HomeMy WebLinkAbout04-6026
F \User Folder\Finn Docs\Gendocs2004\3 7S 1-1 dlY comp1amt wpd
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VENICE D. HAGAN,
Plaintiff
v.
CIVIL ACTION - LA W '-,--,
NO. 2004- ~CbLb C~u~l l~
MELVIN L. HAGAN, JR.,
Defendant
IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in court. If you wish to defend against the claims set forth in the
following pages, you must take prompt action. You are warned that if you fail to do so, the case may
proceed without you and a decree of divorce or annulment may be entered against you by the Court.
A 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 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, MARITAL PROPERTY,
COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR
ANNULMENT IS ENTERED, 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
32 South Bedford Street
Carlisle, Pennsylvania 17013
(717) 249-3166
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VENICE D, HAGAN,
Plaintiff
v.
CNIL ACTION - LAW
NO. 2004-
C~c..>~l ~~
MELVIN L. HAGAN, JR.,
Defendant
IN DNORCE
COMPLAINT IN DIVORCE
AND NOW, thisjD~day of November, 2004 comes Plaintiff, Venice D. Hagan, by and
through her attorneys, Hanft & Knight, P.C., and files the following Complaint in Divorce, and in
support thereof avers as follows:
1. The Plaintiff is Venice D. Hagan, who resides at 617 Ligett Road, Carlisle,
Cumberland County, Pennsylvania 17013.
2. The Defendant is Melvin L. Hagan, Jr., who resides at 1516 Old Shell Road, Port
Royal, South Carolina 29935.
3. The Plaintiff and Defendant are sui juris, and Plaintiff has been a bona fide resident
of the Commonwealth of Pennsylvania and has so been for a period of more than six (6) months
immediately preceding the filing ofthis Complaint in Divorce.
4. The parties were married on October 25,2000, in Cumberland County, Pennsylvania.
5. The marriage is irretrievably broken. The foregoing facts are averred and brought
under Section 330l(c) or 330l(d) of the Divorce Code of 1980, as amended.
6, The Plaintiffhas 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, and
Plaintiff waives same.
7. Plaintiff is an active duty member ofthe United States Army.
WHEREFORE, Plaintiff requests Your Honorable Court to enter a Decree in Divorce,
divorcing the Plaintiff from the Defendant.
Respectfully submitted,
Sean M. Shultz, Esquir
Attorney ill No. 90946
11 Roadway Drive, Suite B
Carlisle, Pennsylvania 17013
(717) 249-5373
Attorneys for Plaintiff
VERIFICATION
The foregoing Complaint in Divorce is based upon information which has been gathered
by my counsel in the preparation of the lawsuit. The language of the document is that of counsel
and not my own. I have read the Complaint in Divorce and to the extent that the document is
based upon information which I have given to my counsel, it is true and correct to the best of my
knowledge, information and belief. To the extent that the content of the document is that of
counsel, I have relied upon counsel in making this verification.
This statement and verification are made subject to the penalties of 18 Pa. C.S. Section
4904 relating to unsworn falsification to authorities, which provides that if I make knowingly
false avennents, I may be subject to criminal penalties,
Yen. ~~~an~ JJ;jOL
"-
~
~
"'<)
--.,Q
7d
~
~ ~
't.~
C>
~ e
lI1 -J
P=-
~
~
','
o
~-:
.....
i:'
,..
......,
c..--::>
c::>
....-
o
ro
(J
I
(";
~~~;
:.:2
~
:-:1
fhFJ
rn
jje;>
::1 Sf
"~L "71
::7. ~'2 (-')
-"~ ~S rr
- ~
.. ~:....
en :.Q
.{:"'
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VENICE D. HAGAN,
Plaintiff
v.
CIVIL ACTION - LAW
NO. 2004-6026
MELVIN L. HAGAN, JR.,
Defendant
IN DIVORCE
AFFIDAVIT OF CONSENT
STATE OF PENNSYLVANIA
)
: SS.
)
COUNTY OF CUMBERLAND
1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on
December 1,2004.
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 after service of notice ofintention
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 prior to a Divorce
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: ~ .5
,2005
~lu ~. ~a~
V . e D. Hagan
Sw~~ to and subscribed before me this
5- dayofArri) ,2005.
-~ -AN;@ '1 '9VmAxd
Notary Pub i
'\lotiO\ria!S.9d
Dolly M. Housel, Netary Public
South Middleton l1;'iQ., Cum::,,€,r.and GC'un~1
My Commis.':,jon [)(Dires '8(;:,;t 24, 2':)~,>:
M~'''y,>''''~
1
o
(;
'-
r-J
<='
~
:<:-
-oJ
;:;Q
I
-'
--
'-
~
-c
~:!I
':',"8
'1:)1"
?i:!:~~
S'~ (~')
61\1
-"!,
2,:;';
:<
...;..,;
~
en
0:>
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
VENICE D. HAGAN,
Plaintiff
v.
CIVIL ACTION - LAW
NO. 2004-6026
MELVIN L. HAGAN, JR.,
Defendant
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY
OF A DIVORCE DECREE UNDER &3301(C) OF THE DIVORCE CODE
I. 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 Affidavi t are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa. C.S. 94904 relating to unsworn
falsification to authorities.
Date: 4/5/05
V)f'i;;'M b. ~~
~:.
"
'-'0
"::;. -<'
f0E
-I'" \'DC(,
."\
.'\..- ;.'\
(::?\i~"
:.....- ~1\.
::~.~,{:-{\
?~}
'_--:.:.-\
-~~.
."-
~
<--1".
cP
r::=;
~?
~{j'
-
-.:::..:}
-;;0
~
--<'
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VENICE D. HAGAN,
Plaintiff
v.
CIVIL ACTION - LAW
NO. 2004-6026
MELVIN L. HAGAN, JR.,
Defendant
IN DIVORCE
CERTIFICATE OF SERVICE.
AND NOW, this~~ day of April, 2005, I, SeanM. Shultz, Esquire, hereby certify that the
following person was served with a True and Correct copy of the Complaint in Divorce filed in the
above-referenced matter. The Complaint in Divorce was mailed on December 22, 2004, but actual
service took place on January 3,2005, by Defendant signing for a copy of the Complaint in Divorce
which was mailed in the United States Mail, Certified Mail--Return Receipt Requested, Restricted
Delivery, Postage Prepaid, addressed as follows:
Melvin L. Hagan, Jr.
7845 Candlestick Lane, #308
Midvale, Utah 84047
A copy of the signed Domestic Return Receipt is attached hereto as Exhibit "A" and by
reference incorporated herein and made a part hereof.
Respectfully submitted,
Sean M. Shultz, Esquire
Attorney ID No. 90946
11 Roadway Drive, Suite B
Carlisle, Pennsylvania 17013
(717) 249-5373
FIUser Foldcr\Finn DocsIGcndocs2005\3751-1cel1 serviccwpd
Attorncys for Plaintiff
#
SENDER: COMPLETE THIS SECTION
. Complete items 1, 2. and 3. Also complete
item 4 jf 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 mailpiece,
or on the front if space permits.
"1. Article Addressed to:
Mdv'Jn L l+~V11 \f(.
-:r~45 C(,Lf'tdleS#C/~ LW1.L
MldvQ.lR1 Ll+ah(/' -#3DK
o404-"t'
2. ..
COMPLETE THIS SECTION ON DELIVERY
3~ServJ ype
rtlfled Mall D Express Man
Registered 0 Return Receipt for Merchandise
D Insured Mall D C.O.D.
4. Restricted Delivery? (Extra Fee)
A. Signature
x
7003 3110 0004 5770 0372
ilii
,i ,i ,',' I' ,I Iii' i
Ij}ii
I
o Agent I
o Addressee
C. Date of OeIi'llery 1
Dves
ONe
I
\
i
(
10259S-Q2-M.1540 I
~
ps Form 3e.11)Fe:~ruary 2Q04 i j i j i ~ )Qom~j9 Return Receipt
(') ", (..:..)
c.:::,'::t
c: c,;.) -n
, <J1
""" .-1
-r
-'iJ ffi:D
;;\J -, r;;
I -Rc::.)
-.J ~~~1
-0
" C:5rn
t-'_ N ~-\
:3 -r."
c.Jl :D
'. c::J ....:
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VENICE D. HAGAN,
Plaintiff
v.
CIVIL ACTION - LAW
NO. 2004-6026
MELVIN L. HAGAN, JR.,
Defendant
IN DIVORCE
NOTICE TO DEFENDANT
If you wish to deny any ofthe statements set forth in this Affidavit, you must file a counter-
affidavit within twenty (20) days after this affidavit has been senred on you or the statements will
be admitted.
PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d)
OF THE DIVORCE CODE
1. The parties to this action separated on July 2, 2003 and have continued to live
separate and apart from each other for a period of at least two years.
2. The marriage is irretrievably broken.
3. I understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses ifl 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 of18 Pa. C.S.A. Section 4904 relating to unsworn
falsification to authorities.
Date: 15 0\)\~ OS"
Ve . eD. ~aJjlaii6r8()J--
,...'
~
~~
<---
c:::'
r"-
-.:>
'\'-0
Q,
.-\
-r.;",
"f1"\f:::
-'(1):\,
:~~\'1)
::..:;.:.:~ '':'\~
-\:,;~(~
,-r'"
-,
';::;'\
~
~
~
-;:
~?
.-
'_I'
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VENICE D. HAGAN,
Plaintiff
v.
CIVIL ACTION - LAW
NO. 2004-6026
MELVIN L. HAGAN, JR.,
Defendant
IN DIVORCE
CERTIFICATE OF SERVICE
AND NOW, this3~ay of September, 2005, I, Sean M. Shultz, Esquire, hereby certify
that the following person was served with a True and Correct copy of Plaintiffs Affidavit Under
Section 3301(d), Defendant's Counter-Affidavit Under Section 3301(d) and Notice of Intention to
Request Entry of Divorce Decree in the above-referenced matter. The documents were mailed on
September 21,2005, but actual service took place on September 24,2005, by Defendant signing for
a copy of the Complaint in Divorce which was mailed in the United States Mail, Certified Mail--
Return Receipt Requested, Restricted Delivery, Postage Prepaid, addressed as follows:
Melvin L. Hagan, Jr.
7845 Candlestick Lane, #308
Midvale, Utah 84047
A copy of the signed Domestic Return Receipt is attached hereto as Exhibit "A" and by
reference incorporated herein and made a part hereof.
Respectfully submitted,
F:\User FolderlFinn Docs\Gendocs2005\3751-1cert,service.2.wpd
ean M. Shultz, q e
Attorney ill No. 90946
11 Roadway Drive, Suite B
Carlisle, Pennsylvania 17013
(717) 249-5373
Attorneys for Plaintiff
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 mailpiece,
or on the front if space permits.
1. Micle Addressed to:
Melvit1 L. HQ901l,Jf;'<,,-,
1~4 5 C(l~dleS'l-j Cl:. Ltv\e
7P- 30g
M.1dVo.1ej Ufah g404-.:J.
~i 1003 3110 0004 5770 0556
c. Signature
x
D,
o Agent
o Address,
DYes
o No
----
'"
c-
o
""
..,.
'"
0-
L
tf;'
^ ,
~
(/)
::0
3. Service Type
~rtified Mail
o Registered
o Insured Mail
4. Restricted Delivery? (Extra Fee)
Yes
102S9S-99-M-17f.
PS Form 3811, July 1999
Domestic Return Receipt
()
C'~
"'"
c.::.
t:::::;,
eon
(:)
"
-I
I
..,..
o
-1'1
-I
:T:j).
m-
r-
:::;q
_U',,'
r:,) (1
---1.)
. ~.~ :;.:-:
i~f'~
~r-_-';
:n
.<
~~
LO
"
a.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VENICE D. HAGAN,
Plaintiff
v.
CIVIL ACTION - LAW
NO. 2004-6026
MELVIN L. HAGAN, JR.,
Defendant
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the following information, to the court for entry of a divorce
decree:
1. Ground for divorce: irretrievable breakdown under Section 3301 (d)(l) of the Divorce
Code.
2. Date and manner of service of the complaint: Mailed to Defendant on December 22,
2004 by U.S. certified, return receipt requested, restricted delivery mail and served on Defendant on
January 3,2005.
3. Date of execution ofthe Plaintiff's affidavit required by S 3301( d) of the Divorce code:
July 15, 2005.
4. Date of filing and service of the Plaintiff s affidavit upon the Defendant: Filed on July
22,2005 and mailed to Defendant on September 21, 2005 by U.S. regular and certified, return receipt
requested, restricted delivery mail.
5. Related claims pending: None.
6. Date and manner of service of the Notice of Intention to File Praecipe to Transmit
Record, a copy of which is attached: Mailed to Defendant on September 21,2005 by U.S. regular and
certified, return receipt requested, restricted delivery mail.
Date: 9121/D5
Sean M. ShUltz, Esquire
Attorney 1.0. No. 90946
11 Roadway Drive, Suite B
Carlisle, Pennsylvania 17013
(717) 249-5373
Attorneys for Plaintiff
FIUser FolderlFirm Docs\Gel1docs2005\3751-] praceipe_wpd
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VENICE D. HAGAN,
Plaintiff
v.
CIVIL ACTION - LAW'
NO. 2004-6026'
MELVIN 1. HAGAN, JR.,
Defendant
IN DIVORCE
NOTICE OF INTENTION TO REOUEST ENTRY OF DIVORCE DECREE
TO: MELVIN 1. HAGAN, JR., Defendant
You have been sued in an action for divorce. You have failed to answer the complaint or file
a counter-affidavit to the Plaintiffs affidavit. Therefore, on or after October 12, 2005, the Plaintiff
can request the Court to enter a final decree in divorce.
If you do not file with the Prothonotary ofthe Court an answer with your signature notarized
or verified or a counter-affidavit by the above date, the Court can enter a final decree in divorce.
Unless you have already filed with the Court a written claim for economic relief, you must do so by
the above date or the court may grant the divorce and you will lose forever the right to ask for
economic relief. A COUNTER-AFFIDAVIT WHICH YOU MAY FILE WITH THE COURT
IS ATTACHED TO THIS NOTICE.
UNLESS YOU HAVE ALREADY FILED WITH THE COURT A WRITTEN CLAIM
FOR ECONOMIC RELIEF, YOU MUST DO SO BY THE ABOVE DATE OR THE COURT
MAY GRANT THE DIVORCE AND YOU WILL LOSE FOREVER THE RIGHT TO ASK
FOR ECONOMIC RELIEF. THE FILING OF THE FORM COUNTER-AFFIDAVIT
ALONE DOES NOT PROTECT YOUR ECONOMIC CLAIMS.
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
32 South Bedford Street
Carlisle, Pennsylvania 17013
Phone (717) 249-3166
F:\User Foldcr\Finn Docs\Gendocs200S\3751-lnotice.intent wpd
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VENICE D. HAGAN,
Plaintiff
v.
CIVIL ACTION - LAW'.
NO. 2004-6026 ,
MELVIN 1. HAGAN, JR.,
Defendant
IN DIVORCE
DEFENDANT'S COUNTER-AFFIDAVIT UNDER SECTION 3301(d)
OF THE DIVORCE CODE
1. Check either (a) or (b):
(a) I do not oppose the entry of a divorce decree.
(b) I oppose the entry of a divorce decree because (check (i), (ii) or both):
(i) The parties to this action have not lived separate and apart for a period
of at least two years.
(ii) The marriage is not irretrievably broken.
2. Check either (a) or (b):
(a) I do not wish to make any claims for economic relief. 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.
(b) I wish to claim economic relief which may include alimony, division of
property, lawyer's fees or expenses or other important rights.
I UNDERSTAND THAT IN ADDITION TO CHECKING (B) ABOVE, I MUST ALSO
FILE ALL OF MY ECONOMIC CLAIMS WITH THE PROTHONOTARY IN WRITING
AND SERVE THEM ON THE OTHER PARTY. IF I FAIL TO DO SO BEFORE THE
DATE SET FORTH ON THE NOTICE OF INTENTION TO REQUEST DIVORCE
DECREE, THE DIVORCE DECREE MAY BE ENTERED WITHOUT FURTHER DELAY.
I verify that the statements made in this counter-affidavit are true and correct. I understand
that false statements herein are made subject to the penalties of18 Pa.C.S. g4904 relating to unsworn
falsification to authorities.
Date:
Melvin 1. Hagan, Jr., Defendant
NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE
AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU
SHOULD NOT FILE THIS COUNTER-AFFIDAVIT.
n '"
C. c:::.' ()
<:-.C';':l
,~ a. .,
0 ::::1
,""") hlp
'TJ (:-~
GO J c::;
) I
, r.)
-, i
-~. :'....
..r;- , n
N
01
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
~
~
~
~
~
To
~
~
~
~
To
To
~
~
~
~
To
To
To
~
~
'f.
~
To
To
~
To
~
To
To
~
~
~
~
To
~
~
To
~
To
~
~
~
~
'f.
~
~
~
To
~
'f.
To
~
~
~
To
'f.
~
~
~
~
~
To
~
~
~
To
~
~
'f.
To
~
'f.
To
~
~
'f.
To
~
~
To
~
To
~
~
'f.
To
To
To
'f.
To
To
To
~
To
To
~
To
To
'f.
To
To
To
~To'f.To~ToTo~~~To~~~'f.~~~~~'f.'f.~~~~~'f.~~~'f.'f.'f.'f.~'f.'f.'f.~'f.'f.'f.'f.~'f.'f.'f.
'f.
~
~
~
To
To
~
~
'f.
~
~
'f.
'f.
!I-
~
'f.
'f.
~
~
'f.
To
~
~
+
-~~
~
~
~
+.
To
~
~
~
!I-
!I-
~
~
!I-
'f.
!I-
~
'f.
+.
To
~
~
+.
'f.
~'f.'f.'f.To'f.To'f.~'f.To'f.ToTo'f.To'f.ToTo~~+''f.To~'f.'f.~~
IN THE COURT OF COMMON PLEAS
OFCUMBERLANDCOUNTY
STATE OF
PENNA.
VENICE D. HAGAN,
Plaintiff
No.
2004-6026
VERSUS
MELVIN L. HAGAN, JR.,
Defendant
DECREE IN
DIVORCE
AND NOW,
(\Q~~t
-
, IT IS ORDERED AND
2005
DECREED THAT
VENICE D. HAGAN
, PLAI NTI FF,
AND
MELVIN L. HAGAN, JR.
, 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
ENTEREkJo~
._),,"'....
/><"
/1'
:' .
?
J~
By THE COURT:
,/
" ':L,!'f
'\ ...~,--~,~" V
"~,/. ~,
ATTEST~ · 4
~~.~~~
-~
~.
.........
"-......"J"
)
/
PROTHONOTARY
~ ~ rpf7YY ~
~.f/ F~~.P)I1J
. .
." .. .
5J';;r' -OJ
cP
w-/; L . (J/
,)
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VENICE D. HAGAN,
Plaintiff
v.
CIVIL ACTION - LAW
No. 2004-6026
MELVIN L. HAGAN, JR.,
Defendant
IN DIVORCE
NOTICE OF ELECTION TO RETAKE FORMER NAME
Notice is hereby given that the Plaintiff in the above matter having been granted a Final
Decree in Divorce from the bonds of matrimony on the 21st day of October, 2005, hereby elects to
retake and hereafter use her previous name of Venice Diana Costello and gives this written notice
avowing her intention in accordance with the provisions ofthe Act of December 16, 1982, P.L. 1309,
No. 295, Section 2,54 Pa. C.S.A. Section 704.
~~~
V
COMMONWEALTH OF PENNSYLVANIA )
:SS.
COUNTY OF CUMBERLAND )
On the 22~ay of February, 2006, before a Notary Public, personally appeared Venice
Diana Hagan, to be known as Venice Diana Costello, known to me to be the person whose name is
subscribed to the within document, and acknowledged that she executed the foregoing for the
purpose therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and Notarial Seal.
1 ~.~._~.,~~_~I,~:-~'~'~"-'___ _ ", __ '''' _ __ "
f: \User-tok1er\J:'irm-D(lCS\Gendoc~OO6\J751-1~_erake maiden. name wpd
r'
---,
-40.
P -::t
"P 7'- \)
~ \:\- (7
~ .-'..
c' .
- r-
-- ..J::
--.l ~
--I:::... -F -'
~ c "
L/J
~
r