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HomeMy WebLinkAbout05-0772 vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. DS - 71;).. C"u:.l. J~ CIVIL ACTION - LAW IN DIVORCE ROY F. LONG, Jr., Plaintiff JEANNETTE M. LONG, Defendant 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 you, including custody or visitation of your children. When the ground for the di vorce is indigni ties 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 the Dauphin County Courthouse, Harrisburg, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO THE 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, PA 17013 (717) 249-3166 (800) 990-9108 I' ROY F. LONG, Jr., Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. No. JEANNETTE M. LONG, Defendant CIVIL ACTION - LAW IN DIVORCE AVISO PARA DEFENDER Y RECLAMAR DERECHOS USTED HA SIDO DEMANDADO EN LA CORTE. Si desea defenderse de las quejas expuestas en las paginas sigientes, de be tomar accion con prontitud. Se Ie avisa que si no se defiende, el caso puede proceder sin usted y decreto de divorcio 0 anulamiento puede se emitido en su contra por la Corte. Una decision puede tambien se emitida en su contra por cualquier otra queja 0 compensacion reclamados por el demandante. Usted puede perder dinero, 0 propiedades, 0 otros derechos importantes para usted. Cuando la base para el divorcio es indignidades 0 rompimiento irreparable del matrimonio, usted puede solicitar consejo matrimonial. Una lista de consej eros matrimoniales esta disponible en la oficina del Prothonotario, en la Dauphin County Courthouse, Harrisburg, Pennsylvania. SI USTED NO RECLAMA PENSION ALIMENTICIA, PROPIEDAD MARITAL, HONORARIOS DE ABOGADO 0 OTROS GASTOS ENTES DE QUE EL DECRETO FINAL DE DIVORCIO 0 ANULAMIENTO SE EMITIDO, USTED PUEDE PERDER EL DERECHO A RECLAMAR CUALQUIERA DE ELLOS. USTED DEBE LLEVAR ESTE PAPEL A UN ABOGADO DE INMEDIATO. SI NO TIENE 0 NO PUEDE PAGAR UN ABOGADO, VAYA 0 LLAME A LA OFICINA INDICADA ABAJO PARA AVERIGUAR DONDE PUEDE OBTENER ASISTENCIA LEGAL . Cumber1and County Bar Association 32 South Bedford Street Car1is1e, PA 17013 (717) 249-3166 (800) 990-9108 II ROY F. LONG, Jr., Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. DS- '77)... C,o;L~, CIVIL ACTION - LAW IN DIVORCE vs. JEANNETTE M. LONG, Defendant COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OR 3301(dl OF THE DIVORCE CODE The Plaintiff, Roy F. Long, Jr., through his attorneys, The Law Offices of Patrick F. Lauer, Jr., makes the following Complaint in Divorce and, in support thereof, avers as follows: 1. The Plaintiff, Roy F. Long, Jr., is an adult individual h tl d t 7 North 29th Street, w 0 curren y resi es a Camp Hill, Cumberland County, Pennsylvania 17011. 2. The Defendant, is an adult Jeannette M. Long, individual who currently resides at 485 C State Street, Oberlin, Dauphin County, Pennsylvania 17113. 3. Plaintiff is The fide a bona resident of the Commonwealth of pennsylvania and has been for at least six months immediately prior to the filing of this Complaint. COUNT I - DIVORCE 4. Paragraphs one through three are incorporated herein by reference. 5. The Plaintiff and the Defendant were married on October 12, 1993, at Harrisburg, Pennsylvania. 6. There have been no prior actions of divorce or for annulment between the parties. 7. The marriage is irretrievably broken. II 8. The Plaintiff has been advised that counseling is available and that the Plaintiff may have the right to request that the court require the parties to participate in counseling. 9. This action is not collusive. 10. There is one minor child by this marriage, namely, Roy F. Long, III, born February 2, 1995. WHEREFORE, the Plaintiff, Roy F. Long, Jr., respectfully requests this Honorable Court to enter a decree of divorce in this matter. Respectfully submitted, Date: t 474~ L. arkley, Esquire Law fices of Patrick F. Lauer, Jr. 2108 Market Street, Aztec Building Camp Hill, pennsylvania 17011-4706 ID# 84745 Tel. (717) 763-1800 II ROY F. LONG, Jr., Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. No. JEANNETTE M. LONG, Defendant CIVIL ACTION - LAW IN DIVORCE NOTICE TO THE DEFENDANT IF YOU WISH TO DENY ANY OF THE STATEMENTS SET FORTH IN THIS AFFIDAVIT, YOU MUST FILE A COUNTERAFFIDAVIT WITHIN TWENTY (20) DAYS AFTER THIS AFFIDAVIT HAS BEEN SERVED ON YOU OR THE STATEMENTS WILL BE ADMITTED. AFFIDAVIT UNDER SECTION 3301ldl OF THE DrvORCE CODE 1. The parties to this action separated on or about February 1996, and have continued to live separate and apart 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 if I 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 of 18 Pa. C.S. ~ 4904 relating to unsworn falsification to authorities. ~ \:U4,ch Roy F.~ng, Jr. / DATE: J- '1.0') Sworn to and subscribed to before me this 9""" day of 1A04 ' 200.( Notary Public ~ ~ No[arial Seal Shelb~ A. Minich. Notary Public Camp Hd,l ~oro. Cumberland County My CommIssIon Expires Aug. 20, 2005 Member, Pennsylvania Association of NOtaries II ROY F. LONG, Jr., Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. No. JEANNETTE M. LONG, Defendant CIVIL ACTION - LAW IN DIVORCE VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~ 4904, relating to unsworn falsification to authorities. Date: 2-11 -20';;<) Signature: Ro _ (J --.l:} ~ 'l ~ --- ........ . r- ~ ~ C> /0 CY ~ ~ ~ ft :" :'.) 1~ v. ~ ~ ~ ~ ~ ~ ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA ROY F. LONG, JR., Plaintiff NO. 05 - 772 CIVIL TERM JEANNETTE M. LONG, Defendant CIVIL ACTION - LAW IN DIVORCE COUNTER-AFFIDAVIT OF DEFENDANT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. Denied that the parties were separated on or about February 1996. Defendant avers that the parties did not separate until December 2000. 2. Denied that the marriage is irretrievably broken. 3. Defendant hereby claims that she has a right concerning alimony and division of property which she hereby asserts. I verify that the statement made in this Counter-Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 9 4904 relating to unsworn falsification to authorities. Date: ~.. \~ - oS " ROY F. LONG, Jr., Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 05-772 Civil Term JEANNETTE M. LONG, Defendant CIVIL ACTION - LAW IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT UNDER SECTION 3301(0) OF THE DIVORCE CODE 1. A complaint in divorce under Section 3301 (c) of the Divorce Code was filed on February 11, 2005. 2. The marriage of the Plaintiff and the 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. 4. 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. 5 4904 relating to unsworn falsification to authorities. Date: 7/:J.O!J005 "G ~ ~ C) Roy ~LOng, Jr. 7 Signature: (") ~~.~ r--:> = = <J' c_ c,.:.: r'.-. N N ...,., o -n .--\ :r.:-n \ n \:::;:.~ -n111 :~:jC) ',.':1 l.~ .,-I(j I~ ~~I;c_, .~-;.:~,~{; . " i.o '-< l)? C OJ II ; ROY F. LONG, Jr., Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 05-772 Civil Term JEANNETTE M. LONG, Defendant CIVIL ACTION - LAW IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT UNDER SECTION 3301/0) OF THE DIVORCE CODE 1. A complaint In divorce under Section 3301 (c) of the Divorce Code was filed on February 11, 2005. 2. The marriage of the Plaintiff and the Defendant is irretrievably broken and ninety days have elapsed from the date of the 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 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. Da te: 7l1C/f,lo::;G. I Signatur C? t" ._~ :;-,. ~ 13-. 'eo ,- I" r-" Q, .:::?~ ;:;\\'fc""- . ~, ~n\-) :; ....\~ "~-:}S~\ )'(-:' :.~:.,(\\ <\ -::':\. ....,. .' \"".-; o d"; ?~0 -:j-' 1/ ROY F. LONG, Jr., Plaintiff IN THE COURT OF COM~ CUMBERLAND COUNTY, [LeAS op YLV/J.NI/J. No. 05-772 Civil TeL vs. JEANNETTE M. LONG, Defendant CIVIL ACTION - LAW IN DIVORCE PLAINTIFF'S WAIVER OF NOTICE OF INTENTION TO ~QOEST ENTRY OF A DIVORCE DEC~E UNDER SECTION 3301(0) OF THE DIVORCE CODE 1. I consent to the entry of a final decree without notice. 2. I understand that I may lose rights concernin division of property, lawyer's fees, or expenses if I do 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 dec~ be sent to me immediately after it is filed with the prothonc 4. I verify that the statements made in this affidavit true and correct. I understand that false statements herein G made subject to the penalties of 18 Pa. C. S. S 4904 relating t, unsworn falsification to authorities. Date: 71.:1oJ.it:I:l~ I Signature:Y&;j 1 ~t; Roy F Long, Jr. () c '" ~ = W"> L c::: f"""' N N o ., ---I X-r, rlip"" ;;~~ /:~?fn i_::: :.0 --< y --.." t:'~) CJ co " ROY F. LONG, Jr., Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 05-772 Civil Term JEANNETTE M. LONG, Defendant CIVIL ACTION - LAW IN DIVORCE DEFENDANT'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees, or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the prothonotary. 4. 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. Date: 7!1Ml/.f11'(":: Signature n c .. r-' G':':l = c.P <- C N N CJ -rI .:::\ :1- -r\ rne ~7)c) .::~() <~~ ~~~, ( ') ==-\ -", ~ --n -",. -",- r:-? o CiJ v. ~ ~ ~ ~ ~ ~ ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ROY F. LONG, JR., Plaintiff NO. 05 - 772 CIVIL TERM JEANNETTE M. LONG, Defendant CIVIL ACTION - LAW IN DIVORCE DIVORCE AGREEMENT/SETTLEMENT This Agreement, made and entered into this J~~ay of(:{hcr 2005, is by and between ROY F. LONG, JR., hereinafter referred to as the "Husband", and JEANNETTE M. LONG, hereinafter referred to as the "Wife" WHEREAS, the parties hereto are now Husband and Wife, having been married on October 12,1993, in Dauphin County, Pennsylvania; WHEREAS, the parties hereto agree that the marriage is irretrievably broken and that it has been so for several years. They have lived separate and apart for several years and, as a practical matter they have considered themselves "divorced" for several years. At this point, they desire to "legally" and finally end the broken marriage by consenting to a divorce and to enter into an Agreement respecting their property rights, regardless of the actual separation or other character thereof and their other rights, including support and maintenance; WHEREAS, both and each of the parties hereto have been advised of their legal rights and the implications of this Agreement and the legal consequences that may and will ensue from the execution hereof. Page 1 of 7 WHEREAS, each party warrants, as part of the consideration of this Agreement, that each has fully and completely disclosed all information of a financial nature requested by the other, and that no information of such nature has been subject to distortion or in any manner being misrepresented; and WHEREAS, other than as set forth herein, Husband and Wife mutually desire to finally and forever relinquish all of their respective rights to be supported by each other and all of their rights of dower, rights as an heir or surviving spouse or otherwise, actual, currently existing, or inchoate, in and to the real and personal property of each other, now owned by either of them or which in the future they may own, and all rights to alimony, alimony pendente lite, counsel fees, or expenses and other than as set forth herein; NOW, THEREFORE, the parties hereto intending to be legally bound hereby do hereby mutually agree as follows: 1. Separation and Divorce. Husband and Wife do hereby mutually agree and consent to continue to live separate and apart from each other (as they have been doing for several years) and each shall be free from any control or restraint or interference, direct or indirect, from the other. Each party shall cooperate fully to immediately pursue and finalize a final divorce in this matter. 2. Mutual Property and Estate Waiver. Except as otherwise expressly set forth herein, in which event such express provision shall take precedence over this paragraph, the parties hereto intend that from and after the date of this Agreement, Page 2 of 7 neither shall have any spouse's rights in the property or estate of the other, and to that end both parties waive, relinquish, and forbear the rights of dower or curtesy, rights to inherit, rights to claim or take the Husband or Wife's or family exemption or allowance, to be vested with letters of administration or letters testamentary, orto take against any will of the other, and each agrees with the other if either should die intestate, his or her share shall descend to vest in his or her heirs at law, personal representatives, and next of kin, excluding the other as though he or she had died a widow or widower. And each further agrees that should the other die testate, his or her property shall descend to and vest in those persons set forth in the other's Last Will and Testament as though the spouse so designated as beneficiary had predeceased the testator. The parties further agree that they may and can hereafter, as though unmarried, without any joinder by him or her, sell, convey, transfer or encumber any and all real estate and personal property which either of them now or hereafter own or possess and further agree that the recording of this Agreement shall be conclusive evidence to all of his or her right to do so. The said Husband and Wife do hereby irrevocably grant, each to the other, should the exercise of this power hereby given be necessary, the right and the power to appoint one or more times any person or persons whom the Husband or Wife shall designate to be the attorney-in-fact for the other, in their name and in their stead, to execute and acknowledge any deed or deeds, releases, quit claims, or satisfactions, under seal or Page 3 of 7 otherwise, to enable either party hereto to alienate his or her real or personal property, but without any power to impose personal liability for breach of warranty or otherwise. Each of the parties hereto further waives any right of election contained in Chapter 22 of the Pennsylvania Probate Estates and Fiduciaries Code, and any right to seek or have an equitable distribution of married property ordered by the Court subsequent to Section 3502 of the Divorce Code. Each of the parties hereto further agrees that neither shall hereafter be under any legal obligations to support the other, pay any expenses for maintenance, funeral, burial, or otherwise for the other, and to that end each of the parties hereto does hereby waive any right to receive support, alimony, alimony pendente lite, counsel fees, expenses, or any type of financial assistance whatsoever from the other, except as otherwise expressly provided for herein. 3. Division of Personal Property. The parties agree that the items of personal property have already been fairly and equitably divided. Those items in Husband's possession remain the exclusive property of Husband and, likewise, those items in Wife's possession remain the exclusive property of Wife. 4. Debts. The parties agree that they will each be responsible individually for existing debts which are in their names individually. 5. Future Debts. The parties further agree that neither will incur any more further debts for which the other may be held liable, and if either party incurs a debt for which the Page 4 of 7 other will be liable, that party incurring such debt will hold the other harmless from any and all liability thereof. 6. Waiver of Alimony. In consideration of the mutual agreements of the parties, and their decision to voluntarily live separate and apart and the provisions contained herein, and for the respective benefit of the parties and other good and valuable consideration, the parties each expressly agree to mutually waive any and all claims for any alimony, spousal support, maintenance, etc. 7. Pension. Both parties agree to waive any claims they may have otherwise had to any pension or employment benefits of any kind, earned during the marriage, by the other party. In addition, each parties account which is presently held in the P A State Credit Union shall remain the exclusive property of the respective party whose name it is held in. 8. Claiming Child for Tax Purposes: The parties agree that they shall take turns, so to speak, claiming their child for tax purposes so that each party/parent obtains the benefit of doing so on alternating years. To this end, Mother shall claim the child for a deduction on her tax return for tax year 8,cx...>5. Then on the following tax year (dOO \..0 ), Father shall claim the child on his tax return for a deduction to his benefit. Then, on the next tax year, Mother shall again claim the child, then Father, etc. Page 5 of 7 9. Breach. In the event that either party breaches any provision of thisAgreement, he or she shall be responsible for any and all costs incurred to enforce the terms hereof, including, but not limited to, court costs and reasonable counsel fees of the other party. In the event of breach, the other party shall have the right, at his or her election, to sue for damages for such breach or to seek such other and additional remedies as may be available to him or her. 10. Enforcement. The parties agree that Agreement or any part or parts hereof may be enforced in any court of competent jurisdiction. 11. Applicable Law and Execution. The parties hereto agree that this marital settlement agreement shall be construed under the laws of the Commonwealth of Pennsylvania and shall bind the parties hereto and their respective heirs, executors and assigns. This document shall be executed as original and multiple copies. 12. The Entire Agreement. The parties acknowledge and agree that this marital settlement agreement contains the entire understanding of the parties and supersedes any prior agreement between them. There are no other representations, warranties, promises, covenants or understandings between the parties other than those expressly set forth herein. 13. Incorporation and Judgment for Divorce. It is anticipated that a divorce shall be obtained in the very near future; that is the purpose of this Agreement. I such an event, this agreement and all of its provisions shall be incorporated into any such Page 6 of 7 judgment for divorce, either directly or by reference. The Court, on entry of judgment for divorce, shall retain the right to enforce the provisions and terms of this marital settlement agreement. 14. Additional Instruments. Each of the parties shall on demand or within a reasonable period thereafter, execute and deliver any and all other documents and do or cause to be done any other act or thing that may be necessary or desirable to effectuate the provisions and purposes of this Agreement. If either party fails on demand to comply with this provision, that party shall pay to the other all attorney's fees, costs, and other expenses reasonably incurred as a result of such failure. IN WITNESS WHEREOF, the parties have set their hands and seals the day and year first written above. WITNESS: R01?~N~~~U~d") Page 7 of 7 --:-' (1 (" ....' ~~~; "'" c_ ~~~~ ",0 N ~ .-l ::r::..,., f-nf:::' .''"',\::.'Q ':~__2)~ "--c . ~ """"(1 ,---; ; .0 n \. .-' r:? c::J- ....J '\7 '1."1 -;...;;;. ------- II ROY F. LONG, JR., Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 05-772 CIVIL TERM JEANNETTE M. LONG, Defendant : CIVIL ACTION - LAW : IN DIVORCE A FFTnA VTT OF SF.RVTCCR TO THE PROTHONOTARY: I, Marlin 1. Markley, Esquire, verifY that the Complaint in Divorce has been served upon the Defendant indicated above by first class, Certified Mail No. 7000 1670 0005 2769 4484, postage prepaid, return receipt requested, pursuant to the requirements ofPa. R.C.P. 1930.4. ... :I . 1 ancllor 2 for additional MNlcH. .. ."lkM'nIa, ... Ifid 4b. I . Print your nart!8 and add.... on the nMIIH 01 this form 10 thai W8 can return till, card 10 you. . -Attach thie tonn to the front of the rnailpMtoe, or on the back If tpaC8 doM not perrriI. I. -Write-Retum Rsc:e/pt Requected. on the maIpIecI b8Iow the artk::Ie number. ti -The Aetum Receipt wi. show 10 whom the article.. deIvered and the date & "'~'od. . 1~;~'1nut If?? - C ~'f1 )t;ud- 8'~ (ffJ /7/ IJ I also wish to receive \lie folloWIng services (lor an extra lee): 1. 0 Addressee's Addr_ ~ ~UIU11HOIIMIy j Consu~ po81masI8r lor lee. I 48. Ar1IcIe Number If ~ Cl Expr8AMeH l::~' ! Cl Return Recsipt for _IS Cl COD 'I .. Etj 1 ~ 2005 ! 8. Addressee's Addr8A (Only" requested 'I 8Ild lee Is psJd) ~ 102595.97.6.0179 Domestic Retum ecalpt itted, Marlin Markley, Esquire Law Of ces of Patrick F. Lauer, Jr. 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 ID# 84745 TeL (717) 763-1800 7-Z, -2005 Date: I t,~" ,- ~>(~: :'3 -, (") c:: '" C? = c.n c_ c::: r-"~ N N o ." --1 I'"11 :!J ,- -nfT; .':";0 .~~ll :::iC.) .--' :~r~ ":~h C5!Tl .'---l Z _IJ -< :9 N o co II ROY F. LONG, JR., Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 05772 CIVIL TERM JEANNETTE M. LONG, Defendant : CIVIL ACTION - LAW : IN DIVORCE PRARc:JPR TO TRANSMIT RIWORn To the Prothonotary: Transmit the record, together with the following information, to the Court for entry I of a divorce decree: 1. Grounds for Divorce: Irretrievable breakdown under S 3301(c) S 3JOl(J)(l) of the Divorce Code. (Strike out inapplicable section) 2. Date and Manner of service of the Complaint: Service by certified mail # 7000 1670 0005 2769 4484, delivered on February 18, 2005. See attached Affidavit of Service. 3. (Complete either paragraph (a) or (b).) (a) Date of execution of the affidavit of consent required by S 3301(c) of the Divorce Code: by the Plaintiff TlIly?O ?OO~ by the Defendant TlIly?O ?OO~ (b) Date of execution of the affidavit required by S 3301(d) of the Divorce Code: n/" Date of filing of the Plaintiffs affidavit upon the respondent: n/::I Date of service of the Plaintiffs affidavit upon the respondent: n/" 4. Related claims pending: PI"",,, inmrpC1T"t" withnllt m"rging th" "tt"~h"cl OiVOTC':f' Aerpp.mp:nt/Sp.ttlp.mpnt nftllf~ r::n1ip:~ into thp: OivnTC':p Op.c:rpp. 5. (Complete either paragraph (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, n/::I (b) Date Plaintiffs Waiver of Notice in S 3301(c) Divorce was filed with the prothonotary: fiJ"cl <imlllt"n"nll<ly with Pr",,~ir" Date Defendant's Waiver of Notice in S 3301(c) Divorce was filed with the prothonotary:' " Date: 7~21-200S- . Marlin L. arkley, Esquire 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 ID# 84745 Tel. (717) 763-1800 (") ~~. r-.:> c:~ = cJ' '- f; ('.) N <~ -c o -rl :r-n "'F ~_0~j ':/c:; G~f ~~<)>r"'1 :~~~ ':D .< -- "" C> CIJ II ROY F. LONG, Jr., Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 05-772 Civil Term JEANNETTE M. LONG, Defendant CIVIL ACTION - LAW IN DIVORCE PLAINTIFF'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(0} 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. 4. 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. Date: 7!.Jn/.l();)!;:; , , Signature:_f?~ '1 ~t) Roy F Long, Jr. (') ~~,~ "" ~ = '"' ,- t-::: r""'" N N o -n .-< ffifIJ --.(1i ~~~1,6 'T.: :~~' <:0 ~;{n1 .,> ".0 '-< \J r:y. C> co IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. ~OY F. LONG, JR., . . Plaintiff No. 05-772 VERSUS JEANNETTE M. LONG, . Defendant . . DECREE IN DIVORCE . . J...\1 ~ry - , ;Z..oQ<., , IT IS ORDERED AND AND NOW, DECREED THAT Roy F. Long, Jr. , PLAINTIFF, AND Jeannette M. Long , 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; . . The attached Separation and Property Settlement Agreement dated July 13, 2005, is incorporated, without merger, herein. . " , ~ ':;'_. 9; '- ........ #. BY THE ~_ ATT " ..- ~,- ..- ",.- / . - .:....--...........- ..... ,~ , '-. '~ \.. .~ "....- \ ..: - - ~ . . . ...... '. ...... . - .' '- .- ",,' -- "v ./ .... ......; ",' 'J~ I.-....C--,~\'.,~ ~ .'''' l::dI"- ....'bo..... -- PROTHONOTARY 00000000cO~000000000' . . . . . . . . . . . . . . . . . . . . . J. _~w~.~;rf ~~ ~SI>ff'L ftr'r frY 't- ~ 141. f"J 5P- teL .' ,',...' ',,' .;. i7"