Loading...
HomeMy WebLinkAbout08-02291 LOIS I. SHEARER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. v; l Tear., MICHAEL SHOFF, Defendant IN DIVORCE NOTICE TO DEFEND 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 the Cumberland County Court House, Carlisle, Pennsylvania. 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 South Bedford Street Carlisle, PA 17013 717-249-3166 Respectfully submitted, SAIDIS, FLOWER & LINDSAY FLOWER & LIlVDS" 1 26 West High Street Carlisle, PA By ` 6 ou Matas,-Esquire Su me Court ID # 84919 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff LOIS I. SHEARER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vi. CIVIL ACTION - LAW NO. 0,. ,Z 2 9 Ccuz l 7-- MICHAEL SHOFF, Defendant IN DIVORCE COMPLAINT IN DIVORCE NO FAULT 1. Plaintiff is Lois I. Shearer, an adult individual currently residing at 215 Hempt Road, Mechanicsburg, Cumberland County, Pennsylvania 17050. 2. Defendant is Michael Shoff, an adult individual currently residing at 215 Hempt Road, Mechanicsburg, Cumberland County, Pennsylvania 17050. 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 February 2, 2002, in Cumberland County, Pennsylvania. 5. There has been no other prior action for divorce or annulment between the parties. FLOWER ? LINDSAY 26 West High Street Carlisle, PA 6. Plaintiff is not a member of the United States Armed Forces or its Allies. Defendant is a member of the United States Air National Guard, 193rd Unit, but is not presently deployed. He is advised of his rights under Soldiers' and Sailors' Civil Relief Act. 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, c Ma a as, Esquire J ire Attorne No. 84919 Attorney for Plaintiff 26 West High Street Carlisle, PA 17013 (717) 243-6222 IS, ? FLOWER WERR & LINDSAY 26 West High Street Carlisle, PA VERIFICATION I verify that the statements made in the foregoing document are true and correct. 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: ? OF of I. Shearer, Plaintiff SAIDIS, FLOWER & LINDSAY Mmxtvets•AMAW 26 West High Street Carlisle, PA JcA- Od r f . ? p A ? 0 c,., . -? p W .z= .? t i ? LOIS I. SHEARER, Plaintiff I v i MICHAEL SHOFF, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 08-229 IN DIVORCE AFFIDAVIT OF SERVICE I, Marylou Matas, Esquire, being duly sworn according to law, hereby deposes and says that on January 12, 2008 1 served a true and correct copy of a Divorce Complaint upon Michael A. Shoff, by mailing those documents to his address at 215 Hempt Road, Mechanicsburg, PA 17050 by Certified U.S. Mail, Restricted Delivery, Return Receipt Requested, as evidenced by the attached U.S. Postal Service Form 3811, Domestic Return Receipt, the latter of which is signed by the recipient, Michael A. Shoff. 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. Respectfully submitted, SAIDIS, FLOWER 8t LINDSAY FLOWER & LINDSAY 26 West High Street Carlisle, PA Dated: ; / Z z_/(- ? Marylou/ atas, Esquire ID No. 8 19 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff 4 ¦ Complete Items 1, 2, and 3. Also complete Rem 4 if Restricted Delivery Is desired. ¦ Print your name and address on the reverse so that we can return the cans to you. ¦ Attach this card to the back of the mailpiece, or on the front If space permits. 1. Article Addressed to: m?ckPr-el R, shoe ass 14-e mP-T Po Pd A. $ R Ule X ? Agent ? Addressee B. Rived j ,q(ame?,,/ Delivery D. Is delkery address different from It YES, enter delivery address _ ? rnCC?Rui[sljurq ©? I?O?O 3. Service IYPO /J l ? Express M ail ? Return Receipt for Merchandise ft,t?:al ? Insured Mail ? C.O.D. 4. Restricted Delivery? (Extra Fee) _ Vtyes 2. Article Number (rrvwwhomsWHoeAIW 7081 2518 0886 5868 2742_ PS Form 3811, February 2004 Domestic Return Receipt 102595-02-M-1540 r.. n ? ? .?. ?, ti i ?-+? i - J .' ?i .. .u?_?. .. _... ,, . _ ?`'+?f ?1 ? ? 'S. ? 1_,.... ?. i -_.. ± Y'" ? `_.. •-?? LOIS I. SHEARER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 08-229 MICHAEL A. SHOFF, Defendant IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT A Complaint in Divorce under § 3301(c) of the Divorce Code was filed January 11, 2008 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 in 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 to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the 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 SAIDIS, LE'-MAY 26 West High Street Carlisle, PA 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 unswon Dat . ?? rw.a _s ? : e`? ..? ;:.7 ?J -;.? ?+ f?a -? ?.? - (-~ ""' = -??- : ?,? ? r ,. ' ll:J ., 3 LOIS I. SHEARER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW NO. 08-229 MICHAEL A. SHOFF, Defendant IN DIVORCE PROPERTY SETTLEMENT AND SEPARATION AGREEMENT THIS AGREEMENT made this day of? , 2008, between Lois I. Shearer, of Mechanicsburg, Cumberland County, Pennsylvania, hereinafter referred to as Wife, and Michael A. Shoff, of Mechanicsburg, Cumberland County, Pennsylvania, hereinafter referred to as Husband. RECITALS: R.1: The parties hereto are husband and wife, having been joined in marriage on February 2, 2002, in Cumberland County, Pennsylvania; and R.2: A Complaint for Divorce has been filed in the Court of Common Pleas of Cumberland County, Commonwealth of Pennsylvania, to Number 2008-229, Civil Term; and R.3: 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. R4: The parties also desire to settle their issues of 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 1 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 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. If either party fails or refuses to execute and file the foregoing documents, said failure or refusal shall be considered a material breach of this Agreement and shall entitle the other party at his or her option to terminate this Agreement. (3) REAL PROPERTY: Wife is the owner of certain real estate with improvements thereon erected and known and numbered as 215 Hempt Road, Mechanicsburg, Cumberland County, Pennsylvania 17050. Husband has waived all right, title, claim or interest to the property, including, but not limited to, any right, title, claim or interest arising from curtsey, the right to request equitable distribution and any and all rights arising by reason of marriage. A copy of husband's executed Subordination of Marital 2 Rights dated August 15, 2003, is attached hereto and incorporated herein as Exhibit "A". (4) DEBT: A. Marital Debt: Husband and Wife acknowledge and agree that there are no other outstanding debts and obligations which are marital or for which the other might be liable incurred prior to the signing of this Agreement, except as follows: Members 1St credit card with an approximate balance of $1,200. ii. AmeriChoice F.C.U. Visa with an approximate balance of $3,300. iii. Home Depot credit card with an approximate balance of $400. Wife shall pay the obligations to the creditors listed in subparagraph A. L, ii. and iii. by making timely monthly payments in at least the minimum amount required by the creditors until paid in full. 2: Husband shall pay any outstanding obligations to any creditors for which he is individually obligated. 3: Husband and wife have not identified other marital obligations or other obligations for which the other party might be liable. Each party shall continue to maintain responsibility for all other debts in their names individually and further agrees to indemnify and save harmless the other from any and all claims and demands made against either of them by reason of such debts or obligations. B: Post Separation Debt: In the event that either party contracted or incurred any debt since the date of separation on January 12, 2008, 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 3 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 parry (5) MOTOR VEHICLES: Each party relinquishes any right, title and interest he or she may have to any and all motor vehicles currently in possession of the other party. Within fifteen (15) 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. (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 parry to the other for such property as may be in the individual possession of each of the parties hereto. (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, 401 K plans and the like. 4 Husband waives any and all right, title and interest he may have to wife's Raymond James account and Ameriprise money market account. Wife waives any and all right, title and interest she may have to husband's military retirement account, pension or retirement earned from his state employment and his 401 k. (8) BUSINESS: Wife has an interest in her own business titled "Shearer Advertising Specialties" located in Carlisle, Cumberland County, Pennsylvania. Husband specifically waives any and all right, title, claim and interest he has to this sole proprietorship. The waiver includes, but is not limited to any right, title, claim or interest arising from curtesy, the right to equitable distribution and any and all rights arising by reason of his marriage to wife. Husband executed a Waiver of Marital Rights dated June 27, 2006, a copy of which is attached hereto and incorporated herein as Exhibit "B". (9) ALIMONY: WAIVER OF ALIMONY: The parties acknowledge that each has income and assets satisfactory to his and her own reasonable needs. Each party waives any claim he or she may have one against the other for alimony, spousal support or alimony and alimony pendente lite. (10) FAMILY DOGS: Wife shall retain possession and control of the family dogs, Libby, a miniature pinscher, and Rita, an Italian greyhound. Wife shall permit Husband to have contact with the family dogs at times as Wife may agree and facilitate. (11) 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 have been provided a copy of this agreement with which to consult with counsel. Wife is represented by Marylou Matas, Esquire and, husband has been advised that he may be represented by counsel of choice. Husband has reviewed this agreement and has had the opportunity to 5 have the provisions of this agreement and their affects explained to him by counsel, but has chosen to proceed on his own without legal representation and is entering into this agreement of his own free will. 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. (12) 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 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. (13) 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 6 Agreement had never been entered into. (14) 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. (15) RIGHTS AND RESPONSIBILITIES: Husband and Wife acknowledge 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. (16) 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 lite, counsel fees, costs and expenses, equitable distribution of marital property and any other claims of the party, including all claims which have been raised or may be raised in an action for divorce. (17) 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 7 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 nature of courtesy and dower; D. All widow or widower's rights; E. All right, title, interest or claim in or to the other's estate, whether now owned or hereafter acquired, including but not limited to all rights or claims: (1) to take against the other's will; (2) under the laws of intestacy; (3) to a family exemption or similar allowance; and (4) all other rights or authority to participate or intervene in a deceased spouse's estate in any way, whether arising under the laws of Pennsylvania or any other country, territory, state or political subdivision. F. All rights or claims to any accounting; G. All rights, claims, demands, liabilities and obligations arising out of or in connection with the marital relationship or the joint ownership of property, whether real, personal or mixed; H. All rights, claims, demands, liabilities and obligations arising 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; 8 I. All rights, claims, demands, liabilities and obligations each party now has, or may hereafter have, against or with respect to the other. (18) GOVERNING LAW: This Agreement shall be construed under the law of the Commonwealth of Pennsylvania. If any provision of this Agreement is determined to be invalid or unenforceable, all other provisions shall continue in full force and effect. (19) 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. (20) 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. (21) 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. (22) 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 have hereunto set their hands and seals the day and year first written above. 9 10 I COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND On this 5s' ? day of 2008, before me, the undersigned officer, personally appeared, LOIS 1. SHEARER, known to me (or satisfactory proven) to be the person whose name is subscribed to the within Agreement and acknowledged that she executed the same for the purpose therein contained. IN WITNESS WHEREOF, I hereunto set myjkw4 and official seal. COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Joseph L. Grove, Notary Public Silver Spring Twp., Cumberland County NOt PU M Commission Expires June 18 2009 Mcxnbol, Pennsylvania Association of Notaries COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND On this Ft4`day of a-y 2008, before me, the undersigned officer, personally appeared MICHAEL A. SHOFF, known to me (or satisfactory proven) to be the person whose name is subscribed to the within Agreement and acknowledged that he executed the same for the purpose therein contained. IN WITNESS WHEREOF, I hen COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Joseph L. Grove, Notary Public Silver Spring Twp., Cumberland County M Commission Ex ires June 18 2009 Momber, Ponnsylvania isociat- of Notar es 11 %J T 'R 'co co ? D a. o { ? 00 Tse LOIS I. SHEARER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 08-229 MICHAEL A. SHOFF, Defendant IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT A Complaint in Divorce under § 3301(c) of the Divorce Code was filed January 11, 2008 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. 1 1 consent to the entry of a final Decree in 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 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: 0 of I. Shearer PLAINTIFF'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER4 3301 (c) 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 SAWIS, FWVVTRR & LINDSAY 26 West High Street Carlisle, PA 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. V I I ,ivt,t,---- Date: L ' I. hearer o C . co rIO co LOIS I. SHEARER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 08-229 MICHAEL A. SHOFF, Defendant IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Kindly transmit the record, together with the following information, to the Court for entry of a Decree in Divorce: 1. Grounds for Divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Defendant accepted service of the Complaint on January 12, 2008, via certified mail. Proof of service was filed with the Court on January 23, 2008. 3. Date Affidavit of Consent required under Section 3301(c) of the Divorce Code was executed: By Plaintiff: On July 21, 2008 and filed with the Prothonotary on July 21, 2008. By Defendant: On May 8, 2008 and filed with the Prothonotary on May 28, 2008. 4. Related claims pending: None. 5. Date Waiver of Notice under Section 3301(c) of the Divorce Code was executed: By Plaintiff: On July 21, 2008 and filed with the Prothonotary on July 21, 2008. By Defendant: On May 8, 2008 and filed with the Prothonotary on May 28, 2008. SAIDIS, FLOWER & LENDSAY MIUMMUR 26 West High Street Carlisle, PA SAIDIS, FLOWER & LINDSAY Mary s, Esqu'h'e - Suprem rt ID No. 84919 26 West High Street Carlisle, PA 17013 717-243-6222 a m rt c...- ' ° - Er , r: ? . N ? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. LOIS I. SHEARER No. VERSUS MICHAEL A. SHOFF 08-229 DECREE IN DIVORCE AND NOW, -i %A 1 z2 Zcy?, IT IS ORDERED AND LOIS I. SHEARER DECREED THAT AND MICHAEL A. SHOFF ARE DIVORCED FROM THE BONDS CAF 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 of the Separation and Property Settlement Agreement dated May 8, 2008 are BY THE COURT: PROTHONOTARY incorporated, but not merged, into this Decree in Divorce. ?u ©: -ee C ? n? e