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HomeMy WebLinkAbout01-0757LINDA KAY HURSON, Plaintiff ARTHUR K. HURSON, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01- 75"7 CIVILTERM : C1VIL ACTION' ~ LAW : IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case will proceed without you and a decree in divorce or annulment may 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 First Floor, Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013. lF YOU DO NOT FILE A CLAIM FOR ALIMONY, DMSION OF MARITAL PROPERTY, LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE 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, Pennsylvania 17013 (717) 249-3166 LINDA KAY HURSON, Plaintiff ARTHUR K. HURSON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : N0.01- 75'~ CIVIL TERM CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is L'mda Kay Hurson, an adult individual, currently residing at 616 Hilltop Drive, New Cumberland, Cumberland County, Pennsylvania. 2. Defendant is Arthur K. Hurson, an adult individual, currently residing at 62 W. North Street, Apt. #3, Carlisle, Cumberland County, Pennsylvania. 3. Pla'mtiff and Defendant are bonafide residents of the Commonwealth of Pennsylvania and have been so for at least six months immediately previous to the filing of this complaint. 4. Plaintiff and Defendant were married on June 26, 1993 in Shiremanstown, Cumberland County, Pennsylvania. 5. There have been no prior actions for divorce or annulment between the parties. 6. The Defendant is not a member of the Armed Forces of the United States of America, or its Allies. 7. The Plaintiff has been advised of the availability of cotmseling and the right to request that the Court require the parties to participate in counseling. Knowing this, the Plaintiff does not desire that the Court require the parties to participate in counseling. 8. Plaintiff and Defendant are citizens of the United States of America. 9. The parties have lived separate and apart since September 2000 and continue to live separate and apart as of the date of this Complaint. 10. The parties' marriage is irretrievably broken. 11. Plaintiff desires a divorce based upon the belief that Defendant will, after ninety days bom the date of the filing of this Complaint, consent to this divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a decree in divorce. 12. full text. 13. COUNT m EOUITABLE DISTRIBUTION Paragraphs 1 through 11 are incorporated herein by reference as if set forth in their Plaintiff and Defendant are joint owners of various items of personal property, furniture, and household furnishings acquired during their marriage which are subject to equitable distribution. 14. Plaintiff and Defendant have incurred debts and obligations during their marriage which are subject to equitable distribution. WHEREFORE, Plaintiff requests your Honorable Court to enter a decree equitably dividing the parties' property and equitably apportioning the debts incurred by the parties. Respectfully Submitted, ROBERT P. KLINE, ESQUIRE 714 Bridge Street Post Office Box 461 New Cmbarland, PA 17070-0461 (717) 770-2540 Attorney for Plaintiff VERIFICATION I verify that the statements made in the foregoing Divorce Co~nplaint are true and correct. ! understand that false statements herein made are subject to the penalties of Pa.C.S. Section 4904 relating to unswom falsification to authorities. Date' LINDA KAY HURSON; Plaintiff LINDA KAY HURSON, Pla'mtiff VS. ARTHUR K. HLrRSON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01- 73~7 PRAECIPE TO PROCEED/N FORMA PAUPERIS To the Prothonotary: Kindly allow Linda Kay Hurson, Plaintiff, to proceed in forma pauperis. I, Robert P. Kline, Esquire, attorney for the party proceeding in forma pauperis, certify that 1 believe the party is unable to pay the costs and that I am providing free legal services to the party. The party's affidavit showing inability to pay the costs of litigation is attached hereto. Respectfully submitted, DATE ROBEI{T PETER KLINE, ESQUIRE~ 714 Bridge Street Post Office Box 461 New Cumberland, PA 17070-046l (717) 770-2540 Attorney for Plaintiff LINDA KAY HURSON, Plaintiff VS. ARTHUR K. HURSON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01- 73'? AFFIDAVIT IN SUPPORT OF PETITION FOR LEAVE TO PROCEED IN FORMA PAUPERIS 1. I am the plaintiff in the above matter and because of my financial condition am unable to pay the fees and costs of prosecuting, defending, or appealing the action or proceeding. 2. I am unable to obtain funds fi'om anyone, including my family and associates, to pay the costs of litigation. 3. I represent that the information below relating to my ability to pay the fees and costs is true and correct. (a) Name: Address: (b) Social Security Number: X (, c~ -.% c~ ~ If you are presently employed, state: Employer: Address: ~ Salary or wages per month: Type of work: .// If you are presently unemployed, state: (c) (d) (e) Date of last employment: Salary or wages per month: Type of work: ~-~c~'c~C~ cx. Other income within the past twelve months Business or profession: Other self-employment: Interest: Dividends: Pension and annuities: j Social Security benefits: ~ Support payments: ~/~ Disability payments: Unemployment compensation and supplemental benefits: Workman's compensation: Public Assistance: Other: Other contributions to household support (Wire--Name: If yom (husband) (wife) is employed, state: Employer: c.L~x-Xx~\-o... ~%~-r'~k ~:*.~w~_J-q5 Salary or wages per month?°~ Type of work: Contributions from children: Property owned Cash: Checking account: Savings accomat: ~ (f) (g) Certificates of Deposit: bi/A- Real estate (including home): 14/~ Motor vehicle: Make fftlTEII3fi~ tr) 5~Or/hr~t: Ye~ Cos~ B ~o~ ~o~t Owed Stocks~onds: Oi~her: Debts and obligations Mortgage: Rent: Loans: Monthly expenses: [IAI~31CI ~'/[b-'D:w- Mo. Persons dependent upon you for suppo~ (Wife) (Hmb~d) Nme: Children, if any: Name: ~/~ Age: 4. I understand that I have a continuing obligation to inform the court of improvement in my financial circumstances which would permit me to pay the costs incurred herein. 5. 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. LINDA KAY HUR~SON LINDA KAY HURSON, Plaintiff ARTHUR K. HURSON, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 01-757 CIVIL TERM : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF SERVICE I HEREBY CERTIFY THAT I served a certified copy of the Divorce Complaint filed in the above captioned case upon Defendant, Aurthur K. Hurson, by certified mail, return receipt requested on February 8, 2001, addressed to: Arthur K. Hurson 62 W. North Street, Apt. #3 Carlisle, PA 17013 and did thereafter receive same as evidenced by the attached Post Office receipt card dated February 20, 2001. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT OF SERVICE ARE TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE, INFORMATION AND BELIEF. I UNDERSTAND THAT FALSE STATEMENTS HEREIN MADE ARE SUBJECT TO THE PENALTIES OF 18 PA.C.S. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. Date ROBERT P. KLINE, ESQUIRE 714 Bridge Street Post Office Box 461 New Cumberland, PA 17070-0461 (717) 770-2540 Attorney for Plaintiff · Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. · Print your r~me and address on the reverse so that we can return the card to you. · Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: B. Dte of Detivery oD/ X n Agent D. is delivery 'om itecn 17 [~] Yes If YES, enter delivery address below: r'l No 3. Service Type ~d!~'~'ertified Mail [] Express Mail [] Registered [] Return Receipt for Merchandise [] Insured Mail [] C.O.D. 4. Restricted Deliver~j? (Extra Fee) ~ 2. Article Number (Copy from service label) PS Fern1 3811, July 1999 Domestic Return Receipt 102595-00~M-0952 LINDA KAY HURSON, Plaintiff VS. ARTHUR K. HURSON, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL TERM - LAW : NO. 01 - 757 CIVIL TERM : : DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on February 7, 2001. 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. I verify that the statements made in this Affidavit 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. 4904 relating to unsworn falsification to authorities. Linde Kay Hdrson, Plaintiff Date: \© ~o~ / LINDA KAY HURSON, Plaintiff V$, ARTHUR K. HURSON, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL TERM - LAW : NO. 01 - 757 CIVIL TERM : : 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 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. 4904 relating to unsworn falsification to authorities. Linda Kay Hurson, Plaintiff Date: LINDA KAY HURSON, Plaintiff va. ARTHUR K. HURSON, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL TERM - LAW NO. 01 - 757 CIVIL TERM DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under ~ 3301(c) of the Divorce Code was filed on February 7, 2001. 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. I verify that the statements made in this Affidavit 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. 4904 relating to unsworn falsification to authorities. LINDA KAY HURSON, Plaintiff VS. ARTHUR K. HURSON, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL TERM - LAW NO. 01 - 757 CIVIL TERM 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 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. 4904 relating to unsworn falsification to Arthur K. Hur/~on, Defendant -'-"-'---' Date: /~)/~-L//(~ / LINDA KAY HURSON, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENI~SYLVANIA vs. : NO. 01 757 CIVIL : ARTHUR K, HURSON, : Defendant : IN DIVORCE ORDER OF COURT AND NOW, this J ~'~ day of ~ ~, 2001, the parties and counsel having entered into an agreement and stipulation resolving the economic issues on October 24, 2001, the date set for a four-party conference, the agreement and stipulation having been transcribed, and subsequently signed by the parties and counsel, the appointment of the Master is vacated, and counsel can conclude the proceedings by the filing of a praecipe to transmit the record with the affidavits of consent of the parties so that a final decree in divorce can be entered. CC: Robert Peter Kline Attorney for Plaintiff Michael J. Hanft Attorney for Defendant BY THE COURT, Geor~ LINDA KAY HURSON, : Plaintiff : Vs. : : ARTHUR K. HURSON, : Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01 757 CIVIL IN DIVORCE (WHEREUPON THE FOLLOWING PROCEEDINGS WERE INTERPRETED BY CHUCK SNYDER AND JENICE WOLGEMUTH.) THE MASTER: Today is Wednesday, October 24, nhe date set for a conference with counsel and 2001. This is the parties. Plaintiff, Present in the hearing room are the Linda Kay Hurson, and her counsel Robert Peter Kline, and the Defendant, Arthur K. Hurson, and his attorney Michael J. Hanft. Also present in the hearing are two interpreters who are interpreting English into sign language inasmuch as the parties are hearing impaired. I will ask both of the interpreters to identify themselves on the record by their name. MR. SNYDER: Chuck Snyder. MS. WOLGEMUTH: Jenice Wolgemuth. First name, J-e-n-i-c-e, last name, W-o-l-g-e-m-u-t-h. THE MASTER: Also present is Lindsay Gingrich, who is here with Mr. Hanft's office. She is a clerk currently in his office. This action was commenced by the filing of a divorce complaint on February 7, 2001, averring grounds for divorce of irretrievable breakdown of the marriage and the economic claim of equitable distribution. The parties have provided the Master with affidavits of consent and waivers of notice of intention to request entry of divorce decree, both documents having been signed today by the parties. The Master will file the documents with the Prothonotary's office so that the divorce can conclude under Section 3301(c) of the Domestic Relations Code. As previously stated, the economic claim raised in the complaint is equitable distribution. There have been no claims raised for alimony or counsel fees and costs. The Master has been advised that the parties have reached an agreement with respect to the economic claim of equitable distribution. The agreement is going to be placed on the record in the presence of the parties and the interpreters. The agreement as stated on the record will be considered the substantive agreement of the parties not subject to any changes or modifications except for correction of typographical errors which may be made during the transcription. When the agreement has been transcribed it will be sent to counsel to review for typographical errors, the corrections can be made of any errors in the transcription, and then the parties will be asked to sign the agreement affirming the terms of settlement as stated on the record. It is specifically noted, however, that when the parties leave the hearing room today, even though there is no signed document, they are bound by the terms of the agreement as stated on the record. Upon receipt by the Master of a completed agreement the Master will prepare an order vacating his appointment so that counsel can file a praecipe transmitting the record to the Court along with the affidavits and waivers requesting a final decree in divorce. The parties were married on June 26, and separated in September 2000. 1993, There were no children born of this marriage. MR. equitable distribution issues as Mr. Kline. KLINE: The parties agree to resolve the follows: 1. Within two (2) weeks of today's date the parties shall arrange for a time to meet to review and divide their collection of photographs. Wife shall contact husband to arrange a time which shall then be confirmed with wife's counsel who will then confirm that time with husband's counsel. 2. At the time the parties meet for the purpose to divide the photographs referred to above, husband shall deliver to wife her Noah's ark set with all accompanying animals in his possession, her engagement ring, and wedding ring. Paragraphs one and two resolve all issues regarding tangible personal property presently located in Pennsylvania. 3. In regard to the tangible personal property presently in storage in the state of Florida, all property located there shall be the property of husband and husband shall bear the responsibility for any expense involved in storing or transporting said property with the exception that any pieces of the Noah's ark set referred to above which remain in the storage unit as of this date shall be delivered by husband to wife at husband's expense no later than June 30, 2002. That resolves all the tangible personal property in Florida. 4. In exchange for the agreements contained herein by the parties, wife agrees, upon entry of a divorce decree, to withdraw her claim for spousal support, docketed at No. 704 Support 2001. 5. The parties agree to indemnify and hold each other harmless from any and all credit card obligations for which they are the primary responsible party. The parties agree to sign any and all documents required to effectuate same. 6. Except as herein otherwise provided, each party may dispose of his or her property in any way and each party hereby waives and relinquishes any and all rights he or she may now have or hereafter acquire under the present or future laws of any jurisdiction to share in the property or the estate of the other as a result of the marital relationship including without limitation, statutory allowance, widow's allowance, right of intestacy, right to take against the will of the other, and right to act as administrator or executor in the other's estate. Each will at the request of the other execute, acknowledge, and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interest, rights, and claims. MR. KLINE: stated primarily by myself It was interpreted for you by Chuck. everything that was stated? MS. HURSON: MR. KLINE: into this as an agreement to Linda, you heard the agreement and also part of it by Mr. Hanft. Did you understand Yes. Very clear. Is it your intention to enter finally resolve your divorce action? MS. HURSON: Yes. Officially, yes. MR. HANFT: Arthur, you were present while Mr. Kline and I read the agreement and it was interpreted to you by Jenice? MR. HURSON: that agreement, agreement as case? Completely. Absolutely. MR. HANFT: It is your intention to agree to be bound by tl~at agreement, and accept that a final resolution of the divorce matter in this MR. HURSON: Yes, indeed. I acknowledge that I have read the above stipulation and agreement, that I understand the terms of settlement as set forth herein, and that by signing below I ratify and affirm the agreement previously made and intend to bind myself to the settlement as a contract obligating myself to the terms of settlement and subjecting myself to the methods and procedures of enforcement which may be imposed by law and in particular Section 3105 of the Domestic Relations Code. WITNESS: DATE: Robert Peter Kline Attorney for Plaintiff Attorney for Defendant Linda Kay Hurs6n 1~ Arthur K. Hurson LINDA KAY HURSON Plaintiff ARTHUR K. HURSON : Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 01 - 757 CIVIL 19 IN DIVORCE STATUS SHEET IN /HE COURT OF C0~5~.ON PLEAS OF CL~4~EPJ-4~D COUNTY, P~NNSYLVA~IA LINDA KAY HURS6N Plaintiff : ARTHUR X. HURSON No. 01-757 MOTION FOR APPOL~T~NT OF .MASTER LINDA KAY HURSON ~Plaintiff) ~f~J), moves the court to appo~.nt a master wi~h respec~ to the following claims: (X) Divorc~ (X) Distribution of Property ( ) Annulment ( ) Support · ( ) Alimony ( ) Counsel Fees ( ) Alimony Pendente Lite ( ) Costs and Expe. nses and in support of ~he motion states: (1) Discover7 is complete as ~o the claims(s) for which the appointment of a master is requested. (2) The defendant ~k~) (has not) appeared /n ~he action ~X k~K ~.XX:~D~XX , Esquire) (3) The statutory ground(s) for divorce (.is,) ~x~ ~501 (c (~) claims: divorce, (5) or fact. Dele=e the inapplicable paragraph(s): (o) The action is contes=ed with raspec= ~o the follow~ng distribution of property The action ~u~L~ (does not involve) complex issues of law The hearing is ~xpected to take two (2) (6) (7) Additiona~ information, if amy. relevant go the mo~ion: Plaintiff and Defendant are deaf. Attorney for (.la/ntlff) O~ER ~POINTING I~S~R is appo~ed ~s~e~h respect to ~he follow~g clams: ~ ~y =he Court: Esquire, ~J IN THE COURT OF C0}R~ON PLEAS OF CL~fBERLAND COUN~f , P~'NSYLVANIA LINDA KAY HURS~N Plaintiff : ARTHUR K. HURSON : NO. 01-757 MOTION FOR APPOINT~--~NT OF ~STE. R LINDA KAY tiURSON (Plaintiff) a master wi~h respect to.the following claims: ( X ) Divorc~ ( ) Annulment · ( ) Alimony ( ) ~~-limony Pendente Lite c~ c~ Distribution of~roB~rt]~j:3 ( ) Counsel Fees ( ) Costs and and in support of the motion states: (1) Discovery is complete as ~o the claims(s) for which the appointment of a master is requesredo (2) (3) The defendant ~h~) (has not) aooeared in the action ,Esquire). The statutory ground(s) for divorce (is) ~X 3301 (C) claims: divorce, (5) or fact. (6) Delete the inapplicable paragraph(s): (c) The action is comtes:ed with respect to the following distribution of property The ac:ion ~ (does not involve) complex issues of law The hearing is ~xpected =o taka two (2) (hours) (7) Additional information, if any. relevant to ~he morion: Plaintiff and Defendant are deaf. Da~e: O~ER ~POINTING }t~S~K .~ NOW ,19 , is appo~ed mas~ar ~h respec~ to ~he following ciasa: Esquire, By the Court: J IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA L1NDA KAY HU(RSON, Plaintiff ARTHUR K. HURSON, Defendants NO. 01-757 CIVIL TERM CML ACTION - LAW IN DIVORCE TO: PROTHONOTARY PRAECIPE Please enter my appearance on behalf of the Defendant, ARTHUR K. HURSON. Date: Respectfully submitted, LAW OFFICE OF MICHAEL J. HANFT Attorney ID No. 57976 19 Brookwood Avenue, Suite 106 Carlisle, PA 17013 (717) 249-5373 Attorney for Arthur K. Hurson, Defendant L1NDA KAY HURSON, Plaimiff ARTHUR K. HURSON, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01-757 CIVIL TERM : : CIVIL ACTION - LAW : IN DIVORCE NOTICE OF ELECTION TO RETAKE FORMER NAME NOTICE IS HEREBY GIVEN that the Plaintiffin the above matter, having been granted a Final Decree in Divorce from the bonds of matrimony on '~.e..~a&~a~. ~t ,2001, hereby elects to retake and hereafter use her previous name of LINDA KAY WARNER. LINDA KAY HURSON LINDA KAY WARNER COMMONWEALTH OF PENNSYLVANIA: : SS COUNTY OF CUMBERLAND : On the !,~'lVr day of %~ ,2001, before me, the undersigned officer, a Notary Public, personally appeared Linda Kay Hurson, known to me or satisfactorily proven to be the person whose name is subscribed to the within instrument, and acknowiedge that she executed the foregoing for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto, fle~'ny ha~d and notarial seal. / NOTARY PUBLIC NOTARIAL SEAL ItOI~F.R-f PEIEIt KUNE, Nolary Pul]lie New Cumberland 8oro., Cumbela~d Co. My Commission Expires June 21, 2004 LINDA KAY HURSON, Plaintiff ARTHUR K. HURSON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-757 CWIL TERM CWIL 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: Ground for divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. 3. Date and manner of service of the Complaint: Certified mail on February 20, 2001. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: By Plaintiff: October 24, 2001; By Defendant: October 24, 2001. 4. Related claims pending: None. All related claims have been resolved pursuant to an agreement reached at the Office of the Divorce Master on October 24, 2001, which has been filed of record and which shall be incorporated into, but shall not merge with the divorce decree. 5. Indicate date and manner of service of the notice of intention to file praecipe to transmit record, and attach a copy of said notice under Section 3301(d) of the Divorce Code: Waiver of notice executed by Plaintiff on October 24, 2001, and by Defendant on October 24, 2001, and both were filed of record by the Divorce Master. Respectfully submitted, Date ROBERT P. KLINE, ESQUIRE 714 Bridge Street Post Office Box 461 New Cumberland, PA 17070-0461 (717) 770-2540 Attorney for Plaintiff IN THE COURT OF COMMON OF CUMBERLAND COUNTY STATE O]~ ~ PENNA. LINDA K~Y HURSON. Plaintiff No. 01-757 PLEAS Civil VERSUS ARTHUR K. HURSON, Defendant DECREE IN DIVORCE DECREED THAT LINDA KAY HUL{SON 2001 , IT IS ORDERED AND ~ PLAINTIFF, AND ARTHUR K. HURSON ,DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. 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; [<one. II]he Agreement entered into by the parties at the Office of incorporated into, the ]:ivoree Master on October 24, 2001 is b~t shal~ not ~e~~,-tMs ])ecree. BY TH E~ ~/ - i ~ ~ ~3PROTHONOTARY