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HomeMy WebLinkAbout09-1739 MARCUS R.THOMPSON, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : CIVIL ACTION -LAW CHRISTIE R. THOMPSON, : IN DIVORCE Defendant NO. /9. I73-57 ?uu l 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 at the Cumberland County Court House, One Courthouse Square, Carlisle, Pennsylvania 17013-3387. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 0 MARCUS R. THOMPSON, Plaintiff VS. CHRISTIE R. THOMPSON, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION -LAW : IN DIVORCE : NO. O9- 1739 Cc?,-j 7-t,- COMPLAINT UNDER SECTION 3301(c)0F THE DIVORCE CODE AND NOW, this day of 2009, comes the Plaintiff, Marcus R. Thompson, by his attorney, Jane M. lexander, Esquire, and files this Complaint upon a cause of action-of which the following is a statement. 1. Plaintiff is Marcus R. Thompson, who currently resides at 25 Kim Acres Dr., Mechanicsburg, Upper Allen Township, Cumberland County, Pennsylvania and has lived there for (2) years. 2. Defendant is Christie R. Thompson, who currently resides at 25 Kim Acres Dr., Mechanicsburg, Upper Allen Township, Cumberland County, Pennsylvania and has lived there for (2) years. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on September 15, 2007 at Mechanicsburg, Pennsylvania. 5. There were no children born between the parties during the marriage. 6. There have been no prior actions of divorce or for annulment between the parties. 7. The parties have not entered into a written agreement as to alimony, counsel fees, cost and property division. 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. While the parties were domiciled within the Commonwealth of Pennsylvania, and through no fault of Plaintiff, the innocent and injured spouse, the Defendant, in violation of the marriage vows and the laws of the Commonwealth, has offered such indignities to the person of the Plaintiff as to render his condition intolerable and life burdensome. 10. The marriage is irretrievably broken. WHEREFORE, the Plaintiff prays your Honorable Court to enter a Decree of Divorce from the bonds of matrimony. COUNT II 11. The allegations of Paragraph one (1) through nine (10) are incorporated herein by reference and made a part hereof. 12. The marriage is irretrievably broken. WHEREFORE, the Plaintiff prays your Honorable Court to enter a Decree of Divorce from the bonds of matrimony. COUNT III 13. During the marriage, Plaintiff and Defendant have acquired various items of marital property, both real and personal, which are subject to equitable distribution under Chapter 35 of the Divorce Code. WHEREFORE, the Plaintiff prays your Honorable Court to enter a Decree of Divorce from the bonds of matrimony and equitably divide all marital property of whatsoever kind and wheresoever situate and for such further relief as the Court may deem equitable and just. Respectfully submitted, bane M. Alex der, Esqui Attorney for Plaintiff I.D. No. 07355 148 South Baltimore Street Dillsburg, PA 17019 (717) 432-4514 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 un-sworn falsification to author Date: Moo 1° 2001 COMMONWEALTH OF PENNSYLVANIA S. S. COUNTY OF YORK Before me, the undersigned officer, a Notary Public, in and for the said Commonwealth and County, personally appeared Marcus R. Thompson who, being affirmed according to law, deposes and says that the facts and matters set forth in the foregoing Complaint are true and correct to the best of her knowledge, informE Sworn to and su gpbed before me tizis f day of ,,4 2009. f -?DF tarv Public ONWEALTrt ^tNnVM4 Notar LasWe K Netbu.. Wartirtgton TwtMy Commission En rrs,; Merttbpr, Pennsylvania Wis. ?iation of Notaries COMMONWEALTH OF PENNSYLVANIA Notarial Seal Leslie K Neidig, Notary Public Warrington Twp., York County My Commissars Expires Feb. 4, 2011 Member, Pennsylvan' a..;^cr•?^? of Notaries G U G.? lv? 1 V w d 4?l r h L ? o a f a "g' ,t MARCUS R. THOMPSON, Plaintiff VS. CHRISTIE R. THOMPSON, Defendant : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, PA : NO. 09-1739 CIVIL ACTION LAW : IN DIVORCE AFFIDAVIT OF SERVICE AND NOW, this day of 2009 personally appeared Jane M. Alexan er Esquire who swe ccording to law, that a true and correct copy of a COMPLAINT IN DIVORCE was caused e served by certified mail with return receipt requested upon the said, CHRISTIE R. THOMPSON 25 KIM ACRES DR. MECHANICSBURG, PA 17055 on March 23, 2009 by leaving the same at the Dillsburg Post Office with postage pre-paid thereon as evidenced by the mailing receipt and return receipt hereto attached and made a part hereof. Sworn and subscrib before me this/? _ , l3 day of LUU \ Public J e M. Ale:?an'der, Esyfri Attorney I.D. #07355 148 S. Baltimore Street Dillshurg, PA 17019-0421 (717) 432-4514 COMMONWEALTH OF PENN; Yt V 'U.1% Notarial Seal Leslie K. Neidig, Notary Public Warrington Twp., York County My Commission Expires Feb. 4, 2011 Member, PennsyivaW a r5ssc,;!; ,,n of Nutanes *. MARCUS R. THOMPSON, : IN THE COURT OF COMMON PLEAS Plaintiff . OF CUMBERLAND COUNTY, PA VS. NO. 09-1739 CIVIL ACTION LAW CHRISTIE R. THOMPSON, Defendant IN DIVORCE PROF SZKVICE ¦ Complete Msma 1, 2. and 3. IMIlndeuy m item 4 It Resbictad DIAMY Is deei+ed. ¦ Print your nwwand address orrthe reveres.' ; so that we can ream the card W you. ¦ Attachii1iffis card to the back of the maiipfim, or 'Yront if space permit. 1. Artids' to: 0 AQW a•5- ?(? ?cY-es T??-? Y? i-7 os? by Q~ I C. Date of D"'my D. )sd*myadI A4sCOMM tftmNpm17 O yes If YES, erMer delivery address below: 13 No 3 @qwType d%d Bp" *WW W E3 Rduin R?cW for Mew /E -R9 ob wmd oco.. 4. Resbicted OeUvW (tuba F60) s 2. Aroae NuMber 7004 0750 0403 6357 2780 PS Form 3811, February 2004 tlwrew? ft*M * to2s9s oz M-tsao p r- Provided) ru rn For delivery information v isit our website at www.usps.com M ..n Poe" $ $1 not? m p Certified Fee $2 70. 05 ? Z C3 Retu fledept Fee (End=..m .M Required) - ; n (REndoreeme tRR ulre?d) $4. _ r%- w p Total Postage & Fees $ $10.20 3/23!2009 S C3 C3 -SFWT* Q• - 5a? ?- 'Q>w--..------------ aPOBlast rro aS ,lJl ------------------ --------- rr? A? ............ - - -- -- -------- cm. stagy., --- -- ` n r ? l7n ? S OF TF rl, P ')T`?r'Mf)TARY 2009 APR 15 PM 3: 40 J(`N 't t``Y ??2( A tA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ? Tto-mw r) Plaintiff FILE NO. y)_1?L?1_-, 3 ? ZO 20I ?! VS. IN DIVORCE Ch '?(-fti t T l I_i efendant m ss_ 1. NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff/Defendant in the above matter, a been granted a Final Decree in Divorce on the 2? ?h day of hereby elects to resume the prior surname of hcaw , , and gives this written notice pursuant to the provisions of 54 P.S?704. DATE: Si ature rn? ature of n m eing resumed COMMONWEALTH OF PENNSYLVANIA . COUNTY OF CUMBERLAND SS. On the day of A-UNAIJ _ 20 /U , before me, a Notary Public, personally appeared the above afiiant known to me to be the person whose name is subscribed to the within document and acknowledged that he/she executed the foregoing for the purpose therein contained. N -.3 3 N N Ul v -' rn In Witness Whereof, I have :hereunto set my hand and official seal. COMMONWEALTH of PENNSnvANw - ? Notarial Seat Nota Public Beverly K. Morgan, Notay Pubic Upper Akn Twp., Cumberland County My Commission Explres 7, 2013 Member, Pennsylvania Association of Notaries G! ??. Cf L g 0- 7 yo9 MARCUS R. THOMPSON, CHRISTIE R. THOMPSON, vs. N/KJA CHRISTIE HECKARD, Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 1739 2009 Defendant MOTION FOR APPOINTMENT OF MASTER Defendant moves the court to appoint a master with respect to Christie R Thompson the following claims: ?X Divorce Q Distribution of Property ? Annulment ? Support ? Alimony ? Counsel Fees ? Alimony Pendente Lite ? Costs and Expenses and in support of the motion states: Discovery is complete as to the claims (s) for which the appointment of a master is I requested. . The defendant has appeared in the action (personally) (by his attorney,_ 2 . Jacqueline M. Verney yui -+ 3. The staturory ground (s) for divorce is rear ?? C. = M -,r 3301(d) -<D , Delete the inapplicable paragraph (s): A ? B ? C QX 4 C:) y0 o= . a. The action is not contested. c-, 5C b. An agreement has been reached with resnect to the following claims: 5(-- c. The action is contested with respect to the following claims: Equitable Distribution 5. The action does not involve complex issues of law or fact. 6. The hearing is expected to take 4 hours 7. Additional information, if any, relevant to the motion: nF Date: June 6, 2011 _ Attor y for Defendant O r ' -r CD Jacqueline M Verney Esquire ri -0 ?::3 -n Print Name r % ORDER APPOINTING MASTERX AND NOW gt? 7 , 20 If ??eA (?""GC dk.A/-.'L7 Esquire,`) ' is appointed master with respect to the following claims: 4a Q 01JO,9ucl n e A?. UCri1G5r ?.54. O lJ "'dame M. AlG}cQ,L, ,- ?Sy Cop;G5 *a •'Ie-4 61 X11, By the c;oun, :L-? - ed J. y CERTIFICATE OF SERVICE I, Jacqueline M. Verney, Esquire, hereby certify that a true and correct copy of the within Motion was served upon the following by the method and date indicated: By US Mail, postage pre-paid: Jane M. Alexander, Esquire 148 South Baltimore Street Dillsburg, PA 17019 Date (p -(o - 1 I acqu ine M. Verney, Esquire #23 44 South Hanover Street Carlisle, PA 17013 (717) 243-9190 Attorney for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MARCUS R. THOMPSON, NO. 2009-1739 Plaintiff R rn= • z= 00 VS. CHRISTINE E. THOMPSON, a/ka/ CHRISTIE R. HECKARD Defendant CIVIL ACTION - LAWS, A? Z ' za Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on August 31, 2009. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from date of filing and service of the Complaint. C7 --+ x-n MF -0m =C? °? ? -ra 3C-) 3. I consent to the entry of a final Decree of Divorce after service of Notice of Intention to Request Entry of the Decree. i? I verify that the statements made in the 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 unworn falsification to authorities. Date: 2-16-12- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MARCUS R. THOMPSON, :NO. 2009-1739 Plaintiff C*J o VS. :CIVIL ACTION - LAW - rrn rn I HRISTINE E. THOMPSON, :r a/k/a CHRISTIE R. HECKARD :IN DIVORCE 3> c} ac Defendant __ cc WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER CODE 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 i, granted. 3. I understand that I will not be divorced until a Divorce Decree is entered by the Court and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Waiver are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unworn falsification to authorities. Date: 2- l w i 2 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MARCUS R. THOMPSON, Plaintiff VS. : NO. 2009-1739 : CIVIL ACTION -LAW CHRISTINE E. THOMPSON, ? Wa CHRISTIE R. HECKARD : IN DIVORCE Defendant AFFIDAVIT OF CONSENT C' tnA N ? © C- 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on February 5, 2010. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from date of filing and service of the Complaint. 3. I consent to the entry of a final Decree of Divorce after service of Notice of Intention to Request Entry of the Decree. I verify that the statements made in the 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. n ac Date: 20713-11 ristine E. Thompson a/k/a Christie eckard I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, ? 1ARCUS R. PENNSYLVANIA THOMPSON, Plaintiff VS. HRISTINE R. THOMPSON, a CHRISTIE R. HECKARD Defendant NO. 2009-1739 n N `' •?, c Nr" CIVIL ACTION -LAW x' -- o -t z. *r) • ac c Zc, c -: o C) rr : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER CODE 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 Waiver 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: L 'stine E. Thompson r a, hrisHeckard r` T HE PRpfd0 nnv 2012 FEB 21 PM 1: 4 7 CUMBERLAND Co ?y MARCUS R. THOMPSON, PEN " URT OF COMMON PLEAS Plaintiff :OF CUMBERLAND COUNTY, PENNSYLVANIA VS. :NO. 2009-1739 CHRISTINE E. THOMPSON, a/k/a CHRISTIE R. HECKARD :CIVIL ACTION - LAW Defendant AN DIVORCE MA UUAGE SETTLEMENT AGREEMENT THIS AGREEMENT made this _ Ti ay of 2012 by and between Marcus R. Thompson of 1209 Indian Peg Road, Mechanicsburg, I Cumberland County, Pennsylvania 17055 (hereinafter referred to as "HUSBAND") and ii Christine E. Thompson a/k/a Christie R. Heckard, of 13 Pine tree Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055 (hereinafter referred to as i "WIFE".) WITNESSETH. WHEREAS, HUSBAND and WIFE were married September 15, 2007 in Mechanicsburg, Cumberland County, Pennsylvania. HUSBAND instituted an action in divorce to No. 2009-1739 in the Court of Common Pleas of Cumberland County, Pennsylvania on March 20, 2009. The pleadings in the case requested dissolution of the marriage between the two parties and for such further relief that the Court may deem equitable and just; and WHEREAS, the parties have reached an agreement as to the settling of all matters relating to the divorce including disposition of all marital property. There were no children born during this marriage. NOW, THEREFORE, in consideration of the promises and the mutual promises, covenants and undertakings hereinafter set forth and for other good and valuable consideration, 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. The parties intend to maintain separate and permanent domiciles and to live apart from each other. It is the intent and purpose of this Agreement to set forth the respective rights and duties of the parties while they continue to live apart from each other. 2. The terms of this Agreement and their effect have been fully explained to the HUSBAND by his counsel, Jane M. Alexander, Esquire. WIFE has been advised of her rights by her counsel, Jacqueline M. Verney, Esquire. The parties acknowledge that they have received independent legal advice from counsel of their choice and have been fully i informed as to their legal rights and obligations or have chosen not to do so. The parties understand the facts and acknowledge and accept this Agreement as fair and equitable. 3. The parties have attempted to divide their matrimonial property in a manner which conforms to a just and right standard, with due regard to the rights of each party. It is the intent of the parties that such division shall be final and shall forever determine their respective rights. The division of existing marital property is not intended by the parties to constitute in any way a sale or exchange of assets, and the division is being affected without the introduction of outside funds or other property not constituting a part of the marital estate. 4. Neither party shall molest, harass, annoy, injure, threaten or interfere with the other party in any matter whatsoever. Each party may carry on and engage in any employment, profession, business or other activity as he or she may deem advisable for Page 2 his or her sole use and benefit. Neither party shall interfere with the uses, ownership, enjoyment or disposition of any property now owned and not specified herein or property hereafter acquired by the other. 5,. The consideration for this contract and agreement is the mutual benefits to be obtained by both of the parties hereto and the covenants and agreements of each of the parties to the other. The adequacy of the consideration for all agreements herein contained is stipulated, confessed, and admitted by the parties, and the parties intend to be legally bound hereby. 6. DEBTS OF THE PARTIES: It is further mutually agreed and understood by and between the parties that all joint debts have been paid including open accounts, credit cards, and bank liabilities except as hereinafter set forth: 7. PERSONAL PROPERTY: As to all items of personal property which the parties have divided to their mutual satisfaction, henceforth, each of the parties shall own, have and enjoy independently of any claim or right of the other party, all items of personal property of every kind, nature and description and wherever situated, which are now owned or held by or which may hereafter belong to the HUSBAND or WIFE, with full power to the HUSBAND or the WIFE to dispose of same as fully and effectually, in all respects and for all purposes as if he or she were not married. Specific disposition of major items or personal property is as follows: 7.1) Bank Accounts: a. Each party has opened and maintained their own separate bank accounts since the time of separation. Neither party will make a claim against those funds. b. All bank accounts both checking and savings which were held in joint names have been closed and proceeds were used to pay marital debt. D--- 1 7.2) Vehicles: a) HUSBAND shall retain possession, title, and sole ownership to the following vehicle: Jeep Cherokee and shall be responsible for any debt thereon, if any. b) WIFE shall retain possession, title, and sole ownership to the following vehicle: 2000 Honda Civic and shall be responsible for payment of the debt thereon, if any. 7.3) Household furnishings: The parties have divided the household furnishings to their mutual satisfaction. 7.4) Pensions: Stock options Retirement funds IRAs: a) Both parties are the owners of 401 K pension plans and neither party will make a claim against the other for these or similar funds. b) Each party shall be responsible for their own health, dental, or other types of insurance as of date of the divorce decree. 8. REAL ESTATE: The Marital residence of the parties located at 25 Kim Acres Drive, Upper Allen township, Mechanicsburg, Pa 17055 was sold as the result of a action of mortgage foreclosure. 9. SPOUSAL SUPPORT/ALIMONY: Neither party will make any claim for spousal support and/or alimony and if any action has been filed it will be promptly withdrawn. 10. SETTLEMENT PAYMENT: I At date of execution of the agreement and signing by the parties of therein respective affidavits of consent and waivers of notice. "HUSBAND" shall pay to the "WIFE" the sum of $3,000.00 in full settlement of any claims of debts full settlement of any claims of debts which "WIFE" may have against him. 11. BANKRUPTCY: The parties hereby agree that the provision of the 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 obtained 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 the division of the parties' marital assets and all other rights determined by this Agreement shall be subject to court determination the same as if this Agreement had never been entered into. 12. STATUS OF SETTLEMENT: The property settlement as provided herein between the parties shall be considered an equitable distribution of marital property and both parties waive any and all rights or claims which they may have been entitled to raise with respect to the issue of equitable distribution under the Provisions of the Pennsylvania Divorce Act. 13. The parties agree that simultaneously with the signing of this Agreement they will sign the necessary affidavits of consent and affidavits acknowledging notice of marriage counseling in order to conclude the divorce action filed by WIFE under the no- fault provisions of the Pennsylvania Divorce Act. 14. The waiver or unenforceability of any term, condition, clause or provision of this Agreement shall in no way be deemed or considered to be a waiver of or forfeiture of right to enforce any other term, condition, clause or provision of this Agreement. 15. This Agreement shall be construed and interpreted according to the laws of the Commonwealth of Pennsylvania. Page 5 16. It is understood and agreed that the heirs, administrators, executors and assigns of the parties hereto shall be bound by all the terms, conditions, clauses and provisions of this Agreement. IN WITNESS WHEREOF, the parties hereto have set their hands and seals the day and year first above written, intending to be legally bound. WITNESS BY: I Kristine E. o son a/k/a Christie R. Heckard, Defendant n^-- L COMMONWEALTH OF PENNSYLVANIA COUNTY OF YORK S.S. On this, the da of ?LLI'Lcc-t-AX4 , 2012, before me the undersigned officer, a Notary public, in and for said Commonwealth and County, personally appeared Marcus R. Thompson known to me (or satisfactorily proven) to be the person whose name is subscribed to the foregoing Marriage Settlement Agreement and in due form acknowledged that she executed the same for the purpose therein contained and desired the same to be recorded as such. WITNESS my hand and notarial seal the day and year aforesaid. COMMONWEALTH OF PENNSYLVANIA } Notarlal Seal ( I 6L -U t ' rr Amy M. Hambright, Notary Public Notary P llc Diltsburg Boro, York County My Commission Expires Sept. 22, 2014 Member, Pennsvivania Assoditlon of Notaries My Commission Expire: GI <?,-)-%G/q COMMONWEALTH OF PENNSYLVANIA . S.S. COUNTY OF CUMBERLAND J dayof `, 2012, before me the On this, the undersigned officer, a Notary public, in and for said Commonwealth and County, personally appeared Christine E. Thompson a/k/a Christie R. Heckard, known to me (or satisfactorily proven) to be the person whose name is subscribed to the foregoing Marriage Settlement Agreement and in due form acknowledged that he executed the same for the purpose therein contained and desired the same to be recorded as such. WITNESS my hand and notarial seal the day and year aforesaid. Seal 'Ila ZPSAII PENNSYLVANIA Notary Public NO Public t Cumres berland Oct. County 14 of Notaries rwmber. ration My Commission Expire: MARCUS R. THOMPSON, Plaintiff VS. CHRIS'T'INE E. THOMPSON, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 09 - 1739 CIVIL IN DIVORCE ORDER OF COURT AND NOW, this ;, day of ,4 , 2012, the economic claims raised in the proceedings having been resolved in accordance with a marriage settlement agreement dated February 13, 2012, the appointment of the Master is vacated and counsel can file a praecipe transmitting the record to the Court requesting a final decree in divorce. BY THE COURT, 4 Kev' A. Hess, P.J. cc: ? Jane M. Alexander Attorney for Plaintiff t/ Jacqueline M. Verney Attorney for Defendant ,°co -n ZE Z m r n M ..,. -r?- U,)r- N u < z-r: l1 t' i" IvL v1312 FEB 23 AM 9.31 NiMBERLAND COUNTY pENN?YLVANtA Marcus R. Thompson, Plaintiff VS. Christine E. Thompson a/k/a Christie R. Reckard, Defendant : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2009-1739 : CIVIL - ACTION LAW : IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under §3301(c)'22 )) of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the complaint: was served to the Defendant by certified mail by the Dillsburg Post Office on. 3. (Complete either paragraph (a) or (b)) a) Date of execution of the affidavit of consent required by §3301(c) of the Divorce Code: by plaintiff 2/16/12; by defendant 2/13/12. b) (1) Date of execution of the affidavit required by §3301(d) of the Divorce Code: (2) Date of filing of the 3301(d) affidavit: (3) Date of service of the 3301(d) affidavit upon respondent: 4. Related claims pending: None 5. (Complete either (a) or (b).) (a) Date and manner of service of the notice of intention to request entry of the divorce decree, a copy of which is attached: 2/13/12 By Plaintiffs Attorney Jacqueline M. Verney, (b) Date plaintiff's Waiver of Notice was filed with the Prothonotary: -7 Date defendant's Waiver of Notice was filed 4h the Prothonotary: i Date: rney for Maintiff rney I.D. #07355 S. Baltimore Street ;buriz, PA 17019 17) 432-4514 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MARCUS R. THOMPSON V. CHRISTINE E. THOMPSON, NO. 2009-1739 a/k/a Christie R. Heckard DIVORCE DECREE AND NOW, ?-n cti-cA 7* , 2 o l L , it is ordered and decreed that MARCUS R. THOMPSON , plaintiff, and CHRISTINE E. THOMPSON, , defendant, are divorced from the a a Christie R. Heckard bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente cite 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.") By the Court, 1--?7 /,J/., J. 3.-7-1;1. OP/? copl ?rtPrG4'01 D lpl.Kdlo ''-