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HomeMy WebLinkAbout09-11421 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA Jason Morris Smith : PLAINTIFF, : CIVIL ACTION-LAW V. DIVORCE Heidi Marie Smith / DEFENDANT. NO: NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIM 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 YOU CHILD(REN). WHEN THE GROUNDS FOR DIVORCE ARE 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 PENNSYLVANIA. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES, OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYERS REFERRAL SERVICE Telephone: Jasq,K Morris Smith, llfain ff Pro Se 426 West Maple Street Palmyra, PA 17078 717-838-1835 Notice to Defend and Claim Rights Page 1 of I IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA Jason Morris Smith PLAINTIFF, CIVIL ACTION-LAW V. Heidi Marie Smith DEFENDANT. DIVORCE NO: lS q - II y z a.?P 7Z., COMPLAINT IN DIVORCE Count I-Divorce Plaintiff, Jason Morris Smith, pro se, respectfully represents: 1. Plaintiff, Jason Morris Smith, currently resides at 426 West Maple Street, Palmyra, PA 17078. 2. Defendant, Heidi Marie Smith, currently resides at 1711 Letchworth Road, Camp Hill, PA 17011. 3. Plaintiff and Defendant are sui juris, and Plaintiff and Defendant have been resident(s) of the Commonwealth of Pennsylvania for a period of more than six (6) months immediately preceding the filing of this Complaint. 4. The parties were married on 07/26/2003, in Shiremanstown, PA. 5. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Service Members' Civil Relief Act of 2003. 6. The parties have no minor or legally dependent children. 7. There have been no prior actions of divorce or for annulment between the parties. 8. The parties have entered into a written agreement as to equitable distribution of marital property, alimony, alimony pendent lite, fees and costs. 9. Plaintiff has been advised of the availability of counseling between the parties and Plaintiff acknowledges the right to request that the court require the parties to participate in such counseling in certain instances. 10. Plaintiff alleges the following grounds for the dissolution of marriage: The marriage is irretrievably broken and Plaintiff believes Defendant will consent to the divorce. Complaint in Divorce Page 1 of 2 (A ?J W ? w IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA Jason Morris Smith PLAINTIFF, V. Heidi Marie Smith CIVIL ACTION-LAW DIVORCE DEFENDANT. NO: O? -//V'_ AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA ) SS: COUNTY OF 410M KIAr ) Before me, the subscriber, a Notary Public in and for said Commonwealth and County, personally appeared Jason Morris Smith, who being duly sworn according to law, deposes and says that the facts contained within the foregoing Complaint in Divorce are true and correct to the best of his/her knowledge, information, and belief, and that he/she is authorized to make this Affidavit. Jason M As Smil , aintiff Pro Se 426 W At Maple Street Palmyra, PA 17078 717-838-1835 Sworn to and subscribed before me this day of 520. NOTARY PUBLIC Affidavit Page 1 of 1 c r.r ' T pp FM1 r ..y ? IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA Jason Morris Smith PLAINTIFF, V. CIVIL ACTION-LAW DIVORCE Heidi Marie Smith DEFENDANT. NO: 4 9 '/iY•z PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A complaint in Divorce under Section 3301(c) of the Divorce Code was filed on ,Z / 5-/ Z 0o . 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and 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 are made subject to the penalties of 18 Pa C.S. Section 4904 relating to unsworn falsification to authorities. S? / Date: Pro Se Plaintiffs Affidavit of Consent Page 1 of 1 co IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA Jason Morns Smith PLAINTIFF, V. CIVIL ACTION-LAW DIVORCE Heidi Marie Smith DEFENDANT. NO: 09,102 DEFENDANT'S AFFIDAVIT OF CONSENT 1. A complaint in Divorce under Section 3301(c) of the Divorce Code was filed on 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and 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 are made subject to the penalties of 18 Pa C.S. Section 4904 r lating to unsworn falsification to authorities. . Date: eidi Mariee-S i , De endant Pro Se Defendant's Affidavit of Consent Page 1 of 1 , n r ` ::? ? Asa ;?v cY IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA Jason Morn Smith PLAINTIFF, V. Heidi Marie Smith DEF NDANT. CIVIL ACTION-LAW DIVORCE NO: 0 5 -u yIX DEFENDANT'S ACKNOWLEDGMENT A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on / 700 7 . I agree that the marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. All information contained 'thin the attached documentation is true and correct to the best of my knowledge, information and belief. It is y desire to file with the Cumberland County Court of Common Pleas the attached Marital Pro erty Settlement Agreement and to be bound fully and completely by the terms and conditions set forth within said Marital Property Settlement Agreement documentation. Aeld'i Mari S th, Defendant Pro Se On this day of 20 before me, a Notary Public, the undersign officer, personally appeared Heidi Marie Smith, Defendant, known to me to be the person whose name is subscribed to the written instrument, and acknowledged that she executed the same fo the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. NOTARY ?UBLIC Defendant's a cknowledgment Page 1 of 1 ?-; ?,, r ' "' -,? ? - ,i?;? "?? IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA Jason Morris Smith PLA?INTIFF, CIVIL ACTION-LAW V. DIVORCE Heidi Mari Smith DEFENDANT. NO: PLAINTIFF'S ACKNOWLEDGMENT A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on I agree that the marriage of the Plaintiff and Defendant is irretrievably broken and nett' (90) days have elapsed from the date of filing the Complaint. All information contained 'thin the attached documentation is true and correct to the best of my knowledge, information and belief. It is y desire to file with the Cumberland County Court of Common Pleas the attached Marital Property Settlement Agreement and to be bound fully and completely by the terms and conditions as set forth within said Marital Property Settlem AiCearept doci tation. JasMorris Smith, Plaintiff Pro Se On this day of , 20 , before me, a Notary Public, the undersign officer, personally appeared Jason Morris Smith, Plaintiff, known to me to be the person who ;e name is subscribed to the written instrument, and acknowledged that she executed the same fo the purposes therein contained. IN WITNE$S WHEREOF, I hereunto set my hand and official seal. NOTARY UBLIC Plaintiff s Acl? owledgment Page 1 of 1 ?` ; ?.:' - ?_, ,. ?? c_ ?? ???' ? - ; i-r? i . ?_ . ?, ? "i _ ? ? + ' ? .t ? ?? .<?" i IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA Jason Morris Smith : PL?,INTIFF, CIVIL ACTION-LAW V. DIVORCE Heidi Mari Smith DEFENDANT. NO: - ?1 MARITAL PROPERTY SETTLEMENT AGREEMENT THIS A REEMENT, made this -? day of ire , 200_7 , between P INTIFF, Jason Morris Smith, residing at 426 West Maple Street, Palmyra, PA 17078, and efendant, Heidi Marie Smith, residing at 1711 Letchworth Road, Camp Hill, PA 17011. WITNESSETH the parties were married on 07/26/2003; the parties filed for 3301(c) Divorce on the parties hereto desire to settle their property rights; WHE AS, both parties agree to relinquish any and all claims which either may have against any property now owned or belonging to the other or which may hereinafter be acquired by either of em by purchase, gift, devise, bequest, inheritance, or otherwise, except as to the obligations, covenants, and agreements contained herein; and, WHE AS, both parties each have had an opportunity to seek the benefit of competent and independent legal advice by separate counsel. NOW, THEREFORE, the parties, intending to be legally bound, do covenant, and agree as follows: 1. INCORPORATION OF RECITALS The ecitals on Page 1 of this Agreement are incorporated herein as if set forth in full. Eac paragraph hereof shall be deemed to be a separate and independent covenant and 2. APPLICABLE LAW Marital Proper Settlement Agreement Pagel of 4 4 Thi$ agreement shall be construed under the laws of the Commonwealth of Pennsylvania. 3. PROPERTY TO BE RETAINED BY WIFE. Hus and and Wife agree that, unless otherwise indicated in this Agreement, the Wife shalkeep all of her personal clothing and effects; and that the following property shall also be retained by Wife: non 4. PROPERTY TO BE RETAINED BY HUSBAND. Hus and and Wife agree that, unless otherwise indicated in this Agreement, the Husband shalkeep all of his personal clothing and effects; and that the following property shall also be retained by Husband: 5. 6 TO BE PAID BY WIFE. )and and Wife agree that the Wife shall pay the following debts and will not at any hold the Husband responsible for them: TO BE PAID BY HUSBAND. and Wife agree that the Husband shall pay the following debts and will not at hold the Wife responsible for them: 7. ALI? 40NY, ALIMONY PENDENTE LITE, SPOUSAL SUPPORT, EXPENSES AND ALL MARITAL RIGHTS. Each of the parties hereto release the other from subsequent claims for alimony, alimony pen dente lite, or spousal support, except as set forth as follows: Nospousal maintenance shall be awarded to either party. 8. JO T DEBTS. Hus and and Wife warrant and certify to each other that there are no individual or joint marl al obligations outstanding, other than those listed in paragraphs 5 and 6. Marital Proper Settlement Agreement Page 2 of 4 none 9. DIVORCE. Husband and Wife agree that the marriage is irretrievably broken and will proceed with said Divorce under 23 Pa. C.A. Section 3301(c). 10. NAVE CHANGE. The Wife requests the court to restore her prior name, to wit: Heidi Marie Cassell. 11. T ADVICE. transfers set forth herein may result in income, inheritance, estate, and other tax quences to the parties. The parties specifically acknowledge that no attorney ved in the negotiating or drafting of this Agreement has provided any tax advice ment Agreement Page 3 of 4 I reg?rdmg the dispositions contained herein. The parties have been advised to seek sep4rate tax counsel concerning the Divorce distributions. IN WITNESS HEREOF, the parties have hereunto set their hands and seals the day and year first written above. Jason On this 2$, day of , 20? before me, a Notary Public, the undersign officer, personally ppeared Jason Morris Smith, Plaintiff, known to me to be the person whose name is subscribed to the written instrument, and acknowledged that he or she executed the same for the purposes therein contained. IN WITNE§S WHEREOF, I hereunto set my hand and official seal. NOTARY I UIBLIC Notarial Seal Cathy L. Youngblood, Notary Public Lemoyne Boro, Cumberland County My Commission Expires June 22, 2010 Member. Pennsylvania Association of Notaries On this day of 20_111, before me, a Notary Public, the undersign officer, personall ppeared Heidi Marie Smith, Defendant, known to me to be the person whose name is subscribed to the written instrument, and acknowledged that he or she executed t4 same for the purposes therein contained. IN WITNE?S WHEREOF, I hereunto set my hand and official seal. NOTARY COMMONWEALTH OF PENNSYLVANIA Notarial Seal Cathy L. Youngblood, Notary Public Lemoyne Boro, Cumberland County My Commission Expires June 22, 2010 Member, Pennsylvania Association of Notaries Marital Proper?y Settlement Agreement Page 4 of 4 r' q Z ` `.. . i ?. _.. r., . . -? _ _? { t '..J ?'\ ? r i : . _. cLLi?- ri 5 NOTICE TO FILE SOCIAL SECURITY NUMBERS PURSUANT TO THE 23 P.S. SECTION 4304.1(a)(3) PARTIES TO A DIVORCE ARE REQUIRE TO PROVIDE THEIR SOCIAL SECURITY NUMBERS TO THE COURT. PLEASES MIT THE SOCIAL SECURITY NUMBERS OF THE PARTIES TO YOUR DIVORCE O THE PROTHONOTARY. PLEASE FILL IN THE APPROPRIATE INFORMATION AND RETURN TO THE PROTHONOTARY OFFICE-THESE INFORMATION SHEETS WILL BE KEPT IN A SEPARATE FILE. DATE: 7/z5-/o 7 DOCKET NUMBER: D9 -// S?iZ PLAINTIFt/PETITIONER SS#: 185-64-3427 NAME: Joon Morris Smith DEFENDANT/RESPONDENT SS#: 197-64-5059 NAME: *i Marie Smith Office of Clerk of Records Prothonotary Division County Courthouse Notice to Fil? Social Security Numbers Page 1 of 1 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA Jason Morris Smith PLAINTIFF, V. CIVIL ACTION-LAW DIVORCE Heidi Marie Smith DEFENDANT. NO: 09 - /l y?1 MARITAL PROPERTY SETTLEMENT AGREEMENT THIS AGREEMENT, made this day of Ae, h , 20-0-5-11 between PLAINTIFF, Jason Morris Smith, residing at 426 West Maple Street, Palmyra, PA 17078, and Defendant, Heidi Marie Smith, residing at 1711 Letchworth Road, Camp Hill, PA 17011. WITNESSETH WHEREAS, the parties were married on 07/26/2003; WHEREAS, the parties filed for 3301(c) Divorce on f 9 ; WHEREAS, the parties hereto desire to settle their property rights; WHEREAS, both parties agree to relinquish any and all claims which either may have against any property now owned or belonging to the other or which may hereinafter be acquired by either of them by purchase, gift, devise, bequest, inheritance, or otherwise, except as to the obligations, covenants, and agreements contained herein; and, WHEREAS, both parties each have had an opportunity to seek the benefit of competent and independent legal advice by separate counsel. NOW, THEREFORE, the parties, intending to be legally bound, do covenant, and agree as follows: 1. INCORPORATION OF RECITALS The recitals on Page 1 of this Agreement are incorporated herein as if set forth in full. Each paragraph hereof shall be deemed to be a separate and independent covenant and agreement. 2. APPLICABLE LAW Marital Property Settlement Agreement Page 1 of 4 4 This agreement shall be construed under the laws of the Commonwealth of Pennsylvania. 3. PROPERTY TO BE RETAINED BY WIFE. Husband and Wife agree that, unless otherwise indicated in this Agreement, the Wife shall keep all of her personal clothing and effects; and that the following property shall also be retained by Wife: none 4. PROPERTY TO BE RETAINED BY HUSBAND. Husband and Wife agree that, unless otherwise indicated in this Agreement, the Husband shall keep all of his personal clothing and effects; and that the following property shall also be retained by Husband: none 5. DEBTS TO BE PAID BY WIFE. Husband and Wife agree that the Wife shall pay the following debts and will not at any time hold the Husband responsible for them: none 6. DEBTS TO BE PAID BY HUSBAND. Husband and Wife agree that the Husband shall pay the following debts and will not at any time hold the Wife responsible for them: none 7. ALIMONY, ALIMONY PENDENTE LITE, SPOUSAL SUPPORT, EXPENSES AND ALL MARITAL RIGHTS. Each of the parties hereto release the other from subsequent claims for alimony, alimony pendente lite, or spousal support, except as set forth as follows: No spousal maintenance shall be awarded to either party. 8. JOINT DEBTS. Husband and Wife warrant and certify to each other that there are no individual or joint marital obligations outstanding, other than those listed in paragraphs 5 and 6. Marital Property Settlement Agreement Page 2 of 4 9. DIVORCE. Husband and Wife agree that the marriage is irretrievably broken and will proceed with said Divorce under 23 Pa. C.A. Section 3301(c). 10. NAME CHANGE. The Wife requests the court to restore her prior name, to wit: Heidi Marie Cassell. 11. TAX ADVICE. The transfers set forth herein may result in income, inheritance, estate, and other tax consequences to the parties. The parties specifically acknowledge that no attorney involved in the negotiating or drafting of this Agreement has provided any tax advice Marital Property Settlement Agreement Page 3 of 4 regarding the dispositions contained herein. The parties have been advised to seek separate tax counsel concerning the Divorce distributions. IN WITNESS HEREOF, the parties have hereunto set their hands and seals the day and year first written above. c Jason orris AINTIFF On this 7?, day of ftft 20before me, a Notary Public, the undersigned officer, personally ppeared Jason Morris Smith, Plaintiff, known to me to be the person whose name is subscribed to the written instrument, and acknowledged that he or she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. NOTARt FLAILIC TH OF Notarial Seal Cathy L. Youngblood, Notary Public Lemoyne Boro, Cumberland County My Commission Expires June 22, 2010 Member, Pennsylvania Association of Notaries Heidi Marie Smrt , EFENDANT On this •19-?-day of , 2061 , before me, a Notary Public, the undersigned officer, personall appeared Heidi Marie Smith, Defendant, known to me to be the person whose name is subscribed to the written instrument, and acknowledged that he or she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. NOTARY B I COMMONWEALTH OF PENNSYLVANIA Notarial Seal Cathy L. Youngblood, Notary Public Lemoyne Boro, Cumberland County My Commission Expires June 22, 2010 Member, Pennsylvania Association of Notaries Marital Property Settlement Agreement Page 4 of 4 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA Jason Morris Smith PLAINTIFF, CIVIL ACTION-LAW V. DIVORCE Heidi Marie Smith : DEFENDANT. NO: O DEFENDANT'S ACKNOWLEDGMENT A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on .2 ?/ -?©o J . I agree that the marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. All information contained within the attached documentation is true and correct to the best of my knowledge, information, and belief. It is my desire to file with the Cumberland County Court of Common Pleas the attached Marital Property Settlement Agreement and to be bound fully and completely by the terms and conditions as set forth within said Marital Property Settlement Agreement documentation. idi Mari S ith, Defendant Pro Se On this day of , 20 , before me, a Notary Public, the undersigned officer, personally appeared Heidi Marie Smith, Defendant, known to me to be the person whose name is subscribed to the written instrument, and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my nand and official seal. NOTARY PUBLIC Defendant's Acknowledgment Page 1 of 1 r -., --:. ? , IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA Jason Morris Smith PLAINTIFF, : CIVIL ACTION-LAW V. DIVORCE Heidi Marie Smith : DEFENDANT. NO: PLAINTIFF'S ACKNOWLEDGMENT A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on ?60 . I agree that the marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. All information contained within the attached documentation is true and correct to the best of my knowledge, information, and belief. It is my desire to file with the Cumberland County Court of Common Pleas the attached Marital Property Settlement Agreement and to be bound fully and completely by the terms and conditions as set forth within said Marital Property Settleme A e t doc ntation. Jascaf Morris Smith, Plaintiff Pro Se On this day of 20 ,before me, a Notary Public, the undersigned officer, personally appeared Jason Morris Smith, Plaintiff, known to me to be the person whose name is subscribed to the written instrument, and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. NOTARY PUBLIC Plaintiff's Acknowledgment Page I of 1 T_ ` r i ....... r --i ? . IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA Jason Morris Smith PLAINTIFF, V. CIVIL ACTION-LAW DIVORCE Heidi Marie Smith DEFENDANT. NO: 07_/111/2 PRAECIPE TO TRANSMIT RECORD 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 Divorce Code. 2. Date and manner of service of the Complaint: on or about G / Z T/ 100 via (circle one) Personal Service or Certified Mail. 3. Date of execution of the Affidavit of Consent and Waiver of Notice of Intention to Request Entry of Divorce Decree Under Section 3301(c) of the Divorce Code: by Plaintiff ( 6 2,/2 5_?/ o100) ); by Defendant ( 0 z / o2S /5??_) 4. Related claims pending: None. 5. Date of filing of Affidavit of Consent and Waiver of Notice of Intention to Request Entry of Divorce Decree Under Section 3301(c) of the Divorce Code:_ by Plaintiff &Cb`? by Defendant JasoeestrM oris m1 Plaintiff Pro Se 426 ap le Street Palmyra, PA 17078 717-838-1835 Praecipe to Transmit Record Page 1 of 1 FELL=?`--Y:?=" THE 2009 Sul 1 R4 t 1"1 f• li 3