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HomeMy WebLinkAbout08-4584 SHELLY CAVANAUGH, Plaintiff V. KEITH CAVANAUGH, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 08 - qqq CIVIL TERM IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselor is available in the Office of the Prothonotary, Cumberland County Courthouse, Carlisle, Pennsylvania 17013. 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORAMTION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Phone: (717) 249-3166 (800) 990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. SHELLY CAVANAUGH, Plaintiff V. KEITH CAVANAUGH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 08 - L/5-y CIVIL TERM IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Shelly Cavanaugh, an adult individual, who resides at 5 Penn Drive, Newville, Cumberland County, Pennsylvania 17241. 2. Defendant is Keith Cavanaugh, an adult individual, who resides at 720 Pinetown Rd., Lewisberry, York County, Pennsylvania 17339. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on October 29, 2005 in Harrisburg, Dauphin County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 8. Plaintiff requests the Court to enter a Decree in Divorce. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree in Divorce and such other Orders as may be just and appropriate. ?' ? D d Date: Respectfully submitted, BAYLEY & MANGAN U?- Mark F. Bayley, Esquire 17 West South St. Carlisle, PA 17013 (717) 241-2446 Supreme Court I.D. # 87663 Attorney for Plaintiff VERIFICATION 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. r Date: " avl,? Shelly Cavanaugh, Plaintiff ?.a A A i 4 6, f MEt R nA .rr Zp40 APR °5 PM 3= 31 SHELLY CAVANAUGH,AB' COURT OF COMMON PLEAS OF Plaintiff pEN.- ?YjYMWBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW KEITH CAVANAUGH, NO. 08 - 4584 CIVIL TERM Defendant IN DIVORCE ACCEPTANCE OF SERVICE I hereby accept service of the Complaint in Divorce on behalf of the Defendant, Keith S. Cavanaugh, in the above-captioned action and I certify that I am authorized to do so. C<Z-01-zoc)? Date Keith S. Cavanaugh, Defendant BY: 4?4?2_ 6, FlI.Eo-?)Ir?iGE Tnr ?2010 APR -5 PM 131 SHELLY CAVANAUGH, : , JIN URT OF COMMON PLEAS OF Plaintiff CUMBER AND COUNTY, PENNSYLVANIA P-144MAX V. CIVIL ACTION - LAW KEITH CAVANAUGH, NO. 08 - 4584 CIVIL TERM Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in Divorce under §3301(c) of the Divorce Code was filed on July 30, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of the final Decree in Divorce after service of Notice of Intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. §4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. - a jaw, Da e Shelly Cavanau FILED-OFFICE .7 T, SHELLY CAVANAUGH, Plaintiff V. KEITH CAVANAUGH, Defendant 2010 APR -5 PM 3; 31 IN THE COURT OF COMMON PLEAS OF COUNTY, PENNSYLVANIA PENPv t? CIVIL ACTION - LAW NO. 08 - 4584 IN DIVORCE WAIVER OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 43301(C) OF THE DIVORCE CODE I consent to the entry of a final Decree of Divorce without notice. CIVIL TERM 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a Divorce Decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. §4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. 3 h5 a?l© "A' Date Shelly Cavana gh R ED-(yFICE 7APY SHELLY CAVANAUGH, Plaintiff " ATEE-$ -41 IN TH CO COMMON PLEAS OF CUWJP P, AUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW KEITH CAVANAUGH, NO. 08 - 4584 CIVIL TERM Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in Divorce under §3301(c) of the Divorce Code was filed on July 30, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of the final Decree in Divorce after service of Notice of Intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. §4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. Date Keith Cavanaugh Fil Eft-+W!-r-ICE SHELLY CAVANAUGH, Plaintiff V. KEITH CAVANAUGH, Defendant 2010 APR -5 Pty 3: 3 I IN THE COURT OF COMMON PLEAS OF : CSI RLA=NMUNTY, PENNSYLVANIA PENNSYLVANIA CIVIL ACTION - LAW NO. 08 - 4584 CIVIL TERM IN DIVORCE WAIVER OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 43301(C) 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, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a Divorce Decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. §4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. ©3-30-10 Date Keith Cavanaugh MARITAL SEPARATION AGREEMENT THIS AGREEMENT, entered into on the specified date below, by and between Keith Cavanaugh, (hereinafter referred to as "HUSBAND") and Shelly Cavanaugh, (hereinafter referred to as "WIFE"). WITNESSETH: WHEREAS, HUSBAND and WIFE were lawfully married on October 29, 2005; and WHEREAS, diverse, unhappy differences, disputes and difficulties have arisen between the parties and it is the intention of HUSBAND and WIFE to live separate and apart for the rest of their natural lives, and the parties hereto are desirous of settling fully and finally their respective financial and property rights and obligations as between each other, including, without limitation by specification; the settling of all matters between them relating to the ownership and equitable distribution of real and personal property; the settling of all claims and possible claims by one against the other or against their respective estates and equitable distribution of property and alimony for each party. NOW, THEREFORE, in consideration of the promises and the mutual promises, covenants and undertakings hereinafter set forth and for other good and valuable consideration, receipt of which is hereby acknowledged by each of the parties hereto, HUSBAND and WIFE, each intending to be legally bound, hereby covenant and agree as follows: I . The parties intend to maintain separate and permanent domiciles and livq?Vart from each other. It is the intention and purpose of this agreement to set forth the r?tive rights and duties of the parties while they continue to live apart from each other. Z x ;:0 (-n 2. The parties have attempted to divide their matrimonial property in 4-6`m1e;-&hat conforms to a just and right standard, with due regard to the rights of each party. Ikihe = intention of the parties that such division shall be final and shall forever determine t Jr respective rights. The division of existing marital property is not intended by the 1) S tQ-- constitutein any way a sale or exchange of assets. 3. Further, the parties agree to continue living separately and apart from each other at any place or places that he or she may select. Neither party shall molest, harass, annoy, injure, threaten or interfere with the other party in any manner whatsoever. Each party may carry on and engage in any employment, profession, business or other activity, as he or she may deem advisable for his or her sole use and benefit. Neither party shall interfere with the uses, ownership, enjoyment or disposition of any property now owned and not specified herein or property hereafter acquired by the other. 4. The consideration for this contract and agreement is the mutual benefits to be obtained by both of the parties hereto and the covenants and agreements of each of the parties to the other. The adequacy of the consideration for all agreements herein contained is stipulated, confessed, and admitted by the parties, and the parties intend to be legally bound hereby. 5. Each party to this agreement acknowledges and declares that he or she, respectively: A. Enters into this agreement voluntarily after receiving the advice of counsel; or has voluntarily decided not to receive advice from counsel acknowledging that adequate time and opportunity has been provided to do so; B. Is fully and completely informed of the facts relating to the subject matter of this agreement and of the rights and obligations of the parties; C. Has given careful and serious thought to the making of this agreement; D. Has carefully read each provision of this agreement; and E. Fully and completely understands each provision of this agreement, both as to the subject matter and legal effect. 6. Each party represents and warrants that he or she has made a full and fair disclosure to the other of all of his or her property interests of any nature, including any mortgage, pledge, lien, charge, security interest, encumbrance, or restriction to which any property is subject. Each party further represents that he or she has made a full and fair disclosure of all debts and obligations of any nature for which he or she is currently liable or may become liable. Each further represents and warrants that he or she has not made any gifts or transfers of Marital Property for inadequate consideration without the prior consent of the other. Each party acknowledges that, to the extent desired, he or she has had access to all of the above information from the other party. Each party acknowledges that, to the extent desired, he or she has had access to all joint and separate state and federal tax returns filed by or on behalf of both parties during the marriage. 7. DEBTS AND LIABILITIES: It is further mutually agreed by and between the parties that HUSBAND and WIFE will be responsible for the following debts, liabilities, contracts and payments relating to the same: a. HUSBAND will be responsible for all debts, liabilities, contracts and payments relating to any accounts, deeds, and titles currently under his name and/or property of any kind in HUSBAND'S possession at time of execution of the within agreement. b. WIFE will be responsible for all debts, liabilities, contracts and payments relating to any accounts, deeds, and titles currently under his name and/or property of any kind in WIFE'S possession at time of execution of the within agreement. 8. REAL ESTATE: a. WIFE shall have full ownership of any real property purchased by WIFE after April 3, 2008. 2 b. HUSBAND shall have full ownership of the marital residence at 720 Pinetown Road, Lewisberry, Pennsylvania, and any other real property purchased by HUSBAND after April 3, 2008. 9. CASH ASSETS: The parties have previously separated cash assets not otherwise mentioned by this agreement to their satisfaction. 10. PERSONAL PROPERTY: Personal property not otherwise mentioned by the within agreement will belong to the respective party possessing the personal property at the time of execution of the within agreement. 11. SUPPORT AND ALIMONY: Both parties hereby waive and forego all financial and material spousal support from each other and agree not to request or seek to obtain alimony or spousal support before or after any divorce which may be granted. 12. RETIREMENT ACCOUNTS/ PENSIONS: a. HUSBAND will assume full ownership of any and all pension, retirement and/or investment plans/accounts of any kind currently in his name. b. WIFE will assume full ownership of any and all Pension and/or Retirement and/or Investment plans/accounts currently in her name. 13. WAIVER OF CLAIMS AGAINST THE ESTATES: Except as otherwise provided herein, each party may dispose of his or her property in any way, and each party hereby waives and relinquishes any and all rights he or she may now have or hereafter acquire, under the present or future laws of any jurisdiction, to share in the property or the estate of the other as a result of the marital relationship, including without limitation, 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 as administrator 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. Additionally, each party waives and relinquishes any and all rights to share in any estate inheritances or bequests the other may receive and/or be entitled to. 14. INCOME TAX RETURNS: a. All future income tax returns will be filed separately and the parties will each retain any refund due to them unless otherwise agreed upon in writing. 15. DIVORCE: HUSBAND and WIFE agree to voluntarily execute all necessary documents to finalize a divorce within seven (7) days of the expiration of the mandatory waiting period. 16. BREACH: In the event of the breach of this agreement by either party, the nonbreaching party shall have the right to seek monetary damages for such breach, where such damages are ascertainable, and/or to seek specific performance of the terms of this agreement, where such damages are not ascertainable. All costs, expenses and reasonable attorney fees 3 incurred by the successful party in any litigation to obtain monetary damages and/or specific performance of this agreement shall be recoverable as part of the judgment entered by the court. 17. ADDITIONAL INSTSRUMENTS: Each of the parties shall from time to time, at the request of the other, execute, acknowledge and deliver to the other party any and all further instruments that may be reasonably required to give full force and effect to the provisions of this agreement. 18. ENTIRE AGREEMENT: This agreement contains the entire understanding of the parties and there are no representations, warranties, covenants or undertakings other than those expressly set forth herein. 19. APPLICABLE LAW: This agreement shall be construed under the laws of the Commonwealth of Pennsylvania. 20. PRIOR AGREEMENTS: It is understood and agreed that any and all property settlement agreements which may or have been executed or verbally discussed prior to the date and time of this agreement are null and void and of no effect. 21. DATE OF EXECUTION: The "date of execution" or "execution date" of this Agreement shall be defined as the date upon which it is executed by the parties if they have each executed the Agreement on the same date. Otherwise, the "date of execution" or "execution date" of this Agreement shall be defined as the date of execution by the party last executing this Agreement. 22. MARITAL DEBT: Each party hereby confirms they have not incurred any additional debt since their separation that has in any way obligated the other party. Neither party will take any action to incur additional debt of any nature whatsoever in the other party's name from the date of execution of this Agreement forward. 23. EQUITABLE DISTRIBUTION: It is specifically understood and agreed that this Agreement constitutes an equitable distribution of property, both real and personal, which was legally and beneficially acquired by Husband and Wife or either of them during the marriage as contemplated by The Act of April 2, 1980 (P.L. No. 63, No. 26), known as "The Divorce Code," 23 P.S. 101 et seq. of the Commonwealth of Pennsylvania, and as amended. 24. SUMMARY OF EFFECT OF AGREEMENT: It is specifically understood and agreed by and between the parties hereto, and each party accepts the provisions herein made in lieu of and in full settlement and satisfaction of any and all of the said parties' rights against the other for any 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 each party, including all claims raised by them in the divorce action pending between the parties. 25. RECONCILIATION: The parties shall only effectuate a legal reconciliation which supersedes this Agreement by their signed agreement containing a specific statement that they have reconciled and that this Agreement shall be null and void; otherwise, this Agreement shall remain in full force and effect. Further, the parties may attempt a reconciliation, which 4 action, if not consummated by the aforesaid agreement, shall not affect in any way the legal affect of this Agreement or cause any new marital rights or obligations to accrue. 26. SEVERABILITY: If any term, condition, clause or provision of this Agreement shall be determined or declared to be void or invalid in law or otherwise, then only that term, condition, clause or provision shall be stricken from this Agreement and in all other respects this Agreement shall be valid and continue in full force, effect and operation. Likewise, the failure of any party to meet her or his obligations under any one or more of the paragraphs herein, with exception of the satisfaction of the conditions precedent, shall in no way void or alter the remaining obligations of the parties. 27. NO WAIVER OF DEFAULT: This agreement shall remain in full force and effect unless and until terminated under and pursuant to the terms of this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall in no way affect the right of such party hereafter to enforce the same, nor shall the waiver of any breach of any provision hereof be construed as a waiver of any subsequent default of the same or similar nature, nor shall it be construed as a waiver of strict performance of any other obligations herein. 28. INTEGRATION: This Agreement constitutes the entire understanding of the parties and supersedes any and all prior agreements and negotiations between them. There are no representations or warranties other than those expressly set forth herein. This Agreement shall survive integration by any court into any judgment for divorce and shall continue to have independent legal significance as a written contract separate from such judgment for divorce and may be enforced as an independent contract. 29. EFFECT OF DIVORCE DECREE: The parties agree that unless otherwise specifically provided herein, this Agreement shall continue in full force and effect after such time as a final Decree in Divorce may be entered with respect to the parties. 30. WAIVER OR MODIFICATION TO BE IN WRITING: No modification or waiver of any of the terms hereof shall be valid unless in writing and signed by both parties and no waiver of any breach hereof or default hereunder shall be deemed a waiver of any subsequent default of the same or similar nature. 31. AGREEMENT BINDING ON HEIRS: This Agreement shall be binding and shall insure to the benefit of the parties hereto and their respective heirs, executor, administrators, successors and assigns. 5 32. ACTIVATION: This agreement shall become effective immediately upon its execution by both parties. IN WITNESS WHEREOF, the parties have hereunto set their hands and seals on the date indicated below. WITNESSES: 4?WL6 03-16-10 Keith Cavanaugh Date Shelly Ca anaugh Date COMMONWEALTH OF PENNSYLVANIA U a, : SS COUNTY OF C PERSONALLY APPEARED BEFORE ME, a notary public for Cumberland County Pennsylvania, this day of(y), 2010 Keith Cavanaugh, known tome (or satisfactorily proven) to be the person whose name is subscribed to the within agreement, and acknowledge that he executed the same for the purposes therein contained. IN WITNESS WHREOF, I have hereunto set my hand and official seal. PENNSYLV Notarial Seal V, Barbra J. WrIoN, Notary Public Fahviety T gin,. , York County At a ry My Comrrtiasiat Expires ,A.ug. 2, 2010 COMMONWAArVfff TWTtR10f.0 t r A : SS COUNTY OF CUMBERLAND PERSONALLY APPEARED BEFORE ME, a notary public for Cumberland County Pennsylvania, this day of MCL20 h , 200 D , Shelly Cavanaugh, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within agreement, and acknowledge that she executed the same for the purposes therein contained. IN WITNESS WHREOF, I have hereunto set my hand and official seal. COMMONWEALTH OF PENNSYLVANIA Notarial Seal Julie M. Good, Notary Public Carlisle Boro. C`a tmbedand Comty My Commission Exp4r D-c. 6, 2011 Member, Penns,pvania Ass7-110ton of NotNrlwe 4 W'6 M. A)ou tary Publie 6 BAYLEY & MANGAN Mark F. Bayley, Esquire Attorney I.D. #: 87663 17 West South Street Carlisle, PA 1701.3 (717) 241-2446 FI! M- -F ICE TAPY 2010 APR -5 PM 3: 3 I CUr BEP.,'LA--4wa 1?(y MY PENNSYLVANIA SHELLY CAVANAUGH, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW KEITH CAVANAUGH, NO. 08 - 4584 CIVIL TERM Defendant IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Grounds for divorce: irretrievable breakdown under § 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: filed on July 30, 2008 and Acceptance of Service signed on August 1, 2008. 3. Date of execution of the affidavit of consent required by § 3301(c) of The Divorce Code: by the Plaintiff March 25, 2010; by the Defendant March 30, 2010. 4. Related claims pending: None 5. Date Plaintiff's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: contemporaneously with this filing. Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: contemporaneously with this filing. Date F. Bayley, Esqui BAYLEY & MANGAN 17 W. South St. Carlisle, PA 17013 717) 241-2446 Supreme Court I.D. # 87663 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SHELLY CAVANAUGH V. KEITH CAVANAUGH DIVORCE DECREE AND NOW, Zc? 1 n , it is ordered and decreed that SHELLY CAVANAUGH plaintiff, and KEITH CAVANAUGH defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") NONE. Prothonotary NO. 2008 - 4584 By the Court, c{-,?K- [o CfXA COYvd "V)?ke8 LA - 1:9`- f o t) cti Qk., vY-IC6 \,V-A -tao -bo 41-t? $atd1e.?- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA S hd(y C..Ct vaasaugqit JPlaintiff Vs File No. 7 l'reli4,1 CR. vote? a Defendant oo8 -'fSS IN DIVORCE C S 773 -N- r r) NOTICE TO RESUME PRIOR SURNAME =1'1 (r)I' Notice is hereby given that the Plaintiff / defendant in the above matter, {r� [select one by marking "x "] [_-,'. prior to the entry of a Final Decree in Divorce, or iX after the entry of a Final Decree in Divorce dated / pri '7) aolo hereby elects to resume the prior surname of Get i i £� , and gives this written notice avowing his / her intention pursuant to the provisions of 54 P.S. 704. -1 Date: a0► c{ COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF ) On the 4-day of Signature 6f name being resumed , 201 '/, 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. Prothonotary or Notary Public Prothonotary, Cwnberlaq County, Carlisle, PA My Commission Expires pe First Monday of Jan. 2018 / 3.00 pee , 6,4.4 3'i