
.
.
.
.
J.
PROTHONOTARY
.
.
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNT1 ,
PENNSYL VANIA
'<'.J?i\k'...(! A S'v>l LVc('1
Plaintiff
Vs
/vttc~tG..<?( ::s-: ~0l\;J{\"
Defendant
FileNo.
030- 59 s /
IN DIVORCE
NOTICE TO RESUME PRIOR SURNAME
Notice is hereby given that the Plaintiff 1 defendant in the above matter,
[select one by marking "x"]
_ prior to the entry of a Final Decree in Divorce,
or L after the entry of a Final Decree in Divorce dated Z ~ l ~- 0
hereby elects to resume the prior surname of Q.e.!\e e A",,,, ~; \ Iv.s , and giv s this
written notice avowing his 1 her intention pursu~ the provision,s of 54 P.S,' 70 .
Date: :'-2--'1-0) !I~ S-~
Signature
""
Signature of name being resum d
COMMONWE~L TH Of PENNSYLVANIA )
COUNTY OF U / h'\.Kl ol1'r1hd
On the :2..!1!oay of fYlM i!J.-- , 200 ~before me, the Prothonotary or the
notary public, personally appeared the above affiant known to me to be the person hose
name is subscribed to the within document and acknowledged that he 1 she execut d the
foregoing for the purpose therein contained.
In Witness Whereof, I have hereunto set my hand hereunto set my hand and of cial
seal.
OJ
NOT! 1M, SEtL
! v!h' 'll~. A., BREWBAKER. NOTARY PUBLIC
. I Car islc Boro, Cumberland County
: MV C(jfff';'SSiOn Expires April 4, 2005
Pmthr>notory Qr NGtary Public
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