HomeMy WebLinkAbout05-2930
KENNETH F. LEWIS, ESQUIRE
Attorney I.D. #69383
1101 North Front Street
Harrisburg, PA 17102
(717) 234-3136
Attorney for Plaintiff
LORI RICHARDSON,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 05- :1J3o (!':;/
CIVIL ACTION - LAW
v.
ROBERT JACK RICHARDSON,
Defendant
IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been Sued in Court. If yoU wish to defend against
the claims set forth in the fOllowing pages, you must take prompt
action. You are warned that if you fail to do so, the case may
proceed without yoU, and a Decree of Divorce or Annulment may be
entered against you by the Court. A jUdgment may also be entered
against yoU for any other claim or relief requested in these papers
by the Plaintiff. You may lose money or property or other rights
important to you, including custody or visitation of Your children.
When the ground for 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 the Cumberland County Courthouse, Carlisle, PA.
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 TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
1-800-990-9108
KENNETH F. LEWIS, ESQUIRE
Attorney I.D. #69383
1101 North Front Street
Harrisburg, PA 17102
(717) 234-3136
Attorney for Plaintiff
LORI RICHARDSON,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. c),)- 2. '7 3" t'~'cl 'T"
CIVIL ACTION - LAW
v.
ROBERT JACK RICHARDSON,
Defendant
IN DIVORCE
COMPLAINT IN DIVORCE
COUNT I
Re uest for a NO-fault Divorce Under 3301 c
of the Domestic Relations Code
1. Plaintiff is LORI RICHARDSON, an adult individual who
currently resides at 344 Coffeetown Rd., Dillsburg, York County, PA
17019.
2. Defendant is ROBERT JACK RICHARDSON, an adult
individual residing at an undisclosed location in Lemoyne,
Cumberland County, Pennsylvania.
3. Plaintiff and Defendant have been bona fide residents
in the CommOnwealth for at least six (6) months immediately
previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on October
20, 2001 in Augusta, Michigan.
5. There have been no prior actions of divorce or for
annulment between the parties.
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6. The marriage is irretrievably broken.
7. The Defendant is not a member of the armed services.
8. Plaintiff has been advised that counseling is
available and that Plaintiff may have the right to request that the
COurt require the parties to participate in coUnseling.
9. There are no children born of the marriage.
WHEREFORE, Plaintiff respectfully requests this Court to
enter a Decree of Divorce pursuant to S 3301(c) of the Domestic
Relations Code.
COUNT II
Re Uest for a FaUlt Divorce under
of the Domestic Relations Code
10. Plaintiff hereby incorPOrates Paragraphs 1 through
9 of her Complaint as if fUlly set forth herein.
11. Defendant has Offered sUch indignities to Plaintiff,
the innocent ond inj"ed epouee, oe to render her Condition
intolerable and life burdensome.
WHEREFORE, Plaintiff respectfully requests this COurt to
enter a Decree of Divorce pursuant to S 3301(a) of the Domestic
Relations Code.
DATED: t /1 )05
~R~ LOw,s, ESQU'RE
Attorney for Plaintiff
VERIFICATION
I hereby verify that the statements made in the foregoing
document ore tree ond correct. 'underetond thot 'olee etotemente
herein ore mOde eUbj ect to the penoltiee 0' " Po. C. S. Section
4904, relating to unsworn falsification to authorities.
Dated:
&/1(05
Jm~;:t) ~
LORI RICHARDSON
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LORI RICHARDSON,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 05-2930
CIVIL ACTION - LAW
ROBERT JACK RICHARDSON,
Defendant
IN DIVORCE
ACCEPTANCE OF SERVICE
I accept service of the divorce Complaint.
DATE:
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ROBERT JACK RICHARDSON
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61102/1994 21:26
71 72348288
LEWIS LAW OFFICE
PAGE 61
Lori R,'ch,d!.on v. foberf'~J eJdfo'l
o5-2QjO {iv;j (d,vO((()
BBlfTLllllBHT AGIU!lBIIlBHT
THIS AGREEMENT, is made this Ii-- day of Jwru; ,
2005, by and between ROBERT JACK RICHARDSON ("Husband")
RICHARDSON ("Wife").
,
and LORI
. I T II . 8 8 . If R:
WHEREAS, the parties, currently Husband and wife, will be
filinq for and obtaining a decree in divorce; and
WHEREAS, "by this Agreement, the parties have intended to
effectuate and equitably divide their marital property and marital
debts; and
WHEREAS, diverse unhappy differences and difficulties have
arisen between the parties and it is their intention to live
separate and apart for the rest of their lives and to settle any
claims by one against the other or against their estates.
NOW THEREFORE, with the foregoing recitals being incorporated
by reference and deemed as an essential part hereof and in
consideration of the premises and of the mutual promises set forth
herein and for other good and valuable consideration, receipt of
which is hereby acknowledged, the parties, each intending to be
legally bound hereby, covenant and agree as follows:
1 . BI'I'BC'l' 01' DIVORCB DECRBE.
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 tD the parties. This Agreement shall be incorporated,
but not merged into the final decree in divorce.
2. J'XIIIAJitC:l:AL D:l:8CL08Ull.C.
The parties confirm each has relied on the substantial
accuracy of the financial disclosure of the other as an inducement
to executinq this Agreement. No representations have been made by
either party to the other, or by anyone else, as to the financial
status of the other except as set forth in this Agreement.
61102/1994 21:41
7172348288
LEWIS LAW OFFICE
PAGE 61
3 . ADV:l:ca O~ COUJI..L.
Wife has been advised regarding this Agreement by her
attorney, Kenneth Lewis. Husband has been advised regarding this
Agreement by the attorney of his choosing or has chosen to forego
seeking such advice. Both parties acknowledge this Agreement is,
under the ciroumstances, fair and equitable and that it is being
entered into freely and voluntarily, after having received
independent le9a1 advice, or choosing not to do so. The parties
acknOWledge this Agreement is not the result of duress or undue
influence and is not the result of any collusion or improper or
illeqal aqreellent(III). This Agreement shall be construed as if
drafted by both parties.
4 . DI8CLOIInB:um WAIVBIl OF PROClBDUIUI.J. llIGBTB.
The parties understand each has the riqht to obtain from
the other party a complete inventory of all the property either or
both parties now own or owned as of the date of separation, and
that each has the right to have such property val~ed by appraisals
or otherwise. The parties understand they have the right to have
a Court hold hearings and make decisions on the matters covered by
this Agreement. Both paJ:ti.. understand a Court's decision
concerning the parties' respective rights and obligations might be
different from the provisions of this Agreement.
Both parties waive the following procedural rights:
a. The riqht to obtain an Inventory and
Appraisement of all marital and separate property as defined by the
Pennsylvania Divorce Code.
D. The right to obtain an Income and Expense
statement of the other party as provided by the Pennsylvania
Divorce Code.
c. The right to have the Court determine which
property is marital and which is non-marital and equitably
distribute between the parties that property which the Court
determines to be marital.
d. The right to have the Court decide any other
rights, remedies, privileges, or O):)ligations covered by this
Agreement, including but not limited to poss!):)le claims for
divorce, spousal support, alimony, alimony pendente lite, counsel
fees, costs and expenses.
2
61162/1994 21:41
71 72348288
LEWIS LAW OFFICE
PAGE 62
5. PBR.O-.L RIGBT..
lfusband "nd Wife, m"y live separate and apart. Each
shall pe free from any interference, direct or indirect, by the
other in all respects as if they were unmarried. Husband and W~fe
shall not harass, disturb or malign each other or the respect1ve
families of the other nor attempt to compel the other to coh"bit or
dwell by any means or in any manner whatsoever with him or her.
6. MUTtI~ aRLII!1I.s...
Husband and Wife each mutually release and forever
discharge the other and the other's estate from any and all rights
of the other or "qainst the other's estate, which he/she now has or
may hereafter have against the other or the other's estate, arising
out of any circumstance whatsoever (intestate laws, the right to
take against the spouse's will, and/or all other rights of a
surviving spouse to participate in a deceased spouse's estate,
regardless of the jurisdiotion). The release includes any rights
which either party may have or "t any time hereafter have for past,
present or future support or maintenance, alimony, alimony pendente
lite, counsel fees, equitable distribution, costs or expenses,
whether arising as a result of the marital relation or otherwise,
except, and only except, rights and obligations arising under this
Agreement or for the breach of any provision thereof. It is the
intention of Husband and wife to give to each other a complete and
general release with respect to all property of any kind or nature,
whiCh the other now owns or may hereafter acquire, except and only
excepting rights and obligations arising under this Agreement.
7 . PBRSOJfJU. PROPD'1'Y.
The parties make the following disposition and settlement with
respect to their personal property.
a) HUSband and Wife agree they have equitably divided
!III their personal property to eaCh's satisfaction and that each
shall retain the property in his/her possession at the time of this
Agreement (except as provided otherwise in this Agreement).
bl Financial Accounts. The parties acknowledge there
are no jointly-titled financial accounts. Husband and Wife agree
that each shall maintain al1 the financial accounts currently
titled in hiS/her name, including but not limited to bank accounts,
cre~it union aocounts, lRAs, certificates of deposit, 401K plans,
ret~rement accounts of whatever nature. Each waives any rights
he/she may have to the others financial accounts.
3
61102/1994 21:41
71 72348288
LEWIS LAW OFFICE
PAGE 03
c) Automobile~.
i) Husband shall retain and be the sole owner of
the two trucXs (Chevy and Ford) ourrently in his possession. Wife
shall transfer title to the chevy within fourteen (14) days of the
signing of this Agreement. Husband shall be responsible for all
debts and expenses pertaining to these vehicles and shall indemnify
wife from any and all harm arising from the possession and/or
ownerShip of these vehicles.
iil Wife shall retain and be the sole owner of the
Suburu Forrester. Wife shall be responsible for all debts and
expenses pertaining to this vehicle and shall indemnify husband
from any and all harm arising from the possession and/or ownership
of these vehicles.
8 . Al'TD-AcOUXaZD PBR801lAL paOplUl'1'Y.
Each of the parties shall hereafter own and enjoy,
independently of any claim or right of the other, all items at
personal property, tanqible 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 not married.
9. aRU .STATB.
wite shall become sole owner of the trailer and land
located at 344 Coffeetown Road, Dillsburg, PA 17019, currently
titled in her name. Wite shall be responsible for all debts and
expenses associated with this property and shall indemnify husband
from any and all harm arising from the possession and/or ownerShip
of this property.
10. ALIIIOIlY. ALJ:I(olrY PBJlDEIl'1'B LZTB. SPOUSAL SUPPOaT.
The parties hereby waive and surrender any rights and/or
claims they may have to interim or final alimony, alimony pendente
lite and spousal support.
11. ATTORJlEY'S FBBS AND COSTS.
The parties waive and surrender any rights and/or claims
they may have to interim or final counsel fees and/or costs.
4
01102/1994 21:41
71 72348288
LEWIS LAW OFFICE
PAGE 04
12... DII.'I'8.
8) The parties acknowledge there are no jointly-titled
debts. Each party shall be solely responsible fo~ all debts listed
in his/her sole name. Each party shall indemnify and hold the
othe~ ha~mless against all actions o~ collections of whatever kind
arising out of these debts. Accordingly, Wife shall be responsible
to~ the approximate $5,000.00 cha:t'ged to her Visa account for
Husband's business expenses.
b) Each party represents he/she has not incurred any
liability tor which the other may be :t'esponsible except as may
be provided. for in this Agreement. Each party agrees to indemnify
or hold the other party harmless from and against any and all such
debts, except tor the obligations arising out of this Agreement.
13. TAXI8.
The parties acknowledge that each is filing a separate
tax return for the year 2004 and that each shall be responsible for
any taxes owed under his/her separate return.
14. WAP.."X8S TO ~UTURB OBLIGATIOIIS.
"usband and Wife each agree that each will now and at all
times hereafter save harmless and keep the other indemnified from
all debts, charges and liabilities incurred by the other after the
execution date of this Ag~eement, except as may be otherwise
specifically p:t'ovided for by the terms of this Agreement and that
neither of them shall hereafter incur any liability whatsoever for
which the estate of the other may be liable.
15. WAXVRR OR MODI.ICATIOH TO DB XH WRITIIIG.
No modification or waiver of any of the terms hereof
shall be valid unless in writing and signed by both parties and no
waiver at any breach hereof or default hereunder shall be deemed a
waiver of any subsequent default of the same or similar nature.
16. DRBACH.
The parties agree that if either fails in the due
performance of any of his or her obligations under this Agreement,
the other party shall have the right at his or her election to sue
5
~1{02/1994 21:41
.
LEWIS LAW OFFICE
PAGE 65
7172348288
for damages for breach thereof, to sue for specific performance, or
to seek any otner legal remedies as may be available and said other
party shall have the right to recover his or her reasonable legal
fees and costs for any services rendered by his or her attorney.
17. IIU'l'UAL COOPBRA'l'IOII.
Each party shall, at any time and from time to time
hereafter, take all steps and execute, acknowledge and deliver to
the other party any 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.
18. LAW O. PBIlIlBYLVARIA APPLICABLB.
This Agreement shall be construed in accordance with the
laws of the Common~ealth of Pennsylvania.
19. Atzll_-IIlIl'l' BIJmIIIG 011 HIlIRS.
This Agreement shall be binding and shall inure
benefit of the parties hereto and their respective
executors, administrators, successors and assigns.
to the
heirs,
20. INTBall:a."'IOII.
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 tnan those expressly set forth herein.
21. NO WAXVBR OF DBPAU~'l'.
This Agreement shall remain in full force and effect
unless and until terminated under and pursuant to the terms of this
Agreement. 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 or any other obligations herein.
6
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,lH182/1994 21: 41
71 72348288
LEWIS LAW OFFICE
PAGE 66
. .
22. S.V"~ILITY.
If any term or provision of this Aqreement shall be
determined to be invalid, then only that term or provision shall be
stricken 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 the exception of the
satisfaction of the conditions precedent, shall in no way void or
alter the remaining obligations of the parties.
23. KBADIIICJ8 NOT PART OP AGRBJDlBlIT.
Any headings preceding the text of the paragraphs and
subparagraphs hereof are inserted solely for convenience of
reference and shall not constitute a part of this Agreement nor
shall they affect its meaning, construction or effect.
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WITNESS
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ROBERT JACK RICHARDSON
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KENNETH F. LEWIS, ESQUIRE
Attorney I.D. #69383
1101 North Front Street
Harrisburg, PA 17102
(717) 234-3136
Attorney for Plaintiff
LORI RICHARDSON,
Plaintiff
IN THE COURT OF co~n10N PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 05-2930
CIVIL ACTION - LAW
ROBERT JACK RICHARDSON,
Defendant
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce was filed under Section 3301
(c) of the Divorce Code on June 8, 2005.
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 to intention to request ent.ry 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.
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LORI RICHARDSON
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LORI RICHARDSON,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 05-2930
: CIVIL ACTION - LAW
ROBERT JACK RICHARDSON,
Defendant
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER SECTION
3301 (e) OF THE DIVORCE CODE
1. r 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 a
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 the foregoing
document are true and correct. I understand that false statements
herein are made subj ect to the penal ties of 18 Pa. C. S. section
4904, relating to unsworn falsification to authorities.
Id/l3/J5
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LORI RICHARDSON
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LORI RICHARDSON,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 05-2930
CIVIL ACTION - LAW
ROBERT JACK RICHARDSON,
Defendant
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
To The Prothonotary:
Transmit the record, together with the following information,
to the Court for entry of a Divorce Decree:
1. Ground for divorce: irretrievable breakdown under section
(Xl 3301(c)
() 3301(dl of the Divorce Code.
2. Date and manner of service of the Complaint: Acceptance of
Service dated 6/15/05 and filed 6/17/05.
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 and Waiver of Notice of
Intention to Request Entry of a Divorce Decree: by the Plaintiff on
10/13/05; by the Defendant on 213/06.
4. Related claims pending: NONE. Propertv Settlement
Aqreement incorporated into decree resolvinq all issues.
DATED: ~/11 oC,
KE ETH F. LEWIS, ESQ.
Attorney I.D. #69383
1101 North Front Street
Harrisburg, PA 17102
(717) 234-3136
Attorney for Plaintiff
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Attorney I.D. 169383
1101 North Front Street
Harrisburg, PA 17102
(717) 234-3136
Attorney tor Plaintiff
LORI RICHARDSON,
Plaintiff
IN THB COURT OF COMMON PLEAS OF
CUMBJ!RLA..I\!!) CO'tn."'!'Y, pn~!SYLv)'.N!.ll
v.
NO. 05-2930
CIVIL ACTION - LAW
: IN DIVORCB
ROBaT JACIt RICHARDSON,
Defendant
"I'TnlLVTT DIP rnml1lll'l'
1. A Complaint in Divorce was filed under Section 3301
Ie) of the Divorce Code on JUne 8, 2005.
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 Pinal Decree in Divorce
after service of notice to intention to request ent%Y 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.
Dsted: 'd/C?o/Cl,.,
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ROBERT JACX RICHARDSON
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IN THB COURT OP COMMON PLEAS OIi'
CUMBBRLAND COtlNTY, PENNSYLVANIA
NO. 05-2930
CIVIL ACTION - LAW
I..ORI RICHARDSON,
Plaintiff
ROBERT JACK RICHARDSON,
Defendant
IN DIVORCB
WAIVBR 01' IIOTICB OF UV".nwl'IOlf TO UQUBST
BI'l'Ry OF A DIVORCB DBCRBB tDlDBR SECTION
3301 (e) 01' THB DIVORCB CODB
1. I con8en~ to entry of a final Decree of Divorce
without notice.
2. I understand that I may lose rights concerning
alimony, division of proper~y, 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
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 t.he 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 falsification to authorities.
Dated: ':;)/0''''1 or.,
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ROBBRT JACK RICHMUlSON
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IN THE COURT OF COMMON PLEAS
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STATE OF
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LOlZI fICHAfJ)50N
()5--2<-J30
No.
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VERSUS
19BEtlT :Sf) O( ~/(jIf}t/)~JJ
DECREE IN
DIVORCE
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AND NOW,
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Z006, iT is ORDERED AND
DECREED THAT Loa 1-/[)I/J/!lJ5o;J
AND /'o&EI-T Jlt{): J-J{lIlllj)J(J;V
, PLAiNTiFF,
, DEFENDANT,
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ARE DiVORCED FROM THE BONDS OF MATRiMONY_
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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;
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jI}..1/1e. TAe parh'e./ IIJf!e /~ 2j(}5 .se lI/ef)Je/JflJjft>e~(/Jf;
filed Oil ,Jr;ae J?12(}1J~ is 1~(U1C1la!ed lfh fi;'s Oecft>e.
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~ B\riHE C
ATTEST:
OTHONOTARY
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Of Of. T.".'"
/47 p /'P"~ ~JC'tL) "7c1 3/ <
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Lori Richardson
vs.
CIVIL ACTION - LAW
Plaintiff
Robert Jack Richardson
Defendant
FILE NO. 05-2930
IN DIVORCE
NOTICE TO RESUME, PRIOR SURNAME
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Cllr EV
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Notice is hereby given that the Plaintiff/Defendant in the above matter, having
been granted a Final Decree in Divorce on the 15th day of February 2006
hereby elects to resume the prior surname of Lori Denise Neely
and gives this written notice pursuant to the provisions of 54 P.S. 704.
DATE: ? ' 13 ' 01611
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
k usu. -C/ Plx`c A ah d Sam
Signature _
Signature of name being resumed
SS.
On the _? day of ?lt V? , 20-LL before me, a
Notary Public, personally appeared the above affiant known 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.
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D
In Witness Whereof, I have hereunto set my hand and official seal.
:aIMMONWEALTH OF PENNSYLVANIA
Notarial seal
ouMy* K. Oattlaman, Notary Public
.;h ? JunoM County e Notary Public
per ?%itntvWpnia Association of Notaries
an4lull.cb Pd PIPS
rno1'k- 18510IL)g0(
nla ac?o8o 3