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HomeMy WebLinkAbout04-5003TERRY WALCK, Plaintiff : 1N THE COURT OF COMMON PLEAS OF : CU]VlBERLAND COUNTY, PENNSYLVANIA VS. TAMMY WALCK, Defendant : CXWL ^CT ON - LAW i NO. 2004-.590-3 : IN DIVORCE NOTICE TO DEFEND AND CLAIM OF RIGHTS You have been sued in Court. If you wfsh 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 plaintirT 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 at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from the list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty (20) days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling 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 A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWh~ER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 TERRY WALCK, Plaintiff VS. TAMMY WALCK, Defendant 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : NO. 2004 - 5'g~oo : IN DIVORCE COMPLAINT UNDER SECTIONS 3301 (c} and 3301{d) OF THE DIVORCE CODE NOW comes Plaintiffand for cause of action against Defendant who says: COUNT I - DIVORCE Plaintiff is Terry Walck, who resides in Mt. Holly Springs, Cumberland County, Pennsylvania with a mailing and street address of 24 South Baltimore Avenue, Apt. I, Mt. Holly Springs, PA 17065. Defendant is Tammy Walck, who resides in Boiling Springs, Cumberland County, Pennsylvania with a mailing and street address of P.O. Box 86, 105 Walnut Street, Boiling Springs, PA 17007. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this complaint. Plaintiffand Defendant were married on September 11, 1999 in Cumberland County, Pennsylvania. There have been no prior actions for divorce or annulment of marriage between the parties in this or any other jurisdiction. The marriage is irretrievably broken. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request the court to require the parties to participate in counseling. Defendant is not a member of the Armed Services of the United States or any of its allies. The causes of action and sections of the Divorce Code under which the Plaintiff is proceeding are: A. Section 3301(c): The marriage is irretrievably broken. B. Section 3301(d): The marriage is irretrievably broken and the parties have been living separately and apart. If the parties do not agree to proceed under Section 3301 (c) of the Divorce Code, the Plaintiff will submit an Affidavit alleging that the parties have lived separately and apart for at least two (2) years and that the marriage is irretrievably broken, once the parties have live separate and apart for two years. The parties separated on September 6, 2004. WHEREFORE, Plaintiffrequests your Honorable Court to enter a Decree of Divorce, divorcing the parties from the bonds of matrimony. Respectfully submitted, Esquire Attorney for Plaintiff Law Offices of LopezNeuharth LLP 401 East Louther Street, Suite 101 Carlisle, PA 17013 (717) 258-9991 VERIFICATION I verify that the statements made in this document are true and correct to the best of my knowledge, information and belief 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:/d2 -/- c~,c.-" MARRIAGE SETTLEMENT AGREEMENT THIS AGREEMENT made this -.1J1!'day of 9 ~(f between TERRY WALCK, (hereinafter referred to as "HUSBAND") and TAMMY WALCK, , 2005, by and (hereinafter referred to as "WIFE"). WITNESSETH: WHEREAS, HUSBAND and WIFE were lawfully married on September 11, 1999, and separated on or about September 6, 2004; and WHEREAS, diverse, unhappy differences, disputes and difficulties have arisen between the parties and it is the intention of HUSBAND and WIFE to live separate and apart for the rest of their natural lives, and the parties hereto are desirous of settling fully and finally their respective financial and property rights and obligation as between each other, including, but not limited to the settling of all matters between them relating to the ownership and equitable distribution of real and personal property, the settling of all claims and possible claims by one against the other or against their respective estates, and the equitable distribution of property and alimony for each party. The parties hereto agree and covenant as follows: 1. The parties intend to maintain separate and permanent domiciles and to live apart from each other It is the intent and purpose of this Agreement to set forth the respective rights and duties of the parties while they continue to live apart from each other 2. The parties have attempted to divide their matrimonial property in a manner which conforms to a just and right standard, with due regard to the rights of each party. It is the intent of the parties that such division shall be final and shall forever determine their respective rights. The division of existing marital property is not intended by the parties to constitute in any way a sale or exchange of assets. 3. Further, the parties agree to continue living separately and apart from the other at any place or places that he or she may select as they have heretofore been doing. Neither party shall molest, harass, annoy, injure, threaten or interfere with the other party in any matter whatsoever. Each party may carry on and engage in any employment, profession, business or other activity as he or she may deem advisable for his or her sole use and benefit. Neither party shall interfere with the uses, ownership, enjoyment or disposition of any property now owned and not specified herein or property hereafter acquired by the other. 4. The consideration for this contract and agreement is the mutual benefit to be obtained by both of the parties hereto and the covenants and agreements of each of the parties to the other. The adequacy of the consideration for all agreements herein contained is stipulated, confessed, and admitted by the parties, and the parties intend to be legally bound hereby. Each party to the Agreement acknowledges and declares that he or she, respectively: (1) Is represented by counsel of his or her own choosing, or if not represented by counsel, understands that he or she has the right to counsel: HUSBAND is represented by Megan Malone, Esquire of Lopez Neuharth LLP; WIFE is represented by Nathan Wolf, Esquire; (2) Is fully and completely informed of the facts relating to the subject matter of this Agreement and of the rights and liabilities of the parties; (3) Is entering into this Agreement voluntarily after receiving the advice of counsel or after choosing not to consult an attorney; (4) Has given careful and mature thought to the making of this Agreement; (5) Has carefully read each provision of this Agreement; (6) Fully and completely understands each provision of this Agreement, both as to the subject matter and legal effect of each provision. This Agreement shall become effective immediately as of the date of execution. 5. It is the purpose and intent of this Agreement to settle forever and completely the interest and obligations of the parties in all property that they own separately, and all property that would qualifY as marital property under the Pennsylvania Divorce Code, Title 23, Section 40 I ( e), and that is referred to in this Agreement as "Marital Property," as between themselves, their heirs and assigns. The parties have attempted to divide their Marital Property in a manner that conforms to a just and fair standard, with due regard to the rights of each party. The division of existing Marital Property is not intended by the parties to constitute in any way a sale or exchange of assets, and the division is being effected without the introduction of outside funds or other property not constituting a part of the marital estate. It is the further purpose of this Agreement to settle forever and completely any obligation under the Pennsylvania Divorce Code relating to spousal support or alimony. 6. Each party represents and warrants that he or she has made a full and fair disclosure to the other of all of his or her property interests of any nature, including any mortgage, pledge, lien, charge, security interest, encumbrance, or restriction to which any property is subject. Each party further represents that he or she has made a full and fair disclosure of all debts and obligations of any nature for which he or she is currently liable or may become liable. Each further represents and warrants that he or she has not made any gifts or transfers for inadequate consideration of Marital Property without the prior consent of the other. Each party acknowledges that, to the extent desire, he or she has had access to all joint and separate State and Federal Tax Returns filed by or on behalf of either or both Parties during marnage. 7. REAL ESTATE: HUSBAND has transferred all right, title, and interest which he may have in that marital property located at 105 Walnut Street, Boiling Springs, Cumberland County, Pennsylvania 17007, and any improvements thereon to WIFE and releases all claims which he may have regarding said real estate in accordance with this paragraph. WIFE agrees to pay any outstanding payments on any mortgages on said property, as well as all real estate taxes, insurance, and any maintenance and repair costs, and hold HUSBAND harmless from any obligations on said payments and indemnifY him if any claim is made against him. In exchange, HUSBAND will pay to WIFE the sum of$7,500.00 over the course of three years, to be paid in monthly payments of $208.00 beginning in July, 2005. 8. SUPPORT: It is the mutual desire of the parties that HUSBAND will not be required to pay spousal support, alimony, alimony pendente lite, or any other financial support to WIFE, and that WIFE will not be required to pay spousal support, alimony, alimony pendente lite, or any other financial support to HUSBAND. The parties thereby waive any rights they have to received spousal support, alimony or alimony pendente lite payments from the other prior to or following the entry of the Divorce Decree in this matter. 9. PERSONAL PROPERTY: The parties agree that the personal property has been divided to the parties' mutual satisfaction. WIFE hereby waives all right, title and interest which she may have in any personal property of the HUSBAND. HUSBAND likewise waives any right, title and interest which he has in the personal property of WIFE. Henceforth, each of the parties shall own, have and enjoy independently of any claim or right of the other party, all items of personal property of every kind, nature and description and wherever situated, which are then owned or held by or which may hereafter belong to HUSBAND or WIFE with full power to HUSBAND or WIFE to dispose of the same as fully and effectually, in all respects and for all purposes as if he or she were unmarried. 10. AUTOMOBILES: The parties agree that the automobiles have been divided to the parties' mutual satisfaction. WIFE hereby waives all right, title and interest in any vehicle that HUSBAND currently owns or any vehicle he may own in the future. HUSBAND shall hold WIFE harmless for any and all liability associated with the use and purchase of any vehicle he may own, and shall be solely responsible for all insurance and other financial responsibility associated with said vehicle. HUSBAND hereby waives all right, title and interest in any vehicle that WIFE currently owns or any vehicle she may own in the future. WIFE shall hold HUSBAND harmless for any and all liability associated with the use and purchase of any vehicle she may own, and shall be solely responsible for all insurance and other financial responsibility associated with said vehicle. 11 MARITAL DEBTS: It is further mutually agreed by and between the parties that WIFE shall assume all liability for and pay and indemnity HUSBAND against all debts incurred by WIFE after the date of separation. WIFE represents and warrants to HUSBAND that since the parties' mutual separation she has not contracted or incurred any debt or liability for which HUSBAND or his estate might be responsible and WIFE further represents and warrants to HUSBAND that she will not contract or incur any debt or liability after the execution of this Agreement, for which HUSBAND or his estate might be responsible WIFE shall indemnity and save HUSBAND harmless from any and all claims or demands made against him by reason of debts or obligations incurred by her. HUSBAND shall assume all liability for and pay and indemnity the WIFE against all debts incurred by HUSBAND after the date of separation. HUSBAND represents and warrants to WIFE that since the parties' marital separation he has not contracted or incurred any debt or liability for which WIFE or her estate might be responsible and HUSBAND further represents and warrants to WIFE that he will not contract or incur any debt or liability after the execution of this Agreement, for which WIFE or her estate might be responsible. HUSBAND shall indemnity and save WIFE harmless from any and all claims or demands made against her by reason of debts or obligations incurred by him. The parties further acknowledge the existence of credit cards in their own names for which each shall be responsible for the payment of and indemnify and hold harmless the other party from said balances. 12. INSURANCE AND EMPLOYEE BENEFITS: The parties agree that any employee benefits of HUSBAND or WIFE including but not limited to retirement, profit sharing or medical benefits of either party, shall be their own. HUSBAND waives all right, title and claim to WIFE'S employee benefits, and WIFE waives all right, title and claim to HUSBAND'S employee benefits. 13. BENEFITS. STOCK AND BANK ACCOUNTS: WIFE agrees to waive all right, title and interest which she may have in the savings or checking or any other bank accounts of HUSBAND and likewise HUSBAND agrees to waive all right, title and interest which he may have in the savings or checking or any other bank accounts of WIFE. 14. DIVORCE: The parties both agree to cooperate with each other in obtaining a final divorce of the marriage. It is agreed that the parties will execute and file the consents necessary to obtain the divorce. Any party who fails to cooperate with obtaining the divorce shall pay all the costs and legal fees of the party who is seeking the divorce. 15. BREACH: If either party breaches any provisions of this Agreement, the other party shall have the right, at his or her election, to sue for damages for such breach or seek such other remedies or relief as may be available to him or her, and the party breaching this contract shall be responsible for payment ofIegal fees and costs incurred by the other in enforcing their rights under this Agreement. 16. 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 that may be reasonably required to give full force and effect to the provisions of this Agreement. 17. VOLUNTARY EXECUTIONS: The provisions of this Agreement and their legal effect have been fully explained to the parties by their respective counsel, are fully understood by both parties, and each party acknowledges that the Agreement is fair and equitable, that it is being entered into voluntarily, an that it is not the result of any duress or undue influence. It is the parties' intent that this Agreement does not merge with the Divorce Decree, but rather shall continue to have independent contractual significance. Each party maintains his or her contractual remedies or any other remedies provided by law or statute. Those remedies shall include, but not be limited to, damages resulting from breach of this Agreement, specific enforcement of this Agreement and remedies pertaining to failure to comply with an order of court or agreement pertaining to equitable distribution, alimony, alimony pendente lite, counsel fees and costs as set forth in the Pennsylvania Divorce Code or other similar statutes now in effect and as amended or hereafter enacted. 18. ENTIRE AGREEMENT: This Agreement contains the entire understanding of the parties and there are no representations, warranties, covenants or undertakings other than those expressly set forth herein. 19. APPLICABLE LAW: This Agreement shall be construed under the Laws of the Commonwealth of Pennsylvania. 20. PRIOR AGREEMENTS: It is understood and agreed that any and all property settlement agreements which mayor have been executed prior to the date and time of this Agreement are null and void and of no effect. 21. PAYMENT OF COSTS: Each party shall be responsible for their own attorneys fees and costs incurred in the settlement of the divorce and economic issues surrounding this divorce. 22 WAIVER OF CLAIMS AGAINST ESTATES: Except as herein otherwise provided, each party may dispose of his or her property in any way, and each party hereby waives and relinquishes any and all rights he or she may now have or hereafter acquire, under the present or future laws of any jurisdiction, to share in the property or the estate of the other as a result of the marital relationship, including without limitation, dower, courtesy, statutory allowance, widow's allowance, right to take in intestacy, right to take against the Will of the other, and right to act as administrator or executor of the other's estate, and each will, at the request of the other, execute, acknowledge and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interests, rights and claims. IN WITNESS WHEREOF, the parties hereunto have set their hands and seals the day and year first above written. WITNESS: LfIJl/{J '[ w~- " .i".,"Ltl' }) (,'111..1n ',oJ '(. i- ~ TAMMY W~LCK (SEAL) JJt14-1 fi~ ~1 JJ.1 TERR WALCK (SEAL) COMMONWEALTH OF PENNSYLVANIA : SS: COUNTY OF CUMBERLAND PERSONALLY APPEARED BEFORE ME, this 17 day of }W//fJ1 2005, a Notary Public" TAMMY WALCK, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Marriage Settlement Agreement, and acknowledges that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. COMMONWEALTH OF PENNSYLVANIA _Seal NaIhan C. Wolf.. NoIsry PublIc Ca/tIsIll Boro, Cunlbeltalld county MyCommisslon Expinls Apr. 19, 200lI Member, Pennsylvania Assootatlon Of NotarIea A/2~ COMMONWEALTH OF PENNSYLVANIA : SS: COUNTY OF CUMBERLAND L day of, "'j I 2005, a Notary Public, , TERRY WALCK, known to me (or satisfactorily proven) to be the PERSONALLY APPEARED BEFORE ME, this ,;.1,. person whose name is subscribed to the within Marriage Settlement Agreement, and acknowledges that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. /i:4", J/( !4:..1'~ ~- Notary Public B ~."".....qaU ir: 'I. NOTARIAL SEAL KATHRYN M. HUNTZINGER, NOTARY PUBLIC CARLISLE BORO., CUMBERLANO COUNlY MY COMMISSION EXPIRES FEBRUARY 21, roos (:~ t:; :.;t:: !'> 0' '-:f\ -.::) :.~ ::? (;:.;1} _nin ""9 (:(~(~, 'r?jen -:;~4 ~)S ,.< (f? r C-? v TERRY WALCK, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA vs. : CIVIL ACTION - LAW TAMMY WALCK, Defendant : NO. 2004 - : IN DIVORCE ACCEPTANCE OF SERVICE I accept service of the Divorce Complaint for the above captioned case. I certify that I am authorized to accept service on behalf of the Defendant, Tammy Walck. Respectfully submitted, Date: /tJ1)CJ Y / ' 01 squire th anover Street, Suite 201 ,PA 17013 ~ V~'.._, ~~ <-- -;;;. ..... X'~ Cr" .-0 -< "",._~ q'\ :::I...... -:c...~,. ,-1, ~f'\ :Wq "C "-~~<.': ..~ -:\ ?)?~~ ,>...,1\ l,:O::\ ".:> .. C -0 .' '::)1:. - TERRY WALCK, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW T AMMY WALCK, Defendant : NO. 2004- : IN DIVORCE AFFIDAVIT OF CONSENT 1 A complaint in Divorce under S 3301(c) of the Divorce Code was filed on October 4, 2004. 2 The marriage of Plaintiff and 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. 4. I understand that I may have rights concerning alimony, division of property, lawyer's fees or expenses in do not claim them before a divorce is granted 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. S4904 relating to unsworn falsification to authorities. Date I' !'7. 0 .-;- -1, 1 T:~~~\V~;~~ '.,/ J .., 2.1 lll; {; J 2 ~ ~:,;:']< ,:.J" <- _po ';~ q, -1--,-, (n{;~ ,...-,,4fn :}JS: :,~~?> ...;"-'-; 17> '~~ ~ ,1"' .-c ? c,,,) .. .t:' o - TERRY WALCK, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW T AMMY WALCK, Defendant : NO. 2004 - : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 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! do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary I verifY that the statements made in this Waiver are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.CS. S 4904 relating to unsworn falsification to authorities. Date: 1- 17 0-) ~j ( Of:,) I tq. \oV\" Tammy Wale r-> .-;> (~::::> "" '- ~: -'- N (1' -a :::~ o ~'T1 ?--.. fnf''::;:;' -n (11 :(?Y ~.:~!<?, ,"')" ~;j ~<t) <K'il ~,O :-<- <(: r:- o TERRY WALCK, Plaintiff . IN THE COURT OF COMMON PLEAS OF . CUMBERLAND COUNTY, PENNSYL VANIA vs. . CIVIL ACTION - LAW T AMMY WALCK, Defendant . NO. 2004- . IN DIVORCE AFFIDAVIT OF CONSENT I. A complaint in Divorce under g 3301(c) of the Divorce Code was filed on October 4, 2004. 2. The marriage of Plaintiff and 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. 4. I understand that I may have rights concerning alimony, division of property, lawyer's fees or expenses ifI do not claim them before a divorce is granted. 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. g4904 relating to unsworn falsification to authorities. Date/ -/2 -0_5 .~ (~L .-> %? cJ' <- ~ ';:..",,' -~ \";) <1' ~ .-1 -C--n "\:tl ~'"'_~ ~ryr'l """,0 "':) 1- '~~:~ S.li "'I. ~\:1, l,2~\ "<"ri\ ~~;\ ~{:;o-' ~-r'l -0 -;~ 0.' .' .,- -"'... '0 - TERRY WALCK, Plaintiff . IN THE COURT OF COMMON PLEAS OF . CUMBERLAND COUNTY, PENNSYLVANIA vs. . CIVIL ACTION - LAW T AMMY WALCK, Defendant . NO. 2004- . IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 330l(c) Ole 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! do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verifY that the statements made in this Waiver 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/-/2-05 T~ Ji.L 0 ....., 0 <;".:;;:t c~ ;::.'::> -n CT' .-' '- ::f ,1 :::c;. -,,'" 111 r~'::' ...,1;.. -Cirn N :d'( Cf' 0- ""'1.~ ,Xt~ ~. -"y" Cf! _I .r !6 CJ .< - TERRY WALCK, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW T AMMY WALCK, Defendant : NO. 2004 - 5003 : 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 9330I( c) of the Divorce Code. 2. Date and manner of service of the Complaint: Mailed to Defendant's Attorney by United States first class mail, postage prepaid. Defendant's Attorney accepted service of the Complaint on October 6, 2004. 3. Date of execution ofthe Affidavit of Consent required by 93301 ( c ) of the Divorce Code: by Plaintiff, January 12, 2005; by Defendant, January 17, 2005. 4. Related claims pending: None. Marital Settlement Agreement filed contemporaneously with Praecipe to Transmit. Agreement will not be merged with the Divorce Decree, but will continue to have independent contractual significance. 5. Date Plaintiff's Waiver of Notice in 3301 ( c ) Divorce was filed with the Prothonotary: January 26,2005. Date Defendant's Waiver of Notice in 3301 (c) Divorce was filed with the Prothonotary: January 26, 2005. !,~~ Attorney for Plaintiff Law Offices of Lopez Neuharth LLP 401 East Louther Street, Suite 10 1 Carlisle, P A 17013 (717) 258-9991 ,.." ~;" \::-;~:;. <:J1 () -1'1 .-l XI1 fl'{',:, '~!:Jnl :00 (:~~(:) !::n f::;!C> ,::h-r"n ,.) ...--1 1'~" ::[.1 --<.: <:... ;;i:,";n :;r: ,"-, cr, ""0 :J':: <-;''1 .r:- o - .. . . . . .. .. . . . . . . . . . . . . . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY . PENNA, . . . . STATE OF TERRY WALCK, . . . . . . . . . . . . . PLAINTIFF No. 04-5003 VERSUS TAMMY WALCK, . . . . . . . . . . . . . . . . . . . . . DEFENDANT DECREE IN DIVORCE ~ TERRY WALCK "2-- -;:~..r-:-;T IS ORDERED AND AND NOW, . . . DECREED THAT , PLAINTIFF, . . TAMMY WALCK 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 VET BEEN ENTERED; NONE. . . . . . . . . . . . . . . . . . . . . . . . , ~ .;. "<" '. ~ . . - r , ,. , , , " . - ... . Bv TH " ,'- --" ATTEST: J. ~~P"O'HONO'^"~ " ,. J......'....,~.. .~ '!!I.', ~jIo" f' ~ - '+"'''t''t':t' . . 'fi'ti",'!;;f'f'f.'fi 'f.;f.;+''f.:t: . . . . .. . . 'f!'fi +''f.'f.:+; .. '. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. rf/vC'7 yc?!? t{:l->.~I /;l*'.?i, ___/PIV fp' ;7 /{T"""> Mi> ,v,' 5cl f C' X7 j1 r<-.