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HomeMy WebLinkAbout08-3981IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA Lisa Hincks Riddle Plaintiff FAMILY DIVISION etvc. C, ?R.?.-1 Gale Martin Riddle vs. No. 08 ! Defendant 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 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, property or other rights important to you, including the right to demand marriage counseling. When the ground for divorce is indignities of irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary for Cumberland County: IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS ENTERED, 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: Cumberland County Bar Association Lawyer Referral Service Adams Co., Gettysburg: (717) 334-6781 Allegheny Co., Pittsburgh: (412) 261-0518 Armstrong Co., Kittanning: 724-548-3251 Beaver Co., Beaver: (412) 728-4888 Bedford Co., Bedford: 814-623-4833 Berks Co., Reading: (610) 375-4591 Blair Co., Hollidaysburg: (814) 693-3090 Bradford Co., Towanda: (570) 265-1705 Bucks Co., Doylestown: (215) 348-9413 Butler Co., Butler: (724) 284-5214 Cambria Co., Ebensburg: (614) 472-1636 Cameron Co., Emporium: (814) 468-3355 Lackawanna Co., Scranton: (570) 969-9600 Lancaster Co., Lancaster (717) 393-0737 Lawrence Co., New Castle: (724) 656-2143 Lebanon Co., Lebanon: (717) 274-2801 Lehigh Co., Allentown: (610) 433-7094 Luzente Co., Wilkes-Barre: (717) 822-6712 Lycoming Co., Williamsport: (570) 327-2251 McKean Co., Smethport: (814) 887-3270 Mercer Co., Mercer: (724) 342-3111 Mifflin Co., Lewistown: (717) 248-8146 Monroe Co., Stroudsburg: (570) 424-7288 Montgomery Co., Norristown: (610) 279-9660 Carbon Co., Jim Thorpe: (570) 325-2481 Centre Co., Bellefonte: (814) 355-6796 Chester Co., West Chester. (610) 429-1500 Clarion Co., Clarion: (814) 226-1119 Clearfield Co., Clearfield: (814) 765-2641 Clinton Co., Loch Haven: (570) 893-4007 Columbia Co., Bloomsburg: (570) 389-5600 Crawford Co., Media: (814) 333-7324 Cumberland Co., Carlisle: (717) 249-3166 Dauphin Co., Harrisburg,: (717) 232-7536 Delaware Co., Media: (610) 566-6625 Elk Co., Ridgway: (814) 776-5344 Erie Co., Erie: (814) 459-4411 Fayette Co., Uniontown: (724) 430-1272 Forest Co., Tionesta: (814) 755-3526 Franklin Co., Chambersburg: (717) 261-3858 Fulton Co., McConnelisburg: (717) 485-4212 Greene Co., Waynesburg: (724) 852,5289 Huntingdon Co., Huntingdon: (814) 643-1610 Indiana Co., Indiana: (724) 465-3855 Jefferson Co., Brookville: (814) 849-1606 Juniata Co., Mifflintown: (717) 436-7715 Montour Co., Danville: (570) 271-3010 Northampton Co., Easton: (610) 258-6333 Northumberland Co., Sunbury. (570) 9884151 Perry Co., New Bloomfield: (717) 582-2131 Philadelphia Co., Philadelphia: (215) 238-1701 Pike Co., Milford: (570) 296-7231 Potter Co., Coudersport: (814) 274-9740 Schuylkill Co., Pottsville: (570) 628-1270 Snyder Co., Middleburg: (570) 837-4202 Somerset Co., Somerset: (814) 445-1428 Sullivan Co., Laporte: (570) 946-7351 Susquehanna Co., Montrose: (570) 278-4600 Tioga Co., Wellsboro: (570) 724-9281 Union Co., Lewisburg: (570) 524-8751 Venango Co., Franklin: (814) 432-9577 Warren Co., Warren: (814) 728-3440 Washington Co., Washington: (724) 225-6710 Wayne Co., Honesdale: (570) 253-5970 Westmoreland Co., Greensburg: (724) 834-8490 Wyoming Co., Tunkhannock. (570) 253-5970 York Co., York: (717) 854-8755 COUNSELING NOTICE UNDER Pa R C P RULE 1920.45(x)*(1) The Divorce Code of Pennsylvania requires that you be notified of the availability of counseling where a divorce is sought under any of the following grounds: Section 3301(a)(6) Indignities Section 3301 (c) Irretrievable Breakdown Mutual Consent Section 3301(d) Irretrievable Breakdown Two-Year Separation where the court determines that there is not a reasonable prospect of reconciliation. A list of qualified professionals is available for inspection in the Prothonotary Office of the Cumberland County court. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA Lisa Hincks Riddle Plaintiff FAMILY DIVISION Gale Martin Riddle vs. No. Off'-39,f/ ' Defendant DIVORCE COMPLAINT UNDER SECTION 3301(0) OF THE DIVORCE CODE 1. The Plaintiff is Lisa Hincks Riddle, who currently resides at 309 Front Street, Boiling Springs, Pennsylvania 17007. She has resided at this address at least since June 2008. The Plaintiff previously resided at 7 Sebastian Way, Carlisle, Pennsylvania 17015 since July 1996. 2. The Defendant is Gale Martin Riddle, who currently resides at 7 Sebastian Way, Carlisle, Pennsylvania 17015. He has resided at this address at least since July 1996. 3. Both the Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on October 22, 1988, at First Congregational Church, Madison, Connecticut, County of New Haven. 5. Neither the Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Servicemember"s Civil Relief Act of 2003 and its amendments. 6. There have been no prior actions of divorce or for annulment instituted by either of the parties in this or any other jurisdiction. 7. The Plaintiff is aware of the availability of counseling and of the right to request that the Court require the parties to participate in counseling. 8. The marriage is irretrievably broken. 9. An original copy of the marriage certificate is attached. 10. After ninety (90) days have elapsed from the date of filing of this Complaint, the Plaintiff intends to file an affidavit consenting to a divorce. The Plaintiff believes that the Defendant will also file such an affidavit. WHEREFORE, if both parties file affidavits consenting to a divorce after ninety (90) days have elapsed from the date of the filing of this Complaint, the Plaintiff respectfully requests the Court to enter a decree of divorce pursuant to §3301 (c) of the Divorce Code. COUNT 11 REQUEST FOR INCORPORATION OF MARITAL SETTLEMENT AGREEMENT PURSUANT TO SECTIONS 3104(A)(1) AND (3) and 3323(B) DIVORCE CODE 1. Paragraphs 1 through 10 are incorporated herein and made a part hereof by reference as though fully set forth. 2. The Plaintiff and Defendant have reached an agreement on issues including alimony, property division, child support and child custody. WHEREFORE, the Plaintiff respectfully requests that this Court approve and incorporate the agreement reached between the Plaintiff and Defendant into the final divorce decree, pursuant to Sections 3104(a) (1) and (3) and 3323(b) of the Divorce Code. I 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 unworn falsification to authorities. ?Io 1 b i oe Date Plaint' ?"` ?? W C? 3 ?„ AG t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA FAMILY DIVISION Lisa Hincks Riddle Plaintiff vs. No. Gale Martin Riddle Defendant ' DIVORCE AFFIDAVIT OF NON-MILITARY SERVICE Personally appeared before me the undersigned, a Notary Public in and for said County and State, Lisa Hinc ks Riddle, for the Plaintiff and duly authorized to execute this Affidavit, and states that the Affiant knows of his or her own knowledge that the Defendant Gale Martin Riddle herein is not in the military service as defined in the Servicemembers' Civil Relief Act of 2003 and its Amendments thereto, for the following reasons: At no time during our marriage have i ever witnessed my spouse report to or make any contact with military personnel Affiant further says that the obligation sought to be enforced in this suit is not an obligation against a surety guarantor, endorser, or other person liable, primarily or secondarily, for a party in the military service. Plaintiff IN WITNESS THEREOF, I have hereunto set my he nd seal. Dated: 06-0-0e ?X NOTARY PUBLIC COMMONWEALTH OF PENNSYLVANIA Notarial Seal Denise S. Kocott, Notary Public East Pennsboro Twp., Cumberland Courtty My Commission E)ires May 29, 2011 Member, Pennsylvania Association of Notaries t N OS - 348 Marital Separation and Property Settlement Agreement between Gate Martin Riddle and Lisa Hincks Rtddte AGREEMENT, made this _(I& day of June, 2008, between Gale Martin Riddle (hereinafter referred to as Husband)_ and_Lisa .Hincks Riddle (hereinafter referred to as Wife). EXPLANATORY STATEMENT The parties were married in Madison, Connecticut, on October 22, 1988, in a religious ceremony. 'There are presently two minor children bom of or adopted by said marriage, namely Jane Kathryn Riddle, born May 06, 1991; and John Everett Riddle, born January 28, 1993. There are presently no adult children, born of or adopted by said marriage, who are legally dependant upon the parties for care or support. There are presently no adult children who are over -the,age of 21 and have mental and/or physical disabilities. Differences have arisen between the parties. They are now, and have been since May 26, 2000, no; longer living as Husband and Wife, living separate and apart, voluntarily and by mutual consent, with the purpose and intent of ending their marriage. It is the desire of both parties in this Agreement to determine, settle, and formalize their duties and obligations to each other and any issues regarding custody of their minor children, alimony, their respective rights in the property or estate of the other, and in property owned by them jointly or as tenants by the entireties and in marital property, and all other rights, claims, relationships or obligations between them arising out of their marriage or otherwise, and each party having general knowledge of the properties owned by them separately and jointly and of their respective means, obligations and needs. NOW, THEREFORE, in consideration of the promises and mutual covenants and understandings of each of the parties, they each hereby mutually agree to the following: 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 may from time to time choose or deem fit The parties shall not molest or interfere with each other, nor shall either attempt to compel the other to cohabit or dwell with him or her, by any means whatsoever. Husband and Wife agree that the marriage is irretrievably broken and will proceed with divorce under 23 Pa. C.A. Section 3301(c) or (d), as appropriate. 2. CUSTODY AND VISITATION GENERAL. Each party agrees to foster in the minds of their children attitudes of respect and love for both of the parents. Each party agrees not to denigrate the other party in the eyes of their children nor to attempt to alienate their children from the other party. Each party agrees to keep the other party fully informed as to the status of the health of the children and to consult with the other party on the major problems and decisions affecting the children, including the schools which the children will attend; the religious instruction the children shall receive; the health care the children shall receive; the manner in which the children shall be disciplined; the extent of any travel of the children away from home; and any other decisions affecting the children's growth and development, to the end that their children will have, as much 1 of 1 :4 as possible, the benefit of two parents. The parties further agree to exert every reasonable effort to maintain free access and unhampered contact between each of them and the children. The parties state that the best interests and welfare of the children are of paramount consideration for both of them. They shall make every effort to foster the respect and affection of the children for each other and shall do nothing which would in any way estrange the children from the other party, or which would injure the opinion of the children for the other party, or which would hamper the free and natural development of the love and affection of the children for the other party. Each party agrees to notify the other of any change in address or telephone number. ST DY. The parties have carefully weighed their decision regarding the custody of their minor children, and in so doing have been guided solely by considerations touching upon said children's welfare. The parties have concluded that it is in the best interest of said children that the parties shall have joint legal custody and control of the minor children of the parties hereto. The parties have concluded that it is in the best interest of the said children that the physical custody of the children shall primarily rest with the Husband, with the children residing in the home of said party during the greater part of each year. The Wife is to have access and parental rights as specified below. It is agreed, however, that physical custody shall shift to the Wife, at such time as the children reside in the home of the Wife, plus any and all such other times as the Wife shall provide for the care and custody of the children, either in the home or otherwise, pursuant to the agreement of the parties. During these periods, the Husband shall have access and parental rights as specified herein below. The parties agree that visitation to be equally split between both parents - 50% of the time (one week at at time) with each parent The parties agree that during the time each of them has the children in his or her physical possession, that parent shall decide all routine matters concerning the children's welfare, medical needs, etc. The parties further agree to cooperate with one another in establishing a mutually- supportive arrangement regarding such routine decisions. Both parties shall be informed at all times of the residence of the children, and each party shall notify the other immediately of any illness or emergency that may arise while the children are in his or her custody. The parties agree that the children shall not be removed from the area without the consent of the other party. The parties agree that at no time shall either minor child be in the care of the Wife when in the company of her associate Thea Rostad, as requested by the Husband. The parties agree that each parent shall be entitled to immediate access from the other, or from a third party, to records and information pertaining to the minor children, including, but not limited to, medical dental, health, school, or educational records. Each party shall be entitled to speak to the children by telephone at reasonable times and intervals when the children are in the custody or subject to the control of the other party. CHANGE OF NAME. Notwithstanding the possible remarriage of either party, the minor children of the parties shall continue to be legally and publicly known by the name in use as of the date of this Agreement. The children shall not, for any reason or purpose, use or assume the name of any subsequent spouse of either party or any other surname. The parties shall see to it that the designations "father" and "mother" or their equivalent shall be used by the child to refer to the parties hereto and to no other person. 3. SUPPORT AND MAINTENANCE OF THE MINOR CHILDREN 9 of 1.14 It is agreed that each party has sufficient financial resources for the support and maintenance of the minor children and that, barring fundamental and unforeseen changes in either's party financial condition, no demand for regular child support payments will be made by either party upon the other. SUMMER CAMP. The Husband shall pay fifty percent (50%), and the Wife shall pay fifty percent (50%), of all costs for each child to attend summer day camp through age eighteen (18). The selection of which summer day camp each child shall attend shall be made by mutual agreement, prior to application and prior to enrollment, after consultation between the Husband, the Wife, and the child. Payments will be made directly to the camp, immediately upon either partys receipt of documentation which sets forth the total expense. COLLEGE EDUCATION FOR THE CHILDREN COLLEGE DEFINED. For purposes of this section, the meaning of the term "college," "university," or "technical school" shall mean any accredited post-secondary educational institution not exceeding four consecutive years of undergraduate work. In case of a child having the aptitude and opportunity for a college education or comparable post- high-school training, the Husband shall be responsible to pay fifty percent (50%), and the Wife shall be responsible to pay fifty percent (50%), of the costs equivalent to the cost of an in-state four-year undergraduate education at a public college in the state where the minor child resides at the conclusion of his or her primary education (typically high-school). These funds shall be paid directly to any college or appropriate third-party associated with the incurred cost, or to the appropriate party (Husband, Wife, or child) as reimbursement of a qualifying cost, only when copies of related receipts are shared between the parties. This clause shall not specifically restrict the child's rights to attend an out-of-state secondary institution, only to restrict the agreed financial obligation of the Husband and Wife. For purposes of this Agreement, the term "cost of an in-state four-year undergraduate education" includes, but is not limited to, tuition and other enrollment or matriculation fees and charges, all attendant fees and expenses, whether charges for attendance in general or by virtue of enrollment in a special course or program, room and board, reasonable transportation charges, books and other expenses reasonably and necessarily incurred and relating to enrollment and or attendance in such colleges, universities, or technical schools. The selection of which college, university, or technical school a child shall attend shall be made by the Husband and the child, prior to application and prior to enrollment, and shall be made with and after due consideration of the financial circumstances and resources of the Husband and the child. 4. ALIMONY WAIVER. In consideration of the terms of this Agreement, the provisions contained herein for the respective benefit of the parties, and for other good and valuable consideration, the Wife hereby releases and discharges the Husband, absolutely and forever, from any claim or right to receive from the Husband temporary, definite, or indefinite alimony, support, or maintenance for the past, present or future. The Wife acknowledges that this Paragraph has been explained to her and that she understands and recognizes that, by the execution of this Agreement, she cannot at any time in the future make any claim against the Husband for alimony, support, or maintenance of any kind whatsoever for herself. The parties acknowledge that the Husband does not permanently waive any rights or daims to receive temporary, definite, or indefinite alimony, support, or maintenance for the past, present or future. PAYMENT. The Wife shall pay to the Husband as alimony the sum of Two Hundred Dollars and .1 of 1.i Zero Cents ($200.00) twice monthly, in advance, commencing July 01, 2008, and continuing twice monthly thereafter, as long as the parties shall remain separate and apart, until the first occurrence of. the death of the Husband, the death of the Wife, or the sale of the jointly owned property at 7 Sebastian Way, Carlisle, PA Said alimony payments shall be fixed in value. The payment value shall not be increased or decreased annually due to any percentage of increases in the Wife's salary from the previous year. For purposes of alimony, the parties shall not be required to share copies of current Federal tax returns each year. TAX CONSEQUENCES. It is the intention of the parties that for Federal, State, and local income tax purposes, the payments made in accordance with this Agreement shalt be taxable as income to the Husband and deductible by the Wife as alimony, maintenance, or spousal support. 5. MEDICAL INSURANCE GENERAL. Each party shall maintain their own medical insurance on their own behalf. Each party waives any interest they have in the other's medical insurance proceeds. The Wife shall solely bear the cost and responsibility to maintain major medical and hospitalization insurance for the benefit of the minor children of the parties. The Husband shall pay fifty percent (50%), and the Wife shall pay fifty percent (50%), of all medical, dental, or orthodontia expenses for the benefit of the minor children which are not covered by said insurance. This is to include all emergency medical treatment. TERMINATION. Obligations for insurance and uncovered expenses for each dependant child of the parties shall terminate when the child becomes independent or reaches eighteen (18) years of age, unless otherwise limited by law or available policies. Such obligations for each minor child shall also terminate as the child becomes emancipated (marries, or otherwise legally qualifies as an adult due to specific events identified by state laws). 6. DISPOSITION OF PROPERTY MARITAL REAL PROPERTY. The parties own as tenants by the entirety, in fee simple, the property known as 7 Sebastian Way, Carlisle, Pennsylvania 17015, which is presently occupied by the Husband. It is the intention of the parties that they presently continue to own the marital home jointly, become tenants4n-common upon being divorced, and to eventually sell the marital home. Therefore, the parties agree as follows: The parties agree that the marital home is valued at approximately Four Hundred Thousand Dollars and Zero Cents ($400,000.00), and that it currently holds one (1) lien, valued at approximately One Hundred And Twenty Eight Thousand Dollars and Zero Cents ($128,000.00). Therefore, the parties agree that the current equity in the marital home is approximately Two Hundred And Seventy Two Thousand Dollars and Zero Cents ($272,000.00). The Husband shall be entitled to sole possession of said premises (rent-free) The parties shall cooperate fully to promptly sell the marital home, the parties shall cooperate fully to promptly sell the marital home within 6 months of the youngest child, John Everett Riddle, graduating from high school, or any time before that which is mutually agreed upon by both parties. Expenses associated with the ownership and/or occupancy of the marital real estate gall include the mortgage, taxes, insurance, . During such time as the property is jointly- owned by the parties, the Husband's share of said expenses shall be one hundred percent (100%) and the Wife's share of said expenses shall be zero percent (0%). Repair d nf 1 costs and every other cost associated with the maintenance of the property less that $200 share be the responsibility of the Husband. Repairs and Maintenance over $200 will be split equally between the Husband and Wife. A party's financial responsibility shall end when all of his or her ownership and/or property rights are lawfully transferred to another. In the event the parties cannot agree upon a sale price, they shall choose a licensed real estate agent in the county where the property resides (or an adjacent county), and list the property for sale at a price which is five percent (5%) higher than its fair market value as determined by a licensed real estate appraiser.. If the parties cannot agree upon a listing agent, they shall each choose a real estate agent in the county where the property resides (or an adjacent county), and the two said agents shall together choose a third real estate agent. The three (3) real estate agents shall decide upon a listing price which is five percent (5%) higher than the fair market value of the property as determined by the real estate appraiser. In the event the parties cannot obtain the desired sale price within ninety (90) days after listing the property, they shall accept the first offer that is at least ninety percent (90%) of the designated listing price. The parties shall bear equally the cost, if any, of effectuating the sale, including the real estate agents' fees and seller's settlement costs. Neither party shall refuse to execute a contract for sale on the above terms or impose unreasonable conditions for the consummation of a contract of sale. Any and all Deeds of Trust, liens, closing costs, including attorney's fees, and real estate commissions shall be paid from the proceeds of sale before any distribution is made therefrom. Upon the sale and settlement of said property, the proceeds of such shall first pay the costs of the transaction and all encumbrances and liens against said property. Following these deductions, the Husband shall receive fifty percent (50%) of all remaining proceeds, and the Wife shall receive fifty percent (50%). Similarly, in the event that such a sale does not result in any net proceeds, that is, where the value of the property as specified within the sale documents does not exceed the costs of the transaction combined with the value of all encumbrances and liens against said property which exist at that time, the parties agree that the financial responsibility for the payment of the remaining costs and balances shall be divided using the same proportions and terms. The responsibilities of the parties pertaining to capital gains taxes related to this property are specifically addressed elsewhere in this Agreement. When applicable, this Agreement acts as an authorization and directive to the settlement attorney to issue separate checks to the Wife and the Husband pursuant to the details of this section of this Agreement. The parties each agree that while they own the said property as tenants4n-common, neither of them may, without the written consent of the other, sell his or her respective half interest in the said property, but, subject to the terms and conditions of this Agreement, either party may force the sale in lieu of partition of the said entire property. OTHER MARITAL REAL PROPERTY. The parties own the property located at jefferson street, Harrisburg, Pennsylvania other prop zip. The parties acknowledge that the property is currently occupied by neither of the parties. The parties agree that this property is currently titled solely in the name of the Husband. The parties agree that the title of this property shall not be changed. This property is to become the sole personal property of the Husband. PERSONAL PROPERTY. The parties agree with respect to their personal property as follows: The 2001 subaru outback, Vehicle Identification Number 4S38H806317677248, shall become the property of the Wife, and, contemporaneously with the execution of this Agreement, the Husband will execute all documents necessary and appropriate to 9; of :i convey title of said automobile to the Wife. The Wife shall thereafter be solely responsible for all expenses arising from such vehicle, and shall hold the Husband harmless as to the operation, maintenance, and all financial obligations arising out of the ownership of said vehicle. The 1996 mazda b2400, Vehicle Identification Number 4FCR16A7TTM38128, shall become the property of the Husband, and, contemporaneously with the execution of this Agreement, the Wife will execute all documents necessary and appropriate to convey title of said automobile to the Husband. The Husband shall thereafter be solely responsible for all expenses arising from such vehicle, and shall hold the Wife harmless as to the operation, maintenance, and all financial obligations arising out of the ownership of said vehicle. The 2001 dodge durango, Vehicle Identification Number 1 B4HS28Z2YF12, shall become the property of the Husband, and, contemporaneously with the execution of this Agreement, the Wife will execute all documents necessary and appropriate to convey title of said automobile to the Husband. The Husband shall thereafter be solely responsible for all expenses arising from such vehicle, and shall hold the Wife harmless as to the operation, maintenance, and all financial obligations arising out of the ownership of said vehicle. The parties agree that the Husband shall have as his We property any belongings he brought into the marriage. In addition, the Husband shall have as his sole personal property the following items: monarch pro 18 boat and trailer,purple couch,brown dresser,wood trunk,rolltop desk,mission bedroom set,fish tanks,cheiry sideboard,flowered couch,oak coffee table,wingbac k chairs, secretary with hutch,futon living set, pier one bookcase,oak rocking chair,universal weight machine, free weights, black futon couch, washing machine, dryer, chest freezer,all guns, bows, hunting equipment,grill, black iron patio set, picnic table, adiraondic k chairs, 2 woodfiron chairs, tv in master bedroom, tv in family room, flat screen tv,tv in weight room,dvd player and receiver in family room, digital movie camera, riding lawn mower, push lawnmower, power tools, power washer, weed whacker. The parties agree that the Wife shall have as her sole property any belongings she brought into the marriage. In addition, the Wife shall have as her sole personal property the following items: grandmothers silver, sony dvd surround sound system,printer in office,ty in bonus room,foldout couch in family room, oak bookcase,dining room set,gradmother travel trunk,mirroed sideboad,coffee table from father,sewing table,flowered chair, 2 drawer cabinet, cherry secretary,cheny doublebed, 314 bed,ikea dresser,blue dresser,dark oak rocker, cedar queen bed, brass single bed, yellow oak desk, white foot stool, 2 wood/iron chairs. Except where otherwise specified in this Agreement, the parties shall divide between them, to their mutual satisfaction, all furniture and household furnishings, and all other items of personal property which heretofore have been held by them in common, jointly, or as tenants by the entirety, and neither party will make any claims to any such items which are agreed to be owned by the other. COMMON FINANCIAL ASSETS. Except where otherwise specified in this Agreement, the parties shall divide all joint checking and savings accounts, all stocks, all certificates of deposit, all bonds, all mutual funds, and all other common financial assets which are legally marital property, whether titled in one or both parties' names. Once divided to the satisfaction of both parties, neither party shall make any claims on the other party's common financial assets, unless such claim can be reasonably considered appropriate compensation for the breach of some other clause of this Agreement, or unless such claim is proper pursuant to a separate amendment, contract, or legal action. OTHER PROPERTY. The parties represent and acknowledge that there is no other property, real or personal, which is owned jointly or in which both have an interest, and hereafter neither R of 1 R party will make any claim to any item which is in the possession of the other. Each party shall own, have and enjoy independently of any claim or right or the other, all items of property, real or personal, of every kind now or hereafter owned or held by him or her with full power to dispose of same as fully and effectively in all respects and for all purposes as if he or she were unmarried. 7. LIFE INSURANCE Each party shall have the right to name any person or organization they so choose as beneficiary on their life insurance policies. Each party waives any interest they have in the other party's life insurance proceeds, cash value, or otherwise. 8. RETIREMENT BENEFITS The Husband agrees to waive and release any rights or claims he may now have to any retirement pay, benefits or privileges earned by the Wife before or during this marriage. The Wife hereby waives all right to claim any interest or share in the Husband's Individual Retirement Accounts, which shall become his sole property. The Husband and the Wife agree that if any payments are specified in this section, said payments will not be taxable to the receiving party, as the payment will be received as a division of marital property of the parties. Each party pledges to cooperate with the other to secure approval of or execution of any documents that are necessary to transfer pension, 401(k) or IRA funds to the payee from the payor's accounts, if applicable. 9. ESTATE PLANNING INHERITANCE. The parties each forever waive all rights to inherit from the other party and rights to receive any property on the death of the other party, except by reason of a will, codicil, or republication of will by the other party executed subsequent to this date. The parties each recognize that this waiver includes rights that they otherwise might have or acquire under 20 Pennsylvania Statutes 2203 at seq., any amendment thereof, or any successor statute. The foregoing, however, shall not bar a claim on the part of either party for any cause arising out of a breach of this Agreement during the lifetime of the deceased party against whose estate such claim may be made. ADMINISTRATION. The parties forever waive all rights to act as administrator of the other party's estate and all rights to request or petition for the appointment of any person to serve as such representative or to act as the executor of the other party's will, unless expressly named in a will, codicil, or republication of will by the other party, executed subsequent to this date or by reason of an insurance policy if specified within this Agreement. 10. DEBTS GENERAL. The parties agree that they will not incur or contract any debt in the name of the other, or on the credit of the other, and will not pledge the other's credit in any manner after the execution of this Agreement, and that each shall hereafter be responsible for his or her obligations, except as set forth in this Agreement. Immediately upon execution of this Agreement, each of the parties shall do whatever is necessary to dose immediately all joint accounts in the name of the Husband and the Wife or either of them under which one may make purchases on the credit of the other. CREDIT HISTORY. The parties acknowledge and agree that the credit history established by them during their marriage shall be deemed to have been the credit history of both parties, notwithstanding ordinary practices of creditors and credit reporting agencies that may have 7nf1A reported such credit history in the name of the Husband only. The Husband agrees that he shall cooperate and execute any documents as may be required to enable the Wife to provide to her prospective creditors the full credit history of the parties during the marriage. Nothing in this Agreement is intended or shall be deemed to create any liability for the Husband of debts or obligations incurred by the Wife arising out of the credit information provided to her. INDEMNIFICATION. Except as otherwise specified herein, the parties agree that each will be responsible for his or her own debts and that neither will be responsible for the debts of the other. In the event that either party shall be called upon to answer for or to pay any debts or obligations of the other, then the Husband or the Wife, as the case may be, shall defend against the payment of such debt, and in the event the Husband or the Wife shall be required to pay, the opposite spouse shall exonerate and indemnify the Husband or the Wife against such debt, including all legal and proper costs, reasonable charges, and such damages as may have been caused by the failure to have paid such debt when due. COMPLIANCE. At the request of the other, the parties shall at any time, and from time to time hereafter, execute, acknowledge and deliver to the other party any further instruments and assurances that may be reasonably required for the purpose of giving full force and effect to the provisions of this Agreement. If either party shall fail to comply with the provisions of this paragraph, this Agreement shall constitute an actual grant, assignment, and conveyance of the property and rights in such manner and with such force and effect as shall be necessary to effectuate the terms of this Agreement. MUTUAL RELEASE. Except as otherwise provided by this Agreement, each party hereby covenants and agrees that he or she will not incur any debts, obligations, or liabilities on the other party's credit, nor do anything for which the other party might be legally liable or answerable. Each party covenants and warrants that there are no debts or obligations of any kind incurred by him or her and binding on the other party. Except as otherwise provided by this Agreement, all property and money received and retained by the parties pursuant hereto shall be the separate property of the respective parties, free and clear of any right, interest, or claim of the other party, and each party shall have the right to deal with and dispose of his or her separate property, both real or personal, as fully and effectively as if the parties had never been married. 11. UNIQUE LUMP-SUM PAYMENT As compensation or contribution for one or more other marital issues, the Wife agrees to pay the Husband the sum of Thirty Thousand Dollars and Zero Cents ($30,000.00). This payment will be made in one lump-sum, by cash, personal check or certified check, upon the sale of the jointly held property at 7 Sebastian Way, Carlisle, PA. The Husband shall provide a written and signed receipt to the Wife when this payment is made. 12. MISCELLANEOUS PROVISIONS EFFECTIVE DATE OF AGREEMENT This Agreement shall be effective as of the date it is executed by both parties. All agreements and representations of the Husband and the Wife shall be deemed to have been made as of this date. LEGAL REPRESENTATION The Husband and Wife each acknowledge that they have had the opportunity to retain counsel but have decided not to do so. The parties fully understand the facts and terms of this Agreement. Each party, whether or not represented by licensed legal counsel, enters freely and voluntarily into this Agreement. R M 1 "x If after the final divorce judgment has been entered, either party shall default in the performance of any of the obligations of this Agreement, or of any order or judgment, the other party may take action to lawfully recover his or her reasonable attorney's fees and costs from the defaulting party or his or her estate. COSTS OF ENFORCEMENT The parties agree that any costs, including but not limited to counsel fees, court oasts, investigation fees, and travel expense, incurred by a party in the successful enforcement of any of the agreements, covenants, or provisions of this Agreement, whether through litigation or other action to compel compliance herewith, shall be borne by the defaulting patty. Any such costs incurred by a party in the successful defense to any action for enforcement of any of the agreements, covenants, or provisions of this Agreement shall be borne by the party seeking to enforce compliance. TAX RETURNS AND REFUNDS The parties shall file separate Federal and state income tax returns for the taxable year 2008 If the parties agree to a joint filing for any taxable year, the Husband shall indemnify and hold harmless the Wife against all claims or loss, including reasonable attorney's fees, which the Wife may incur as a result of her agreement to file joint income tax returns with the Husband, and the Wife shall indemnify and hold harmless the Husband against all claims or loss, including reasonable attorney's fees, which the Husband may incur as a result of his agreement to file joint income tax returns with the Wife; the purpose of this paragraph being that each party shall pay for his or her own errors, omissions, or failure to report his or her income correctly. At such time as the parties shall file separate Federal and State income tax returns, the Husband shall be entitled to claim the deduction for the dependency exemption for two (2) minor children named herein and the Wife shall be entitled to claim the deduction for the dependency exemption for none of the minor children named herein, as long as either party is entitled to claim the dependency exemption under Section 152(e) of the Internal Revenue Code of 1954, as amended. The parties agree to sign and share Internal Revenue Service Form 8332 or any other declaration or declarations required by the Treasury Department and/or the Internal Revenue Service to implement this Agreement. INTEREST DEDUCTIONS AND DEPRECIATION. At such time as the parties file separate Federal and State Income Tax returns and as long as they own any real property described in this Agreement, the Husband shall receive one hundred percent (100%) of the interest deductions and depreciation attendant thereto, and the Wife shall therefore receive zero percent (0%) of the interest and depreciation attendant thereto. CAPITAL GAINS. The parties acknowledge that they have not accrued any capital gains from the sale of any marital property during the previous tax year, or in the current tax year until the present, which have not yet been appropriately documented within State and Federal tax filings, as required by law. Other than any capital gains tax implications and responsibilities identified in Section 6 above, if future capital gains, associated with the sale or transfer of any marital property, are recognized, the parties agree that the Husband will pay fifty percent (50%) of all taxes due on these gains, and any and all interest and/or penalties that may become due upon that portion, and the Wife agrees to pay fifty percent (500A) of all taxes due on these gains, and any and all interest and/or penalties that may become due upon that portion. COOPERATION REGARDING CLAIMS AND DEFENSES. The Husband and the Wife each agree to promptly notify the other in the event the Internal Revenue Service or any state or local taxing authority provides notice of an audit, deficiency, refund, or the adjustment regarding a tax return that was jointly filed or that should have been jointly filed. The party receiving such notice from a taxing authority shall provide a copy of the notice to the other party. The Husband and the Wife further agree to cooperate fully with the other in any claims for refunds or in defending against any deficiencies that may be determined with respect to joint income tax returns filed (or to be filed) for the calendar year 2007 and years prior. This includes, without limitation, the Q of V making, executing, and filing of amended income tax returns; applications for refunds, protests, and other instruments; and documents as may be required. RELEASE OF GENERAL CLAIMS Except as expressly provided in this Agreement, each party hereby waives, releases, renounces and forever discharges all other claims, causes of action, rights or demands, known or unknown, past, present or future, which he or she now or hereafter has, might have, or could claim to have against the other or any present or future property of the other by reason of the marital relationship or any matter, thing or cause whatsoever. Nothing in this Paragraph shall be deemed to prevent either party from enforcing the terms of this Agreement or from asserting any rights or claims expressly reserved to either party in this Agreement. Nothing herein shall impair or waive any cause of action which either party may have against the other for dissolution of the marriage or any defenses either may have to any such cause of action. The parties, by execution of this Agreement, have provided for a fair and equitable distribution of all property belonging to the parties. AUTOMOBILE INSURANCE Each party shall be responsible for his or her own automobile insurance from the date of separation and thereafter, with no contribution required from the other party. SOCIAL SECURITY AND OTHER BENEFITS Nothing in this Agreement shall constitute a waiver of either partys individual rights to receive Social Security or other governmental benefits (state, local and/or Federal) on his or her own account, as a widow, widower, or separated or divorced person, in consonance with applicable law. BINDING EFFECT This Agreement shall be binding upon the parties, their heirs, administrators, executors and assigns. SUCCESSIONS This Agreement shall inure to the benefit of the parties and their respective heirs, administrators, executors, successors, and assigns. GOVERNING LAW This Agreement shall be governed by the law of the Commonwealth of Pennsylvania. The Husband and the Wife consent to the jurisdiction of the Court of Common Pleas of the Commonwealth of Pennsylvania for the purposes of enforcing the elements of this Agreement. ENTIRE UNDERSTANDING This Agreement contains the entire understanding and agreement of the parties pertaining to these matters, and they shall not be bound by any representations, warranties, promises, covenants, or understandings other than those set forth herein. All prior agreements, understandings, or representations are hereby terminated and cancelled in their entirety and are of no further force. No amendment or modification of this Agreement or any judgment or order based on it shall be valid unless signed by the Husband and the Wife or ordered by the court after duly noticed hearing. RELIANCE ON MATERIAL REPRESENTATIONS The Husband and the Wife acknowledge that in entering into this Agreement, each has been induced to and is directly and materially relying in good faith on the troth and completeness of the representations and warranties expressly made by the other party to this Agreement. The parties have also either agreed to not exchange any financial statements and records, or upon agreement, have exchanged sworn Financial Disclosure Affidavits (Statements of Net Worth) and 1n of 1.14 other financial data including, but not limited to, joint Federal and State Income Tax Returns, W-2 Wage and Tax statements, data regarding the benefits from employment, pension information, bank statements, checking account statements, and credit card bills, as well as other miscellaneous business and personal financial data. MODIFICATION The parties at any time may, by mutual consent, amend or modify the terms of this Agreement, provided that any modification or waiver of any of the terms of this Agreement shall not be effective unless in writing and executed with the same formality as this Agreement. BREACH AND WAIVER Any waiver of any breach or default under this Agreement shall not be deemed a waiver of any subsequent breach or default. FURTHER ASSURANCES The Husband and the Wife shall each execute and deliver promptly on request any additional papers, documents, and other assurances reasonably necessary in connection with the performance of these obligations. In the event that either party fails or refuses to comply with the provisions of this paragraph, the failing party shall reimburse the other party for all losses and expenses including, but not limited to, attorneys' fees and costs incurred as a result of such failure. SUBMISSION TO COURT This Agreement may be submitted by either party to any court before which a petition for the dissolution of the marriage may be pending for approval by the court and for incorporation into the final judgment decreeing the dissolution of the marriage. SUBSEQUENT DIVORCE If any action for divorce is hereafter instituted by either party against the other, this Agreement may, if desired, be submitted to the Court in such action for approval and incorporation in a decree should one be granted; but this Agreement shall be independent of, not merged with, nor dependant for its effectiveness upon such approval or incorporation, nor be otherwise affected thereby. RELIGIOUS DIVORCE If requested by either party, the parties shall cooperate fully in obtaining a religious divorce. Each party shall cooperate in executing all documents reasonably necessary to obtain such a divorce. The parties shall be equally responsible for any additional costs which are a direct result of additional fees or processing, associated with any existing, reasonable religious divorce requirements. RECONCILIATION The parties recognize the possibility of reconciliation. It is their intention that a reconciliation, temporary or permanent, or a further separation after any reconciliation, shall in no way abrogate or affect the provisions of this Agreement having to do with the settlement and disposition of the property rights of the parties nor their respective real and personal property, as set forth herein. DISPUTE RESOLUTION The parties agree that every dispute or difference between them, arising under this Agreement, shall be settled first by a meeting of the parties attempting to confer and resolve the dispute in a good faith manner. The parties shall attempt to meet together as soon as reasonably practical. If the parties cannot resolve their dispute after conferring, either party may require the other party to submit the matter to non-binding mediation, utilizing the services of an impartial professional mediator approved by both parties. Such mediation shall occur as soon as reasonably practical and neither party shall unreasonably withhold its consent to the appointment of the mediator. The reasonable costs and expenses of the mediator shall be borne equally between the parties. In •11 nT 13 the event that a dispute between the parties cannot be resolved in the foregoing manner, each of the parties hereby waives its rights to a trial by jury in any action or proceeding arising out of in connection with or in any way pertaining to this Agreement. It is agreed and understood that this waiver constitutes a waiver of trial by jury of all claims against all parties to such action or proceedings, including claims against parties who are not parties to this Agreement. This waiver is knowingly, willingly and voluntarily made by each party. NOTICES All written notices and demands that either of the parties gives to the other party in connection with this Agreement, or any to personal service, shall be made by mailing the notice or demand in a sealed envelope addressed to the party, with postage fully prepaid by certified mail, return receipt requested. Any service to the Husband shall be addressed to him at 7 Sebastian Way, Carlisle, Pennsylvania 17015, or another address designated by him in writing to the Wife. Any service to be made on the Wife shall be addressed to her at 309 Front Street, Boiling Springs, Pennsylvania 17007, or another address designated by her in writing to the Husband. IN WITNESS WHEREOF, the parties hereto have set their hands and seals to two counterparts of this Agreement, each of which will constitute an original, this 17 day of Sv h2 , 20 0W. Gale Martin Riddle, Husband t bAJ, Witness t L Lisa Hincks Ri Ile, Wife f " W1 Witness i-9 of `11 COMMONWEALTH OF PENNSYLVANIA, COUNTY OF 01 LM , SS.: On he 114 V1 day of t k 20 before me, No 1 ?-j? a notary public within and for the County and State aforesaid, personally appeared Gale Martin Riddle, personally known to me for proved to me on the basis of satisfactory evidence) to be the individual whose name is subscribed to the within Agreement and acknowledged to me that he executed the same in his authorized capacity, and that by his signature on the Agreement he executed the same as his free and voluntary act and deed for the uses and purposes therein contained. IN WITNESS W REOF I hereunto se y n nd official seal. COMMONWEALTH OF PENNSYLVANIA Notarial Seal Cathy M. Hoffman, Notary Public East Pennsboro Twp., Cumberland County My Commission Expires May 4, 2010 otary Pub c 614, 2o' 6 Member, Pennsylvania Association of Notaries My commission expires on COMMONWEALTH OF PENNSYLVANIA, COUNTY O SS.: nL 20 before me, On e ?. ' day of `)lL ?I SG t vYkS _ lC rl 1 , a notarY public within and for the County and State aforesaid, personally appeared Lisa Hincks Riddle, personally known to me (or proved to me on the basis of satisfactory evidence) to be the individual whose name is subscribed to the within Agreement and acknowledged to me that she executed the same in her authorized capacity, and that by her signature on the Agreement she executed the same as her free and voluntagry aac?tt deed for the uses and purposes therein contained. COMMONWEALTH Cl PERN9MANIA Notarial Seal IN WITNESS W EREOF I hereunto se my ha d and official seal Cathy M. Hoffman, Notary Public Cumberla East Pennsboro Twp., Expires May 4 County My Commission 9010 Member, Pennsylvania Association of Notaries Notary Public My commission expires on i J S-04 -aQ/v 13 of 13 !lJ 1 W -i v ?A 1 '.Y w. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA liSti ?1 RIO, ?L . Plaintiff 0%- IN Vs File No. 7 DIVORCE (?ti4 M?chh ?d?! I? Defendant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff / defendant in the above matter, [select one by marking "x"] X prior to the entry of a Final Decree in Divorce, or after the entry of a Final Decree in Divorce dated hereby elects to resume the prior surname of H111 L.R.S , and gives this written notice avowing his / her intention pursuant to the provisions of 54 P..$. 704. Date:, ILI 0% ?& 'a "A. Signa e Signature of name being resumed U-sk le COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF On the 3 /,A day of , 200 F, before me, the Prothonotary or the notary public, personally appeared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he / she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand hereunto set my hand and official seal. PtlellQ Prothonotary or Notary Public CANALE C gE W COMMON WM JANUARY 4.2010 J4 _ A Y. S'S 9. 7/ ' A? -74 '7. , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA Lisa Hincks Riddle Plaintiff Gale Martin Riddle Defendant FAMILY DIVISION VS. No. 08-3981 DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in Divorce under Section 3301(c) of the Divorce Code was filed and served on _ ZI I'll } 2.00S (date). 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. 1 consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 4. 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. io g zoo Date Plaintiff SWORN and SUBS CED to befo a me his da of otaryublic COMMONWEALTH OF PENNSYLVANIA Notarial Seal Cathy M. Hoffman, Notary Public East Pennsboro Twp., Cumberland County My Commission Expires May 4, 2010 Member, Per, nsvlvania Association of Notaries n,? MW, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, ENNSYLVANIA FAMILY DIVISION Lisa Hincks Riddle Plaintiff Gale Martin Riddle Defendant vs No. 08-3981 DIVORCE AFFIDAVIT OF CONSENT 1. A complair? in Divo ce under Section 3301(c) of the Divorce Code was filed and served on - T) 00 (date). -k 2 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. 1 consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 4. 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. Date SWORN and SUBSCR?PED to before me this /S day of ?cf boo C N?tP ub lic COMMONWEALTH OF PENNSYLVANIA Notarial Seal Jackie A. Kaftenbaugh, Notary Public South Middleton Up- Cumberland County My Commission Expires Dec. 24, 2009 Member, Pennsylvania Association of Notaries Defendant ev rT, ca ? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA Lisa Hincks Riddle Plaintiff Gale Martin Riddle Defendant FAMILY DIVISION vs. No. 08-3981 DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 43301 (C) AND 83301 (D) To the Prothonotary: 1. 1 consent to the entry of a final decree without notice. 2. 1 understand that I may lose rights concerning alimony, division of property. Lawyer's fee 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 statement are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are subject to the penalties of 18 PA C.S. § 4904, relating to unsworn falsification to authorities. /1og 2D0 , Date Plaintiff r-s zt? ZQr ,. to ?. ME IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FAMILY DIVISION Lisa Hincks Riddle Plaintiff VS. No. 08-3981 Gale Martin Riddle Defendant DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 43301 (C) AND §3301 (D) To the Prothonotary: 1. 1 consent to the entry of a final decree without notice. 2. 1 understand that I may lose rights concerning alimony, division of property. Lawyer's fee 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 statement are true and correct to the best of my knowledge, information and belief. I understand that false statements made herein are subject to the penalties of 18 PA C.S. § 4904, relating to unsworn falsification to authorities. Date Defendant co ? . ?f CT• IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA FAMILY DIVISION Lisa Hincks Riddle Plaintiff Gale Martin Riddle Defendant VS. No. 08-3981 DIVORCE ACCEPTANCE OF SERVICE I, Gale rtin Riddle, hereby state that I have accepted service of a true correct copy of the C_6 *1 A Y'" (document) in the above captioned maftd&r on -71 q In (date) by (a) Certified Mail sent to the following address: (b) Personal Service. This document was hand-delivered by: L,5,, IM LIV,n ra ti whose age is 1?3_ and address is a-?_ Li I A c- Di iv L fty thhn)'c6bum PA n Q?-6 ?'- Defendant CJ +?a C 0 - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Lisa Hincks Riddle Plaintiff FAMILY DIVISION vs. No. 08-3981 Gale Martin Riddle Defendant DIVORCE AFFIDAVIT OF SERVICE Lisa Hincks Riddle, after being duly cautioned and sworn, deposed and says that in regard to the above-captioned case, I served Gale Martin Riddle with a true and correct copy of the Notice to Defend (document) on the date of July 9, 2008 in the manner of (a) Certified Mail sent to the following address: !x_ (b) Personal Service. This document was hand-delivered by: Lisa Mckinney whose age is 43 and address is 22 Lilac Drive Mechanicsburg, PA 17050 SWORN and SUBS RIBED to befo me this * day of , it ANX112 I or 4 5 ? 'Ir &7?' ? ? 4 o ary Pu lc VFJIaintV COMMONWEALTH OF PENNSYLVANIA Notarta' Seal Cathy M. Hoff nai 1, Notary Pubrlc East Pennsboro'i wN„ Cumberland county My Commission Expires May 4, 2010 Member, Pennsylvania Association of Notaries I-a 91 C7 ?r ?G VS. PAth;,, 944 TvAr, "-f- IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NO. OS- 3R 0 I CIVILTERM 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) '3)(1) of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the complaint: Si, 1 2M q b ?s017?( 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 101912OOV by defendant JdP51?? (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: 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: Date defendant's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: r Attorney for Plaintiff / Defendant k/"1 F OM _ J' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. L.i 5k rq li L L!S !(I My1-t P/414w 6"-s2--W10 VERSUS 6AIt rulhh I 'dd llo- Nkmdent 170-5 ?- (off 57 No. Os- ?)'ll DECREE IN DIVORCE - j."I 3s - ' ? AND NOW, O VVft 1{ y 1 IT IS ORDERED AND DECREED THAT LiS,, fhn[s ?/ (7 (1f /? PLAINTIFF, AND (wt w- n l (ll ?.? 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; ,__ e tj V WC PROTHONOTARY ?u ? ?? -? . ??: ?.. . . ??, ??- ?/ ?Q" ?? ' ??