HomeMy WebLinkAbout03-6539GAYLE C. GREEN, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNA.
v. CIVIL ACTION - LAW_
No.
JEFFREY W. GREEN,
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 papers, 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 at the Office of
the Prothonotary at the Cumberland County Courthouse.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED,
YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
GAYLE C. GREEN, 1N THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNA.
v. CIVIL ACTION - LAW 0[. L(~Q_/...~
JEFFREY W. GREEN,
Defendant IN DIVORCE
COMPLAINT IN DIVORCE
1. Plaintiff is Gayle C. Green, who currently resides at 444 Pawnee Drive,
Mechanicsburg, Cumberland County, Pennsylvania 17050.
2. Defendant is Jeffrey W. Green, who currently resides at 444 Pawnee Drive,
Mechanicsburg, Cumberland County, Pennsylvania 17050.
3. Plaintiff Gayle C. Green and Defendant Jeffrey W. Green have been bona fide
residents of the Commonwealth for at least six months immediately preceding the filing of this
Complaint.
4. The Plaintiff and Defendant were married on May 1, 1993, in Mechanicsburg,
Pennsylvania.
5. There were no children born to this marriage.
6. There have been no prior actions of divorce or annulment instituted by either of
the parties in this or any other jurisdiction.
7. Plaintiff has been advised of the availability of counseling and that she may have
the right to request the Court require the parties to participate in counseling.
COUNT I
Request for a No-Fault Divorce Under
§ 3301 of the Divorce Code
8. Paragraphs 1 through 7 of thc Complaint arc incorporated herein by reference.
9. The marriage of the parties is irretrievably broken.
WHEREFORE, Plaintiff Gayle C. Green respectfully requests the Court to enter a decree
of divorce pursuant to § 3301 of the Divorce Code.
COUNT II
Re~luest for E~tuitable Distribution of Marital
Prol~ertv Under ~ 3502 of the Divorce Code
10. Paragraphs 1 through 9 of the Complaint are incorporated herein by reference.
I 1. Plaintiff requests the Court to equitably divide, distribute, or assign the marital
property between the parties without regard to marital misconduct in such proportion as the
Court deems just after consideration of all relevant factors.
12. There have been no prior actions for equitable distribution of marital property
instituted by either of the parties in this or any other jurisdiction.
WHEREFORE, Plaintiff Gayle C. Green respectfully requests the Court to enter an order
of equitable distribution of marital property pursuant to § 3502(a) of the Divorce Code.
COUNT III
Re~luest for Sl~ousal Suoport and/or Alimony Pendente Lite
and Alimony Under ~ 3701(a~ and 1~ 3702 of the Divorce Code
13. Paragraphs 1 through 12 of this Complaint are incorporated herein by reference.
14. Plaintiff is employed, however, due to the disparity in the parties' incomes, as
well as the parties' debts, she will be unable to sustain herself during the course of this litigation.
15. Plaintiff requests that the Court enter an award of spousal support and/or alimony
pendente lite until final hearing and thereupon to enter an order of alimony in her favor pursuant
to § 3701(a) and § 3702 of the Divorce Code.
16. There have been no prior actions for spousal support and/or alimony pendente lite
and/or alimony instituted by either of the parties in this or any other jurisdiction.
WHEREFORE, Plaintiff Gayle C. Green respectfully requests the Court to enter an order
of spousal support and/or alimony pendente lite at the final hearing and thereupon enter an order
of alimony in her favor pursuant to § 3701(a) and § 3702 of the Divorce Code.
Attorney for Plaintiff
I.D. #52654
Commerce Towers - 10th Floor
300 North Second Street
Post Office Box 62003
Harrisburg, PA 17106-2003
December / .,/2003D_, (717) 920-8100
Dated:
VERIFICATION
Is Gayle C. Green, verify that the statements made in this Complaint are true and correct.
I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904,
relating to unswom falsification to authorities.
GAYLE C. GREEN, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNA.
v. CIVIL ACTION - LAW
NO. 03-6539 Civil Term
JEFFREY W. GREEN,
Defendant IN DIVORCE
PROOF OF SERVICE
TO: PROTHONOTARY OF CUMBERLAND COUNTY
The undersigned, counsel for the Plaintiff, hereby certifies that the Complaint in the
above-captioned matter was served upon the Defendant via certified mail on January 9, 2004,
pursuant to Pa. R.C.P. 1930.4 (c). A true and correct copy of the return receipt is attached hereto
as Exhibit "A".
Respectfully submitted,
LP
~ Attorney for Plaintiff
Commerce Towers - 10th Floor
300 North Second Street
Post Office Box 62003
Harrisburg, PA 17106-2003
(717) 920-8100
Date: January / D, , 2004 Attorneys for Plaintiff
Gayle C. Green
· Complete items 1, 2, and 3. Also complete
item 4 if Restricted Delivery rs desired. X. '~'f~ ~.,4 f-T Agent
· Print your name a~d address on the reverse ,_ 4./~,!¢ ?.~' N~ ' F"'I Addressee
SO tha. t we can return the da. rd to you. B. Red,red I~y (Printed Name) C. te of Ddivery
· Attach this card to the back of the mailp'ece, ~,.~
or on the front if space permits.
D. Is delivery address different from item 1 ? I-I Yes
1. Article Addressed to: If YES, enter delivery ~ddress below; [-1 No
3. Se e Type
~/)~5~(~ Certified Mail [] Express Mail
~Ree!istered ~ Return Receipt for Merchandise
I~ Insured MaiJ [] C.O.D.
4. Restricted Delivery? (~xtra Fee)
PS For t02595-02-M-1540
· Sender: Pleas e, address ~~~¢~,~"x~
EXHIBIT A
CERTIFICATE OF SERVICE
AND NOW, this ,/t.. day of January, 2004, I, Karen S. Coates, Esquire, hereby certify
that I served a true an correct copy of the foregoing Proof of Service by first class mail, postage
pre-paid, at Harrisburg, Pennsylvania, addressed to the following persons at the following
addresses:
Jeffrey W. Green
444 Pawnee Drive
Mechanicsburg, PA 17050~ ~r//
e
GAYLE C. GREEN, IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY PENNSYLVANIA
Plaintiff
CIVIL ACTION - LAW
NO. 03-6539
JEFFREY W. GREEN,
Defendant IN DIVORCE
AFFIDAVIT OF CONSENT
4. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on
December 19, 2003.
5. 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.
6. I consent to the entry of a final Decree of Divorce and have executed a Waiver of
Notice of Intention to Request Entry of a 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.
Je/ffr~q~. Gree~
GAYLE C. GREEN, IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY PENNSYLVANIA
Plaintiff
CIVIL ACTION - LAW
NO. 03-6539
JEFFREY W. GREEN,
Defendant IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER § 3301(c) OF TIlE DIVORCE CODE
1. I consent to the entry of a final Decree of Divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property,
lawyers' 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 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:. Je~/~/~een -
GAYLE C. GREEN, IN TIlE COURT OF COMMON PLEAS
CUMBERLAND COUNTY PENNSYLVANIA
Plaintiff
CIVIL ACTION - LAW
V.
NO. 03-6539
JEFFREY W. GREEN,
Defendant IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on
December 19, 2003.
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 Cornplaint.
3. I consent to the entry of a final Decree of Divorce and have executed a Waiver of
Notice of Intention to Request Entry of a 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: Gay e~. Green
: IN THE COURT OF COMMON PLEAS
GAYLE C. GREEN, : CUMBERLAND COUNTY PENNSYLVANIA
Plaintiff CIVIL ACTION - LAW
v. NO. 03-6539
JEFFREY W. GREEN,
Defendant IN DIVORCE
~F NOTICE OF INTENTION TO ~_Q._.~Q_.~_~T
~IVORCE DECREE UNDER 3301c OF THE DIVORCE CODE
1. I consent to the entry of a final Decree of Divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property,
lawyers' 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 this Affidavit are true and correct. I understand that
false statements herein are made subject to the penalties of 18 I?a.C.S. § 4904 relating to unsworn
falsification to authorities.
Gayl~.~Z. ,Green
SEPARATION AND PROPERTY SETFLEMENT AGREEMENT
THIS AGREEMENT, made thisH~of~.~ 2004, by and between
JEFFREY W. GREEN, of Mechanicsburg, Cumb~land C~uuty, Pennsylvania,
helxdnal~r referred to as "Husband," and GAYLE C. GREEN, of Mechanicsburg,
Cumberland County, Pennsylvania, hereinAt~er referred to as "Wife."
WHEREAS, Husband and Wife were lawfully married on May 1, 1993, at
Mechanicsburg, Cumberland County, Pennsylvania; and
WItliREAS, there were no children bom to the marriage; and
WHEREAS, certain differences have arisen between the parties, as a result of which
they have decided to separate, and are desirous therefore of entering into an Agreement
which will distribute their marital property in a manner which is equitable and will
provide for their mutual responsibilities and rights growing out of the marriage
relationship; and
WHEREAS, the parties hereto, afl~ being properly advised by counsel, or having
had the opportunity of being properly advised by counsel, understand the legal impact of
this Agreement and execute this Agreement intending to be legally bound by the terms of
this Agreement.
NOW, THEREFORE, in consideration of the above recitals and the following
covenants and promises mutually made and mutually to be kept, the parties heretofore,
intending to be legally bound and to legally bind their heirs, successors and assigns
thereby, covenant, promise and agree as follows:
1. s~..AilA~I_Q~: The parties agree to live separate and apart f~om one another at
such places as he or she may from time to time choose or deem fit.
2. I~: Each party shsl! be free fiom interference, authority and
contact by the other, as fully as if he or she were single and unmarried, except as may be
necessaO, to cany out the provisions of this Agreement. Neither party shall molest the
other nor attempt to endeavor to molest the other, nor compel the other to cohabit with
the other, nor in any way inteit'ere with the peaceful existence, separate and apart
the other.
3. ~: Wife represents and warrants to Husband that since the date of
this Agreement she has now, and in the future she will not, contract or incur any debt or
liability for which Husband or his Estate might be responsible and shall indemnify and
save Husband harmless for any and all claims or demands ~sge against him by reason of
debts or obligations incurred by her.
4. l~~: Husband represents and warrants to Wife that since the
date of this Agreement he has no~, and in the future he will not, conlract or incur any debt
or liability for which Wife or her Estate might be responsible and shall indemnify and
save Wife harmless from any and all claims or demands made against her by reason of
debts or obligations incurred by him.
5. MUTUAL I~F~I,F.&$F.: Subject to the provisions of this Agreement, each party
waives his or her right to alimony and any further distribution of propeaiy inasmuch as
the parties hereto agree that this Agreement provides for an equitable distribution of their
marital property in accordance with the Divorce Code of 1980. Subject to the provisions
of this Agreement, each party has released and discharged, and by this Agreement does
for himseff or herself; and his or her heirs, legal representatives, executors, adminislrators
and assigns, release and discharge the other of and from all causes of action, claims,
rights or demands whatsoever in law or equity, which either of the parties ever had or
now has against the other, except any or ali cause or causes of action for divorce and
except in any or all causes of action for breach of any provisions of this Agreement.
Each party also waives their right to request marital counseling pursuant to Section 202
of the Divorce Code.
6. EOUITARI.~.. DISTRIRUTION OF MARITAL PROPERTY: Thc parties
have aC~ml~cd to dislribute their marital property in a manner which conforms to the
criteria set forth in Section 401 of the Pennsylvania Divorce Code, and ta~ino~ in to
account the following consideratious: the length of thc marriage; the fact that it is thc
-2-
Wife's first marriage and the Husband's first marriage; the age, health, station, amount
and sources of income, vocational skills, employability, estate, liabilities and needs of
each of the parties; the contribution of each party to the education, Iruining or increased
earning power of the other party; the opportunity of each party for future acquisitions of
capital assets and income; the sources of income of both parties, including but not limited
to medical, retirement, insurance or other benefits; the contribution or dissipation of each
_.p___a~y, ;.m th.e. acqui.si.ti.'on~, pre,s~t?'on, depreciation or appreciation of the marital property,
mciuomg me conmoutton of eacu spo.use as a homemaker; the value of the property set
epm to each party; the standard of living of the parties established during the marriage;
and the economic circumstances of each party at the time the division of property is to
become effective.
The division of existing marital property is not intended by the parties to constitute ia
any way a sale or exchange of assets; and the division is being effected without the
introduction of outside funds or other '-~---'--'-- n ..... ~ .......
· . . l,~,p~y ut ~onsl~mmlg Inarl~al prop the
di_~s~on of property under this Agreement shah be in full satisfaction of all
o! t~e parties.
A. MAR~.AJ,~O.~: The parties hereto mutually agree that the marital home
situate at ~.~.~ Pawnee Drive, Mechanicsburg, Cumberland County, Pennsylvania, has
been sold and settlement is scheduled on or about August 15, 2004. The sale price is
$199,900.00, and the parties agree to execute whstever documents are necessary to
effectuate the sale.
The parties agree that the net proceeds from the sale of the property will be divided
equally. It is anticipated that each party will receive approximately $11,500.00, although
each party acknowledges that the equal division may result in a figure different than
$11,500.00.
B. PERSONAL PROPERTY: The parties hereto agree that the remaining personal
property accumulated during the marriage is more fully set out in Exhibit A, which is
incorporated herein by reference, and attached hereto. That Exhibit sets forth the
personal property in the name of the party to whom that personal property will own that
personal property.
-3-
Each pmiy agrees to release, relinquish and discharge any and all right, title and
interest in the property that will become the personal property of the other.
7. AL,IM.O.A~: Both parties acknowledge and agree that the provisions of this
Agreement providing for equitable dis~ibution of mArital property are fair, adequate and
satisfactory to them and are accepted by them in lieu of and in full and final settleraent
and satisfaction of any claims or demands that eithe~ may now or hereafter have against
the other for support, maintenance or alimony. Husband and Wife further, voluntarily
and intelligently, waive and relinquish any right to seek fi'om the other any payment for
support or alimony.
8. ALIMONY PENDENTE LITE. COUNSEL FE, F,,q, AND EXPENSF.~::
Husband and Wife acknowledge and agree that the provisions of this .Agreement
providing for the equitable distribution of marital properly of the parties is fair, adequate
and satisfactory to them. Both ps~ies agree to accept the provisions set fol~ in this
Af~reement in lieu of and in full and final settlement and satisfaction of all claims and
demands that either may now or hereafter have against the other for alimony pendente
lite, counsel fees or expenses or any other provision for their support and maintenance
before, during and afle~ the commencement of any proceedings for divorce or annulment
between the parties.
9. WAIV~RN OF CLAIMN ACAINNT ENTA'I~£: Except ss he~in otherwise
provided, each par~ may dispose of his or her property in any way, and each party
here.by waives and relinquishes any and all rights he or she may now have or hereafter
acqmre, under the present or future laws of any jurisdiction, to share in the proper~y or
the estate of the other as a result of the mari~l relationship, including without limitation,
dower, curtesy, statutory allowance, widow's allowance, right to take in intestacy, right to
take against the Will of the other, and right to act ss admlnis~rator 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 interests, rights and claims.
10. SUBSEOUENT I)IVOI~C~~. The parties hereto acknowledge that Wife has filed
an action in divorce in the Court of Common Pleas of Cumberland CounF at No. 03-
6539 Civil Temp. Husband and Wife each a~ree to sign an ~qidavit of conseut and an
affidavit waiving counseling to be filed in said divorce action. In the event such divorce
action is concluded, Wife shall be entitled to receive a copy of the Decree in Divorce for
the normal fee cha~ed by the Prothonotary and shall not be assessed any costs of thc
proceeding. In the event such divorce action is concluded, the parties shall be bound by
all the terms of this Agreement, which shall not be incorporated by reference into the
Divorce Decree, but shall in all respects survive the same end be forever binding and
conclusive upon the parties.
11. I~F, AC~: If either party breaches any provision of this Agreement, the other
party shall have the right, at his or her election, to sue for damages for such breach, or
seek such other remedies or relief as m,y be available to him or her, and the party
breaching the conlract should be responsible for payment of le§al fees and costs incurred
by the other in enforcing his or her rights under this Agreement.
12. ADDITIONAL INSTRUMENT~: 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 nmy be reasonably required to give full force and effect to the
provisions of this Agreement.
13. VOLUNTARY EXI~CUTiO[~q: Husband and Wife acknowledge the provisions
of this Asrcement are fully understood by both parties. Each party acknowledges that the
Agreement is in all respects fair and equitable, and it is entered into voluntarily and
knowingly, and not as the result of any duress or undue influmce.
th l4..ENTIRE AGI~iF, MENT: This Agreement contains the entire und .er.s. tanding of
e part~es and there are no r~resentafions, warranties, covenants or undertakings other
than those expressly set forth herein. Husband and Wife acknowledge and agree that the
provisions of this Agreement with respect to the distribution and division of marital and
separate property are fair, equitable and satisfactory to them based upon the length of
their marriage and other relevant factors which have been taken into consideration by the
parties. Both parties hereby accept the provisions of this Agreement with respect to the
division of property in lieu of and in full and final settlement and satisfaction of all claims
and demands that they may now have or hereafter have against the other for equitable
distribution of their property by any court of competent jurisdiction pursuant to Section
401(d) of the Divorce Code or any other laws. Husband and Wife each voluntarily and
intelligently waive and relinquish any right to seek a court order determination and
distribution of marital property, but nothin~ herein contained shall constitute a waiver by
-5-
either pray of any rights to seek the relief of any court for the purpose of enforcing the
provisions of this Agreement.
15. ~: Husband and Wife each represent and warrant to the other&at
he or she has made a full and complete disclosure to the other of all assets of any nature
whatsoever in which such party hs~ in interest, the sources and amount of the income of
such par~y of every type whatsoever and of all other facts relating to the subject matter of
this Agreement.
16. MODIFICATION AND WAIVlC~: A modification or waiver of any of the
provisions of this Agreement shsll be effective only if made in writing and execu~l with
the same form*lib/as this Agreement. The failure of either party to insist upon s~ct
performance of any of the provisions of this Agreement shall not be construed as a waiver
of any subsequent default of the same or similar nature.
17. DESCRIFTIV~ H~.ADING~: The descriptive headings used herein are for
convenience only. They shall have no effect whatsoever in determining the rights or
obligations of the par~es.
18. INDI~PEND~NT SEPARATI~ COVENANT.~: It is specifically understood
and agreed by and between the parties hereto that each paragraph hereof shall be deemed
to be a separate and independent covenant and agreement.
19. ~-P-J~,C~,~lu~a~: This Agreement shall be construed under the laws of the
Commonwealth of Pennsylvania.
20. ~D~[~.~a~: If any term, condition, clause or provision of&is Agreement
shall be detennined or declared to be void or invalid in law or otherwise, then only that
te~a, condition, clause or provision shall be stricken from &is Agreement and in all other
respects &is Agreement shall be valid and continue in full force, effect and operation.
21. AGRICF~MENT BINDING ON Hl~Ha~: This Agreement shall be binding and
shall inure to the benefit of the parties hereto and their respective heirs, executors,
8ami~|slrators, successors and assigns.
22. ~: The parties asree that Wife shall become the sole and
separate owner of the van and the Explorer.
Husband and Wife agree that Husband shall become the sole and separate owner of
the ~ruck.
Each party agrees to execute whatever documents are necessary, to effectuate the
provisions herein, and each party agrees to be solely responsible for any indebtedness on
the vehicle that is acquired by that party.
Each party asrees to indenmify and save harmless the other on account of any claims
or causes of action maintained for the indebtedness on the vehicle in the possession of
that party.
23. ~: Both parties agrec that all credit card accounts shall be
extinguished and paid off with each patty being responsible for 50% of the indebtedness.
24. ~ Husband and Wife agree that Husband shall retain sole and separate
ownership of his 401K with Wife executing any and all documents necessary to
effectuate the same.
25. S~,]~: Husband and Wife agree that the stocks shall become the sole and
separate property of Wife, and Husband asrees to release, relinquish, and discharge any
and all right, title and interest in said stocks.
Husband and Wife expressly asree that the stock values were disclosed to the parties
in a document dated June 22, 2004, a copy of which is attached hereto, incorporated
herein by reference and marked as Exhibit B.
26. LI~~: Husband and Wife agree that they will maintain sole
ownership of the polices un their respective lives, and each is free to name a boneficia~/
of his or her choice.
27. ~,.~.~: Except as hereinafter set forth, Husband and Wife agree
that until such time that the divorce is final, each shall bc responsible equally for thc
household debts are incurred.
-7-
IN WITNESS WHEREOF, the parties hereto, intending to be legally bound, have
set their han~d seals thc day and year first above written.
Wire,ss / ~
-8-
GAYLE & JEFF G~.H - IIIARR~ A~.ET IN~N'I'ORY
Ow~mmhlp: Item: Value:
Jeff
.,eft ...
,plit
I~ I/~l~uun18
~it ';~,=,, ;~,,.- .-; .,.~..~e, P_,W-,z~_ ~ ~_-~_. i;,~ ....
~ell & split $ H=um (444 P.wMe I:~ve)
--... C;~,,...;~i (;log)
,.-"-~ ~,~y (cat)
~'~'"' ~,w (cat)
.Gi'¢~ P~l ~i,,d,,~' ,,.;ai.a~
Jeff Ford F-150 tru~;~
:~.._:_. il~;~,~; " .. ·
Jeff B~ ,,.,,,= & ,,..,,=~ (king
Jeff Tall/-r~.:._, ..
Jeff Long ~i-...~.., & ,,,;i,u~ unit
Jori' C-..~=~o~ mild
.... L,~ [;~][ui F~i~i ~he bed'
Jeff ~tJque ~:.~,,, ~.~,- (,'~n~.) '"
;eft ~.'h (bi,,- love ,,-,~) · ·
81Xit ~.,.~,~.. ' '
j~ 'g:~.~ i~~ ..
T~I!dre~. '
0....-,~ V. CR & r,,,,
.Jee ~,,i...d:m- ~=~. & ,:.,~,~, _ '- -
..... ~::~Jt~r
'C.='~ .~.,,,.,
Split Phon,,
P-~e ~"~-.,a;; ~ & r~.,,,~L,= "
e'-:-~? & H~:~-:
--t'- C, oan~ ~=-_'~_, chUrCh ·
Jeff ~'='~';'L":d h~;_-~'_~ (~,~...;.., ~:.:--} .,
~ ~illf d~ll~ .
Pink c'nmr
~ ·
~ Bluerecline' Ch.ir ~ ~
~ "
J~ ?.¥. ~~_
~=,y~ DVO/VCR
Jeff ~,~_~ print over the couch (~tone mill)
~le F~ cow ~ra,-,
~ Greyhound Inn wooden sign
Jeff ~ KettJe
Jeff Srnlll lab],= & c~,~;~ (2)
Dining .R~m:
J-~ White metal cabinet
~. C~ "
IT~,~;~ ....
end ' '" ' '
C~lr
014 pLEAS
-...-~ c~F COMM_.~,.~/L¥ A'XlI^
plaintiff : CWIL AcxIO~ ' LAW
: ~O. 03-6539
: ~ DWoKGE
TO T~E pRo~O~OT AR~: _.~,, with ~e follo~ng inf°~ati°n'
plea~ transmB ~he ~cor~,
for entr~ of a DeCree in DivOrCe: l~rievable Bre~do~ ~ficr SeCtiOn 3:) of
ccct the
thcOi~OrCC C°~e _~~' S~'ce~7 ~:, ~ceipt
2. ~~f 3ul~, 2004, by ccmficd
. ~ - W Green on &e 9 oa~ u p~of ot semite ~d
req~sle& reeeip~ number ~002 2030 0001 3402
with &c cou~ on ]~ 13, 2004. ' d
~ipt filed , ~ ution of ~2004.
3. . : by plamUU o~ J tlement
~ Se~tlefi by Sepmation ~6 P
~greement ~a~e~ July 30, 2004.
5. (,a) Date ?lainfiff's ~a'~ver of~N°tice flied v~th the p~othOnO~:
Augus~ 9, ~00~.
(bi Date Defender's w~er of No6ce filed ~th ~e ProthouO~:
August 9, 2004.
2215 Forest Hills Drive
Suite 3?
Harrisburg, PA 17112
DATE: September 3, 2004
CERTIFICATE OF SERVICF~
AND NOW, this 3rd day of September, 2004, I. Karen S. Coates, Esquire, hereby
certify that I served a true and correct copy ofthe foregoing Praeeipe to Transmit the
Record, by first class mail, postage pre-paid, at Harrisburg, Pennsylvania, addressed to
the following:
P. Richard Wagner
Mancke & Wagner
2233 North Front Street
Harrisburg, PA 17110
Karen S. Coates, Es~i~..~
IN THE COURT Of COMMON PLEAS
OFCUMBERLANDCOUNTY
STATE OF PENNA.
GAYL~ C. GREEN
N O. 03-6539
PLAINTIFF
VERSUS
JEFFREY W. GREEN
DEFENDANT
DECREE IN
DiVOrCe ~ (~
DECREED THAT GAYLE C. GREEN , PlAINtiff,
AND JEFFREY W. GREEN , DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
THE COURT RETAINS JURISDICTION OF ThE fOLLOWING CLAIMS WHICH hAVE
BEEN RAISED OF RECORD IN This ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED;
The terms of the parties Separation and Property Settlement
Agreement dated July 30,2004 and attached hereto are
incorporated herein but not merged herewith.
~~3TARY