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HomeMy WebLinkAbout01-1197BRIAN L. YOHE, Plaintiff VS. CYNTHIA A. YOHE, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA :No. : : ACTION 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 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 fights important to yon, including custody or visitation of your children. Where 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 at the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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 (717) 249-3166 BRIAN L. YOHE, Plaintiff VS. CYNTHIA A. YOHE, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No. : ACTION IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiffis Brian L. Yohe, an individual suijuris, who has resided at 210 Bridge St., New Cumberland, Cumberland County, Pennsylvania, 17070, since 1999. 2. Defendant is Cynthia A. Yohe, an individual suijuris, who has resided at 800 York Road, Lot//103, Dover, York County, Pem~sylvania, 17315 since July 13, 199l. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiffand the Defendant were married on July 13, 1991 in York Haven, York County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Plalnfiffhas been advised that counseling is available and that plaintiffmay have the fight to request that the court require the parties to participate in counseling. 7. Plaintiffand Defendant have two (2) children together, namely, Lindsay A. Yohe, date of birth, 6-10-92, and Amber L. Yohe, date of birth, 5-11-94. 8. Plaintiff and Defendant are both citizens of the United States of America. 9. Neither Plaintiff or Defendant are a member of the Atoned Forces of the United States of any of its allies. 10. The Plaintiff avers that the grounds on which this action is based are: (a) That the marriage is irretrievably broken; and/or (b) That the Defendant has offered such indignities to the Plaintiff, the innocent and injured spouse, as to render her condition intolerable and life burdensome. WHEREFORE, Plaintiffrequests the court to enter a decree in divorce. I verify that the statements made in this Complaint are true and correct. 1 understand that false statements herein are made subject to the penalties of 18 Pa.C.S. {4904 relating to unswom falsification to authorities. Date:.~.~ Respectfully submitted, Adams, Esquire No, 79465 117 South Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF BRIAN L. YOHE, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 01 o 1197 Civil Term ~: CYNTHIA A. YOHE, : ACTION IN DIVORCE ?,- Defendant : -- c NOTICE OF INTENT TO REQUEST ENTRY OF DIVORCE DECRI~ TO: Cynthia A, Yohe 800 York Road Lot #103 Dover. Pa, 17315 DATE.' July 26, 2001 You have been sued in aa action for divorce. You have failed to answer the Complaint or file a Counter-Affidavit to the 3301(d) affidavit. Therefore, on or after Aug:last 15, 2001 the Plaintiff can request the Court to enter a final decree in divorce. If you do not file with the Prothonotary of the Court an answer with your signature notarized or verified or a Counter-Affidavit by the date above, the Court can enter a final decree in Divorce. Unless you have already filed with the Court a written claim for economic relief, you must do so by the above date or the Court may grant the divorce and you lose forever the right to ask for economic relief. A COUNTER-AFFIDAVIT WHICH YOU MAY FILE WITH THE PROTHONOTARY OF THE COURT IS ATTACHED TO THIS NOTICE. Unless you. have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of your counter-affidavit alone does not protect your economic claims. 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 (717) 249-3166 BRIAN L. YOHE, Plaintiff VS. CYNTHIA A. YOHE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 01 - 1197 Civil Term ACTION IN DIVORCE AFFIDAVIT OF SERVICE REGARDING NOTICE OF INTENT AND COUNTER-AFFIDAVIT AND NOW, this August 21, 2001, I, Jane Adams, Esquire, hereby certify that on July 28, 2001, a true and correct copy of the NOTICE OF INTENT AND COUNTER- AFFIDAVIT was served, via certified mail, restricted delivery, return receipt requested, addressed to: Cynthia A. Yohe 800 York Road, Lot 103 Dover, Pa. 17315 DEFENDAN'I~ Respectfully Submitted: ~D. I~o. 79465 1 l~S, buth Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF -, P~t your n~e and add~ on the mve~ ~ t~ we ~ ~urn the ~ to you. a A~achthis~tothe~ckofthem~lpi~e, Reg~tefed F3 Return Receipt for Mem~endise Mall r'l C.O.D. 2. Article Number (Copy fr~n service ~beO ~ __ Ps Fo~ 3811, Ju~ 1999 ~tJc Ream R~ei~ BRIAN L. YOHE, Plaintiff' VS. CYNTHIA A. YOHE, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No. 01 - 1197 Civil Term : : ACTION 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 trader ~3301(d~ ofthe Divorce Code, 2. Date and manner of the service of the Complaint: Delivered by certified mail. restricted delivery, return receipt requested, delivered on: March 10. 2001. Affidavit of Service was filed March 13. 2001, 3. Date of execution of the affidavit required by §3301(d) of the Divorce Code: By Plaintiff.' June 24. 2001. Date of filing and service of the plaintiffs affidavit required by {}3301(d) of the Divorce Code on respondent: Filed: June 27. 2001. Served on Defendant: July 5. 2001. Affidavit of Service filed: July 10. 2001. 4. Related claims pending: None. 5. Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: Plaintiff's original notice of intent and counter-affidavit was served on Defendant on July 28. 2001. via certified mail. return receipt requested.: notice and affidavit of service attached. lm~ Adams, Esquire D. No. 79465 17 South Hanover St. 'arlisle, Pa. 17013 (717) 245-8508 Attorney for Plaintiff BRIAN L. YOHE, Plaintiff VS. CYNTHIA A. YOHE, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : No. 01 - 1197 Civil Term : : ACTION IN DIVORCE AFFIDAVIT OF SERVICE OF THE NOTICE TO DEFEND AND COMPLAINT AND NOW, this March 12, 2001, I, Jane Adams, Esquire, hereby certify that on March 10, 2001, a true and correct copy of the NOTICE TO DEFEND AND COMPLAINT were served, via certified mail, restricted delivery, return receipt requested, addressed to: Cynthia A. Yohe 800 York Road, Lot 103 Dover, Pa. 17315 DEFENDANT Respectfully Submitted: Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF c' · Comp~te items 1, 2, and 3. Also complete A. Received by (Ptease Print Clearly)___.,_ ,,~ ~-/[ B. Oate~f Oeliw[y 2. Article Number (Copy from service fabe0 PS Form 3811, July 1999 (~ Registered I-/Return Receipt ~r Memh~dise - J 1~6~ta. ge ~, Fees l~id ] ~ J ~rmit NO. ~18 BRIAN L. YOHE, Plaintiff VS. CYNTHIA A. YOHE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. O1 - 1197 Civil Term : : ACTION IN DIVORCE AFEIDAVIT OF SEPARATION 1. The parties to this action separated on June 10, 1999 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 my rights concerning alimony, division of property, lawyer's fees or expenses ifI do not claim them before a divorce is granted. I verify that the statements made in this affidavit are true and correct. 1 understand that false statements herein are made subject to the penalties of 18 Pa.C.S. {}4904 relating to unswom falsification to authorities. Date: ~///o~///~/ BRIAN L. YOHE, Plaimiff VS. CYNTHIA A. YOHE, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : No. 01 - 1197 Civil Term : : ACTION IN DIVORCE AFFIDAVIT OF SERVICE REGARDING PLAINTIFF'S AFFIDAVIT OF SEPARATION. AND NOW, this July 10, 2001, I, Jane Adams, Esquire, hereby certify that on July 5, 2001, a true and correct copy of the PLAINTIFF'S AFFIDAVIT OF SEPARATION, was served, via certified mail, restricted delivery, return receipt requested, addressed to: Cynthia A. Yohe 800 York Road, Lot 103 Dover, Pa. 17315 DEFENDANT Respectfully Submitted: dams'Esquire o°~ 7th94H62over St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF · Complete items 1,2, and 3. Nso complete item 4 if Restricted Delivery is desired. ~ print your name and eddreSS on the reverse so that we can return the card to you. =~ Attach this card to the back of the maitp[ece, or on the front if space permits. 1. Afficle AddreSsed to: Received by (Please print Clearly) Date of Detlvery Agent BRIAN L. YOHE, Plaintiff VS. CYNTHIA A. YOHE, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : No. 01 - 1197 Civil Term : : ACTION IN DIVORCE . NOTICE OF INTENT TO REQUEST ENTRY OF DIVORCE DECREE TO: Cynthia A. Yohe 800 York Road Lot 0103 Dover, Pa. L7315 DATE: July 26, 2001 You have been sued in an action for divorce. You have failed to answer the Complaint or file a Counter-Affidavit to the 3301(d) affidavit. Therefore, on or after August 15, 2001 the Plaintiff can request the Court to enter a final decree in divorce. If you do not file with the Prothonotary of the Court an answer with your signature notarized or verified or a Counter-Affidavit by the date above, the Court can enter a final decree in Divome. Unless you have already filed with the Court a written claim for economic relief, you must do so by the above date or the Court may grant the divorce and you lose forever the right to ask for economic relief. A COUNTER-AFFIDAVIT WHICH YOU MAY FILE WITH THE PROTHONOTARY OF THE COURT IS ATTACHED TO THIS NOTICE, Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of your counter-affidavit alone does not protect your economic claims. 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 (717) 249-3166 UNITED STATES POSTAL SERVICE , i First-Class Mail ~ Postage 8, Fees / usps ? '~ {~ Permit No. G.'~o .... "Sender.. Please print ~ ~ .... ' address, and ZIP+4 iR th*s box · BRIAN L. YOHE, Plaintiff VS. CYNTHIA A. YOHE, Defendant : 1N THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No. 01 - 1197 Civil Term ACTION IN DIVORCE AFFIDAVIT OF SERVICE REGARDING NOTICE OF INTENT AND COUNTER-AFFIDAVIT AND NOW, this August 21,2001, 1, Jane Adams, Esquire, hereby certify that on July 28, 2001, a tmc and correct copy of thc NOTICE OF INTENT AND COUNTER- AFFIDAVIT was served, via certified mail, restricted delivery, return receipt requested, addressed to: Cynthia A. Yohe 800 York Road, Lot 103 Dover, Pa. 17315 DEFENDANT Respectfully Submitted: Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF .m Prat your name ~nd address on the reverse ~//.~ ~ so t~t we can return the card to yo~. · Affach this ca~ to the back of the maiipiece, X it ,~ [ ,~ ~ ~. ~ ~ ~A~nt ~ On the front if space ~its. ~~ ~, ~ Add~ D. Isd~iv~a~diffem~t~ 17 ~ Yes 1. ~ic[e Ad, rased to: If YES, enter delive~ add~ ~w: ~ NO 2. Article Number (Copy from service label) o~ r:n~m :~811 ~ July 1999 3. Service Type --~ ~I~BIII~II~ (:3 Express Mail [] tnsurec[ Ma[i [] C.O.D. Domestic Return Receipt 102595-0~-M*D952 UNITED STATES POSTAL SERV~4CE ¢ First-Class'Mai~' i ' Postage & Fees Paid ~, USPS I Permit No G-10~ · Sender: Please print your name, address, and ZIP+4 in this box ' BRIAN L. YOHE, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 01 - 1197 CivilAction CYNTHIA A. YOHE, Defendant : ACTION IN DIVORCE MARRIAGE SETTLEMENT AGREEMENT THIS AGREEMENT, made this/7~r'~' dayof ~/_./~.,~'~. , ~,0,01, b,yand between, CYNTHIA A. YOHE, of Dover, York Co~n6j, Pennsylvania,hereinafter referred to as WIFE, and BRIAN L. YOHE, of New Cumberland, Cumberland County, Pennsylvania,hereinafter referred to as "HUSBAND". WITNESSETH: WHEREAS, Husband and Wife were lawfully married on July 13, 1991, in York County, Pennsylvania, and; WHEREAS, there were two children bom of this marriage; WHEREAS, differences, disputes, and difficulties have arisen between the parties and it is the intention of Husband and Wife to live separate and apart for the rest of their natural lives, and the parties desire to settle their respective financial property rights and obligations as between each other, including the settling of all matters between them relating to ownership and equitable distribution of real and personal property; the settling of all matters between them relating to the past, present, and future support, alimony, and/or maintenance of Husband or Wife; and in general, the settling of any and all possJble claims by one against the other or against their respective estates; NOW THEREFORE, Wife and Husband, each intending to be legally bound, hereby covenant and agree as follows: '1. FULL DISCLOSURE OF ASSETS. Each party warrants that he or she has made a full and fair disclosure of income, assets, and their valuation prior to the execution of this Agreement as well as any other fact relating in any way to the subject matter of this agreement. These disclosures are part of the consideration made by each party for entering into this agreement. 2. ADVICE OF COUNSEL. The Husband has employed and had the benefit or counsel of JANE ADAMS, ESQUIRE, as his attorney. The Wife is PRO SE. Each party has carefully and completely read this agreement and has been advised and is completely aware not only of its contents but of its legal effect. 3. SEPARATION. That the parties intend to maintain separate and permanent domiciles and to live apart from each other, it is the intention and purpose of this agreement to set forth their respective rights and duties while they continue to Jive apart from each other. Whereas a Complaint in Divorce was filed, both parties will agree to a No-Fault Divorce after the applicable ninety (90) day time period has run. 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 intention of the parties that such division shall be final and 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 asset~. 4. FREEDOM FROM INTERFERENCE. Further, the parties agree to continue living separately and apart from each other at any place or places that he or she may select. Neither party shall harass, annoy, injure, threaten, or interfere with the other party in any manner whatsoever. Each party may carry on and engage in any employment, profession, business or other activity as he or she may deem advisable for 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. SUBSEQUENT DIVORCE. The parties hereby acknowledge that Husband has filed a Complaint in Cumberland County, claiming that the marriage is irretrievably broken under the no-fault mutual consent provision of Section 3301(c) of the Pennsylvania Divome Code. Wife hereby expresses her agreement that the mardage is irretrievably broken and expresses her intent to execute any and all affidavits or other documents necessary for the parties to obtain an absolute divorce pursuant to Section 3301(c) of the Divorce Code. The parties hereby waive all rights to request Court Ordered counseling under the Divorce Code. It is further specifically understood and agreed by the parties that the provisions of this Agreement relating to equitable distribution of property of the parties are accepted by each party as a final settlement for all purposes whatsoever, as contemplated by the Pennsylvania Divorce Code. Should a decree, judgment, or order of separation or divorce be obtained by either of the parties in this or any other state, country or jurisdiction, each of the parties hereby consents and agrees that this Agreement and all of its covenants shall not be affected in any way by any such separation or divorce; and that nothing in any such decree, judgment, order, or further modification or revision thereof shall alter, amend, or vary any term of this Agreement, whether or not either or both of the parties shall remarry (it being understood by and between the parties hereto that this Agreement shall survive and shall not be merged into any decree, judgment, or order of separation.) It is specifically agreed, however, that a copy of this Agreement or the substance of the provisions thereof, may be incorporated by reference into any divorce, judgment, or decree. This incorporation, however, shall not be regarded as a merger, it being the specific intent of the parties to permit this Agreement to survive any judgment and to be forever binding and conclusive upon the parties. 6. DATE OF EXECUTION. The "date of execution" or "execution date" of this agreement shall be defined as the date upon which it Js executed by the parties 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. 7. DISTRIBUTION DATE. The transfer of property, funds, and/or documents provided for herein shall only take place on the "distribution date" which shall be defined as the date of execution of this Agreement unless otherwise specified herein. 8. MUTUAL RELEASE OF ALL CLAIMS. HUSBAND and WIFE each do hereby mutually remise; release, qqit-claim and forever discharge the other and the estate of the other, of and from any and all rights; titles, and interests, or claims in or against the property (including income and gain from property hereafter accruing) of the other or against the estate of such other, or whatever nature and wheresoever situate, which she or he now has or at any time hereafter may have against such other, the estate of such other or any part thereof, whether arising out of any former acts, contracts, engagements, or liabilities of such other or by way of dower or curtesy, or claims in the nature of dower or curtesy of widow's or widower's dghts, famiJy exemption or similar allowance, or under the intestate laws, or the right to take against the spouse's will; or the right to treat a lifetime conveyance by the other as testamentary, or all other rights of a surviving spouse to participate in the decease spouse's estate, whether adsing under the laws of Pennsylvania, any state, commonwealth, or territory of the United States, or any other country, or any rights which Wife may have or at any time hereafter have for past, present or future support or maintenance, alimony, alimony pendente lite, counsel fees, costs or expenses, whether arising as a result of any marital relation or otherwise, except, and only except, all rights and agreements and obligations of whatsoever nature arising or which may arise under this agreement or for the breach of any thereof. 9. WARRANTY OF DEBTS AND FUTURE OBLIGATIONS. Each party warrants represents that they have not contracted any debt or liability for the other or which the estate of the other party may be responsible or liable, and except only for the dghts arising out of this agreement, neither party will hereafter incur any liability whatsoever for which the other party or the estate of the other party, will be liable. Each party agrees to indemnify or hold harmless from and against all future obligations of every kind incurred by them, including those for necessities. t0. OUTSTANDING JOINT DEBTS. Husband agrees that he will pay off all debts relating to the couple's 1985 Shultz trailer. Wife shall retain possession of the trailer which is currently located at 800 York Road, Lot #103, Dover, Pa, 17315. Husband will transfer the title and all appropriate paperwork into Wife's name as soon as the trailer is paid off in full. The parties shall cooperate in executing any documents which may be required to effetuate this transfer. 11. DIVISION OF PERSONAL PROPERTY. Husband and Wife do hereby acknowledge that they have previously divided their tangible personal property including, but without limitation, jewelry, clothes, furniture, furnishings, rugs, carpets, household equipment and appliances, pictures, books, works of art, and other personal property. Except as may otherwise be provided in this Agreement, Wife agrees that all of the property of Husband or in his possession shall be the sole and separate property of Husband; and Husband agrees that all of the property of Wife or in her possession shall be the sole and separate property of Wife. The parties do hereby specifically wavier, release, renounce, and forever abandon whatever claim, if any, he or she may have with respect to the above items which shall become the sole and separate property of the other. 12. MOTOR VEHICLES. With respect to the motor vehicles, owned by one or both of the parties, they agree as follows: Each party shall retain full ownership in their respective vehicles. The titles to the said motor vehicles shall be executed by the parties, if appropriate for effecting transfer as herein provided, on the date of execution of this Agreement, and said executed titles shall be delivered to the proper parties on the distribution date. Each party agrees to be solely responsible for the amounts presently due and owing against his or her respective automobiles. 13. MUTUAL WAIVER OF EMPLOYMENT BENEFITS, The parties agree to waive any and all rights they have in and to each other's employment benefits, including but not limited to both parties pensions and retirement plans and incentive Savings Plans. The parties agree never to assume any claim to such benefits of the other at any time in the future. 14. ALIMONY, ALIMONY PENDENTE LITE and LEGAL FEES. Each party hereby waives any right to alimony pendente lite, and each party agrees to be responsible for his or her own legal fees and expenses. The parties herein acknowledge that by this Agreement, they have respectively secured and maintained a substantial and adequate fund with which to provide for themselves sufficient financial resources to provide for their comfort, maintenance, and support in the station of life to which they are accustomed. Wife and Husband do hereby waive, release, and give up any rights they may respectively have against the other for alimony, support, or maintenance, it shall be from the execution of this Agreement the sole responsibility of each of the respective parties to sustain themselves without seeking any support from the other party. have the right, at his or her election, to sue for damages for such breach, or seek other remedies or relief as may be available to him or her, and the party breaching this contract should be responsible for payment of legal fees and costs incurred by the other in enforcing their rights under this agreement. 25. INFORMED AND VOLUNTARY EXECUTION. Each party to this agreement acknowledges and declares that he or she is fully informed as to the facts relating to the subject matter of this agreement, is entering into this agreement voluntarily, free from fraud, undue influence, coercion or duress of any kind, has given careful thought to the making of this agreement, has carefully read each provision of this agreement, and fully and completely understands each provision of this agreement. IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the day and year first above written: WITNESS: Date: COMMONWEALTH OF PENNSYLVANIA COUNTY OF On this, the /~/ dayof personally appeared C ) ):SS ) ,2001, before me, the undersigned officer, known to me, (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he/she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. Pa~'icia A. Gordon, Not~r~ Public Palrview T,,,o., York County I( Notary Public My Comm~osp,~ ~-~'irc, "!ly 31, 2005 MemOer, Pennsyi~miaAssociationofNotales My commission expires: ? SEAL BRIAN L. YOHE Date: COMMONWEALTH OF PENNSYLVANIA ) ):SS same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. My commission expires: IN-THE COURT OF COMMON PLEAS OFCUMBERLAND COUNTY STATE OF ~,,,'i..a.~ L. ~ohe~ ~lalntiff VERSUS Cynthia A. Yohe, Defendant AND NOW, DECREED THAT AND NO. DECREE IN DIVORCE Briam L. Yehe Cynthia A. Yohe ARE DIVORCED FROM THE BONDS OF MATRIMONY. PENNA. O1 - 11~7 ~ivil Term , IT IS ORDERED AND , PLAINTIFF, , DEFENDANT, PROTHONOTARY I I I + + + ++++++ +++ + + + + + ++++++++ + 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;