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Home My WebLink About01-3450Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge SUt~et New Cumberland, PA 17070 (717) 774-1445 LINDA C. PINOS, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v. · NO. 3¢5-0 : ROBERT J. PINOS, : CIVIL ACTION - LAW 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 judgement 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 and visitation of your children. When the grounds for a divorce is indignities or irreffievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Domestic Relations Office at the County Courthouse. 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 2 LIRERTY AVENUE Carlisle, Penn*ylvania 17013 (717) 249-3166 Barbara Sumple-Sullivan, Esquire Supreme Com~ //32317 549 Bridge Street New Cumberland, PA 1'/070 (717} 774-1445 LINDA C. PINOS, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v. : NO. 0/- ; ROBERT J. PINOS, : CIVIL ACTION - LAW Defendant : IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Linda C. Pinos, an adult individual residing at 419 Walnut Strea, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Defendant is Robert J. Pinos, an adult individual residing at 1527 Fisher Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. Both Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months prior to filing this complaint. 4. The Plaintiff and Defendant were married on August 11, 1973 in Chester County, Pennsylvania. 5. There are three (3) adult children born of this m~rriage. 6. The parties separated on August 27, 2000. 7. There have been no prior actions for divorce or annulment between the pa~es. 8. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 9. Plaintiff has been advised that counseling is available and that Plaintiff has the right to request that the court require the parties to participate in counseling. COUNT I - DIVORCE 10. The averments in paragraphs I through 9, inclusive, of Plaintiff's Complaint are incorporated herein by reference thereto. 11. The marriage is irretrievably broken and no possibility of reconciliation exists. WHEREFORE, Plaintiff requests entry of a divorce decree in her favor in accordance with § 3301 of the Pennsylvania Divorce Code. EQUITABLE DISTI~mUTION 12. The averments in paragraphs 1 through 11 of Plaintiff's Complaint are incorporated herein by reference thereto. 13. The Plaintiff requests the Court to equitably divide, distribute or assign the marital property between the parties in such proportion as the Court deems just after consideration of all relevant factors. WHEREFORE, Plaintiff requests this Court to equitably divide said property in accordance with Section 401(d) of the Pennsylvania Divorce Code. WHEREFORE, Plaintiff, Linda C. Pinos, prays this Honorable Court to enter judgment: A. Awarding Plaintiff a decree in divorce; B. Equitably distributing the marital property; and C. Awarding other relief as the Court deems just and r~o~e. Dated: June 5, 2001 , Barbara Sumple-Sullivan, Es~e Attorney for Plaintiff 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. No. 32317 Bnrbara Sumple-Sullivan, Esquire Supreme Court//32317 549 Bridge Street New Cumberland, PA 1'/070 (717) 774-1445 LINDA C. PINOS, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v. : NO. : ROBERT J. PINOS, : CIVIL ACTION - LAW Defendant : IN DIVORCE AFFIDAVIT REGARDING COUN.gg.I.INC. 1. I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling. 2. I understand that the Court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me upon request. 3. Being so advised, I do not require that the Court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the Court. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A Section 4904 relating to unswom falsification to authorities. LINDA C. PINOS Bnrbnra Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-144~ LINDA C. PINOS, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v. : NO. : ROBERT $. PINOS, : CIVIL ACTION - LAW Defendant : IN DIVORCE I, LINDA C. PINOS, hereby certify that the facts set forth in the foregoing COMPLAINT IN DIVORCE are true and correct to the best of my knowledge, information and belief. I understapA that any false statements made herein are subject to penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. Dated: .~/2 b/~/ X~4~ ~ ~/~f~ C. PINO Barbara Sumple-Sul{ivan, Esquire Supreme Court #323 { 7 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 LINDA C. PINOS, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v. : NO. 2001-03450 : ROBERT $. PINOS, : CIVIL ACTION - LAW Defendant : IN DIVORCE AFFIDAVIT OF ~EI~VICE I, Barbara Sumple-Sullivan, Esquire, do hereby certify that I served a copy of the Complaint in Divorce in the above-captioned matter by United States Mail, Restricted Delivery, Certified No. 7000 0600 0028 3892 5008, Return Receipt Requested, on the above- named Defendant, Robert J. Pinos, on June 6, 2001 at Defendant's last known address: 1527 Fisher Road, Mechanlcsburg, PA 17055. The original receipt and return receipt card are attached hereto as Exhibit "A". I hereby certify that the facts set forth above are true and correct to the best of my knowledge, information and belief. I understand that any false statements made herein are subject to penalties of 18 Pa. C.S.A. §4904 relating to u~.~on authorities. tB~'~arbam Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 (717)-774-1445 Supreme Court ID//32317 Attorney for Plaintiff Ill ~'~ ~_, ..' ~- .,. -,. J.' ': 1 m y~.~ ..~. J.~.[~inos .............................................. III '""llllllii;,ll · ~omplete ~tem$1, 2,~'~i 3' Ns° c°mp~ete tt~n 4 ~ ~ ~ Is d~. I~urn~~t~ ~at ~ ~ ~rn ~e c~ ~'. ~. ~~ ~G~ ~~ ~k ~ ~m ~1~'~ Mon~e~ffs~~' 1527 ~s~ ~ ~cs~ ~ 17055 ~ RESTRICTED ~ DELIVERY ~~')~ Bnrbara Sumple-Sullivan, Esquire Supreme Coun #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 LINDA C. PINOS, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v. : NO. 2001-03450 : ROBERT J. PINOS, : CIVIL ACTION - LAW Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on June 5, 2001. 2. The marriage of the Plaintiffand Defendant is irretrievably broken. Ninety days have elapsed since the filing and service of the Complaint. 3. I consent to the emry of a final decree of divorce after service of notice of intention to request entry of the decree. 4. I understand that I may lose fights concerning alimony, division of property, lawyer's fees or expenses ifI do not claim them before a divorce is granted. 5. I verify that the statements made in this affidavit are Rue and correct. I understand that false statements are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unswom falsification to authorities. DATE: ',~/'~7/~ /~ ~.7/~ ,mos Baffoara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 LINDA C. PINOS, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v. : NO. 2001-03450 : ROBERT $. PINOS, : CIVIL ACTION - LAW Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(e) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I undemtand that I may lose rights concerning alimony, division ofpmperty, lawyer's fees or expenses ifl 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 aider it is filed with the prothonotary. I verify that the statements made in this affidavit are lrue and correct. I understand that false statement herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unswom falsification to authorities. LII A Barbara Sumplc-Sullivan, Esquire Supreme Court//32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 LINDA C. PINOS, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v. : NO. 2001-03450 : ROBERT J. PINOS, : CIVIL ACTION - LAW Defendant : IN DIVORCE NOTICE OF INTENTION TO RESUME PRIOR NAME NOTICE is hereby given that Plaintiff in the above-captioned matter, having been granted a final decree in divorce on the 29~.h day of t. lay ,2002, hereby intends to resume and hereafter use the previous name of Linda I. Cheney and gives this written notice avowing her intention in accordance with the provisions of the Act of 54 Pa. C.S. §704. ~n'da C. Pinos TO BE KNOWN AS: Linda I. Cheney~ COMMONWEALTH OF PENNSYLVANIA : : SS. COUNTY OF On th/s, the 31 st day of lqa¥ ,2002, before me, a Notary Public, the undersigned officer, personally appeared Linda C. Pinos, known to me (or satisfactorily proven) to be the person whose name is subscribed to the w/thin instrument, and acknowledged that she executed the foregoing Notice of Intention to Resume Prior Name for the purposes contained therein. IN W~WHEREOF, I hereunto set my hand and official seal. ~ (SEAL) LINDA C. PINOS, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : vs. : CIVIL ACTION - LAW : NO. 01-3450 CIVILTERM ROBERT J. PINOS, : Defendant : IN DIVORCE PROPERTY SEI'rLEMENT AND SEPARATION AGREEMENT THIS AGREEMENT made this /~,~ dayof (,~.,~ ,2002, BY AND BETWEEN ROBERT J. PINOS, of 1527 Fisher Road, Mechanicsburg, Cumberland County, Pennsylvania, hereinafter referred to as Husband, AND LINDA C. PINOS, of 2048 Chestnut Street, Harrisburg, Pennsylvania 17104, hereinafter referred to as Wife. RECITALS: R.I: The parties hereto are husband and wife, having been joined in mardage on August 11, 1973 in Chester County, Pennsylvania; and R.2: A Complaint for Divorce has been filed in the Court of Common Pleas of Cumberland County, Commonwealth of Pennsylvania, to Number 01-~"-450, Civil Term; and R.3: The parties hereto desire to settle fully and finally their respective financial and property rights and obligations including, but not limited, of all matters between them relating to the ownership of real and personal property, claims for spousal support, alimony, alimony pendente lite. NOW THEREFORE, in consideration of the covenants and promises hereinafter to be mutually kept and performed by each party, as well as for other good and valuable consideration and intending to be legally bound, it is agreed as follows: (1) SEPARATION: It shall be lawr~l 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 from time to time may choose or deem fit, free from any control, restraint or interference from the other. Neither party will molest the other or endeavor to compel the other to cohabit or dwell with him or her by any legal or other proceeding. Each party shall be free of the interference, authority or contact by the other as if he or she was single and unmarried except as maybe necessary to carry out the terms of this agreement. (2) DIVORCE: The parties acknowledge that the marriage is irretrievably broken and that they will secure a mutual consent no-fault divorce decree in the above- captioned divorce action. Upon the execution of this Agreement, the parties shall execute and file Affidavits of Consent and Waiver of Notice Forms, necessary to finalize said divorce. (3) REAL PROPERTY,: The parties are the owners of certain real estate with improvements thereon erected at 1527 Fisher Road, Mechanicsburg, Pennsylvania. On the same day as the date of this Agreement, Wife will execute a special warranty deed transferring to Husband all her right, title and interest in the marital property. Said deed shall be held in escrow by Barbara Sumple-Sullivan, Esquire, until such time as the Affidavits of Consent have been signed and filed and the property refinanced as set out below. Husband shall pay for all household expenses including, but not limited to, 2 mortgages and liens of record, utility bills, insurance and real estate taxes in connection with said pmperbj. With regard to all such expenses, Husband hereby shall hold Wife harmless and indemnify Wife from any loss thereon. Husband shall refinance said mortgage obligation within 60 days from the date of this Agreement at which time the escrow deed shall be released to him. (4) DEBT: A. MARTIAL DEBT: The parties acknowledge that each had in his or her own name certain debt which might be considered madtal debt. Each party will be solely responsible for the payment of any debt in his or her name, and shall indemnify and hold the other party harmless from claims of any creditor which he or she hereby agrees to pay. B: Post Separation Debt: In the event that either party contracted or incurred any debt since the date of separation, the party who incurred said debt shall be responsible for the payment thereof mcjardless of the name in which the debt may have been incurred. The parties disagree as to the date of separation, but both aver that there are no debts in joint names and that each has incurred no liability for which the other may be liable, at least since the filing of the Complaint in Divorce on June 5, 2001. C: Future Debt: From the date of this agreement neither party shall contract or incur any debt or liability for which the other party or his or her property or estate might be responsible and shall indemnify and save the other party harmless from any and all claims or demands made against him or her by reason of debts or obligations incurred by the other party. 3 (5) MOTOR VEHICLES: Each party relinquishes any right, title and interest he or she may have to any and all motor vehicles currently in possession of the other party. There are no vehicles joinlJy titled. (6) TANGIBLE PERSONAL PROPERTY: The parties hereto mutually agree that they have effected a satisfactory division of the furniture, household furnishings, appliances, tools and other household personal prope,~ between them, and they mutually agree that each party shall from and after the date hereof be the sole and separate owner of all such property presently in his or her possession whether said property was heretofore owned jointly or individually by the parties hereto. This agreement shall have the effect of an assignment or bill of sale fi'om each party to the other for such property as may be in the individual possession of each of the parties hereto. (7) INTANGIBLE PERSONAL PROPERTY: Each party hereby relinquishes any right, title or interest he or she may have in or to any intangible personal property currenfly rifled in the name of or in the possession of the other party, including, but not limited to, stocks, bonds, insurance, bank accounts, individual reflrement accounts, employment benefits incl~Jding retirement accounts, savings plans, pension plans, stock plans, 401K plans and the like. On the same day as Husband refinances the marital home as set out in Paragraph 3 above, upon the passing of the rescission period, Husband will pay to Wife $65,000.00. (8) WAIVER OFALIMONY: The parties acknowledge that each has income and assets saflsfactory to his and her own reasonable needs. Each party 4 waives any claim he or she may have one against the other for alimony, spousal support or alimony and alimony pendente lite. (9) ADVICE OF COUNSEL: The parties hereto acknowledge that each has been notified of his or her right to consult with counsel of his or her choice, and have been provided a copy of this Agreement with which to consult with counsel. Husband is represented by Carol J. Lindsay, Esquire, and W'~e is represented by Barbara Sumple- Sullivan, Esquire. Each party acknowledges and accepts that this Agreement is, under the circumstances, fair and equitable, and that it is being entered into freely and voluntarily after having received such advice and with such knowledge as each has sought from counsel, and the execution of this agreement is not the result of any duress or undue influence, and that it is not the result of any improper or illegal agreement or agreements. Each party shall pay his or her own attorney for all legal services rendered or to be rendered on his or her behalf. (10) ADDITIONAL INSTRUMENTS: Each of the parties shall from time to time, at the request of the other, execute, acknowledge and deliver to the other party any and all further instruments +.hat may be reasonably required to give full force and effect to the provisions of this Agreement. (11) INCOME TAX: The parties have heretofore filed joint Federal and State Tax returns. Both par~ies agree that in the event any deficiency in Federal, state or local income tax is proposed, or assessment of any such tax is made against either of them, each will indemnify and hold harmless the other from and against any loss or liability fur any such tax deficiency or assessment and any interest, penalty and expense incurred in connection therewith. Such tax, interest, penalty or expense shall be paid solely and entirely by the individual who is finally determined to be the cause of the misrepresentations or failures to disclose the nature and extent of his or her separate income on the aforesaid joint returns. (12) BANKRUPTCY: The parties hereby agree that the provisions of this Agreement shall not be dischargeable in Bank,~Jptcy 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 dght to declare this Agreement to be null and void and to terminate this Agreement in which event the division of the parties' martial assets and all other rights determined by this Agreement including alimony shall be subject to court determination the same as if this Agreement had never been entered into. (13) COMPLETE DISCLOSURE: The parties do hereby warrant, represent, acknowledge and agree that each is fully and completely informed of, and is familiar with, the wealth, real and personal property, estate and assets, eamings and income of the other and has made any inquiry he or she desires into the income or estate of the other and received any such information requested. Each has made a full and complete disclosure to the other of his and her entire assets, liabilities, income and expenses and any further enumeration or statement thereof in this Agreement is specifically waived. (14) RIGHTS AND RESPONSIBILITIES: Husband and Wife acknowledge that each of them has read and understand his and her rights and responsibilities under 6 this Agreement and that they have executed this Agreement under no compulsion to do so but as a voluntary act. (15) FULL SE'I'rLEMENT: Except as herein otherwise provided, each party hereby releases the other from any and all claims, or demands up to the date of execution hereof. It is further specifically understood and agreed by and between the parties hereto that each party accepts the provisions herein made in lieu of and in full settlement and satisfaction of any and all of said party's rights against the other for past, present and future claims on account of support, maintenance, alimony, alimony pendente lite, counsel fees, costs and expenses, equitable distribution of marital property and any other claims of the party, including all claims which have been raised or may be raised in an action for divorce. (16) RELEASE OF ALL CLAIMS: Except as may be otherwise specifically provided in this Agreement, Husband and Wife, for themselves, their heirs, representatives and assigns, each hereby forever releases, remises, discharges and quitclaims the other, and such other's heirs, representatives, assigns and estate, from and with respect to the following: A. All liability, claims, causes of action, damages, costs, contributions and expenses or demands whatsoever in law or in equity; B. All rights, title, interest or claims in or to any property of the other, whether real, personal or mixed and whether now owned or hereafter acquired; C. Ail rights of courtesy and dower and all claims or rights in the nature of courtesy and dower;, 7 D. All widow or widower's rights; E. All fight, title, interest or claim in or to the other's estate, whether now owned or hereafter acquired, including but not limited to all rights or claims: (1) to take against the other's will; (2) under the laws of intestacy; (3) to a family exemption or similar allowance; and (4) all other rights or authority to participate or intervene in a deceased spouse's estate in any way, whether arising under the laws of Pennsylvania or any other country, territory, state or political subdivision. F. All rights or claims to any accounting; G. All rights, claims, demands, liabilities and obligations adsing out of or in connection with the madtal relationship or the joint ownership of property, whether real, personal or mixed; H. All fights, claims, demands, liabilities and obligations adsing under the provisions of the Pennsylvania Divome Code, as the same may be amended from time to time, and under the provisions of any similar statute enacted by any other country, state, territory or political subdivision; I. All dghts, claims, demands, liabilities and obligations each party now has, or may hereafter have, against or with respect to the other. 8 (17) GOVERNING LAW: This Agreement shall be construed under the law of the Commonwealth of Pennsylvania. If any provision of this Agreement is determined to be invalid or unenforceable, all other provisions shall continue in full force and effect. (18) INCORPORATION INTO DECREE: In the event that either of the parties shall recover a final judgment or decree of absolute divorce against the other in a court of competent jurisdiction, the provisions of this Agreement may be incorporated by reference or in substance but shall not be merged into such judgment or decree and this Agreement shall survive any such final judgment or decree of absolute divorce and shall be entirely independent thereof. (19) BREACH: In the event that either party breaches any provision of this Agreement, he or she shall be responsible for any and all costs incurred to enforce the Agreement, including, but not limited to, court cost and counsel fees of the other party. In the event of breach, the other party shall have the right, at his or her election; to sue for damages for such breach or to seek such other and additional remedies as may be available to him or her. (20) ENTIRE UNDERSTANDING: This Agreement constitutes the entire understanding between the parties and there are no covenants, conditions, representations, or agreements, oral or written, of any nature whatsoever, other than those herein contained. (21) AGREEMENT BINDING ON PARTIES AND HEIRS: This Agreement shall bind the parties hereto, their respective heirs, executors and assigns. IN WITNESS WHEREOF, the parties hereto intending to be legally bound have hereunto set their hands and seals the day and year first written above. WITNE~. /"7 ~.J Linda C. Pinos 10 Barbara Sumple-Sullivan, Esquire Supreme Cour~ #32317 549 Bridge S~eet New Cumberland, PA 17070 (7[7) 774-1445 LINDA C. PINOS, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v. : NO. 01-3450 : ROBERT J. PINes, : CIVIL ACTION - LAW 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 §3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: United States Mail, Certified Mail, Restricted Delivery on June 6, 2001. 3. Date of execution nfthe affidavit of consent required by § 3301(c) of the Divorce Code: by PlaintiffMay 20, 2002; by Defendant May 6, 2002. 4. Related claims pending: Ail matters have been resolved pursuant to the Property Settlement and Separation Agreement reached by the parties dated April 16, 2002 and incorporated, but not merged into the Decree. 5. Date Plaintiff's Waiver of Nntice in §3301(c) Divorce was filed with Prothonotary: May 21, 2002. Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with Prothonotary: May 14, 2002. Dated: MayO~, 2002 .. /Barbara Sumple-Sulllvan, Esqulrc 549 Bridge S~reet New Cumberland, PA ! 7070-193 i (717)-774-1445 Supreme Court ID//32317 Attorney for Plaintiff Barbara Sumpl~-Sullivan, Esquir~ Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 LINDA C. PINOS, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : vi. : NO. 01-3450 : ROBERT J. PINOS, : CIVIL ACTION - LAW Defendant : IN DIVORCE CERTIFICATE OF SERVICE I, Barbara Sumple-Sullivan, Esquire, do hereby certify that on this date, I served a true and correct copy of the foregoing Praecipe to Transmit Record, in the above-captioned matter upon the following individual by first class mail, postage prepaid, addressed as follows: Carol J. Lindsay, Esquire Saidis, Shuff, Flower & Lindsay 26 West High Stxeet Carlisle, PA 17033 · ? p - ivan, Esquire Attorney for Plaintiff 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. No. 32317 IN THE COURT OF COMMON PLEAS OFCUMBERLAND COUNTY STATE OF .~_~~ PENNA. LIA~IA C. PIN0S~ Plaintiff N O. 2001-3450 VERSUS ~0R~T J. PIN0~, Defe~aut DECREE IN DIVORCE AND NOW, ~"] 2 ~ · 2002 , IT IS ORDERED AND r.T]~lA C. DECREED THAT , PLAINTIFF, AND , DEFENDANT, 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; Ail matters have been resolved pursuant to the Property Settlement and Separati~ Agreement reached by the parties dated April 16, 2002 and incorp~rat~ -' ~' J' PROTHONOTARY