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HomeMy WebLinkAbout08-6991Ok John B. Dougherty, Esquire Pa. I.D. No. 70680 IRA H. WEINSTOCK, P.C. 800 North Second Street Harrisburg, PA 17102 Telephone: 717-238-1657 Fax: 717-238-6691 Attorney for: PLAINTIFF WILLIAM CORBETT, vs. LORNA CORBETT, Plaintiff, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. No. 08 - (Aq 0,1vit -Ferm CIVIL ACTION - IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take 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, Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania, 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNUL- MENT 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 Phone: 717-249-3166 or 800-990-9108 1116 John B. Dougherty, Esquire Pa. I.D. No. 70680 IRA H. WEINSTOCK, P.C. 800 North Second Street Harrisburg, PA 17102 Telephone: 717-238-1657 Fax: 717-238-6691 WILLIAM CORBETT, vs. LORNA CORBETT, Attorney for: PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. Plaintiff, No. 0 Civil Action - In Divorce Defendant COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE AND NOW, Plaintiff, William Corbett, by and through his attorney, John B. Dougherty, Esquire, respectfully submits this Complaint and, in support thereof, avers the following: 1. Plaintiff, William Corbett, is an adult individual who currently resides at 113 Park Avenue, Watertown NY, 13601 and has maintained a residence at this location since 1987. 2. Defendant, Lorna Corbett, is an adult individual who currently resides at 216 Silver Spring Road, Mechanicsburg, Cumberland County, Pennsylvania, 17055 and has resided at this location since November 2008. 3. Plaintiff has resided in the Commonwealth of Pennsylvania for periods of time, since 2003, however, Plaintiff and Defendant have not lived together as husband and wife for at least two years prior to the commencement of this action. A 4. Defendant has resided in the Commonwealth of Pennsylvania for at least six months immediately previous to the commencement of this action. 5. The Plaintiff and Defendant were married on May 20, 1991 in Moalboal, Phillipines. 6. There have been no prior actions of divorce or annulment of marriage between the parties. 7. The Defendant is not a member of the Armed Services of the United States of America or its Allies. 8. Plaintiff has been advised as to the availability of counseling and that he may have the right to request that the court require the parties to participate in counseling. 9. The marriage of the parties is irretrievably broken. WHEREFORE, the Plaintiff respectfully requests that this Honorable Court enter a decree of divorce. Respectfully Submitted, IRA H. WEINSTOCK, P.C. 800 North Second Street Harrisburg, PA 17102 Phone: 717-238-1657 By. ? ERTY I -ft VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unworn falsifications to authorities. OD m r? J [A S ., d WILLIAM CORBETT, Plaintiff, vs. LORNA CORBETT, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. No. 08- 6q9/ &V"t lefo, Defendant. CIVIL ACTION - LAW NOTICE TO THE DEFENDANT If you wish to deny any of the statements set forth in this Affidavit, you must file a Counter-Affidavit within 20 days after this Affidavit has been served on you or the statement will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE The parties to this action separated in or about 2005 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 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.C.S. §4904 relating to unswom falsification to authorities. ?J Dated: f WILLIAM CORBETT C') 'v i`' iNo 3? WILLIAM CORBETT, vs. LORNA CORBETT, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. Plaintiff, No. 08-6991 Civil Term Defendant. CIVIL ACTION - DIVORCE DEFENDANT'S COUNTER-AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): _/(a) I do not oppose the entry of a divorce decree. ? (b) I oppose the entry of a divorce decree because (Check (i), (ii) or both): Vi(i) The parties to this action have not lived separate and apart for a period of at least two years. _ (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): __ (a) I do not wish to make any claims for economic relief. 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. -fi(b) I wish to claim economic relief which may include alimony, division o f'property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my r -- r? M economic claims with the Prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further delay. I verify that the statements made in this counteraffidavit are true and correct. I tinderstand that false statements herein are made subject to the penalties of 1S Pa.C.S. §4904 relating to unsworn falsification to authorities. Date:_ ?''? ?' ? ? -1 NOTICE: If you do not wish to oppose the entry of a divorce decree and you do not wish to make any claim for economic relief, you should not file this counteraffidavit. mW t+a CJ c=) C .`av Ui r-n S A (D .' • % WILLIAM CORBETT, Plaintiff vs. LORNA CORBETT, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 08-6991 Civil Term CIVIL ACTION -LAW DIVORCE DEFENDANT'S PETITION FOR RELATED CLAIMS PURSUANT TO PA.R.C.P.1920.15(b) AND NOW comes the Defendant, Lorna Corbett, and represents as follows in support of this Petition: 1. Petitioner is Lorna Corbett, Defendant above-named, hereinafter referred to as Wife. 2. Respondent is William Corbett, Plaintiff above-named, hereinafter referred to as Husband. 3. Husband and Wife were married on May 20, 1991 in Moalboal, Philippines. 4. Husband filed a Complaint in Divorce on November 26, 2008. 5. Husband filed Plaintiff's Affidavit Under Section 3301(d) of the Divorce Code on November 26, 2008. COUNT I - EQUITABLE DISTRIBUTION 6. While no settlement has been reached as of the date of the filing of this Complaint, Wife is and has always been willing to negotiate a fair and reasonable settlement of all matters with Husband. To the extent that a written Settlement Agreement might be entered into between the parties prior to the time of hearing on this Divorce Complaint, Wife desires that such written Agreement be approved by the Court and incorporated, but not merged, in any Divorce Decree which might be entered dissolving the marriage between the parties. 7. The parties are the owners of various items of real and personal property, furniture and household furnishings acquired during their marriage, which are subject to equitable distribution by this court. 8. The parties are the owners of various motor vehicles, bank accounts, investments, and insurance policies acquired during their marriage, which are subject to equitable distribution by this court. COUNT II - ALIMONY PENDENTE LITE, ATTORNEY'S FEES AND COSTS 9. By reason of this action, Wife will be put to considerable expense in the preparation of her case in the employment of counsel and the payment of costs. 10. Wife is without sufficient funds to support herself and to meet the costs and expenses of this litigation and is unable to appropriately maintain herself during the pendency of this action. 11. Wife's income is not sufficient to provide for her reasonable needs and pay her attorney's fees and costs of this litigation. 12. Husband has adequate earnings to provide for Wife's support and to pay her counsel fees, costs and expenses. COUNT III - ALIMONY 13. Wife lacks sufficient property to provide for her reasonable needs. 14. Wife is unable to sufficiently support herself through appropriate employment. 15. Husband has sufficient income and assets to provide continuing support for the Wife after the entry of a Decree in Divorce. WHEREFORE, Defendant, Lorna Corbett, requests this Honorable Court: 1) Equitably distribute all property, both personal and real, owned by the parties; 2) Compel Husband to pay alimony pendente lite to Wife; 3) Compel Husband to pay post-divorce alimony to Wife; 4) Grant Wife's attorney's fees and costs; 5) Grant such further relief as the Court may deem equitable and just. RESPECTFULLY SUBMITTED: Dated: -/-/ q- 6q Lora Corbett 21 Silver Spring Road echanicsburg, PA 17055 Telephone: (717) 877-0762 VERIFICATION I, Lorna Corbett, hereby verify and state that the facts set forth in the foregoing document are true and correct to the best of my information, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn verification to authorities. Date: / f O q Corbett d CZ* IN W va V- r WILLIAM CORBETT, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. Plaintiff, vs. No. 08-6991 Civil Term LORNA CORBETT, Defendant. CIVIL ACTION - IN DIVORCE ACCEPTANCE OF SERVICE I, Lorna Corbett, Defendant in the above-captioned action, acknowledge receipt of the Complaint in Divorce and Plaintiff's Affidavit Under Section 3301(d) of the Divorce Code filed on November 26, 2008. Dated: /(,-)b Id? LORNA CORBETT OF THE ? 7' `'?Trn 2 0 0 9 'SEP 15 F' r 2. 0 b WILLIAM CORBETT, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. Plaintiff, vs. No. 08-6991 Civil Term LORNA CORBETT, Defendant. CIVIL ACTION - DIVORCE AFFIDAVIT OF CONSENT A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on November 26, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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. 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 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 C.S. §4904 relating to unsworn falsification to authorities. _ n 1 Dated: n S?? Or d1 Q.r? G\?j ? uJ c?Lj-'v cC f Zit 1 WILLIAM COR TT > >S; J O ON A 30°x° Z aid. Z Zt 1 1° oa w u-v°;Z O m aiv'A T moaU I- o a 3 Q Z N w E % E o 'to c N? 9.x,:?:s - COMMC 4.L i H OF PENNSYLVA :notarial Seal Jr Grove, Notary Public Silver I wp., Cumberland Count; My Cc on Expires June 18, 201." Member. .; ? ivania Association Of NW . FILE OF THE FP T 2009 SEP 15 Fil 2: 05 lfU Mi..ri..,..t1. WILLIAM CORBETT, : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. Plaintiff, VS. LORNA CORBETT, Defendant. No. 08-6991 Civil Term CIVIL ACTION - DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on November 26, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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. 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. !1 l? Dated: LORNA CORBETT ?' c.??c?r-r\ G +?c? Sa Scr: 1Do- S (-11?^ C?ct y COMMONWEAL"s` /? tA? , . Joseph L Silver Spring Tai. My CommissiuJ, Member, Penns•;^^ b. pq R _ma ?yonN [A Z ? ? m C1 U X >O ci W J CA N aN? 0 i °, y V to `? NSYLVANIA Public 'and County i:z 18, 2013 lon of Notaries 20 04 SE;' 15 Pi 4 2.00" 08-(o441 CPOSTNUPTIAL AGREEMENT THIS AGREEMENT, made this 1'74day of , 2009, by and between LORNA CORBETT, hereinafter called "Wife", and WILLIAM CORBETT, hereinafter called "Husband". WITNESSETH: WHEREAS, Husband and Wife were legally married on May 20, 1991; and WHEREAS, differences have arisen between Husband and Wife in consequence of which they desire to live separate and apart from each other; and WHEREAS, Husband and Wife desire to settle and determine their rights and obligations. NOW THEREFORE, in consideration of the premises and covenants contained herein, it is agreed by and between the parties hereto that: 1. NO-FAULT DIVORCE. Husband and Wife agree to secure a No-Fault Divorce based upon the irretrievable breakdown of the marriage. Husband and Wife agree to execute their respective Affidavits Of Consent under Section 3301(c) of the Pennsylvania Domestic Relations Code and to execute any and all other documents necessary under existing law to expedite a final decree of divorce from the Court of Common Pleas of Cumberland County. 2. INTERFERENCES. Each party shall be free from interference, authority and control by the other except as may be necessary to carry out the provisions of this Agreement. Neither party shall molest or attempt to endeavor to molest the other, or in any way harass or malign the other, nor in any other way interfere with the peaceful existence, separate and apart from the other. 3. DIVISION OF PERSONAL AND REAL PROPERTY. The parties have divided all personal and real property owned by them during the marriage to their satisfaction. Husband and Wife agree to keep all personal property within their respective possession. To the extent that any Wife's personal items remain in Husband's possession, he will maintain those items and assist wife in the costs of labor and equipment, not to exceed $200, to have those items moved. Husband may give Wife forty five (45) days written notice to have her personal items removed from Husband's residence and at the end of the forty five (45) days, whatever items remain with :Husband shall become property of Husband to be disposed of at his discretion. 4. VEHICLES. (a) Wife will receive the 2006 Honda CRV and Husband will agree to continue to make the payments on the vehicle and maintain the insurance on the vehicle until the vehicle is paid off. When the vehicle is paid off, Wife shall maintain sole possession of the vehicle and shall take whatever steps that are necessary to see that Husband's name is removed from the title and Wife shall obtain her own insurance on the vehicle. Wife shall be responsible for all fees and costs associated with transferring title to the vehicle and obtaining auto insurance. Husband agrees to cooperate with Wife in transferring title to said vehicle including but not limited to signing all documents required to expedite said transfer. (b) Husband will maintain possession of the 1995 Jeep Grand Cherokee which will be turned over to Husband and Wife's son on his 18`h birthday. - 2 - 5. PENSION PLAN. Husband agrees to relinquish all rights, title, and interest he may have in any and all of Wife's pension(s), 401(k)'s, profit sharing, or in any other monies Wife is or may be entitled to receive now or in the future. Wife agrees to relinquish any and all rights, title or interest she may have in any pensions, 401(k)'s, profit sharing, or other monies that Husband may be entitled to now or in the future. 6. CHILD SUPPORT. Husband agrees to pay to Wife $400 per month for the support of their minor child until that child's 18th birthday. Wife agrees that if Husband is laid off from or loses his job at YRC that the Child Support shall be reduced to $300 per month until the minor child's 18th birthday. 7. CUSTODY. Husband and Wife shall have shared legal custody of the parties' child. Wife shall have primary physical custody of the child. Husband shall have temporary physical custody at such times as agreed upon by the parties. 8. BANKRUPTCY. It is acknowledged and agreed by the parties that the payments called for in this Agreement are not intended to be a debt which is affected by discharge in bankruptcy. The parties further specifically intend that Husband's and Wife's obligations under the terms of this Agreement shall not be subject to discharge in bankruptcy because such payments of debts and other liabilities are necessary for Husband and Wife to meet his and her respective financial obligations and to support and maintain his and her respective standard of living and that of their minor children. Husband and Wife represent that there are no bankruptcy proceedings presently pending in which he - 3 - or she is involved. Husband and Wife expressly agree not to file a bankruptcy action prior to the completion of his or her obligations pursuant to this paragraph. These debts are not intended to be nor shall they be discharged in a bankruptcy action filed by or on behalf of either Husband or Wife. Furthermore in the event that, at any time prior to Husband and Wife's fulfillment of all of the financial obligations set forth in this Agreement, either he or she declares personal or professional bankruptcy, this Agreement shall constitute conclusive evidence of the parties' intent that the obligations under this Agreement are in the nature of maintenance and are not dischargeable under current Bankruptcy Law or under any amendment thereto. Further, if Husband or Wife institutes any section in bankruptcy, and the U.S. bankruptcy Court, contrary to the terms of this Agreement, declares that any or all of the said payments required hereunder are dischargable, then in that even the affected portions of the Agreement shall become null and void. Husband and Wife shall have the absolute right to prosecute his or her economic claims in the divorce action as they relate to the portions of the Agreement that are null and void. 9. BREACH. If either party breaches any provision of this Agreement, the other party shall have the right, at his or her election, to sue for damages for such breach. The party breaching this contract shall be responsible for the payment of legal fees and costs incurred by the other in enforcing his or her rights under this Agreement, or seeking such other remedy or relief as may be available to him or her. 10. FULL DISCLOSURE. Husband and Wife each represent and warrant to the other that he or she has made a full and complete disclosure to the other of all assets of any nature whatsoever in which such party of - 4 - every type whatsoever and all other facts relating to the subject matter of this Agreement. 11. ADDITIONAL INSTRUMENT. Each of the parties shall on demand execute and deliver to the other any deeds, bills of sale, assignment, consents to change of beneficiary on insurance policies, tax returns and other documents and do or caused to be done any other act or thing that may be necessary or desirable to the provisions and purposes of this Agreement. If either party fails on demand to comply with this provision, that party shall pay to the other all attorneys' fees, costs and other expenses reasonably incurred as a result of such failure. 12. WIFE'S DEBTS. Wife represents and warrants to Husband that since the parties' separation 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 debts or obligations incurred by her. 13. HUSBAND'S DEBTS. Husband represents and warrants to Wife that since the parties' separation 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 debts or obligations incurred by him. 14. WAIVERS OF CLAIMS AGAINST ESTATES. Except as herein otherwise provided, each party may dispose of his or her property in any way, and each party hereby waives and relinquishes any and all rights he or she may now have or hereafter acquire, under the present or future laws of any jurisdiction, to share in the property or the - 5 - estate of the other as a result of the marital relationship, including without limitation, dower, curtesy, statutory allowance, widow's allowance, right to take in intestacy, right to take against the Will of the other, and right to act as administrator or executor of the other's estate, and each will, to the request of the other, execute, acknowledge and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interests, rights and claims. 15. REPRESENTATION. It is fully understood and agreed that each party has the right to have advice of independent counsel prior to the signing of this Agreement. By the signing of this Agreement, the parties recognize that he/she fully understands the legal impact of this Agreement and waives his/her right to have the Agreement reviewed by an attorney of his/her choosing, and further intends to be legally bound by the terms of this Agreement. 16. EFFECTIVE AGREEMENT. This Agreement shall bind the parties, their heirs, executors, administrators and assigns. 17. VOLUNTARY EXECUTION. The provisions of this Agreement are fully understood by both parties and each party acknowledges that this Agreement is fair and equitable, that it is being entered into voluntarily and that it is not the result of any duress or undue influence. 18. ENTIRE AGREEMENT. This Agreement contains the entire understanding of the parties and there are no representations, warranties, covenants or undertakings other than those expressly set forth herein. - 6 - 19. PRIOR AGREEMENT. It is understood and agreed that any and all property settlement agreements which may or have been executed prior to the date and time of this Agreement are null and void and of no effect. 20. MODIFICATION AND WAIVER. Any modification or waiver of any provision of this Agreement shall be effective only if made in writing and executed with the same formality as this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall not be construed as a waiver of any subsequent default of the same or similar nature. 21. GOVERNING LAW. This Agreement shall be governed by and shall be construed in accordance with the laws of the Commonwealth of Pennsylvania. 22. INDEPENDENT SEPARATE COVENANTS. It is specifically understood and agreed by and between the parties hereto that each paragraph hereof shall be deemed to be a separate and independent covenant and agreement. 23. VOID CLAUSES. If any term, condition, clause or provision of this Agreement shall be determined or declared to be void or invalid in law or otherwise, then only that term, condition, clause or provision shall be stricken from this Agreement and in all other respects this Agreement shall be valid and continue in full force, effect and operation. 24. ENTRY AS PART OF DECREE. It is the intention of the parties that this Agreement shall be incorporated, but not merged, in any final Decree in Divorce. - 7 - 25. WAIVER OF CLAIMS. With the exception of the specific terms of this Agreement, the parties waive any claims they may have against the other under the Divorce Code of the Commonwealth of Pennsylvania including, but not limited to, alimony, alimony pendente lite, counsel fees, costs and expenses and equitable distribution. IN WITNESS WHEREOF, the parties hereto, intending to be legally bound hereby, have hereunto set their hands and seals the day and year first above written. WITNESS: r? LORNA CORBETT CORBETT - 8 - COMMONWEALTH OF PENNSYLVANIA ) ss: COUNTY OF On this, the tl day of A,- jj? s-t , 2009, before me, a Notary Public, personally appeared Lorna Corbett, known to me to be the person whose name is subscribed to the within Postnuptial Agreement and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunt COMMONWEALTH OF PENNSYLVANIA Notarial Seal Joseph L. Grove, Notary Public Silver Spring T'wp., Cumberland County My Commission Expires Judie 18, 2013 Member, Pennsylvani?+P=ssaciation of Notaries COMMONWEALTH OF PENNSYLVANIA ) ss: COUNTY OF j ) On this, the 1-7 day of 2009, before me, a Notary Public, personally appeared William Corbett, known to me to be the person whose name is subscribed to the within Postnuptial Agreement and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunl COMMONWEAL T H OF PENNSYLVANIA Notarial Seal ESilver eph L. Grove, Notary Public pring Up., Cumberland County mmission Ex pires June 18, 2013 Member, Penns,, r ;i .?esoc+ation of Notaries TWr: It "- i- ^h^n `?. i ,idt i L! IN THE COURT OF COMMON PLEAS WILLIAM CORBETT VS. LORNA CORBETT CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION loqqj NO 08 -'&%+ CIVIL TERM. PRAEO PE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information to the court for entry of a divorce decree: 1. Ground for divorce: Irretrievable breakdown under 3301(c) (Strike out inapplicable section) 2. Date and manner of service of the complaint: Defendant accepted service on December 3, 2008 3. Comp ete (a) or ). a. Date of execution of the affidavit of consent required by 3301(c) of the Divorce code: by plaintiff 08/17/2009 ) by defendant 08/17/2009 b. (1) Date of execution of the affidavit required by 3301(d) of the Divorce Code: (2) Date of filing and service of the plaintiff s affidavit upon the respondent: 4. Related claims pending: All claims resolved pursuant to Postnuptial Agreement dated August 17, 2009 and filed with this Court. 5. Complete either (a) or (b) a. Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: b. Date of plaintiffs Waiver of Notice in 3301(c) Divorce was filed with the Prothonotary: September 15, 2009 Date defendant's Waiver of Notice in 3301 (c) divorce was filed with the Prothonotary: September 15, 2009 Attorney for Ff LEL"?-FD ? E OF THE P_, ;y ,•'OTAPY 2UP09 SEA' i 7 PM 82• 4 u f WILLIAM CORBETT V. LORNA CORBETT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-6991 Civil Term DIVORCE DECREE AND NOW, Z 2-oo ( it is ordered and decreed that WILLIAM CORBETT plaintiff, and LORNA CORBETT defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.")-None. FURTHER, the POSTNUPTIAL AGREEMENT executed on August 17, 2009 is incorporated, but not merged, in this Decree by reference and the parties are ordered to comply with it. o By the Court, Attest: Protho otary n ??j z