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HomeMy WebLinkAbout02-0451GOLDBERG, KATZMAN & SHIPMAN, P.C. Paul J. Esposito - I.D. #25454 Attorneys for Plaintiff 320 Market Street, Strawberry Square Post Office Box 1268 Han'isburg, PA 17108-1268 (7].7) 234-4161 LOKI LIN FULMER, Plaintiff, BRADFORD SCOTT FULMER, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. O.,.~ ~'q-q/ 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 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 at the Cumberland County Courthouse, Carlisle, Pennsylvania. 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 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 Ooldber& Katmmm & Shipman, P.C. P~ul J. F~, Esquire - I.D. ~5454 320 Market Street Post Office Box 126g Har~ PA 17108-126g Attomeys for Plainti~ LORI LIN FULMER, ' Plaintiff, : V. BRADFORD SCOTT FULMER, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW · IN DIVORCE WAIVER OF COUNSELING LORI LIN FULMER, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the Court require my spouse and I to participate in counseling. 2. I understand that the Court maintains a list of marriage counselors in the Office of the Prothonotary, which list is available to me upon request· 3. Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the Court. I verify that the statements made in this Waiver 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: ~' LORI L-~ FULME~, GOLDBERG, KATZMAN & SHIPMAN, P.C. Paul J. Esposito - I.D. #25454 Attorneys for Plaintiff 320 Market Streeq Strawbeny Square Post Office Box 1268 Han'isburg, PA 17108-1268 (717) 234-4161 LORI LIN FULMER, Plaintiff, V. BRADFORD SCOTT FULMER, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff, LORI LIN FULMER, is an adult individual, who currently resides at 1837~A Sterretts Gap Avenue, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant, BRADFORD SCOTT FULMER, is an adult individual who currently resides at 223 North Locust Point Road, Mechanicsburg, Cumberland County, Pennsylvania 17050. 3. Pennsylvania for a period of at least six (6) months previous to the filing of this Complaint. 4. The parties were married on September 16, 2000, in Jamaica. 5. There have been no prior actions of divorce or annulment filed by either of the parties hereto. Plaimiff avers that he has been a bona fide resident in the Commonwealth of 6. Plaintiffhas been advised of the availability of counseling and that Plalntiffhas the right to request that the Court require the parties to participate in counseling. 7. The Defendant in this action is not presently a member of the United States Armed Forces or of any of its allies. 8. Plaintiff requests the court to enter a decree of divorce. reference thereto. 10. COUNT I The averments of Paragraphs 1 through 8 herein are hereby incorporated by The marriage is irretrievably broken. WHEREFORE, Plaintiff prays Your Honorable Court to: (a) Enter a Decree in Divorce, divorcing the Plaimifffrom the bonds of matrimony heretofore existing between Plaintiff and Defendant; and (b) Order such other relief as the Court deems just and reasonable. Respectfully submitted, GOLDBERG, KATZMAN & SHIPMAN, P.C. PAUL J. pos o, SQUn,,E Post Office Box 1268 Hardsburg, PA 17018-1268 Supreme Court ID #25454 Attorneys for Plaintiff VERIFICATION I verify that the statements contained in the foregoing COMPLAINT IN DIVORCE are tree and correct to the best of my knowledge, information and belief. I understand that false statements contained herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities. Date: //-~'1-~' a. ,...-?~., ,_.~'Y~// .~,~-,~/'~- -' / .... LORI LI=N FULMER GOLDBERG, KATZMAN & SI-I~MAN, P.C. Paul J. Esposito - I.D. #25454 3~omeys for Plaintiff 0 Market S~xcet, Strawbeny Square POst Office Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 LORI LIN FULMER, : Plaintiff, BRADFORD SCOTT FULMER, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-451 CIVIL TERM IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) ) SS: COUNTY OF DAUPHIN ) Personally appeared before me, a Notary Public, in and for said Conunonwealth and County, PAUL J. ESPOSITO, ESQUIRE, who being duly sworn according to law deposes and says that on January 30, 2000 (sic), he sent a copy ora Complaim in Divorce filed with the Cumberland County Court of Common Pleas on January 25, 2002, by certified mail, return receipt requested, restricted delivery, to Bradford Scott Fulmer, and the return receipt card signed by Bradford S. Fulmer and shown as being delivered January 31, 2002, is attached hereto and made a part hereof. PAUL 3.~SPO~iTO, ESQUIRE Sworn to and subscribed before me this ~ day of J~:~ry, 2002. ~'l~Notary Public My Commission Expires: CHg.1. L BAKEI~. NOTArt PUBU~ 74805.1 HARRISbURg, DAUPHIN COUN1Y , I~f COMMISSION EXPIRE~ JA~ ~1~1, :~l~l m Goldber · rad~ord Scott Fulmer 223 l~orth Locust Point Road Nechanicsburg, PA 17050 from Item 17 OYae If YE~, er4m' deavery addree~ below: ONo : 3. 8e~,oe "1~ " [] I~sts~l ~ Cl C.O.O. GOLDBERG, KATZMAN & SHIPMAN, P.C. Paul $. Espo~ito - I.D. #25454 Attomey~ for Plaintiff 320 Market Street, Strawberry Square Post Office Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 LORI LIN FULMER, : Plaintiff, : BRADFORD SCOTT FULMER, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION- LAW NO. 02-451 IN DIVORCE ELECTION TO RESUME PRIOR NAME LORI LIN FULMER, being duly sworn according to law, deposes and says: That she is the Plaintiff in the above suit. That Plainfiffwishes to retake and hereafter use her prior name of LORI LIN WAGNER. AND, THEREFORE, gives written notice of avowing said intention, in accordance with the provisions of Title 54 Pa.C.S.A. §704. ' Lorn To be known as LORI LIN WAGNF_~ ~x 9~ ~ ) Sworn to and subscribed before me this day of~ 2002. Notar~ Public (_J My Commission Expires:/~-,~ NOTARIAL ~ I IIECHANIC~UR$ BOIIO,, CUMBEIL~D CO, I >~ 2'_ GOLDBERG, KATZMAN & SltlPMAN, P.C. Paul J. Esposito - I.D. #25454 Attorneys for Plaintiff 320 Market Street, S~awbewj Square Post Office Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 LORI LIN FULME~ Plaintiff, V. BRADFORD SCOTT FULMER, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION- LAW NO. 02-451 IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301 (c) of the Divorce Code was filed on January 25,2002. 2. The marriage of Plainfiffand Defendant is irretrievably broken and ninety 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 afcer 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. Section 4904, relating to unswom falsification to authorities. Now: 78961.1 z ~4 C. OLDBERG, KATZMAN & SI'I]PMAN, P.C. Paul J. Esposito - I.D. #25454 Attorneys for Plaintiff 320 Market Street, Strawberry Square Post Office Box 1268 Han'isburg, PA 17108-1268 (717) 234-4161 LORI LIN FULMER, Plaintiff, V. BRADFORD SCOTT FULMER, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION- LAW NO. 02-451 IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECI~EE UNDER SECTION 3301¢e~ 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 the Court and that a copy of the decree will be sent to me immediately after it is f'fled 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. Now: Lt~WAGNER / / / 78962.1 LORI LIN FULIVIER, Plaintiff, BRADFORD SCOTT FULMEI~ Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION- LAW NO. 02-451 IN DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF COUNSI~'.I,_ING 25,2002. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on January 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 ora final decree in divorce after service of notice of intention to request entry of the decree. 4. I have been advised of the availability of marriage counseling and I understand that I may request that the Court require that my spouse and I participate in counseling. I understand that the Court maintains a list of marriage counselors, which list is available to me upon request. Being so advised, I do not request that the Court require my spouse and I to participate in counseling prior to a divorce being handed down by the Court~ 5. I acknowledge that I received a copy of the Complaint in Divorce on or about January 31, 2002, by certified mail, restricted delivery. I verify that the statements made in this Affidavit are true and correct. I understand that t,t ment m,d to unswom falsification to authorities. /~i~.aD~ SCOgT ~rrr~R 78966.1 LORI LIN FULMER, Plaintiff, V. BRADFORD SCOTT FULMER, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION- LAW NO. 02-451 IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUF~T ENTRY OF A DIVORCE DECREE UNDER SECTION 3301¢c) OF ~ 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 fried 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 penglfie unswom falsification to authorities. / ~t~f 18 Pa.C.S. §4904 re~g~9~ Date: ~- t/~- O7---~ ~~~~/~ 78965.1 MARITAL SETTLEMENT AGREEMENT THIS AGREEMENT, made. tiffs __~__y of ~ 2002, by and between now known as LoCi Lin Wagner ' ' LORI LIN FULMER/(hereinafter '~3?IFE") and BRADFORD SCOTT FULMER, (hereinafter '~-IUSBAND"); W I TN E S S E T H: WItEREAS, the parties hereto were married on September 16, 2000, in Jamaica; and WHEREAS, the parties have no children of this marriage; and WHEREAS, difficulties have arisen between the parties and it is therefore their intention to live separate and apart for the rest of their lives and the parties are desirous of settling completely the economic and other rights and obligations between each other, including, but not limited to: the equitable distn'bution of the marital property; past, present and future support; alimony, alimony pendente lite; and, in general, any and all other claims and poss~le claims by one against the other or against their respective estates; and NOW TItEREFORE, in consideration of the covenants and promises hereinafter to be kept and performed by each party and intending to be legally bound hereby, the parties do hereby agree as follows: 1. ADVICE OF COUNSEL. The provisions of this Agreement and their legal effect have been fully explained to the parties by their respective counsel. WIFE is represented by Paul J. Esposito, Esquire of Goldberg, Katzman & Shipman, P.C. and HUSBAND is represented by Joanne Harrison Clough, Esquire of Reager & Adler, PC.. The parties further declare that each is executing this Agreement freely and voluntarily having either obtained sufficient knowledge and disclosure of their respective legal rights and obligations, or ff cmm~el has not been consulted, expressly waiving the fight to obtain such knowledge. The parties each acknowledge that thk Agreement is fair and equitable and is not the result of any fraud, coercion, duress, undue influence or collusion_ 2. DIVORCE ACTION. The parties acknowledge that their marriage is irretrievably broken and that they shall secure a mutual consent no fault divorce pursuant to § 3301(c) of the Divorce Code. A divorce action was filed by WIFE with the Court of Common Pleas of Cumberland County, Pennsylvania at Civil Action No. 02- 2151. January25, 2002. The parties agree to execute Affidavits of Consent for divorce and Waivers of Notice of Intention to Request Entry of a Divorce Decree concurrently with the execution of this Agreement. This Agreement shall remain in full force and effect after such time as a final decree in divorce may be entered with respect to the parties. The parties agree that the terms of this Agreement shall be incorporated into any Divorce Decree which may be entered with respect to them and specifically referenced in the Divorce Decree. This Agreement shall not merge with the divorce decree, but shall continue to have independent contractual significance. 3. DATE OF EXECUTION. The "date of execution" and "execution date" of thi~ 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 thin Agreement shall be defined as the date of execution by the party last executing this Agreement. 4. MUTUAL RELEASES. Each party absolutely and unconditionally release the other and the estate of the other from any and all fights and obligations which either may have for past, present, or future obligations, arising out of the marital relationship or otherwise, including all rights and benefits under the Pennsylvania Divorce Code of 1980, and amendments except as described herein. Each party absolutely and unconditionally releases the other and his or her heirs, executors, and estate from any claim~ arising by virtue of the marital relationship of the parties. The above release shall be effective whether such claims arise by way of widow's or widower's rights, family exemption, or under the intestate laws, or the right to take against the spouse's will, or the right to treat a lifetime conveyance Page 2 of 9 by the other as testamentary or all other fights of a surviving spouse to participate in a deceased spouse's estate, whether arising under the laws of Penmylvania, any state, Commonwealth, or territory of the United States, or any other country. Except for any cause of action for divorce which either party may have or claim to have, each party gives to the other by the execution of this ~ment an absolute and unconditional release from all claims whatsoever, in law or in equity which either party now has against the other. 5. FINANCIAL AND PROCEDURAL DISCLOSURE. The parties confirm that each has relied on the accuracy of the financial disclosure of the other as an inducement to the execution of this Agreement. Each party understands that he/she had the fight to obtain from the other party a complete inventory or list of all property that either or both parties owned at the time of separation or currently and that each party had the fight to have all such property valued by means of appraisals or otherwise. Both parties understand that they have fight to have a court hold hearings and make decisions on the matters covered by this Agreement. Both parties hereby acknowledge that this A4veement is fair and equitable, and that the term~ adequately provide for his or her interests, and that this Agreement is not a result of fraud, duress or undue influence exercised by either pan'y upon the other or by any person or persons upon either party. 6. SEPARATION/NON-INTERFERENCE. WIFE and HUSBAND may and shall, at all times hereafter, live separate and apart. They shall be free from any interference, direct or indirect, by the other in all respects as fully as if they were unmarried. Each may, for his or her separate use or benefit; conduct, carry on and engage in any business, occupation, profession or employment which to him or her may seem advisable. WIFE and HUSBAND shall not harass, disturb, or malign each other or the respective families of each other. 7. REAL PROPERTY. The parties do not own any joint real estate. WIFE specifically acknowledges that HUSBAND owns real property located at 223 North Locust Point Road, Mechanicsburg, Cumberland County, Pennsylvania and owns real property with improvements located at adjacent to the real property located at 223 North Locust Point Road. In consideration of HUSBAND tendering to WIFE the sum of FOUR Page 3 of 9 THOUSAND DOI I.~RS ($ 4,000.00) WIFE waives any and all claim she may have what so ever to said real property or any other property of HUSBAND as set forth in this Agreement. 8. DEBTS. If a party has acquired debt, the parties agree that each shall assume full and complete responsibility for his or her own debts. HUSBAND represents and warrants to WIFE that since the separation he has not, and in the future he will not, contract or incur any debt or liability for which WIFE or her estate might be responsible, and he shall indemnify and save WIFE harmless from any and all claims or demands made agaimt her by reason of such debts or obligations incurred by him since the date of said separation, except as otherwise set forth here~ WIFE represents and warrants to HUSBAND that since the separation she has not, and in the future she will not, contract or incur any debt or liability for which HUSBAND or his estate might be responsible, and he shall indemnify and save HUSBAND harmless from any and all claim or demands made agaimt him by reason of such debts or obligations incurred by her since the date of Said separation, except as otherwise set forth herei~ 9. RETIREMENT BENEFITS. HUSBAND hereby waives his right, title and interest to and of WIFE's pension and/or retirement and any and all other retirement benefits otherwise disclosed. WIFE hereby waives her right, title and interest to any of HUSBAND's pension and/or retirement and any and all other retirement benefits otherwise disclosed. The parties specifically waive any and all other retirement benefits obtained by the parties pre- marriage, during marriage, and post-separation. The individual who holds said benefits shal/own the property solely and individually. Each party waives their right to title and interest to the other party's benefit. Page 4 of 9 10. BANK ACCOUNTS. The parties acknowledge that they have divided the marital bank accounts to their satisfaction~ The bank accounts held solely in individual names shall become the sole and separate property of the party in whose name k is registered. Each party does hereby specifically waive and release his/her right, title and interest in the other party's respective accounts. 11. PERSONAL PROPERTY. Except as set forth here below, the parties hereto mutually agree that they have divided all furniture, household fumishlngs and personal property between them in a manner agreeable to both parties. The parties mutually agree that each party shall from and after the date of thi.q Agreement be the sole and separate owner of all tangible personal property in hi.q or her possession~ 12. BANKRUPTCY OR REORGANIZATION PROCEEDINGS. In the event that either party becomes a debtor in any bankruptcy or financial reorganization proceedings of any kind while any obligations remain to be performed by that party for the benefit of the other party pursuant to the provisions of this Agreement, the debtor spouse hereby waives, releases and relinquishes any right to claim any exemption (whether granted under State or Federal law) to any property remaining in the debtor as a defense to any claim made pursuant hereto by the creditor-spouse as set forth herein, including all attorney fees and costs incurred in the enforcement of this paragraph or any other provision of thi~ Agreement. No obligation created by this Agreement shall be discharged or dischargeable, regardless of Federal or State law to the contrary, and each party waives any and all right to assert that obligation hereunder is discharged or dischargeable. The parties mutually agree that in the event of bankruptcy or financial reorganization proceedings by either party in the future, any monies to be paid to the other party, or to a third party, pursuant to the terms of thi~ Agreement shall constitute support and maintenance and shall not be discharged in bankruptcy. Page 5 of 9 15. ALIMONY, SUPPORT, AND ALIMONY PENDENTE LITE. The parties hereby expressly waive, release, discharge and give up any and all fights or clalm~ which either may now or hereafter have for spousal support, alimony pendente lite, alimony, or maintenance. The parties further release any rights that they may have to seek modification of the terms of this Agreement in a court of law or equity, with the understanding that this Agreement constitutes a final determination for all time of either party's obligations to contribute to the support or maintenance of the other. 16. ATTORNEY FEES, COURT COSTS. Each party hereby agrees to be solely responsible for his or her own counsel fees, costs and expenses. Neither shall seek any contribution thereto from the other except as otherwise expressly provided herein. 17. ATTORNEYS' FEES FOR ENFORCEMENT. In the event that either party breaches any provision of this Agreement and the other party retains counsel to assist in enforcing the terms thereof, the breaching party will pay all reasonable attorneys' fees, court costs and expenses (including interest and travel costs, if applicable) which are incurred by the other party in enforcing the Agreement, whether enforcement is ultimately achieved by litigation or by amicable resolutior~. It is the specific Agreement and intent of the parties that a breaching or wrongdoing party shall bear the obligation of any and all costs, expenses and reasonable counsel fees incurred by the nonbreaching party in protecting and enforcing his or her rights under this Agreement. 18. WAIVER OF RIGHTS. Both parties hereby waive the following procedural rights: (a~) The right to obtain an inventory and the appraisement of all marital and non- marital property; (b.) The right to obtain an income and expense statement of either party; (c.) The right to have all property identified and appraised; (d.) The right to discovery as provided by the Pennsylvania Rules of Civil Procedure; and Page 6 of 9 (e.) The right to have the corot make all determinations regarding marital and non- marital property, equitable distribution, spousal support, alimony pendeme lite, alimony, counsel fees and costs and expenses. 19. MUTUAL COOPERATION. WIFE and HUSBAND shall mutually cooperate with each other in order to carry through the terms of thi.q Agreement, includin~g but not limited to, the signing of documents. 20. VOID CLAUSES. If any term, condition, clause or provision of this Agreement shall be determined or declared to be void or invalid in hw or other~vise, then only that term, condition, clause or provision shall be stricken from this Agreement, and in all other respects this Agreement shall be valid and continue in full force, effect and operation. 21. APPLICABLE LAW. This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania. 22. ENTIRE AGREEMENT. This Agreement COlltain,~ the entire understanding of the parties, and there are no representations, warranties, covenants or undertakings other than those expressly set forth herein. 23. CONTRACT INTERPRETATION. For purposes of contract interpretation and for the purpose in resolving any ambiguity herein, the parties agree that this Agreement was prepared jointly by the parties. Page 7 of 9 IN WITNESS WHEREOF, the parties hereto have set their hands and seals of the day first above written~ This Agreement is executed in duplicate, and in counterparts. WIFE and HUSBAND acknowledge the receipt of a duly executed copy hereof. Page 8 of 9 COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN SS: On this, the 8th day of May, 2002, before me, the undersigned officer, personally appeared LORI LIN FULMER, now known as Lori Lin Wagner, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. ~) ""' ' No~aryPublic My Commission Expires: :SS. COUNT3 On the ~f in and for the ~ FULMER , known to me (or instrument, and she acknowledges the ,2002, before me, a Notary Public the undesigned officer, personally appeared LORI LIN to be one of the parties executing the foregoing r free act and deed. IN WITNESS WHEREOF, I have hereunto set my above writte~ 1 the day and year first Notary Public CO O aWA OF PO, /v Z : :SS. COUN~ OF Ct~ [~ : Onthe ~~5'('~' dayof -~3h.~. ,2002, beforeme, a Notary Public in and for the Commonwealth of Pennsylvania, the uudesigned officer, personally appeared BRADFORD ScoTr FULMER, known to me (or satisfactory proven) to be on of the parties executing the foregoing immanent, and he acknowledges the foregoing imtmment to be hi~ free act and deed. IN WITNESS WHEREOF, I have hereunto set my hand and notarial seal the day and year first above written. Notary Public My Commi.qsion Expires: l Notarial Seal i Deborah L, Brenneman, Notary Public Camp Hill Bom, Cumbedand County My Commission Exaires June 18, 2002 Member 9~mr~sviv+m~a ,~ssociation ot Notaries Page 9 of 9 LORI LIN FULMER, Plaintiff, V. BRADFORD SCOTT FULMER, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION- LAW NO. 02451 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: Code. Ground for divorce: irretrievable breakdown under § 3301(c) of the Divorce 2. Date and manner of service of the Complaint: Certified Mail~ Restricted Delivery~ on January 31~ 2002, 3. (a) Date of execution of the affidavit of consent required by § 3301(c) of the Divorce Code: by Plaintiff $-14-2002; by Defendant $-10-2002 Co)(1) Date of execution of the Affidavit required by § 3301(d) of the Divorce Code: (2) Date of filing and service of Plaintiffs Affidavit upon the Defendant: Related claims pending: None. (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: Date Plaintiffs Waiver of Notice in § 3301(c) Divorce was filed with the prothonotary: $-14-2002 , Date Defendant's Waiver of Notice in § 3301(c) Divorce was filed with the prothonotary: 6-10.~OttOo~ey~.~forfffor~.~ IN THE COURT OF COMMON OF CUMBERLAND COUNTY STate Of LORI LIN F~, Plaintiff, VERSUS BRADFORD SCOTT FULMER, Defendant. PENNA. PLEAS NO. 02 451 DECREE IN DIVORCE AND NOW, 2002 IT iS ORDERED AND DECREED THAT LORI LIN FULMER , PLAINTIFF, AND BRADFORD SCOTT FULMER , 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;that the terms, provisions and conditions of a certain Marital Settlement Agreement between the parties dated June 10, 2002, are hereby incorporated in this Decree by reference as fully as though the same were set forth herein at length. Said Agreement shall not merge with, but shall survive this Decree. By THE COURT: ~~NOTARY