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HomeMy WebLinkAbout08-5293SCOTT R. GIBSON, IN THE COURT OF COMMON PLEAS Plaintiff COUNTY OF CUMBERLAND, PENNSYLANIA V. CIVIL ACTION - LAW NO. Qg - SZg3 ASHLEY N. GIBSON, 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 & LINDSAY FLOWER & LINDSAY 26 West High Street Carlisle, PA AO-A'?Nzkj Marylo atas, Esquire Attorney Id. 84919 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff SCOTT R. GIBSON, IN THE COURT OF COMMON PLEAS Plaintiff COUNTY OF CUMBERLAND, PENNSYLANIA V. CIVIL ACTION - LAW NO. U I'- Y Z 9 3 ASHLEY N. GIBSON, Defendant IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) or (d) OF THE DIVORCE CODE 1. The Plaintiff is Scott R. Gibson, an adult individual currently residing at 105 South East Street, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Defendant is Ashley N. Gibson, an adult individual currently residing at RR 2, Box 3310, Folkston, Charlton County, Georgia 31537. 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 October 21, 2006 in Charlton County, Georgia. 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 is a member of the United States Armed Forces. The Defendant FLOWER IS, LIlVDSAY .LAW 26 West High Street Carlisle, PA is not a member of the United States Armed Forces or its Allies. 7. The Plaintiff has been advised that counseling is available and that he has the right to request that the court require the parties to participate in counseling. 8. Plaintiff and Defendant are citizens of the United States of America. 9. The parties' marriage is irretrievably broken. 10. Plaintiff desires a divorce based upon the belief that the Defendant will, ninety (90) days from the date of service of this Complaint, consent to this divorce. WHEREFORE, Plaintiff requests entry of a divorce decree in his favor in accordance with §3301 (c) or (d) of the Pennsylvania Divorce Code. Respectfully submitted, SAIDIS, FLOWER & LINDSAY Ma Id atas, lisquire Attorn d. 84919 26 West High Street Carlisle, PA 17013 (717) 243-6222 Dated: 9/ 316b Counsel for Plaintiff SAIDIS, FLOWER & LINDSAY 26 West High Street Carlisle, PA SCOTT R. GIBBON, IN THE COURT OF COMMON PLEAS Plaintiff COUNTY OF CUMBERLAND, PENNSYLANIA V. CIVIL ACTION - LAW NO. ASHLEY N. GIBSON, Defendant IN DIVORCE 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 unswom falsifications to authorities. _ti. COTT R. GIBBON Date: 09- 03- v8 FLOWER & LINDSAY 26 West High Street Carlisle, PA w w ? ? e v C1 v? 1"lam t :} "i 1 SCOTT R. GIBSON, IN THE COURT OF COMMON PLEAS Plaintiff COUNTY OF CUMBERLAND, PENNSYLANIA V. CIVIL ACTION - LAW NO. 2008-5293 CIVIL TERM ASHLEY N. GIBSON, Defendant IN DIVORCE ACCEPTANCE OF SERVICE SAIDIS, FLOWER & LINDSAY .u1o?,eruw 26 West High Street Carlisle, PA i, ASHLEY N. GIBSON, Defendani, accept service of the Divorce Compiaint in the above-captioned matter. 0(10112S Date ++? c C) F'I ` Fri m ;. 27 ?n - fil f rn C E`.? (s SCOTT R. GIBSON, IN THE COURT OF COMMON PLEAS Plaintiff COUNTY OF CUMBERLAND, PENNSYLANIA V. CIVIL ACTION - LAW NO. 2008-52 93 CIVIL TERM ASHLEY N. GIBSON, Defendant IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed September 4. 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. 1 consent to the entry of a final Decree in 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 to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. '0?pg Date: -ao 5?41al-l? 6 --1-- OTT R. GIBSON PLAINTIFF'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER$ 3301 (c) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree of Divorce without notice. 2. 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. 3. 1 understand that I will not be divorced until a Divorce Decree is entered by the Court SAIDIS, FWVMR &z LINDSAY AITOR VEYS.AT•tnw 26 West High Street Carlisle, PA 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 to the best of my knowledge, information and belief. 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: ?_ OTT R. GIBSON IS6 :: ?'? <=" ....o 4.. ? ?,s? -r? .,L q, ? 4? {S„Y` .' ?, ..`., C?` ?'. ?-??. ' i ? „:? ? : ?, -' t j„r SCOTT R. GIBSON, IN THE COURT OF COMMON PLEAS Plaintiff COUNTY OF CUMBERLAND, PENNSYLANIA V. CIVIL ACTION - LAW : NO. 2008-52 93 CIVIL TERM ASHLEY N. GIBSON, Defendant IN DIVORCE DEFENDANT'S PLMUWV" AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed September 4 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. 1 consent to the entry of a final Decree in 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 to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unswom falsification to authorities. a Date: d2 HLEY . GIBSON DEFENDANT'S 1. 1 consent to the entry of a final Decree of Divorce without notice. 2. 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. 3. 1 understand that I will not be divorced until a Divorce Decree is entered by the Court SAMIS, LINDSAY nriotwexs..vuw 26 West High Street Carlisle, PA 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 to the best of my knowledge, information and belief. 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: );L //,p A LEY IBSON ?--? ?? .?.. n ??? -x ;;?. .. f`.l ..;. ? -' SCOTT R. GIBSON, IN THE COURT OF COMMON PLEAS Plaintiff COUNTY OF CUMBERLAND, PENNSYLANIA V. CIVIL ACTION - LAW NO. 2008-5293 CIVIL TERM ASHLEY N. GIBSON, Defendant IN DIVORCE PROPERTY SETTLEMENT AND SEPARATION AGREEMENT THIS AGREEMENT made this day of zd C ,i-y%kLA_ , 2008, between SCOTT R. GIBSON, of Carlisle, Cumberland County, Pennsylvania, hereinafter referred to as Husband, and ASHLEY N. GIBSON, of Folkston, Charlton County, Georgia, hereinafter referred to as Wife. RECITALS: R.1: The parties hereto are husband and wife, having been joined in marriage on October 21, 2006, in Folkston, Charlton County, Georgia; and R.2: A Complaint for Divorce has been filed in the Court of Common Pleas of Cumberland County Commonwealth of Pennsylvania, to Number 2008-5293, Civil Term; and R.3: The parties hereto desire to settle fully and finally their respective financial and property rights and obligations including, but not limited, of all matters between them relating to the ownership of real and personal property, claims for spousal support, alimony, alimony pendente lite. R4: The parties also desire to settle their issues of counsel fees and costs, and the settling of any and all claims and possible claims against the other or against their respective estates. NOW THEREFORE, in consideration of the covenants and promises hereinafter to be mutually kept and performed by each party, as well as for other good and valuable consideration 1 r and intending to be legally bound, it is agreed as follows: (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 from time to time may choose or deem fit, free from any control, restraint or interference from the other. Neither party will molest the other or endeavor to compel the other to cohabit or dwell with him or her by any legal or other proceeding. Each party shall be free of the interference, authority or contact by the other as if he or she was single and unmarried except as maybe necessary to cant' out the terms of this agreement. (2) DIVORCE: The parties acknowledge that the marriage is irretrievably broken and that they will secure a mutual consent no-fault divorce decree in the above-captioned divorce action, and will execute and file the necessary documents to finalize the divorce after the expiration of ninety (90) days of the service of the Complaint and the moving party shall move for the entry of the divorce decree at that time. (3) REAL PROPERTY: The parties are the owners of certain real estate with improvements thereon erected and known and numbered as 105 South East Street, Carlisle, Cumberland County, Pennsylvania. Wife agrees upon execution of this Agreement, she shall convey the real estate with improvements thereon erected at 105 South East Street, Carlisle, Cumberland County, Pennsylvania to Husband by special warranty deed. Said deed shall be held in escrow by Marylou Matas, Esquire until such time as the affidavits of consent have been executed and filed and the property refinanced as set out below. Husband shall pay for all household expenses including, but not limited to, mortgages and liens of record, utility bills, insurance and real estate taxes in connection with said property. With regard to all such expenses, Husband hereby shall hold Wife harmless and indemnify Wife from any loss thereon. Assuming there is no prepayment penalty clause in the current mortgage loan 2 or note, Husband shall refinance, assume or otherwise remove Wife's name from said mortgage obligation within fifteen (15) months of the date of this agreement, at which time the escrowed deed shall be released to the Husband. Until such approval, Husband shall continue to make all such mortgage payments in a timely and consistent manner. If Husband is unable to remove Wife's name from the mortgage obligation within fifteen months from the date of this Agreement or upon Husband's death prior to having refinanced or otherwise removing Wife's name from the mortgage, the real estate shall be sold and the proceeds distributed to Husband or Husband's estate. (4) DEBT: A. Marital Debt: Husband and Wife acknowledge and agree that there are no other outstanding debts and obligations which are marital or for which the other might be liable incurred prior to the signing of this Agreement, except as follows: i. Members 1st, with an approximate date of separation balance of $600; ii. Members 1st, with an approximate date of separation balance of $12,000 (representing business debt and $8,000 payment to Wife); Members 1st Home Equity loan, with an approximate date of separation balance of $5,100. Husband shall pay the obligations to the creditors listed above by making timely monthly payments in at least the minimum amount required by the creditors until paid in full). B: Post Separation Debt: In the event that either party contracted or incurred any debt since the date of separation on August 19, 2008, the party who incurred said debt shall be responsible for the payment thereof regardless of the name in which the debt may have been incurred. C: Future Debt: From the date of this agreement neither party shall contract or incur 3 any debt or liability for which the other party or his or her property or estate might be responsible and shall indemnify and save the other party harmless from any and all claims or demands made against him or her by reason of debts or obligations incurred by the other party. (5) MOTOR VEHICLES: Each party relinquishes any right, title and interest he or she may have to any and all motor vehicles currently in possession of the other party. Within 15 days of the date of this agreement each party shall execute any documents necessary to have said vehicles properly registered in the other party's name with the Pennsylvania Department of Transportation. Each party shall assume full responsibility of any encumbrance on the motor vehicle received by said party, and shall hold harmless and indemnify the other party from any loss thereon. (6) TANGIBLE PERSONAL PROPERTY: The parties hereto mutually agree that they have effected a satisfactory division of the furniture, household furnishings, appliances, tools and other household personal property between them, and they mutually agree that each party shall from and after the date hereof be the sole and separate owner of all such property presently in his or her possession whether said property was heretofore owned jointly or individually by the parties hereto. This agreement shall have the effect of an assignment or bill of sale from each party to the other for such property as may be in the individual possession of each of the parties hereto. Wife acknowledges that on the date of separation she removed all items of household furnishings, furniture, tools, appliances, personal effects and the like that she wanted and intended to have. Wife shall have no right to enter the real estate located at 105 South East Street, Carlisle, Cumberland County, Pennsylvania, to remove additional items from that residence or items surrounding the residence as of the date of separation forward. (7) INTANGIBLE PERSONAL PROPERTY: Each party hereby relinquishes any right, title or interest he or she may have in or to any intangible personal property currently titled in the 4 name of or in the possession of the other party, including, but not limited to, stocks, bonds, insurance, bank accounts, individual retirement accounts, employment benefits including retirement accounts, savings plans, pension plans, stock plans, 401 K plans and the like. (8) BUSINESS INTEREST: Husband has an interest in a business, known as "Gibson Solutions, Inc." This is an S Corporation. Wife hereby waives all right, title and interest she has in this business corporation and hereby agrees to sign any document necessary to have her name removed from all ownership interests and all other documents that may be required from time to time. Husband agrees to maintain financial responsibility for the business and hereby agrees to hold Wife harmless and indemnify Wife from any loss thereon. (9) WAIVER OF ALIMONY: The parties acknowledge that each has income and assets satisfactory to his and her own reasonable needs. Each party waives any claim he or she may have one against the other for alimony, spousal support or alimony and alimony pendente lite. (10) PAYMENT TO WIFE: In consideration for Wife's equitable distribution interests and considering the factors as set forth in 23 Pa. C.S.A. §3502 and the Pa Divorce Code, Husband hereby agrees to make payment to Wife in the amount of ELEVEN THOUSAND AND 00/100 ($11,000.00) DOLLARS. Wife acknowledges that she received $8,000.00 on August 19, 2008 and $1000 in the month of October 2008. Husband shall make two $1,000.00 payments to Wife in the months subsequent to the signing of this Agreement, the first being no sooner than November 30, 2008, and the second payment being no sooner than January 30, 2009, for a total of $2,000.00. (11) ADVICE OF COUNSEL: The parties hereto acknowledge that each has been notified of his or her right to consult with counsel of his or her choice, and have been provided a copy of this agreement with which to consult with counsel. Husband is represented by Marylou 5 Matas, Esquire and, has been advised that he may be represented by counsel of choice. Wife has reviewed this Agreement and has had the opportunity to have the provisions of this Agreement and their legal effect explained to her by counsel but has chosen to proceed on her own without legal representation and is entering into this Agreement of her own free will. Each party acknowledges and accepts that this agreement is, under the circumstances, fair and equitable, and that it is being entered into freely and voluntarily after having received such advice and with such knowledge as each has sought from counsel, and the execution of this agreement is not the result of any duress or undue influence, and that it is not the result of any improper or illegal agreement or agreements. Each party shall pay his or her own attorney for all legal services rendered or to be rendered on his or her behalf. (12) ADDITIONAL INSTRUMENTS: 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. (13) INCOME TAX: A: The parties have heretofore filed joint Federal and State Tax returns, prior to the 2008 Tax year. Both parties agree that in the event any deficiency in Federal, state or local income tax is proposed, or assessment of any such tax is made against either of them, each will indemnify and hold harmless the other from and against any loss or liability for any such tax deficiency or assessment and any interest, penalty and expense incurred in connection therewith. Such tax, interest, penalty or expense shall be paid solely and entirely by the individual who is finally determined to be the cause of the misrepresentations or failures to disclose the nature and extent of his or her separate income on the aforesaid joint returns. B: Wife agrees to join in the filing of a 2008 joint federal, Pennsylvania, and 6 local income tax return with Husband. Wife agrees, upon the request of Husband, to cooperate in the filing of a corporate/business return for the 2008 tax year. Husband will bear the expense of preparing all joint tax returns. In the event that a joint return is filed, and a deficiency is determined so that the parties owe sums for federal, state, local or corporate taxes, Husband shall be responsible for payment of the tax due. Husband shall pay all taxes due on or before April 15, 2009. In the event of any refund the distribution of it will be determined by computing the amount of refund received as if the parties had filed separate returns. (14) HEALTH INSURANCE: The parties acknowledge that they each are providing for their own health insurance as of the date of separation. From the date of separation forward, each party is individually responsible for their own uninsured or unreimbursed medical bills that may be incurred. (15) BANKRUPTCY: The parties hereby agree that the provisions of this Agreement shall not be dischargeable in Bankruptcy and expressly agree to reaffirm any and all obligations contained herein. In the event a party files such bankruptcy and pursuant thereto obtains a discharge of any obligations assumed hereunder, the other party shall have the right to declare this Agreement to be null and void and to terminate this Agreement in which event the division of the parties' marital assets and all other rights determined by this Agreement including alimony shall be subject to court determination the same as if this Agreement had never been entered into. (16) COMPLETE DISCLOSURE: The parties do hereby warrant, represent, acknowledge and agree that each is fully and completely informed of, and is familiar with, the wealth, real and personal property, estate and assets, earnings and income of the other and has made any inquiry he or she desires into the income or estate of the other and received any such information requested. Each has made a full and complete disclosure to the other of his and her 7 entire assets, liabilities, income and expenses and any further enumeration or statement thereof in this Agreement is specifically waived. (17) RIGHTS AND RESPONSIBILITIES: Husband and Wife acknowledge that each of them has read and understand his and her rights and responsibilities under this Agreement and that they have executed this Agreement under no compulsion to do so but as a voluntary act. (18) FULL SETTLEMENT: Except as herein otherwise provided, each party hereby releases the other from any and all claims, or demands up to the date of execution hereof. It is further specifically understood and agreed by and between the parties hereto that each party accepts the provisions herein made in lieu of and in full settlement and satisfaction of any and all of said party's rights against the other for past, present and future claims on account of support, maintenance, alimony, alimony pendente life, counsel fees, costs and expenses, equitable distribution of marital property and any other claims of the party, including all claims which have been raised or may be raised in an action for divorce. (19) RELEASE OF ALL CLAIMS: Except as may be otherwise specifically provided in this Agreement, Husband and Wife, for themselves, their heirs, representatives and assigns, each hereby forever releases, remises, discharges and quitclaims the other, and such other's heirs, representatives, assigns and estate, from and with respect to the following: A. All liability, claims, causes of action, damages, costs, contributions and expenses or demands whatsoever in law or in equity; B. All rights, title, interest or claims in or to any property of the other, whether real, personal or mixed and whether now owned or hereafter acquired; C. All rights of courtesy and dower and all claims or rights in the nature of courtesy and dower; D. All widow or widower's rights; 8 E. All right, title, interest or claim in or to the other's estate, whether now owned or hereafter acquired, including but not limited to all rights or claims: (1) to take against the other's will; (2) under the laws of intestacy; (3) to a family exemption or similar allowance; and (4) all other rights or authority to participate or intervene in a deceased spouse's estate in any way, whether arising under the laws of Pennsylvania or any other country, territory, state or political subdivision. F. All rights or claims to any accounting; G. All rights, claims, demands, liabilities and obligations arising out of or in connection with the marital relationship or the joint ownership of property, whether real, personal or mixed; H. All rights, claims, demands, liabilities and obligations arising under the provisions of the Pennsylvania Divorce Code, as the same may be amended from time to time, and under the provisions of any similar statute enacted by any other country, state, territory or political subdivision; I. All rights, claims, demands, liabilities and obligations each party now has, or may hereafter have, against or with respect to the other. (20) GOVERNING LAW: This Agreement shall be construed under the law of the Commonwealth of Pennsylvania. If any provision of this Agreement is determined to be invalid or unenforceable, all other provisions shall continue in full force and effect. (21) INCORPORATION INTO DECREE: In the event that either of the parties shall recover a final judgment or decree of absolute divorce against the other in a court of competent 9 jurisdiction, the provisions of this Agreement may be incorporated by reference or in substance but shall not be merged into such judgment or decree and this Agreement shall survive any such final judgment or decree of absolute divorce and shall be entirely independent thereof. (22) BREACH: In the event that either party breaches any provision of this Agreement, he or she shall be responsible for any and all costs incurred to enforce the Agreement, including, but not limited to, court cost and counsel fees of the other party. In the event of breach, the other party shall have the right, at his or her election; to sue for damages for such breach or to seek such other and additional remedies as may be available to him or her. (23) ENTIRE UNDERSTANDING: This Agreement constitutes the entire understanding between the parties and there are no covenants, conditions, representations, or agreements, oral or written, of any nature whatsoever, other than those herein contained. (24) AGREEMENT BINDING ON PARTIES AND HEIRS: This Agreement shall bind the parties hereto, their respective heirs, executors and assigns. IN WITNESS WHEREOF, the parties hereto intending to be legally bound have hereunto set their hands and seals the day and year first written above. WITNESS: Wi ss ate Cott R. Gibson fitness ley N ibson 10 ,} L COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND On this day of 2008, before me, the undersigned, personally appeared SCOTT R. GIBSON, whose name is subscribed to the within instrument, and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. Notary Public NOTARIAL SEAL MERLENE J, MARHEVKA, NOTARY PUBLIC CARLISLE, CUMBERLAND COUNTY, PA MY COMMISSION EXPIRES JUNE 8, 2010 STATE OF GEORGIA COUNTY OF CHARLTON On this W4"` day of b Q- ? , 2008, before me, the undersigned, personally appeared ASHLEY N. GIBSON, whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. No ry FYjblic Notary Public, Chc-iton County, Loor0ia My Commission Expires Oct. 8, 2010 11 i ? N ,;. r°, _ ?? m ? .? ?.: r'' I !'T'. fi:::: ?) .. 7? ?..- :. ?,?. S mot= _ - =r' k.s ?, C..?' --C _v ` ? SCOTT R. GIBSON, Plaintiff V. CIVIL ACTION - LAW NO. 2008-5293 CIVIL TERM ASHLEY N. GIBSON, Defendant PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Kindly transmit the record, together with the following information, to the Court for entry of a Decree in Divorce: 1. Grounds for Divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Defendant accepted service of the Complaint on September 8, 2008, via regular mail. Proof of service was filed with the Court on September 16, 2008. 3. Date Affidavit of Consent required under Section 3301(c) of the Divorce Code was executed: 4. Related claims pending: None. SAIDIS, ELONWR & LINDSAY nrro?s.nruw 26 West High Street Carlisle, PA 5. Date Waiver of Notice under Section 3301(c) of the Divorce Code was executed: IN THE COURT OF COMMON PLEAS COUNTY OF CUMBERLAND, PENNSYLANIA IN DIVORCE By Plaintiff: On December 5, 2008 and filed with the Prothonotary on December 16, 2008. By Defendant: On December 10, 2008 and filed with the Prothonotary on December 16, 2008. By Plaintiff: On December 5, 2008 and filed with the Prothonotary on December 16, 2008. By Defendant: On December 10, 2008 and filed with the Prothonotary on December 16, 2008. SAIDIS, FLOWER & LINDSAY MaryloufiMa s, Esqu`he Supreme urt ID No. 84919 26 West High Street Carlisle, PA 17013 717-243-6222 Attorney for Plaintiff c-> '? ?: ? ;?w? . -?€ _ ? f?, : ?? ?_ ., ; _ .Z? ?: .. - - t?.J -? ,.. :? SCOTT R. GIBSON, Plaintiff ASHLEY N. GIBSON Defendant IN THE COUR OF COMMON PLEAS CUMBERL COUNTY, PENNSYLVANIA CIVIL ACTI, NO. 2008- IN D Notice is hereby given that the Defendant in GIBSON, [select one by marking "x"] X prior to the entry of a Final Decree in Divoi or after the entry of a Final Decree in Di hereby elects to resume the prior surname of ALBEF avowing her intention pursuant to the provisions of 54 Date: p ID -LAW 3 CIVIL TERM above matter, ASHLEY N. rce dated , S and gives this written notice S.704. SAMIS, FLOWER & LINDSAY ArFLAM -ADUw 26 West High Street Carlisle, PA N. STATE OF GEORGIA ) COUNTY OF CHARLTON ) On the I D4? day of 1? Q (p J) j t 1( , 2 or the notary public, personally appeared the above person whose name is subscribed to the within docur executed the foregoing for the purpose therein containe In Witness Whereof, I have hereunto set my hand Notary My Col ing resumed TS before me, the Prothonotary Ity N1' ckt,Ic GIbs0, ? unt known to me to be the and acknowledged that she Official Seal. ari or Notary Public bli Charlton County, Georgia issi n Expires Oct. 6, 2010 s. } F - I-o i r r> IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SCOTT R. GIBSON Plaintiff V. ASHLEY N. GIBSON NO. 2008-5293 Defendant DIVORCE DECREE AND NOW, e- e- , 2 3 Zc,c, S , it is ordered and decreed that SCOTT R. GIBSON , plaintiff, and ASHLEY N. GIBSON , 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 terms of the Separation and Property Settlement Agreement dated December 5, 2008, are incorporated, but not merged, into thiG Decree in Divorce. By the Court, w ? Prothonotary a?