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HomeMy WebLinkAbout04-2252LISA SHUGHART, BARTLSHUGHART, Plaintiff Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW ._ : NO. 04~ o~.~ CIVIL TERM : IN DIVORCE NOTICE 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 Courthouse, High and Hanover Streets, Carlisle Pennsylvania. 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 TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Phone 717 249-3166 LISA SHUGHART, BARTT. SHUGHART, Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 04- o~-x CIVIL TERM : IN DIVORCE COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Lisa Shughart, who currently resides at 204 Burnt House Road, Carlisle Pennsylvania, 17013. 2. Defendant is Bart L. Shughart, who currently resides at 986 Houck Road, Mechanicsburg, Pennsylvania, 17055. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on July 14, 1990 in Carlisle Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. The parties have been advised that counseling is available, and that either may have the right to request that the Court order the parties to participate in counseling. 8. There were three children born during this marriage. 9. The custody and visitation of and with the minor children is not at issue. 10. Plaintiff respectfully requests this Court enter a Decree in Divorce. Richard R. Gan, Esquire Attorney for Plaintiff 50 E. High Street Carlisle, PA 17013 (717) 258-8558 Supreme Court ID #68721 VERIFICATION I vedfy that the statements made in the foregoing Divorce Complaint 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. Lisa Shughart, Plaint~ ' 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA Lisa Shughart, V Bart Shughart Plaintiff Defendant Action in Divorce File No: 2004-02252 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 19th day of May, ,.004, I served by first class mail, a true copy of the complaint for Divorce on Bart Shughart at the following address, 986 Hauck Road, Mechanicsburg Pa 17055. Orr Law Offices 50 East High Street Carlisle, PA 17013 717-258-855 I.D 68721 ACKNOWLEDGMENT OF SERVICE RE: SHUGHART V SHUGHART File No: 04-2252 Now comes the Defendant herein, BART L. SHUGHART and acknowledges that on the ~ _day of May, 2004, I received a copy of the Con~tplaint for Divorce in the above referenced matter by first class mail. Dated: l - Bart L. Shughart ~' ~'-- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-IN DIVORCE LISA SHUGHART, Plaintiff VS. BART SHUGHART, Defendant No. 2004-02252 MARITAL PROPERTY SETTLEMENT AGREEMENT 1. This agreement is made and concluded this ~-,,~ day of~;~, 2004 by and between Lisa Shughart, hereafter referred to as "Plaintiff" and Bart Shughart, hereafter referred to as "Defendant". 2. WITNESSETH: 3. WHEREAS, the parties are HUSBAND AND WIFE; 4. WHEREAS, unfortunate and irreconcilable difference have arisen between the parties by reason of which continued cohabitation as HUSBAND and WIFE has been rendered impossible; and 5. WHEREAS, the parties have agreed on a settlement of all property rights and differences existing between them. 6. WHEREAS, the parties intend this agreement to be a full, complete, and valid Postnuptial Agreement, providing for the absolute and final settlement of all They're respective property rights and all claims for spousal support, alimony pendente lite and alimony. 7. NOW, THEREFORE, with the foregoing recitals being hereinafter incorporated by reference and deemed as an essential part hereof, and intending to be legally bound hereby, and for other good and sufficient consideration, the receipt whereof is hereby acknowledged, the parties being advised and represented by counsel, mutually agree as follows: 8. NO-FAULT DIVORCE UNDER SECTION 3301(c) OF THE DOMESTIC RELATIONS CODE OF PENNSYLVANIA. Plaintiff and Defendant agree that Plaintiff shall secure a no fault divorce based upon the irretrievable breakdown of their marriage. PLAINTIFF AND DEFENDANT further agree to execute their respective affidavits of consent under section 3301 9c) of the Domestic relations Code of Pennsylvania, Waivers of Notice of Intention to Request Entry of Divorce Decree, and to execute any documents necessary under existing rules of Pennsylvania Civil Procedure and local rules of the Court of Common Pleas of Cumberland County, in order to allow Plaintiff to file all such documents in the Court of Common Pleas of Cumberland County, PA. Neither Plaintiff nor Defendant shall either directly or indirectly permit the withdrawal of their respective affidavits of consent or of any and all other documents executed by Plaintiff and Defendant subsequent to the execution of the documents. The affidavits of Consent and Waivers of Notice shall be executed within (10) days of receipt. 9, DATE OF EXECUTION. The date of execution or execution date of this agreement shall be defined as the date upon which the parties execute it, if they have each executed the Agreement on the same date. Otherwise, the date of execution or execution date of this Agreement shall be defined as the date of execution by the party last executing this Agreement. 10. REAL ESTATE. The Plaintiff shall continue to reside at the marital residence located at 204 Burnt House Road, Carlisle Pennsylvania. The parties agree that by virtue of this agreement that when the home is sold, the net equity realized will be divided equally between the parties. 11. ENCUMBRANCES, WARRANTIES, GUARANTEES. The parties represent AND WARRANT herein that they have fully informed each other and are aware of all liens and encumbrances that exist on the marital residence. 12. PERSONAL PROPERTY. The parties have divided all of their marital and non-marital personal property. Each relinquishes any and all claims to the personal property in possession of the other party. 13. MOTOR VEHICLES. Each party shall be responsible for all payments, insurance, fuel and related expenses on all vehicles that they own or lease both during this proceeding and after the entry of judgment. 14. DIVISION OF SAVINGS AND CHECKING ACCOUNTS. All joint savings and checking accounts have been closed and or reorganized and divided as agreed upon by the parties. 15. MEDICAL INSURANCE. The defendant shall continue all medical dental and optical coverage on and for the minor children of this marriage. The defendant shall further make available to the Plaintiff, COBRA coverage for a Period of no less than 36 months subsequent to the entry of this agreement. 16. DEBTS. The parties stipulate and agree that there are no other debts arising from this marriage other than the ones herein mentioned. It is further stipulated and agreed that any debt that is incurred by either party after the filing of this Post Nuptial Agreement shall be the exclusive responsibility of the party incurring the debt. 17. RETIRMENT ACCOUNTS. The parties agree that each have their own Separate retirement accounts and that these accounts shall remain the exclusive Property of the owner. The parties further agree that each shall be barred From making a claim on the other parties retirement benefits after the entry Of this agreement. 18. TAXES, TAX RETURN, REFUNDS. The parties agree that they have filed or will file individual Federal, State and Local tax returns. The Parties further stipulate that if there is any local, state of Federal Tax responsibilities due and owing by the parties up and through the filing of this property settlement agreement, it shall be the responsibility of the Defendant. '19. SPOUSAL SUPPORT, ALIMONY, ALIMONY PENDENTE LITE. The parties stipulate and agree that no alimony shall be paid by either party and after the entry of this agreement the issue of alimony is barred. The parties do agree however that the Defendant shall assist the Plaintiff in the maintenance and upkeep of the marital residence for a period of 36 months as mutually agreed to between the parties. 20. ADVICE OF COUNSEL, PROPERTY RIGHTS The provisions of this agreement and their legal effect have been fully explained to the parties by their respective legal counsel. The parties acknowledge that they have mutually worked to construct this agreement and agree with the terms as presented herein. More specifically, each understands that if either party had proceeded with an action in Divorce, under Pennsylvania law, the marital property of the parties would have been divided by the Court based on the following factors: a. The length of the marriage. b. Any prior marriage of either party. c. The age, health, station, amount and sources of income, vocational skills, employability, estate, liabilities and needs of each of the parties. d. The contribution by one party to the education, training or increased Earning power of the other party. e. The opportunity of each party for future acquisitions of capital assets and income. f. The sources of income of both parties, including but not limited to, medical, retirement, insurance or other benefits. g. The contribution or dissipation of each party in the acquisition, preservation, depreciation or appreciation of the marital property. h. The standard of living of the parties established during the marriage. i. The economic circumstances of each party at the time the division of property is to become effective. 21. ADVICE OF COUNSEL- ALIMONY. Further, each party has had explained to him / her that if either had proceeded with an action in Divorce, under Pennsylvania law, the appropriateness of awarding alimony to one of the parties would have been determined by the court, based upon the following factors: a. The relative earnings and earning capacities of the parties. b. The ages and physical, mental and emotional conditions of the parties. c. The sources of income of both parties, including but not limited to medical, retirement, insurance or other benefits. d. The expectancies and inheritances of the parties. e. The duration of the marriage. f. The contribution by one party to the education, training or increased earning power of the other party. g. The standard of living of the parties established during the marriage. h. The relative assets and liabilities of the parties. i. The property brought into the marriage by either party. j. The relative needs of the parties. k. The marital misconduct of either of the parties during the marriage. The marital misconduct of either of the parties from the date of final separation shall not be considered by the court in its final decision relative to alimony. I. The Federal, State and local tax ramifications of the alimony award. m. Whether the party seeking alimony is incapable of self-support through appropriate employment. Each party has also had explained to him / her that if an Order for Alimony had been entered by the court, the court would have determined the amount of the payments, the duration of the payments, and that the payments would be subject to modification or termination based upon changed circumstances, cohabitation, remarriage or death. Each party confirms that she or he fully understands the factors regarding equitable distribution and alimony under the Divorce Code of Pennsylvania, that each waives her / his rights to have the Court equitably divide their marital property or determine the appropriateness of alimony, and that each fully understands the terms, conditions and provisions of this Agreement, and finds them to be fair, just, equitable and reasonable under the existing circumstances. The parties further confirm that each is entering into this Agreement freely and voluntarily and that the execution of this Agreement is not the result of any duress, undue influence, collusion or improper or illegal agreement. 22. BREACH If either party breaches any provision hereof, then the Non-breaching party shall have the right, at his or her election, to sue for damages for the breach, or seek such other remedies or relief as may be available to him or her, and the defaulting party shall be responsible for payment of all legal fees and costs incurred by the other party in enforcing his or her right under this Agreement. It is expressly understood and agreed by and between the parties that this Agreement may be specifically enforced by either the Plaintiff or the Defendant in a Court of Equity by either party, the other party will make no objection on the alleged ground of lack of jurisdiction of the court on the ground that there is an adequate remedy at law. The parties do not intend or purport to improperly confer jurisdiction on a court in Equity by their Agreement, but they agree as provided herein for the forum of equity in mutual recognition of the present state of the law, and in recognition of the general jurisdiction of courts in equity over Agreements as outlined herein. 23, WAIVER OF PENNSYLVANIA DIVORCE CODE RIGHTS. All property set apart herein either now or in the future as the separate property of either the Plaintiff or Defendant and all property now owned by or titled to the Plaintiff or to the Defendant individually and all property acquired by Plaintiff or Defendant individually at anytime after the execution of this Agreement shall remain the separate property of that party and shall under no circumstances be considered or construed to be marital property as that term is used in the Pennsylvania Divorce Code and as such shall not be subject to equitable distribution. This agreement shall be deemed to be and construed to be a valid Agreement for the purpose of waiving the provision concerning equitable distribution as that term is used in the Pennsylvania Divorce Code. 24. DISCLOSURE, Each party agrees and represents that he or she has made a full and complete disclosure to the other of all assets and liabilities whether joint or individual of each party and each party further acknowledges that he or she is satisfied that such complete disclosure has been made. 25. DIVORCE. It is the understanding of the parties that their marriage is irretrievably broken, and each warrants and represents to the other that he or she will acknowledge to the Court of Cumberland County that his or her marriage to the other is irretrievably broken and each will consent to the courts decree divorcing them from the bonds of matrimony as a condition to the performance of this Agreement. 26. EQUITABLE BINDING PROPERTY AGREEMENT. The parties agree and acknowledge that this Agreement affects an equitable distribution of the parties marital property in a manner which is satisfactory to each. This agreement may be incorporated into the final decree of divorce in any divorce action which may be pending between the parties. This Agreement shall not be merged in any such decree, but shall survive the decree and be forever binding upon the parties. 27. TRANSFERS AND PAYMENT CONTINGENT UPON THE ENTRY OF A DECREE OF DIVORCE, It is specifically understood and agreed by and between the parties that the conveyances, transfers and assignments of real and personal property are all made contingent upon the entry of a valid and final decree in Divorce sevedng and terminating the marriage relationship between the parties. 28. INCORPORATION IN JUDGMENT FOR DIVORCE. In the event either the Plaintiff or the Defendant at any time hereafter obtains a divorce in the cause presently or hereafter pending between them, this Agreement and all of its provisions may be incorporated for the purposes of enforcement only, but not merged, into any such judgment for divorce, either directly or by reference. The Court, on entry of the judgment for divorce shall retain the right to enforce the provisions and the terms of the Agreement. 29. COUNSEL FEES. The parties shall be responsible for their own attorney fees. 30. PERSONAL RIGHTS. Each party shall be free from all interference, authority and control, direct or indirect, by the other, as fully as if he or she were single and unmarried. Neither party shall disturb, malign or molest the other or compel or endeavor to compel the other to cohabit or dwell with him or her, or to interfere with the occupation, friendships, society, or acquaintances which either of the parties may choose to have from this day forward. 31. EXECUTION OF DOCUMENTS. Each party shall, upon the reasonable request of the other party or his or her designee, promptly make, execute and deliver any papers, documents and instruments and perform such acts as may be reasonably necessary or desirable for the purpose of giving full force and effect to the provisions of this Agreement and to carry out the intent of the parties as expressed herein. 32. PARTIAL INVALIDITY. If any provision of this agreement is held to be invalid or unenforceable, all other provisions shall nevertheless continue in full force and effect. 33. WAIVER OF ESTATE CLAIMS. Each party hereby waives, releases, and relinquishes any and all rights that he or she may now have, or hereafter acquire as the other party's spouse under the present or future laws of any jurisdiction, including but not limited to the following: (a) To elect or take against any will or codicils of the other party, now or hereafter in force. (b) To share in the other party's estate in the case of intestacy. (c) To act as executor or administrator of the other party's estate. (d) To be the beneficiary of any stock account, bank account, life insurance policy, pension, 401 (K), profit sharing, or other retirement account. 34. SITUS. This agreement shall be construed and governed in accordance with laws of the Commonwealth of Pennsylvania. 35, CONSTRUCTION. This Agreement shall not be construed against either party as the party preparing it, it being agreed that both parties have participated in the preparation thereof. 36. 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. 37. REPRESENTATION. Each party acknowledges that this Agreement has been entered into freely and voluntarily with full knowledge of the facts and full information as to the legal rights and liabilities of each and that each hereby certifies he or she has fully read this Agreement, understands the same and believes the same to be reasonable under the circumstances. 38. BINDING EFFECT. The terms, provisions and conditions of this Agreement shall be binding upon any and all of the heirs, executors, administrators, successors or assigns of either of the respective parties hereto, except as may be otherwise herein provided. 39. MODIFICATION AND WAIVER. A modification or waiver of any of the provisions 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. 40. ENFORCEMENT. The parties hereto agree that the provisions of this Agreement may be entered and enforced by an appropriate court order at the action of the entitled party and against the obligated party, as the case may be, when any problem arises. 41. PURPOSE. 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. The provisions of this Agreement are intended to consider, determine, and distribute all assets of the parties as a part of the terms of this Postnuptial Agreement. This Agreement is intended by the parties to be a valid Postnuptial Agreement, providing for the absolute and final settlement of their respective property dghts. This agreement is not intended to be a mere Separation Agreement. 42. INTENTION. Each of the parties intends to be legally bound hereby and this Agreement shall be binding upon the heirs, personal representatives and assigns of the respective parties hereto. 43. INCORPORATION BY REFERENCE. This Marital Property Settlement Agreement may be incorporated by reference into the Judgment of Divorce as if reproduced in full therein. IN WITNESS WHEREOF, the parties hereto have set their hands and seal the day and year first above written. This Agreement is executed in duplicate, and in counterparts, and Plaintiff and Defendant, as parties hereto, acknowledge the receipt of a duly executed copy and further acknowledge that each copy shall constitute an original. COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND On this, theo~0'~'day of 5a~004, before me, a Notary Public, the undersigned officer, personally appeared known to me, or satisfactorily proven to be the person whose name is subscribed to the within Postnuptial Agreement, and acknowledged that he / she executed the same for the purposes therein contained. IN WITNESS WHEREOF, 1~3ave hereunto set my hand and notarial seal. ' Notar~Public COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND On this, the og-Ow' .day of ~, 2004, before me, a Notary Public, the undersigned officer, personally appeared /.. ~ 1) ~-{~x.4-/-/,'J-~~ known to me, or satisfactorily proven to be the person whose name is subscribed to the within Postnuptial Agreement, and acknowledged that he / she executed the same for the purposes therein contained. IN WITNESS WHEREO~,j~o hereTto, set my hand and notadal seel. ' "No(ary Public ......... I ~4¥ c.,ommis..,~'n E,,-~.~s t~. This Marital Property Settlement Agreement was prepared by Richard R. Gan. LISA SHUGHART, Plaintiff BART SHUGHART, Defendant IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 2004-02252 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on MAY 18TM 2004.. 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. 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. LISA SHUGART, PLAINTIFF LISA SHUGHART, Plaintiff BART SHUGHART, Defendant IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 2004~02252 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on MAY 18TM 2004. 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. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. Date: ~-~E ~RR T S~H ~UGH~T, pLAi~NTiFF LISA SHUGHART BARTSHUGHART Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2004-022252 CIVIL TERM : IN DIVORCE 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. 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 unswom falsification to authorities. LISA SHUGHART BART SHUGHART Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2004-022252 CIVIL TERM : IN DIVORCE 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. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~4904, relating to unsworn falsification to authorities. Date: LISA SHUGHART, Plaintiff IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA VS. BART SHUGHART, Defendant CIVIL ACTION - LAW DIVORCE NO. 2004 02252 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 §3301(d)(1) of the Divorce Code. 2. Date and manner of service of Complaint: Served upon Defendant: acknowledgment of service, on May 20 2004. 3. Complete either paragraph (a) or Co): (a) Date of execution of Plaimiffs and Defendant's Affidavits of Consem required by Section 3301(c) of the Divorce Code and Waiver of Notice of Intemion to Request Entry of a Divorce Decree under Section 3301(c) of the Divorce Code, pursuant to Pa.R.C.P. 1920.42(eXI): Plaintiff- 9,21,04 Defendant - 9,22,04 CoXI) Date of execution of Plaintiffs affidavit required by Section 3301(d) of the Divorce Code: 9,21,04; (2) Date of filing and service of PlaintiWs affidavit upon the responder~: 9,22,04. 4. Complete the appropriate paragraphs: (a) Related claims pending: All claims have been resolved by a signed Marital Settlement Agreement. (a) Date and manner of service of the notice of intention to file praecipe a copy of which is attached: By first class mail on: 9, 23,04. (b) Date PlaintiWs Waiver of Notice was filed with the Prothonotary: 9, 23,04. (c) Date defendant's Waiver of Notice was filed with the Prothonotary: 9,23,04 Law Offices of Richard R. Gan mcnara ~. t_/an, Esquire I.D. No. 68721 17 West South Street Carlisle, PA 17013 (717) 241-4300 Attorney for Plaintiff CERTII~ICA~ OF SERVICE AND NOW, this day of ~ , 2004 I, Richard IL Gan, Esquire, attorney for Plaintiff, hereby certify that I served a copy of the Praeeipe to Transmit Reeord on the Defendant Bart Shughart this day by depositing thc same in the United States mail, postage prepaid, at Carlisle, Pennsylvania, addressed to: Mr Bart Shughart 986 Hauck Road Mechanicsburg, PA 17055 LAW OFFICES OF RICHARD IL GAN =tqJCHARD IL GAN, ESQUIRE r'-,.) -'(t ? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF ,~~'~ PENNA. LISA SHUGHART, Plaintiff N o. 2004-02252 VERSUS BART SHUGHART, Defendant DECREE iN DIVORCE DECREED that Lisa Shuqhart AND Bart Shughart ARE DIVORCED FROM THE BONDS OF MATRIMONY. 2004 , IT IS ORDERED AND , PLAINTIFF, , DEFENDANT, THE COURT RETAINS JURISDICTION Of THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOr WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED;