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Home My WebLink About01-4095 12/18/2884 88:51 7172406573 PROTHONOT AF~V C LONG PAGE 01/81 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA M\c~l c./ Los~ Jr. P1aintiff Vs FileNo, 01 - 40C')5 IN DIVORCE A.m l-\ N. ~ne. Defendant NOT.CE TO RESUMJ} I'NOR SURN~ Notice is hereby given that the: Plaintiff I defendant iu toe above matter, [select one by m.arking '"x"] _ prior to the etItry of a Final Decree in Divorce~ or L after the en1ry of a Final Decree in Divorce dated S./I L{ /Oa... hereby elects to resume the prior surname of Amy N. Wi Il; CVY1 S . and gives this wtittm notice avowing his I her intention pn, the prov(? of 54 P .S. 704. Date: Id/16jOY , fY1tr~~ ;:n~ture -P~C'){~ ~ ,/'( Signa: of name beio,g J:eS\lmed COMMO~~ OF~~~~. ) COUNTYOF~L~h) On the /Oui( day of ~A./ t efr..h&1, . 200~ before me, the Prothonotary ot' the notary public, peT!~Qn.ally appeared the ab()ve affiant known to me to be the person whose name is subscribed to the wjtbin document and acknowledged that he I she executed the fotegoing fOT the purpose therein contained. In WimeS5 Whereof, I have hereunto set my hand h seal. Prothonotary Q%' Notary Public ~~ (' i ........ VI """ \...l ~ -l:, ~ N t-J I;,. C) ;J:> -f ~ '" ~ g (") ......) ~~; -..j --'J C' " i' r....,.,; : I: {<r ... t Ci .. . 0~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY ,'f~ STATE OF PENNA. MICHAEL C. LANE, JR., No. 01-4095 Plaintiff VERSUS AMY N. LANE, Defendant DECREE IN DIVORCE AND NOW, ravV.~ ZOO....... IT IS ORDERED AND 1'1" DECREED THAT MH~HAF.T, r. T ANF., TR , P LA I NT IFF, AND AMY N. LANE , 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 NONE YET BEEN ENTERED; This Agreement of January 11, 2002 is hereby incorporated into the final Divorce Decree. sn;E C~4d PROTHONOTARY J. " ~r~ ~ .~ eOble ~,) fp 1- r'" ~;;j5'V C'(/p!C" - . AGREEMENT THIS AGREEMENT, made this 1/ day of ~ by and between MICHAEL C. LANE, JR., of Dauphin -<-- 2001" Cov.nty, Pennsylvania (hereinafter referred to as HUSBAND), and AMY W. LANE of Cumberland County, Pennsylvania (hereinafter referred to as WIFE) , WHEREAS, HUSBAND and WIFE were lawfully married O~ December 31, 1994 in Passaic County, New Jersey, and; WHEREAS, one child born of this marriage, to wit: Dylan Lane, born May 3, 1999 WHEREAS, diverse, unhappy differences, disputes and difficulties have arisen between the parties and it :;_8 the intention of WIFE and HUSBAND to live separate and apart fCT the rest of their natural lives, and the parties hereto are desir0us of settling fully and finally their respective financial and prGperty rights and obligations as between each other, including wi~hout limitation by specification: the settling of all matters bt~t~een them relating to the ownership and equitable distribution cf real and personal property; settling of all matters between them relating to the past, present and future support, and alimony: and or maintenance of the child; the implementation of custodv and visitation arrangements for the minor child of the partiesj and in general, the settling of any and all claims by one agains:: the other or against their respective estates. NOW, THEREFORE, in consideration the premises and of the mutual promises I covenants and undertakings hereinafter se::: ;:.)rth . hereby acknowledged by each of the parties hereto, '';,-:-~.-::. 3.nd HUSBAND, each intending to be legally bound, hereby coven~nt. and agree as follows: 1. SEPARATION: It shall be lawful for each part.j" <"l.i: all times hereafter to live separate and apart from the other. '!J-=trty at such place as he or she may from time to time chose or de::.:') :,:it. The foregoing provisions shall not be taken as an admissi.o:;::," C'T~ t:.he part of either party of the lawfulness or unlawfulness c :.:::ne causes leading to their living apart. 2. INTERFERENCE: Each party shall be ';=''''c ":";. ~rom interference, authority, and contact by the other, as fullv _. ~ ........::, if he or she were single and unmarried, except as may be necess~~y to carry out the provisions of this Agreement. Neither pa~ty ~hall molest the other or attempt to endeavor to molest the c~t~~" nor compel the other to cohabit with the other, or in any 'Viav n?~-ass or malign the other, nor in any way interfere with their D~?_C2ful existence, separate and apart and they agree that neither ~h3li do or say anything to the child of the parties at any time wl1L::'':. ":,:,:ght in any way influence the child adversely against the othey.- ~::'?!:ty. . 3 . SUBSEQUENT DIVORCE: The parties hereby ac1,:::C'~"T~edge that HUSBAND has filed a Complaint in Divorce in CumberIRTl-o-"i. C>:--..:.nty to docket number 01-4095 claiming that the mar-r-i:-:-'-7" is irretrievably broken under the no-fault mutual consent prO\:i::'~_o:: of Section 3301 (c) of the Pennsylvania Divorce Code. WIF2 b~reby expresses her agreement that the marriage is irretrievably b:::-oken and expresses her intent to execute any and all affidavits Qr ~:t.her 2 documents necessary for the parties to obtain an absolute div0rce pursuant to Section (c) of the Divorce Code after January l, 2002. The parties hereby waive all rights to request Court-ordered counseling under the Divorce Code. It is further specifically understood and agreed by the parties that the provisions 0f this Agreement as to equitable distribution of property of the D~"~Cles are accepted by each party as a final settlement for all p~rposes whatsoever, as contemplated by the Pennsylvania Divorce Cede. Should a decree, judgment or order of separaticl or divorce be obtained by either of the parties in this or any ether state, country or jurisdiction, each of the parties hereby Cc,~~.s2nts and agrees that this Agreement and all of its covenants s~?~l be not affected in any way by any such separation or divorce; and that nothing in any such decree, judgment, order or further modif:.c,=,.tion or revision thereof shall alter, amend or vary any tems o~ '::his Agreement, whether or not either or both of the parties s~'1all remarry. It is specifically agreed, that a copy of this Aq:~eement or the substance of the provisions thereof, may be incorporc=ed by reference but not merged into any divorce, judgment or decr~~. It is the specific intent of the parties to pemit this Agreemenc to survive any judgment and to be forever binding and conclusi'le upon the parties. 4. DATE OF EXECUTION: The "date of executio!".l; or "execution date" of this agreement shall be defined as th2 date upon which it is executed by the parties if they have each eXE';c1.:ted 3 the agreement on the same date. Otherwise the "date of e).:,:':c~;'.,~:'con" or "execution date" of this agreement shall be defined as :::~le date of execution by the party last executing this agreement. S. DISTRIBUTION DATE: The transfer of property I ~~.;,:-:lds and/or documents provided for herein, shall only take placf: Dl"" t:.he "distribution date" which shall be defined as specified h,,:~:-'?_::"!,:. 6 . MUTUAL RELEASE: HUSBAND and WIFE each co }"":"creby mutually remise, release, quitclaim and forever discharge tGe ~~~~r and the estate of such other, for all time to come, and ~ ':::-;;' 3..11 purposes whatsoever, of and from any and all rights, ti~l~ ~nd interests, or claims in or against the property (including .i,rcome and gain from property hereafter accruing) of the other 0:;:- :,=0'2inst the estate of such other, of whatever nature and whf';resc2:ver situation, which he or she now has or at any time hereo:.f :.?:..' ,'"lay have against the other, the estate of such other or 0:.:1\.' :;::>,3.rt thereof, whether arising out of any former acts, cont,-'? ,'::-_8, engagements or liabilities of such other or by way of dO'('J;::~: or curtesy, or claims in the nature of dower or curtesy or \J2,CC;';"': <.; or widower's rights, family exemption or similar allowance, 0:-: u"J.der the intestate laws, or the right to take against the spouse r S T,'l..!..c.. or the right to treat a lifetime conveyance by the O~>2:': as testamentary, or all other rights of a surviving 8'00'.1.-:'" to participate in a deceased spouse's estate, whether arisj.n:: ;_L~der the laws of (a) Pennsylvania, (b) any State, Commonweal:-,'l or territory of the United States, or (c) any country, or any Y'isnts which either party may have or at any time hereafter shal~ ~~V2 for 4 past, present or future support or maintenance, alimony, 2ll:.~nony pendente lite, counsel fees, property division, costs or expe~ses, whether arising as a result of the marital relations or other'Nise, except, all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or fs:<.:: the breach of any provisions thereof. It is the intention of h~JSBAND and WIFE to give to each other by the execution of this Agreement a full, complete and general release with respect to any aLd all property of any kind or nature, real, personal or mixed, wl:i.cn the other now owns or may hereafter acquire, except and only excep~ all rights and agreements and obligations of whatsoever nature ~~~sing or which may arise under this Agreement or for the breach o! any provision thereof. It is further agreed that this Agreement 2hall be and constitute a full and final resolution of any and all ~laims which each of the parties may have against the other for equitable division of property, alimony, counsel fees and expenses, ~li~ony pendente lite or any other claims pursuant to the Pennsylvania Divorce Code or the divorce laws of any other jurisdiction. 7. ADVICE OF COUNSEL: The provisions of this Agre2ment and their legal effect have been fully explained to the parti~s by JUDITH A. CALKIN, ESQUIRE, counsel for HUSBAND and MICF.....:.~~J-.., S. TRAVIS, ESQUIRE, counsel for WIFE. HUSBAND and WIFE accept that this Agreement is, ;n the circumstances, fair and equitable and that it is being entere.j into freely and voluntarily and that execution of this Agreement ~s not the result of any duress or undue influence and that it is n~c the 5 result of any collusion or improper or illegal agree!r.c-':r'.c. or agreements. The parties further acknowledge that they have eacn made to the other a full accounting of their respective asseLS, estate, liabilities, and sources of income and that they waive any specific enumeration thereof for the purpose of this AgreeEent. Each party agrees that he and she shall not at any future t.!~"".ie raise as a defense or otherwise the lack of such disclosure i:<: ?.~~'r legal proceeding, involving this Agreement, with the exceptic:: oi disclosure that may have been fraudulently withheld. 8. WARRANTY AS TO EXISTING OBLIGATIONS: Each f.\ar.:y represents that they have not heretofore incurred or contracted ::or any debt or liability or obligation for which the estate of th2 other party may be responsible or liable except as may be prov~_c\""c~ for in this Agreement. Each party agrees to indemnify and hold :.:~},::: other party harmless for and against any and all such cEbt.3.' liabilities or obligations of every kind which may have heretcfc~~e been incurred by them, including those for necessities, excepr: :=.~., the obligations arising out of this Agreement. 9 . WARRANTY AS TO FUTURE OBLIGATIONS: WIFE and HUS:~.~,.:!\'l]J each covenant, warrant, represent and agree that with the excepticr-.i of obligations set forth in this Agreement, neither of them 8::-:201:i hereafter incur any liability whatsoever for which the estat.e c"':: the other may be liable. Each party shall indemnify and hJ1.:, harmless the other party for and against any and all debts, cha::'~!.o:0. and liabilities incurred by the other after the execution dace 0:: this Agreement, except as may be otherwise specifically prov"i.ce'j 6 for by the terms of this Agreement. 10. PERSONAL PROPERTY: The parties hereto have di,,'j..'1,.o;:i between themselves, to their mutual satisfaction, all iteIT'B ;-.f tangible and intangible marital property. HUSBAND shall be the Eel: owner of the property listed in Exhibit "A". WIFE shall he ':~.:=: sole owner of all other property located in the marital '--:,~r,,: 0 Neither party shall make any claim to any other such iter),;,; marital property, or to the separate personal property of ei':~-i=:'::' party, which are now in the possession and/or under the control :::: the other. Should it become necessary, the parties each agre~ sign, upon request, any titles or documents necessary to SiVf: effect to this paragraph. Property shall be deemed to be i~ ~~2 possession or under the control of either party if, in the cas.? :~:::: tangible personal property, the item is physically ili .'... possession or control of the party at the time of the signing o~ this Agreement, and in the case of intangible personal propert:i', -,. any physical or written evidence of ownership, such as pass~,~c< checkbook, policy or certificate of insurance or other sir:-'.iJ.aT writing is in the possession or control of the party. HUSBAND 2'n.2 WIFE shall be deemed to be solely and individually in L~e possession, control and ownership of any pension or other emp2.0~r,:?:,::: benefit plans or other employee benefits of any nature to ::~-:i.:-:h either party may have a vested or contingent right or inte:.F.:.s~ I apart from the provisions of the Divorce Code, at the time o!'::::r:-=: signing of this Agreement. 11. MOTOR VEHICLES: WIFE shall become the sole ::t::c:. 7 exclusive owner of the 1998 Honda and HUSBAND shall become the sale and exclusive owner of the 1999 Honda. Each will be solely liable for the payments of the liens on their individual vehicles. 12. REAL ESTATE: The parties own by the entireties a home located at 2190 Brunswick Avenue, Mechanicsburg, Cumberland County, Pennsylvania. The home is currently on the market for sale. After the home is sold WIFE will receive all of the procee,:S.a should there be a deficit after the sale it will be shared e~a"~~:::~r by the parties. Pending the sale WIFE will have sole posseesic::: of the home and she will be solely liable for the payments of ~he expenses on said home, including, but not limited to, the pa.Yl:~e~").t of the mortgage. 13. AFTER ACQUIRED PERSONAL PROPERTY: Each of the parties shall hereafter own and enjoy, independently of any clai~s or right of the other, all items of personal property, tangible Q~ intangible, hereafter acquired by him or her, with full powe:>.~ in him or her to dispose of the same as fully and effectively, in c.J.:. respects and for all purposes, as though he or she were unmar:cte.r:.. 14. APPLICABILITY OF TAX LAW TO PROPERTY TRANSFERS: The parties hereby agree and express their intent that any tra:r"~:=2"!:' of property pursuant to this Agreement shall be within the scr-pe and applicability of the Deficit Reduction Act of 1984 (herein "Act"), specifically, the provisions of said Act pertaining" to transfers of property between spouses or fonner spouses. 'T'.., <:\ parties agree to sign and cause to be filed any elections or ct!~~~ documents required by the Internal Revenue Service to render t/:;..", 8 Act applicable to the transfers set forth in this Agreement wi::'!1out recognition of gain on such transfer and subject to the carry-aver basis provisions of said Act. 15. The parties agree to file a joint IRS return zor 2001. WIFE shall receive any refund due the parties. 16. WAIVER OF ALIMONY PENDENTE LITE AND LEGAL ?'B28: Each party hereby waives any right to alimony pendente lite. The parties agree to be responsible for their own attorney's fees. 17. FULL DISCLOSURE: Each party asserts that she cr he has made a full and complete disclosure of all the real :=md personal property of whatsoever nature and wheresoever loc"lced belonging in any way to each of them, of all debts and encumbrances incurred in any manner whatsoever by each of them, of all SOULCE3 and amounts of income received or receivable by each of partiEs, and of every other fact relating in any way to the subject m3t::'cr of this Agreement. These disclosures are part of the considera.c:~cn made by each party for entering into this Agreement. 18. WAIVER OF ALIMONY: The parties herein acknowledge that by this Agreement they have respectively secured 2nd maintained a substantial and adequate fund with which to provid~ for themselves sufficient financial resources to provide for t~?~~. comfort, maintenance and support, in the station of life to whicc they are accustomed. WIFE and HUSBAND do hereby waive, release and give up any rights they may respectively have against the other for alimony, spousal support or maintenance. It shall be fro~ ~he execution of this Agreement the sole responsibility of each of che 9 respective parties to sustain themselves without seeking ~ny support from the other party. 19. BANKRUPTCY OR REORGANIZATION PROCEEDINGS: I!l the event that either party becomes a debtor in any bankruptcy or financial reorganization proceedings of any kind while a~y obligations remain to be performed by that party for the benef~t of the other party pursuant to the provisions of this Agreement, tile debtor spouse hereby waives, releases and relinquishes any right to claim any exemption (whether granted under State or Federal la'!?) to any property remaining in the debtor as a defense to any claim ~ade pursuant hereto by the creditor-spouse as set forth here:!::!, including all attorney fees and costs incurred in the enforcement of this paragraph or any other provisions of this Agreement. No obligation created by this Agreement shall be discharged or dischargeable, regardless of Federal or State law to the contra~y, and each party waives any and all right to assert that obligS.i::i'):-:. hereunder is discharged or dischargeable. The parties mutually agree that in the even'-. of bankruptcy or financial reorganization proceedings by either p~~~y in the future, any monies to be paid to the other party, or :0 a third party, pursuant to the terms of this Agreement 51:.311 constitute support and maintenance and shall not be discharged in bankruptcy. 20. INCOME TAX PRIOR RETURNS: The parties n.3.VE: heretofore filed joint federal and state tax returns. Both par::ies agree that in the event any deficiency in federal, state or ~0~al 10 income tax is proposed, or any assessment of any such tax is made against either of them, each will indemnify and hold harmle~s the other from and against any loss or liability for any such tax deficiency or assessment and any interest, penalty and e:;"''"Pense incurred in connection therewith. Such tax, interest, penalty or expense shall be paid solely and entirely by the individual who is finally determined to be the cause of the misrepresentations or failures to disclose the nature and extent of his or her sepc_rate income on the aforesaid joint returns. 21. .CHILD SUPPORT: Child support has been establj~shed by the Court of Corrnnon Pleas of Cumberland County, pennsyl Va!-L:Le.; at PACSES Case Number 16503642. 22. LIFE INSURANCE: Each party agrees to maiI:..tain a minimum of $150,000.00 life insurance on their life naming t.heir son as irrevocable beneficiary until their son reaches the age of twenty-two (22). Each will provide the other yearly verific~tion of this insurance coverage. 23. CUSTODY: CUstody has been established by O-:.:der docketed in case number , CUmberland County, Penny:!. v2.nia. 24. WAIVER OR MODIFICATION TO BE IN WRITING: No modification or waiver of any of the terms hereof shall be 'T~lid unless in writing and signed by both parties and no waiver cf: ::my breach hereof or default hereunder shall be deemed a waiver of any subsequent default of the same or similar nature. 25. MUTUAL COOPERATION: Each party shall, at anv ~ime and from time to time hereafter, take any and all ste!=s and 11 . execute, acknowledge and deliver to the other party any 2~Q all further instruments and/or documents that the other pa::-t:y may reasonably require for the purpose of giving full force and ef:ect to the provisions of this Agreement. 26. APPLICABLE LAW: This Agreement shall be con~trued in accordance with the laws of the Connnonwealth of PennsY~'_vania which are in effect as of the date of execution of this Agreement. 27. AGREEMENT BINDING ON HEIRS: This Agreement shall be binding and shall inure to the benefit of the parties here~o and their respective heirs, executors, administrators, successor~ and assigns. 28. INTEGRATION: This Agreement constitutes thE er~1:.ire understanding of the parties and supersedes any and all Lrior agreements and negotiations between them. There ~r~ no representations or warranties other than those expressly set forth herein. 29. OTHER DOCUMENTATION: WIFE and HUSBAND covenar::.'l: and agree that they will forthwith execute any and all 'i,':,~:.'cten instruments, assignments, releases, satisfactions, deeds, no~es or such other writings as may be necessary or desirable for the p:oper effectuation of this Agreement. 30. NO WAIVER ON DEFAULT: This Agreement shall ~emain in full force and effect unless and until tenuinated unC.ET and pursuant to the tenus of this Agreement. The failure of Either party to insist upon strict perfonnance of any of the provisj.0r:s of this Agreement shall in no way affect the right of such l}arty 12 .. . hereafter to enforce the same, nor shall the waiver of any j..::;;:.a,ult or breach of any provisions hereof be construed as a waiver o~=. any subsequent default or breach of the same or similar nature, nor shall it be construed as a waiver of strict performance or any other obligations herein. 31. SEVERABILITY: If any term, condition, clalIs:::, or provision of this Agreement shall be determined or declared ~o be void or invalid in law or otherwise, then only that ~erm, 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 obligation under anyone or more of the paragraphs herein, with the exception G~ the satisfaction of the conditions precedent, shall in no way avoid or alter the remaining obligations of the parties. 32. BREACH: If either party breaches any provisi()Es of this Agreement, the other party shall have the right, at his 0~ her election, to sue for damages for such breach or seek such c~her remedies or relief as may be available to him or her, and the !:..~arty breaching this contract shall be responsible for payme~t of reasonable legal fees and costs incurred by the other in enforcing their rights under this agreement. 33 . HEADINGS NOT PART OF AGREEMENT: Any 1.....e3ding preceding the text of the several paragraphs and subparagraphs hereof are inserted solely for convenience of reference and shall not affect its meaning, construction or effect. 13 . \ .. . IN WITNESS WHEREOF, the parties hereto have se~ their hands and seals this day and year first ~/I~ ~. ve written. ~ 1 C. Lane, " fL~dS ~ - Amy)l::: Lane W, 14 C> N CD 0- '^ ,.' w ,..J h $ C) ;~~ ~~c; _.,..~ .'\ -~{ -( '.') : ',-1 -< '-' MICHAEL C. LANE, JR., Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Vs. No. 01-4095 AMY N. LANE, CIVil., ACTION- IN DIVORCE Defendant 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) 3301 C ( ) 3301 D of the Divorce Code. (Check applicable code) 2. Date and manner of service of the complaint Certified-Restricted delivery 7/7/01 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 1/11 /02 ; by defendant 1/23/02 (B) (1) Date of execution of the plaintiffs affidavit required by Section 3301 (D) of the Divorce Code: (2) Date of filing and service of the plaintiffs affidavit upon the respondent 4. Related claims pending: NONE 5. (Complete either (a) or (b).) (A) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: (B) Date plaintiffs Waiver of Notice in ~ 3301(c) Divorce was filed with the Prothonotary: 2/5/02 Date defendant's Wavier of Notice in ~ 3301 (c) Divorce was filed with the Prothonotary: 2/05/02 ~ ft ~m.JA~ Attorney for (x ) Plamtiff ( ) Defendant Prothon. -4 9 ("........, 0 I:; N -., ;.11 .:0 0- , , VI . , .~.'...' vv --.J ..J .h.- i MICHAEL C. LANE, JR., Plaintiff vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. DI - ofO'RS Ciu~l 't-~ IN DIVORCE AMY N. LANE, Defendant NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN the claims set forth action. SUED IN COURT. If you wish to defend againsc in the following pages, you must take prompt You are warned that if you fail to proceed without you and a decree of divorce entered against you by the Court. A judgment against you for any other claim or relief papers by the Plaintiff. You may lose money rights important to you, including custody children. do so, the case may or annulment may be may also be entered requested in these or property or othe~ or visitation of your When the ground for the divorce is indignities o:c irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Court Administrator's Office, Cumberland County Courthouse, Carlisle, PA. PROPERTY, GRANTED, IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION 0;< LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. DO NOT OFFICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTy, PENNSYLVANIA NO. 01- 'iC>9S ~ '-r~ MICHAEL C. LANE, JR., Plaintiff AMY N. LANE, IN DIVORCE Defendant COMPLAINT IN DIVORCE 3301 (e) 1. Plaintiff is MICHAEL C. LANE, JR., whose mailing adc.:resE is 423 Walnut Street, #314, Harrisburg, Dauphin County, Pennsylva.nia. Plaintiff's social security number is # 072-66-7841. 2. Defendant is AMY N. LANE, who resides at 2190 Brunswick Avenue, Mechanicsburg, Cumberland County, Pennsylvania. Defendant's social security number is 139-82-5325. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on December 31, 1994 in Passaic County, New Jersey. 5. There has been no prior action for divorce or for annulment between the parties. 6. The Defendant is not a member of the Armed Forces. 7. The marriage is irretrievably broken. 8 . Plaintiff has been advised of the availability of marriage counseling and that he may have the right to request the Court to require the parties to participate in such counseling. Being so advised, Plaintiff does not request that the COlir~ require the parties to participate in counseling prior to a Divorce Decree being handed down by the Court. WHEREFORE, the plaintiff prays your Honorable Court to enter a Decree in Divorce from the bonds of matrimony. Respectfully submitted: 2201 North Second Street Harrisburg, PA 17110 (717) 238-2312 Commonwealth of Pennsylvania: ss. County of Dauphin I verify that the statements made in this 3301 (c) Divorce Complaint 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: Sworn and Subscribed -t'1J before me this)J day of JvA/~ , 2001. t~~ Notary Public , ._".'----1 NOTARIAL SEAL ELLEN ROSENBLOOM. Notary Public City of Harrisburg, Dauphin County I r Commission Ex jres.~.~~~_j CERTIFICATE OF SERVICE I, Judith A. Calkin, do hereby certify that a true and correct copy of the within 3301 (c) Divorce Complaint was mailed at Harrisburg, PA., certified-restricted delivery, postage pre-paid to the following person: Amy N. Lane 2190 Brunswick Avenue Mechanicsburg, PA 17055 Date: J (Jv:, - ",. III ~ tIIA MI CHAEL C. LANE, JR., IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND CO., PENNSYLVANIA vs. NO. 01-4095 AMY N. LANE Defendant IN DIVORCE AIfl4'lDA VIT OF SERVICE I, Judith A. Calkin, Esquire, deposes and says: 1. That she is an adult individual residing in Dauphin County, Pennsylvania. 2. That on July 6, 2001, she sent by ce-'-~.fied- restricted delivery, requested from Harrisburg, pennsyl va"'_~. 3., No. 7099 3220 0009 4715 4596 and, if applicable, the Divorce Complaint in the above-captioned case to: Amy Lane 2090 Brunswick Avenue Mechanicsburg, PA 17055 3. That on July 7, 2001, Amy Lane signed the rece:. No. 7099 3220 0009 4715 4596 and it is attached to this affic.;:-'" Date: 1/18/01 ~~.1 fit (I cU.huJ di th A. Calkin, Esm" ~ ." , Attorney for Plainti~ 2201 North Second St Harrisburg, PA 17110 (717) 238-2312 ." "r" . -...~ ~ . Complete items 1, 2, and 3. Also compleh.. item 4 if Restr'cted Delivery is desired. . Print your name and address on the reverse so that we call 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, HIS SECTION Am {,I [a.M- )oqo 8 i^' U/V5 \A/d' k ~e., lM~1\;U>:j lQA.'1-~~ pel 1~)'cS s: D. Is delivery a es.> differ from item 1? If YES, enter delivery address below, RESTRICTED o Agent o Addressee DYes o No 2. Article Number (Copy from service labelj 7 0 q l1 3.) ;l-(:) b---E-rt> C, Lf71S 4: PS Form 3811, July 1999 Domestic Return Receipt 102S9S.99.M.17S9 .~ U.S. Postal Service . CERTIFIED MAil RECEIPT (Domestic Mail Only; No Insurance Coverage Provided) U1 .-'I I"'- ::r- Certified Fee ....ll IT" U1 ::r- tmIMIlCS1U16 ItA ,- $ ".57 Postage IT" Return Receipt Fee CJ (Endorsement Required) CJ Restricted Delivery Fee CJ (Endorsement Required) Total Postage & Fees $ CJ ru ; :::,(;;;:;:~:iii~:J::;;F=:":')"",,_,,- ~ Ci~~-~ft4-~2~~~~_'~~----'---~~~i--~rD-S'f'-'--- : II - . - - - . () "J N ~, , , , ;D 0- ' . L}) ;'-':" ~'< '.. - :.) V,J , --j -.J ~ t -- .... . , MICHAEL C. LANE, JR., Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND CO. , PENNSYLVANIA vs. NO. 01-4095 Civil Term IN DIVORCE AMY W. LANE, Defendant At'It'IDA VIT OF CONSENT 1. A Complaint in Divorce under Section 3301{c) of the Divorce Code was filed on July 2, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the 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 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: ,\ \' \ 02- .:-:; .,., " . '~-:i I C . .) Ci'i .....'" III . MICHAEL C. LANE, JR., Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND CO., PENNSYLVANIA vs. NO. 01-4095 Civil Term IN DIVORCE AMY W. LANE, Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 (c) OF THE DIVORCE CODE 1. I consent to 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 & Decree is entered by the Court and that a copy of the Decree wlll be sent to me immediately after it is filed with the Prothonot~ry. 4. I verify that the statement made in this Waiver are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relat_ng to unsworn falsification to authorities. DATE: \ ~l\to~ !>- \ l\ll~ cx c---, I- "T: ...." [~_~: :-fl /(F -:) ~~ (-" ( ), . It << In the Court of Common Pleas of Cumberland County, Pennsylvania MICHAEL C. LANE, JR., Plaintiff, Defendant. ) ) ) ) ) ) No. 2001- 4095 vs. AMY W. LANE, CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under S 3301(c) of the Divorce Code was filed on July 2, 2001. 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. S 4904 relating to unsworn falsification to authorities. DATED: I l ) J I 0 v ~ " I \ ~ f(!~ d\~y1..L Amy W. L e, De dant Sf' 1:3 q - ~ J .. S:r :2 S- ~ ~) n, /'- (/:J .........~::- G~ L~_ ~ c/ f.-) -,.., ;-" ::'.J I (.) ;J :;'::"_1 ~t.- :.1-.) _,~J -.< ..._; .. . In the Court of Common Pleas of Cumberland County, Pennsylvania MICHAEL C. LANE, JR., Plaintiff, Defendant. ) ) ) ) ) ) No. 2001 - 4095 vs. AMY W. LANE, CIVIL TERM 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 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. 94904 relating to unsworn falsification to authorities. Date: II ;;.13' U0 0 0 .:"' ) 0 C : -,.j ! r-" < ...,.., ,., ~ ,..0 1 V C V'\ ~::-'"":" - ~ ~ . , ~~,-~ ~...; \AI .~ -< .-J t MICHAEL C. LANE, JR., Plaintiff VS. AMY N. LANE, To the Prothonotary: Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA : No. 01-4095 CIVIL TERM : IN DIVORCE Entry of Appearance Please enter my appearance on behalf of the Defendant, Amy Lane, in the above captioned matter. Date: 7~/;lo/ lchael S. Travis Attorney for Defendant, Amy Lane ... MICHAEL C. LANE, JR., Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA VS. : No. 01-4095 CIVIL TERM AMY N. LANE, : IN DIVORCE Defendant CERTIFICATE OF SERVICE I, Michael S. Travis, certify that I have this day served a true and correct copy of the foregoing document by first class mail, postage prepaid, on the following person, addressed as follows: Judith A. Calkin, Esquire 2201 North Second Street Harrisburg, PA 17110 Dated: 7- /;1--0 I i hael S. Travis ill No. 77399 4076 Market Street, Suite 209 Camp Hill, PA 17011 (717) 731-9502 Fax 731-9511 Attorney for Defendant () ~ ~ :J ., --S:l -, - ~ ;3