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HomeMy WebLinkAbout08-4649A. LINDA A. CASTLE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA IVIL ACTION - LAW/? , V. C NO- PHILIP D. CASTLE, Defendant IN DIVORCE NOTICE TO DEFEND YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims' set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DECREE OF DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 or 800-990-9108 SAIDIS, FLOWER "NQSAY SAIDIS, FLOWER & L #4DSAY Uw 26 West High Street Carlisle, PA Carol J. Linds , Attorney Id. 26 West Hig Streel Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff 4 LINDA A. CASTLE, Plaintiff V. PHILIP D. CASTLE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. or -v& Y9 +!'c.'U-77.?- IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) or (d) OF THE DIVORCE CODE 1. The Plaintiff is Linda A. Castle, an adult individual, residing at 185 Regal View, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Defendant is Philip D. Castle, an adult individual, residing at 185 Regal View, Carlisle, Cumberland County, Pennsylvania 17013. 3. The Plaintiff and Defendant both have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on January 30, 1982 in Annandale, SAMIS, FtiONVM & LINDSAY 26 West High Street Carlisle, PA Virginia. 5. There have been no prior actions of divorce or for annulment between the parties in this or in any other jurisdiction. 6. The Plaintiff has been advised that counseling is available and that she has the right to request that the court require the parties to participate in counseling. 7. The marriage is irretrievably broken. WHEREFORE, Plaintiff requests entry of a divorce decree in her favor in accordance with §3301 of the Pennsylvania Divorce Code. COUNTI SUPPORT, ALIMONY PENDENTE LITE AND ALIMONY 8. The averments in paragraphs 1 through 7 are incorporated hereto as if fully set forth herein. 9. Plaintiff is unable to provide for her/his reasonable needs in the standard of living established during the marriage. WHEREFORE, Plaintiff requests an award of Support, Alimony and Alimony Pendente Lite. COUNT II ATTORNEY'S FEES AND COSTS 10. The averments in paragraphs 1 through 9 are incorporated hereto as if fully set forth herein. 11. Plaintiff is unable to sustain herself during the course of this litigation or to pay the necessary and reasonable attorney's fees and reasonable costs and expenses. WHEREFORE, Plaintiff requests an award of counsel's fees and expenses. SAIDIS, F?A? & LIVMAY Carol J. Lines 'EsquSire Attorney Id. Sk4 3 26 West Hi treet Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff SAIDIS, I?ZAWER Sz LINDSAY 26 West High Street Carlisle, PA VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsifications to authorities. Lin . Castle Date: 7/3 /O r 3Amis, OWER & IMSAIY C.1_T.? w West High Street Carlisle, PA Q1 -414, r AJ ?+kJ LV L 4, 444 ??` ?t ^ ?, ? c c C t tT _1 i j ? LINDA A. CASTLE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW PHILIP D. CASTLE, NO. D$- OL} Ut,tol Defendant IN DIVORCE AFFIDAVIT OF SERVICE I, Carol J. Lindsay, Esquire, being duly sworn according to law, hereby deposes and says that on August 7, 2008, 1 served a true and correct copy of Complaint in Divorce upon Defendant, by mailing those documents to the his address at 185 Regal View, Carlisle, PA 17013 by Certified U.S. Mail, Restricted Delivery, Return Receipt Requested, as evidenced by the attached U.S. Postal Service Form 3811, Domestic Return Receipt, the latter of which is signed by the recipient, Philip D. Castle. Respectfully submitted, SAIDIS, FLOWER & k WDSAY Carol J-Li say Esquire Attorney I 93 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff Dated: August 26, 2008 SAIDIS, FLOWER & LINDSAY ;WM* 615.AT W 26 West High Street Carlisle, PA 4' *S?AIDIS,, LINDSAY ertoetMeruw 26 West High Street Carlisle, PA • Prktt your Mile and ?ddleee on the rwom eo then we can CetuR1 iha c to you. • Attach this cared to floe back of tM nwoel^ or on the front M epiroe permits. 1. Ardole Addteoad to: ?t h; r . C C S+ e J ?'.? egr? Vl'ec? (?r(FSlel r70 13 A. O Adder Dawy wva "YM of? D. Is Man adtlara tl?arwx fiom bm 17 0 ym M YK a dw dMwry addwsbelow: ANO awvkm Two j9GWMd Md O Exproa? Md ? R?OI -1 1 13 Mum Reoaipt for I I A -aiaa ? Nmaed and 0 C.Q.D. 4. RsatrbMd DaeMtaey4 gxba Foo ar be Mw1Aw (lfanm*.ftm 7008 0150 0001 6187 6075 ,rarvlo. Mbsl) Ps Relna M 1, ftb wy =4 De.wr. twewn fteaW te1e864046.140 tr (Domestic Onl y; No Insuranc e Coverage , N C3 delivery For _o OFF ICIA L U!5-t r- ? rl Postage $ 8 Certified Fee a O Return Receipt Fee Postmark C3 (Endorsement Required) 01 1,5 Here C3 Restricted Deh" Fee O (Endorsement Required) , L rA Total Postage & Fees $ O co Sent To !; 7 --r- f I - ti'- ---- --------------- t3 Street, Apt. No.; rti or PO Box No. 85 Q 41 "e- j ------ ---- --- -- ---------------------------------------------- ?..? y ?t-,. ?::? i ?.>?: t ? a ?,; ?`F ? f?.t"'? .? i v.: ??: ? ? a .. , / . 2 t'., 1?; .,` LINDA A. CASTLE VS. PHILIP D. CASTLE : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 4649 2008 Defendant MOTION FOR APPOINTMENT OF MASTER Philip D. Castle Defendant , moves the court to appoint a master with respect to the following claims: ?X Divorce ? Distribution of Property ? Annulment X? Support X? Alimony X? Counsel Fees © Alimony Pendente Lite ® Costs and Expenses and in support of the motion states: 1. Discovery is complete as to the claims (s) for which the appointment of a master is requested. 2. The Plaintif f has appeared in the action (personally) (by- attorney,_ her Marylou Matas , Esquire). 3. The staturory ground (s) for divorce Irretrievable breakdown. ?_yq = i - rn 4. Delete the inapplicable paragraph (s): A ? BE CE] - a. The action is not contested. ._, -- - b. An aereement has been reached with respect to the following claims: C. The action is contested with respect to the following claims: See above. 5. The action does not involve complex issues of law or fact. 6. The hearing is expected to take I days 7. Additional information, if any, relevant to the motion: ? - wkl ) Date: Ar AAttomO'y f Defendant Jennifer L. Spears Print Name ORDER APPOINTING MASTER AND NOW , 20 Esquire, is appointed master with respect to the following claims: Plaintiff By the Court, LINDA A. CASTLE PHILIP D. CASTLE VS. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 4649 2008 Defendant MOTION FOR APPOINTMENT OF MASTER Philip D. Castle Defendant , moves the court to appoint a master with respect to the following claims: ?X Divorce ? Distribution of Property ? Annulment ?X Support ?X Alimony ? Counsel Fees © Alimony Pendente Lite ® Costs and Expenses and in support of the motion states: 1. Discovery is complete as to the claims (s) for which the appointment of a master is requested. 2. The Plaintiff has appeared in the action (personally) (by 7 attorney,_ her Marylou Matas , Esquire). 3. The staturory ground (s) for divorce 18 -, Irretrievable breakdown. 4. Delete the inapplicable paragraph (s): A ? B © CF Lf a. The action is not contested. ?n r b. An agreement has been reached with respect to the following claims: C. The action is contested with respect to the following claims: See above. 5. The action does not involve complex issues of law or fact. 6. The hearing is expected to take I days 7. Additional information, if any, relevant to the motion: Date:-311bb? Attorn f Defendant Jennifer L. Spears Print Name ORDER APPOINTING MASTER AND NOW 5 , 20/ I . Esquire, is appointed master with respect to the following claims: '?Q.,1-/ ,mm By the Court, did I c° i a Fl ?11-en f L/Spy is e Mar4loo Mal", 1. Ord CASTLE LINDA A IN THE COURT OF COMMON PLEAS , . Plaintiff CUMBERLAND COUNTY, PENNSIgV"IA ° V. CIVIL ACTION - LAW M°,-n° c NO. 2008-4649 can tom- PHILIP D. CASTLE, -<3> 21, ?° Defendant IN DIVORCE C) Ica NOTICE TO DEFEND - -- , ?- Cn 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. 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 or 800-990-9108 SAIDIS, SULLIVAN & ROGERS Law Offices of Saidis Sullivan & Rogers 26 West High Street Carlisle, PA 17013 Marylou Ida s, Esquire Attorney I . 84919 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff c4Mk- 4,301. So Ck u SI SSS pip) I (P 4J LINDA A. CASTLE, Plaintiff V. PHILIP D. CASTLE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2008-4649 IN DIVORCE PETITION FOR EQUITABLE DISTRIBUTION AND NOW, comes the Petitioner, Linda A. Castle, by and through her counsel, Marylou Matas, Esquire and the law firm of Saidis, Sullivan & Rogers and Petitions this Honorable Court as follows: 1. Plaintiff is Linda A. Castle, an adult individual currently residing at 150 Cranes Gap Road, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Philip D. Castle, an adult individual currently residing at 185 Regal View, Carlisle, Cumberland County, County, Pennsylvania. 3. The parties hereto are Husband and Wife having been joined in marriage on January 30, 1982, in Annandale, Virginia. 4. Plaintiff herein filed a Complaint in Divorce on or about August 1, 2008. 5. During their marriage, the parties have acquired certain property, both personal and real. WHEREFORE, Plaintiff requests this Honorable Court to equitably divide the Law Offices of Saidis Sullivan & Rogers 26 West High Street Carlisle, PA 17013 marital property of the parties. Dated: Respectfully submitted, SAIDIS, SUL IVAN & ROGERS i J?I Marylou M t , Esquire 26 West Hig Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to c:nmvorn falsifications to a0t!;orities. l A. Castle Date: 7111 Law Offices of Saidis Sullivan & Rogers 26 West High Strcet Carlisle, PA 17013 F:\FILES\Clients\13135 Castle\13135.1 aos won Revised: 11/18/11 9:55AM Jennifer L. Spears, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. Nos. 29943 and 87445 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant C7 C* J ern -,.;o L' 3y r? ?o ?y Q 0 N N ss w rv I? G7 t C7 LINDA A. CASTLE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW NO. 08-4649 CIVIL TERM PHILIP D. CASTLE, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on August 1, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in 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 unswom falsification to authorities. Date: \??t(4?t Philip D. Castle, Defendant C C7 r" ax 4,, Jennifer L. Spears, Esquire -aZ MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER i ° ` J MARTSON LAW OFFICES cnn - N I.D. Nos. 29943 and 87445 10 East High Street nc-t ' Carlisle, PA 17013 o 7 (717) 243-3341 Attorneys for Defendant LINDA A. CASTLE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 08-4649 CIVIL TERM PHILIP D. CASTLE, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) AND § 3301(d) 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 this waiver 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: _< l ? 4 ?\ Philip D. Castle, Defendant LINDA A. CASTLE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : CIVIL ACTION - LAW : NO. 2008-4649 CIVIL TERM PHILIP D. CASTLE, Defendant IN DIVORCE QUALIFIED DOMESTIC RELATIONS ORDER This cause came before the Court for entry of a Qualified Domestic Relations Order as that term is defined and applied under Section 414(p) of the Internal Revenue Code of 1986 or any successor statute thereto (the "Code"). As the terms of this Order have been stipulated and agreed to by the parties, and the Court has been fully advised thereof, IT IS HEREBY ORDERED AS FOLLOWS: 1. Background. This Order pertains to the Allianz Life Insurance Company of North America, BonusDex Annuity Account, (hereinafter referred to as the "Plan"); is incorporated into the judgment order dissolving the marriage of the parties; and may be amended if necessary to comply with the Code. The Court retains jurisdiction of the subject matter hereof and the parties hereto to enforce the terms of this Order. 2. Applicable Law. This Order is intended to be a Qualified Domestic Law Offices of Saidis Sullivan & Rogers 26 West High Street Carlisle, PA 17013 Relations Order (hereinafter referred to as "QDRO") as that term is defined by Section 414(p) of the Internal Revenue Code and Section 206(d)(3) of ERISA, as amended. This Order relates to the equitable division of martial property as defined under the Pennsylvania Domestic Relations Code of 1980, as amended. 3. Definitions. As used in this Order, the following terms shall apply: a. "Participant" shall mean Philip D. Castle, whose current address is 904 Patton Drive, Carlisle, Pennsylvania, 17013, and whose Social Security Number is and whose date of birth is July 30,1962. b. "Alternate Pave e" shall mean Linda Castle, whose current address is 150 Cranes Gap Road, Carlisle, Pennsylvania, 17013, and whose Social Security Number is and whose date of birth is October 18, 1962. C. "Administrator'' shall mean The Plan Administrator for the Allianz Life Insurance of North America, in care of Policy Administration, PO Box 59060, Minneapolis, MN 55459-0060, facsimile 763-582-6004. 4. Assianment to Alternate Payee. The Alternate Payee (who is the former spouse of the Participant) is awarded and assigned the amount of TWO HUNDRED THIRTEEN FOUR HUNDRED EIGHT DOLLARS AND 00/100 ($213,408.00) from Participant's BonusDex Annuity account, Policy No. 7983291. Any outstanding loans shall be treated or allocated as follows: Participant shall continue to make payment on any outstanding loans and such loans shall not in any way affect the Alternate Payee's monetary benefit as assigned in this paragraph. 5. Commencement of Asslaned Benefits to Alternate Payee. The Alternate Payee shall receive the Alternate Payee's assigned benefit under the Plan as soon as administratively practicable following the Administrator's determination that this Order is a Qualified Domestic Relations Order. 6. Form of Payment. Upon Alternate Payee's request for an immediate Law Offices of Saidis Sullivan & Rogers 26 West High Street Carlisle, PA 17013 distribution, as soon as administratively feasible after the date this Order is determined to be a QDRO by the Plan Administrator, the Plan shall distribute Alternate Payee's interest in a single lump sum payment directly to Alternate Payee, or at the direction of Alternate Payee, to an Individual Retirement Account. The Alternate Payee shall complete such distribution forms as may be required under the terms of the Plan. In the event Alternate Payee does not request an immediate distribution, as soon as administratively feasible after this Order is determined to be a QDRO by the Plan Administrator, the Alternate Payee's interest shall be separated from the Participant's interest in the account and will be held by the Plan in a separate account for the Alternate Payee until Alternate Payee's request for distribution. Such separate account will be credited with its allocable share of the income and losses of the Plan but shall not be credited with any future contributions or forfeitures. Alternate Payee shall have the same ability to designate the investment of the amounts in the separate account as the Participant would otherwise have had with respect to those amounts. In accordance with the Plan, as soon as administratively feasible after Participant's Normal Retirement, death or termination of employment, or at such earlier time as Alternate Payee may request in writing, the Plan shall distribute the amount in Alternate Payee's separate account to Alternate Payee in a single lump sum payment directly or, at the direction of the Alternate Payee, to an Individual Retirement Account. The Alternate Payee shall complete such distribution forms as may be required under the terms of the Plan. 7. Death of Participant. The death of the Participant, either before or after the Alternate Payee has received payment of the Alternate Payee's assigned benefit, shall neither affect the Alternate Payee's right to payment of the assigned benefit nor entitle the Alternate Payee to any additional benefits. 8. Death of Alternate Payee. a. Before Commencement to Alternate Payee. If the Alternate Law Offices of Saidis Sullivan & Rogers 26 West High Street Carlisle, PA 17013 Payee dies prior to receiving payment of the benefits assigned under this Order, the benefits payable under this Order shall be paid to Alternate Payee's beneficiary, or if no beneficiary has been designated, then to her estate. b. After Commencement to Alternate Payee. If the Alternate Payee dies after receiving payment of the benefits assigned under this Order, no additional benefits shall be payable under this Order. 9. Taxes. For purposes of Sections 402(a)(2) and 72 of the Internal Revenue Code, any Alternate Payee who is the spouse or former spouse of the Participant shall be treated as the distributee of any distribution or payments made to the Alternate Payee under the terms of this Order, and as such, will be required to pay the appropriate federal income taxes on such distribution. The Alternate Payee shall have the right to roll over the benefits distributed to her pursuant to the terms and provisions of this Order to an eligible retirement plan such as an Individual Retirement Account. Subject to the conditions imposed by ERISA and the Internal Revenue Code, such transfer shall be considered a tax-free rollover of the benefits distributed. 10. Continuina Interests. From the date of this Order and thereafter, except as provided herein, the Alternate Payee shall have no further right or interest in any portion of Participant's Plan benefits. From the date of this Order and thereafter, except as provided herein, the Participant shall have no further right or interest in any portion of the Plan benefits which are assigned to the Alternate Payee pursuant to this Order. 11. Costs for Implementation. Any reasonable costs incurred by the Plan Administrator to effectuate the terms and provisions of the Qualified Domestic Relations Order shall be assessed against the parties such that the Alternate Payee pays 50% of the costs and the Participant pays 50% of the costs. 12. Plan Provisions to Govern. This Order shall not be construed to require Law Offices of Saidis Sullivan & Rogers 26 West High Street Carlisle, PA 17013 the Plan, the Administrator, or any trustee or other fiduciary with respect to the Plan to take any action which is inconsistent with any provision of the Plan, as now or hereafter in effect. The Participant and the Alternate Payee shall be subject to all of the provisions of the Plan and any administrative rules as from time to time in effect under the Plan. 13. Limitations. This order shall not be construed to require the Plan, the Administrator, or any trustee or other fiduciary with respect to the Plan to: a. Make any payment or take any action which is inconsistent with any federal law, rule, regulation, or applicable judicial decision; b. Provide any type or form of benefit, or any option, which is not otherwise provided under the provisions of the Plan; C. Pay benefits to the Alternate Payee that are required to be paid to another alternate payee under another order previously determined to be a Qualified Domestic Relations Order in accordance with the provisions of Code Section 414(p) and Section 206(d) of the Employee Retirement Income Security Act. 14. Mailing to Last Known Address. All appropriate payments, notices and other communications shall be mailed to the Participant and the Alternate Payee at the respective addresses set forth in Paragraph 3 above, until such time as the Participant or Alternate Payee advises the Administrator in writing of the occurrence of a change of address. Any benefit payment or communication to the Alternate Payee at the Alternate Payee's last known address shall operate on a complete discharge of the obligations, with respect to such payment or communication, of the Plan. 15. Parties to Cooperate. If the Administrator of the Plan does not agree that this is a "Qualified" Domestic Relations Order under Code Section 414(p), each party shall cooperate and do all things reasonably necessary to devise a form of Order acceptable to the Administrator as a Qualified Domestic Relations Order. BY THE COURT: Law Offices of Saidis Sullivan & Rogers 26 West High Street Carlisle, PA 17013 211z-f le', 6/a Date 49?4- Withes&V Wi es cc p;PS wta"lr d sI //1a. J dge t '"Cj ?v i Philip D. astle, Participant -5, -- 6 ? Dated: 31 Zvi 2 A =; -a n a. ? Tz a Castle, ernate yee - Dated: 3 Z8 -Zo/Z COMMONWEALTH OF PENNSYLVANIA ?_? / SS COUNTY OF CQ M[?•A' I0P : On this 3rd day of Q , 2012, before me, the undersigned officer, personally appeared PHILIP . CASTLE, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Agreement and acknowledged that he executed the same for the purpose therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. Law Offices of Saidis Sullivan & Rogers 26 West High Street Carlisle, PA 17013 COMMONWEALT+i\OF PENNSYLVANIA COUNTY OF SS On this day of Z 44 ?_, 2012, before me, the undersigned officer, personally appeared L A CASTLE, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Agreement and acknowledged that she executed the same for the purpose therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. otary Public NOTARIAL SEAL RENEE L. MURRAY. Notary Public Carlisle Boro, Cumberland County. PA My Commission Expires Dec. 13, 2013 F.\FILES\Clients\13135 Castle\13135.1. PRA Revised 5/16/12 1009AM Jennifer L. Spears, Esquire MARTSON LAW OFFICES I.D. Nos. 29943 and 87445 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Defendant 1112 ; v 18 P11 2: CUMSERLAM) PENNSYLVANIX LINDA A. CASTLE, Plaintiff V. PHILIP D. CASTLE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 08-4649 CIVIL TERM IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: via certified mail, restricted delivery on August 7, 2008. 3. Date of execution of the Plaintiff's affidavit of consent required by Section 3301 (c) of the Divorce Code; November 30, 2011; by the Defendant; November 18, 2011. 4. Related claims pending: All claims have been resolved by a Marital Settlement Agreement dated November 15, 2011. 5. Date Plaintiff's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: December 1, 2011. Date Defendant's Waiver ofNotice in §3301(c) Divorce was filed with the Prothonotary: November 22, 2011. MARTS AW OFFICES By Jenni . Spears, Esquire Ten East High Street Carlisle, PA 17013 (717) 243-3341 Date: May 18, 2012 Attorneys for Defendant LINDA A. CASTLE V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PHILIP D. CASTLE NO 2008-4649 DIVORCE DECREE AND NOW, t 3 ao it is ordered and decreed that LINDA A. CASTLE plaintiff, and PHILIP D. CASTLE bonds of matrimony. defendant, are divorced from the 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.") A Marital Settlement Agreement dated November 15, 2011, is incorporated but not merged into this Decree. Prothonotary By the Court, tEr rn7?L?c.L