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Home My WebLink About02-0519MATTHEW T. BUTLER, Plaintiff vs. BECKY A. BUTLER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA O2- J 19 o CIVIL ACTION - 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 the divorce is indignities or irretrievable breakdown of the marriage, you may.request marriage counseling. A list of marriage counselors is available in the office of the Prothonotary, Cumberland County Courhouse, 1 Courthouse Square, 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. COURT ADMINISTRATOR Cumberland County Courthouse 4th Floor, Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6200 MATTHEW T. BUTLER, Plaintiff V. BECKY A. BUTLER, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No. On- Si? : CIVIL ACTION-DIVORCE COMPLAINT IN DIVORCE COUNT NO. 1 23 PA. C.S.A. §3301(c) or (d) 1. The Plaintiff is Matthew T. Butler, an adult individual who currently resides at 1116 Bethlynn Drive, Harrisburg, Dauphin County, Pennsylvania 17112. 2. The Defendant is Becky A. Butler, an adult individual who currently resides at 321 College Hill Road, Enola, Cumberland County, Pennsylvania 17025. 3. Plaintiff has been Commonwealth of Pennsylvania a bona fide resident of the for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant are both citizens of the United States of America. 5. The Defendant is not a member of the Armed Services of the United States or any of its allies. 6. The Plaintiff and Defendant were married on September 18, 1995, in Maryland. 7. There have been no prior actions of divorce or annulment between the parties. 8. The marriage is irretrievably broken. 9. Plaintiff has been advised of the availability of counseling and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling. 10. Plaintiff avers that there are no children of the parties under the age of 18 namely. WHEREFORE, the Plaintiff requests the Court to enter a Decree: (a) Dissolving the marriage between Plaintiff and Defendant; Dated: PANNEBAKER AND JONES, P.C. Attorneys for Plaintiff PeterS[ ~n[~r,~/~~., Esquire I.D. #44873 4000 Vine Street Middletown, PA 17057 Telephone: (717) 944-1333 VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalty of 18 Pa. C.S.A. ~4904, relating to unsworn falsification to authorities. · Butler, Plaintiff :sls BUTLERMATTHEW DIVORCE MASTER D 1,,,Dt*VO RCECOIVlPI~7.DOC MATTHEW T. BUTLER Plaintiff vs. BECKY A. BUTLER Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - 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-the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courhouse, 1 Courthouse Square, 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. COURT ADMINISTRATOR Cumberland County Courthouse 4th Floor, Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6200 MATTHEW T. BUTLER, Plaintiff V. BECKY A. BUTLER, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-159 Civil Term : : : CIVIL ACTION-DIVORCE AMENDED COMPLAINT IN DIVORCE COUNT NO. 1 23 PA. C.S.A. §3301(c)or(d) 1. The Plaintiff is Matthew T. Butler, an adult individual who currently resides at 1116 Bethlynn Drive, Harrisburg, Dauphin County, Pennsylvania 17112. 2. The Defendant is Becky A. Butler, an adult individual who currently resides at 321 College Hill Road, Enola, Cumberland County, Pennsylvania 17025. 3. Plaintiff has been Commonwealth of Pennsylvania a bona fide resident of the for at least six (6) months immediately previous to the filing of this Amended Complaint. 4. The Plaintiff and Defendant are both citizens of the United States of America. 5. The Defendant is not a member of the Armed Services of the United States or any of its allies. 6. The Plaintiff and Defendant were married on September 15, 1995, in Maryland. 7. There have been no prior actions of divorce or annulment between the parties. 8. The marriage is irretrievably broken. 9. Plaintiff has been advised of the availability of counseling and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling. 10. Plaintiff avers that there are no children of the parties under the age of 18 namely. COUNT NO. 2 23 Pa.C.S.A. 3301(a) (6) 11. Averments one (1) through (10) above are herein incorporated by reference thereto and made a part of this Count. 12. The Defendant has offered such indignities to the Plaintiff, the innocent and injured spouse, as to render his condition intolerable and his life burdensome. 13. Plaintiff requests the Court to enter a Decree of Divorce. COUNT NO. 3 CLAIM FOR EQUITABLE DISTRIBUTION OF MARITAL PROPERTY UNDER 23 Pa.C.S.A. §3501 14. The Plaintiff and Defendant are owners of various items of personal property, furniture and household furnishings acquired during their marriage which are subject to equitable distribution by the Court. 15. The Plaintiff and Defendant are owners of various motor vehicles acquired during their marriage which are subject to equitable distribution by the Court. 16. The Plaintiff and Defendant singly or jointly have interests in various bank accounts and insurance policies acquired during their marriage which are subject to equitable distribution by the Court. 17. Plaintiff and Defendant own or have an interest in the following real estate which is subject to equitable distribution by this Court: 321 College Hill Road, Enola PA 17025. 18. The Plaintiff and Defendant have acquired during the term of this marriage other marital property which is subject to equitable distribution by the Court. WHEREFORE, the Plaintiff requests the Court to enter a Decree: Defendant; (a) Dissolving the marriage between Plaintiff and (b) Equitably distributing all marital property owned by the parties hereto; Dated:_ PANNEBAKER AND JONES, P.C. Attorneys for Plaintiff By:~ i.D. #44873 ., Eo~uire 4000 Vine Street Middletown, PA 17057 Telephone: (717) 944-1333 VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalty of 18 Pa. C.S.A. §4904, relating to unsworn falsification to authorities. Mat~th~lTe'r, Plaintiff :sls BUTLERMATTHEW AMENDEDCOMPLAINT CERTIFICATE OF SERVICE A copy of the foregoing Amended Complaint in Divorce has been served upon Defendant, Becky A. Butler, by sending a copy to her attorney of record: Herschel A. Lock, Esquire 3107 North Front Street Harrisburg, PA 17110-1310 by depositing same in the United States mail, postage prepaid, in Middletown, Pennsylvania, this day of ~ , 2002. By: PANNEBAKER AND JONES, P.C. Attorneys for Plaintiff Peter R. Henninger, Jr., Esquire I.D.# 44873 4000 Vine Street Middletown PA 17057 (717) 944-1333 MATTHEW T. BUTLER, Plaintiff BECKY A. BUTLER, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. O2-R-~ Civil Term : : : CIVIL ACTION-DIVORCE INVENTORY AND APPRAISEMENT OF MATTHEW T. BUTLER Matthew T. Butler, Plaintiff files the following inventory and appraisement of all property owned or possessed by either party at the time this action was commenced and all property transferred within the preceding three years. Plaintiff verifies that the statements made in this inventory and appraisement were true and correct. Plaintiff understands that false statements herein are made subject to the penalties of 18 Pa.C.S. ~4904, relating to unsworn falsification to authorities. MATTHEW T. BUTLER, Plaintiff V. BECKY A. BUTLER, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-159 Civil Term : : : CIVIL ACTION-DIVORCE ASSETS OF PARTIES Defendant marks on the list below those items applicable to the case at bar and itemizes the assets on the following pages. If an items has been appraised, a copy of the appraisal report is attached. (X) 1. (x)2. )3. )4. )5. )6. )7. )8. 9. 10. 11. 12. 13. 14. 15. 16. 17, 18. 19. 20. 21. 22. 23. } 4. ~25. )26. Real Property Motor vehicles Stocks, bonds, securities and options Certificates of deposit Checking account, cash Savings accounts, money market and savings certificates Contents of safe deposit boxes Trusts Life Insurance policies (indicate face value, cash surrender value and current beneficiaries) Annuities Gifts Inheritances Patents, copyrights, inventions, royalties Personal property outside the home Businesses (list all owners, including percentage of ownership and officer/director positions held by a party with company) Employment termination benefits-severance pay, workmen's compensation claim/award Profit sharing plans Pension plans (indicate employee contribution and date plan vests) Retirement plans, Individual Retirement accounts Disability payments Litigation claims (matured and unmatured) Military/V.A. Benefits Education benefits Debts due, including loans and mortgages held Household furnishings and personalty (include as a total category and attach itemized list if distribution of such assets as in dispute) Other 0 4-) 0 0 0 J~ 0 ~ 0 -,-I 0 ,--t 0 0 0 0 0 0 0 uJ 0 0 r, C 0 C U ~J 0 -mi 0 0 0 0 0 m 0 ..~ -~t 4J 0 r~ 0 J~ -,-.I 0 0 r~ 0 0~ 0 0 u~ 0 0 -~1 4-} CERTIFICATE OF SERVIC~ A copy of the foregoing Inventory and Appraisement has been served upon Defendant, Becky A. Butler, by sending a copy to her attorney of record: Herschel A. Lock, Esquire 3107 North Front Street Harrisburg, PA 17110-1310 by depositing same in the United States mail, postage prepaid, in Middletown, Pennsylvania, this ~ day of~ , 2002. By: PANNEBAKER AND JONES, P.C. Attorneys for Plaintiff Peter R. Henninger,--j~., Esquire I.D.# 44873 4000 Vine Street Middletown PA 17057 717) 944-1333 MATTHEW T. BUTLER, Plaintiff Vo BECKY A. BUTLER, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ~1~ : NO. 02~50 Civil Term : : CIVIL ACTION-DIVORCE INCOME AND EXPENSE STATEMENT OF ~TTHEW T. BUTLER Matthew T. Butler files the following Income and Expense Statement and verifies that the statements made in herein 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. Mat[hew T. Butlgr, Plaintiff I'rEMZZED PAYROLL DEDUC izONS: Federal Withholding 123.00 Social Security 46.97 Local Wage Tax 15.15 State Income Tax 21.21 Retirement .00 Savings Bonds .00 Credit Union .00 Life Insurance .00 Other (specify): MEDICARE 10.98 Net Pay Per Pay Period: $538.89 $ 756.20 Weekly $2335.15 $28,022.28 OTHER ZNCOIRE: Alimony Interest Dividends Pension Annuity Social Security Rents Royalties Expense Account Unemployment Comp Workmen's Comp WEEKLY 2.31 NONTHLY $ 10.00 YEARLY 120.00 TOTAL ZNCOIqE 541.20 2,345.15 28,142.28 HOHE Rent Maintenance Utilities: Electric Gas Oil Telephone Water Sewer WEEKLY 126.92 17.31 MONTHLY 550.00 75.00 YEARLY 6600.00 900.00 EHPLOYlqENT Public Transportation Income TAXES Real Estate Personal Property Income ZNSURANCE Homeowners Automobile Life Accident Health Other: NSG Liability 8.08 23.08 23.08 35.00 100.00 100.00 420.00 1200.00 1200.00 AUTOMOBZLE Payments Fuel Repairs EDUCATION Private School Parochial School College MEDICAL [~)c~or Dentist Orthodontist Hospital Medicine Special Needs RELZGIOUS PERSONAL Clothing Food Barber/Hairdresser Credit Payments Credit Card Charge Account Memberships LOANS Credit Union Providian (Second Mortgage) 138.46 40.38 11.54 WEEKLY 0.69 14.42 69.23 5.77 46.15 1.92 600.00 175.00 30.02 MONTHLY 3.00 62.50 300.00 25.00 200.00 8.33 7200.00 2100.00 600.00 YEARLY 36.00 750.00 3600.00 300.00 2400.00 100.00 HZSCELLANEOUS Household Help Child Care Papers/Books Magazines 1.92 Entertainment Pay TV 13.85 Vacation Gifts 5.77 Legal Fees 'J8.07 Hlscell~neous (Cont'd) Other Child Support Alimony Payments TOTAL EXPENSES WEEKLY $596.67 8.33 60.00 25.00 208.33 HONTHLY $2585,58 100.00 720.00 300.00 2500.00 YEARLY $31,027 :sis BUTLERMATTHEW INCOMEEXPENSE #17300 CERTIFICATE OF SERVIC~ A copy of the foregoing Income and Expense Statement has been served upon Defendant, Becky A. Butler, by sending a copy to her attorney of record: Herschel A. Lock, Esquire 3107 North Front Street Harrisburg, PA 17110-1310 by depositing same in the United States mail, postage prepaid, in Middletown, Pennsylvania, this ~ day of ~ , 2002. By: PANNEBAKER AND JONES, P.C. Attorneys for Plaintiff Peter R. He~ing~r,-~f., Esquire I.D.# 44873 4000 Vine Street Middletown PA 17057 (717) 944-1333 CUMBERLAND IN THE COURT OF COMMON PLEAS OF~COUNTY, PENNSYLVANIA CIVIL DIVISION MATTHEW T. BUTLER : Plaintiff : VS. : BECKY A. BUTLER Defendant : File No. 02""t'r'~ 5 CIVIL ACTION - LAW IN DIVORCE NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the F,r,~tii~t~l:/Defendant in the above matter, [select one by marking "x"J xx prior to the entry of a Final Decree in Divorce, or ~ after the entry of a Final Decree in Divorce dated hereby elects to resume the prior surname of Becky A. Sawyer written notice avowing t'~ / her intention pursuant to the provisions of 54 P.S. § 704. Date: January (~ 2003 ~ - . ure SiOnat~nanti~ being resumed , and gives this COMMONWEALTH OF PENNSYLVANIA ) ) SS. COUNTY OF ~[~?P'~~'>'C", ) On the g;/V'?q day of .~',~"~/~'~.¢~ , ,~2~,a ., before me, · the Prothonotary ~r'~otary Public, perdsonally ap.[~ared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he / she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand and official seal. ?rot, h. - 61 (Rev. 4/01) "-~P-rothonotary or Notary Public MATTHEW T. BUTLER, Plaintiff V. BECKY A. BUTLER, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-519 Civil Term : CIVIL ACTION-DIVORCE BILL OF PARTICULARS In compliance with the Rule Entered by the Prothonotary n the above-entitled case the Plaintiff submits the following Bill of Particulars: The Plaintiff avers that in violation of her marriage vows, under the Law of this Commonwealth the said Becky A. Butler, the Defendant, has offered such indignities to the person of the Plaintiff as to render the condition of the Plaintiff intolerable, his life burdensome and thereby forced him fi.om their home in cohabitation with her. 1. Such conduct began shortly after the parties' marriage such that in August 1996, your Plaintiff left the marital residence for approximately one month due to the fact that the parties were not getting along. Most specifically these concerns concerned housework, the upkeep of the house, and a lack of communication. Your Plainfiffreturned to the marital residence after approximately one (1) month whereupon the Defendant did at that point begin to help with the housework and the upkeep of the home, however she did refuse to attend counseling sessions in order to help with the parties communication. 2. From the date of the marriage through the Spring of 1999, the Defendant pursued a course of a conduct toward the Plaintiff which envinced an utter want of affection and sympathy for him and which was continually characterized with hatred, settled malice, disrespect, ill treatment, unkindness, which was not only consistent with the duty of the Defendant toward the Plaintiff as his wife, but also humiliating, mortifying and degrading to the Plaintiff. 3. In the Spring of 1999, the Plaintiff again moved out of the marital residence due to the fact that there was absolutely no help from the Defendant with the upkeep of the house or the parties' pets. The Plaintiff did everything himself. The Plaintiff avers that the Defendant sat in front of her computer or the television when she was home. A sex life did not exist because there was no desire from the Defendant toward the Plaintiff for such. 4. After a short separation in the Spring of 1999 the Plaintiff moved back in due to the fact that he missed the security of the relationship. Again your Defendant refused to go to marriage counseling to try and improve the communication and sharing of responsibilities in the marriage. 5. The parties eventually separated for good on January 12, 2002 when your Plaintiff moved out of the marital residence and eventually filed for a divorce. The complaints and the problems have remained the same throughout the course of the marriage. 6. The Plaintiff avers that the parties live two (2) separate lives: Defendant worked and had the National Guard and her computer. The Plaintiff did all of his own laundry (he quit doing hers when she quit putting it away), cooked 95% of the meals, did all housework that was done and constantly worked on home repairs and landscape projects. 7. The parties never did anything together. The Defendant did what she wanted to do thus forcing Plaintiff to do things alone. Plaintiff actually spent twice as much time with Defendant's dad and brother as he did with the Defendant due to Defendant's lack of interest. 8. There was no common courtesy in the relationship. Up until the time of final separation Plaintiff would always leave a note or message as to where he was going or what he was doing. He always had his cell phone with him and could always be reached. When he was on his way home from somewhere he would call to see if she needed anything. The Plaintiff never received anything in return. It could be 8:00 p.m. and she would still not be home from work. She would never call saying she was running late. 9. There was no communication between the parties. When the Plaintiff would start a conversation it would just turn into a question and answer session from Defendant. 10. Plaintiff reluctantly did a lot of things with Defendant's family, which he has no problem with but when it came to Plaintiff's family there was always a problem with doing something when Plaintiff wanted or needed to do something with his family. 11. The Defendant never returned calls to her friend and when with Plaintiff's friends, Defendant made is very obvious she did not want to be there and thus Plaintiff's friends would not ask the parties out again. The Defendant would not talk to anyone and would just stand in the comer and be there. 12. As time went on and on the parties had less and less :in common. 13. The Defendant made certain allegations in a protection from abuse action, which are out and out lies. She eventually dropped the action. 14. Your Plaintiff has attempted time and time again to effect the sharing of responsibilities within the marriage and to open lines of communication through marriage counseling which your Defendant has continually refused to pursue choosing instead to spend all of her time at work and the National Guard and with her family to detriment of the Plaintiff. 15. The Defendant's conduct as aforesaid was not induced or provoked by the Plaintiff in any way whatsoever, but on the contrary, the Plaintiff was industrious in advancing the interests of the Defendant, always kind, loving and affectionate toward her and did every means within his power to move this marriage forward. 16. As a result of the indignities offered to him by the Defendant as herein before mentioned, the Plaintiff was forced into almost complete isolation which caused such a strain on him as to render his condition intolerable, his life was made burdensome and he was thereby forced to withdraw from the party's home and cohabitation with the Defendant on January 12, 2002, since which time he has lived separate and apart. Respectfully submitted, PANlb[EBAKER &JONES, p.C. Peter~ He'in, r, Jr., Esqui~%~ I.D. #44873 4000 Vine Street Middletown, PA 17057 (717)944-1333 VERIFICATION I verify that the statements made in this Bill of Particulars are true and correct. I understand that false statements herein are made subject to the penalty of 18 Pa. C.S.A. §4904, relating to unswom falsification to authorities. Matthew T. Butler, Plaintiff CERTIFICATE OF SERVICE A copy of the foregoing Bill of Particulars has been sen, ed upon Defendant, Becky A. Butler, by sending a copy to her attorney of record: Herschel A. Lock, Esquire 3107 North Front Street Harrisburg, PA 17110-1310 by depositing same in the United States mail, postage prepaid, in Middletown, Pennsylvania, this c~day of ~,' 2003. PANNEBAKER AND JONES, P.C. Attorneys for Plaintiff By: P&er R. H~nn~nger, Jr., Esq(fi~ I.D.# 44873 4000 Vine Street Middletown PA 17057 (717) 944-1333 JONES & HENNINGER, P.C. By: Peter R. Henninger, Jr., Esquire Attorney for the Plaintiff IDENTIFICATION NO. 44873 905 West Governor Road, Suite 330 Hershey, PA 17033 (717) 533-7113 Fax (717) 533-7233 MATTHEW T. BUTLER Plaintiff v BECKY A. BUTLER Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-519 CIVIL ACTION-DIVORCE PRAECIPE Please withdraw the appearance of Pannebaker & Jones, P.C. and enter the appearance of Peter R. Henninger, Jr., Esquire, Jones & Henninger, P.C. as attorneys for the Plaintiff, Matthew T. Butler in the above-captioned matter. Respectfully Submitted, JONES & HENNINGER, P.C. By ~ Peter R. l-~nninger, Jr., Esq. ID No. 44873 905 West Governor Road Suite 330 Hershey, PA 17033 (717) 533-7113 Fax (717) 533-7233 PANNEBAKER & JONES, P.C. By_ Four Thousand Vine Street Middletown, PA 17057-3596 (717) 944-1333 Fax (717) 944-4004 CERTIFICATE OF SERVICE A copy of the foregoing Praecipe has been served upon the Defendants by sending a copy to the attomey of record: Herschel A. Lock, Esquire 3107 North Front Street Harrisburg, PA 17110-1310 by depositing same in the United States mail, postage prepaid, in Hershey, Pennsylvania, this day of ~ '-'/"~ ~ ,2004. JONES & HENNINGER, P.C. Attorneys for Plaintiff By: Peter R. Henninger, Jr., Esquire ID No. 44873 905 Governor Road Suite 330 Hershey, PA 17033 MATTHEW T. BUTLER, Plaintiff BECKY A. BUTLER, vs. Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 0 2 -~ CIVIL ACTION - LAW IN DIVORCE INCOME AND EXPENSE STAT~N-T OF BECk~Y A. SAW-Y~R Defendant files the following income and expense statement. INCOME AND EXPENSE STA~]~4ENT OF BECKY SAWlq~R INCO~4E Employer: Computer Aid, Inc. Address: 1390 Ridgeview Drive, Allentown, PA 18104 Type of Work: Computer consultant Payroll Number: 3635 Pay Period (weekly, bi-weekly, etc.): weekly Gross Pay per Pay Period: Itemized Payroll Deductions: Federal Withholding Social Security Local Wage Tax State Income Tax Retirement Savings Bonds Credit Union Life Insurance Health Insurance Other (specify) Fed. MED/EE PA Unemployment EE $1,288.80 255.15 80.90 26.06 36.49 1.59 18.92 0.26 Net Pay per Pay Period $869.43 Other Income: Interest Dividends Pension Annuity Social Security Rents Royalties Expense Account Gifts Unemployment Comp. Workmen's Comp. Army National Guard Total Week Month Year (Fill in Appropriate Column) $ $ 2,647.20 $46,118.70 TOTAL INCOME $46,118.70 Home Mortgage/rent Maintenance Utilities Electric Gas Oil Telephone Water Sewer Other EXPENSES Weekly Monthly Yearly (Fill inAppropriate Column} $8,713.08 2,500.00 1,104.00 1,320.00 1,680.00 1,344.00 1,152.00 Employment Public transportation Lunch 780.00 Taxes Real Estate Personal property Income 1,089.00 12.00 550.00 Insurance Homeowners Automobile Life 306.00 1,513.80 Accident Health Other Weekly Monthly Yearly (Fill in ApDropriate Column) Automobile Payments Fuel Repairs 4,386.00 2,280.00 2,700.00 Medical Doctor Dentist Orthodontist Hospital Medicine Special needs (glasses, braces, orthopedic devices) Education Private school Parochial school College Religious 2,000.00 Personal Clothing Food Barber/hairdresser Credit payments Credit card Charge account Memberships Weekly Monthly Yearly (Fill in Appropriate Column) 1,800.00 4,200.00 960.00 7,200.00 3,600.00 680.00 Loans Credit Union Miscellaneous Household help Child care Papers/books/magazines Entertainment Pay TV Vacation Gifts Legal fees Charitable contributions Other child support Alimony payments 350.00 2,500.00 1,325.40 1,500.00 1,250.00 Other TOTAL EXPENSES $61,195.28 PROPERTY OWN I~,D Checking account Savings accounts Credit Union Stocks/bonds Real estate Other Description PSECU PSECU Oppenheimer Stocks Marital home 401(k) Ownership* Value ~ ~ $9,500 X $1,200 $1,565.21 881.91 $93,0OO $2,000 X X X X X TOTAL $108,147.12 * H = Husband, W = Wife, J = Joint LIABILITIES OF PARTIES ( ) Plaintiff ( X ) Defendant marks on the list below those items applicable to the case at bar and itemizes the liabilities on the following pages. Secured (x) 1. ( ) 2. ( ) 3. ( ) 4. Mortgages Judgments Liens Other secured liabilities Unsecured (x) ( ) 6. ( x ) 7. ( ) 8. ( ) 9. Credit card balances Purchases Loan payments Notes payable Other unsecured liabilities Continqent or Deferred 10 11 12 13 14 15 Contracts or Agreements Promissory Notes Lawsuits Options Taxes Other contingent or deferred liabilities ASSETS OF PARTIES ( ) Plaintiff ( X ) Defendant marks on the list below those items applicable to the case at bar and itemizes the assets on the following pages. If an item has been appraised, a copy of the appraisal report is attached. X X X X X X 1. Real property 2. Motor vehicles 3. Stocks, bonds, securities, and options 4. Certificates of deposit 5. Checking accounts, cash 6. Savings accounts, money market and savings certificates 7. Contents of safe deposit boxes 8. Trusts 9. Life insurance policies (indicate face value, cash surrender value and current beneficiaries) 10. Annuities 11. Gifts 12. Inheritances 13. Patents, copyrights, inventions, royalties 14. Personal property outside the home 15. Businesses (list all owners, including percentage of ownership, and officer/director positions held by a party with company) 16. Employment termination benefits - severance pay, worker's compensation claim/award 17. Profit sharing plans 18. Pension plans (indicate employee contribution and date plan vests) 19. Retirement plans, individual retirement accounts 20. Disability payments 21. Litigation claims (matured and unmatured) X X 22. Military/V.A. benefits 23. Education benefits 24. Debts due, including loans, mortgages held 25. Household furnishings and personalty (include as a total category and attached itemized list of distribution of such assets is in dispute 26. Other MARITAL PROPERTY: ( ) Plaintiff ( X ) Defendant lists all marital property in which either or both spouses have a legal or equitable interest individually or with any other person as to the date this action was commenced. ITEM NO. 1 DESCRIPTION: 321 College Hill Road, Enola VALUE: $93,000 DATE OF VALUATION: 8/8/03 NON-MARITAL PORTION: -0- AMOUNT/NATURE OF ANY LIEN: $75,964.08 to Columbia Nat'l 1/12/04 ITEM NO. 2 VALUE: $4,500 DATE OF VALUATION: NON-MARITAL PORTION: -0- AMOUNT/NATURE OF ANY LIEN: -0- DESCRIPTION: 1999 Mercury Couqar Current ITEM NO. 2 VALUE: $4,500 DATE OF VALUATION: NON-MARITAL PORTION: -0- AMOUNT/NATURE OF ANY LIEN: -0- DESCRIPTION: 1988 Ford 9~stang 8/10/03 ITEM NO. 2 DESCRIPTION: 1993 & 1994: VALUE: $1-1,500 DATE OF VALUATION: NON-MARITAL PORTION: -0- AMOUNT/NATURE OF ANY LIEN: -0- Seadoos & Trailer Current MARITAL PROPERTY: ( ) Plaintiff ( X ) Defendant lists all marital property in which either or both spouses have a legal or equitable interest individually or with any other person as to the date this action was commenced. ITEM NO. 2 DESCRIPTION: 2001 Ford F-250 VALUE: $33,000 DATE OF VALUATION: 8/10/03 NON-MARITAL PORTION: -0- AMOUNT/NATURE OF ANY LIEN: $24,558.52 - PSECU loan ITEM NO. 3 DESCRIPTION: Stocks VALUE: $1,286 DATE OF VALUATION: NON-MARITAL PORTION: $405 AMOUNT/NATURE OF ANY LIEN: -0- 5/3o/o3 ITEM NO. 5 DESCRIPTION: PSECU Acct. VALUE: $2,801.58 DATE OF VALUATION: NON-MARITAL PORTION: $1,545.55 AMOUNT/NATURE OF kNY LIEN: -0- 2/1/02 ITEM NO. 9 DESCRIPTION: ING Life Ins. VALUE: $3,420.57 DATE OF VALUATION: NON-MARITAL PORTION: AMOUNT/NATURE OF ANY LIEN: -0- 3/9/02 MARITAL PROPERTY: ( ) Plaintiff ( X ) Defendant lists all marital property in which either or both spouses have a legal or equitable interest individually or with any other person as to the date this action was commenced. ITEM NO. 18 DESCRIPTION: 401(k) PSECU VALUE: $3,731.04 DATE OF VALUATION: NON-MARITAL PORTION: -0- AMOUNT/NATURE OF ANY LIEN: -0- 12/31/01 ITEM NO. 3 DESCRIPTION: Oppenheimer Mutual Fund VALUE: $2,734.58 DATE OF VALUATIONs: 12/31/01 NON-MARITAL PORTION: $1,169.37 AMOUNT/NATURE OF ANY LIEN: -0- ITEM NO. 25 DESCRIPTION: Tools, equipment, machinery VALUE: $11,000 DATE OF VALUATION: Purchase price NON-MARITAL PORTION: -0- AMOUNT/NATURE OF ANY LIEN: -0- ITEM NO. 25 DESCRIPTION: Rifles, pistols, huntinq equipment VALUE: $6,500 DATE OF VALUATION: 8/17/03 NON-MARITAL PORTION: -0- AMOUNT/NATURE OF ANY LIEN: -0- MARITAL PROPERTY: ( ) Plaintiff ( X ) Defendant lists all marital property in which either or both spouses have a legal or equitable interest individually or with any other person as to the date this action was commenced. ITEM NO. 25 DESCRIPTION: Diecast cars, VALUE: $1,500 DATE OF VALUATION: NON-MARITAL PORTION: collectibles 8/17/03 AMOUNT/NATURE OF ANY LIEN: ITEM NO. DESCRIPTION: VALUE: DATE OF VALUATION: NON-MARITAL PORTION: AMOUNT/NATURE OF ANY LIEN: ITEM NO. DESCRIPTION: VALUE: DATE OF VALUATION: NON-MARITAL PORTION: AMOUNT/NATURE OF ANY LIEN: ITEM NO. DESCRIPTION: VALUE: DATE OF VALUATION: NON-MARITAL PORTION: AMOUNT/NATURE OF ANY LIEN: NON-MARITAL PROPERTY: ( Plaintiff ( X ) Defendant lists all property in which a spouse has a legal or equitable interest which is claimed to be excluded from marital property. ITEM NO. DESCRIPTION: VALUE: DATE OF VALUATION: REASON FOR EXCLUSION: AMOUNT/NATURE OF ANY LIEN: ITEM NO. DESCRIPTION: VALUE: DATE OF VALUATION: REASON FOR EXCLUSION: AMOUNT/NATURE OF ANY LIEN: ITEM NO. DESCRIPTION: VALUE: DATE OF VALUATION:: REASON FOR EXCLUSION: AMOUNT/NATURE OF ANY LIEN: ITEM NO. DESCRIPTION: VALUE: DATE OF VALUATION: REASON FOR EXCLUSION: AMOUNT/NATURE OF ANY LIEN: PROPERTY TRA~NSFERRED: ( ) Plaintiff ( X ) Defendant lists all property in which either or both spouses had a legal or equitable interest individually or with any other person and which has been transferred within the preceding three years. ITEM NO. DESCRIPTION: NAME OF OWNER: DATE OF TR3~NSFER: CONS IDEP~ATION: PERSON TO WHOM TPJ~NSFERRED: ITEM NO. DESCRIPTION: NAME OF OWNER: DATE OF TRANSFER: PERSON TO WHOM TR/LNSFERRED: CONSIDERATION: ITEM NO. DESCRIPTION: NAME OF OWNER: DATE OF TP3dNSFER: PERSON TO WHOM TRANSFERRED: CONSIDERATION: ITEM NO. DESCRIPTION: NAME OF OWNER: DATE OF TRANSFER: PERSON TO WHOM TR3LNSFERRED: CONS IDEP~AT I ON: LIABILITIES: ( ) Plaintiff ( X ) Defendant lists all liabilities of either or both spouses alone or with any person as of the date of separation. ITEM NO. 1 DESCRIPTION: Columbia National Mortqage AMOUNT OF DEBT PRESENTLY: $76,411.26 as of 9/1/03 AMOUNT OF DEBT AT SEPARATION: $77,982.53 DATE DEBT INCURRED, INITIAL AMOUNT OF I~EBTEDNESS AND PURPOSES OF DEBT: 8/20/97 - $81,400 house AMOUNT PAID BY DEBTOR SINCE DATE OF SEPARATION: $13,950 ITEM NO. 5 DESCRIPTION: PSECU Visa AMOUNT OF DEBT PRESENTLY: $679.41 AMOUNT OF DEBT AT SEPAP~ATION: $591.57 DATE DEBT INCURRED, INITIAL AMOUNT OF II~EBTEDNESS AND PURPOSES OF DEBT: 12/31/01 - $1,586.72 - marital purchases AMOUNT PAID BY DEBTOR SINCE DATE OF SEPARATION: $995.15 ITEM NO. 7 DESCRIPTION: AES Loan Servicinq AMOUNT OF DEBT PRESENTLY: $3,917.02 AMOUNT OF DEBT AT SEPARATION: DATE DEBT INCURRED, INITIAL AMOUNT OF INDEBTEDNESS AND OF DEBT: 8/18/00 $3,732 - pay off credit cards AMOUNT PAID BY DEBTOR SINCE DATE OF SEPARATION: -0- PURPOSES LIABILITIES: ( ) Plaintiff ( X ) Defendant lists all liabilities of either or both spouses alone or with any person as of the date of separation. ITEM NO. 7 DESCRIPTION: AES Loan Servicinq AMOUNT OF DEBT PRESENTLY: $5,235.04 AMOUNT OF DEBT AT SEPAP~TION: DATE DEBT INCURRED, INITIAL AMOUNT OF INDEBTEDNESS AND PURPOSES OF DEBT: 1/19/00 - $4,992 - pay off credit cards AMOUNT PAID BY DEBTOR SINCE DATE OF SEPt~RATION: -0- ITEM NO. 7 DESCRIPTION: AES Loan Servicinq AMOUNT OF DEBT PRESENTLY: $5,707.29 AMOUNT OF DEBT AT SEPARATION: DATE DEBT INCURRED, INITIAL AMOUNT OF INDEBTEDNESS AND PURPOSES OF DEBT: 10/9/97 - $5,049 - pay off credit cards AMOUNT PAID BY DEBTOR SINCE DATE OF SEPARATION: -0- ITEM NO. 7 DESCRIPTION: AES Loan Servicinq AMOUNT OF DEBT PRESENTLY: $1,045.49 AMOUNT OF DEBT AT SEPAP~ATION: DATE DEBT INCURRED, INITIAL AMOUNT OF INDEBTEDNESS AND PURPOSES OF DEBT: 6/13/97 - $968 - pay off credit cards AMOUNT PAID BY DEBTOR SINCE DATE OF SEP]kRATION: -0- LIABILITIES: ( ) Plaintiff ( X ) Defendant lists all liabilities of either or both spouses alone or with any person as of the date of separation. 7 DESCRIPTION: AES Loan Servicinq ITEM NO. AMOUNT OF DEBT PRESENTLY: $2,047.10 AMOUNT OF DEBT AT SEPARATION: DATE DEBT INCURRED, INITIAL AMOUNT OF I~EBTEDNESS AND PURPOSES OF DEBT: 6/13/97 $1,992 - pay off credit cards AMOUNT PAID BY DEBTOR SINCE DATE OF SEPARATION: -0- ITEM NO. DESCRIPTION: AMOUNT OF DEBT PRESENTLY: AMOUNT OF DEBT AT SEPARATION: DATE DEBT INCURRED, INITIAL AMOUNT OF I~EBTEDNESS AND PURPOSES OF DEBT: AMOUNT PAID BY DEBTOR SINCE DATE OF SE~RATION: ITEM NO. DESCRIPTION: AMOUNT OF DEBT PRESENTLY: AMOUNT OF DEBT AT SEPARATION: DATE DEBT INCURRED, INITIAL AMOUNT OF INDEBTEDNESS AND PURPOSES OF DEBT: AMOUNT PAID BY DEBTOR SINCE DATE OF SEPARATION: I verify that I have reviewed this form with my client and to the best of my knowledge the answers herein are true and correct. HERSCHEL LOCK, ESQUIRE Attorney for Defendant VERIFICATXON I verify that the statements made in the foregoing document are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: 1~-23.-04 B{ECKY (iA. S~WYE~H{ MATTHEW T. BUTLER, Plaintiff vs. BECKY A. BUTLER, Defendant IN THE COURT OF cOMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02- -r £17 CIVIL ACTION - LAW IN DIVORCE pRAECIPE AND RULE FOR BILL OF PARTICUI2%RS TO THE PROTHONOTARY: Kindly enter a Rule upon Plaintiff to file a Bill of Particulars on the fault count of the Complaint in Divorce within twenty (20) days after service of the Rule or non pros sec. leg. DATED: HERSCHEL LOC~, ESQUIRE Attorney for Defendant 3107 North Front Street Harrisburg, PA 17110 (717) 23~3-6661 Supreme Tourt No. 22691 AND NOW, this ~aY of upon Plaintiff as above. L~j[- 2002, a Rule is entered Prothonotary MATTHEW T. BUTLER, Plaintiff VS. BECKY A. BUTLER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02- IVIL IN DIVORCE AFFIDAVIT OF CONSENT. 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on January 30, 2002. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of the final Decree in Divorce after service of notice of intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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 UNSWORN FALSIFICATION TO AUTHORTIES. DATE: MATTHEW T. BUTLER, Plaintiff VS. BECKY A. BUTLER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02 CIVIL : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE o~vER SECTION 3301{C) OF THE DIVORCE COvE 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 THE FOREGOING 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 UNSWORN FALSIFICATION TO AUTHORTIES. DATE: MATTHEW T. BUTLER MATTHEW T. BUTLER, Plaintiff vs. BECKY A. BUTLER, Defendant IN THE cOURT OF cOMMON PLEAS cUMBERLAND cOUNTY, PENNSYLVANIA NO. 02-~ CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT Personally appeared before me, a Notary Public in and for the aforesaid Commonwealth and County, BECKY A. BUTLER, who, being duly sworn according to law deposes and says that: 1 A Complaint in Divorce under Section 3301(c) of the · 2002. Divorce code was filed on ~l 90) 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 after 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 unsworn falsification to authorities. Sworn to and subscribed before me this ~ day of f~i~/~ ' 2004. Notary Public MATTHEW T. BECKY A. BUTLER, Plaintiff vs. BUTLER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-~ CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENT TO REQUEST EN'rK¥ OF 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 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 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.So Section 4904 related to unsworn falsification to authorities. ~E~KY ~B'UTLE MATTHEW T. BUTLER, Plaintiff BECKY A. BUTLER Defendant 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLV,MNIA NO. 02-519 CIVIL 1N DIVORCE ORDER ANDNOW, this /~ dayof '~~ ,2004, upon consideration of Master's Report, for the reasons stated in the accompanying opinion and in the Stipulated Addendum to Master's Report, it is ordered and directed as follows: MARITAL ASSETS AND VALUES ASSIGNED TO HUSBAND 2001 Ford F-250 pickup truck 1998 Ford Mustang Diecast car collection Rifles and pistols in husband's possession Characterized as marital: (30-06 Remington rifle; Savage 22-250 rifle; Bushmaster 223 semi-autoAR 15; 12-gauge Mossberg shot gun; 22 semi-auto rifle) ING life insurance policy on husband's life - cash value zero to negative value $ 1,985.00 $ 1,592.00 $ 1,500.00 _$_ 3,0O0.57 TOTAL $ 8,077.57 MARITAL ASSETS AND VALUES ASSIGNED TO WIFE Marital home, 321 College Hill Road Enola, Cumberland County, Pennsylvania $ 17,127. ! 5 1999 Mercury Cougar $ 6,200.00 1993 and 1994 Seadco XPs and 1998 Loadrite trailer Ameritrade stock account Oppenheimer Mutual Fund PSECU accounts: Savings $ 50.00 Checking $1,285.25 Money Market $4,828.71 Total (per stipulation) TOTAL $ 2,000.00 $ 878.12 $ 2,126.80 6,118.98 34,451.05 CREDITS AND CHARGES RELATING TO MARITAL DEBT The marital debt, exclusive of the mortgage on the real estate, related to student loans and Visa charges totals $19,775.61. That debt is assigned to wife and wife is entitled to a credit of 50% of the total as husband's share in the amount of $9,887.81. Further, wife paid marital bills after separation, including husband's insurance bill, totaling $1,316.24. One-half of those payments are husband's responsibility entitling wife to a credit of $658.12. Wife's total credit against what she owes husband for his share of the equitable distribution of the marital estate is $10,545.93. COMPUTATIONS Value of marital assets husband entitled to receive Value of marital assets assigned to husband Shortfall on husband's distrib-*;^- -" '~ ' uuuu t~lmarl[al assets $ 23,390.74 $ 8,077.57 $ 15,313.17 Value of marital assets wife entitled to receive Value of marital assets assigned to wife Excess of in kind distribution to wife $ 19,137.88 $ 34,451.05 $ 15,313.17 Applying wife's credit for payment of marital obligations (1/2 of $21,091.85) or $10,545.93, husband is entitled to receive a net distribution from wife of $4,767.24. Within thirty (30) days ora final order in these proceedings, wife shall pay to husband the sum of $4,767.24. Upon receipt of the cash payment from wife, husband shall execute and deliver to wife a special warranty deed transferring all his right, title, smd interest in the real estate at 321 College Hill Road, Enola, Cumberland County, Penn~ylvania. Wife will take said property subject to the existing mortgage and will indemnify and hold husband harmless on account of any claims which may be made against him by the mortgagee. The parties will sign all titles and documents necessary to transfer ownership of assets assigned to each of the parties as herein provided in the distribution of assets as set forth above so that all transfers are accomplished within thirty (30) days ora final order in these proceedings. Husband shall return to wife a picture of wife's sister, a magazine for an M-16, and a collection of Match Box cars. Wife shall return to husband a cast iron picture (wife claims husband removed picture from house previously) and a freezer. The transfers of personal property shall occur within thirty (30) days of a final order in these proceedings. Wife will retain her 401(k) and husband his pension plan free of any claims by the other party. Each party will retain the tangible personal property in his or her possession free of any claims by the other party except for the items to be returned to each party provided hereinabove. Plaintiff shall refinance the debt presently owed by him on his Ford F-250 truck so as to have Defendant's name removed therefrom within sixty (60) days from the date of the final order but in the event he is unable to do so he shall nevertheless continue to indemnify Defendant and hold her harmless for any liability, therefore. Because Defendant alleges that she does not have the cast iron picture of a frog, the subject of the Master's Report, she shall not be obligated[ to transfer the same to Plaintiff, this with the understanding that in the event she at any time finds it she will transfer possession of it to Plaintiff. BY THE COURT: IN THE COURT OF CC~MON PLEAS OF ~3MBERLAND COUNTY, PENNSYLVANIA NO. O ~ CIVIL 519 vs. 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. Grounds for divorce: irretrievable breakdo~ under Section 3301 (c) 3~T-T-d-[~ of--thc Di-~-cz~= Cod=. (Strike out inapplicable section) 2. Date and manner of service of the complaint: 3. Complete either Paragraph A. or B. A. Date of execution of the affidavit of consent required by Section 3301 (c) of the Divorce Code: by the plaintiff by the defendant ~ _~ _ ~ ~ B. (1) Date of execution of the plaintiff,s affidavit requJn~ed by Section 3301 (d) of the Divorce Code: (2) Date of service of the plaintiff's affidavit upon the defendant: 4. Related claims pending: 5. Indicate date and manner of service of the notice of intention to file praecipe to transmit record, and attach a copy of said notice under Section 3301 (d)(1)(i) of the Divorce Code ~/- ~/~ Attorney for Plaintiff/Del~r~ IN THE COURT Of COlVIMON PLEAS OF CUMBERLANDCOLJNTY STATE OF PENNA. MAq3~,~ T. ~ NO. 02 519 VERSUS ~C~Y A. ~ DECREE IN DIVORCE AND NOW, /~7~I./ /~a. , 2004 , IT IS ORDERED AND DECREED THAT MARZITIEWT. BUT~ , 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; NONE - SEE ORDER BY THE COURT: , / ATT ~"'~~~~1~ PROTHONOTARY