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HomeMy WebLinkAbout07-7548 STEVEN D. GAYMAN, JR., Plaintiff V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION -LAW KYLIE R. ANDERSON, : NO. h?- 75gg CIVIL TERM Defendant 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 will proceed without you and a decree of divorce or annulment may be entered against you for any 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 Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania, 17013. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. TI-IIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Street Carlisle, Pennsylvania 17013 Phone: (717) 249-3166 or (800) 990-9108 STEVEN D. GAYMAN, JR., Plaintiff V. KYLIE R. ANDERSON, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW : NO. CIVIL TERM IN DIVORCE COMPLAINT IN DIVORCE NO FAULT 1. Plaintiff is Steven D. Gayman, Jr., an adult individual currently residing at 35 Roaring Creek Court, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Kylie R. Gayman, an adult individual currently residing at 315 Shed Road, Newville, Cumberland County, Pennsylvania. 3. Plaintiff is a bonafide resident of the Commonwealth of Pennsylvania and has been so for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on October 8, 2005 in Cumberland County, Pennsylvania. 5. There have been no other prior actions for divorce or annulment between the parties. 6. Neither the Plaintiff nor the Defendant are members of the United States Armed Forces or its Allies. 7. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling. 8. Plaintiff and Defendant are citizens of the United States of America. 9. The parties' marriage is irretrievably broken. 10. Plaintiff desires a divorce based upon the belief that the Defendant will, ninety (90) days from the date of service of this Complaint, consent to this divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a divorce pursuant to 23 P.S. Section 3301 (c) of the Domestic Relations Code. Respectfully submitted, !)k (I NN4 k '* -S12\X-Ift n - S A14411 A - Hannah Herman-Snyder, Esquire Attorney for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 VERIFICATION I verify that the statements made in the foregoing document 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: ,.2 O TEVEN D. MAN, J , Plaintiff co - ? 9 CFN L c STEVEN D. GAYMAN, JR., IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION -LAW KYLIE R. ANDERSON, NO. 07-7548 CIVIL TERM Defendant IN DIVORCE AFFIDAVIT OF SERVICE AND NOW, this 1!n day of , 2008, comes Hannah Herman-Snyder, Esquire, and states that she mailed a certified and true copy of a Complaint in Divorce to the Defendant, Kylie R. Anderson, at her address of 315 Shed Road, Newville, Pennsylvania, by certified mail, restricted delivery, return receipt requested. A copy of said receipt is attached hereto indicating service was made on December 19, 2007. Hannah Herman-Snyder, Es wire Attorney for Plaintiff GRIFFIE AND ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 Sworn and subscribed to before me this ) -4?e" day of 2008 NO ARY P LIC #AQfAR1At Ulm w J. &4"n Nato pubNt; t'NRA U BOROUGH. CU AINANO 1 M , Gonpnl " Eupk" Apt .1 ? r 261 I ?x r-l 4 Ut:H FIFIED MAIL F /Domestic f,"I'l Oniy: I L-., in O Postage $ Im ' C3 CeRiW Fee lEndoraementRegWredj ! ?? ?v?4ere Co C3 %*kW DOMMY Fee Postage ? ,ter ru Tow a 1%- Sent o I/ I n n uO°u uuul 5.848 8171. T`. -, rv p c.... ?, .? ? ? ?" ;. "? Chew # rn ? ? .. :'?y k ( i - .. f "`('": 1.;:. _ "C STEVEN D. GAYMAN, JR., Plaintiff V. KYLIE R. GAYMAN, Defendant TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07-7548 CIVIL TERM IN DIVORCE PRAECIPE Please amend the caption in the above case such that Defendant's name reads as Kylie R. Gayman, as reflected above, rather than Kylie R. Anderson as is currently, and mistakenly, set forth in the caption. Date: a tq - Ul Respectfully submitted, Hannah Herman-Snyder, Esq ire GRIFFIE AND ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 co CD r.? =c STEVEN D. CAYMAN, JR., Plaintiff V. KYLIE R. CAYMAN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07 - 7548 Civil Term IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on or about December 7, 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. 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: Kyli . Gayman, Defen nt WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 43301(c) AND 43301(d) OF THE DIVORCE CODE 1. 1 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 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: 1 /?a? Cog Kylie . Gayman, Defendant ? ? ?° ? ? -n -? } . . N c? ? , ;? ? ? c ?' ??; - -? ? = ? =, s? ? a r . ?? N -? ?. STEVEN D. GAYMAN, JR., IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION -LAW KYLIE R. GAYMAN, NO. 07-7548 CIVIL TERM Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on December 18, 2007, and service was made on December 19, 2007 by restricted delivery, certified mail. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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 -- - D. GAY ., Plaintiff ?"'=a ?? N,? <?,?, .- _?'?. c-.-. ? c. r:i ?` STEVEN D. GAYMAN, JR., Plaintiff V. KYLIE R. GAYMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 07-7548 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST THE ENTRY OF A DIVORCE DECREE UNDER 43301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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: ///XtVEN D. GAY , J K, Plaintiff S.al % ?r S ? 17rJ, _ ?? ?,•? . y STEVEN D. GAYMAN, JR., Plaintiff V. KYLIE R. GAYMAN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07 - 7548 Civil Term : IN DIVORCE MARRIAGE SETTLEMENT AGREEMENT THIS AGREEMENT, made this 9A4? day of kook ryib-e r 2008, by and between, KYLIE R. GAYMAN, of Newville, Cumberland County, Pennsylvania, hereinafter referred to as "WIFE", and STEVEN D. GAYMAN, JR., of Carlisle, Cumberland County, Pennsylvania, hereinafter referred to as "Husband"; WITNESSETH: WHEREAS, Husband and Wife were lawfully married on October 8, 2005, and; WHEREAS, there were no children born of this marriage; WHEREAS, disputes and difficulties have arisen between the parties and it is the intention of Husband and Wife to live separate and apart, and the parties desire to settle their respective financial property rights and obligations as between each other, including the settling of all matters between them relating to ownership and equitable distribution of real and personal property; the settling of all matters between them relating to the past, present, and future support, alimony, and/or maintenance of Husband or Wife; and in general, the settling of any and all possible claims by one against the other or against their respective estates; NOW THEREFORE, Husband and Wife, in consideration of the mutual promises, covenants and undertakings hereinafter set forth and for other good and valuable consideration, receipt of which is hereby acknowledged, and each intending to be legally bound, Husband and Wife hereby covenant and agree as follows: 1. FULL DISCLOSURE OF ASSETS. Each party warrants that he or she has made a full and fair disclosure of income, assets, and their valuation prior to the execution of this Agreement as well as any other fact relating to this agreement. These disclosures are part of the consideration made by each party for entering into this agreement. Each party agrees that he or she shall not, at any future time, raise as a defense, or otherwise, the lack of such disclosure in any legal proceedings involving this agreement, with the exception of disclosure that may have been fraudulently withheld. In the event that either party, at any time hereafter, discovers such a fraudulently withheld. In the event that either party, at any time hereafter, discovers such a fraudulently undisclosed asset, that party shall have the right to petition the Court of Common Pleas of Cumberland County to make equitable distribution of such asset. The non-disclosing party shall be responsible for payment of counsel fees, costs, or expenses incurred by the other party in seeking equitable distribution of such asset. 2. ADVICE OF COUNSEL. The Husband has employed and had the benefit of counsel of HANNAH HERMAN SNYDER, ESQUIRE as his attorney. The Wife has employed and had the benefit of having JANE ADAMS, ESQUIRE, as her attorney. Each party has carefully and completely read this agreement and has been advised and is completely aware not only of its contents but of its legal effect. Husband and Wife acknowledge that this agreement is not a result of collusion, improper or illegal agreements. 3. SEPARATION. The parties intend to maintain separate and permanent domiciles and to live apart from each other. Neither party shall harass, annoy, injure, threaten, or interfere with the other party in any manner whatsoever. Neither party shall interfere with the uses, ownership, enjoyment, or disposition of any property now owned and not specified herein or property hereafter acquired by the other. 4. SUBSEQUENT DIVORCE. The parties hereby acknowledge that HUSBAND has filed a Complaint in Cumberland County, Pennsylvania, claiming that the marriage is irretrievably broken under the no-fault mutual consent provision of Section 3301(c) of the Pennsylvania Divorce Code. The parties express their agreement that the marriage is irretrievably broken and express their intent to execute any and all affidavits or other documents necessary for the parties to obtain an absolute divorce pursuant to Section 3301(c) of the Divorce Code. The parties hereby waive all rights to request Court Ordered counseling under the Divorce Code. The provisions of this Agreement relating to equitable distribution of property of the parties are accepted by each party as a final settlement for all purposes whatsoever, as contemplated by the Pennsylvania Divorce Code. Should a decree, judgment, or order of separation or divorce be obtained by either of the parties in this or any other state, country or jurisdiction, each of the parties hereby consents and agrees that this Agreement and all of its covenants shall not be affected in any way by any such separation or divorce; and that nothing in any such decree, judgment, order, or further modification or revision thereof shall alter, amend, or vary any term of this Agreement, whether or not either or both of the parties shall remarry. It is specifically agreed that a copy of this Agreement or the substance of the provisions thereof, shall be incorporated by reference into any divorce, judgment, or decree. This incorporation shall not be regarded as a merger, it being the specific intent of the parties to permit this Agreement to survive any judgment and to be forever binding and conclusive upon the parties. 5. DATE OF EXECUTION. The "date of execution" or "execution date" of this agreement shall be defined as the date upon which it is executed by the parties if they have each executed the Agreement on the same date. Otherwise, the "date of execution" or "execution date" of this Agreement shall be defined as the date of execution by the party last executing this Agreement. All provisions of this agreement shall be effectuated by the parties within thirty (30) days of the execution date of this agreement unless otherwise specified within this agreement. 6. MUTUAL RELEASE OF ALL CLAIMS. Other than as provided in this agreement, each party may dispose his or her property in any way and each party hereby waives and relinquishes any and all rights he or she may now have or hereafter acquire under the present or future laws of any jurisdiction to share in the property or the estate of the other as a result of the marital relationship, including without limitation, statutory allowance, widow's allowance, right of intestacy, right to take against the will of the other, and right to act as administrator or executor in the other's estate. 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. 7. WARRANTY OF DEBTS AND FUTURE OBLIGATIONS. Each party warrants that they have not contracted any debt or liability for the other or which the estate of the other party may be responsible or liable, and except only for the rights arising out of this agreement, neither party will hereafter incur any liability whatsoever for which the other party or the estate of the other party, will be liable. Each party agrees to indemnify or hold harmless from the other and against all future obligations of every kind incurred by them. The parties agree as follows regarding the debts: (a) Wife agrees that the following debts are her own personal responsibility and therefore agrees to completely and finally pay on the following debts and obligations. Any and all debts in her name alone or incurred by her after separation. (b) Husband agrees that the following debts are his own personal responsibility and therefore agrees to completely and finally pay on the following debts and obligations. .M1 Any and all debts in his name alone or incurred by him after separation. (c) The parties will take any steps necessary to close any joint credit card accounts. 8. EQUITABLE DIVISION OF MARITAL PROPERTY. The parties have attempted to distribute their marital property in a manner which conforms to the criteria set forth in the Divorce Code at 23 Pa.C.S.A. §3501 et. seq. The division of existing marital property is not intended by the parties to constitute in any way a sale or exchange of assets, and the division is being effected without the introduction of outside funds or other property not constituting marital property. The division of property under this Agreement shall be in full satisfaction of all the marital rights of the parties. 9. BANKRUPTCY. The parties further warrant that they have not heretofore instituted any proceedings pursuant to the bankruptcy laws nor are there any such proceedings -pending with respect to them which have been. initiated by others. It is stipulated and agreed by the parties that the terms of this Agreement as they resolve the economic issues between the parties incidental to their divorce and the obligations of the parties to each other resulting therefrom shall not be dischargable in bankruptcy, should either party file for protection under the Bankruptcy Code at any time after the date of execution of this Agreement. Should Husband or Wife pursue an action in bankruptcy and be successful in extinguishing his or her obligation to pay any debts for which he or she had taken sole obligation as set forth herein, he or she shall immediately be obligated to pay alimony to the other party in an amount equal to the monthly obligation on such debts that he or she otherwise had assumed and for which he or she had taken sole obligation and responsibility, plus an additional fifteen percent (15%) in consideration of the tax consequences associated with receipt of alimony. 10. OTHER PERSONAL PROPERTY. Husband and Wife do hereby acknowledge that they have previously divided all their tangible personal property. Except as may otherwise be provided in this Agreement, Wife agrees that all of the tangible personal property in Husband's possession shall be the sole and separate property of Husband; and Husband agrees that all of the tangible personal property in Wife's possession shall be the sole and separate property of Wife. Both parties agree that intangible personal property, including retirement benefits, shall remain the individual property of the registered or titled owner, unless otherwise provided in this agreement. The parties do hereby specifically waive, release, renounce, and forever abandon whatever claim, if any, he or she may have with respect to the above items which shall become the sole and separate property of the other. 11. VEHICLES. With respect to these items, owned by one or both of the parties, each party shall retain the respective vehicles in their possession. The titles to the said motor vehicles shall be executed by the parties, if appropriate for effecting transfer as herein provided, within thirty days of the execution date of this Agreement, and said executed titles shall be delivered to the proper parties on the distribution date. Each party agrees to be solely responsible for the amounts presently due and owing against his or her respective automobiles. 12. REAL ESTATE: The parties hold joint title as tenants by the entireties to a property known as 315 Shed Road, Newville, Cumberland County, Pennsylvania, 17241, which was purchased during the parties' marriage. Regarding this property, the parties agree as follows: (a) Husband hereby waives all his right, title, and interest in and to the property and Wife shall have sole and exclusive possession of this property as of the date of this agreement. Within fourteen (14) days of this agreement, Husband shall sign a Deed to the marital home in favor of Wife, whereby he waives all right, title, and interest in the marital home. (b) Wife has applied to refinance the loan obligation on the marital home. Upon Wife being approved for refinancing of the mortgage obligation on the marital home in her name alone, Husband's attorney shall release the Deed to be recorded, on or before the date of settlement of the loan, as the mortgage company requires. The parties shall cooperate with any other requirements of the mortgage company. Wife shall bear all costs of refinancing, preparation and filing of the Deed. Wife shall finalize the refinance within sixty (60) days of execution of this agreement. (c) As of the date of separation, and without regard to when bills for such items are incurred, received or due, WIFE shall be solely responsible for all past, present, and future costs or liabilities associated with or attributable to maintaining the residence (except as provided herein), including but not limited to, all real estate taxes, water and sewer rents, gas, electric, and telephone service, homeowner's insurance, and gardening expenses and repairs, and WIFE shall keep HUSBAND and his successors, assigns, heirs, executors, and administrators indemnified and held harmless from any liability, cost or expense, including attorney's fees, which are incurred in connection with such maintenance, costs, and expense. 13. MUTUAL WAIVER OF EMPLOYMENT BENEFITS. The parties agree to waive any and all rights they have in and to each other's employment benefits, including but not limited to both parties IRA's, 401(k)'s, stock savings plans, pensions, and retirement plans and Incentive Savings Plans. The parties agree never to assume any claim to such benefits of the other at any time in the future. 14. ALIMONY, ALIMONY PENDENTE LITE and LEGAL FEES. Each party hereby waives any right to spousal support, alimony, or alimony pendente lite, counsel fees and costs, and each party agrees to be responsible for his or her own legal fees and expenses. The parties herein acknowledge that by this Agreement, they have respectively secured and maintained a substantial and adequate fund with which to provide for themselves sufficient financial resources to provide for their comfort, maintenance, and support in the station of life to which they are accustomed. 15. TAXES. The parties have previously filed joint State and Federal Tax returns. The parties intend on filing separately from 2008 forward. Transfers of property pursuant to this Agreement are transfers between Husband and Wife incident to their divorce and as such are non-taxable, with no gain or loss recognized. The transferee's basis in the property shall be the adjusted basis of the transferor immediately before the transfer. The transfers herein are a division of marital property for full and adequate consideration and as such will not result in any gift tax liability. 16. RECONCILIATION; WAIVER OR MODIFICATION TO BE IN WRITING. No modification or waiver of any of the terms hereof shall be valid unless in writing and signed by both parties, and no waiver of any breach hereof or default hereunder shall be deemed a waiver of any subsequent default of the same or similar nature. Notwithstanding reconciliation between the parties, this agreement shall continue to remain in full force and effect absent a writing signed by the parties stating that this Agreement is null and void. 17. MUTUAL COOPERATION. Each party shall, at any time and from time to time hereafter, take any and all steps and execute, acknowledge, and deliver to the other party any and all further instruments and/or documents that the other party may reasonably require for the purpose of giving full force and effect to the provisions of this Agreement. 18. APPLICABLE LAW. The Agreement shall be construed in accordance with the laws of the Commonwealth of Pennsylvania which are in effect as of the date of execution of this Agreement. i +t 19. INTEGRATION. This Agreement constitutes the entire understanding of the parties and supersedes any and all prior agreements or negotiations between them. There are no representations or warranties other than those expressly set forth herein. 20. OTHER DOCUMENTATION. Wife and Husband covenant and agree that they will forthwith execute any and all written instruments, assignments, releases, satisfactions, deeds, notes, or such other writings as may be necessary or desirable for the proper effectuation of this Agreement. 21. NO WAIVER OF DEFAULT. This Agreement shall remain in full force and effect unless and until terminated under and pursuant to the terms of this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall in no way affect the right of such party hereafter to enforce the same, nor shall the waiver of any default or breach of any provision hereof by construed as a waiver of any subsequent default or breach of the same or similar nature, not shall it be construed as a waiver or strict performance of any other obligations herein. 22. SEVERABILITY. If any term, condition, clause, or provision of this Agreement shall be determined or declared to be void or invalid in law or otherwise, then only that term, condition, clause, or provisions shall be stricken from this Agreement; and in all other respects, this Agreement shall be valid and continue in full force, effect, and operation. Likewise, the failure of any party to meet his or her obligations under any one or more of the paragraphs herein, with the exception of the satisfaction of the conditions precedent, shall in no way avoid or alter the remaining obligations of the parties. 23. 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 for such breach, or seek other remedies or relief as may be available to him or her, and the party breaching this contract shall be responsible for payment of reasonable legal fees and costs incurred by the other in enforcing their rights under this agreement. 24. INFORMED AND VOLUNTARY EXECUTION. Each party to this agreement acknowledges that he or she is fully informed as to the facts relating to the subject matter of this agreement, is entering into this agreement voluntarily, free from fraud, undue influence, coercion or duress of any kind, has given careful thought to the making of this agreement, has carefully read each provision of this agreement, and fully and completely understands each provision of this agreement. IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the day and year first above written: WITNESS: Ja/p Adams, Esquire 1 . South St. lisle, Pa. 17013 (717) 245-8508 Attorney for Wife ?. . Ira Vni ' ? Q -s l41 f1 Hannah Herman Snyder, Esq ire 200 N. Hanover St. Carlisle, Pa. 17013 (717) 243-5551 Attorney for Husband 4 V'w- & 4 a4"'L r Kylie R. Gayman, Wife Date: (1);g14% I teven D. Gay n, r., Husban Date: //?? 0101f F`i ? ij ??_r. ??-?'? ?? r "'r'1 am„ ?,,? ? ? `? ? / rtRt ?r VY /?_ ?'1M ? `? i ti ';???s i...-? `y ,__. ???{ ~ ;? .? t° .Y ?" (`r`5 STEVEN D. GAYMAN, JR., Plaintiff V. KYLIE R. GAYMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION -LAW NO. 07-7548 CIVIL TERM IN DIVORCE 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) 3301(d)(1) of the Di,,,er-ee Gede. (Strike out inapplicable section). 2. Date and manner of service of the Complaint: by certified mail, restricted delivery on December 19, 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: November 24, 2008 by Defendant: November 24, 2008 (b) (1) Date of execution of the affidavit required by §3301 (d) of the Divorce Code: (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: November 25, 2008 Date defendant's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: November 25, 2008 W ft r. -a &_ jM br?_wn" - wear i? Hannah Herman-Snyder, Esquire GRIFFIE & ASSOCIATES Attorney for Plaintiff C3 ti co IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Steven D. Gayman, Jr. V. Kylie R. Gayman No. 07-7548 CIVIL TERM DIVORCE DECREE AND NOW, r??it is ordered and decreed that Steven D. Gayman, Jr. , plaintiff, and Kylie R. Gayman , 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.") N C.-VX-0-- The parties' Property Settlement Agreement entered into on November 24, 2008 is incorporated herein, but not merged. B e Court, Attest: J P thonotary Pv iz /ar-v-w;p"v --7vT w: