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HomeMy WebLinkAbout04-3740 SHA WNA M. MEYER, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA v. NO. 01../ - 3'1I..fD (lILH'L 18VY\ CHRISTOPHER D. MEYER, DEFENDANT CNIL ACTION - DNORCE NOTTCR TO DRFRNI) ANI) Cl ,A 1M RIQHTS 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 ofthe Prothonotary, 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LA WYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing of business before the Court. SHA WNA M. MEYER, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA v. NO. Ol{ -j'740 C;Q; L L-~ CHRISTOPHER D. MEYER, DEFENDANT CNIL ACTION - DNORCE COMPLATNT TTNDF.R SF:CTTON :BOl(c) OR ~~Ol(d) OF THF, mVORCF. CODF. TO THE HONORABLE, THE JUDGES OF SAID COURT: AND NOW, comes Plaintif!~ Shawna M. Meyer, by and through her attorneys, SMIGEL, ANDERSON & SACKS, and represents as follows: COTTNTT .mVORCR TTNDF.R SF.CTTON ~~Ol(c) OR :B01(d) OF THF. mVORCR CODE 1. Plaintiff is Shawna M. Meyer, who currently resides at 2 I 08 Cedar Run Drive #305, Camp Hill, Cumberland County, Pennsylvania and has resided there since on or about July 1,2004. 2. Plaintiff's Social Security No. is 165-68-5639. 3. Defendant is Christopher D. Meyer, who currently resides at 57 Rose of Sharon Drive, Etters, York County, PeJllisy]vania and has resided there since on or about November 2001. 4. Defendant's Social Security No. is 173-68-3921. 5. Both Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. ---~._--,-~,~-~...~ 6. The Plaintiff and Defendant were mamed on September 17, 1999, at Dauphin County, Pennsylvania. 7. There have been no prior actions of divorce or for annulment between the parties. 8. The marriage is irretrievably broken. 9. 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. 10. Plaintiff avers that there is one child of the patiies under the age of 18, namely: Leanne Elizabeth Meyer, born January 18, 2002. WHEREFORE, Plaintiff requests the court to enter a decree of divorce. SMIGEL, ANDERSON & SACKS Date: ? /' )(,~ ~)'f BY~ tJ~ Ann V. Levin, Esquire J.D. #: 70259 James R. Demmel, Esquire J.D. #: 90918 4431 North Front Street Harrisburg, PA 17110 (717) 234-2401 Attorneys for Plaintiff VF,RTFTf:A nON I, Shawna M. Meyer, verify that the statements made in the foregoing pleading are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Date: '1 - 'J. '1- 0<./ '"- 1 .......... V) w ~ <::: ----c::. \-:) t ~ Vv U1 ..cQ.. - ..c C) o ~ ~ t'-' "" ~~::~ Cj -Tl ::;::! J'T; rnr~ rn CJ (1) " -:-\} C) rn r_... ,,""": \" '-..... \ '.l f:--.') o. 'OJ l-~ ,; , , " " I, " " 'I " Ii " " 'I Ii " " I, " " II II 'I II 'I , Ii " II " " II 1 f I II 'I II Ii II 1 /, // II I I , 1/ II SHA WNA M. MEYER, PLAINTIFF v. CHRISTOPHER D. MEYER, DEFENDANT , IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-3740 CNIL TERM CNIL ACTION - DIyORCE A('C')?PTANC')? OFSFRYlCE I, Christopher D. Meyer, accept service of the Complaint Under Section 330l(c) or 330l(d) of the Divorce Code. Date:_t~;;t5 ~~OO~I Cit4~-~ Christopher D. Meyer 57 Rose of Sharon Dlive Etters, PA 17319 ~. , a ~ vcr IT! ~,-~: ..<- .~ "':;;':T ('J:l ;; ~~~. 2''': :< .... ,...., = = J:'" (/') r"rl -0 I N o " --, :r: -., nl-,= -,,~,:, -i:'} 0 ()c'. -.....,! j -l""'Y' cFL~ ?5h1 --' 1:~ :-.v -< :::2 _1... r;-:: Ul 0'/ J? f"O MARRIAGE SETTLEMENT AGREEMENT AGREEMENTMADEthis J-O( dayofJJ""rpk1Dc:r ,20~byand between Sbawna M. Meyer ("Wife") - AND - Cbristopber D. Meyer ("Husband"), at arrisburg, Pennsylvania. WHEREAS, the parties hereto are husband and wife having been married on Sept ber 17, 1999, at Harrisburg, Dauphin County, Pennsylvania; WHEREAS, one (1) child was born of this marriage; said child being: Leanne Er h Meyer, born January 18,2002. WHEREAS, diverse unhappy differences, disputes and difficulties have arisen betw parties and it is the intention of Wife and Husband to live separate and apart for the rest oft eir natural lives, and the parties desire to settle fully and finally their respective financial and property ri ts and obligations as between each other including, without limitation by specification: settling of I matters between them relating to the ownership and equitable distribution of real and personal prope and in general, the settling of any and all claims and possible claims by one against the other or agai st their respective estates. NOW, THEREFORE, in consideration of the foregoing premises and of the mutual romises, covenants and undertakings hereinafter set forth and for other good and valuable consideratio ,receipt of which is hereby acknowledged by each of the parties, Wife and Husband, each intending to legally bound hereby, covenant and agree as follows: 1. Divorce aDd Seoaration. The parties agree to the entry of a decree in div rce pursuant to Section 3301(c) of the Divorce Code ofl980. Husband and Wife shall at all times here right to live separate and apart from each other and to reside from time to time at such pia or places as they shall respectively deem fit, free from any control, restraint, or interference whatsoever y the other. Neither party shall molest the other or endeavor to compel the other to cohabit or dwell wi him or her by any legal or other proceedings. The foregoing provision shall not be taken to be an ad ssion on the part of either Husband or Wife of the lawfulness or unlawfulness of the causes leading to th ir living apart. The parties acknowledge that a divorce action has been filed in the Court ofComm Cumberland County, Pennsylvania at docket number 04-3740 Civil Tenn. The parties agr will execute Affidavits of Consent and Waivers of Notice ofIntention to Request Entry ofa Decree simultaneously with the signing of this Agreement. Thereafter, counsel for Wife sh Praecipe to Transmit Record and obtain a divorce decree. 2. Division of Prooertv. Husband and Wife agree that the following constitute an equitable distribution of the marital property. A. Husband's Prooertv. The following property shall become the sole d exclusive property of Husband: 1. The Oldsmobile Cutlass Sierra. 2. The Cadillac E1dorado. 3. The PSERS pension accrued through his employment with the Harrisburg School District. 2 4. The property and lot situate at 57 Rose of Sharon Drive, E 17319 subject to all existing liens and obligations. Husband shall immediately take necessary steps to remove Wife's name from all debts, utilities, etc. associated with this property . 5. The household goods and personalty on the attached Exhibit The parties shall transfer these items within thirty (30) days of the date of this agr they have not already done so. B. Wife's Pronertv. The following property shall become the sole and exclusive property of Wife: I. The 1995 Chrysler Concorde. 2. The household goods and personalty on the attached Exhibit The parties shall transfer these items within thirty (30) days of the date of this agr they have not already done so. C. Satisfactorv Division of Marital and Non-Marital ProMrtv. and Wife hereby acknowledge that they have divided, to their mutual satisfaction, ail f their marital and non-marital assets, including but without limitation to, business inter sts, partnerships, inheritances, jewelry, clothing, pensions, brokerage accounts, stocks, bo ds, life insurance policies or other securities, individual retirement accounts, 401(k), employment benefits, checking and savings accounts, mutual funds and other assets, whether real, personal or mixed, tangible or intangible. 3. Additional Documentation. The parties agree to execute any deeds, assignm nts, titles or other instruments necessary and appropriate to accomplish the aforesaid division of prope 3 4. Transfers Subiect to Existin2 Liens. Notwithstanding any other provisio s in this document all property transferred hereunder is subject to the existing lien or liens set forth bove. The respective transferee of such property agrees to indemnifY and save hannless the other p from any claim or liability that such other party may suffer or may be required to pay on account of ch lien or encumbrance. 5. Reoresentations and Warranties. The parties represent and warrant to ea h other that the property described in this Agreement represents all of the property in which they have y right, title and interest, and that such property is subject to no mortgage, pledge, lien, security interest encumbrance or charge except those which are disclosed herein. 6. Equitable Division. By this Agreement the parties have intended to effect equitable division of their jointly owned property. The parties have determined that an equitable divis n of such property conforms to a just and right standard, with due regard to the rights of each party. of existing marital property is not intended by the parties to constitute in any way a sale or e change of assets, and the division is being effected without the introduction of outside funds or other p perty not constituting a part of the marital estate. It is the intention of the parties to treat all transfers erein as non-taxable. 7. Relinquishment of Ri2hts. Except as expressly provided herein, Husband fo ever relinquishes any right, title or interest he may now or hereafter have in any tangible or intangi Ie assets now belonging to Wife, and Wife forever relinquishes any right, title or interest she may now r hereafter have in any tangible or intangible assets now belonging to Husband. s. After-Acquired PropertY. Each of the parties shan hereafter own and enjoy independently of any claim or right of the other, all items of property, be they real, personal or mixed, 4 tangible or intangible, which are hereafter acquired by him or her, with full power in him 0 her to dispose of the same as fully and effectively, in all respects and for all purposes as though he or she ere unmarried. 9. Debts. Husband shall be solely responsible for the loan associated with th Cadillac Eldorado, the Best Buy credit card debt, and the Sears credit card debt. Wife shall be solei responsible for the Old Navy credit card debt. Husband and Wife shall each be solely responsible for other debts in their respective names, including but not limited to personal loans, charge accounts and Both parties represent and warrant to the other that as of the date of this Agreement they incurred, and in the future will not contract or incur, any debt or liability for which the othe or the estate of the other might be responsible. 10. Liabilities. All debts, contracts, obligations or liabilities incurred at any tim in the past or future by either party will be paid promptly by said party, unless and except as otherwise pecifical1y set forth in this Agreement; and each of the parties hereto further promises, covenants and each will now and at all times hereafter save harmless and keep the other or his or her estate nderonified and save harmless from all debts or liabilities incurred by him or her, as the case may be, and om all actions, claims and demands whatsoever with respect thereto, and from all costs, legal or oth rwise, and counsel fees whatsoever pertaining to such actions, claims and demands. Neither party shall, of the date of this Agreement, contract nor incur any debt or liability for which the other or his or h r property may be responsible, and shall indemnifY and save harmless the other from any and all claims 0 demands made against him or her by reason of debts or obligations incurred by him or her and from all xpenses, legal costs, and counsel fees unless provided to the contrary herein. 5 11. Counsel Fees. Costs and EXDenses. Each party shall be responsible for hi or her own legal fees, costs and expenses incurred in connection with their separation and/or the disso tion oftheir marriage. 12. Alimonv. In exchange for and in consideration of the promises and represe tations made hereunder, Husband and Wife hereby waive and release any and all right, title, interest, clai s or demand of whatsoever nature which he or she now has or hereafter can, shall or may have against t e other or the respective separate property ofthe other under the laws of the Commonwealth ofPennsylv 'a or any other governing state, country, territory or jurisdiction in the nature of spousal support, sep rate maintenance or support, alimony, either pendente lite, temporary, rehabilitative, pennanent r lump sum and right to seek equitable or community distribution or division or assignment of property r similar marital rights. 13. Life Insurance. The child shall be named as irrevocable beneficiary on any I e insurance policies insuring Husband's life and Wife's life for no more than $100,000. Husband and W e shall maintain their policies until the child attains age 22. 14. Full Disclosure. The respective parties do hereby warrant, represent and dec are and do acknowledge and agree that each is and has been fully and completely informed of and is fi and cognizant of the wealth, real and/or personal property, estate and assets, earnings and in other and that each has made a full and complete disclosure to the other of his or her entire a liabilities and any further enumeration or statement thereof in this Agreement is specifically w 'ved. 15. Releases. Each party does hereby remise, release, quitclaim and forever disch ge the other and the estate of the other from any and every claim that each other may now have, or h have or can have at any time, against the other, or in and to or against the other's estate, or an part 6 thereof, whether arising out of any former contracts, engagements or liabilities of the othe or by way of dower or claim in the nature of dower, widow's rights, or under the intestate laws, or the t to take against each other's will, or for support or maintenance, or of any other nature whatsoever except any rights accruing under this Agreement. 16. Indemnification. Each party represents and warrants to the other that he she has not incurred any debt, obligation, or other liability, other than described in this Agreement, on hich the other party is or may be liable. Each party covenants and agrees that if any claim, action 0 proceeding is hereinafter initiated seeking to hold the other party liable for any other debts, obligations, Ii bility, act or omission of such party, such party will at his or her sole expense, defend the other against y such claim or demand, whether or not well-founded, and that he or she will indemnifY and hold harmle the other party in respect of all damages as resulting therefrom. Damages as used herein shall include action, demand, loss, cost, expense, penalty, and other damage, including without limitation, counsel fees and other costs and expenses reasonably incurred in investigating or attempting to avoid opposing the imposition thereof or enforcing this indemnity, resulting to Husband or Wife fr m any inaccurate representation made by or on behalf of either Husband or Wife to the other in this any breach of any of the warranties made by Husband or Wife in this Agreement, or breach 0 default in performance by Husband or Wife of any of the obligations to be performed by such party her under. The Husband or Wife agrees to give the other prompt written notice of any litigation threatened 0 instituted against either party which might constitute the basis for a claim for indemnity pursuant to the erms of this Agreement. 17. General Provisions. This Agreement constitutes the entire understanding oft e parties and supersedes any and all prior agreements and negotiations between them. There are no 7 representations or warranties other than those expressly set forth herein. 18. Fair and Eauitable Contents. The provisions of this Agreement and thei have been fully explained to the parties by their respective counsel. Each party acknowled es that he or she has received independent legal advice from counsel of his or her selection and that eac understands the facts and has been fully informed as to his or her legal rights and obligatio . Each party acknowledges and accepts that this Agreement is, under the circumstances, fair and equitab e, and that it is being entered into freely and voluntarily after having received such advice and with such and that execution of this agreement is not the result of any duress or undue influence and the result of any collusion or improper or illegal agreement or agreements. 19. Breacb. It is expressly stipulated that if either party fails in the due perform his or her material obligations under this Agreement, the other party shall have the right, at election, to sue for damages for breach thereof, to sue for specific performance, or to seek yother legal remedies as may be available, and the defaulting party shall pay the reasonable legal fees for rendered by the non-defaulting party's attorney in any action or proceeding to compel perfo hereunder. 20. Execution of Documents. Each party shall on demand execute any other do may be necessary or advisable to carry out the provisions of this Agreement. 21. Modification. No modification, rescission or amendment to this Agreement effective unless in writing signed by each of the parties hereto. 22. Severabilitv. If any provision of this Agreement is held by a Court of compet jurisdiction to be void, invalid or unenforceable, the remaining provisions hereof shall neverth less survive and continue in full force and effect without being impaired or invalidated in any way. 8 23. Aoolicable Law. This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania. 24. Al!reement Not to be Memed. This Agreement may be filed with the Cou for incorporation into the Decree of Divorce for purposes of enforcement only, but otherwise merged into said Decree. The parties shall have the right to enforce this Agreement under Code of 1980, as amended, and in addition, shall retain any remedies in law or in equity un Agreement as an independent contract. Such remedies in law or equity are specifically not aived or released. IN WITNESS WHEREOF, the parties hereto have set their hands and seals the da and year first above written. Witness: 9D 2)) 9 .r-- y ~~~ Christopber D. Meyer 9 Exhibit A Assets to Christopher Mever Large television Small television Computer equipment (except pc to Shawna) VCR Sony DVD player Stereo equipment White bookcase Toddler bed King bed Recliners Computer chairs Coffee table Towels (to be split) Silverware, dishes, glasses/cups, kitchen utensils (to be split) 2 Fish tanks Cat and associated care items DVDs (to be split) Wine Goblets and Carafe Wooden western style dresser Camping gear Appliances Lamps (except free-standing lamp) Leanne's toys (to be split) Xbox King size sheets and blankets Golden handled pots/pans Dining room table Vacuum cleaner Cordless phone Answering machine Entertainment Center All PC games (except those gifted to Shawna) All other assets gotten/not specified Exhibit B Assets to Shawna Mever VCR All record players Proscan DVD player Computer of Pentium 2 class or better Small CD radio Alarm clock radio Car radio and CD changer Digital Camera and re-charger Free standing lamp Blenderlfood processor Ugly chair Desk Bookcases (except white bookcase) Hope chest Bedside stand Dining room chairs Green dresser Crib w/mattress Iron and ironing board Vacuum cleaner Baskets Records Books (to be split) DVDs (to be split) CDs (belonging to Shawna) Blue bath mats Blue Jiving room pilIow/blanket set Mexican blanket Ivy throw Various gifted knick-knacks Dishes, glasses/cups, silverware (to be split) Steak knives Pots/pans (except gold handled pots/pans), baking pans Mixing bowls, mixing pitcher Tupperware and similar containers Rose cake plate w /top 1 carry casserole Glass pie plates Small casserole Platter dishes (to be split) Tea kettle Large cookie sheets Blue telephone Training potty Lemme's clothes (to be split) Leanne's toys (to be sp it) Battery operated carou I Leanne's books (to be slit) ABC bedding set Sun & Moon quilt and Marble race set All infant items Diaper pail ;~:"~ ;~ ~' o c "'~ c:;) c:.:.:. -<:" r:":1 f1; " l'>,' v:.' C) -II --I T Fii :Tl ~- ::q:::3 -:~() .'1 ~:-j ," --ro -:.b: G z,- -" ----- - ,I SHA WNA M. MEYER, PLAINTIFF IN THE COURT OF COMMON PL AS CUMBERLAND COUNTY, PENN YL VANIA v. NO. 04-3740 CIVIL TERM CHRISTOPHER D. MEYER, DEFENDANT CIVIL ACTION - DIVORCE A FFInA VlT OF C:ONSRNT 1. A Complaint in Divorce under S330l(c) of the Divorce Code was filed on July ,2004. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) d ys 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 intent on to request entry of the decree. I verify that the statements made in this Affidavit are true and correct. I understand t at false statements herein are made subject to the penalties of 18 Pa.C.S. S4904 relating to unsworn Isification to authorities. Date: !c);:sn c4 /f) ,. \ i ~/ c-~-_.. r.~l--- .f'" /: '..' fe' ",:....,? ShmfnaM. Meyer, Plaintiff...... '.',.'" ~~, ~.-~'~ ; ~~:,. ;t:~: i . ~;; ~-~ .;. \..- --;v :~ (") ~'~ "'" C? G,-:;;) .c- o rrI n N "" .....J C) ~TI :::! f}"p,j -rf'fl :67 or-} -;:,..1 ~l', "---i, '~~fA -...' ;(! -",',' -" fS1 en - < SHAWNA M. MEYER, PLAINTIFF IN THE COURT OF COMMON PL AS CUMBERLAND COUNTY, PENN YL V ANIA v. NO. 04-3740 CIVIL TERM CHRISTOPHER D. MEYER, DEFENDANT CIVIL ACTION - DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under ~3301(c) of the Divorce Code was filed on July 2 ,2004. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) da shave elapsed from the date of filing and service of the Complaint. 3. I consent to the entry ofa final Decree of Divorce after service of notice of intent n to request entry of the decree. I verilY that the statements made in this Affidavit are true and correct. I understand t at false statements herein are made subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn sification to authorities. Date: -J d- - ). q -::<.0 (1 't Christopher D. Meyer, Defendant ~ :l~' " ;:/ ~~::: :~~J r.:J .- j;; .- :t~~; ::4 -<... '" = = ..,- Cl rn " N \.0 o >Tl --I ~ fti~] -vi-n ?::~Cf-; ::.:iC> ::~ ~~-; "'"-fTl ?? ~?,~ ~ i~ .c:- (,;", ii II II \1 I. II II Ii II II \ I I \ II \ I I ii/December 29,20049:40 AM . ~ SHA WNA M. MEYER, PLAINTIFF IN THE COURT OF COMMON PL AS CUMBERLAND COUNTY, PENN YLVANIA v. NO. 04-3740 CIVIL TERM CHRISTOPHER D. MEYER, DEFENDANT CNIL ACTION - DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER &3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI 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 t Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotar . I verify that the statements made in this Affidavit are true and correct. I understand t at false statements herein are made subject to the penalties of 18 Pa.C.S. 94904 relating to unsworn lsification to authorities. /," Date: lei- (~4' (> (I \~_..,. ..j. '\ \ . , ~ /,_/ \ /j /' ~"" .' //3,. / /. -"~i'll; , ;' (F><(' // q.L-__ I . c. . . '--. Sha Da M, Meyer, Plaiflt-iff. . . I - "... t,) r~- ~;f~. :.~~~ --j -~ --- ....., c.:, = ..,.. o reI n N ..0 o 'n ...J I-. hiF -nU:~ ")Y ~"~c'-:' ~i::{i .~~~. f~ ::-i )~: -:1: j":? .r:-- Q". .-::' """, - IllDecember 29,20048;24 AM SHA WNA M. MEYER, PLAINTIFF IN THE COURT OF COMMON PL AS CUMBERLAND COUNTY, PENN VANIA v. NO. 04-3740 CIVIL TERM CHRISTOPHER D. MEYER, DEFENDANT CIVIL ACTION - DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER &3301(~ 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 ifI 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 t Court and that a copy ofthe decree wiII be sent to me immediately after it is filed with the Prothonot I verify that the statements made in this affidavit are true and correct. I understand t at false statements herein are made subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn alsification to authorities. Date: 1.:1. - d- q - ;:).0'0 <. / Christopher D. Meyer, Defendant (") c- -:".' ~.-'" s,~T; /..... C) r;: )-;;i-::' ~'-{~j :r>S ~ - ...., C~ c.~ -"'" o rT1 n N ill -0 ~, ~~ o ~Tt -l :~-n n,.-- ~fJj:q ~{j '1.... ~J(~ ~:t} ~~:} t;? :::~11""1 .-.~.:.~ r:"'2 r -.l :p --- ii/December 29, 2004 9:42 AM ~ SHA WNA M. MEYER, PLAINTIFF IN THE COURT OF COMMON PL AS CUMBERLAND COUNTY, PENN YL VANIA v. NO. 04-3740 CIVIL TERM CHRISTOPHER D. MEYER, DEFENDANT CIVIL ACTION - DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the court for entry f a divorce decree: 1. Ground for divorce: irretrievable breakdown under 93301(c) of the Divorce Co e. 2. Date and manner of service of the Complaint: The Complaint was served via fir t class mail on the defendant on August 25, 2004. 3. (a). Date of execution of the affidavit of consent required by 93301(c) of e Divorce Code: by plaintiff December 29,2004; by defendant December 29,2004. (b)(I). Date of execution of the affidavit required by 93301(d) of the Divorce Code: N/A; (b )(2). Date of filing and service of the plaintiffs affidavit upon the responde t: N/ A. 4. Related claims pending: None. 5. (a). Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: N/A. (b). Date plaintiffs Waiver of Notice in g3301(c) Divorce was filed with th Prothonotary: A copy is attached hereto and is being filed simultaneously with this Praecipe. ~ ~ . Date defendant's Waiver of Notice in 93301(c) Divorce was filed with the Protho otary: A copy is attached hereto and is being filed simultaneously with this Praecipe. SMIGEL, ANDERSON & SACKS Date: ) L/2() t OL/ ~/.~. 0- Q ".. 1.' \ .' .... " ./ '" i;, By: '... / , - ..-.--' AnryV.-JLevin, Esquire LD. #: 70259 Jam~. Demmel, Esquire 1.D. #: 90918 4431 North Front Street Harrisburg, P A 17110 (717) 234.2401 Attorneys for Plaintiff .'t)i:" ':.:) ~ " 0~;. ~- ~? ":':"~ (- , ;..- t~~ ./-~ :::< o c ,-.~ C:> c' .1;:"" C? 1--'1 ("') N ,p ....---- "'" :;i'; .-l ~C",'"'l fn(;o::: ~Dl~ ::0'..,.... l--:~(j ~.~1: ::;, \,;;'7:C~2. ,,_.;~ t ' , '~:~, :~C", is? r. c::> ~1 - ... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . +:-f'+++++ '+ ++"'+;1; :1:+ .. . ++'+' + +++ ++++++++ + +++++ ;I; '" '+:+: "":+: + ;+: Of. '+ + +.;+c+ . . . . . . . . + + + + . + + + + + . + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + . + + + + + + + + + + + + + + + + + + + + + + + + + . + + . + + + + + + + + + + + + Of: '+ + :+: + '+ '+' + +. +. :+: + ++. .. + + +. IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PEN NA. SHAWNA M. MEYER PLAINTIFF No. 04 - 3740 crvn. VERSUS CHRISTOPHER D. MEYER DEFENDANT DECREE IN DIVORCE AND ~ NOW, . "'2--'1 AND :::Jt;tl~ IT IS ORDERE DECREED THAT SHAWNA M. MEYER . PLAI NTI FF AND CHRTS'lDPHF.R n MP.VF.R . DEFENDA T, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHIC HAVE BEEN RAISED OF RECOli..o~J:LJ_'!~ ACTION FOR YET BEEN ENTERED; \~ It is further ORDERED and DECREED that the Marriage Settlement Agre executed by and between the parties, dated December 29, 2004, is incorporat by re erence into this Decree for the purpos~. O,fjIDfor but shall NOr be deemed to have been merged with this Dee . / , WHICH A FINAL ORDER H S NOT / By THE COURT; </ ATTEST; ! PROTHON ARY + + Of + Of "" +. +. +. +. fi' . . . . . . J. ~;'z /fl..~ ~<<. ~b~~11f'k~ -pp Sr;?.5' I 5'9.5'/