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HomeMy WebLinkAbout04-6410 REBECCA A. TRAVIS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW Defendant : NO. o~. l-lf (0 : IN DIVORCE CIVIL TERM TODD T. TRAVIS, 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 will proceed without you and a decree of divorce or annulment may be entered against you for any 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 at Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania, 17013. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITH INFORMA nON ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 REBECCA A. TRAVIS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION - LAW Defendant NO. () i- tr, 41 0 IN DIVORCE CIVIL TERM TODD T. TRAVIS, COMPLAINT IN DIVORCE NO FAULT 1. Plaintiff is Rebecca A. Travis, an adult individual currently residing at 8 Lilac Drive, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant is Todd T. Travis, an adult individual currently residing at 2200 Susquehanna Trial, Apt. 16, York, York County, Pennsylvania. 3. Plaintiff is a bonafide resident of the Commonwealth of Pennsylvania and has been so for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on January 23,2000, in Las Vegas, Nevada. 5. There have been no other prior actions for divorce or annulment between the parties. 6. Neither the Plaintiff nor the Defendant are members of the United States Armed Forces or its Allies. 7. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling. 8. Plaintiff and Defendant are citizens of the United States of America. 9. The parties' marriage is irretrievably broken. 10. Plaintiff desires a divorce based upon the belief that the Defendant will, ninety (90) days from the date of the filing of this Complaint, consent to this divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a divorce pursuant to 23 P.S. Section 3301 (c) of the Domestic Relations Code. COUNT V EQUITABLE DISTRIBUTION 11. Paragraphs 1 through 10 are incorporated herein by reference as if set forth in their full text. 12. Plaintiff and Defendant are joint owners of various items of personal property, furniture, and household furnishings acquired during their marriage which are subject to equitable distribution. 13. Plaintiff and Defendant are joint owners of real estate located in Cumberland County, which was acquired during their marriage and which is subject to equitable distribution. 14. Plaintiff and Defendant have incurred debts and obligations during their marriage which are subject to equitable distribution. WHEREFORE, Plaintiff requests your Honorable Court to enter a decree equitably dividing the parties' property and equitable apportioning the debts incurred by the parties. Respectfully submitted, .. ~-S~ES~~-~ ~f. y fi r Plaintiff G FFIE & ASSOCIATES 200 North Hanover Street Carlisle,PA 17013 (717) 243-5551 (800) 347-5552 VERIFICATION I verify that the statements made in the foregoing document 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 falsifications to authorities. DATE: '~)d-\ )0--\ /~ l~.A,,^~ Rebecca A. Travis, Plaintiff ~~ -- ~ c:.q ~ ~ Vc ~ w .... \1\. ,. ) ,....,~) .. " ') C') , '- ., -- - ..~{ I r-'1 --~ j ( I :_,C~ i~! l ~ i r,,) .. . . fil ; ,::,') ~i , ...) .1 r ... d -; " - - (~) ) :.;~~! (' ~""j> > I ( " '. "'~ ~: ~ F , ~ ..n C)! C> () . I. . ~%d ~ ~ ~ ~ ~ f. REBECCA A. TRAVIS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, : CIVIL ACTION - LAW Defendant : NO. 04-6410 : IN DIVORCE CIVIL TERM TODD T. TRAVIS, AFFIDAVIT OF SERVICE AND NOW, this /7- #V day of January, 2005, comes Marylou Matas, Esquire, counsel of record for Plaintiff, Rebecca A. Travis, and states that a true and attested copy a Complaint in Divorce, was sent to Defendant, Todd T, Travis, at 2200 Susquehanna Trail, Apt 16, York, PA 17404, by certified mail, restricted delivery, return receipt requested. Service of said Complaint was made on December 28, 2004. w. o~ Maryl Matas, (squire Attorney for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 Sworn and subscribed to before me this 17 t!I day of ,2005 // NO ~ NOTARiAl SEAL R08I1U GOSHORN, NOTARY PUBlIC CARLISLE BORO., ClJMBERLAND COUNTY MY COMMISSION EXPIRES APRILJ 7 2007 CJ CJ CJ CJ tr .-'I CJ .-'I Certified Fee Return Receipt Fee a- (Endorsement Required) c:::J Restricted Delivery Fee o (Endorsement Required) CJ Total Postage & Fees CJ .-'I ~S79dd..:rCnL~n~unnmm.mnn Street, Apt. No,; ;:j O'.~ B~'.N'~~.c:>51A...'S'L~~~,:,c"T~ltll-pl-L ~ c. '';-'L PA J !'f=L/ s._~ ~MlIIII~~M8Il C RegioIeIod AIIil~ ReceIpt for M..__ C 1_ Mall 1::i-ao.D. 4. _ DeIIvorII (e<ft F<le) ~ 7001 2510 0009 1019 0000 . _-'rleleltems 1. 2, end 3. ,.., complete -'411 Reelrtcted Delivery Is deeinld. . PIllIIyaur name end l!d!l- on the _ _that we can return the cerd to you. . AIlIlch this cerd to the back of the meHplece, .... on the front II opace permits. t. _._to: "'-oed. .,... - I ~~' "Z-'1..C>O ~t ~c-r.I'\e.. ~ ~~.Ib 'lorY- \ PA 17 o.fo'f" 2. _Number PS=~!tt-'-Itl,; -- Donlodc -... """"'" 1. ..'&to '. ~'I t --' ~.\- -'. \i.'\ .,);:"0 %Q 7r;,;; 3. ~ o .' ;r::- ef' - SEPARATION AND PROPERTY SETTLEMENT AGREEMENT THIS AGREEMENT, made this 6ffA day of jlAj, U(U"6 ' 2006, by and between TODD T. TRA VIS., of York County, Pennsylvania, party of the first part, hereinafter referred to as "H usbuJl(l", AND REBECCA A. TRA VIS, of Cumberland County, Pennsylvania, party of the second part, hereinafter referred to as "Wife", WITNESSETH: WHEREAS, the parties hereto are husband and wife, having becn married on January 23,2000, in Las Vegas, Nevada; and WHEREAS, diverse unhappy differences, disputes and difficulties have arisen between the parties and it is the intention of Wife and Husband to live separate and apart, and the parties hereto are desirous of settling their respective fmancia1 rights and obligations as between each other, and to finally and for all time to settle and determine their respective property and other rights growing out of their marital relations; and wish to enter into this Separation and Property Settlement Agreement; and WHEREAS, both and each of the parties hereto have had the opportunity to be advised of their legal rights and the implications of this Agreement and the legal consequences which may and will ensue from the execution hereof; and WHEREAS, Wife acknowledges that she has had the opportunity to be thoroughly conversant with and know accurately the size, degree, and extent of the estate and income of Husband and Husband acknowledges that he has had the opportunity to be thoroughly --Page 1 of 14-- conversant with and know accurately the size, degree, and extent of the estate and income of Wife; NOW, THEREFORE, in consideration of the premises and of the mutual promIses, covenants and undertakings hereinafter set forth which are hereby acknowledged by each of the parties hereto, Wife and Husband, each intending to be legally bound hereby, covenants and agree as follows: I, Advice of Counsel: The parties acknowledge that they have received independent legal advice from counsel of their own selection or that they have elected not to seek independent legal advice and that they fully understand the facts and have been fully informed as to their legal rights and obligations and they acknowledge and accept that this Agreement is, in the cirCllmstance, fair and equitable and that it is being entered into freely and voluntarily after having received such advice and with such knowledge that execution of this Agreement is not the result of any duress or undue influence and that it is not the result of any collusion or improper or illegal agreement or agreements and the parties hereto state that he/she, in the procurement and execution of this Agreement, has not been subject to any fraud, concealment, overreaching, imposition, coercion, or other unfair dealing on the part of the other, or on the part of the other's counsel. The provisions of this Agreement and their legal effect have been fully explained to Husband by his counsel, Martin Miller, Esquire and to Wife by her counsel Marylou Matas, Esquire. 2. Warrantv of Disclosure: The parties warrant and represent that they have made a full disclosure of all assets and their valuation prior to the execution of this Agreement. This disclosure was in the form of an informal exchange of information by the parties but also reflects --Page 2 of 14-- the fact that the parties had personal knowledge before their separation of their various assets and debts all of which fom1 the basis of this Agreement between the parties. 3, Personal Rif!hts and Sevaration: Wife and Hnsband may and shall, at all times hereafter, live separate and part, They shall be free from any control, restraint, interference or anthority, direct or indirect, by the other in all respects as if they were unmarried. They may reside at such place or places as they may select. Each may, for his or her separate use or benefit, conduct, carryon and engage in any business, occupation, profession or employment which to him or her may seem advisable, Wife and Husband shall not molest, harass, disturb, nor malign each other or the respective families of each other nor compcl or attempt to compel the other to cohabit nor dwell by any means or in any manner whatsoever with him or her. 4. Al!reement not a Bar to Divorce Proceedinl!s: This Agreement shall not be considered to affect or bar the right of Wife or Husband to a limited or absolute divorce on lawful grounds if such grounds now exist or shall hereafter exist or to such defense as may be available to either party. This Agreement is not intended to condone and shall not be deemed to be a condonation on the part of either party hereto of any act or acts on the party of the other party which may have occasioned the disputes or unhappy differences which have occurred prior to or which may occur subsequent to the date hereof The parties intend to secure a mutual consent, no-fault divoree pursuant to the terms of S3301(c) of the Divorce Code of 1980. 5, Al!reement to be Incomorated in Divorce Decree: The parties agree that the terms of this Agreement shall be incorporated into any divorce decree which may be entered with respect to them. Notwithstanding such incorporation, this Agreement shall not be merged into the decree, but shall survive the same and shall be binding and conclusive on the parties for all time. --Page 3 of 14-- " 6. Date of Execution: The "date of execution" or "execution date" of this Agreement shall be defined as the date upon which it is executed by the parties if they have each executed the Agreement on the same date. Otherwise, the "date of execution" or "execution date" of this Agreement shall be defined as the date of execution by the party last executing this Agreement. 7, Personal Propertv: Husband and Wife do hereby acknowledge that they have previously divided their tangible personal property including, but without limitation, jewelry, clothes, furniture, furnishings, rugs, carpets, household equipment and appliances, pictures, books, works of art and other personal property. Wife agrees that all of the property in the possession of Husband shall be the sole and separate property of Husband and Husband agrees that all of the property in the possession of Wife shall be the sole and separate property of Wife, The parties do hereby specifically waive, release, renounce and forever abandon whatever claims, if any, he or she may have with respect to the above items which shall become the sole and separate property of the other, with full power to him or her to dispose of the same as fully and effectually, as though he or she were unmarried. 8. Marital Debt: Each party hereby confirms that they have not incurred any additional debt since their separation that has, in any way, obligated the other party. Neither party will take any action to incur additional debt of any nature whatsoever in the other party's name from the date of execution of this Agreement forward. Wife has paid the following debts since the time of the parties' separation: Chase, with an approximate date of separation balance of $2,825 Home Depot (account number *5188), with an approximate date of separation balance of $1,473.70 hPage 4 of 14-- Home Depot (account number *1462) with an approximate date of separation balance of $4,532.27 Bank One, with an approximate date of separation balance of$3,051.78 AT&T, with an approximate date o~~ation balance of$8,482,45. C'hu.'-Z.~ With the exception of the AT&T debt, all other credit card debts mentioned above are satisfied in full, either through Wife's sole efforts or through use of the proceeds received through the sale of the fornler marital resi.~~xPlained in paragraph 12 below. Wife shall C VI l.l1J1. \W continue to make payments on this AT&T debt (now known as Providian) until paid in full. The parties agree that there are no other joint debts, They have not incurred other debts since separation in the other's name. 9. Bank Accounts: For the mutual promises and covenants contained in this Agreement, Husband and Wife hereby waive all right, title, claim or interest they may have by equitable distribution in their respective bank accounts, checking or savings, if any, and each party waives against the other any duty of accounting for disposition of any jointly held funds. 10. After-Acquired Personal Prooertv: Each of the parties shall hereafter own and enjoy, independently of any claim or right of the other, all items of personal property, tangible or intangible, hereafter acquired by him or her, with full power, in him or her to dispose of the same as fully and effectively, in all respects and for all purposes, as though he or she were unmarried. 11, Motor Vehicles: With respect to the motor vehicles owned by one or both parties, the parties agree as follows: a.) Husband shall retain sole and exclusive possession of the parties' Ford Explorer. Wife shall make no claim to Husband's access or ownership of said vehicle. It is believed that this vehicle is titled in Husband's name individually. In the event it --Page 5 of 14-- " is discovered that this vehicle is listed in the parties' names jointly. Wife will promptly execute any and all necessary documents to transfer this vehicle to Husband's name individually. b.) Wife retained sole and exclusive possession of the parties' GMC Jimmy. Husband shall make no claim to Wife's access or ownership of said vehicle. In the event it is discovered that this vehicle is listed in the parties' names jointly, Husband will promptly execute any and all necessary documents to transfer this vehicle to Wife's name individually. 12. Real Estate: During their marriage, the parties owned real estate located at 8 Lilac Drive, Mechanicsburg, Pennsylvania. The parties sold that real estate and received proceeds in the total amount of $11,430.75. From those proceeds, payments were made to Chase/Bank One credit card in the amount of $7,300 and to OSI in the amount of $4,000 to satisfy joint marital credit card debt. There remains approximately $140, which Wife will retain. 13. Payment to Wife: For her interest in the marital estate, Husband shall make & p~yment to Wife in the~mount of $4,800, in twelve equal installments of $400, beginning k brlil{(I{ 10,2C(h and continuing for twelve months thereafter. This shall include reimbursement for arrears withheld from settlement in the amount of $2,371.48; 27% of Husband's September bonus; additional amounts due from Husband's June bonus; and additional amounts due to Wife for her interest in the marital estate. 14. Pension Interests: Husband hereby waives, relinquishes and transfers any and all right, title and interest he has or may have in Wife's pension, retirement account, or deferred compensation account, as well as other accounts that Wife may have in her individual name or may have secured through her present or prior employment. --Page 6 of 14-- Wife hereby waives, relinquishes and transfers any and all right, title and interest he has or may have in Husband's pension, retirement account, or deferred compensation account, as well as other accounts that Husband may have in his individual name or may have secured through his present or prior employment. 15. Warranty as to Post SeDaration and Future Ohlizations: Husband and Wife each covenant, warrant, represent and agree that each will now and at all times hereafter hold harmless and keep the other party indemnified from all debts, charges and liabi lilies incurred by the Husband or Wife, respectively. 16. SDousal SUTJDort, Alimony, Alimony Pendente Lite, and Spousal Maintenance: a.) Husband hereby waives any right or claim of any nature whatsoever relative to alimony, alimony pendente lite, spousal support, spousal maintenance, counsel fees and expenses against Wife. b.) Wife hereby waives any right or claim of any nature whatsoever relative to alimony, alimony pendente lite, spousal support, spousal maintenance, counsel fees and expenses against Husband. 17. Mutual Releases: Husband and Wife each do hereby mutually remise, release, quitclaim, and forever discharge the other and the estate of such other, for all times to come and for all purposes whatsoever, of and from any and all right, title and interest, or claims in or against the property (including incomc and gain from property hereafter accruing) of the other or against the estate of such other, of whatever nature and wheresoever situate, which he or she now has or at any lime hereafter may have against such other. the estate of such other, or any part thereof, whether arising out of any former acts, contracls, engagements, or --Page 7 of 14-- '. liabilities of such other as by way of dower or curtesy, or claims in the nature of dower or curtesy or widow's or widower's rights, family exemption, or similar allowance, or under the intestate laws, or the right to take against the spouse's Will; or the right to treat a lifetime conveyance by the other as testamentary, or all other rights of a surviving spouse to participate in a deceased spouse's estate, whether arising under the laws of (a) Pennsylvania, (b) any state, commonwealth or territory of the United States, or (c) any other country, or any rights which either party may have or at any time hereafter have for past, present, or future support or maintenance, alimony, alimony pendente lite, counsel fees, costs or expenses, whether arising as a result of the marital relation or otherwise, except and only except, all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any thereof It is the intention of Husband and Wife to give to each other by execution of this Agreement a full, complete, and general release with respect to any and all property of any kind or nature, real or personal, or mixed, which thc other now owns or may hereafter acquire, except and only except, all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any thereof execution of this Agreement, Wife has commenced an 18. action for divorce against Husban all vvwt ,-,v~l~ Cluj fc.UI El33ocill:tc:a y,'it1:1 tl:t~ filiug gftkig actio"L It is understood and agreed that any Decree in Divorce which may be issued between the parties shall incorporate this Agreement. Further: --Page 8 of 14-- a.) This Agreement represents a complete and final agreement as to their respective property rights which arose from the marital relation and therefore mutually waive any and all rights they may have under 93502, et. of the Pennsylvania Code, Act. No 1980-26. b.) This Agreement may be offered in evidence in the action for divorce and may be incorporated by reference in the decree to be granted therein. Notwithstanding such incorporation, this Agreement shall not be merged in the decree, but shall survive the same and shall be binding and conclusive to the rights of all parties. 19. Lezal Fees: In the review and preparation of this Agreement each party shall bear his or her own legal fees, 20. Remedv for Breach: If either party breaches any provision of this Agreement, the other party shall have the right, at his or her election, either to sue for damages for such breach, in which event the breaching party shall be responsible for payment of legal fees and costs incurred by the other in enforcing their rights hereunder, whether through formal court action or negotiations, or to seek such other remedies or relief as may be available to him or her. 21. Equitahle Distribution: It is specifically understood and agreed that this Agreement constitutes an equitable distribution of property, both real and personal, which was legally and beneficially acquired by Husband and Wife or either of them during the marriage as contemplated by The Act of April 2, ] 980 (P.L No. 63, No. 26) known as 'The Divorce Code." 23 P.S. 101 et seq. ofthe Commonwealth of Pennsylvania, and as amended, 22. Summary of Effect ofAr;reement: It is specifically understood and agreed by and between the parties hereto, and each party accepts the provisions herein made in lieu of and in full settlement and satisfaction of any and all of the said parties' rights against the other for any npage 9 of 14-- past, present and future clams on account of support, maintenance, alimony. alimony pendente lite, counsel fees, costs and expenses, equitable distribution of marital property and any other claims of each party, including all claims raised by them in the divorce action pending between the parti es. 23. Tax Consequences: By this Agreement, the parties have intended to effectuate and by this Agreement have equitably divided their marital property. The parties have determined that such equitable division conforms to a right and just standard with regard to the rights of each party. The division of existing marital property is not, except as may be otherwise expressly provided herein, intended by the parties to institute or constitute in any way a sale or exchange of assets and the division is being effected without the introduction of outside funds or other property not constituting a party of the marital estate, 24. Mutual Coooeration/Dutv to Effectuate A IZreement: Each party shall at any time and from time to time hereafter, take any and all steps and execute, acknowledge and deliver to the other party any and all further instruments and/or documents that the other party may reasonably require for the purpose of giving full force and effect to the provisions of this Agreement. 25. Reconciliation: The parties shall only effectuate a legal reconciliation which superscdes this Agreement by their signed agreement containing a specific statement that they have reconciled and that this Agreement shall be null and void; otherwise, this Agreement shall remain in full force and effect. Further, the parties may attempt a reconciliation, which action, if not consummated by the aforesaid agreement, shall not affect in any way the legal affect of this agreement or cause any new marital rights or obligations to accrue. 26, Severabilitv: If any ternl, condition, clause or provision of this Agreement shall --Page 10 of14-- bc determined or declared to be void or invalid in law or otherwise, then only that term condition, clause or provision shall be stricken from this Agreement and in all other respects this Agreement shall be valid and continue in full force, effect, and operation. Likewise, the failure of any party to meet her or his obligations under anyone or more of the paragraphs herein, with exception of the satisfaction of the conditions precedent, shall in no way void or alter the remaining obligations of the parties. 27. No Waiver of Default: This Agreement shall remain in full force and effect unless and until terminated under and pursuant to the temlS of this Agrcement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall in no way affect the right of such party hereafter to enforce the same, nor shall the waiver of any breach of any provision hereof be construed as a waiver of any subsequent default of the same or similar nature, nor shall it be construed as a waiver of strict performance of any other obligations herein. 28. Inteeration: This Agreement constitutes the entire understanding of the parties and supersedes any and all prior agreements and negotiations between them. There are no representations or warranties other than those expressly set forth herein. This Agreement shall survive integration by any conrt into any judgment for divorce and shall continue to have independent legal significance as a written contract separate from such judgment for divorce and may be enforced as an independent contract. 29. E[fect of Divorce Decree: The parties agree that unless otherwise specifically provided herein, this Agreement shall continue in full force and effect after such time as a final Decree in Divorce may be entered with respect to the parties. 30. Notices: Any and all notices given hereunder shall be in writing and shall be sent registered mail, return receipt requested: --Page 11 of 14-- a.) To Husband in care of Martin Miller, Esquire, 204 North George Street, Suite 200, York Pennsylvania 17401. b.) To Wife in care of Marylou Matas, Esquire, Saidis, Shuff, Flower & Lindsay, 26 West High Street, Carlisle, Pennsylvania 17013. 31, Waiver or Modification to he in Writinz: No modification or waiver of any of the terms hereof shall be valid unless in writing and signed by both parties and no waiver of any breach hereof or default hereunder shall be deemed a waiver of any subsequent default of the same or similar nature. 32. CaTJIions: The captions of this Agreement are inserted only as a matter of convenience and for reference and in no way define, limit or describe the scope and intent of this Agreement, nor in any way effect this Agreement. 33. Azreement Bindin" on Heirs: This Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective heirs, executor, administrators, successors and assigns. 34. Governinz Law: This Agreements shall be construed in accordance with the laws of the Commonwealth of Pennsylvania, --Page 12 of 14-- IN WITNESS WHEREOF, the parties have set forth their hands and seals to two counterparts of this Agreement, each of which shall constitute an original, the day and year first above written. Date TOD ,),~ (cLUi,(?u.\-i \,\ lL-fevJ '- ". 'j '. OI/io}Ol. Date /Ro lA<<~~ REBECCA A. TRAVIS --Page 13 of 14-- COMMONWEALTH OF PENNSYLVANIA COUNTY OF llvrn..6..uJ! alJ:'( On this J Ol:f.- day of ~ K..t1..au r ' 2006, before me, the undersigned officer, personally appeared TODD T. TRA VIS known to me (or satisfactory proven) to be the person whose name is subscribed to the within Agreement and acknowledged that he executed the same for the purpose therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seaL ~?9!A J'U~cW~t1' Not' y Public ----- NOTARIAL SEAL MERlENE J. MARHEIIKA, NOTARY PUBLIC CARLISLE. CUMBERLAND COUNTY PA MY COMMISSION EXPIRES JUNE 8, 2006 COMMONWEALTH OF PENNSYLVANIA COUNTYOF ~a~ On thiS IOu... day of ~ILU.a! ' 200~~ before me, the underSigned officer, personally appeared REBECCA A. TRA VIS, known to me (or sallsfactory proven) to be the person whose name is subscribed to the within Agreement and acknowledged that she executed the same for the purpose therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seaL k~~ NOTARIAL SEAL MERLENE J. MARHEIIKA, NOTARY PUBlIC CARLISLE. CUMBERLAND COUNTY, PA MY COMMISSION EXPIRES JUNE 8, 2006 ,- --Page 14 of 14-- ,. -- SAlOIS, FLOWER & LINDSAY ATlORNEYS.AHAW 26 West High Streer Carlisle, (J/\ 'I REBECCA A. TRAVIS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO, 04-6410 CIVIL TERM v, TODD T. TRAVIS, Defendant IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Kindly transmit the record, together with the following information, to the Court for entry of a Decree in Divorce: 1. Grounds for Divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Defendant accepted service of the Complaint on December 28, 2004, via certified mail. Proof of service was filed with the Court on January 20, 2005. 3. Date Affidavit of Consent required under Section 3301(c) of the Divorce Code was signed: By Plaintiff: January 10, 2006 and filed with the Prothonotary on January 12, 2006. By Defendant: January 10, 2006 and filed with the Prothonotary on January 12, 2006. 4. Related claims pending: None. 5. Date Waiver of Notice under Section 3301 (c) of the Divorce Code was signed: By Plaintiff: January 10. 2006 and flied with the Prothonotary on January 12, 2006. By Defendant: January 10, 2006 and filed with the Prothonotary on January 12, 2006. SAlOIS, FLOWER & LINDSAY \ , ,.. Ii Ii .. C, ) i' d_<~A \z{:~ ~ Ij [.L,\~r~,j Marylou ~ tas, Esquire 26 West High Street Carlisle, PA 17013 717 -243-6222 . .. SAIDIS, FLOWER & LINDSAY ATIOIt,,""ll'S'.U.lAW 26 West High Street Carlislc,I'A 11 CERTIFICATE OF SERVICE I. Marylou Matas, Esquire, of the law firm of SAlOIS. FLOWER & LINDSAY, hereby certify that on this date a copy of the attached document was served on the following individual, via first class mail. postage prepaid, addressed as follows: Martin Miller. Esquire 204 North George Street Suite 200 York, PA 17401 SAlOIS, FLOWER & LINDSAY Dated: January 12. 2006 ~... ) " '.-' '...F' ~ -) -h --.1 , i!C; i'.) ( ..~ " C;", :.~< SAlOIS, FLOWER & LINDSAY ATTORNEYS'AHAW 26 West High Street Carlisle. PA REBECCA A. TRAVIS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ~; C) ':_~~. -;i:-1 U'" (_ .-1 v. CIVIL ACTION - LAW NO, 04-6410 CIVIL TERM :'i', TODD T. TRAVIS, Defendant IN DIVORCE r"...) DEFENDANT'S AFFIDAVIT OF CONSENT ("J .,_ :"':J 1. A Complaint in Divorce under 9 3301 (c) of the Divorce Code was filed OFt'DecertJber 21,2004. 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 in 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 to the best of my knowledge, information and belief, I understand that false statements herein are made :;ubject to the Date: ;/II! / Of, , I penalties of 18 Pa,C,S. 4904 relating to unsworn falsification to DEFENDANT'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER& 3301 leI 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 to the best of my knowledge, information and belief. I understand that false stateme penalties of 18 Pa,CS de subject to the Date: ( h~ J~6 I I ,'~1 ';C-;;) ("co'- '~\ r<: ( SAllIS, FLOWER & LINDSAY ATn)RNFfSo.U.L\W 2G \X'est High Street Carlisle, PA REBECCA A. TRAVIS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v, CIVIL ACTION - LAW NO. 04-6410 CIVIL TERM TODD T. TRAVIS, Defendant IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1, A Complaint in Divorce under S 3301 (c) of the Divorce Code was filed on December 21,2004 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 in 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 to the best of my knowledge, information and belief, I understand that false statements herein are made subject to the penalties of 18 Pa.C,S, 4904 relating to unsworn falsification to authorities, Date: ol)tolo(" <'-& ~-{C (' lAA J: 1 tIL---O Rebecca A. Travis PLAINTIFF'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDERll 3301 leI 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 to the best of my knowledge, information and belief, I understand that false statements herein are made subject to the penalties of 18 Pa,C.S, 4904 relating to unsworn falsification to authorities, Date: Ol}) 0 JOb , ~..~ ~j1 I/1lVC Rebecca A. Travis ~" , (.! -n r... ::-:! ,j f',) ~TJ C, -< ,.,'f:+;:t':+; if. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . + + + + + + + + + + . + + + + + + . + . + . . + + + . + . .+ :+; :+;:t' :+;~:t'~ :+; :+;:+;:t'if. :+;:+':+':+':+':+;:t' ~~~ :+;:+;if.~++:+':t':t':+;+.:+;+.+.+.+.:+;:+;+++:+;:t'+++:+;+':+;+++++~ + + + + + + + + . . . . . . . + + + . . . . . . + + + . . . . . . + . . . . IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY REBECCA A. TRAVIS PENNA. STATE OF No. 04-6410 VERSUS TODD T, TRAVIS DECREE IN DIVORCE YET . . . + . . . . . + . . . . . . . . . . . . . . . . . . . . . . BEEN ENTERED; ; The terms of the Separation and Property Settlement Agreement dated January 10, ; . . . + . . . + . j o...--,,}D.(" '1 REBECCA A. TRAVIS 1.~ , 100 Co , IT IS ORDERED AND AND NOW, DECREED THAT , PLAINTIFF. TODD T. TRAVIS , DEFENDANT, AND 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 . . . + + + + + + + + + . . . . . . . . . . . . . . . . . . ""+. + "" 2006 are incorporated, but not merged, into this Decree in Divorce. By THE COURT: . . . . . . . . . . . . . . . . . . +:t'+.+:+;ct:+;~""+++'+""++':+;""+'+:+;+""~? ATTEST: ~ --t. ~ ~MJ ROTHONOTARY ct+.+.++.+ ++. +. ~+ J, _ ~jJ'j// Jr/ Y .; 1'fT'1:?>"4 .?~Jt, ;V'h C" ;I ':Zc;?,yt/ 'j!:P :z /;7'2'tt,' ~7 /"':) ,/(;'hC' / . \.. ~: