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HomeMy WebLinkAbout04-3687 JEFFREY L. FUHRMAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW vs. NO. 04-3'-7 CIVIL TERM LAURIE A. FUHRMAN, Defendant 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 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, First Floor, Cumberland County Courthouse, Carlisle, Pennsylvania 17013. 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, P A 17013-3302 Telephone number: (717) 249-3166 Toll Free (in PAl 1-800-990-9108 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JEFFREY L. FUHRMAN, Plaintiff CIVIL ACTION -LAW : vs. NO. 04-JLP1CIVIL TERM LAURIE A. FUHRMAN, Defendant . . IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE PENNSYLVANIA DIVORCE CODE 1. Plaintiff is Jeffrey L. Fuhrman, who currently resides at 430 Crossroad School Road, Carlisle, Cumberland County, Pennsylvania 17013. since February 2002. 2. Derendant is Laurie A. Fuhrman, who currently resides at 430 Crossroad School Road, Carlisle, Cumberland County, Pennsylvania 17013. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing oftrus Complaint. 4. The plaintiff and derendant were married on October 16, 1982 at Carlisle, Cumberland County, Pennsylvania 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 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. Plaintiff requests the court to enter a decree of divorce. g~~~ David Patrick Perkins, Esquire Attorney for Plaintiff Attorney !D. No. 34342 4 James Circle Shippensburg, PA 17257-2165 Telephone: (717) 532-6629 I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. S 4904, relating to unsworn falsification to authorities 16 .-;:.. J Date: July 26,2004 ' 7 h ~ L.qruhrrllan, Plaintiff tu R + ~ '- - lI) ~ eN U) Ii" ~ -Q ......... '8 S ~ b ~ --ore nlr! ~"; ~,. :'-; ~.r~ r; c- "', ~ C,':) -<-- :-.:~ -~ ~ 'T.'.'.'@ ~r:r\ :l~J CT- 5:"~ ~~ :tJ ,-- c: r-"' ", CD o 0" ~,::i '1:...._. -::....J :...::;, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JEFFREY L. FUHRMAN, Plaintiff CIVIL ACTION -LAW vs. NO. 04 - ?ft;r/ CIVIL TERM LAURIE A. FUHRMAN, Defendant IN DIVORCE ACCEPTANCE OF SERVICE I Laurie A. Fuhrman accept service of the Complaint in Divorce in the above-captioned matter. Date: July cfi , 2004 '~A^ I' IQ. ~)1~^ WfuQ J I AURIE A. FUHRMAN Address: 430 Crossroad School Road Carlisle, PA 17013 COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF CUMBERLAND On this, the ~gtday of July, 2004, before me, the undersigned officer, a Notary Public in and for said County and State, personally appeared LAURIE A. FUHRMAN, known to me (or satisfactorily proven) to be the person whose name is subscribed to this Acceptance of Service, and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. " > ci 11"" Public --. t<<>TARl~. SEtIJ.. I JANIS l. JAi30. t,lI;:<lrj i'"JlJllc I C~,1ilk &~v, ')JrnborkiOO County '1 1':1 o.'ffim'itsloo !:.K~l1lllApriI7. 2007 \.{;..~""'{.l"~(a3li~. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JEFFREY L. FUHRMAN, Plaintiff : CIVIL ACTION -LAW VS. : NO. 04 - 3687 CIVIL TERM LAURIE A. FURHMAN Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under S 3301(c) of the Divorce Code was filed on July 28, 2004. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. Date: .:5 It) /0) 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. q 4904 relating to unsworn falsification to authorities. Jf/;L~ '''-..) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JEFFREY L. FUHRMAN, Plaintiff CIVIL ACTION -LAW vs. NO. 04 - 3687 CIVIL TERM LAURIE A. FUHRMAN, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER g3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. & 4904 relating to unsworn falsification to authorities. Date: s /;)!o~ ~/~L Jeffrey L. Fuhrman, Plaintiff ,. c IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JEFFREY L. FUHRMAN, Plaintiff : CIVIL ACTION -LAW vs. : NO. 04 - 3687 CIVIL TERM LAURIE A. FURHMAN Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under ~ 3301(c) of the Divorce Code was filed on July 28, 2004. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. & 4904 relating to unsworn falsification to authorities. Date:~ ~J) 0 e ~L\/Yy} G\- '\. ~ Laurie A. Furhman, Defendant i";j-." c.:; (,.;. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JEFFREY L. FUHRMAN, Plaintiff CIVIL ACTION -LAW VS. NO. 04 - 3687 CIVIL TERM LAURIE A. FUHRMAN, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 93301(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. Q 4904 relating to unsworn falsification to authorities. Date: ~\ \~\D$ Cl91A ~^Y O~l~jYYl~~ Laurie A. Fuhrman, Defendant (~-} C) 01 - 3 (p <6' 7 Page I of8 MARITAL AGREEMENT THIS AGREEMENT, made this l:l~day of May, 2005, by and between Jeffrey L. Fuhrman, hereinafter referred to as Husband, of 430 Crossroad School Road, Carlisle. Cumberland County, Pennsylvania, 17013, and Laurie A. Fuhrman, hereinafter referred to as Wife, of 2 South Second Street, Apartment D. DIllsburg, York County, Pennsylvania, 17019. WITNESSETH: WHEREAS, the parties hereto are Husband and Wife; and WHEREAS, diverse unhappy differences, disputes and difficulties have arisen between the parties and it is the intention of Wife and Husband to live separate and apart, and the parties hereto are desirous of settling some of their respective financial and property rights and obligations as between each other including, without limitation by specification: the equitable division of marital property; and the settling of all matters between them relating to the past, present and future support, alimony and lor maintenance of Wife by Husband or of Husband by Wife. NOW. THEREFORE, in consideration of the premises and of the mutual promises, covenants and under takings hereinafter set forth which are hereby acknowledged by each of thc parties hereto, Wife and Husband, each intending to be legally bound hereby, covenant and agree as follows: AGREEMENT NOT A BAR TO DIVORCE PROCEEDINGS This Agreement shall not be considered to affect or bar the right of Wife or Husband to a limited or absolute divorce on lawful grounds, if such grounds exist or shall hereafter exist or to such defense as may be available to either party. This Agreement is not intended to condone and shall not be deemed to be a condonation, on the part of either party hereto, of any act or acts on the part of the other party which have occasioned the disputes or unhappy differences which have occurred prior to or which may occur subsequent to the date hereof. The parties intend 10 secure a mutual consent, no-fault divorce pursuant to the terms of Section 3301(c) of the Pennsylvania Divorce Code of 1980, as amended. 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. AGREEMENT TO BE INCORPORATED IN DIVORCE DECREE The parties agree that the terms of this Agreement may be incorporated into any divorce decree, which may be entered with respect to them. Page 2 01'8 DATE OF EXECUTION The "date of execution" or "execution date" of the Agreement shall be defined as the date upon which it is 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. ADVICE OF COUNSEL The provisions of this Agreement and their legal effect have been fully explained to Jeffrey L. Fuhrman, husband, by David P. Perkins, Esquire, who is attorney for husband and who prepared this marital agreement. Wife acknowledges that she has been advised of her right to seek independent legal counsel and she has decided not to do so. Both parties acknowledge that they fully understand the facts and have been fully informed as to their legal rights and obligations and understand the same. The parties hereto further acknowledge and accept that this Agreement is, in the circumstances, fair and equitable and that it is being entered into freely and voluntarily after having received such advice and with such knowledge, and that execution of this Agreement is not the result of any duress or undue influence and that it is not the result of any collusion or improper or illegal agreement or agreements. PERSONAL RIGHTS Wife and Husband may and shall, at all times hereafter, live separate and apart. They shall be free from any control, restraint, interference or authority, direct or indirect, by the other in all respects as fully as if they were unmarried. They may reside at such place as they may select. Each may, for his or her separate use or benefit. conduct, carryon and engage in any business, occupation, profession or employment, which to him or her may seem advisable. Wife and Husband shall not molest, harass, disturb or malign each other or the respective families of each 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. SEPARATION DATE The parties do hereby acknowledge that they separated on June 30, 2004. It is hereby agreed that June 30, 2004, shall be the separation date for purposes of equitable distribution under the Pennsylvania Divorce Code unless altered by subsequent agreement of the parties in writing and signed by each of the parties. No attempt at reconciliation shall be considered to alter the separation date unless evidenced by written agreement. Page 3 of8 MOTOR VEHICLES A. The parties agree that Wife shall become the sole and exclusive owner of the parties' 1995 Chevrolet S 1 0 pickup truck. Wife shall be solely responsible for all payments owed to Norwest Consumer Loan Company for the automobile loan secured by the 1995 Chevrolet S I 0 pickup truck. B. The parties agree that Husband shall become the sole and exclusive owner of the parties' 1994 Ford Escort motor vehicle. The 1994 Ford Escort shall be free and clear of allleins and encumbrances. PERSONAL PROPERTY Husband and Wife do hereby acknowledge that they have previously divided their tangible personal property, including but not limited to jewelry, clothes, furniture, furnishings, rugs, carpets, household equipment and appliances, vehicles, pictures, books, works of art and other personal property and hereafter Wife agrees that all of the property in the possession of Husband shall be the sole and separate property of Husband and Husband agrees that all of the property in the possession of Wife shall be the sole and separate property of Wife. The parties do hereby specifically waive, release, renounce and forever abandon whatever claims, if any, he or she may have with respect to the above items, which shall become the sole and separate property of the other. AFTER-ACOUlRED PERSONAL PROPERTY Each of the parties shall hereafter own a;,d enjoy, independently of any claim or right of the other, all items of personal property. tangible or intangible, hereafter acquired by him or her, 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 not married. REAL EST A TE The parties hereto acknowledge and agree that they are owners of a single family residence known as 430 Crossroad School Road, Carlisle, Pennsylvania 17013 situate in West Pennsboro Township, and more specifically described in Cumberland County Deed Book 187 , at Page 613. For and in consideration of the mutual covenants and agreements herein contained in the body of this instrument, Husband and Wife further stipulate and agree that said real estate shall be retained by husband. In consideration 'of the mutual covenants and agreements herein contained in the body of this instrument, husband shall assume the first mortgage loan obligation secured by the residence in the original principal amount of One Hundred Twenty-Two Thousand Six Hundred ($122,600.00) Dollars dated September 9, 1999 and recorded in Cumberland County Mortgage Book 1569, Page 479, between Jeffrey L. Fuhrman and Laurie A. Fuhrman, Mortgagers and Accubanc Mortgage Corporation. Husband shall indemnify Wife and hold Wife harmless with respect to any and all payments owed to Accubanc Mortgage Corporation in connection with the parties mortgage obligation. Page 4 of8 WARRANTY AS TO EXISTING OBLIGATIONS Each party represents that he or she has 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 and 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 of this Agreement. WARRANTY AS TO FUTURE OBLIGATIONS Wife and Husband 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 the execution date of this Agreement, except as may be otherwise specifically provided for by the terms of this Agreement and that neither of them shall hereafter incur a liability whatsoever for which the estate of the other may be liable. LEGAL FEES Husband shall pay the cost of legal fees incurred in preparation of this marital agreement and all legal fees and court costs in connection with obtaining a 3301(c) No-Fault Divorce. Wife agrees to cooperate by executing the necessary consents and other documents required to effectuate said divorce, as requested by Husband's attorney. INCOME TAX RETURNS The parties agree to file joint income tax returns for federal and state income tax purposes. The parties agree that any and all refunds of federal and or state income tax payments shall be the sole and separate property of Husband. Wife hereby specifically waives, releases, renounces and forever abandons whatever claims, if any, she may have with respect to said income tax refunds. Husband has agreed to pay wife the full sum of two thousand dollars ($2,000.00) upon receipt of refunds of federal and or state income tax payments. Wife hereby acknowledges that she has received the agree upon sum of two thousand dollars ($2,000.00). STUDENT LOAN Wife shall assume sole responsibility for payment of Wife's student loans with PHEAA. Wife shall indemnify Husband and hold Husband harmless with respect to any and all payments owed to PHEAA in connection with Wife's student loan obligations. Page 5 of8 MUTUAL RELEASES Husband and Wife each do hereby mutually remise, release, quitclaim and forever discharge the other and the estate of each other, for all time to come, and for all purposes whatsoever, of and from any and all rights, title and interest, 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. of whatsoever nature and wheresoever 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 by way of dower, courtesy, or claims in the nature of dower or courtesy or widow's or widower's rights, family 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 a deceased spouse's estate, whether arising under the laws of (a) Pennsylvania, (b) any State. Commonwealth or territory of the United States, or (c) any other country, 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. It is the intention of Husband and Wife to give to each other by the execution of this 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. WAIVER OR MODIFICATION TO BE IN WRITING No modification or 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. DIVORCE The parties hereto agree to enter into a mutual consent divorce under Section 3301(c) of the Pennsylvania Divorce Code of 1980, as amended. Husband agrees to file a No-Fault Divorce action and to be the Plaintiff therein. Wife agrees to sign the necessary documents, including the Affidavit of Consent, at such time after the ninety (90) days of filing and service of the Complaint and further instruments that may be reasonably required to give full force and effect to the provisions of this Agreement. MUTUAL COOPERATION Each party shall, at any time and from time to time hereafter, take any and all steps and execute, acknowledge and deliver to the other party any and all future instruments and/or documents that the other party may reasonably require for the purpose of giving full force and effect to the provisions of this Agreement. Page 6 of8 LAW OF PENNSYLVANIA APPLICABLE This Agreement shall be construed in accordance with the laws of the Commonwealth of Pennsylvania. AGREEMENT BINDING ON HEIRS This Agreement shall be binding and shall insure to the benefit of the parties hereto and their respective heirs, executors, administrators, successors and assigns. BREACH If either party breaches any provision of this Agreement, the other party shall have the right, at his or her election, to sue for damages for such breach or seek such other remedies or relief as may be available to him or her, and the party breaching this contract shall be responsible for payment of legal fees and costs incurred by the other in enforcing their rights under this Agreement. WAIVER OF ALIMONY AND OTHER RIGHTS The parties hereto have been informed of their rights or have been advised to seek counsel to inform them oftheir rights under and pursuant to the Divorce Code, Action of April 2, 1980, Number 1980-26, as amended, particular::; the provisions for alimony, alimony pendente lite, equitable distribution of marital property, counsel fees or expenses. Both parties agree that this Agreement shall conclusively provide for the distribution of property under the said law and except as specifically provided for in this agreement, hereby waive, release and relinquish any further rights they may respectively have against the other for alimony, alimony pendente lite, equitable distribution of marital property, counsel fees or expenses. From the date hereof, each party may acquire either personal or real property in their own name. Any property so acquired shall be owned solely by the individual and shall not be subject to any claim whatsoever by the other party. FINANCIAL DISCLOSURE The parties confirm that they have relied on the substantial accuracy of the financial disclosure of the other as an inducement to the execution of this Agreement. ENTIRE AGREEMENT This Agreement constitutes the entire understanding of the parties and supersedes any and all prior agreements and negotiations between them. It is specifically agreed that this Marital Agreement supersedes, replaces, voids and nullifies a certain written marital agreement between the parties dated July 2004. There are no representations or warranties other than those expressly set forth herein. Page 7 of8 NO WAIVER OF DEFAULT This Agreement shall remain in full force and effect unless and until terminated under and pursuant to the terms of this Agreement. The failure of either 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 breach of any provision hereof be construed as a 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. 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 provisions 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 her or his obligations under anyone or more of the paragraphs herein, with the exception of the satisfaction of the conditions precedent, shall in no way void or alter the remaining obligations of the parties. HEADINGS NOT PART OF AGREEMENT Any headings preceding the text of the several paragraphs and subparagraphs hereof are inserted solely for convenience of reference and shall not constitute a part of this Agreement nor shall they affect its meaning, construction or effect. VOLUNTARY EXECUTION The provisions of this Agreement and their legal effect have been fully explained to the parties by their respective counsel, and each party acknowledges that the Agreement is fair and equitable, that it is being entered into voluntarily, and that it is not the result of any duress or undue influence. IN WITNESS WHEREOF, the parties hereto have set their hands and seals the day and year first above written. WITNESS: c;:;:;(~ G,(l~ J It /-1?j'-- je . Fuhrman c;;)~ C?~~ ,~ r, O.~::;t:Lrh .~ Laurie A. Fuhrman COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS. On this 12th day of May, 2005, before me, a notary public, the undersigned officer, personally appeared David P. Perkins, Esquire, Pennsylvania Supreme ID No. 34342, known to me or (satisfactorily proven) to be a member of the bar of the highest Court in said state and a subscribing witness to the within instrument, and certified that he was personally present when Jeffrey 1. Fuhrman whose name is subscribed to the within instrument executed the same, and that said person acknowledged that he executed the same for the purposes therein contained. IN WITNESS THEREOF, I hereunto set my hand and official seal. Ill':/, , 1{ 12 k . /, lc. M jA~. .. ilh vrLO NOlanal Seal J . Victoria N. Perkins. Notary Public SbJppensburg Boro, Cumberland County My Commission Expires OCL 15. 2006 Member, Pennsylvani? A<:'<:C~(3t!lr~ ~es COMMONWEALTH OF PENNSYL VANIA COUNTY OF CUMBERLAND SS. On this 16th day of May, 2005, before me, a notary public, the undersigned officer, personally appeared David P. Perkins, Esquire, Pennsylvania Supreme ID No. 34342, known to me or (satisfactorily proven) to be a member of the bar of the highest Court in said state and a subscribing witness to the within instrument, and certified that he was personally present when Laurie A. Fuhrman whose name is subscribed to the within instrument executed the same, and that said person acknowledged thal>he executed the same for the purposes therein contained. IN WITNESS THEREOF, 1 hereunto ~et my hand and official seal. ~FJ-M~. .-Po~#~ Notarial Seal Victoria N. Perkins. Notary Public Shippensburg Boro. Cumberland County My Commission Expires Oct. J 5. 2006 Member, PennsyrvaniaAssociationOfNotanes (' ~ .) -' ) f\.... ..<: , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA JEFFREY L. FUHRMAN, Plaintiff CIVIL ACTION -LAW vs. NO. 04 - 3687 CIVIL TERM LAURIE A. FUHRMAN, Defendant 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 under S3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: July 28, 2004, acceptance of service by Defendant. 3. Complete either paragraph (a) or (b). (a) Date of execution of the Affidavit of Consent required by S3301(c) of the Divorce Code: by Plaintiff on May 12,2005; by Defendant on May 16, 2005. (b)(I) Date of execution of the affidavit required by S300 1 (d) of the Divorce Code: ; (2) Date of filing and service of the Plaintiffs affidavit upon the "" t ,",\D.l"' ;,. \..\ "'- respondent: , 4. Related claims pending: None. Plaintiffs and Defendant's Marital Agreement . dated May 12, 2005 is hereby incorporated, but not merged, into this Decree in Divorce as a final Order of Court. 5. Complete either (a) or (b) (a) Date and manner of service of the notice of intention to file praecipe a copy of which is attached: \'I"'~<3-'f(' \ ;~'o\ 't (b) Date Plaintiffs Waiver of Notice was filed with the Prothonotary: May 18, 2005. Date Defendant's Waiver of Notice was filed with the Prothonotary: May 18, 2005. g~ U - GJv..\<J David P. Perkins, Esquire Attorney for Plaintiff -. rx..) '-::.~ "_.'1 :.:J j,");:.-- f....,; ---J (:J. G',I . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . '. . . . . .. . IN THE COURT OF COMMON PLEAS . , . . . . . OF CUMBERLAND COUNTY . . PEN NA. STATE OF . . JEFFREY L. FUHRMAN . . . . . No. Civil Term 04-3687 Plaintiff VERSUS . . T.IITTRTF: II 1"TTHRMIIN . Defendant . . . . DECREE IN DIVORCE . . . . . . . . . . . . . . . . . . . . AND NOW~~ JEFFREY L. FUHRMAN 2005 IT IS ORDERED AND DECREED THAT , PLAI NTI FF, LAURIE A. FUHRMAN AND , DEFENDANT, . . . ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF REC~R~ .T~S ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; ~ Plaintiff's and Defendant's Marital Aqreement dated . 2005 . is hereby incorporated, but not merged~to in Div a final Order of Courf. By THE OURT: in Of' Arrm~~ PROTHONOTARY . . 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