Loading...
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. -.. - 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 GJ 0 .--, ~ = ~c; = ~ c.n <;:)1 " '- ~-n ~ ~ "'-- l~" i LCO nl-- :;~ hi ~ I -09 G) :u co C) c_, -"JO r~': -:r:-'-' '" ::-,. ;po "", :D ~<:> . ...." '~..:J ::~ S~t(') <;;;- :f; ~.~ CS <yn -C ~ z :'!~ e :;: 0 ~1J ~ co '< ~ v- 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: c::,( /S/t!JS f:J~ 0" rt?~~ ROBERT JACK RICHARDSON c " :~ ...., = c;:;) OJ' o " ~ rfi :!J r " fT< T''T' (-~a ~;)~~ ~:?l-n )....,.: CD .< <- ~ -.l ""'" -". <;"=? w 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 . ,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. \~ \J Wll^o-J~ WITNESS -1fU -:r 1? ~-<~ ROBERT JACK RICHARDSON f~ ~ <K~~ WITNESS JfflJ T~ Rv\A^C~/\l~ LORI~R CHARD SON - 7 (2 r-' c:s ~.r'\ c......~ :2. -- ..J <;;? ~:Q ('nr,::;-. -<0'<4 ~r}\ .(~\q, :;:~~ c..:)_(.(\ .~~~ t:;') CL ..,...... .".'., -;.:).:. -S -- '-'" 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. 10 I' ~ /fi {OI-'L" (f) RJ.)--ha/f.c/~jro... LORI RICHARDSON Dated: 0 ...., 0 ,= (~'~ ,;:;:1 -n C..'"l ~, ,'~. ~~ 0 nlf~ ..;i:_ iT) 0 Q . ~~: -:'j ..-~ -i :~,: rj rn r.'~ " CJ '-, CD 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 Uru; D f2ut-htJ.Ad~ LORI RICHARDSON Dated: ~ s?, S::7, ~~l <--;. --(1 -'. -~ ..0:..+ - o 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 '---I! ~2 ~~ " -n r~ j t)',~: t uo r-c",", t-:-:) f''':'-' llBlOl.-.n1 F. LBWIS, BSQt11.RB 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,., R06uL ~.~dtcU~ ROBERT JACX RICHARDSON !'<~ ,......., .:::.-:. '~-' C"-.::> -n '_1'-' -.-, :"';-1 C:..:.:; I U) , -',') '':"::) _,-..I r--....., .,,;:. v. 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., /;& IJ ~ ~.~ d ;\ '/..A.~ ROBBRT JACK RICHMUlSON ,-'" (j r'.' r-~" ~ c:~, r:~"'" o -11 --t -r-, r"-~ C::J I ,0 (';"\ ,'i" c.<~ c~~" i''''" ~ :+: 'lo;:+::+: +. ~ Of. '" Of. . . . . . . . . . . . . :+: '" '" Of "';+; ;+; ~ ~~~~T.~~~:+:* ~+'Of.+.+.+Of."'Of.T.+'T.+':+:+'+':+::+:+'+'T.+':+:+':+:++'++T.++' :+: +.:+: +. 'I' '" "'Of. + + + + + + + + + + + + + + + + + + + + IN THE COURT OF COMMON PLEAS + STATE OF PEN NA. . . + + LOlZI fICHAfJ)50N ()5--2<-J30 No. + + + + + + + + . + + + + + + + VERSUS 19BEtlT :Sf) O( ~/(jIf}t/)~JJ DECREE IN DIVORCE + + + . . . + + . + + + + + + + + + . + + . + AND NOW, f~/S G g:~jA~ 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, + . + + + 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; + + + + + + . + . + . + . . + + + + + + + . + + + + . + + 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. ~ /. -- .. ~ B\riHE C ATTEST: OTHONOTARY + + . . ,., 'f 'f ",;f +.;f;+;;+, ~ 'f; 'I':f:f '" +' 'f ~ 'f;~:f :f - + + + + + + + + . + + + + + + + + + + + + . + + + + + + + + + + + + + + + + + + + + + + + + + . . + . + + + J_ + + + + + + + + + + + + + - + + + + Of Of. T.".'" /47 p /'P"~ ~JC'tL) "7c1 3/ < ??rnp f:~c7lo/~7i-V ~7.)~7 'Il'?'/'>! c' . . "''1.. .' ~.. .' -~ ....- 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 C7 r.a 3 Zrn c Cllr EV ?Z o zo z ? 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. c; -r; r- 'L7 ? o 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