The URL can be used to link to this page

Home My WebLink About04-4068 IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PA CIVIL ACTION - LAW SHARON K. STEVENS, NO. 01./ - 4ot.P G~itT~ Plaintiff v. RICHARD W. STEVENS, JR., Defendant IN DIVORCE NOTICE TO DEFEND 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 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, Cumberland County Courthouse, Carlisle, P A 17013. If you do not file a claim for alimony, marital property, counsel fees or expenses before the final decree of divorce or annulment is entered, you may lose the right to claim any of them. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 TEL.: (717) 249-3166 22198_1 DILWORTH PAXSON LLP THOMAS B. YORK, ESQ. ATTORNEY ill NO. 32522 112 Market Street, 8th Floor Harrisburg, PA 17101 Telephone: (717) 236-4812 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PA CIVIL ACTION - LAW SHARON K. STEVENS. NO. 01../ - 461o~ Ie... ~~ULG l~ Plaintiff v. RICHARD W. STEVENS, JR., Defendant IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff, Sharon K. Stevens, is an adult individual who currently resides at 1176 Kingsley Road, Camp Hill, PA 17011. 2. Defendant, Richard W. Stevens, Jr., is an adult individual who currently resides at 713 Valley Street, Enola, PA 17025. 3. Plaintiff and Defendant are U.S. citizens and have been bona fide residents of the Commonwealth of Pennsylvania for a period of more than six (6) months immediately preceding the filing of this Complaint. 4. The parties were married on September 30, 1989. 22198_1 5. There has been no prior action for divorce or annulment by either party in this or any other jurisdiction. 6. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of Soldiers' and Sailors' Civil Relief Act of 1940 and its amendments. 7. Plaintiffhas 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. COUNT I REQUEST FOR A NO-FAULT DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE 8. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 9. The marriage of the parties is irretrievably broken. 10. After ninety (90) days have elapsed from the date of the filing of this Complaint, Plaintiff intends to file an affidavit consenting to the divorce. Plaintiff believes that Defendant will also file such an affidavit. WHEREFORE, if both parties file affidavits consenting to a divorce after ninety (90) days have elapsed from the date of the filing of this Complaint, Plaintiff respectfully requests the Court to enter a decree of divorce pursuant to Section 3301(c) of the Divorce Code of 1980 and its subsequent amendments. 22198_1 2 COUNT II REOUEST FOR APPROVAL OF ANY SETTLEMENT AGREEMENT AND INCORPORATION THEREOF IN DIVORCE DECREE UNDER SECTIONS 3104(a)(1) and (3) and 3323(b) OF THE DIVORCE CODE 11. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 12. The public policy of the Commonwealth of Pennsylvania encourages parties to a marital dispute to negotiate a settlement of their differences. 13. A settlement has been reached as of the date of the filing of this Complaint, and is attached hereto as Exhibit A. The Plaintiff and the Defendant have negotiated a fair and reasonable settlement of all matters. 14. Plaintiff desires that such written agreement be approved by the Court and incorporated but not merged in any divorce decree which may be entered dissolving the marriage between the parties. WHEREFORE, since a written settlement agreement has been reached between the Parties, Plaintiff requests the Court that, pursuant to Sections 3104(a) (1) (3) and 3323(b) of the Divorce Code, the Court approve and incorporate but not merge such agreement in the final divorce decree. C7~cfJ.~ THOMAS B. YORK l/ Dilworth Paxson LLP Attorney ill No. 32522 112 Market Street, 8th Floor Harrisburg, PA 17101 Tel.: (717) 236-4812 Attorney for Plaintiff 22198_1 3 VERIFICATION SHARON K. STEVENS verifies that the statements made in this Complaint in Divorce are true and correct. She understands that false statements herein are made subject to the penalties of 18 P A C.S. Section 4904, relating to unsworn falsification to authorities. " ..~- ~ , ~/ .,-----.- , _____\J..~.A.u.wy SHARON K. ST VENS Dated: '(- - I ~ ()f---- 22198_1 4 Exhibit A (xhibH-' rr SEPARATION AND PROPERTY SETTLEMENT AGREEMENT *' THIS AGREEMENT is made and entered into this I d. day of _ j \ A.fI...Q , 2004, by and between SHARON K. STEVENS (hereinafter referred to as "Wife") and RICHARD W. STEVENS, JR. (hereinafter referred to as "Husband"). WIT N E SSE T H: WHEREAS, Husband and Wife were lawfully married on September 30, 1989; and WHEREAS, there is one (I) child born of said marriage, namely, MIKHALA STEVENS (hereinafter referred to as the "Child"); and WHEREAS, certain irreconcilable differences have arisen between Husband and Wife as a consequence of which they agree to live separate and apart from each other during their natural lives and wish to proceed with a prompt divorce; and WHEREAS, the parties' marriage is irretrievably broken; and WHEREAS, in view of the foregoing, the parties desire to finally settle and determine their mutual obligations, to equitably divide their marital property,. to provide for the maintenance, support and welfare of the Child and to establish all rights, relationships and obligations between them arising out of their marriage or otherwise. NOW THEREFORE, in consideration of the foregoing and of the mutual promises and obligations set forth herein, the parties, intending to be legally bound, hereby agree as follows: Wife's Initials: Husband's Initials: .:sLS- ~ 22001_1 ARTICLE I Separation l.l It shall be lawful for each party at all times hereafter to live separate and apart from the other party at such place or places as he or she may from time to time choose or deem fit. 1.2 Except as otherwise provided herein, each party shall be free from interference, restraint, authority and control, direct or indirect, by the other, as fully as if he or she were single and unmarried. Neither party shall in any manner or form whatsoever compel or endeavor to compel the other to cohabit or dwell with him or her, or harass or slander the other party. 1.3 The Parties intend to immediately proceed with an action for divorce which will be initiated by Wife. Husband will fully and promptly cooperate with Wife to obtain an uncontested Final Judgment of Dissolution of Marriage and consents to the filing of a petition in divorce. ARTICLE II Custody of Children 2.1 The parties acknowledge that the welfare and best interests of the Child are paramount considerations for each of them. 2.2 Wife shall have legal custody of the Child. The parties hereby agree to participate in major decisions pertaining to the Child including, but not limited to, education, medical care and spiritual upbringing, with a view to arriving at policies and decisions calculated to promote the Child's best interests. Husband shall have visitation rights with the Child every other weekend. Husband shall also be allowed other reasonable visitation time, which Wife agrees to liberally grant. Wife's Initials: Husband's Initials: 5Y<;y-- V1.1'1 ~/ 2.3 Each party shall make every effort to foster the respect and affection of the Child for the other party and shall do nothing which would in any way estrange the Child from the other party or hamper the natural development of the Child's love for both parties. The parties desire that the Mother/Child and the Father/Child relationships shall be fostered and enhanced by a cordial relationship between Husband and Wife even though they are living separate and apart. ARTICLE III Child Support 3.1 Wife has agreed that she will not seek support for the Child from Husband. ARTICLE IV Division of Property 4.1 Upon the execution of this Agreement, Husband shall deliver to Wife a quitclaim deed acknowledging that he does not have now, or at any time in the future, any right, title or interest in and to the premises at 1176 Kingsley Road, Camp Hill, PelIDsylvania. Except as otherwise provided in this Agreement, Wife hereby agrees to assume sole responsibility for payment of the mortgage and all expenses associated with said premises, and she indemnifies Husband and holds him harmless from and against any liability, cost and expense, including reasonable legal fees, as a result of any claim against him arising from said expenses. Wife shall have three (3) years from the date of this Agreement to obtain refinancing for said premises and to thereby remove Husband from any mortgage on said premises. 4.2 The parties hereby agree that all personal property, including motor vehicles and jewelry, will remain the separate property of the person currently in possession of Wife's Initials: Husband's Initials: ~~// said property. In particular, Wife will solely own the Saturn automobile and Husband will solely own the Nissan automobile. ARTICLE V Separate Assets 5.1 Except as otherwise expressly provided in this Agreement, each party shall retain as his or her separate assets, all items of property, including, but not limited to, automobiles, bank accounts, securities accounts, pension or retirement accounts, business interests and jewelry, titled individually or in his or her possession, with full power to dispose of the same as fully and effectively, in all respects and for all purposes, as ifhe or she were unmarried. 3.2 Except as otherwise expressly provided in this Agreement, each party hereto does hereby forever, remise, release and quitclaim all right, title, interest and claim which he or she either now has or ever may have in or to the personal property of the: other. ARTICLE VI Debts 6.1 Except as otherwise provided herein, each party agrees to assume sole responsibility for the payment of his or her debts, including all federal, state and local taxes, and each indemnifies and holds the other harmless from and against any liability, cost and expense, including reasonable legal fees, as a result of any claims against him or her arising out of debts of the other. 6.2 As to the Chase Manhattan credit card account which is in both parties' names, Husband agrees to be liable for all payments and to remove Wife's name from the account as soon as possible. Husband will indemnify and hold harmless Wife from and against Wife's Initials: ~.'/ -,.:;'U -.___ any liability, cost and expense, including reasonable legal fees, as a result of any claims against her arising out of this debt. 6.3 After the execution of this Agreement, neither party shall incur any expenses on behalf of the other, nor pledge the other's credit and each party shall be solely responsible for the payment of his or her individual debts. Further, each party shall hold the other harmless from any and all liability, cost and expense, including reasonable legal fees, as a result of any claim arising out of any debt of the other incurred subsequent to the execution of this Agreement. ARTICLE VII Mutual Releases 7.1 Except as otherwise expressly provided by this Agreement: (a) Each party hereby absolutely and unconditionally releases and forever discharges the other from any obligation for: alimony, alimony pendente lite; support and maintenance; equitable division of property; and, counsel fees and expenses; and each accepts the provisions herein in full satisfaction of all obligations for support or otherwise arising out of the marital relationship of the parties and each relinquishes any right of claim to the eamings, accumulations, money or property of the other. Neither party shall have any obligation to the other not expressly set forth herein. (b) Each party hereby absolutely and unconditionally releases and forever discharges the other, his or her heirs, executors, administrators, assigns, property, and estate from any and rights, claims, demands, or obligations whatsoever arising out of or by virtue of the marital relation of the parties, including dower rights, curtesy, homestead rights, right or claim in the estate of the other, right of election regarding the estate of the other or to take against the will of the other, right of inheritance or distribution in the event of intestacy, right to Wife's Initials: Husband's Initials: S #5j-- 0,1 A ~/ act as administrator of the estate of the other, and all other similar or related rights or claims under the laws of any state or territory of the United States or of any foreign country, as such laws exist or may hereafter be enacted or amended. (c) Except for the obligations of the parties herein contained, each party does hereby absolutely and unconditionally release and forever discharge the other of and from all causes of action, claims, rights or demands whatsoever, in law or in equity, which either party ever had or now has against the other. ARTICLE VIII Divorce 8.1 The parties agree that they shall obtain a divorce. This Agreement shall be submitted to the Court for incorporation into a Decree, but this Agreement shall not depend for its effectiveness upon such incorporation, nor be merged in or otherwise be effected thereby, but shall survive any such Decree of Divorce. By said incorporation, the Court, on entry of the Judgment for Divorce, shall retain continuing jurisdiction over the parties and the subject matter of the Agreement to enforce the provisions and the terms thereof, but the parties hereby agree that the Court shall not have the jurisdiction to modify the provisions and the terms of this Agreement. 8.2 Each party shall be responsible for his or her own attorneys' fees in connection with the preparation of this Agreement and the dissolution of their marriage, including all claims made under the Pennsylvania Divorce Code or otherwise. However, in the event of breach of this Agreement, the breaching party shall be obligated to pay the reasonable attorney's fees of the non-breaching party incurred for enforcement. Wife's Initials: 6~. /' ' I /., __ J.lllsb~nrt'c Tnit;';;l)"" ARTICLE IX Taxes 9.1 The parties hereby agree to file separate federal and state income tax returns for 2004. Husband and Wife shall be individually responsible for any additional taxes due under those returns. Any refund will be the sole and exclusive property of the filing party. ARTICLE X Miscellaneous 10.1 The parties agree that upon request, and in no event more than twenty (20) days after demand, to execute and deliver any and all instruments and take all such action necessary or appropriate to effectuate and carry out the provisions of this Agreement. 10.2 This Agreement shall be binding upon the parties, their heirs, administrators, executors and assigns. 10.3 This Agreement contains the entire understanding of the parties hereto superseding and revoking any and all prior agreements or understandings, written or oral, between the parties with respect to their respective property rights, the question of maintenance and support of each party by the other, and the present and future interests of each in the estate of the other. There are no representations or understandings by or between the parties except as expressly set forth herein. Any modification, waiver or amendment of any of the terms of this Agreement shall not be effective unless in writing and signed by the parties. 10.4 Any waiver of any breach or default under this Agreement shall not be deemed a waiver of any subsequent breach or default. 10.5 If any provision of this Agreement is held to be invalid or unenforceable, all other provisions shall nevertheless continue in full force and effect. 1'1f'1r\1 1 ~. Wife's Initials: Husband's Initials: 10.6 This Agreement shall be construed in accordance with the laws of the Commonwealth of Pennsylvania and specifically under the laws of the Divorce Code of 1980 and amendments thereto. 10.7 Each party acknowledges: (a) that he or she has had the opportunity to obtain the advice of independent counsel prior to the execution of this Agreement; (b) that he or she has read this Agreement and understands its terms; (c) that the transfers and agreements provided herein constitute a fair, reasonable and adequate settlement of their respective rights and obligations; and, (d) that this Agreement is signed freely and voluntarily and is not the result of any duress or undue influence. 10.8 The parties do hereby warrant, represent and declare that each is fully and completely familiar, informed and cognizant of the estate, real and personal property, assets, earnings and debts of the other, and each of the parties hereto having verified the income, property, estate and assets of the other, hereby waives further enumeration and itemization thereof in this Agreement. Wife's Initials: Husband's Initials: 8~'5 4~u~ ?/M! 1 IN WITNESS WHEREOF, the parties have signed, sealed and acknowledged this Agreement as of the day nd year first above written. ------------- \~~8~ S~ON K. STEVENo/ ~ "'-............ r;)~Jtju/ ~] RICHARD W. STEVENS, JR. y~ 22001 1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF iY~ SS. SHARON K. STEVENS, being duly sworn according to law, deposes and says that she executed the foregoing Separation and Property Settlement Agreement as and for her ree, ," md dood md ;o,"od;o, 10 b, 1".ly bom'" ili=bY~ ~ &15--- SHARON K. STEvENS SWORN TO AND SUBSCRIBED BEFORE ME THIS (f)...f1,..DAY OF ~ ,2004. ~ar;-(~llc~ (""-'-NoTAAIAl SEAl I ,'OSEPHINE M. BAlNlEY, Notary fUlIc ! c!tyoj H8rr16burg, PA DauphIn County ! ',5\' 1;'7'1'!i~~!cn ExpIm Dee. 11 2005 . ., ' '..-..-.---...... , COMMONWEALTH OF PENNSYLVANIA SS. COUNTY OF RICHARD W. STEVENS, JR., being duly sworn according to law, deposes and says that he executed the foregoing Separation and Property Settlement Agreement as and for his free act and deed and intending to be legally bound thereby. //) / ~ ili ~#a/;~ RI6HARD W. ST \ \ .~ S,JR SWORN TO AND SUBSCRIBE!) BEFORE ME THIS / J). #-nAY OF r ,2004. { C1.-p.J.: ,~/VJ.~ ()' -TN~ublic (j r NOTARIAL SEAL .JOSEPHINE M. BRINLEY. Nolary AM: : ,elly of HllIIlaburg, PA ~ CclwIIy :"-1 r:~ Dee. 11, 2005 pc.... ft- ~ ~ - w ~ lrr () (). ..c:: - f1.) - -:tJ ~ F ~ .... -~ (\ ~ IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PA CIVIL ACTION - LAW SHARON K. STEVENS, NO. 04-4068 Plaintiff v. RICHARD W. STEVENS, JR., Defendant IN DIVORCE ACCEPTANCE OF SERVICE I accept service ofthe COMPLAINT IN DIVORCE. August 16. 2004 Date tJ[:dtMJ N Si-tw~ S~ RICHARD W. STEVENS, JR. (DEFENDANT) 713 Valley Street. Enola. PA 17025 MAILING ADDRESS 22613JDOC '" r-.,~) C.~.:::) c.,::::) C..rl c> -., :t ~ ("n-D r -r:,rn ,~J:JCl ;~;~~ <:1 :!J z() :,,~5f'J'! <- """ =e '" .c- -0 ::t;: ",... ;;;',. :"i.i ....;;: DILWORTH PAXSON LLP THOMAS B. YORK., ESQ. ATTORNEY ill NO. 32522 112 Market Street, 8th Floor Harrisburg, P A 17101 Telephone: (717) 236-4812 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, P A CIVIL ACTION - LAW SHARON K. STEVENS, NO. 04-4068 Plaintiff v. RICHARD W. STEVENS, JR., Defendant IN DIVORCE AFFIDAVIT OF CONSENT I. A complaint in divorce under ~ 3301(c) of the Divorce Code was filed on August 16,2004. 2. The marriage of Plaintiff and Defendant is irretril~vably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 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 P3l.C.S. 94904 relating to unsworn falsification to authorities. 22616JDOC Date: 22616JDOC 2 ;;}//~~: o c:: ,,-, ('::.~J r::,:) <or, 3:;; ;;;:, "v -!O'- o -,., ::::f fh.~i) ,..... -ni'.'"1 :F1; .'>f'i'7 ~~;_.; I -,., ::tt: - "v DILWORTH PAXSON LLP THOMAS B. YORK, ESQ. ATTORNEY ID NO. 32522 112 Market Street, 8th Floor Harrisburg, PA 17101 Telephone: (717) 236-4812 Altorney for Plaintiff IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PA CIVIL ACTION - LAW SHARON K. STEVENS, NO. 04-4068 Plaintiff v. RICHARD W. STEVENS, JR., Defendant IN DNORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER !l 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 10se 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 ofthe decree will be sent to me immediatdy 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: ( /q OS ~~~~ 22630JDOC 2 . -, ......." ~::5 .:..n C,') -11 -, i~i :!] !~-~ ~on'l 'ClC'.'" ,_..., r'" ~;:JCi~ ~1~;~ "-~. :",1.] .'<:, '-- :r:~. :.ll:= 1'\) ~ ;:~ .r::- N DILWORTHPAXSONLLP THOMAS B. YORK, ESQ. ATTORNEY ill NO. 32522 112 Market Street, 8th Floor Harrisburg, PA 17101 Telephone: (717) 236-4812 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PA CIVIL ACTION - LAW SHARON K. STEVENS, NO. 04-4068 Plaintiff v. RICHARD W. STEVENS, JR., Defendant IN DIVORCE AFFIDAVIT OF CONSENT: 1. A complaint in divorce under 9 3301(c) of the Divorce Code was filed on August 16, 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 Cornplaint. 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. S 4904 relating to unsworn falsification to authorities. 22617JDOC Date: 22617_I.DOC 2 rft~~IW/IW 2Y'~~dr Richard W. Stevens, Jr. (Defendant) o c N .......' \0.,. ~., (7;::":) = .:'.":...11 () ., :;1 f,c'-n 11,-::.;;; -orn :!j(~) (::)(1.. -I^;:t:/ (,:~5 (f? --...., '- """ :;;e N -<:- 3! -'..;~ ..c- ::0 ....;- DILWORTH PAXSON LLP THOMAS B. YORK, ESQ. ATTORNEY ill NO. 32522 112 Market Street, 8th Floor Harrisburg, PA 17101 Telephone: (717) 236-4812 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PA CIVIL ACTION - LAW SHARON K. STEVENS, NO. 04-4068 Plaintiff v. RICHARD W. STEVENS, JR., Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER & 3301(C) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divofCl~ 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 immediatdy 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: ( ( //r;tktvl /AI~~sr1-. Richard W. Stevens, Jr. (Defendant) 22632JDOC 2 C) (= ...., C~) c:> c.:.n "- ;,.. z C) -n ::t rn::!"J -or:;:; "'lC) (:) 1 Ie> c~!~ ~.:! ,-""- .,i) 1'0.) ... -0 :1:: x:- N DILWORTH PAXSON LLP THOMAS B. YORK, ESQ. ATTORNEY 10 NO. 32522 112 Market Street, 8th Floor Harrisburg, PA 17101 Telephone: (717) 236-4812 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, P A CIVIL ACTION - LAW SHARON K. STEVENS, NO. 04-4068 Plaintiff v. RICHARD W. STEVENS, JR., Defendant IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following infomlation, to the court for entry of a divorce decree: L Ground for divorce: Irretrievable breakdown under 9 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint Hand-delivered to Defendant, Richard W. Stevens, Jr., on August 16,2004. 226!SJDOC 3. Date of execution of the affldavit of consent required bY/S, ~3(I(C) of the Divorce Code: by Plaintiff 5 ; by Defendant _ ( f-lJ-f- 05 . 4. Related claims pending: NONE. 5. Date Plaintiff's Waiver of Notice was filed with. the Prothonotary: JJ )Lf f6~ Date Defendant's Waiver of Notice was filed with the Prothonotary: Jj J4 (05 O~6JC~L Thomas B. York . . 22615_1.DOC 2 CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing document was seSi-ed on the Defendant, Richard W. Stevens, Jr., via first-class, postage prepaid mail on this ~ I day of ,2005 at the following address: 713 Valley Street, Enola, PA 17025. (~~/%~~ rJ) Thomas B. York 22615JOOC 3 ".' .~~.:; (,:.,11 -.,.., rr; t:O / - en ..;::- '" . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . :+:+ :f.:f. :f.* :f. ~:f.:f.*:f.:f. ***:f.'+' ~ . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. 64_- ~ NO. DECREE IN DIVORCE ~-a!5 IT IS ORDERED AND AND NOW, DECREED THAT , PLAINTIFF, , DEFENDANT, AND ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE . BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT . YET BEEN ENTERED; Nt ClillffiS BY TH m"T<(1~ - PROTHONOTARY :f.'F. +' :f. :+:+: .. Of :+:'f'f'+':+::+:+' . . . . . . . . :+::t'f!'f:+::+:+:+:+:l'+' +':+:'1' :+: . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J. . . .,/r;" 'Z fi1l~1 ~";J:.:i(~ f/{A /it! <7 /~t!['?"' :-~7 1'- . .. .. ~ .57 /1 I -"/ ~ y:, lie -