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HomeMy WebLinkAbout08-5201BENHAM & CURCILLO John R. Beinhaur, Esquire 3964 Lexington Street Harrisburg, PA 17109 717/651-9100 Attorney ID #55631 STEPHEN B. NORFORD, PLAINTIFF V. GAIL M. NORFORD. DEFENDANT JN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA :NO. ()8- 5A01 C ivy t Term :CIVIL ACTION - LAW AN 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 claim of 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 grounds 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 Courthouse, Courthouse Square, Carlisle, Pennsylvania 17013. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from the list. All necessary arrangements and the cost of counseling sessions are to be borne by the parties. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE THE 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 Lawyer Referral Service 32 South Bedford Street Carlisle, PA 17013 (717) 249-3160 BEINHAUR & CURCILLO John R. Beinhaur, Esquire 3964 Lexington Street Harrisburg, PA 17109 717/651-9100 Attorney ID #55631 STEPHEN B. NORFORD, PLAINTIFF V. GAIL M. NORFORD. DEFENDANT :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA :NO. :CIVIL ACTION - LAW JN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN NAMED DEFENDANT: You have been named as the Defendant in a divorce proceeding filed in the Court of Common Pleas of Cumberland County, Pennsylvania. This notice is to advise you that in accordance with Section 3302(d) of the Divorce Code, as amended, you may request that the Court require you and your spouse to attend marriage counseling prior to a Divorce Decree being handed down by the Court. A list of professional marriage counselors is available at the Office of the Prothonotary, Cumberland County Courthouse, Courthouse Square, Carlisle, Pennsylvania 17013. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from the list. All necessary arrangements and the cost of counseling services are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty (20) days of the date on which you receive this Notice. Failure to do so will constitute a waiver of your right to request counseling. BEINHAUR & CURCILLO John R. Beinhaur, Esquire 3964 Lexington Street Harrisburg, PA 17109 717/651-9100 Attorney ID #55631 STEPHEN B. NORFORD, PLAINTIFF V. GAIL M. NORFORD. DEFENDANT JN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA :NO. :CIVIL ACTION - LAW :IN DIVORCE COMPLAINT COUNT I - Divorce 3301(c) or 3301(d) 1. Plaintiff, Stephen B. Norford, is an adult individual residing at 87 Oneida Road, Camp Hill, Cumberland County, Pennsylvania 17011. 2. Defendant, Gail M. Norford, is an adult individual residing at 204 Clearview Road, New Cumberland, York County, Pennsylvania, 17070. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania and have resided therein for a period in excess of six (6) months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on May 25, 1985, in Berks County, Pennsylvania. 5. Plaintiff avers that the ground upon which this action is based is that the marriage is irretrievably broken. 6. There has been no prior action of divorce between the parties in this or any other jurisdiction. 7. The Defendant is not a member of the Armed Services of the United States of America. 8. 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. 9. Plaintiff and Defendant have lived separate since at least March 1, 2003. 10. There are three children born of this marriage, namely: two adult children, Melanie S. Norford and Julie A. Norford and one minor child, Stephanie N. Norford whose date of birth is July 30, 1996. WHEREFORE, the Plaintiff requests this Honorable Court to enter a Decree of Divorce. Respectfully submitted, BEINHAUR & CURCILLO By: Jjdm R. Be' ur Supreme Court I.D. # 55631 3964 Lexington Street Harrisburg, PA 17109 (717) 651-9100 Attorney for Plaintiff DATED: ? `-ZZ1Q 8 VERIFICATION I have read the foregoing Document and hereby affirm and verify that it is true and correct to the best of my personal knowledge, information and belief. I verify that all of the statements made in the foregoing are true and correct and that false statements made therein may subject me to the penalties of 18 Pa.C.S.A. Section 4904, relating to unworn falsification to authorities. Stephen B. Norford DATE: U .Z.Z D BENHAM & CURCILLO Joseph A. Curcillo, III, Esquire 3964 Lexington Street Harrisburg, PA 17109 717/651-9100 Attorney ID #44060 STEPHEN B. NORFORD, PLAINTIFF V. GAIL M. NORFORD. DEFENDANT :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA :NO. :CIVIL ACTION - LAW :IN DIVORCE CERTIFICATE OF SERVICE AND NOW, this a;?day of 11d?, 2008, I, John R. Beinhaur hereby certify that I have served the foregoing Complaint in Divorce by mailing a true and correct copy by United States first class mail, certified mail return receipt requested, postage prepaid, addressed as follows: Ms. Gail M. Norford 204 Clearview Road New Cumberland, PA 17070 Respectfully submitted, BEINHAUR & CURCILLO q1 , 1?j - By:_ ftu hn R. B our preme Court I.D. # 55631 3964 Lexington Street Harrisburg, PA 17109 (717) 651-9100 Attorney for Plaintiff -?. c? 0 0 1 ` 0 j 'J W Q C' , , mac.. CO ? } _ .,, ? ? b r y ? ' ir i BERWAUR & CURCILLO John R Beinhaur, Esquire 3964 Lexington Street Harrisburg, PA 17109 717/651-9100 Attorney ID #55631 STEPHEN B. NORFORD, PLAINTIFF V. GAIL M. NORFORD. DEFENDANT :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA :NO. 08-5201 Civil Term :CIVIL ACTION - LAW :IN DIVORCE AFFIDAVIT OF SERVICE AND NOW, this 51- day of IA arv -1 200 q , comes John R. Beinhaur, Esquire, of Beinhaur & Curcillo, attorney for Plaintiff, who being duly sworn according to law, deposes and says that: 1. A Complaint for Divorce was filed to the above term and number on August 28, 2008. 2. On September 9, 2008, a certified copy of the Complaint in Divorce was sent to the Defendant via certified mail, return receipt requested pursuant to Pa. R.C.P. 1920.4. 3. On or about September 14, 2008, undersigned counsel for Plaintiff received the return receipt card signed by the Defendant on September 13, 2008, indicating service of the Complaint for Divorce. Said receipt is attached hereto as Exhibit "A" and is incorporated herein by reference. 1 Respectfully submitted, BEINHAUR & CURCILLO By: Jo R. Beinha Supreme Court I.D. #55631 3964 Lexington Street Harrisburg, PA 17109 (717) 651-9100 Attorney for Plaintiff DATED: 6[ i o 5` & o o 2 EXHIBIT «A" f ¦ Complete items 1, 2, and 3. Also complete item 4 If Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mailpiece, " or on the front if space permits. 1. Article Addressed to: fW, 00r7f6r-d al-a*ot? f a `'D by ( D. Is delivery address different from item 1? C7 Yes If YES, enter delivery address below: 0 No A' 3. Service Type O&Certified Mail 0 Express Mail 0 Registered 0 Return Receipt for Merchandise 0 insured mail 0 C.O.D. 4. Restricted Delivery? (Extra Fee) 0 Yes 2. Article Number 7007 0 710 0001 9 914 6888 (r,ansfer from service 1abet) PS Form 3811, February 2004 Domestic Return Receipt 102595-02-W1540 L3 t _r r- qzlk ? T PROPERTY SETTLEMENT AGREEMENT THIS AGREEMENT is made this o day of ?LVfPM&O6 200' , by and between: GAIL M. NORFORD, herein referred to as Wife, of 204 Clearview Road, New Cumberland, Pennsylvania, 17070; and STEPHEN B. NORFORD, herein referred to as Husband, of 87 Oneida Road, Camp Hill, Pennsylvania, 17011. WITNESSETH: WHEREAS, Husband and Wife were lawfully married on May 25, 1985, in Bethel, Berks County, Pennsylvania; and WHEREAS, there are three children born of the marriage, two adult children Melanie S. Norford and Julie A. Norford, and one minor child Stephanie N. Norford, born July 30, 1996; and 'WHEREAS, diverse unhappy marital difficulties have arisen between the parties causing them to believe that their marriage is irretrievably broken, as a result of which they have separated since on or about March 1, 2003, and now live separate and apart from one another with no reasonable expectation of reconciliation due to such marital difficulties; 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 of real and personal property; and in general, the settling of any and all claims and possible claims by one against the'other or against their respective estate, particularly those responsibilities and rights growing out of the marriage relationship. NOW THEREFORE, in consideration of the mutual promises, covenants and undertakings hereinafter set forth and for other good and valuable consideration, the 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: 1. SEPARATION It shall be lawful for each party, at all times hereafter, to live separate and apart from the other, at such place or places as he or she may, from time to time, choose or deem fit. Each party shall be free from interference, authority or contact by the other, as fully as if he or she were single and, unmarried, except as may be necessary to carry out the provisions of this Agreement. Neither party shall molest the other or attempt to endeavor to molest the other, nor compel the other to cohabit with the other, or in any way harass or malign the other, nor in any way interfere with the peaceful existence, separate and apart from the other. Should a Decree, Judgment, or Order of divorce be obtained by either of the parties to this matter, the parties hereby consent and agree that this Agreement and all of its covenants shall be incorporated by reference but not merged with such Decree, Judgment or Order of divorce; and that nothing in any such Decree, Judgment, Order or further modification or revision thereof shall alter, amend or vary any term of this Agreement, whether or not either or both of the parties shall remarry. This incorporation, however, shall not be regarded as a merger, it being the specific intent of the parties to permit this Agreement to survive any Judgment and be forever binding and conclusive upon the parties. 2. EFFECTIVE DATE The effective date of this Agreement shall be the "date of execution" or "execution date", defined as the date upon which it is executed or signed 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 or signing this Agreement. 3. MUTUAL. RELEASES Husband and Wife do hereby mutually. remise, release, quit-claim or forever discharge the other and estate of such other, for all time to come, and for all purposes whatsoever, from any and all rights, title and interest, or claims in or against the estate of such other, or whatever nature and wherever situate, which he or she now has or at any time hereafter may have against such other, the- estate of such other or any part thereof, whether arising out of any former acts, contracts, engagements, or liabilities of such other or by way of dower or curtesy, of claims in the nature of dower or curtesy, or widow's or widower's rights, family exemption or similar allowance or under the intestate laws; or the right to take against the spouse's will; or the right to treat a lifetime conveyance by the other as testamentary or all other rights or.a surviving spouse to participate in, a deceased spouse's estate, whether arising under the United States, or any other country; or any rights which either party may now have or at any time hereafter have for the past, present, or future support or maintenance, alimony, alimony pendente lite, counsel fees, costs or expenses, whether arising as a result of the marital relation or otherwise, except all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provision thereof. It is the intention of Husband and Wife to give to each other, by the execution of this Agreement, a full, complete and general release with respect to any and all property of any kind or nature, real, personal, or mixed, which the other now owns or may hereafter acquire, except, and only except, all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provision thereof. 4. DISTRIBUTION DATE The transfer of property, funds and/or documents provided for herein shall-only take place on the "distribution date" which shall be defined as the date of execution of the Divorce Decree, unless otherwise specified herein. 5. MUTUAL CONSENUADVICE OF COUNSEL Husband and Wife acknowledge and understand the terms and conditions of this Agreement, and Husband is represented by John R. Beinhaur, Esquire, and Wife is or may be represented by her own attorney. Each parry acknowledges that he or she has received or has been given an opportunity to receive independent advice from counsel of his or her selection and was fully informed as to his or her legal rights and obligations. Husband and Wife acknowledge that they fully understand the facts as to their legal rights and obligations under this Agreement. Husband and Wife acknowledge and accept that this Agreement is, under the circumstances, fair and equitable and that it is being entered into freely and voluntarily, and that the execution of this Agreement is not the result of any collusion or improper or illegal agreement or agreements. 6. FINANCIAL DISCLOSURE The parties confirm that each has relied on the substantial accuracy of the financial disclosure of the other as an inducement to the execution of this Agreement. Notwithstanding the foregoing, the rights of either party to pursue a claim for equitable distribution, pursuant to the Pennsylvania Divorce Code, of any interest owed by the other party in an asset of any nature at any time prior to the date of separation that was not disclosed to the other party or his or her counsel is expressly reserved. In the event that either party, at any time hereafter, discovers such an undisclosed marital asset, the parties shall have the right to petition the Court of Common Pleas of Cumberland Cumberland County to make equitable distribution of said asset. The non-disclosing parry shall be responsible for payment of counsel fees, costs, or expenses incurred by the other party in seeking equitable distribution of said asset. 7. DEBTS AND OBLIGATIONS Husband represents and warrants to Wife that since March 1, 2003, he has not, and in the future he will not contract or incur any debt or liability for which Wife or her estate might be responsible and shall indemnify and save Wife harmless from any and all claims or demands made against her by reason of such debts or obligations incurred by him since the date of said separation, except as otherwise may have been previously disclosed to Wife or as otherwise set forth herein. Wife represents and warrants to Husband that since March 1, 2003, she has not, and in the future she will not contract or incur any debt or liability for which Husband or his estate might be responsible and shall indemnify and save Husband harmless from any and all claims or demands made against him by reason of such debts or obligations incurred by her since the date of said separation, except as otherwise may have been previously disclosed to Husband or as otherwise set forth herein. 8. REAL ESTATE Husband and Wife are the joint owners of real estate identified below and the parties agree that such real estate shall be titled or otherwise handled as set forth herein: A. 204 Clearview Road, New Cumberland, PA, 17070, shall be titled as joint tenants with the right of survivorship and not as tenants in common and subject to the provisions of paragraph 11 below. B. 208 Clearview Road, New Cumberland, PA,.17070, shall be titled as joint tenants with the right of survivorship and not as tenants in common. C. 319 Ninth Street, New Cumberland, PA, 17070, shall be titled as joint tenants with the right of survivorship and not as tenants in common. D. 325 Ninth Street, New Cumberland, PA, 17070, shall be titled as joint tenants with the right of survivorship and not as tenants in common. E. 15 Plainview Road, Camp Hill, PA, 17011, shall be titled as joint tenants with the right of survivorship and not as tenants in common. The parties agree that they own four (4) Baltimore Ravens Personal Seat Licenses. Such Personal Seat Licenses shall continue to be held as joint assets and each parry shall have the option to purchase such licenses or any of them from the other at the fair market value within thirty (30) days written notice, otherwise, a sale to an outside arm's length third party shall be permitted and any proceeds shall be split equally between Husband and Wife. The parties jointly own a time share property interest with Westgate Properties at Westgate Lakes in Orlando, Florida. The parties agree that they shall continue to hold such as a joint asset and if either party desires to sell their interest, they shall first offer such to the other party at the fair market value and such other party shall have not less than thirty (30) days written notice to accept such offer and proceed to closing, otherwise, a sale to an outside arm's length third party shall be permitted and if both parties sell together, then any proceeds shall be split equally between Husband and Wife after the normal and customary settlement charges. Maintenance Fees shall continue to be paid equally between the parties as the same shall become due. I' ` 1 9. PERSONAL PROPERTY Except as set forth herein, Husband and Wife have agreed that their personal property has been divided to the parties' mutual satisfaction and neither party will make any claims to the property possessed by the other, except as set forth herein: Husband and Wife hereby acknowledge that they are the owners of two (2) vehicles and that said vehicles have been amicably distributed between them, in that, Husband has received the 2003 Cadillac Escalade and Wife has received the 1993 VW Cabriolet. Husband and Wife hereby acknowledge that they have executed the titles to said vehicles, or will do so contemporaneously with the execution of this Agreement, and if not previously properly recorded with the Pennsylvania Department of Transportation, Husband and Wife hereby acknowledge that said motor vehicle titles shall be properly executed and filed with the costs for transferring said titles into their names alone being borne by the ultimate owner of said vehicle. Husband and Wife hereby acknowledge that the titles shall be recorded with the Pennsylvania Department of Transportation within thirty (30) days of the date of this agreement. Husband and Wife hereby acknowledge that they are the joint owners of one checking account which is utilized as the rental account of their investment properties and shall continue to be so utilized as a joint account. Each party shall share equally in any profits and shall also share equally in any deficits. All other accounts and debts have been split or terminated to the mutual satisfaction of the parties. 10. PENSION Husband and Wife hereby agree that as to their respective pensions/retirement funds, there shall be a valuation which shall be the value determined by the year end statement of each account of each party. The parties desire that each shall have accounts valued equally in the aggregate as between them both and in the event any sums must be reallocated from one party to the other then in that event, this Agreement shall be the shall be the written authorization and sole authority required for such reallocation contemporaneous with this Divorce and this Agreement. Husband will most likely have to reallocate funds to Wife and Husband's :account is with Oppenheimer and is an Oppenheimer SEPP and IRA. After such reallocation, each party acknowledges that any pensions/retirement funds which each may have shall be that party's individual property and each respectively hereby waives all of his or her right, title, and interest in and to said pensions/retirement funds of the other and no further reallocations shall ever be required. 11. ALIMONY/ CHILD SUPPORT Provided Wife and Husband are still the j oint owners of the real property known as 204 Ciearview Road, New Cumberland, Pennsylvania, and provided further that the mortgage existing at the time of the signing hereof, currently with Freddie Mac, remains in place and is not released, satisfied or refinanced, the parties agree that Husband shall pay to Wife the sum of $800.00 per month representing alimony to Wife for a period which shall not exceed the period of time which Husband has an ownership interest as a joint owner of said real property (sale of the property), or such time as either party shall die, or such time as Wife shall re-marry (the discontinuation events). Husband and Wife hereby acknowledge that said payment amount and duration are non-modifiable, with the exception of the event of a refinance, then said amount is subject to change as the amount is based on the current PITI (principal, interest, taxes and insurance) amount and shall continue to be so based and to be due and payable unless one of the discontinuation events occur. If a discontinuation event occurs then no payment shall be due from Husband. In the event of a sale of the real property, then the proceeds of sale, after payment of any mortgage or other debts and the customary settlement charges, which may include real estate commissions, shall be split equally by the parties hereto. In the event of a refinance in order to remove one party from title, the party being removed parry from title, the party being removed shall be entitled to payment. of one-half of the equity of the fair market value of said property. Husband and Wife hereby acknowledge that the alimony payments shall be. deductible by Husband on his federal income tax returns and shall be included as income to Wife on her federal income tax return. The parties also agree that until such time as their youngest minor child shall attain the age of eighteen years or shall graduate high school, whichever shall last occur, Husband shall pay to Wife, provided that is the principal residence of said minor child, the sum of $800.00 per month for the care and maintenance of said minor child. Said amount shall continue as set forth herein until such time as the above events occur or such time as the parties shall agree to a different amount due to a change in circumstances of either party or both parties. 12. WAIVER OF RIGHTS The parties hereto fully understand their rights under and pursuant to the Divorce Code, Act of 1980, No. 1980-26, as amended February 12, 1998, and from time to time, particularly the provisions for alimony pendente lite, spousal support, equitable distribution of marital property, attorneys fees, and expenses. Both parties agree that this Agreement shall conclusively provide for the distribution of property under the said law and the parties hereby waive, release and forever relinquish any further rights they may respectively have against the other for alimony, alimony pendente lite, spousal support, equitable distribution of marital property, attorneys fees, and expenses. 13. WAIVER OR MODIFICATION TO BE IN WRITING A modification or waiver of any of the terms of this Agreement shall be effective only if in writing, signed by both parties, and executed with the same formality as this formality as this Agreement. No waiver of any breach hereof or default hereunder shall be deemed a waiver of any subsequent default of the same or similar nature. 14. MUTUAL COOPERATION Each party shall, at any time and from time to time hereafter, take any and all steps and execute, acknowledge and deliver to the other party, any and all future instruments and/or documents that the other party may reasonably require for that purpose of giving full force and effect to the provisions of the Agreement. 15. AGREEMENT BINDING ON HEIRS This Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective legatees, devises, heirs, executors, administrators, successors, and assigns in the interest of the parties. 16. BREACH If either party breaches any provision of this Agreement, the other party shall have the rights, at his or her election, to sue in law or in equity to enforce any rights and remedies which the party may have, and the party breaching this Agreement shall be responsible for payment of attorneys fees and all costs incurred by the other in enforcing his or her rights under this Agreement. 17. LAW OF PENNSYLVANIA APPLICABLE This Agreement shall be construed in accordance with the laws of the Commonwealth of Pennsylvania. 18. HEADINGS NOT PART OF AGREEMENT Any headings preceding the text of the several paragraphs/provisions and sub- paragraphs hereof, are inserted solely for convenience of reference and shall not constitute a part of this Agreement nor shall they affect its meaning, construction or effect. 19. DIVORCE The parties hereto acknowledge that their marriage is irretrievably broken. The parties further agree to execute the necessary Affidavits of Consent and Waiver of Counseling, and Waiver of Notice of Intent to Request Entry of Divorce Decree upon request so that the divorce may become finalized. The parties further agree and acknowledge that this Property Settlement Agreement shall be incorporated into said Decree in Divorce; however, shall not merge therewith. 20. IRREVOCABILITY It is understood and agreed to by and between the respective parties thereto that the property division/distribution affected by the herein agreement is IRREVOCABLE and that such division/distribution shall not be, affected by any change of circumstances of the respective parties OR by other statutory or judicial alternatives which may be available to the respective parties under prior, current, or future laws of the Commonwealth of Pennsylvania or any other jurisdiction. Except as provided herein, the parties hereby waive any respective rights to financial support and/or alimony and/or pension or future expectancies each may respectively have under prior, current, or future laws or case decisions. 21. HEALTH CARE The parties agree that Husband shall pay healthcare for himself and for their minor child Stephanie and child Julie as he shall deem appropriate. Any uncovered medical medical expenses. shall be paid by Husband unless a significant change in circumstances shall occur, in which event Husband and Wife shall share such costs. Husband shall notify Wife in writing in such event. Wife shall obtain her own health care coverage within thirty (30) days of the entry of the final Divorce Decree. IN WITNESS WHEREOF, the parties hereto have set their hands and seals the day and year first above written. Witness G M. NO O V/11V/Jtw W tness ? 7- - STEP EN B. NORFO COMMONWEALTH OF PENNSYLVANIA COUNTY OF// On this, the day of 206,T , before me, a Notary Public, a the undersigned officer, personally appeared GAIL M. NORFORD, known to me or satisfactorily proven to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. My Commission Expire 'O/'-"- '&'e- 01-1 N&tary Public ANtA COMMUNWtALIH Or ANNSYLY 7GAILP. TARIAL SEAL CKLER, Notary Public ro, Cumberland CoZuO? n Expires Jan. 30, COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN On this, the day of 4 &?bz, 20 0, before me, a Notary Public, the undersigned officer, personally appeared STEPHEN B. NORFORD, known to me or satisfactorily proven to be the person whose name is subscribed to the within instrument, and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. My commission expires: 3-13 / / Notary Public COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL JOHN R. BEINHAUR, Notary Public Lower Paxton Twp., Dauphin County Commission Expires march 13, 2011 C) ?a i ? J BEINHAUR & CURCILLO John R. Beinhaur, Esquire 3964 Lexington Street Harrisburg, PA 17109 7171651-9100 Attorney ID #55631 STEPHEN B. NORFORD, PLAINTIFF V. GAIL M. NORFORD. DEFENDANT AN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA :NO. 08-5201 Civil Term :CIVIL ACTION - LAW AN DIVORCE AFFIDAVIT OF CONSENT (Under Section 3301(c)) 1. A complaint in divorce under Section 3301(c) of the Divorce Code was signed August 22, 2008, and filed on and is time stamped August 28, 2008. A time-stamped copy was served on Defendant. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce. 4. 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. 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. Cons. Stat. Section 4904 relating to unsworn falsification to authorities. Date: /00/l/V 4alMbeyc ail M. Norford ?i ?.?. t to .? -c, ?: .. STEPHEN B. NORFORD, PLAINTIFF V. GAIL M. NORFORD. DEFENDANT :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA :NO. Of - 5 26 ? CfV' / 7-0 rrh :CIVIL ACTION - LAW :IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(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 this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: Gail M. Norford t Z t tC? BEINHAUR & CURCILLO John R. Beinhaur, Esquire 3964 Lexington Street Harrisburg, PA 17109 7171651-9100 Attomey ID #55631 STEPHEN B. NORFORD, AN THE COURT OF COMMON PLEAS OF PLAINTIFF :CUMBERLAND COUNTY, PENNSYLVANIA V. :NO. 08-5201 Civil Term GAIL M. NORFORD. :CIVIL ACTION - LAW DEFENDANT JN DIVORCE AFFIDAVIT OF CONSENT (Under Section 3301(c)) 1. A complaint in divorce under Section 3301(c) of the Divorce Code was signed August 22, 2008, and filed on and is time stamped August 28, 2008. A time-stamped copy was served on Defendant. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce. 4. 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. 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. Cons. Stat. Section 4904 relating to unworn falsification to authorities. Date: 1? 02 c? 0 ?--79, Stephe B. Norford BEINHAUR & CURCILLO John R. Beinhaur, Esquire 3964 Lexington Street Harrisburg, PA 17109 717/651.9100 Attorney it) #55631 STEPHEN B. NORFORD, PLAINTIFF V. GAIL M. NORFORD. DEFENDANT :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA :NO. 0-52-6( -52-61 al 'o-1 /e roi :CIVIL ACTION - LAW :IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(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 this affidavit are true and correct, understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: a 3 d ?' - ?? Stephen B. Norford ?. WiHAUR & CURCILLO John R. Beinhaur, Esquire 3964 Lexington Street Harrisburg, PA 17109 717/651-9100 Attorney ID #55631 STEPHEN B. NORFORD, :IN THE COURT OF COMMON PLEAS OF PLAINTIFF :CUMBERLAND COUNTY, PENNSYLVANIA . V. :NO. 08-5201 Civil Term GAIL M. NORFORD. :CIVIL ACTION - LAW DEFENDANT AN DIVORCE PRAECIPT TO TRANSMIT TO THE PROTHONOTARY: Kindly 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 Pennsylvania Divorce Code. 2. Date and manner of service of Complaint: Service on September 13, 2008, by United States certified mail. 3. Date of execution of the Affidavit of Consent required by Section 3301(c). of the Divorce Code: by Plaintiff on December 23, 2008; by Defendant on December 30, 2008. 4. Related claims pending: None. Settlement Agreement shall be filed with this consent and the parties desire that such be incorporated by reference but not merged into the Divorce Decree. 5. Date Plaintiffs Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: contemporaneously with this Praecipe. Date Defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: contemporaneously with this Praecipe. Respectfully submitted, BEINHAUR & CURCILLO By: Jo . Beinha , Esquire Supreme Ct. ID# 55631 3964 Lexington Street Harrisburg, PA 17109 (717) 651-9100 Attorney for Plaintiff Date: 0 1 - 0 S- ®g S4 N STEPHEN B. NORFORD V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GAIL M. NORFORD NO. 08-5201 CIVIL TERM DIVORCE DECREE AND NOW, .f' ' v v -i 14 , 7-602 , it is ordered and decreed that STEPHEN B. NORFORD plaintiff, and GAIL M. NORFORD , 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.") The Property Settlement Agreement of the parties dated December 23, 2008, is incorporated by reference but not merged herein. By the Court, cat& (20 x 1