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Home My WebLink About04-5576 vs. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2004- ~t,;'1/P Civil Term ANITA L. BLACK, Plaintiff MICHAEL A. BLACK, Defendant : CIVIL ACTION - LAW : 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 the divorce is indignities or irretrievable breakdown of marriage, you must request marriage counseling. A list of marriage counselors is avail- able in the Office of the Prothonotary at CUMBERLAND COUNTY COURTHOUSE CARLISLE, PENNSYLVANIA 17013 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, PENNSftNlA/7013 ~1!1'I / MAX J. SMITH, J , Esquire JARAD W. HANDELMAN, Esquire Attorney for Plaintiff P.O. Box 650 Hershey, P A 17033 (717) 533-3280 ANITA L. BLACK, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 2004- S'S'1fc::. Civil Term MICHAEL A. BLACK, Defendant : CNIL ACTION - LAW : IN DNORCE COMPLAINT IN DNORCE AND NOW comes the Plaintiff, ANITA L. BLACK, by her attorney, MAX J. SMITH, JR., Esquire, and seeks to obtain a Decree in Divorce upon the grounds hereinafter more fully set forth: 1. The Plaintiff, ANITA L. BLACK, is an adult individual and citizen of the United States of America, whose address is 2907 Westbury Court, Apt. 708, Camp Hill, Cumberland County, Pennsylvania 17011. 2. The Defendant, MICHAEL A. BLACK, is an adult individual and citizen ofthe United States of America, whose address is 408 Kings Highway, Marysville, Perry County, Pennsylvania 17053. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing ofthis Complaint. 4. Plaintiff and Defendant were married on or about February 25, 1983 in Camp Hill, Pennsylvania. 5. Plaintiff avers that there are no children of the parties under the age of 18. 6. Neither Plaintiff nor Defendant is a member of the United States Armed Services. 7. Plaintiff and Defendant have both been advised of the availability of marital counseling and that each may have the right to request that the court require the parties to participate in counseling. 8. Plaintiff avers that there has been no prior action for divorce or annulment of the marriage filed by either party in this or any other jurisdiction. 9. Plaintiff avers that the marriage is irretrievably broken, pursuant to Section 330l(c) of The Pennsylvania Divorce Code Act 206 of 1990. 10. Defendant has offered such indignities to the Plaintiff, the innocent and injured spouse, as to render her condition intolerable and life burdensome, pursuant to Section 3301(a)(6) of The Pennsylvania Divorce Code Act 206 of 1990. 11. This action is not collusive. WHEREFORE, Plaintiff prays your Honorable Court to enter a Decree of Divorce from the bonds of matrimony. Respectfully submitted, Date: November 2, 2004 ~4W MAX 1. SMITH, JR., I.D. No. 32114 JARAD W. HANDELMAN, Esquire I.D. No. 82629 James, Smith, Dietterick & Connelly LLP P.O. Box 650 Hershey, P A 17033 (717) 533-3280 I verify that the statements made in this Complaint are true and correct. I under- stand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. U7uit;J 6tw ~ ANITA L. B/~ (7J ...ca p -- ~ ~ ...() -l () "l . ,...." ~ () (') c:.::> ~ - C c.::) f'- ~:: .x.- ~ Z .-1 ',)'.,ii :c., - ~ C.'t) :.,~.. C~ rt1r-", 6"' -- 6' r :~:.~ 1,-' -on1 .....0 I TIC? (';'"1,"', U1 9(:-> -<::., ", ~~ (_.f ,.c-r, " () -r; 22r:~ -..o;:1P" -. () ~ ....... ,"'--rn ;.~ _.. W ~~~~ 'C :;2': .. .~ :;.i C> '"0 ~ '- N -< '" ANITA L. BLACK, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 2004-5576 Civil Term MICHAEL A. BLACK, Defendant : CIVIL ACTION - LAW : IN DIVORCE CERTIFICATE OF SERVICE AND NOW, this 8th day of November, 2004, I, MAX J. SMITH, JR., Esquire, Attorney for Plaintiff, hereby certify that I have this day sent a copy of Complaint in Divorce by depositing a certified copy of the same in the United States mail, postage prepaid, certified mail #70020860 000421422475 at Hummelstown, Pennsylvania, addressed to: Michael A. Black 408 Kings Highway Marysville, P A 17053 Mailing and return receipt cards attached hereto. MPJ fl!!i1SQrnre LD. No. 32114 JARAD W. HANDELMAN, Esquire LD. No. 82629 James, Smith, Dietterick & Connelly LLP P.O. Box 650 Hershey, P A 17033 (717) 533-3280 US Postdl S"'VI( ( CERTIFIED MAIL RECEIPT (Domestic Mail Only: No Insurance Coverage PrOV/Q<!d) ru c C lfi"nt To f'- ...............b~.c.r~t..Q....J~b.L!C............................._.... _t. Apt. No.; orPOBo1lNo. ' ~,... ~' i1' . ......................::!9 5_.._.i.::::Q~J..\.hL.~~~~.........__.......... CIty, ...... ZII4" \"111 ,." .., . , /),)-..J ,-. ~ "- ,', ~1'\~'VV\AlJ"lt. t"v IC....5 U'J f'- :T ru ru :T ..=t ru g; Postage $ . (0 () C C Certified Fee L- C Return Recefpt Fee ..D (Endorsement RequIred) o:Q Restricted DellVOl)' Fee C (Endorsement Required) lbtal PolItage & ..... $ CI 35C ';.1$ . Complete Items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. . Print your name and address on the reverse so that we can return the card to you. . Attach this card to the back of the mail piece, or on the front if space permits. 1. Miele Addressed to: ~ C. ~\(uJ a. ,.B(l c k. '-1<.Y6' t(~fV~ ~~vJ'L1 _ ~~~-~tV\ IJ I 7(:~ IIOS3 2. Article Number (Transfer from service Jabel) PS Form 3811 , August 2001 D. Is delivery address different from item 1? If YES, enter delivery address below: 3. ",ervice Type ~ Certified Mail 0 Express Mail o Registered 0 Return Receipt for Merchandise o Insured Mail 0 C.O.D. 4. Restricted Delivery? (Extra Fee) bQ Yes 7002 0860 0004 2142 2475 Domestic Return Receipt 10259!Hl1-M-2509 :~,~., , z:D ~~ ~CJ J> 20 )>0 c: ~ .,....,... <::~,::') <:::;) CJ'"' (/) f'T1 U N CJ1 ::t~ N (.n ,- t...';" o -n :r-n n1r-" :Q("T'; ~~)C' .:::::1(;, , . ~I:' ANITA L. BLACK, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 2004-5576 Civil Term MICHAEL A. BLACK, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDA VIT OF CONSENT AND WAIVER OF COUNSELING 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on November 5, 2004. 2. The marriage of Plaintiff and Defendant is irretrievably broken, and ninety days have elapsed since 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. 4. I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling. I further understand that the Court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a decree being handed down by the Court. 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. Date: {J, ~ ~ . 0& fkjJ~ ANITA L. BLACK ...-0 ~ ~ .' U\ V:1 ~ ~e, ~tQ <) \ ./,;~?~~ '0 '"...........\ -R'- :z (1 ~ "'-;" """J\1 \~;\\ ~;'.1.". '(~;:, ~~; \:; ::vC . 'i2 ~ ~ cP (1:'. "0 r;J... ANITA L. BLACK, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 2004-5576 Civil Term MICHAEL A. BLACK, Defendant : CIVIL ACTION - LAW : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER &3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a Final Decree of Divorce without further 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 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. Date: q ad.O~ fkfL~0 ANITAL. BLACK (") c: z:. -(.Ii] :l\i: ~;~~ ~: U;'; r:: .r.:.._ I;; ;:~~. ";;" s;; ::-J. -( r-) <= = 0..... (/) 1'1 -0 f') c..n -0 - -- ~ ~ :r: '"Tl 01- -o~ 'ie;' ?~] <2\ J:?: :Q r:-:? <.J'! (..,.) ANITA L. BLACK, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 2004-5576 Civil Term MICHAEL A. BLACK, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF COUNSELING 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on November 5, 2004. 2. The marriage of Plaintiff and Defendant is irretrievably broken, and ninety days have elapsed since 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. 4. I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling. I further understand that the Court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a decree being handed down by the Court. 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. Date: 9' - jg- 0<0 )/LL;Jt2~ MICHAEL A. BLACK o ~ '-':~9, .-< , \ \:--/ ' t-' ~ ~ c./>. Co ti, ~? fe, . ~.; ~-~.'t~ '2 ~ --'-n :r"r:: r\ K' --cq ~~~I.\Q, .~\~)~ \.:~~"\ ."") \-::.\ :-.;- ;""'") :.'4 -v ~ t;? cJ' ...... .... ANITA L. BLACK, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 2004-5576 Civil Term MICHAEL A. BLACK, Defendant CIVIL ACTION - LA W IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a Final Decree of Divorce without further 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 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. Date: 1 --19;- CJC /Yl';~e-J d dLL MICHAEL A. BLACK (') C ~:: -OIJ fYl ~.'1_ ~,~'/ (J-.:;;~ r;~ Z.~ ~ ~ v; ~ N c.r, ~~'~:, ~/ :2 r) "::=h .-\ ~-r\ ('ne, -OM j],~b .~_y: ....~i... qZ? 51'1 ~\ Y": ')? .- -0 _i'it --"','-.. r:-? U1 ~. . ' MARITAL SETTLEMENT AGREEMENT THIS AGREEMENT, made this ~~ day of ~ pnnJDtv ,2006, by and between ANITA L. BLACK (hereinafter called "Wife") and MICHAEL A. BLACK (hereinafter called "Husband"). WITNESSETH: WHEREAS, Husband and Wife were married on February 25, 1983; and WHEREAS, There has been one (1) child born of this marriage, who is emancipated; and WHEREAS, the parties hereto desire to fix and determine by this Marital Settlement Agreement the rights and claims that have accrued to each of them in the estate and real and personal property of the other by reason of the marriage, and all economic rights of every kind and description arising from the marital relationship, including but not limited to present and future rights of inheritance, support, maintenance, alimony, payment of counsel fees and equitable distribution and to accept the provisions of this Agreement in lieu of and in full discharge, settlement and satisfaction of all such rights and claims. NOW, THEREFORE, in consideration of the premises and of the marriage, and in further consideration of the mutual promises and undertakings hereinafter set forth, each intending to be legally bound hereby, the parties agree as follows: 1. SEP ARA TION. It shall be lawful for each party at all times hereafter to live separate and apart from the other party at such place as he or she may from time to time choose or deem fit. The foregoing provisions shall not be taken as an admission on the part of either party of the lawfulness or unlawfulness ofthe causes leading to their living apart. 2. INTERFERENCE. Each party shall be free from interference, authority and contact by the other, as fully as ifhe or she were single and unmarried except as may be necessary to carry out the provisions of this Agreement. 3. WIFE'S DEBTS. Wife represents and warrants to Husband that as of the date of separation she has not incurred, and in the future she will not contract or incur, any debts or liability for which Husband or his estate might be responsible and shall indemnify and save harmless Husband from any and all claims or demands made against him by reason of debts or obligations incurred by her. Any and all loans, and/or debts and charge accounts presently in Wife's name alone shall be Wife's sole and separate responsibility for payment thereof, and Wife agrees to indemnify and save harmless Husband from any loss he may sustain, including attorney fees, as a result of any default in payment by Wife. 4. HUSBAND'S DEBTS. Husband represents and warrants to Wife that as of the date of the separation he has not incurred, and in the future he will not contract or incur, any debt or liability for which Wife or her estate might be responsible and shall indemnify and save harmless Wife from any and all claims or demands made against her by reason of debts or obligations incurred by him. Any and all loans, and/or debts and charge accounts, presently in Husband's name alone shall be Husband's sole and separate responsibility for payment thereof, and Husband agrees to indemnify and save harmless Wife from any loss she may sustain, including attorney fees, as a result of any default in payment by Husband. 5. EQUITABLE DISTRIBUTION. Husband and Wife acknowledge and agree that the provisions of this Agreement with respect to the distribution and division of marital and separate property are fair, equitable and satisfactory to them based on the length of their marriage and other relevant factors which have been taken into consideration by the parties. Both parties hereby accept the provisions of this Agreement with respect to division of property in lieu of and in full and final settlement and satisfaction of all claims and demands that they may now have or hereafter have against the other for the equitable distribution of their property by any court of competent jurisdiction pursuant to Section 3502 of The Divorce Code or any other laws. 2 Husband and Wife voluntarily and intelligently waive and relinquish any right to seek a court ordered determination and distribution of marital property, but nothing herein contained shall constitute a waiver by either party of any rights to seek the relief of any court for the purpose of enforcing the provisions of this Agreement. 6. DIVISION OF PERSONAL PROPERTY, ACCOUNTS AND VEHICLES. The parties have divided between them, to their mutual satisfaction, the personal effects, bank accounts, household furniture and furnishings and all other articles of personal property which have heretofore been used by them in common. The parties expressly agree that Wife shall be entitled to exclusive ownership of any vehicle(s) currently in her possession, and that Husband shall relinquish any and all interest he may have in same. Wife agrees to be solely responsible for payment of any and all encumbrances, and all other expenses affecting such vehicle(s). Wife agrees to indemnify and save harmless Husband from any loss he may sustain, including attorney fees, as a result of any default in payment by Wife. Husband shall be entitled to exclusive ownership of the 1998 Chevrolet Silverado truck currently in his possession, and that Wife shall relinquish any and all interest she may have in same. Husband agrees to be solely responsible for payment of any and all encumbrances, and all other expenses affecting such vehicle. Husband agrees to indemnify and save harmless Wife from any loss she may sustain, including attorney fees, as a result of any default in payment by Husband. The parties further agree to execute any vehicle titles, Powers of Attorney or other documents necessary to give this Paragraph full force and effect, upon request. 7. PENSIONS AND EMPLOYMENT BENEFITS. Husband and Wife are the owners of certain pension plans and/or retirement plans and/or employee stock or savings plans, which they have accumulated during the course of their past and/or present employment. It is hereby specifically agreed that Husband and Wife each shall forever relinquish to the other his or her right, title and interest in said pension plans and/or retirement plans and/or employee stock or savings plans, as well as all other employment benefits, of the other. Specifically included herein are all benefits to which Husband is entitled through his employment with Perry County 3 Interiors and all benefits to which Wife is entitled through her employment with Quality Digial Office Technology. The parties agree to execute any and all documentation necessary to effectuate the terms herein contained. 8. IRA ACCOUNTS/BANK ACCOUNTS. In addition to the provisions that are set forth in paragraphs 6 and 7 above, the parties agree that Wife shall have exclusive ownership of the following accounts, free from any interest in Husband: (1) American Express Financial IRA, approximate value $18,000; and (2) First National Bank of Marysville statement savings account, approximate value $2,600. Further, the parties agree that Husband shall have exclusive ownership of the following accounts, free from any interest in Wife: (1) American Express Financial IRA, approximate value $24,000; and (2) First National Bank of Marysville passbook savings account, approximate value $4,000. 9. ALIMONY. Both parties agree to make no claim for alimony or alimony pendente lite now or at any future time, or in connection with the pending divorce action between the parties. 10. COUNSEL FEES. Husband and Wife agree to be solely responsible for payment of his or her attorney fees in connection with this Agreement and the pending divorce action between the parties. 11. FINANCIAL DISCLOSURE. The parties have disclosed to each other and they are aware of the extent of each other's income, assets, liabilities, holdings and estates. Husband and Wife confirm that by executing this Agreement each forever waives any future right to set aside said Agreement, or to defend against its enforcement or any portion thereof based upon the absence of such a disclosure by the other party, or based upon any claim that it is inequitable, unconscionable or does not make a reasonable provision for one or the other of them. 4 12. NO-F AUL T DIVORCE. Both parties agree to execute an Affidavit of Consent and Waiver of Notice of Intention to Request Entry of a Divorce Decree to facilitate entry of a divorce decree pursuant to Section 3301(c) of the Divorce Code contemporaneously with execution of this Agreement. However, the parties agree to refrain from concluding the divorce until August 21, 2006, as Wife shall continue to maintain health insurance coverage for Husband until that date, which is two years from the date of separation of the parties. 13. 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, including attorney fees, for such breach, or seek such remedies or relief as may be available to him or her respectively. 14. 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, including Deeds and other real estate-related documents, titles, pension documents, or other documents that may be reasonably required to give full force and effect to the provisions of this Agreement. 15. VOLUNTARY EXECUTION. The provisions of this Agreement and their legal effect have been fully explained to the parties by Max J. Smith, Jr., Esquire, attorney for Wife, and Kevin E. Prosser, Esquire, attorney for Husband, and each party acknowledges that the Agreement is fair and equitable, that full disclosure has been made by each respective party to the other, that it is being entered into voluntarily, and that it is not the result of any duress or undue influence. Wife and Husband acknowledge that they have been furnished with all information relating to the financial affairs of the other, which has been requested by them respectively. 16. WAIVER OF CLAIMS AGAINST ESTATE. 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 or hereafter acquire, under the 5 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, curtesy, statutory allowance, widow's allowance, right to take property against the Will of the other, and the 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 interest, rights and claims. 17. INCORPORATION OF AGREEMENT FOR ENFORCEMENT. This Agreement shall bind the parties hereto and their respective heirs, executors, administrators, legal representatives and assigns. This Agreement shall survive a decree of divorce between the parties in any jurisdiction and any other order which may be entered in accordance with this Agreement. In the event that a Decree of Divorce is entered in the Court of Common Pleas of Cumberland County, Pennsylvania or in the event that a Decree in Divorce is entered in any other jurisdiction, the parties agree to incorporate this Agreement in the Divorce Decree for purposes of enforcement. It is the specific intent of the parties to be bound by the provisions hereof in lieu of any other claim or order of support, maintenance, alimony, equitable distribution, counsel fees, costs, maintenance of insurance, equitable relief or property settlement or with regard to any other provision hereof. In the event that any final order of court is entered in any jurisdiction with respect to the parties hereto which is contrary to the provisions hereof, then the rights and responsibilities of each of the parties hereto shall be relieved or adjusted to the extent necessary to conform to this Agreement. 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. MODIFICATION AND WAIVER. A modification or waiver of any of the provisions of this Agreement shall be effective only if made in writing and executed with the same formality as this Agreement. The failure of either party to insist upon strict performance of 6 . . any of the provisions ofthis Agreement, shall not be construed as a waiver or any subsequent default of the same or similar nature. 20. DESCRIPTIVE HEADINGS. The descriptive headings used herein are for convenience only. They shall have no effect whatsoever in determining the rights or obligations of the parties. 21. IRREVOCABILITY. It is understood and agreed to by and between the respective parties hereto that the property division-distribution effected by the herein Agreement is IRREVOCABLE and that such division-distribution shall not be affected by any future change in circumstances of the respective parties OR by other statutory or judicial alternatives which may be available to the respective parties under prior, current or future laws of the Commonwealth of Pennsylvania or any other jurisdiction. Except as provided herein, the parties hereby waive any respective rights to financial support and/or alimony and/or pension or future expectancies each may respectively have under prior, current or future laws or case decisions. IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the day and year first above written. ~~ ---- fk;~)j~ ANITA L. BLACK /Jk./L. }t!,M-(!L MICHAEL A. BLACK WITNESS 7 (l C -r) ~~:;; l~~ :' r--) c:::> C'" cT" en 1"'1 -J N U1 -0 ~ ~-n n'p:' --r1i-n -j)O ?"'l (1.\ ~:fl ';~(') ,<:-"m ,..", :<\ ::r-> ~ __'./" ...,.)I.'''' ~ U1 ~. ANITA L. BLACK, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 2004-5576 Civil Term MICHAEL A. BLACK, Defendant : CIVIL ACTION - LAW : 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 Section (X) 330 I ( c) ( ) 3301 (d) of the Divorce Code. (Check applicable section). 2. Date and manner of service of the complaint: By certified mail on November 10. 2004. 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 Plaintiff September 22. 2006 ; by Defendant September 18. 2006 (b)(l) Date of execution of the Plaintiffs affidavit required by Section 3301 (d) ofthe Divorce Code: ; (2) date of service of the Plaintiffs affidavit upon the Defendant: 4. Related claims pending: None(}n ~ If . . Attorney for (X) PIa iff ( ) Defendant o ~ <~.:o.. \')6_ qJr:- 2', (/) ~.. ~~t~ ?:~ \, :b:: t:: -'/ ~~ ,< r-...:> = = cr- (/) rr1 V o "Tl ~:n -,., r:;:; --iJO ?')C :;J ~~ :-5e') ~m ~ =-< N (J1 -0 J: ~ (J1 C ;t;'I' llilli lli ;I; ;I; ;t; ;I; ;I; ;I; ;I; ~ ~ ~ ~ ~ ~ lli lli;l;;I; lli ;I; ;l;lli llilli '" llillillilli ;t;lli ~;I;;I; ;I;~~~~~~;I;~;I;~lli~lli~ ~~lli IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA. ANITA L. BLACK, Plaintiff No. 2004-5576 VERSUS MICHAEL A. BLACK, Defendant DECREE IN DIVORCE AND NOW, S e~ 't..~ ~t.(' ~ ~ 2006 , IT IS ORDERED AND DECREED THAT ANITA L. BLACK , PLAINTIFF, AND MICHAEL A. BLACK , 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; Marital Settlement Agreement dated 22 September 2006, is her~by incorporated into the Final Divorce Decree. :~:~~~\ \ ~\ \ j?~ '" '" '" ;+' lli '" :+:':.f. ~:f.:+: PROTHONOTARY 'I' 'I'~~~ ~ ~~~~;t;;I;~~ ~ ~~~~~~;I;~;I;~~;+'~~~~~ ~ ~ lli lli lli ~'r. ;I; ;+' ~ ~ '" ;+' '" ~ ;+' ;+' '" ;+' ~ ;+' ;+' ~ ;+' ;I; ;I; ;+' ~ 'I' J. ~ 'I' ;f."" ~tI' fJ:P $! ~ ~tt, 9tJ- LC -{; ~ frP 1-- ~ ,I"f,; . r'J 1(/- L -e b . "' , . .. ..... ,. . ' ,~ ANITA L. BLACK, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 2004-5576 Civil Term MICHAEL A. BLACK, Defendant CIVIL ACTION - LAW IN DIVORCE NOTICE OF INTENTION TO RESUME PRIOR NAME Notice is hereby given that the Plaintiff in the above matter, having been granted a final decree in divorce on the l?2(P~ day of ~~~bv..'" ,2006, hereby intends to resume and hereafter use the previous name of ANITA L. DITMER, gives this written notice avowing her intention in accordance with 54 Pa. C.S.A. 9704 as amended and supplemented to date. thm-x NtUCJ ANITA L. BLACK to be known as ~X~h[bf) ANITA L. DITMER SWORN and subscribed to before me this ~ day of WI"J-.bv-- , 2006. aQl0o\ ell. ~k NOTARY PUBLIC COMMONWEALTH OF PENNSYLVANIA Notarial Seal Alisa M. Stine, Notary Public Deny Twp.. Dauphin County My Commission Expires Nov. 19.2007 Member. Pennsylvania Association Of Notanes P -<<Q. 1 ~ r--~ ~ c,:.;. 0 C> = -n CT" .-1 \) 0 ..J:......, c; r\1F -~n\_~ ~ I :~~:'~~; \ ,- - - ~ r- 0 ,~c\:': :~"~: W ;.~.:::::(~ ~ VJ ,-- "') ~ ~ - ~.:::,~ D .- "r> C) '::C t' -t. :< 0:, I -