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HomeMy WebLinkAbout03-6057KAREN L. GREEN-STINE, Plaintiff VS. .' MARK A. STINE, : : Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE NO. 2003- ~,,,O~"7' CIVIL TERM 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 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 mardage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, Carlisle, Pennsylvania, 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DECREE OF 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 BEDFORD STREET CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA SAIDIS, SHUFF, FLOWER & LINDSAY Attorney, s foEPlaintiff ~ By:~ --'// Carpf~}~ir~dsay, #squire 11:;~4~93 26 West High Street Carlisle, PA 170'13 (717) 243-6222 KAREN L. GREEN-STINE, Plaintiff VS. ., MARK A. STINE, .' : Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION- DIVORCE NO. 2003- ~.,~,~'~7 CIVIL TERM IN DIVORCE COMPLAINT SAIDIS SHUFF, FLOWER & LINDSAY 26 w. High Streel Carlisle, PA KAREN L. GREEN-STINE, Plaintiff, by attomeys, SAIDIS, SHUFF, FLOWER & LINDSAY, respectfully represents: 1. The Plaintiff is KAREN L. GREEN-STINE, who currently resides at 765 Old Silver Spdng Road, Mechanicsburg, Cumberland County, Pennsylvania, 17055 where she has resided since March of 1999. 2. The Defendant is MARK A. STINE, who currently resides at 528 Enola Road, Apt. #A, Enola, Cumberland County, Pennsylvania, 17025 where he has resided since September, 2003. 3. The Plaintiff and Defendant both have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately pdor to the filing of this Complaint. 4. The Plaintiff and Defendant were married on October 24, 1998, at Clearfield, Pennsylvania. 5. That there have been no prior actions of divorce or for annulment between the parties in this or in any other jurisdiction. 6. The Plaintiff avers that she is entitled to a divorce on the ground that the marriage is irretrievably broken and Plaintiff is proceeding under Sections 3301 (c) and/or (d) of the Divorce Code. 7. Plaintiff has been advised of the availability of mardage counseling and of the right to request that the Court require the parties to participate in marriage counseling, and does not request counseling. WHEREFORE, Plaintiff requests the Court to enter a decree of divorce. Date: SAIDIS, SHUFF, FLOWER & LINDSAY, P.C. Attorneys for Plaintiff Carol O. Lindsay,.j;l:squire ID # 44693 26 West High Street Carlisle, PA 17013 (717) 243-6222 SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA KAREN L. GREEN-STINE, Plaintiff VS. MARK A. STINE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE NO. 2003 - CIVIL TERM IN DIVORCE VERIFICATION I, the undersigned, hereby verify that the statements made herein 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. ~,aren L. Green-Stine, Plaintiff SAIDIS SHUFF, FLOWER & LINDSAY 26 w, High Street Carlisle, PA LAW OFFICES SAIDIS, SHUFF, FLOWER & LINDSAY 26 w. HIGH STREET 2109 MARKET STREET CARLISLE, PA 170~3 CAMP HILL, PA 170Il PHONE (717) 243-6222 PHONE (717) 737-3405 CERTIFIED COPY: KAREN L. GREEN-STINE , VS. MARK A. STINE, Plaintiff De~ndant INTHECOURTOFCOMMONPLEASOF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE NO. 2003 - : ~'-57 CIVIL TERM IN DIVORCE ,-,_._~,.,,.-, , A~CE OF SERVICE I, MARK A. STINE, Defendant above, accept service of the Complaint in Divorce in the above captioned matter. Date Mark A. Stine, Defendant SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA PROPERTY SETTLEMENT AND SEPARATION AGREEMENT THIS AGREEMENT made this /~ day of _(~-J~o~. , 2003, BETWEEN Mark A. Stine, of 528 Enola Road, Apartment A, Enola, PA 17025, Cumberland County, Pennsylvania, hereinafter referred to as Husband, AND Karen L. Green-Stine, of 765 Old Silver Spring Road, Mechanicsburg, Cumberland County, Pennsylvania 17055, hereinafter referred to as Wife. RECITALS: R.'I: The parties hereto are husband and wife, having been joined in marriage on October 24, 1998, in Clearfield, Pennsylvania; and R.2: The parties hereto desire to settle fully and finally their respective financial and property rights and obligations including, but not limited, of all matters between them relating to the ownership of real and personal property, claims for spousal support, alimony, alimony pendente lite. R3: The parties desire to settle their issues counsel fees and costs, and the settling of any and all claims and possible claims against the other or against their respective estates. NOW THEREFORE, in consideration of the covenants and promises hereinafter to be mutually kept and performed by each party, as well as for other good and valuable consideration and intending to be legally bound, it is agreed as follows: (1) SEPARATION: It shall be lawful for each party at all times hereafter to live separate and apart from the other party at such place or places as he or she from time to time may choose or deem fit, free from any control, restraint or SAIDIS SHUFF, FLOWER & LINDSAY ATfORNEYS*AT*LAW 26 W. High Street Carlisle, PA interference from the other. Neither party will molest the other or endeavor to compel the other to cohabit or dwell with him or her by any legal or other proceeding. Each party shall be free of the interference, authority or contact by the other as if he or she was single and unmarried except as maybe necessary to carry out the terms of this agreement. (2) DIVORCE: The parties acknowledge that the marriage is irretrievably broken and that they will secure a mutual consent no-fault divorce decree in the above-captioned divorce action, and will execute and file the necessary documents to finalize the divorce after the expiration of ninety (90) days of the service of the Complaint and the moving party shall move for the entry of the divorce decree at that time. (3) REAL PROPERTY: Husband is the owner of certain marital real estate with improvements thereon erected and known and numbered as 765 Old Silver Spring Road, Mechanicsburg, Pennsylvania. On the date of this Agreement, Husband shall transfer to Wife all his right, title and interest in the marital home by executing a special warranty deed. Within thirty (30) days Wife shall obtain a release from Husband's obligation from the parties' lender, or in the alternative, will refinance the marital home so that Husband is no longer liable thereon. Wife shall pay for all household expenses including, but not limited to, mortgages and liens of record, utility bills, insurance and real estate taxes in connection with said property. With regard to all such expenses, Wife hereby shall hold Husband harmless and indemnify him from any loss thereon. SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA (4) DEBT: A. Marital Debt: Husband and Wife acknowledge and agree that each has incurred debt in his or her individual names and that there is no joint debt or other debt incurred by one party for which the other might be liable. The parties hereto agree that they will pay all debts incurred in their own names and shall indemnify and hold the other harmless against any such debt. B: Post Separation Debt: In the event that either party contracted or incurred any debt since the date of separation on August, 31, 2003, the party who incurred said debt shall be responsible for the payment thereof regardless of the name in which the debt may have been incurred. C: Future Debt: From the date of this agreement neither party shall contract or incur any debt or liability for which the other party or his or her property or estate might be responsible and shall indemnify and save the other party harmless from any and all claims or demands made against him or her by reason of debts or obligations incurred by the other party. (i) Notwithstanding the above, the parties will equally split the costs of any medical treatment that is required for their dog including the hip replacement or, if it should be determined that such intervention will not avail, then the cost of putting the dog down. The parties will share the costs for medical treatment for the dog equally. (5) MOTOR VEHICLES: Each party relinquishes any right, title and interest 3 SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA he or she may have to any and all motor vehicles currently in possession of the other party. Within ten (10) days of the date of this agreement each party shall execute any documents necessary to have said vehicles properly registered in the other party's name with the Pennsylvania Department of Transportation. Each party shall assume full responsibility of any encumbrance on the motor vehicle received by said party, and shall hold harmless and indemnify the other party from any loss thereon. In particular, Wife will retain the 1994 Chrysler Concorde and Husband will retain the 1998 Ford F150 Extended Cab and the 2-ee3'Yamaha motorcycle. (6) TANGIBLE PERSONAL PROPERTY: The parties hereto mutually agree that they have effected a satisfactory division of the furniture, household furnishings, appliances, tools and other household personal property between them, and they mutually agree that each party shall from and after the date hereof be the sole and separate owner of all such property presently in his or her possession whether said property was heretofore owned jointly or individually by the parties hereto. This agreement shall have the effect of an assignment or bill of sale from each party to the other for such property as may be in the individual possession of each of the parties hereto. Attached hereto, as Exhibit "A" is a list of personal property, which shall be exclusively Husband's, and a list of personal property that shall be exclusively Wife's. Husband may store his personal property at wife's residence but must make arrangements with wife to remove the property by July 31, 2005. Husband's failure to remove the property by that date shall be considered an abandonment of the property and wife shall have the right to retain or dispose of it. SAIDIS SHUFF, FLOWER & LINDSAY 26W. High Street Carlisle, PA (7) INTANGIBLE PERSONAL PROPERTY: Each party hereby relinquishes any right, title or interest he or she may have in or to any intangible personal property currently titled in the name of or in the possession of the other party, including, but not limited to, stocks, bonds, insurance, bank accounts, individual retirement accounts, employment benefits including retirement accounts, savings plans, pension plans, stock plans, 401K plans and the like. Listed on Exhibit "A" is also intangible personal property to be retained by each party. (8) ALIMONY: HUSBAND agrees to pay to WIFE as alimony the sum of $600 per month commencing August 2003 and continuing in equal amounts on the same day of the month as the first payment is made for twenty-four (24) months. The payments shall terminate upon the death of Husband or the death of WIFE. The parties acknowledge that they know one another's Social Security Number. Alimony payments shall be deductible from Husband's gross in come for the purpose of filing federal income tax returns and includible in Wife's gross income for the same purpose. The alimony payments set out herein shall be paid directly by husband to wife. In the event husband fails to make the payment as set out herein, wife may have the obligation entered as a Court Order to the Office of Domestic Relations of Cumberland County or of a county having jurisdiction over husband. (9) ADVICE OF COUNSEL: The parties hereto acknowledge that each has been notified of his or her right to consult with counsel of his or her choice, and 5 SAIDIS SHUFF, FLOWER & LINDSAY Carlisle, PA have been provided a copy of this agreement with which to consult with counsel, Wife is represented by Carol J. Lindsay, Esquire and Husband has been advised that he may be represented by counsel of choice. Each party acknowledges and accepts that this agreement is, under the circumstances, fair and equitable, and that it is being entered into freely and voluntarily after having received such advice and with such knowledge as each has sought from counsel, and the execution of this agreement is not the result of any duress or undue influence, and that it is not the result of any improper or illegal agreement or agreements. Each party shall pay his or her own attorney for all legal services rendered or to be rendered on his or her behalf. The parties shall equally share in the expenses incurred by Wife in filing for divorce and the preparation of this Madtal Settlement Agreement, including her attorney's fees in those regards. Any attorney's fees incurred by Wife in the obtaining of a release of Husband's obligation on the Mortgage shall be the sole responsibility of Wife. (10) 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 may be reasonably required to give full force and effect to the provisions of this Agreement. (11) INCOME TAX: The parties have heretofore filed joint Federal and State Tax returns. Both parties agree that in the event any deficiency in Federal, state or local income tax is proposed, or assessment of any such tax is made against either of them, each will indemnify and hold harmless the other from and against any loss or liability for SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA any such tax deficiency or assessment and 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 the cause of the misrepresentations or failures to disclose the nature and extent of his or her separate income on the aforesaid joint returns. (12) BANKRUPTCY: The parties hereby agree that the provisions of this Agreement shall not be dischargeable in Bankruptcy and expressly agree to reaffirm any and all obligations contained herein. In the event a party files such bankruptcy and pursuant thereto obtains a discharge of any obligations assumed hereunder, the other party shall have the right to declare this Agreement to be null and void and to terminate this Agreement in which event the division of the parties' marital assets and all other rights determined by this Agreement including alimony shall be subject to court determination the same as if this Agreement had never been entered into. (13) COMPLETE DISCLOSURE: The parties do hereby warrant, represent, acknowledge and agree that each is fully and completely informed of, and is familiar with, the wealth, real and personal property, estate and assets, earnings and income of the other and has made any inquiry, he or she desires into the income or estate of the other and received any such information requested. Each has made a full and complete disclosure to the other of his and her entire assets, liabilities, income and expenses and any further enumeration or statement thereof in this Agreement is specifically waived. (14) RIGHTS AND RESPONSIBILITIES: Husband and Wife acknowledge SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street that each of them has read and understand his and her rights and responsibilities under this Agreement and that they have executed this Agreement under no compulsion to do so but as a voluntary act. (15) FULL SETTLEMENT: Except as herein otherwise provided, each party hereby releases the other from any and all claims, or demands up to the date of execution hereof. It is further specifically understood and agreed by and between the parties hereto that each party accepts the provisions herein made in lieu of and in full settlement and satisfaction of any and all of said party's rights against the other for past, present and future claims on account of support, maintenance, alimony, alimony pendente /~te, counsel fees, costs and expenses, equitable distribution of madtal property and any other claims of the party, including all claims which have been raised or may be raised in an action for divorce. (16) RELEASE OF ALL CLAIMS: Except as may be otherwise specifically provided in this Agreement, Husband and Wife, for themselves, their heirs, representatives and assigns, each hereby forever releases, remises, discharges and quitclaims the other, and such other's heirs, representatives, assigns and estate, from and with respect to the following: A. All liability, claims, causes of action, damages, costs, contributions and expenses or demands whatsoever in law or in equity; B. All rights, title, interest or claims in or to any property of the other, whether real, personal or mixed and whether now owned or hereafter acquired; C. All rights of courtesy and dower and all claims or rights in the SAIDIS SHUFF, FLOWER & LINDSAY 26 W, High Street Carlisle, PA nature of courtesy and dower; D. E. All widow or widower's rights; All right, title, interest or claim in or to the other's estate, whether and (4) (1) to take against the other's will; (2) under the laws of intestacy; (3) to a family exemption or similar allowance; deceased spouse's estate in any way, whether arising under the Pennsylvania or any other country, territory, state or political subdivision. F. All dghts or claims to any accounting; all other rights or authority to participate or intervene in a laws of G. All dghts, claims, demands, liabilities and obligations arising out of or in connection with the madtal relationship or the joint ownership of property, whether real, personal or mixed; H. All rights, claims, demands, liabilities and obligations adsing under the provisions of the Pennsylvania Divorce Code, as the same may be amended from time to time, and under the provisions of any similar statute enacted by any other country, state, territory or political subdivision; i. All rights, claims, demands, liabilities and obligations each party now has, or may hereafter have, against or with respect to the other. (17) GOVERNING LAW: This Agreement shall be construed under the law now owned or hereafter acquired, including but not limited to all rights or claims: SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA of the Commonwealth of Pennsylvania. If any provision of this Agreement is determined to be invalid or unenfomeable, all other provisions shall continue in full rome and effect. (18) INCORPORATION INTO DECREE: In the event that either of the parties shall recover a final judgment or decree of absolute divorce against the other in a court of competent jurisdiction, the provisions of this Agreement may be incorporated by reference or in substance but shall not be merged into such judgment or decree and this Agreement shall survive any such final judgment or decree of absolute divorce and shall be entirely independent thereof. (19) BREACH: In the event that either party breaches any provision of this Agreement, he or she shall be responsible for any and all costs incurred to enforce the Agreement, including, but not limited to, court cost and counsel fees of the other party. In the event of breach, the other party shall have the right, at his or her election; to sue for damages for such breach or to seek such other and additional remedies as may be available to him or her. (20) ENTIRE UNDERSTANDING: This Agreement constitutes the entire understanding between the parties and there are no covenants, conditions, representations, or agreements, oral or written, of any nature whatsoever, other than those herein contained. (21) AGREEMENT BINDING ON PARTIES AND HEIRS: This Agreement shall bind the parties hereto, their respective heirs, executors and assigns. IN WITNESS WHEREOF, the parties hereto intending to be legally bound 10 SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Slreet Carlisle, PA have hereunto set their hands and seals the day and year first written above. WITNESS: ~l~rk A. Stine Kamn L. ~men-Stina COMM OF PA ~. ss COUNTY OF CUMB J swo~k~ F~FO~E ME ON.Jt~.O~,~O0~ 13_ Karen's Possession's Living room couch and chair All coffee and end tables in living room T.V. stand Cherry dining room table Buffet and china cabinet All major appliances (refrigerator, stove, dishwasher, deep freeze) Microwave with cart Micron 866 Mhz PC, HP pdnter and Flatbed scanner 1 queen sized bed with frame Master bedroom furniture 1994 Chrysler Concord GE water cooler 19" Magnavox t.v. 19" Montgomery Ward t.v. DVD Player VCR's (2) All cordless phones KitchenAid hand mixer Leaf blower/vac Bissel carpet cleaner Washer and dryer Total Gym Kenmore humidifier Garden hose and reel Deck/porch furniture Gas gdll Sewing machine 401k in Karen's name All AmedChoice FCU accounts in Karen's name All Vartan Bank accounts in Karen's name All Commerce Bank accounts in Karen's name All Members ls FCU accounts in Karen's name All Integrity Bank accounts in Karen's name Commerce Bank stock EXHIBIT "A' Mark's Possessions: Gun Safe with all guns and ammunition Recliner 32" JVC t.v. 19" t.v. with DVD player I queen size bed with frame Camp 9-C-741 1998 Ford F-150 2002 Yamaha V-Star Craftsman air compressor KitchenAid stand mixer with attachments Power tools Hand tools Chain saw 8 foot Warner stepladder Love seat in basement 3 drawer white dresser Sony camcorder 401k in Mark's name All PSECU accounts in Mark's name All Members 1St accounts in Mark's name EXHIBIT "A" SAIDIS SHUFF, FLOWER & LINDSAY ATTORNEYS*AT*LAW 26W. High Street Carlisle, PA KAREN L. GREEN-STINE, Plaintiff VS. : : MARK A. STINE, : : Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE NO. 2003 - 6057 CIVIL TERM IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT UNDER §3301(c) OF THE DIVORCE CODE AND WAIVER OF COUNSELING 1. A Complaint in Divorce under {}3301 (c) of the Divorce Code was filed November 19, 2003. -r~.-,,,~ marriage of plaintiff, and defendant is irretrievably broken a~d r,i~ety days have elapsed from the date of filing and service of the Complaint. I consent to the entry of a final Decree in Divorce after service of notice of intention to request entry of the Decree. I verif~ that the statements made in this Affidavit are true and correct to the best of 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 unswom falsification to authorities. Date: Karen L Gre'b'~-Stine PLAINTIFF'S 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. 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 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 veri~ that the statements made in this Affidavit are true and correct to the best of 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 unswom falsification to authorities Date: Karen L. Green-Stine- SAIDIS SHUFF, FLOWER & LINDSAY 26 w. High Street Carlisle, PA KAREN L. GREEN-STINE, Plaintiff VS. MARK A. STINE, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : .. . : CIVIL ACTION - DIVORCE : NO. 2003 - 6057 CIVIL TERM : : IN DIVORCE Defendant : DEFENDANT'S AFFIDAVIT OF CONSENT UNDER §3301(c) OF THE DIVORCE CODI= AND WAIVER OF COUNSELING A Complaint in Divorce under §3301 (c) of the Divome Code was filed November 19, 2003. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. I consent to the entry of a final Decree in Divome 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 to the best of 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. Date: O~,,~ f..,q,/~ t ~(~JO (-/ ' ~ ~ark'A. Stine DEFENDANT'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 3301 lc) OF THE DIVORCE CODF 1. I consent to the entry of a final Decree of Divorce without notice. 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 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 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 Date: ,~J/.,~__~ / I t Mark A. Stine FEB ~ '~ ~00~ SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA KAREN L. GREEN-STINE, Plaintiff VS, MARK A. STINE, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - DIVORCE : NO. 2003 - 6057 CIVIL TERM : :IN DIVORCE : pR~ECIpE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section 3301(c) 3301(d)(I) of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the complaint: Defendant was served via Acceptance of Service signed by Mark A. Stine on November 21, 2003 and filed with Prothonotary on December 11,2003. (copy enclosed) 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 the Plaintiff Feb.27/04; by the Defendant Feb 26/04. Related claims pending: None: Resolved by Marital Propert.v Sefflement and ~ep~mtion A_oreement dated October 6. 2003. 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 3301(c) Divorce was filed with the Prothonotary: /'/~'( ~/O~/ Date Defendant's Waiver of Notice in 3301(c) Divorce was filed with the Prothonotary: Alu( .,~,/'(Y-F'~ '- /'.~ /? Ca~rJ. Lihd'~/~, ]Es~ui-re ~. Supreme C ~ ~o~_.~.lo 44693 Saidis, Shuff, Flower & Lindsay 26 West High Street Carlisle PA 17013 Phone: 717.243.6222 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. KAREN L. GREEN-STINE Plaintiff VERSUS MARK A. STINE Defendant NO. 2003 - 6057 DECREE IN DIVORCE AND NOW, DECREED THAT AND Karen L. Green-Stine Mark A. Stine IS ORDERED AND PLAINTIFF, 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; None: The terms of the marital settlement agreement of O~tober 6th, 2003 are incorporated but not merged into the Decree in Divorce. ATTEST: PROTH ONOTAF~Y SAIDIS SHUFF, FLOWER & LINDSAY 26W. High Street Carlisle, PA KAREN L. GREEN-STINE, Plaintiff VS. MARK A. STINE, Defendant :IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA :CIVIL ACTION - LAW : :NO. 2003-6057 :IN DIVORCE NOTICF OF INTI::NTION TO RF. fiLI[~j~[= PRiCeR NAMe= NOTICE IS HEREBY GIVEN that, Karen L. Green-Stine, the Plaintiff in the March 11, 2004 above matter, having been granted a Final Decree in Divorce on^ hereby intends to resume and hereafter use the previous name of KAREN GREEN, and gives this written notice avowing her intention in accordance with the provisions of the Act of April 2, 1980, P.L., 23 P.S. 702, effective July 1, 1980. Karen Green-Stine, Petitioner TO BE KNOWN AS: KAREN GREEN SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High $1reet Carlisle, PA KAREN L. GREEN-STINE, Plaintiff VS. MARK A. STINE, Defendant :IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA :CIVIL ACTION - LAW : :NO. 2003-6057 :IN DIVORCE ON this, the ~7 day of F'~b,-u,~, ,2004, before me, a Notary Public, personally appeared, known to m'~ or satisfactory proven to be the person whose name is subscribed to the within instrument and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. ~ Notary Public ~OMMONWEALTH OF PENNSYLVANIA / ~ May Nat~s. Notary ~ub~c ~m~r, Penna~vania ~,~ation