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HomeMy WebLinkAbout10-2049RMORCE OF THE PPOrHONNOTARY Quintina M. Laudermilch, Esquire DALEY ZUCKER MEILTON MINER & GINGRICH, LLC 2010 MAR 23 Pil 1. 1029 Scenery Drive Harrisburg, PA 17109 C (717) 6574795 u a t .` . ?_ + r r tlaudermilch(a)dzmmglaw. com IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TRACY L. MCCURDY, Plaintiff V. DANIEL D. MCCURDY, JR., Defendant No. 16 - 01049 l .:i v i L Il° 'm CIVIL ACTION - LAW (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 Court House, One Courthouse Square, 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 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 DATE: 3 Izz J 10 DALEYZUCKER MEILTON MINER & GINGRICH, LLC By: uintina M. Laudermilch, Esquire Supreme Court I.D. #94664 1029 Scenery Drive Harrisburg, PA 17109 (717) 657-4795 Attorneys for Plaintiff W0.50 PO 60 4a?4 A-qY add ? 3 (? Quintina M. Laudermilch, Esquire DALEYZUCKER MEILTON MINER & GINGRICH, LLC 1029 Scenery Drive Harrisburg, PA 17109 (717) 657-4795 tlaudermilch(a4 mmglaw.com IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TRACY L. MCCURDY, Plaintiff No. V. CIVIL ACTION - LAW DANIEL D. MCCURDY, JR., Defendant (In Divorce) COMPLAINT UNDER & 3301(c) OR & 3301(d) OF THE DIVORCE CODE Count I - Divorce 1. Plaintiff is Tracy L. McCurdy, who currently resides at 301 Chestnut Street, Apartment 1702, Harrisburg, Dauphin County, Pennsylvania. 2. Defendant is Daniel D. McCurdy, Jr., who currently resides at 1646 Lowell Lane, New Cumberland, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on September 13, 2002, in New York, New York. 5. No children were born of the marriage. 6. There have been no prior actions of divorce or for annulment between the parties. 7. 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. 8. Neither Plaintiff nor Defendant is a member of the Armed Services of the United States or any of its Allies. 9. The cause(s) of action and section(s) of Divorce Code under which Plaintiff is proceeding are: A. Section 3301(c). The marriage of the parties is irretrievably broken. After ninety (90) days have elapsed from the date of the filing of this Complaint, Plaintiff intends to file and Affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an Affidavit. B. Section 3301(d). The marriage of the parties is irretrievably broken. The Plaintiff and Defendant separated on November 8, 2008. WHEREFORE, Plaintiff requests your Honorable Court to enter a Decree in Divorce, divorcing Plaintiff and Defendant from the bonds of matrimony. Count II - Equitable Distribution 10. Paragraphs 1 through 9 of this Complaint are incorporated herein by reference as though set forth in full. 11. Plaintiff and Defendant have acquired property, both real and personal, during their marriage which property is subject to equitable distribution by the Court. WHEREFORE, Plaintiff requests this Honorable Court equitably divide all martial property. Count III - Alimony 12. Paragraphs 1 through 11 of the Complaint are incorporated herein by reference as though set forth in full. 13. Plaintiff has inadequate means of support for herself except as provided for by Defendant. 14. Plaintiff requires reasonable support to adequately maintain herself in accordance with the standard of living established during the marriage. WHEREFORE, Plaintiff requests your Honorable Court to enter an award of Alimony in her favor. Count IV - Alimony Pendente Lite, Counsel Fees and Expenses 15. Paragraphs 1 through 14 of the Complaint are incorporated herein by reference as though set forth in full. 16. Plaintiff lacks sufficient funds to support herself and pay Counsel fees and expenses incidental to this action. 17. Defendant is full well and able to pay Plaintiff Alimony, Alimony Pendente Lite, counsel fees and expenses incidental to this Divorce action. WHEREFORE, Plaintiff requests your Honorable Court to enter an award of Alimony Pendente Lite, Plaintiff's counsel fees and the costs of this proceeding. Respectfully submitted, DALEY ZUCKER MELTON MINER & GINGRICH, LLC Date: 3) ZZ By: uintina M. Laudermilch, Esquire Supreme Court ID # 94664 1029 Scenery Drive Harrisburg, Pennsylvania 17109 Attorneys for Plaintiff VERIFICATION I, Tracy L. McCurdy, verify that the statements made in this Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. f Dated: a?1 /0 C-- Wr Tracy L. Mc urdy, Plaintiff Quintina M. Laudermilch, Esquire DALEY ZUCKER MEILTON '`' MINER & GINGRICH, LLC 1~-~ ~i~` ~ 2 ~~~ ~~ `` 1029 Scenery Drive Harrisburg, PA 17109 {;~;',~ ~ ~~'-;t1~`''i `j v.`.,~4;r (717)657-4795 rL ~ `'.`~',~,J.j~J;1 tlaudermi lchna,dzmm~law.com IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TRACY L. MCCURDY, Plaintiff v. DANIEL D. MCCURDY, JR., Defendant No. 2010-2049 CIVIL Af"?'IC)N - I,AW (In Divorce) ACCEPTANCE OF SERVICE I, Donald T. Kissinger, Esquire, do hereby accept service of the true and correct copy of the Complaint in Divorce on behalf of my client, Daniel D. McCurdy, Jr., the Defendant in the above-captioned case, and I certify that I am authorized to do so. Respectfully submitted, Date: ~ ~~ ~~ L Donald: T. Kissinger, E:;q~ Howett Kissinger & Holst, PC 130 Walnut Street P.O. BOX 810 Harrisburg, PA 17108 Donald T. Kissinger, Esquire JUDGE MASLAND HOWETT, KISSINGER & HOLST, P.C. 130 Walnut Street, P.O. Box 810 Harrisburg, PA 17108 Telephone: (717) 234-2616 Counsel for Defendant/Petitioner Daniel D. McCurdy, Jr. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVAT41A TRACY L. BOAR f/n/a TRACY L. McCURDY, Plaintiff/Respondent NO. 2010-2 CIVIL TERM (PACSES CASE NO. 067111532) V. DANIEL D. McCURDY, JR., Defendant/Petitioner CIVIL ACTION - LAW IN DIVORCE PETITION TO MODIFY EXISTING ALIMONY PENDENTE LITE ORDER AND NOW, comes Defendant, Daniel D. McCurdy, Jr., by and through his counsel, Howett, Kissinger & Holst, P.C., who hereby files the instant Petition to Modify Existing Alimony Pendente Lite Order and in support thereof avers as follows: 1. Plaintiff is Tracy,L. Boak, who resides at 301 Chestnut Street, Apartment 1702, Harrisburg, Pennsylvania, 17101, and is unemployed. 2. Defendant is Daniel D. McCurdy, Jr., who resides at 1646 Lowell Lane, New Cumberland, Pennsylvania, 17070, and is employed by EMC Corporation. 3. On the 18t' day of June, 2010, your Honorable Court entered an Order against Defendant in the amount of One Thousand Four Hundred Dollars ($1;400.00) per month ($1,300.00 for alimony pendente lite and $100 on arrears). Said order also required Defendant to make additional quarterly payments of $1,950 directly to Plaintiff. 4. Defendant's income is strongly influenced by sales for which he receives commission. Since the entry of said Order, Defendant's commission income has significantly decreased thus warranting a decrease in his alimony pendente lite obligation. WHEREFORE, Petitioner respectfully requests this Honorable Court enter an order modifying his alimony pendente lite obligation appropriately. Date: f 1 Respectfully submitted, Donald T. Kissinger, Esquire HOWETT, KISSINGER & H LST, P.C. 130 Walnut Street P.O. Box 810 Harrisburg, PA 17108 Telephone: (717) 234-2616 Counsel for Defendant/Petitioner Daniel D. McCurdy, Jr. VERIFICATION I, Donald T. Kissinger, Esquire, hereby swear and affirm that the facts contained in the foregoing Petition to Modit? Existing Alimony Pendente Lite Order are true and correct to the best of my knowledge, information, and belief based upon information provided by Defendant and from my own first-hand knowledge and that said facts are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Date: //'- / 0 Donald T. Kissinger, Esq it IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TRACY L. BOAK f/n/a TRACY L. McCURDY, ) Plaintiff/Respondent ) NO. 2010-2094 CIVIL TERM PACSES CASE NO. 067111532 V. ) DANIEL D. McCURDY, JR., ) CIVIL ACTION - LAW Defendant/Petitioner ) IN DIVORCE CERTIFICATE OF SERVICE I, Donald T. Kissinger, Esquire, counsel for Daniel D. McCurdy, Jr., Defendant in the above-captioned action, hereby certify that a true and correct copy of the foregoing Petition to Modify Existing Alimony Pendente Lite Order was served upon Quintina M. Laudermilch, Esquire, counsel for Plaintiff Tracy L. Boak, by depositing same in the United States mail, first class, on November 5, 2010, addressed as follows: Quintina M. Laudermilch, Esquire DALEY, ZUCKER, MEILTON, MINER & GINGRICH, LLC 1029 Scenery Drive Harrisburg, PA 17109 Date: Donald T. Kissinger, Esq e HOWETT, KISSINGER & HOLST, P.C. 130 Walnut Street, P.O. Box 810 Harrisburg, PA 17108 Telephone: (717) 234-2616 Counsel for Defendant/Petitioner Daniel D. McCurdy, Jr. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TRACY L. BOAK f/n/a TRACY L. McCURDY, Plaintiff l v. ) NO. 2010-2049 CIVIL TERM DANIEL D. McCURDY, JR.., ) CIVIL ACTION - LAW Defendant ) IN DIVORCE NOTICE If you wish to deny arty of the statements set forth in this Affidavit, you must file} a 7-1 ,., w Counteraffidavit within twenty days after this Affidavit has been served on you or the statements will be admitted. DEFENDANT'S AFFIDAVIT UNDER §3301(d) OF THE DIVORCE CODE 1. The parties to this action separated no later than November 8, 2008 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 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 unsworn falsification to authorities. Date: Daniel D. McCurdy, , D ndant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TRACY L. BOAK f/n/a TRACY L. McCURDY, Plaintiff V. DANIEL D. McCURDY, JR., Defendant NO. 2010-2049 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE COUNTER-AFFIDAVIT UNDER §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): (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. (b) I wish to claim economic relief which may include alimony, division of 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 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, understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: Tracy L. Boak, Plaintiff COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND, SS: TRACY L. BOAK f/k/a TRACY L. McCURDY, PLAINTIFF V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2010-2049 CIVIL TERM DANIEL D. McCURDY, JR., ) CIVIL ACTION - LAW DEFENDANT ) IN DIVORCE a MOTION FOR APPOINTMENT OF MASTER Defendant Daniel D. McCurdy, Jr. moves the court to appoint a master with respect to the f' 0 wing claims: = (X) Divorce (X) Distribution of Property ( ) Annulment ( ) Support (X) Alimony (X) Counsel Fees (X) Alimony Pendente Lite (X) Costs and Expenses and in support of the motion states: requested. Esquire. Discovery is complete as to the claim(s) for which the appointment of a master is The plaintiff has appeared in this action by his attorney, Quintina M. Laudermilch, The statutory grounds for divorce are §3301(c). 4. The action is not contested. An agreement has been reached with respect to the following claims: The action is contested with respect to the following claims: divorce, alimony, alimony pendente lite, distribution of property, counsel fees, costs and expenses. 5. The action does not involve complex issues of law or fact. 6. The hearing is expected to take one day. 7. Additional information, if any, relevant to the motion: N/A Date: 141r1l'L Donald T. Kissinger, Esquir Attorney for Defendant AND NOW, , 2010, master with respect to the following claims: Esquire is appointed BY THE COURT: J. K... COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND, SS: TRACY L. BOAK f/k/a TRACY L. McCURDY, ) PLAINTIFF ) V. ) ) NOV 15 '1010 I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2010-2049 CIVIL TERM DANIEL D. McCURDY, JR., ) CIVIL ACTION -LAW -_.., DEFENDANT ) IN DIVORCE MOTION FOR APPOINTMENT OF MASTER /?iJ?C- 'n cv Defendant Daniel D. McCurdy, Jr. moves the court to appoint a master with respect to the i?lwinf claims: (X) Divorce (X) - Distribution of Property ( ) Annulment ( ) cs Support (X) Alimony (X) Counsel Fees (X) Alimony Pendente Lite (X) Costs and Expenses and in support of the motion states: 1. Discovery is complete as to the claim(s) for which the appointment of a master is requested. 2. The plaintiff has appeared in this action by his attorney, Quintina M. Laudermilch, Esquire. The statutory grounds for divorce are §3301(c). _.? Y? ?, 46 4. The action is not contested. An agreement has been reached with respect to the following claims: The action is contested with respect to the following claims: divorce, alimony, alimony pendente lite, distribution of property, counsel fees, costs and expenses. 5. The action does not involve complex issues of law or fact. 6. The hearing is expected to take one day. 7. Additional information, if any, relevant to the motion: N/A Date: Donald T. Kissinger, Esquir CC Attorney for Defendant It.3 2010, C, , \?? ? .1L , Esquire is appointed ti. cm wij U_ 7? pect to the following claims: `fir - w CL ? I+X M'a't L/ - BY THE ggiMT: d- AL N c.a n' ???`1„ J. l ? T.?A NOY 1 5 201D IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TRACY L. BOAK f/n/a TRACY L. McCURDY, Plaintiff V. DANIEL D. McCURDY, JR., Defendant NO. 2010-2049 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE COUNTER-AFFIDAVIT UNDER §3301(d) OF THE DIVORCE CODE i Check either (a) or (b): (a) I do not oppose the entry of a divorce decree. C) c rnco z? ?b z? 0 nc (b) I oppose the entry of a divorce decree because (check (i), (ii) or both): (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 0 0 -c M ss a .e- co 0 rrn ?rn ca c --fC) =-n 0 X, c? 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. (b) I wish to claim economic relief which may include alimony, division of 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 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 understand that false statements herein are made subject to the penalties,of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: ?- Tracy L. Bo Plaintiff 1 TRACY L. BOAK, Plaintiff/Petitioner VS. DANIEL D. McCURDY, JR., Defendant/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORDER OF COURT CIVIL ACTION - DIVORCE C IVIL TERM NO. 10.20" . IN DIVORCE 5. ` PACSES CASE: 067111532 -?a AND NOW, this 19th day of November 2010, a petition has been filed against you, Tracy L. Boak, to modify an existing Alimony Pendente Lite Order. You are ordered to appear in person at the Domestic Relations Section, 13 North Hanover Street, Carlisle, Pennsylvania, on December 15, 2010 at 10:30 A.M. for a conference and to remain until dismissed by the Court. If you fail to appear as provided in this Order, an Order of Court may be entered against you. You are further ordered to bring to the conference: (1) a true copy of your most recent Federal Income Tax Return, including W-2's as filed (2) your pay stubs for the preceding six (6) months (3) the Income and Expense Statement attached to this order, completed as required by the Rule 1910.11. (4) verification of child care expenses (5) proof of medical coverage which you may have, or may have available to you IF you fail to appear for the conference or bring the required documents, the Court may issue a warrant for your arrest. Copies mailed to: Petitioner Respondent Quintina M. Laudermilch, Esq. Donald T. Kissinger, Esq. Date of Order: November 19.2010 BY THE COURT, Albert H. Masland, Judge YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND REPRESENT YOU. 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 MAY GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVE. CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 cc361 TRACY L. BOAK, Plaintiff VS. DANIEL D. McCURDY, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE NO. 10-2049 CIVIL TERM IN DIVORCE PACSES CASE: 067111532 ORDER OF COURT - RESCHEDULE A CONFERENCE C"7 C M ;-r& ? y. c-e C:) N O O M C-) M -v N w C) -n ^^I _- rnr ?M ::0CD o, ?o z? C) -Tj o? D xi AND NOW, this 3rd day of December, 2010, upon consideration of the Petition for Alimony Pendente Lite and/or counsel fees, it is hereby directed that the parties and their respective counsel appear before R. J. Shadday on January 6. 2011 at 9:00 A.M. for a conference, at 13 N. Hanover St., Carlisle, PA 17013, after which the conference officer may recommend that an Order for Alimony Pendente Lite be entered. This date replaces the prior conference date of December 15, 2010. YOU are further ordered to bring to the conference: (1) a true copy of your most recent Federal Income Tax Return, including W-2's as filed (2) your pay stubs for the preceding six (6) months (3) the Income and Expense Statement attached to this order, completed as required by Rule 1910.11© (4) verification of child care expenses (5) proof of medical coverage which you may have, or may have available to you (6) IF you fail to appear for the conference or bring the required documents, the Court may issue a warrant for your arrest. BY THE COURT, Date of Order: December 16, 2010 Copies mailed to: Petitioner Respondent Quintina M. Laudermilch, Esq. Donald T. Kissinger, Esq. A Masland, Judge YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND REPRESENT YOU. 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 MAY GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVE. CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 cc361 TRACY L. BOAK, IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE NO. 10-2049 CIVIL TERM DANIEL D. McCURDY, JR., IN DIVORCE Defendant/Respondent PACSES CASE: 057111532 w.s Mt" YL co ORDER OF COURT ??rl _ ?> C) N r- AND NOW to wit, this 4th day of February, 2011, it is hereby Ordered that 9*liVgny> Pendente Lite is terminated, effective December 31, 2010, with no balance due, pursuant to the parties' Marital Settlement Agreement of February 2, 2011. This Order shall become final twenty (20) days after the mailing of the notices of the entry of the Order to the parties unless either party files a written demand with the Office of the Prothonotary for a hearing de novo before the Court. BY THE COURT: Albert H. Masland, J. DRO: R.J. Shadday xc: Petitioner Respondent Qunitina A Laudermilch., Esq. Donald T. Kissinger, Esq. Form OE-001 Service Type: M Worker: 21005 I NO. 2010-2049 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE ORDER AND NOW, this 8 day of , 2011, the within Petition for Donald T. Kissinger, Esquire HOWETT, KISSINGER & HOLST, P.C. 130 Walnut Street P.O. Box 810 Harrisburg, PA 17108 Telephone: (717) 234-2616 Counsel for Defendant, Daniel D. McCurdy, Jr. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TRACY L. BOAK f/n/a TRACY L. McCURDY, ) Plaintiff ) V. ) DANIEL D. McCURDY, JR., ) Defendant ) Revocation of Master is hereby granted. Distribution: BY THE COURT: - r- _...ti f? rn cc .G° r- --4 c:, --n -ice ?E. Robert Elicker, II, Esq. 9 North Hanover Street, Carlisle, PA 17013, (717) 240-6534 ?Donald T. Kissinger, Esq., P.O. Box 810, Harrisburg, PA 17108, (717) 234-2616 ?Quintina M. Laudermilch, Esq., 1029 Scenery Drive, Harrisburg, PA 17109, (717) 657-4795 I'? C?pleo M 0j 4jalDa 9 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TRACY L. BOAK, f/k/a TRACY L. MCCURDY Plaintiff avgJCI No. 2010409*- v. DANIEL D. MCCURDY, JR., Defendant CIVIL ACTION - LAW (In Divorce) AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on March 23, 2010. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. 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 & 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. 1 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. / n r n Date: Tracy L. Boak (Pn/a Tracy L. McCurdy), Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENPSYI*A ty ? r TRACY L. BOAK ' f/n/a TRACY L. McCURDY, ) : i'a W Plaintiff ) NO. 2010--CIVIL TERM V. ) DANIEL D. McCURDY, JR., ) CIVIL ACTION - LAW Defendant ) IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT A complaint in divorce under §3301(c) of the Divorce Code was filed on March 23, 2010. 2. The marriage of Plaintiff and Defendant is irretrievably broken, and ninety days have elapsed from the date of filing and service of the complaint. 3. I consent to the entry of a final decree in 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 §3301(c) OF THE DIVORCE CODE 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. 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 above 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: Z 2 ,?4/ ?i= i Daniel D. McCurdy, Jr., Defe an IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TRACY L. BOAK, f/k/a TRACY L. MCCURDY, . V. DANIEL D. MCCURDY, JR., 1Jq No. 2010-209W DIVORCE DECREE AND NOW, _ !I g, c L, \ 11 '1611 , it is ordered and decreed that TRACY L. BOAK, f/k/a TRACY L. MCCURDY, plaintiff, and DANIEL D. MCCURDY, JR., bonds of matrimony. defendant, are divorced from the 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. By the Court, 3'17111 - e&-t. 4y mailed 4o ocxty Laude-rm i l ah Nofi'ee + 4y mai d 4o aLLY Kissinj er