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HomeMy WebLinkAbout07-7397STACEY M. CLARK PLAINTIFF V. CHRISTOPHER T. CLARK, DEFENDANT : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA . NO. 0? ^ ?3Q7 Civi ( (er m DIVORCE ACTION 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 at (717) 240- 6195, Cumberland County Courthouse, One Courthouse Square, Carlisle, PA 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS 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 S. Bedford Street Carlisle, PA 17103 (717) 240-6195 STACEY M. CLARK PLAINTIFF v. CHRISTOPHER T. CLARK, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA . NO. 07- '7397 DIVORCE ACTION COMPLAINT UNDER SECTION 3301(c) OR SECTION 3301(d) OF THE DIVORCE CODE 1. Plaintiff, STACEY M. CLARK, is an adult individual who currently resides at 11 Marble Street, Mechanicsburg, Pennsylvania 17050. 2. Defendant, CHRISTOPHER T. CLARK, is an adult individual who currently resides at 11 Marble Street, Mechanicsburg, Pennsylvania 17050 3. The Plaintiff's Social Security Number is 169-58-8721. 4. The Defendant's Social Security Number is 190-66-0922. 5. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of the Complaint. 6. The Plaintiff and Defendant were married on August 20, 1994, in Mechanicsburg, Pennsylvania. 7. There have been no prior actions of divorce or for annulment between the parties. 8. The marriage is irretrievably broken. 9. 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. 10. Plaintiff requests the Court to enter a Decree of Divorce. WHEREFORE, Plaintiff, STACEY M. CLARK, urges this Honorable Court to enter a Decree of Divorce. Respectfully submitted, NEALON & PE By: James G. Nealon, III, Esquire Attorney I.D. #46457 101 South Duke Street York, PA 17403 (! /? /? 7 (717) 852-7888 VERIFICATION I, STACEY M. CLARK, verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to authorities. DATED: i I /z /p 7 Lh 00'?' ACEY M. CLARK ''l 0 V W --W- ? r-, tes O 00 7 a 4; G 'te C STACEY M. CLARK IN THE COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 07-7397 CHRISTOPHER T. CLARK, : DIVORCE ACTION DEFENDANT ACCEPTANCE OF SERVICE I accept service of the Complaint under Section 3301(c) or Section 3301(d) of the Divorce Code. ? U Date CHRISTOPHER T. CLARK 1 r., c= a v Co STACEY M. CLARK PLAINTIFF v. CHRISTOPHER T. CLARK, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. p-i --139-7 : DIVORCE ACTION MARITAL SETTLEMENT AGREEMENT THIS AGREEMENT, made this 1ST day of d 2007, by and between STACEY M. CLARK (hereinafter called "Wife") and CHRISTOPHER T. CLARK (hereinafter called "Husband"). WITNESSETH: WHEREAS, Husband and Wife were married on August 20, 1994; and WHEREAS, the parties are the parents and natural guardians of one minor child, COLLIN PATRICK CLARK, born March 13, 2006; 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: SEPARATION. 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 not 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 all 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. HUSBAND'S DEBTS. Husband represents and warrants to Wife that as of the date of separation he has not incurred, and in the future he will not contract or incur, any debts 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. DIVISION OF PROPERTY. Husband and Wife agree that the following constitutes an equitable distribution of the marital property. A. Husband's Property The following property shall become the sole and exclusive property of the Husband: All right, title and interest in the 2002 Saturn Vue. Husband shall be solely responsible for all payments, repairs, maintenance, insurance and registration fees for the vehicle; and 2. All right, title and interest in any of Husband's pension, 401(k), IRA, retirement, checking, savings, or other accounts in his name. B. Wife's Property The following property shall become the sole and exclusive property of Wife- 1 . All right, title and interest in the 1997 Honda Civic. Wife shall be solely responsible for all payments, repairs, maintenance, insurance and registration fees for the vehicle. 2. All right, title and interest in any of Wife's pension, 401(k), IRA, retirement, checking, savings, or other accounts in her name. C. Marital Home 1. Husband and Wife currently reside in the property known as 11 Marble Street, Mechanicsburg, Pennsylvania. The property is currently deeded in both names and is encumbered by two (2) mortgages. 2. Husband agrees to be solely responsible for the payment of both mortgages, insurance, taxes, maintenance and repairs on the property. Husband agrees to indemnify and hold Wife harmless of and from any loss she may sustain, including attorneys fees, as a result of any default in payment by Husband. 3. The parties wish to maintain the marital residence for the benefit of the minor child. Therefore, Husband will continue to reside in the marital residence. 4. At this time, Husband is unable to refinance the mortgages into his name alone. The parties have agreed to delay the receipt by Wife of any equity that she may have in the marital residence. The parties calculate that Wife's share of the equity in the marital residence is approximately $40,000.00. 5. Husband has the right to refinance the mortgages on the property and to pay to Wife one-half of the equity in the residence up to a maximum of $40,000.00. At the time of refinancing, Wife will sign a deed conveying her interest in the property to Husband. At that time, Wife shall relinquish all right, title and interest in the marital residence. 6. The parties agree that if either party shall file for child support against the other, the party against whom the child support complaint has been made will have the absolute right to have the property listed for sale. The party exercising the right to list the property for sale shall have the right to choose the real estate agent and set the asking price. The other party agrees to sign all documents necessary to effectuate the sale of the residence at that time. At the time of sale, Wife shall receive one-half of the net sale proceeds up to a maximum of $40,0000. Husband shall receive then receive the balance of any sale proceeds. 7. Husband agrees that if he should pay the mortgage thirty (30) days late three times, then the property shall be sold. In such event, Husband, upon demand of Wife, sign all necessary to papers to list the property for sale. 8. If the property is to be sold due to Husband's failure to pay the mortgage or for any other reason, the parties agree to mutually select a realtor and agree that the asking price for the property shall be set by the realtor. The parties agree to accept any offer within five (5%) percent of the asking price. At settlement, Wife shall receive one-half of the net sale proceeds up to a maximum of $40,000.00. Husband shall then receive the balance of any sales proceeds. D. Other property. The parties agree that they have divided all other separate and marital property to their mutual satisfaction. As of the date of this Agreement, any and all property not specifically addressed herein shall be owned by the party to whom the property is titled, and if untitled, the party in possession. This Agreement shall constitute a sufficient bill of sale to evidence the transfer of any and all rights in such property from one to the other. Each party hereby waives any and all claims to the property of the other that is either titled in the name of the other party or in the other party's possession. E. Cosmo, the Dog. The parties agree that Cosmo will live with Husband and Collin at 11 Marble Street and will remain with Husband after Collin no longer resides there or until Cosmo's death, whichever first occurs. In the event that Husband should no longer want Cosmo, Collin will have the opportunity to take him with him when he leaves the residence. The parties agree that Cosmo will never be put up for adoption. 6. POST-SECONDARY EDUCATION SUPPORT. The parties agree that each shall contribute to the post-high school expenses incurred by their child that exceed funds received from grants, scholarships, children's earnings, education loans and funds available from Uniform Gift to Minors accounts or other accounts established for the child's post-high school education. Post-high school expenses are defined as tuition, books and room and board only. This obligation shall continue until the child reaches the age of 23, or graduates, whichever occurs first. The parties' obligation is conditioned upon each being actively consulted in the selection of an appropriate post-high school education for the child; taking into consideration the parents' then financial ability and economic circumstances, and the child's needs, desires, talents, and aptitudes for post-high school education. In no event shall either party be required to pay more than 50% of post-high school education costs for the child. The parties currently maintain a separate account, Account #157476 for the benefit of the child. The parties agree that they will both remain on the account to allow them to assist with the management of the account and the decisions regarding the use of the account. 7. MISCELLANEOUS PROVISIONS PENDING DIVORCE. The parties recognize that they will not be divorced until the expiration of the statutory waiting period. During that time, Wife agrees to maintain Husband on the current automobile insurance with Liberty Mutual and the current cell phone account with Cingular Wireless. In addition, Husband agrees to maintain Wife on his employer- sponsored health benefits with the Commonwealth of Pennsylvania. Husband agrees to pay Wife the sum of Sixty and 00/100 ($60.00) per month until the divorce is final for these shared expenses (car insurance and cell phone bill). 8. EFFECT OF SUBSEQUENT BANKRUPTCY. The Parties agree that none of the Parties obligations under the terms of this Agreement are intended to be a debt that is affected by a discharge in bankruptcy. They further specifically intend that the Parties obligations under the terms of this Agreement shall be non- dischargeable and not subject to discharge in bankruptcy because they acknowledge that, based upon the respective incomes, assets and needs of the Parties and their households, such are necessary for each to meet his/her financial obligations and to support and maintain his/her standard of living. The parties represents that there are no bankruptcy proceedings presently pending in which they are involved. The parties expressly agree not to file a bankruptcy action prior to the completion of his/her obligations pursuant to this Agreement. These obligations shall not be discharged in a bankruptcy action filed by or against either Party. 9. INCOME TAX. The parties have previously agreed to file joint federal and state tax returns. Both parties agree that in the event of any deficiency in federal, state or local income tax is proposed or any assessment of any such taxes made against either of them, each will indemnify and hold harmless the other from and against any loss or liability for any such tax deficiency or assessment or any interest, penalty and expense incurred in connection therewith. Such tax, interest, penalty or expense shall be paid solely and entirely by the individual who is finally determined to be cause of the misrepresentations or failure to disclose the nature and extent of his or her separate income on the foresaid joint return. For the tax year 2007, the parties agree to file jointly and agree to share equally any tax refund or liability. Thereafter, the parties agree that they will alternate the tax exemption for the minor child. It is specifically and mutually understood and agreed and recognized by and between the parties hereto that in even-numbered tax years, Wife shall claim the U.S. individual income tax exemption and any other federal, state or local income or other tax exemptions for Collin Patrick Clark in odd-numbered tax years, Father shall claim the U.S. individual income tax exemption and any other federal, state or local income or other tax exemptions for Collin Patrick Clark. Neither party shall interfere in any way or take any step or do any act that would interfere with the other from securing the benefit of such tax exemption. 10. ALIMONY/SPOUSAL SUPPORT. Both parties agree to make no claim for alimony, alimony pendente lite, spousal support or any claim for separate maintenance now or at any future time, or in connection with the pending divorce action between the parties. 11. CHILD SUPPORT. Both parties agree to make no claim for child support against the other party. In lieu of providing child support, the parties agree to equally share in the purchase of clothing, school expenses, such as lunches, and any other major necessary purchases. In addition, the parties agree that unreimbursed medical bills incurred on behalf of the minor child shall be split equally between the parties. The parties further recognize that Husband would not be able to refinance the mortgages on the marital residence. The parties desire Collin remain in the marital residence and as a result, Wife is willing to assist Husband with the expenses of the residence by delaying her receipt of any equity in the marital residence. The parties agree that is fair and reasonable and adequately provides for the needs of the minor child. 12. 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. 13. 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 doe not make a reasonable provision for one or the other of them. 14. NO-FAULT 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 divorce 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. 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 attorney 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 have been read by the Parties. Each party acknowledges that the Agreement is fair and equitable, that full disclosure has been made by each respective part 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 acknowledges that he has either had this Agreement reviewed by counsel and explained to him or waives the right to do so. Husband acknowledges that James G. Nealon, III, Esquire, is acting solely as counsel for Wife and that he has not received any advice from him. 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 rights he or she may now 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 martial relationship, including, without limitation, dower, curtesy, statutory 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 instruments 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 of 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 provisions 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 provision 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 undertaking other than those expressly set forth herein. 21. MODIFICATIONS 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 obligation of the parties. 23. IRREVOCABILITY. It is understood and agreed to by and between the respective parties hereto that the property division-distribution effected by the herein 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. Except as provided herein, 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 year first above written. fitness &?aCkrPA.C"_. PTACEY M. CLARK Witness ISTOPHE T. CLARK C:D 4 .7 -T C wA I STACEY M. CLARK : IN THE COURT OF COMMON PLEAS PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 07-7397 CHRISTOPHER T. CLARK, : DIVORCE ACTION DEFENDANT AFFIDAVIT OF CONSENT 1. A complaint in divorce under § 3301(c) of the Divorce Code was filed on December 7, 2007. 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. 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 understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. DATE: 6 (? , L-' a ?-"n . U "`" ' S ACY M. CLARK r._ s STACEY M. CLARK PLAINTIFF v. CHRISTOPHER T. CLARK, DEFENDANT : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 07-7397 : DIVORCE ACTION WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER s 3301(c) AND. § 3301(d) OF THE DIVORCE CODE 1. I consent to the 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 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 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. § 4904 relating to unsworn falsification to authorities. DATE: l ACY M. CLARK ?'? ?? ?- ?} r - ??? ? ?• STACEY M. CLARK : IN THE COURT OF COMMON PLEAS PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 07-7397 CHRISTOPHER T. CLARK, : DIVORCE ACTION DEFENDANT AFFIDAVIT OF CONSENT 1. A complaint in divorce under § 3301(c) of the Divorce Code was filed on December 7, 2007. 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. 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 understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. /?$ 0 ?G-- DATE: CHRISTOPHER T. CLARK CAP c' . STACEY M. CLARK PLAINTIFF v. CHRISTOPHER T. CLARK, DEFENDANT : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY,1'ENNSYLVANIA : NO. 07-7397 : DIVORCE ACTION WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(c) AND § 3301(d) OF THE DIVORCE CODE I consent to the 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 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 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. § 4904 relating to unsworn falsification to authorities. 31ala K? S??--"- - DATE: CHRISTOPHER T. CLARK ?'. ,?,- [7J .s" STACEY M. CLARK : IN THE COURT OF COMMON PLEAS PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 07-7397 CHRISTOPHER T. CLARK, : DIVORCE ACTION DEFENDANT . PRAECIPE TO TRANSMIT 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) of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the complaint: Acceptance of Service dated December 17, 2007. 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 March 18, 2008, by defendant Marh 18, 2008. (b) (1) Date of execution of the affidavit required by § 3301 (d) of the Divorce Code: August 9, 2006. (2) (a) Date of filing of Plaintiff's affidavit upon respondent: (b) Date of service of Plaintiff's affidavit upon respondent: 4. Related claims pending: None, all claims resolved by Marital Settlement Agreement dated November 1, 2007. 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 plaintiff's Waiver of Notice in Divorce was filed with the Prothonotary: April 4, 2008. (c) Date defendant's Waiver of Notice in Divorce was filed with the Prothonotary: April 4, 2008. es G. Nealon, III, Esquire Attorney I.D. #46457 2411 North Front Street Harrisburg, PA 17110 (717) 232-9900 Dated: May 15, 2008 Attorney for Plaintiff z r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF aml- PENNA. STACEY M. CLARK PLAINTIFF VERSUS CHRISTOPHER T. CLARK DEFENDANT No. 07-7397 DECREE IN DIVORCE AND NOW, The- 3 , 2008 , IT IS ORDERED AND DECREED THAT AND CHRISTOPHER T. CLARK ARE DIVORCED FROM THE BONDS OF MATRIMONY. , PLAINTIFF, , DEFENDANT, 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 TERMS AND CONDITIONS OF A CERTAIN AGREEMENT DATED 11/1/2007, A COPY OF WHICH IS ATTACHED HERETO AND MADE. A PART HERROE, AND IN ACCORDANCE WITH SAID AGREEMENT, SHALL BE INCORPORATED INTO THE DECREE OF DIVORCE ENTERED BY THE COURT OF COMMON PLEAS OF CUMBERLA - ND COUSTY, PENNSYLVANIA. BY THE COURT: ATT E Y J PROTHONOTARY STACEY M. CLRK _ Aw --)Mt "W