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HomeMy WebLinkAbout04-3618 LISA BRIDGE, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. No. JODY BRIDGE, Defendant CIVIL ACTION - LAW IN DIVORCE COMPLAINT FOR DIVORCE UNDER SECTION 3301(C) OR 3301(D) OF THE DIVORCE CODE AND NOW, comes the above-named Plaintiff, Lisa Bridge, by her attorney, Mark A. Mateya, Esquire, and seeks to obtain a Decree in Divorce from the above-named Defendant upon the grounds hereinafter more fully set forth. 1. Plaintiff is Lisa Bridge, and adult individual who currently resides at 5 Front Street, Boiling Springs, Cumberland County, PA 17007. 2. Defendant is Jody Bridge, an adult individual who currently resides at 5 Front Street, Boiling Springs, Cumberland County, PA 17007. 3. Plaintiff and Defendant are bona fide residents of the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on December 21, 1990 in Hagerstown, Maryland. 5. There have been no prior actions of divorce or for annulment of marriage between the Parties in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. Neither the Plaintiff nor the Defendant are members of the armed services of the United States or any of its allies. 8. Plaintiff has been advised that counseling is available and that plaintiff may have the right to request that the Court require the parties to participate in counseling. 9. Plaintiff requests the Court to enter a Decree of Divorce. Respectfully submitted, Dated 7f77-/6l( By: W-~A&- Mark A. M~~~~:r- Attorney I.D. No. 78931 P.O. Box 127 Boiling Springs, PA 17007 (717) 241-6500 Attorney for Plaintiff VERIFICATION I, Lisa Bridge, verify that the facts set forth in the foregoing Complaint for Divorce are true and correct to the best of my knowledge, information, and belief. I understand that false statements herein are subject to the penalties of 18 Pa. C.S. 5 4094, relating to unsworn falsification to authorities. DATED: 7- JS-Olf ----- lrisa' o{Q. fJ - ~ rs ~ it-.l. . .... \'- CJ t1 ~ v rn p:: Jt 12 ~ '-'-' e'l I ~ LISA BRIDGE, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 04-3618 CIVIL TERM JODY BRIDGE, Defendant : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF SERVICE AND NOW, this 6th day of AUllliSt. 2004, comes Mark A. Mateya, Esquire, Attorney for Plaintiff, who, being duly sworn according to law, deposes and says that: I. A Complaint for Divorce was filed to the above term and number on July 23, 2004. 2. On August 3, 2004, a certified copy of the Complaint in Divorce was sent to the Defendant via certified mail, restricted delivery, return receipt requested pursuant to Pa. R.C.P. 1920.4. A copy of the Certified Mail Receipt is attached hereto as Exhibit "A" and is incorporated herein. 3. On August 3, 2004, a certified copy of the Complaint was set to the Defendant via first class mail, postage prepaid. A copy of the Certificate of Mailing is attached hereto as Exhibit 'B' and is incorporated herein by reference. , 4. On or about August 6, 2004, undersigned counsel for Plaintiff received the Certified Mail Return Receipt which had been previously sent to the Defendant which was signed by the Defendant on August 5, 2004. A copy of the Return Receipt (green card) indicating the delivery of the Certified Mail is attached hereto as Exhibit "A" and is incorporated herein by reference. Respectfully submitted, \v.lCt. ~ Mark A. Mateya, Esquire Attorney LD. No. 78931 P.O. Box 127 Boiling Springs, P A 17007 (717) 241-6500 (717) 241-3099 Fax Attorney for Plaintiff rn 3" ru I'- U.S. Postal Service"" CERTIFIED MAIL. RECEIPT (DomestIc Mail Only; No Insurance Covera e Provided) 3" ru rn ru USE ~ noo;- , ~~~.. 05 ..... ~ 1Pfk, '"' \:>. \,c;-#,~.,,<, 08)tJ.~.\\' C.""'ed Fee ~$JgfJ) tr?3' ~~ Total Postag.. Fee. $ , ~ rn C t OJ(b t3 ~ s;;,;,;i.APr:'i--y.--"r~.!J2'~~h""h"'__'__'''''''''__'__'''', :;itY;":~'';;;''4-t~iIj.g-z'ff),,~A'J?!:..'';TDTB--'~'~~~~~~ . . HI II 3" C C I:J Retum Reclept Fee (Endorsement Required) c::J Restricted Delivery Fee Cl (Endorsement ReqUIred) LtJ C . Complete ~ems 1, 2, end 3. Also complete ~om 4 ~ Restricted Delivery Is desired. . Print your name 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: o Agent o Add_ C. Date of Delivery e-s--c'( D. Is delivery different from item 1? 0 Yes If YES, enter delivery address below: 0 No :JObt "'Be fPGE ..to/, milA l s j) ~ CAtLISL~ P4 J7()/3 3. Service Type Jl( Certified Mail 0 Express Mail o Registered 0 Return Receipt for Merchancn.. o Insured Mail 0 C.O.D. 4. Resllictad Delivery? {E>ctnI Fw),i!! 2. Article Number (Tn",.ferf,"",servlc.~) '1003 0500 OOO~ A3.GI~ '7tRJ./,5 PS Form 3811, August 2001 Domestic Return Receipt 102595-01.M-25OQ EXHIBIT "A" U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE useD FOR DOMESTIC AND INTERNATIONAL MAll, DOES NOl. PROVIDE FOR INSURANCE-POSTMASTER Received From: '-frJ1/~t< 4. '-rYJATEfA', ES~, PO. 13dX /:;.1 'BoILING- :5PR I AlGs, PA J'7oo1 One piece of ordinary mail addressed to: JCfDV ?, f. fD G E J.o~ mEALS DR. CA~LI5LG PA J'10J3 PS Form 3817, Mar. 1989 EXHIBIT "B" o :5~ =~ .... oot.C bc::l '" o o o o gOI ! .' "~ ~! u ~" 00 o ~ r c: H :DC") Z l 3: _C')"'O. oo-....J :D c::WO(/)- z~ o"'Oc; -1o-...J:D ' o H ... % '" V> " ~ '-- ;;:' -orr rl1 rr :;::-.:::r -."r- u"1;:. -......"': ,<I:- 12:( >:~ ;.{ .,,-,~ c::. ,=.:, C;:J ","J . MARJUAGESETTLEMENTAGREEMENT AGREEMENT made this -1.(~ day of Januarv ,2005, by and between JODY BRIDGE (hereinafter called "Husband") and LISA BRIDGE (hereinafter called "Wife"). WIT NE S SE T H: WHEREAS, the Parties hereto are Husband and Wife, having been married on December 21, 1990, in Hagerstown, Maryland. WHEREAS, diverse unhappy 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 hereto are desirous of settling fully and finally the respective financial and property rights and obligations as between each other, including without limitation: 1. The settling of all matters between them relating to ownership and equitable distribution of real and personal property; 2. The settling of all matters between them relating to past, present and future support, alimony and/or maintenance of Husband by Wife or Wife by Husband; . ; . . 3. In general, the settling of any and all claims and possible claims by one against the other or against their respective estates. NOW THEREFORE, in consideration of the premises and of the mutual promises, covenants and undertakings hereinafter set forth and for other good and valuable consideration, receipt of which is hereby acknowledged by each of the Parties hereto, Husband and Wife, each intending to be legally bound hereby, covenant and agree as follows: 1. AGREEMENT NOT PREDICATED UPON DIVORCE: It is specifically understood and agreed by and between the Parties hereto, and each ofthe Parties does hereby warrant and represent to the other that the execution and delivery of this Agreement is not predicated upon nor made subject to any Agreement for the institution, prosecution, defense or for the non- prosecution or non-defense of any action for divorce; provided, however, that nothing contained in this Agreement shall prevent or preclude either of the Parties hereto from commencing, instituting or prosecuting any action or actions for divorce, either absolute or otherwise, upon just, legal and proper grounds, nor to prevent either party from defending any such action which may, has been, or shall be instituted by the other Party, or from making any just or proper defense thereto. 2. EFFECT OF DIVORCE DECREE: The Parties agree that unless otherwise specifically provided herein, this Agreement shall continue in full force and effect after such time as a final decree in divorce may be entered with respect to the Parties. 2 .. . . 3. AGREEMENT TO BE INCORPORATED INTO DIVORCE DECREE: The Parties agree that the terms ofthis Agreement shall be incorporated but not merged into any Divorce Decree which may be entered with respect to them. 4. ADVICE OF COUNSEL: The provisions of this Agreement are intended to effect a legally binding property settlement between the parties. Husband has represented himself, choosing not to be represented by counsel, and Wife has been represented Mark A. Mateya. Each party acknowledges that he or she fully understands the facts and has been fully informed as to his or her legal rights and obligations, and each party acknowledges and accepts that this Agreement is fair and equitable, that it is being entered into freely and voluntarily and that this Agreement and the execution thereof is not the result of any duress, undue influence or collusion. 5. INTERFERENCE: Each party shall be free from all control, restraint, interference or authority, direct or indirect, by thl: other in all respects as fully as if he or she were unmarried. Each may reside at such place or places as he or she may select. Each may, for his or her separate use or benefit, conduct, carry on or engage in any business, occupation, profession or employment which to him or her may seem advisable. This provision shall not be taken, however, to be an admission on the part of either Husband or Wife of the lawfulness of the causes which led to, or resulted in, the continuation of their living apart. Husband and Wife shall not molest, harass, disturb or malign each other or the respective families of each other, nor in any way interfere with the peaceful existence, separate and apart from the other, nor compel or attempt to compel the other to cohabit or dwell by any means or in any manner whatsoever with him or her. 3 , ... . . 6. MUTUAL RELEASE: Husband and Wife each do hereby mutually remise, release, quit claim, and forever discharge the other in the estate of such other, for all time to come, and for all purposes whatsoever, 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) ofthe other or against the estate of such other, or whatever nature and whatsoever situate, which he or she 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 byway of dower or courtesy, or widows or widowers rights, family exemptions 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 a deceased spouse's estate, whether arising under the laws of Pennsylvania, any state, commonwealth or territory or the United States, or any other country, or any right which Wife may have or at any time hereafter have for past, present or future SUPPOlt of maintenance, alimony, alimony pendente lite, counsel fees, costs or expenses, whether arising as a result of the 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. It is the intention of Husband and Wife to give each other, by the execution ofthis Agreement, a full, complete and general release with respect to any and all property of any kind or nature, real, personal or mixed, which the other now owns or may hereafter acquire, 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 provision thereof. 4 . . . 7. DISCLOSURE AND WAIVER 0 F PROCEDURAL RIGHTS: Each party understands that he or she has the right to obtain from the other party a complete inventory or list of all ofthe property that either or both parties own at this time or owned as of the date of separation, and that each party has the right to have all such property valued by means of appraisals or otherwise. Both parties understand that they have the right to have a court hold hearings and make decisions on the matters covered by this Agreement. Both parties understand that a court decision concerning the parties' respective rights and obligations might be different from the provisions of this Agreement. Each party hereby acknowledges that this Agreement is fair and equitable, that is adequately provides for his or her needs and is in his or her best interests, and that the Agreement is not the result of any fraud, duress, or undue influence exercised by either party upon the other or by any other person or persons upon either party. Both parties hereby waive the following procedural rights: a. The right to obtain an inventory and appraisement of all marital and non- marital property as defined by the Pennsylvania Divorce Code. b. The right to obtain an income and expense statement of the other party as provided by the Pennsylvania Divorce Code. c. The right to have property identified and appraised. d. The right to discovery as provided by the Pennsylvania Rules of Civil Procedure. e. The right to have the court determine which property is marital and which is non-marital, and equitably distribute between the parties that property which the court determines 5 .. . . to be marital, and to set aside to either party that property which the court determines to be the parties' non-marital property. f. The right to have the court decide any other rights, remedies, privileges, or obligations covered by this Agreement and/or arising out of the marital relationship, including but not limited to possible claims for divorce, child or spousal support, alimony, alimony pendente lite (temporary alimony), equitable distribution, debt allocation, and counsel fees, costs and expenses. 8. REAL PROPERTY: Wife and Husband hold title as Tenants by the Entireties to the premises identified as 5 Front Street, Boiling Springs, Cumberland County, Pennsylvania (hereinafter "The Premises"). The parties agree as follows with respect to The Premises: a. On the date ofthe execution of this Agreement Husband shall deliver to Wife a Quit Claim Deed, conveying to Wife all of his rights, title, claim and interest in the Premises, subject to a mortgage presently in both Wife and Husband's name, and an assignment of all tax, insurance and other escrows with respect thereto, if any and an assignment in his interest in the proceeds payable under the homeowners insurance which currently insures the Premises. Upon receipt of the Deed, Wife shall be permitted to record it and take any other action with respect thereto that she deems appropriate. The parties agree that Wife shall be solely responsible for any and all real estate taxes attached to the Premises. The said conveyance shall be free and clear of all liens and encumbrances except for the first mortgage. From the date ofthe execution ofthis Agreement, Wife shall be solely responsible for all past, present and future costs, expenses, or liabilities attributable and/or resulting from ownership of The Premises, or by reason of Husband's former ownership thereof, and associated with maintaining the premises, including but not limited to all mortgage payments, real 6 . . estate taxes, water and sewer rents, gas, electric and telephone service, homeowners insurance, gardening expenses, minor and major repairs, and routine maintenance. Wife agrees to assume full responsibility of the mortgage attached to The Premises, which mortgage is presently held by Members First/Sun Trust Mortgage Company. 9. PERSONAL PROPERTY: Husband and Wife do hereby acknowledge that they have satisfactorily divided the marital property, including but not limited to those items listed below, as of the date ofthis Agreement, induding, but without limitation, jewelry, clothes, furniture and other personalty and hereafter Husband agrees that all the property in the possession of Wife on the date ofthis Agreement shall be the sole, separate property ofthe Wife; Husband further agrees that all household furnishings are the property of Wife; Wife agrees that all of the property in the possession of the Husband on the date of this Agreement shall be the sole, separate property of Husband. By these presents, each of the Parties does hereby specifically waive, release, renounce and forever abandon whatever claims he or she may have with respect to any of the above-items which are the sole and separate property of the other from the date of execution hereof. A) Vehicles: Husband shall retain the 1991 Explorer and the 1997 Kawasaki Vulcan 1500 Classic. Wife shall retain the 1984 Nissan Stanze and the 1986 Kawasaki 454 LTD. B) Vacation Vehicle: Husband shall retain ownership ofthe Motor Home which he currently owns jointly with R. Paxton. 7 . . 10. AFTER-ACOUlRED PERSONAL PROPERTY: Each of the Parties shall hereinafter own and enjoy, independently of any claim or right of the other, all items of personal property, tangible or intangible, acquired by him or her after July I, 2004, with full power in him or her to dispose of the same as fully and effectively, in all respects and for all purposes, as though he or she were unmarried. 11. APPLICABILITY OF TAX LAW TO PROPERTY TRANSFERS: The parties hereby agree and express their intent that any transfer of property pursuant to this Agreement shall be within the scope and applicability of the Deficit Reduction Act of 1984 (hereinafter the "Act"), specifically, the provisions of said Act pertaining to the transfers of property between spouses and former spouses. The parties agree to sign and cause to be filed any elections or other documents required by the Internal Revenue Service to render the Act applicable to the transfers set forth in this Agreement without recognition of gain on such transfer and subject to the carry-over basis provisions of the said Act. 12. LIABILITIES: During the course ofthe marriage, Wife and Husband have incurred certain bills and obligations. Each party warrants to the other that there are no joint debts. Any and all obligation relating to or flowing form ownership of the Real Property, as mentioned more fully in paragraph eight herein, is the sole responsibility of Wife . It is further agreed that the parties shall be responsible for the debts that each has separately incurred since July 1, 2004. 8 " . . 13. WARRANTY AS TO EXISTING OBLIGATIONS: Each Party represents that they have not heretofore incurred or contracted for any debt or liability or obligation for which the estate of the other Party may be responsible or liable except as may be provided for in this Agreement. Each Party agrees to indemnify or hold the other Party harmless from and against any and all such debts, liabilities or obligations of every kind which may have heretofore been incurred by them, including those for necessities, except for the obligations arising out ofthis Agreement. 14. WARRANTY AS TO FUTURE OBLIGATIONS: Husband and Wife each covenant, warrant, represent and agree that each will now and at all times hereafter save harmless and keep the other indemnified from all debts, charges and liabilities incurred by the other after July 1, 2004, except as may be otherwis(~ specifically provided for by the terms of this Agreement and that neither of them shall hereafter incur any liability whatsoever of which the estate ofthe other may be liable. Husband agrees to retain health insurance ofthe same or similar type as was held by him on July 1,2004, the date of separation, for the benefit ofKara L. Bridge until she reaches eighteen (18) years of age. Husband and Wife each agree and covenant that they will share any and all child rearing expenses equally. 15. WAIVER OF ALIMONY. SUPPORT AND MAINTENANCE: Husband and Wife do hereby waive, release, and give up any rights they may respectfully have against the other for alimony, support, or maintenance. It shall be from the date of this Agreement the sole 9 " . . responsibility of each of the respective parties to sustain themselves without seeking any support from the other party. The parties hereby acknowledge that by this Agreement each has respectfully secured and maintained a substantial and adequate fund with which to provide themselves sufficient financial resources to provide for their comfort, maintenance and support in the station of life to which they are accustomed. 16. PENSION. RETIID:MENT. PROFIT-SHARING. Husband and Wife agree to relinquish any and all rights to execute Qualified Domestic Relations Orders relating to their spouse's resp(lctive pensions. Husband agrees to waive, relinquish or transfer any and all of his right, title and interest he has or may have in Wife's pension through her present or prior employment. Husband hereby waives, relinquishes and transfers any and all right, title and interest he has in any present retirement account, as well as other accounts that Wife may have in her individual name or may have secured through her present or prior employment. Wife agrees to waive, relinquish or transfer any and all of his right, title and interest she has or may have in Husband's pension through his present or prior employment. Wife hereby waives, relinquishes and transfers any and all right, title and interest she has in any present retirement account, as well as other accounts that Husband may have in his individual name or may have secured through his present or prior employment. 16. CUSTODY: Husband and Wife will share legal and physical custody oftheir daughter Kara L. Bridge, born June 16,1991 (hereinafter "Child"). Physical custody of the Child 10 '. . . will be shared evenly, with Mother having physical custody of the Child during the first week and Father having physical custody of the Child the second week, continuing thereafter in the same manner. Custodial exchange shall occur each week at 6:00 PM. The parent gaining custody shall provide transportation. Both Father and Mother shall have reasonable telephone contact with the Child while in the custody ofthe other parent. There shall be no holiday schedule. This agreement may be amended by the agreement of both parties. A condition precedent to this Custody agreement is Husband remaining in South Middleton Township until such time as Child has graduated from high school. 17. CLAIM AS THE CHILD AS A DEPENDANT: For every year which husband or wife are entitled to claim child as a dependent, wife shall claim child as a dependent for federal and state income tax purposes during even numbered years and husband shall claim child as a dependent for federal and state income tax purposes during odd numbered years. 18. OTHER DOCUMENTATION: Wife and Husband covenant and agree that they will forthwith (and within at least thirty (30) days for demand therefore) execute any and all other written instruments, assignments, releases, satisfactions, deeds, notes or other such writings as may be necessary or desirable for the proper effectuation of this Agreement in order to carry out fully and effectively the terms ofthis Agreement. 19. FULL DISCLOSURE: Each party asserts that he or she has made a full and complete disclosure of all of the real and personal property of whatsoever nature and wherever located belonging in any way to either or both of them, of all the debts and encumbrances incurred 11 " . . in any manner whatsoever by either or both ofthem during the marriage, of all sources and amounts of income of each party, and of every 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 in this Agreement. 20. BANKRUPTCY: The parties hereby agree that the provisions of this Agreement shall not be dischargeable in bankruptcy and expressly agree to reaffirm any and all obligations contained herein. In the event a party files such bankruptcy and pursuant thereto obtains a discharge of any obligations assumed hereunder, the other party shall have the right to terminate this Agreement in which event the division of the parties' marital assets and all other rights determined by this Agreement shall be subject to court determination the same as if this Agreement had never been entered into. 21. FEES. COSTS AND EXPENSES: Each party agrees to be solely responsible for her and his respective counsel fees, costs and expenses in negotiating and concluding this Agreement, dissolving their marriage and consummating all provisions of this Agreement. 22. ENTIRE AGREEMENT: This Agreement contains the entire understanding between the Parties. There are no representations, warranties, covenants or undertakings other than as expressly set forth herein. 12 '. . . 23. WAIVER OR MODIFICATION TO BE IN WRITING: No modification nor waiver of any of the terms hereof shall be valid unless in writing and signed by both Parties and no waiver of any breach hereof or default hereunder shall be deemed a waiver of any subsequent default of the same or similar nature. 24. LAW OF PENNSYL VANIA APPLICABLE: This Agreement shall be construed in accordance with the laws ofthe Commonwealth of Pennsylvania. 25. AGREEMENT BINDING ON HEIRS: This Agreement shall be binding and shall inure to the benefit of the Parties hereto and their respective heirs, executors, administrators, successors and assigns. 26. SEVERABILITY: If any term, condition, clause or provision of this Agreement shall be determined or declared to be void or invalid in law or otherwise, then only that term, condition, clause or provision shall be stricken from this Agreement and in all other respects this Agreement shall be valid and continue in full force, effect and operation. Likewise, the failure of any Party to meet his or her obligations under anyone or more of the paragraphs herein with the exception of the satisfaction ofthe conditions precedent, shall in no way void or alter the remaining obligations of the Parties. 27. NOWAlVEROFDEFAULT: This Agreement shall remain in full force and effect unless and until terminated under and pursuant to the terms ofthis Agreement. The failure of either 13 , , ' . . party to insist upon strict performance of any of the provisions of this Agreement shall in no way affect the right of such party hereafter to enforce the same, nor shall the waiver of any subsequent default of the same or similar nature:, nor shall it be construed as a waiver of strict performance of any other obligations herein. 28. BREACH: If for any reason either Husband or Wife fails to perform his or her obligations hereunder to the other spouse, and the other spouse incurs any expense hereby (including but not limited to legal fees and costs) in enforcing his or her rights, the non-breaching party shall have the right, at his or her election, to sue in law or in equity to enforce any rights and remedies which the party may have and the spouse who failed to perform the obligations agrees to indemnifY THIS SP ACE INTENTIONALLY LEFT BLANK 14 , . ... . . the other spouse and hold him or her harmless from any and all such expenses. 29. HEADINGS NOT PART OF AGREEMENT: Any headings preceding the text of the several paragraphs and subparagraphs hereof are inserted solely for the convenience of reference and shall not constitute a part of this Agreement nor shall they effect its meaning, construction or effect. IN WITNESS WHEREOF, the Parties hereto have set their hands and seals the day and year first above-written. WITNESS: ~~ - (SEAL) LisaJlridge ~~ (SEAL) 15 , ' ' , . . COMMONWEALTH OF PENNSYLVANIA : SS. COUNTY OF CUMBERLAND On this, the -5- day of C::bto bif 2004, before me, a Notary Public in and for said Commonwealth and County, personally appeared lODY BRIDGE, known to me (or satisfactorily proven) to be the person whose natn<: is subscribed to the within Agreement, and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. My Commission Expires: 4cu. <PC~;;J1A':UVYlU)~ No a Publi (1' IO'}005 , ,~()~lM!)NW8\Lit-L ()f ,'iCNNSYlVANIA '1 NOTARIAL SEAL JACQUEliNE ~L WORLEY. Nolary PlilIic I Boro 01 CllI1iskl, _ Cunlll9r1and County , My Comm_ f~",. JIn. 10, 2005 __C_""''''.''' ,_,,",_...-_ (SEAL) COMMONWEALTH OF PENNSYLVANIA DA 'U {lflJ,.V y~~ : SS. COUNTY OF eUMBRF~ <U-ID On this, the 1f-1Jday Of~, 2004, before me, a Notary Public in and for said Commonwealth and County, personally appeared LISA BRIDGE, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Agreement, and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. cJuxt1.J O. tLmJ&u Notary Public My Commission Expires: (SEAL) Notarial Seal Frances A. Aumiller, Notary Public City of Harrisburg, Dauphin County My Commission Expires Mar. 16, 2006 Member PMnsvlvania Association otNotarieS 16 , . . . SCHEDULE "A" Wife's Personal Property Any and all personal property presently in Wife's possession. 17 .. . ,.-; . SCHEDULE "B" Husband's Personal ProDertv Any and all personal property presently in Husband's possession. 18 . , . lit(. . ~ . SCHEDULE"C" Wife's Liabilities Any and all debts incurred after July I, 2004. 19 ,. ..t - . SCHEDULE"D" Husband's Liabilities Any and all debts incurred after July 1, 2004. 20 - . :-{i __+l -i! )' '; ;~ .'- LISA BRIDGE, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 04-3618 CIVIL TERM JODY BRIDGE, Defendant : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT I. A Complaint in Divorce under Section 3301( c) or (d) of the Divorce Code was filed on July 23, 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 in divorce after service of notice of intention to request entry ofthe 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. 94904 relating to unsworn falsification to authorities. DATED: ..., ) - C- / - C DO ~ )3{~/~ Lita Bridge Plaintiff ...~ ---- . r.~" T n"~ C,) :.~J .< LISA BRIDGE, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 04-3618 CIVIL TERM JODY BRIDGE, Defendant : CIVIL ACTION - LAW : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST 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. 9 4904 relating to unsworn falsification to authorities. DATE 'J /1 -, " - "---I - cOO jo ~~-c- 0?r Lis'a' Bridge 17 ~ Plaintiff -.. , , -:of; ;1 ,_~.",.d LISA BRIDGE, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 04-3618 CIVIL TERM JODY BRIDGE, Defendant : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301( c) or (d) ofthe Divorce Code was filed on July 23,2004. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service ofthe Complaint. 3. I consent to the entryofa 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. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. g4904 relating to unsworn falsification to authorities. DATED: 31~lcl" ~~~/ ~U1"- M'dy Brid e l'nefendant ('.--) r::;:::l C':.',' 0..:-,,-. (.) -'n ::;:1 ~'ii r:~) ., :.J :-:r::: ~... .< - LISA BRIDGE, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 04-3618 CIVIL TERM JODY BRIDGE, Defendant : CIVIL ACTION - LAW : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER IS 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 in 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 ofthe 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. 9 4904 relating to unsworn falsification to authorities. DATE 3[~t;b.) {)"(.c A:f~6~ efendant t".....} f;-. ",=.w..~ - LISA BRIDGE, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 04-3618 CIVIL TERM JODY BRIDGE, Defendant : CIVIL ACTION - LAW : IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a divorce decree: I. Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: By certified mail on August 3, 2004. 3. Complete either paragraph (a) or (b): (a) Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by Plaintiff March 21. 2006 by Defendant March 22. 2006 (b)(1) Date of execution of the Plaintiffs affidavit required by Section 3301(d) of the Divorce Code: (2) Date of service ofthe Plaintiffs affidavit upon the Defendant: 4. Related claims pending: None 5. (a) Date and manner of service ofthe notice of intention to file praecipe to transmit record, a copy of which is attached: (b) Date plaintiffs Waiver of Notice in 9330I(c) Divorce was filed with the prothonotary: simultaneouslv herewith. t Date defendant's Waiver of Notice in 9330I(c) Divorce was filed with the prothonotary: simultaneouslv herewith. Each party has filed 11 Waiver of the Notice ofIntention to Request Entry of A Divorce Decree. , . I c \ r k" i (,c. " !' \vlh' . ~ \..kib Mark A. Mateya, ~uire P.O. Box 127 Boiling Springs, PA 17007 (717) 241-6500 Attorney for Plaintiff .." :-i; . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ~~~ ~~~~~~~~~~~+++++++.+.~+.+++.+++.++.++.+++.+.++.+. ++.+++++++++. +++++++++++++++++~ . . IN THE COURT OF COMMON PLEAS : . OFCUMBERLANDCOUNTY : . . . . STATE OF PENNA. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Settlement Agreement entered into by and between . . . is incorporated but not merged into the Divorce Decre Lisa Bridge, Pliantiff VERSUS Jody Bridge, Defendant AND NOW, No. 3618 7.004 DECREE IN DIVORCE tWr, \. \1 ~ ~, IT IS ORDERED AND DECREED THAT Lisa Bridqe AND Jody Bridge . PLAINTIFF, , DEFENDANT. ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE YET BEEN ENTERED; BEEN RAISED OF RECORD IN THIS ACTION \lJo~ The Marriage the parties . . . . . . . . . . . . . . . . . . . . . . ~+++++++ ++++. ++++++++++++++++++++++++. FOR WHICH A FINAL ORDER HAS NOT / . . . . . . . . . . . . J. . . . . . . . PROTHONOTARY . . . . ++++++++++++++++++++++++++++++++++ 'f +. +. +. +. frk't[/ - t.'/ 7- '~pW ~1 ~_.: Ir- . hZ /7(/??W.. 77. ''iL Jc/ L /7 >~"W pz /Y'"- .~l ,;:"iJ ":J i h .