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HomeMy WebLinkAbout05-2262 HEATHER 1. PALUMBO, Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYL V ANI v. :CIVIL ACTION - LAW :IN DIVORCE ANTONIO PALUMBO, Defendant :NO. OS' - d;l(.~ Cu;f...~ I r'\ NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT, If you wish to defend against the clai s set forth in the following pages, you must take prompt action, You are warned that if y u fail to do so, the case may proceed without you and a decree of divorce or annulment y be entered against you by the court. A judgment may also be entered against for y other claim or relief requested in these papers by the Plaintiff. You may lose money r property or other rights important to you, including custody or visitation of your childre . When the ground for the divorce is indignities or irretrievable breakdown of marriage, you may request marriage counseling. A list of marriage counselors available in the Office of the Prothonotary at: Office of the Prothonotary Cumberland County Court House I Courthouse Square Carlisle, Pennsylvania 17013 IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION 0 PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE 0 ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. I YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO 0 TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 S, Bedford Street Carlisle, P A 17013 (717) 249.3166 (800) 990-9108 . HEATHER L. PALUMBO, Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYL V ANI v. :CIVIL ACTION. LAW :IN DIVORCE ANTONIO PALUMBO, Defendant :NO. OS - ;:);(I...J.., COMPLAINT AND NOW comes the Plaintiff, Heather L. Palumbo, who, by and through er attorneys, Thomas A. Beckley, Esquire, Elizabeth S, Beckley, Esquire, and Beckley & Madden, of Counsel, files this Complaint, in which she avers that: I. Plaintiff, Heather L. Palumbo, is an adult individual residing at 2 Woodmyre Lane, Enola, Cumberland County, Pennsylvania 17025. 2. Defendant, Antonio Palumbo, is an adult individual residing at 10 Da Lane, Mechanicsburg, Cumberland County, Pennsylvania 17050. 3. Both parties were bona fide residents of the Commonwealth 0 Pennsylvania for at least six months immediately prior to the filing of the origina Complaint. 4. Plaintiff and Defendant were married on December 7, 2002. parties in this or any other jurisdiction. 5, There have been no prior actions in divorce or for annulment between the 6, The marriage is irretrievably broken, 7. Plaintiff has been advised of the availability of counseling and at Plaintiff or Defendant has the right to request the Court to require the partie to participate in such counseling. COUNT I REQUEST FOR A NO-FAULT DIVORCE UNDER SECTIONS 3301(c) OR (d) OF THE DIVORCE CODE 8. The averments contained in Paragraphs I through 7 of this Complaint e incorporated herein by reference as though set forth in full. 9. Plaintiffs marriage to Defendant is irretrievably broken. 10. Plaintiff has been advised that counseling is available and that she m have the right to request that the Court require the parties to participate in counseling. Palumbo, respectfully requests the Court to enter a Decree of Divorce. WHEREFORE, pursuant to 23 Pa.C.S.A, gg3301(c) or Cd), Plaintiff, Heather DATED: ~-~~OS of Counsel Respectfully submitted, BECKLEY & MADDEN 212 North Third Street P.O. Box 11998 Harrisburg, PA 17108 (717) 233.7691 ~ ----- omas A. Beckley 2 VERIFICATION I, Heather L. Palumbo, hereby verify that the statements made in the foreg ing document are true and correct to the best of my knowledge, information and belie, I understand that false statements herein are made subject to the penalties 18 Pa, C S. Section 4904, relating to unsworn falsification to authorities. DATED: 4-}j"--Gt) }J (J ~ ~ 1 --0 "" \t- () (") C~ 0 C C:~ .1 C,,, c;> "T~ :." 3- -l :L." R.J 1'~ '. :?'" rn...:-:. ...... ", -, -O~-n ~ ~ ,/,- I W p:! C/,:> W ~ ,] "'I.... -<-< ~~3 5~~ l0 ~ ~;:: \ ~ "-'-'-q '~ ", '~~: F~: C/1 :'1;; i ~ ~ -) J .. ., .<. "1> -'-I .r.- ~',l -( 0' -< ~'- ." HEATHER L. PALUMBO, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUl\TY, PENNSYLVANIA v, CIVIL ACTION - IN DIVORCE ANTONIO PALUMBO, NO. 05-2262 CIVIL TERM Defendant AFFIDAVIT OF SERVICE I, Elizabeth S, Beckley, being duly sworn according to law, do depose and say: I, I am an adult individual over eighteen years of age, 2, I served the Divorce Complaint of Heather L. Palumbo upon Antonio Palumbo, at 10 Dapp Lane, Mechanicsburg, Cumberland County, Pennsylvania 17050, on or about May II, 2005, by certified mail, parcel number 7001 2510 0002 2637 4330, return receipt requested, Attached hereto is the return receipt (green card) signed by the Defendant. -~~-"'.,."-->:/ ' / Sworn and subscribed to before me this 5th day of December, 2005, I 'I .---, / -J..-i-----<- LLF{I,LJ_- :,:". ~_ .~__I---zt:'__ ~" <-.(~- - Notary Public NOTARIAL SEAL GERALDINE J. SCRBACIC, Notary Public City of Harrisburg, Dauphin County My Commission Expires Nov, 20, 2006 .' " . I Complete items 1, 2, and 3. Also complete item 4 jf Restricted Delivery is desired. . Print your name and address on the reverse so that we can return the card to you. . Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: j)!-l f.t'!,<-~t>,,-c-<:,.j:~ t. "- '1-<--/(' ;';' it'rt- il;~>,: I}//~-l_~,!_<'~ "",.i,( 'l_)t--J //9 / 7~~ 6--L~ Ij 1t y' 71 ft' 2. Article Number (Transfer from service label) PS Form 3811, August 2001 ") [J Agent o Addressee Date of Delivery o Express Mail o Return Receipt for Merchandise o C.OD. 4. Restricted Delivery? (Extra Fee) ~s 7001 2510 0002 2637 4330 102595-01-M-250~ Domestic Return Receipt .-> c..:." L~-;} ;,;..J1 c; C' I. C) r:? r<) f'..) Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA HEATHER L. PALUMBO, v, : CIVIL ACTION - IN DIVORCE ANTONIO PALUMBO, : NO, 05.2262 CIVIL TERM Defendant AFFIDAVIT OF CONSENT I. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on May 3, 2005, 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: ,~/il' k ~. (~tc,v~-- Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA HEATHER 1. PALUMBO, v. : CIVIL ACTION - IN DIVORCE ANTONIO PALUMBO, : NO. 05-2262 CIVIL TERM Defendant AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 330 1 (c) of the Divorce Code was filed on May 3,2005. 2. The marriage of plaintiff and defendant is in'etrievably 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. 1 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. !i 4904, relating to unsworn falsification to authorities. Date~\llf\~ \ ~/ </.~ ( J\..J:-~ 't-..~ ~niQ Palumbo , Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA HEATHER 1. PALUMBO, v. : CIVIL ACTION - IN DIVORCE ANTONIO PALUMBO, : NO. 05-2262 CIVIL TERM Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. 1 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 ifI 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. !i 4904 relating to unsworn falsification to authorities. !' Dated: ".-1, / Ii: (. "", ~u~i9r-- Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA HEATHER 1. PALUMBO, v. : CIVIL ACTION - IN DIVORCE ANTONIO PALUMBO, : NO. 05-2262 CIVIL TERM 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 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 ifI 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. ii 4904 relating to unsworn falsification to authorities. Dated: ,;;l./ \ tq! 0 tp ~, OIVO Palumbo ,. . PROPERTY SETTLEMENT AGREEMENT This is a Property Settlement Agreement entered into thi~ day of k 2005, by and between ANTONIO PALUMBO, of Cumberland County, Pennsylvania (hereinafter referred to as "Husband"), and HEATHER L. PALUMBO, of Cumberland County, Pennsylvania (hereinafter referred to as "Wife"). and; (") ~ S; ~ "'t;;".','; 3t CD!,:- ;no. ~.-- -< WHEREAS, Husband and Wife were lawfully married on Decembem,: 20~ r.:~ ".'7 ._t;; . :r- ::J: WITNESSETH: 5-~. ~~.? Julian :ejhlI~ "'" --.J WHEREAS, one child has been conceived of this marriage: whose date of birth is May 11, 2003; and WHEREAS, unhappy differences have arisen between Husband and Wife in consequence of which they are now living separate and apart from each other; and WHEREAS, Husband and Wife are now in the process of obtaining a divorce, and, consequently, they desire to settle and determine finally and for all time both their respective financial and property rights, including any and all claims which either of them may have against the other. NOW THEREFORE, in consideration of this Property Settlement Agreement, and of the mutual promises, covenants and undertakings set forth herein, and incorporating the above "WHEREAS" clauses herein by reference, the parties hereto, each intending to be legally bound, hereby agree as follows: L SEPARATION: It shall be lawful for each party at all times hereafter to live separate and apart from the other party at such place as he or she may from time to 1 o " :r m:!l -ofT; :"'9 06 ::~lJ -r! "5:!l '''('5 om --I 3i .< . time choose or deem fit. The foregoing provisions shall not be taken as an admission on the part of either party of the lawfulness or unlawfulness of the causes leading to their living apart. 2. INTERFERENCE: Each party shall be free from interference, authority and contact by the other, as fully as ifhe or she were single and unmarried except as may be necessary to carry out the provisions of this Agreement. Neither party shall molest the other or attempt or endeavor to molest the other, nor compel the other to cohabit with the other, or in any way harass or malign the other, nor in any way interfere with the other's peaceful existence, separate and apart from the other. 3. WIFE'S DEBTS: Wife represents and warrants to Husband that since the separation she has not and in the future she will not contract or incur any debt or liability for which Husband or his estate might be responsible, and that she shall indemnify and save harmless Husband from any and all claims or demands incurred by her. 4. HUSBAND'S DEBTS: Husband represents and warrants to Wife that since the separation he has not and in the future he will not contract or incur any debt or liability for which Wife or her estate might be responsible, and that he shall indenmify and save harmless Wife from any and all claims or demands made against her by reason of debts or obligations incurred by him. 5. OUTSTANDING JOINT DEBTS: All debts, obligations or liabilities incurred at any time in the past by either of the parties will be paid promptly by the party which incurred such debt, obligation or liability, unless except as otherwise specifically set forth in this Agreement. Each of the parties hereto further promises, covenants and agrees that each will now and at all times hereafter save harmless and keep the other or 2 . his or her estate indenmified and saved harmless from all debts or liabilities incurred by him or her, as the case may be, and from all actions, claims and demands whatsoever with respect thereto, and from all costs, legal or otherwise, and counsel fees whatsoever appertaining to such actions, claims and demands. Neither party shall, after the date of this Agreement, contract or incur any debt or liability for which the other or his or her property might be responsible, and shall indemnify and save harmless the other from any and all claims or demands made against her or him by reason of debts or obligations incurred by her or him, and from all costs, legal costs and counsel fees incurred in connection therewith unless provided to the contrary herein. 6. BANK ACCOUNTS. RETIREMENT ACCOUNTS AND INSURANCE: Husband and Wife are owners of individual savings, checking and pension accounts and insurance at various institutions, and Husband hereby releases all claims in and to all accounts in the name of Wife, and Wife hereby releases all claims in and to all accounts in the name of Husband, and each party shall retain as his or her separate property each account currently titled to that party. Husband and Wife agree to sign, upon request and after execution of this Agreement, any titles or any other documents reasonably necessary to give effect to this Section. 7. HUSBAND'S RELEASE: Husband does hereby release, remise, quitclaim, and forever discharge Wife and the Estate of Wife from any and all claims that he now has or may hereafter have against Wife, or in, to, or against her Estate or any part thereof, whether arising out of any former contracts, agreements, engagements, or liabilities of Wife, or by way of dower or claim in the nature of dower, spouse's right or under any intestate laws or the right to take against Wife's Will, or for equitable distribution, support, alimony, alimony pendente lite, or maintenance of any other nature 3 whatsoever, excepting only those rights accruing to Husband under this Postnuptial Agreement. 8. WIFE'S RELEASE: Wife does hereby release, remise, quitclaim, and forever discharge Husband and the Estate of Husband from any and all claims that she now has or may hereafter have against Husband, or in, to, or against his Estate or any part thereof, whether arising out of any former contracts, agreements, engagements, or liabilities of Husband, or by way of dower or claim in the nature of dower, spouse's right or under any intestate laws or the right to take against Husband's Will, or for equitable distribution, support, alimony, alimony pendente lite, or maintenance of any other nature whatsoever, excepting only those rights accruing to Wife under this Postnuptial Agreement. 9. MUTUAL INDEMNIFICATION: Each party represents that no debts, liabilities, or obligations have been incurred or contracted for which the other party or the Estate of the other party may be responsible or liable, except those specifically identified in this Agreement. Each party hereto shall hereafter keep the other and his or her heirs and personal representatives indemnified and saved harmless against and from all debts and liabilities contracted for or incurred by or on behalf of the indemnifying party, and against and from all actions, proceedings, claims, demands, costs, attorneys' fees and expenses incurred in respect to any such debts or liabilities, excepting, however, obligations of the parties hereto to each other under this Agreement. 10. CUSTODY: Husband and Wife will share legal custody of their minor child, Julian Palumbo. Wife will have primary physical custody 9f the child. Husband will have partial physical custody with the child at such times as the parties may agree. 4 , Husband and Wife agree that Husband will not take the child out of the Commonwealth of Pennsylvania without prior written permission from Wife. I L DIVISION OF PERSONAL PROPERTY: The parties have divided between them, to their mutual satisfaction, their personal property and the personal effects, household furniture and furnishings, and all other articles of personal property which have theretofore been used by them in common, and neither party will make any claim to any items of personal property which are now in the possession or under the control of the other. Should it become necessary, the parties each agree to sign any titles or documents necessary to give effect to this paragraph upon request. 12. LEGAL COUNSEL: Wife has retained Elizabeth S. Beckley, Esquire, to represent her in her divorce and support proceedings. Husband has had the opportunity to obtain counsel for himself, but has opted not to do so. Husband acknowledges that while Elizabeth S. Beckley, Esquire, has drafted all of the divorce documentation, she has not in any way provided him any legal advice and has advised him to obtain counsel of his own which he has chosen not to do. 13. BREACH: If either party breaches any provision of this Agreement, the other party shall have the right, at his or her election, to sue for damages for such breach, to sue for specific performance, and to seek such other remedies or relief as may be available to him or her, and the party breaching this contract shall be responsible for payment of legal fees and costs incurred by the other in enforcing their rights under this Agreement. 14. ADDITIONAL INSTRUMENTS: Each of the parties shall from time to time, at the request of the other, execute, acknowledge, and deliver to the other party any 5 . and all further instruments that may be reasonably required to give full force and effect to the provisions of this Agreement. 15. VOLUNTARY EXECUTION: Each party acknowledges that he or she fully understands the facts and has been fully informed or has had the opportunity to be fully informed as to his or her legal rights and obligations, and each party acknowledges and accepts that this Agreement is, under the circumstances, fair and equitable, and that it is being entered into freely and voluntarily after having received such advice and/or with such knowledge as each party desires, and 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. Also, each party hereto acknowledges that under the Pennsylvania Divorce Reform Act, the Court has the right and duty to determine all marital rights of the parties, including divorce, alimony, alimony pendente lite, equitable distribution of all marital property or property owned or possessed individually by the other, counsel fees and costs of litigation and, fully knowing the same and being advised of his or her rights thereunder, each party hereto still desires to execute this Agreement, acknowledging that the terms and conditions set forth herein are fair, just, and equitable to each of the parties, and each party waives their respective right to have the Court of Common Pleas or any Court of competent jurisdiction make any determination or order affecting the respective parties' right to a alimony, alimony pendente lite, equitable distribution of all marital property, counsel fees and costs of litigation. 16. ENTIRE AGREEMENT: This Agreement contains the entire understanding of the parties, and there are no representations, warranties, covenants, or undertakings other than those expressly set forth herein. This Agreement shall be binding upon the parties hereto, and there respective heirs, executors, administrators and assigns. 6 . 17. MODIFICATION AND WAIVER: A modification or waiver of any of the provisions of this Agreement shall be effective only if made in writing and executed by both parties with the same formality as this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall not be construed as a waiver of any subsequent default of the same or similar nature. 18. SEVERABILITY: If any provision of this Agreement is held by a court of competent jurisdiction to be void, invalid or unenforceable, the remaining provisions hereof shall nevertheless survive and continue in full force and effect without being impaired or invalidated in any way. 19. DATE OF EXECUTIONIEFFECTIVE DATE: The "date of execution" or "execution date" of this Agreement shall be defined as the date upon which the parties signed the Agreement if they did so on the same date, or if not on the same date, then the date on which the Agreement was signed by the last party to execute this Agreement. This Agreement shall become effective and binding upon both parties on the execution date. 20. DESCRIPTIVE HEADINGS: The descriptive headings used herein are for convenience only. They shall have no effect whatsoever in determining the rights or obligations of the parties. 7 . IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the day and year first above-written. Jj~ -- ( ;) -- ~ ~ H ther L. Palumbo COMMONWEALTH OF PENNSYLVANIA COUNTYOF Cumberi<tnG ) ) SS.: ) On this the 2.Cl day of NOVUYl beY ,2005, before me, the undersigned officer, personally appeared ANTONIO PALUMBO, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he executed the same for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and notarial seal. COMMONWEALTH OF PENNSYLVANIA NoIarIaJ Seal Amy WIIUamson. Notary Public Camp HIlI Boro, C<rnbel1and County My CorM1issIoo Expires Apr. 7, 2009 Member I Pennsylvania Association of Notaries ~~C1fY\D~ Notary Public My Commission Expires: Lf {l ( 09 8 , . COMMONWEALTH OF PENNSYLVANIA COUNTY OF CuYl" \xr knc, ) ) SS.: ) On this the~ day of NfJYeYnber , 2005, before me, the undersigned officer, personally appeared HEATHER L. PALUMBO, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and notarial seaL ~\~J~1JJtYl0~ Notary Public My Commission Expires: yl1 {ttd1 COMMONWEALTH OF PENNSYLVA",A Notarial Seal AATi WIIIamson, Notary PubliC I Camp HIlI Born, Cumberland County , My CanmIssion Expires ApI. 7, 2r09 J Member, Pennsylvania Association of N,'L,ri.> 9 01(1]"/111 HEATHER 1. PALUMBO, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE ANTONIO PALUMBO, Defendant : NO. 05-2262 PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Please transmit the record, together with the following information, to the Court for the entry of a Decree of Divorce. I. Ground for divorce: irretrievable breakdown of the marriage under Section 330l(c) of the Divorce Code. 2. Date and manner of service of the Complaint: the complaint was served on Antonio Palumbo, on May 11,2005, by certified mail. 3. Date of execution of the affidavit of consent required by Section 330l(c) of the Divorce Code: by plaintiff on February 16, 2006; by defendant on February 16, 2006. 4. Related claims pending: No economic claims raised. 5. (a) Date plaintiff's Waiver of Notice February 16, 2006, and it was filed on March 9, 2006. (b) Date defendant's Waiver of Notice February 16,2006, and it was filed on March 9, 2006. DATED: $" -g- --06 of Counsel BECKLEY & MADDEN 212 North Third Street P.O. Box 11998 Harrisburg, P A 17108 (717)233-7691 (') c: <:'. -ol5~:l o;;q.', "t;..,....,: Zf)'- ~b ( .' ;L r-:: <C ......,.,.. Z"" ~.C; rC ~ .< ~ = "" ::It ~ ~ ~ m~ - ~'? o :i~ ~ %~ - :::.t ~ ~ -> . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PEN NA. HEATHER L. PAllJMBO, Plaintiff No. 2262 2005 VERSUS Ai'IT'CNIO PAllJMBO , Defendant DECREE IN DIVORCE . . AND NOW, friar IV 2006 IT IS ORDERED AND DECREED THAT HEATHER L. PAlllMBO , PLAINTIFF, AND AN'l'CmO PAllJMBO , 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; NOOE. The Property Settlement Agreement between tl:le parties shall be inco:rporated into the final de=ee for purposes of enforcement, but shall not merge with . . . . . the f~nal. !.Jel,;,Lee ~n uivorce. . . '~ , ~~OTHONOTAR' J. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . _ ~ ft ~ T?1!!t, 1il-U-> ~ f1" ?-~ h/Pl-Pl w- L/;9 '. , .... -~,'" .. ,,~ -'.,~ ~.,.. "'"" .-. .- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA lIeCtther L. Palutv\bo Plaintiff Vs .0<005"..- 2202- FIle No. IN DIVORCE Antoni6 Pa.l uMk Defendant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff / defendant in the above matter, [select one by marking "x"] _ prior to the entry of a Final Decree in Divorce, or L after the entry of a Final Decree inDivorce dated 5 J lie I WaG, , hereby elects to resume the prior surname of Heo..ther R ,++ex'" , and gives thi~ written notice avowing his / her intention pursuant to e provisions <{f'141'S. 704. Date: l'/22./0<.o ~ Signature ~ COMMONWE#TH OJ! PE:t;JNSYLV ANIA COUNTYOF~ On the )}..- day of ^) d~k ,2001, before me, the Prothonotary or the notary public, personally appeared the above affiant lmown to me to be the person whose name is subscribed to the within document and acknowledged that he / she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand hereunto set my hand and official seal. I~~~I C1o~t~0() r-;) 0 c~ c::? 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