HomeMy WebLinkAbout01-3733
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IN THE COURT OF COMMON PLEAS
OFCUMBERLANDCOUNTY
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STATE OF
LEIGH A. STOEY,
VERSUS
TODD E. STOEY,
PENNA.
Plaintiff
No.
01-3733 CIVIL
Defendant
DECREE IN
DIVORCE
o;r i./: )Of- flit ·
AND NOW,
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2002 , IT IS ORDERED AND
DECREED THAT
LEIGH A. STOEY
, P LA I NT IFF,
TODD E. STOEY
AND , DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD IN TH IS ACTION FOR WH ICH A FI NAL ORDER HAS NOT
YET BEEN ENTERED;
2002 is incorporated
THe parties' Post-Nuptial Aqreement dated September 15,
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None.
this Decree.
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LAW OFFICES
SNELBAKER.
BRENNEMAN
& SPARE
LEIGH A. STOEY,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
v.
NO, 01-3733 CIVIL TERM
CIVIL ACTION - LAW
TODD E. STOEY,
Defendant
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
TO: Prothonotary of Cumberland County:
Please 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 3301(c) of the Divorce
Code.
2. Date and manner of service of Complaint: by certified mail, restricted delivery on
Defendant on August 3, 2001 (see Affidavit of Service filed August 7, 2001).
3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the
Divorce Code: by the Plaintiff: September 15, 2002; by the Defendant: September 15,2002,
4, Date of execution of Waiver of Notice in Section 3301(c) Divorce: by the Plaintiff:
September 15,2002; by the Defendant: September 15,2002.
5. Related pending claims: None.
SNELBAKER, BRENNEMAN & SPARE, P. C.
Date: September 20, 2002
By:
Attorneys for Plaintiff
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POST-NUPTIAL AGREEMENT
THIS AGREEMENT, made and entered into this / 6 -r A. day of September, 2002
by and between:
LEIGH A. STOEY, of Carlisle, Cumberland County,
Pennsylvania, party of the first part, (hereinafter "Wife")
AND
TODD E. STOEY, of Boiling Springs, Cumberland
County, Pennsylvania, party of the second part,
(hereinafter "Husband")
WITNESSETH:
WHEREAS, Husband and Wife (collectively referred to herein as the "parties") were
married to each other on June 12, 1998 in Cumberland County, Pennsylvania and separate
January 1,2001 since which time they have been living separate and apart; and
WHEREAS, the parties last resided with each other at 5 Valley Street, Carlisle,
Pennsylvania; and
WHEREAS, the parties have accumulated certain assets and incurred certain debts during
their marriage; and
WHEREAS, the parties have one child, namely, Kyle B. Stoey, born March 19, 1992;
and
WHEREAS, certain differences have arisen between the parties, as a consequence of
which they are separated and live apart from each other; and
WHEREAS, on June 18, 2001 Wife commenced an action in divorce docketed to
No. 2001-3733 in the Court of Common Pleas of Cumberland County, Pennsylvania (hereinafter
the "Divorce Action"); and
WHEREAS, the parties agree that their marriage is irretrievably broken; and
WHEREAS, the parties acknowledge that each has had the full opportunity to be advised
independently and represented by separate counsel concerning their respective rights, duties and
obligations arising out of their marital status and with respect to the terms and provisions ofthis
Post-Nuptial Agreement and the meaning and legal effect thereof and have either obtained such
advice and representation or have voluntarily chosen not to do so; and;
WHEREAS, the parties having a full opportunity to be so advised of their respective
rights, duties and obligations arising out of their marital status, and each having a full
opportunity to investigate and evaluate assets, liabilities and all other aspects of each other's
property and their jointly owned assets and liabilities, have come to an agreement for the final
settlement of their property and affairs, which they believe to be fair, just and equitable.
NOW THEREFORE, in consideration of these presents and the mutual covenants,
promises, terms and conditions hereinafter set forth and to be kept and performed by each party
hereto, and intending to be legally bound hereby, the parties mutually agree as follows:
1. INCORPORATION OF PREAMBLE. The foregoing preamble and paragraphs are
incorporated by reference herein in their entirety.
2. MUTUAL SEP ARA TION. Husband and Wife shall be free from constraint or control
by the other as fully as ifhe or she were unmarried. Neither shall disturb, trouble nor interfere in
any way with the other or with any person for associating with the other.
3. DECLARATION AS TO ASSETS AND WAIVER OF EVALUATION.
The parties declare and agree that they have, prior to the execution of this Post-Nuptial
Agreement, voluntarily agreed to divide and have physically divided and distributed between
themselves all of the parties' personal property, furnishings and furniture. All assets and
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property possessed by each party as a result of this final division and distribution shall be owned
and possessed free of any right or claim of the other, it being understood that each party may
own, possess, use and dispose of freely any property in his or her possession.
The parties acknowledge and agree that the division and distribution of property as set
forth above has occurred whether or not said property is or would be deemed to be marital
property under the Pennsylvania Divorce Code and subject to equitable distribution,
The parties declare and acknowledge that they are fully aware and familiar with all assets
and real property that each has brought into the marriage and that has been obtained or acquired
separately or jointly by them during the course of their marriage and therefore waive any
valuation thereof. Each party expressly releases the other of and from any and all right of
equitable distribution or claims to assets and property of any kind or nature whatever possessed
in accordance with this Agreement by the other party and hereby declares and acknowledges
that the voluntary division by them of all property, whether marital or not, is fair and equitable.
4. AUTOMOBILES. The parties represent and acknowledge that each is in possession
of motor vehicle titled in his or her name alone and that each shall retain sole ownership, use and
possession of the motor vehicle in his or her possession. Each party further agrees to waive any
right or interest in or to the motor vehicle in the possession of the other and be solely responsible
for insuring and paying any debt secured by or applicable to the vehicle in his or her possession
whether or not said debt was incurred during the parties' marriage. Finally, each party agrees to
hold harmless and indemnify the other of and from any liability, loan or expenses relating to the
ownership, use and maintenance of the motor vehicle in his or her possession,
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5. BANK ACCOUNTS AND MONEY MARKET ACCOUNTS.
The parties represent that there are no joint bank accounts and that any bank accounts
jointly held by the parties up to the time of their separation have been divided by mutual
agreement to their satisfaction.
6. MUTUAL DEBT AND FUTURE OBLIGATIONS. The parties represent that there
are no joint debts or other obligations outstanding, due or collectable for which they are jointly
liable. The parties agree that each shall be responsible for the payment of any debt in his or her
own name or any other obligation for which he or she is solely liable, whether or not that debt
was incurred during their marriage and irrespective of the purpose for which such debt or
obligation was incurred.
The parties agree that any and all loans, debts and/or obligations incurred subsequent to
January 1, 2001 shall be the sole and separate liability and responsibility of the party incurring
the obligation and each party agrees that he/she will not incur or attempt to incur any obligations
for or on behalf of the other party and will indemnify and hold harmless the other party of and
from any and all liability arising from any debt or obligation that either party has presently in his
or her name and is solely obligated to pay.
7. CUSTODY. The parties acknowledge that they have a shared legal and physical
custody arrangement with respect to their son, Kyle, which is acceptable to them,
8. PENSION, 401K, RETIREMENT PLANS, BENEFITS EMPLOYMENT BENEFITS.
Each party waives and forever releases the other of and from any and all claims which either
may have against the other's pension, 401K Plan, retirement plan or any other retirement plan,
benefit or employee benefit or benefits, whether or not same may be vested.
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9. TAX IMPLICATIONS AND MATTERS. Husband and Wife agree that Wife shall be
able to claim their son, Kyle, as a dependent for federal income tax purposes on even numbered
years and Husband on odd numbered years,
In the event it is determined that there is any tax liability of the parties, which liability
relates to any year the parties were married and filed jointly, then in such event, the parties will
contribute to the payment of such liability in proportion to their respective incomes for the year
to which such liability pertains.
10. RELEASE OF SUPPORT AND RIGHTS UNDER DIVORCE CODE.
Each party waives and forever releases the other party of and from any and all claims
which either may have against the other for spousal support and for claims which either may
have against the other by reason of and pursuant to the Pennsylvania Divorce Code (and the
divorce law of any other jurisdiction) including, but not limited to, alimony, alimony pendente
lite, equitable distribution of marital property, counsel fees, cost and expenses, except that the
performance of any obligation created hereunder may be enforced by any remedies under the
Pennsylvania Divorce Code.
11. DIVORCE, The parties agree to terminate their marriage by mutual consent without
counseling and each agrees to execute the necessary affidavits, waivers and consents to procure a
consensual divorce under the provisions of the Pennsylvania Divorce Code, such documents to
be filed in the Divorce Action.
12. GENERAL RELEASE, Husband relinquishes his inchoate intestate right in the
estate of Wife, and Wife relinquishes her inchoate intestate right in the estate of Husband, and
each of the parties hereto by these presents, for himself or herself, his or her heirs, executors,
administrators or assigns, does hereby remise, release, quit-claim and forever discharge the other
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party hereto, his or her heirs, executors, administrators or assigns, or any of them, of any and all
claims, demands, damages, actions, causes of action or suits at law or in equity of whatsoever
kind or nature, for or because of any matter or thing done, omitted or suffered to be done by such
other party prior to the date hereof, except that this release shall in no way exonerate or discharge
either party from the obligations and promises made or imposed by reason of this Agreement.
13. SURVIVAL OF AGREEMENT. It is the intention of the parties that this Post-
Nuptial Agreement shall survive any action in divorce which may be instituted or prosecuted by
either party, and no order, judgment or decree of divorce, temporary, interlocutory, final or
permanent, shall affect or modify the terms of this Agreement, but said Agreement may be
enforced by any remedy at law or in equity, including enforcement proceedings under the
Pennsylvania Divorce Code. The parties agree to incorporate this Agreement into a separate
order of court to be entered in the Divorce Action, but this Agreement shall not be merged into
said order or decree in divorce,
14. COOPERATION. The parties agree to cooperate with each other and to make,
execute, acknowledge and deliver such instruments and take such further action as may hereafter
be determined to be requisite and necessary to effect the purposes and intention of this Post-
Nuptial Agreement.
15. BREACH; INDEMNIFICATION. If either party hereto breaches any provision
hereof, then the nonbreaching party shall have the right, at his or her election, to sue for damages
for said breach, or seek such other remedies or relief as may be available to him or her, and the
defaulting party shall be responsible for payment of all reasonable legal fees and costs incurred
by the other party in enforcing his or her rights under this Agreement. Each party agrees and
covenants to indemnify and hold harmless the other party from any and all liability and/or claims
and/or damages and/or expenses (including attorneys' fees and expenses of litigation) that the
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...
indemnitee may sustain or may become liable or answerable in any way whatsoever, or shall pay
upon, or in the consequence of, the indemnitor's breach of any obligation, term or covenant of
indemnitor under this Agreement, including, but not limited to, indemnitor's obligation to make
any payment provided for herein.
16. VOLUNTARY EXECUTION. The parties declare and acknowledge that they have
had the opportunity to have the provisions of this Post-Nuptial Agreement and their legal effect
explained to them by independent counsel of their choosing and each party acknowledges that
this Post-Nuptial Agreement is fair and equitable, that it is being entered into voluntarily, with
full knowledge of the assets of both parties, and that it is not the result of any duress or undue
influence. The parties acknowledge that they have been furnished with all information
relating to the financial affairs of the other to the extent same has been requested by each of
them.
17. ENTIRE AGREEMENT. This Post-Nuptial Agreement contains the entire
understanding of the parties and there are no representations, warranties, covenants or
undertakings other than those expressly set forth herein. The parties acknowledge and agree that
the provisions of this Agreement with respect to the distribution and division of marital and
separate property are fair, equitable and satisfactory to them based on the length of their marriage
and other relevant factors which have been taken into consideration by the parties. Both parties
hereby accept the provisions of this Agreement with respect to the division of property in lieu of
and in full and final settlement and satisfaction of all claims and demands that they may now
have or hereafter have against the other for equitable distribution of their property by any court
of competent jurisdiction pursuant to the Pennsylvania Divorce Code or any amendments
thereto. Each party voluntarily and intelligently waives and relinquishes any right to seek a court
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ordered determination and distribution of marital property, but nothing herein contained shall
constitute a waiver by either party of any rights to seek the relief of any court for the purpose of
enforcing the provisions of this Agreement.
18. W AIVER/MODIFICA TION. The waiver of any term, condition, clause or provision
of this Agreement shall in no way be deemed or considered a waiver of any other term,
condition, clause or provision of this Agreement. This Agreement can only be modified in
writing executed by both parties hereto.
19. APPLICABLE LAW. This Agreement shall be construed, interpreted and enforced
according to the laws of the Commonwealth of Pennsylvania.
20. HEADINGS. The headings or titles of the numbered paragraphs of this Agreement
have been used only for the purpose of convenience and shall not be resorted to for the purposes
of interpretation or construction of the text of this Agreement.
21. EFFECTIVE DATE. This Agreement shall be dated and become effective on the
date when executed by the latter of the two parties.
IN WITNESS WHEREOF, the parties have hereunto set their respective hands and seals
intending to legally bind themselves and their respective heirs, personal representatives and
aSSIgns.
WITNESSED BY:
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Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
LEIGH A. STOEY,
v.
: NO. 01- 3?33
CIVIL TERM
TODD E, STOEY,
Defendant
CIVIL ACTION - LAW
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 that the court require you and your spouse to attend marriage counseling prior
to a divorce decree being handed down by the court. A list of marriage counselors is available in
the Office of the Prothonotary at the Cumberland County Court House, Carlisle. You are
advised that this list is kept as a convenience to you and you are not bound to choose a counselor
from the list, All necessary arrangements and the cost of counseling sessions are to be borne by
you and your spouse.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LA WYER'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 WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
(717) 249-3166
SNELBAKER, BRENNEMAN & SPARE, P.c.
LAW OFFICES
SNELBAKER.
BRENNEMAN
& SPARE
By:
Attorneys for Plaintiff
LAW OFFICES
SNELBAKER.
BRENNEMAN
& SPARE
LEIGH A. STOEY,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. o/~ 3733
Plaintiff
v.
CIVIL TERM
TODD E. STOEY,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
COMPLAINT
l. Plaintiff Leigh A. Stoey is an adult individual residing at 5 Valley Street, Carlisle,
Cumberland County, Pennsylvania.
2. Defendant Todd E. Stoey is an adult individual residing at 120 3rd Street, Boiling
Springs, Cumberland County, Pennsylvania.
3. Both Plaintiff and Defendant have been bona fide residents of the Commonwealth of
Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were lawfully joined in marriage on June 12, 1998 in
Cumberland County, Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the parties
hereto in this or any other jurisdiction since the date of the marriage averred in Paragraph
4, above.
6. Neither party is a member of the armed forces of the United States of America.
7. The Plaintiff avers as the grounds upon which this action is based is that the marriage
LAW OFFICES
SNELBAKER.
BRENNEMAN
& SPARE
between the parties hereto is irretrievably broken.
8. The 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. The Plaintiff requests this Court to enter a decree of divorce.
WHEREFORE, Plaintiff Leigh A. Stoey requests this Court to enter a Decree of
Divorce, divorcing the Plaintiff from the bonds of matrimony and to order such other
relief as this Court deems just and reasonable.
SNELBAKER, BRENNEMAN & SPARE, P.C.
~~~
Date:
By:
Keith O. Brenneman, Esquire
44 West Main Street
Mechanicsburg, P A 17055-0318
(717) 697-8528
Attorneys for Plaintiff Leigh A. Stoey
June 15, 2001
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LAW OFFICES
SNELBAKER.
BRENNEMAN
& SPARE
VERIFICATION
I verify that the statements made in the foregoing Complaint are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section
4909 relating to unsworn falsification to authorities.
Date:
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"..._ Leigh A. St
June 15, 2001
LAW OFFICES
SNELBAKER.
BRENNEMAN
8: SPARE
LEIGH A. STOEY,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
v.
NO.
CIVIL TERM
TODD E. STOEY,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
AFFIDA VIT
LEIGH A. STOEY being duly S\VOlTl accmding to law, deposes and says:
1. I have been advised of the availability of marriage counseling and understand that I
may request that the court require that my spouse and I participate in counseling.
2, I understand that the court maintains a list of marriage counselors in the Office of the
Prothonotary, which list is available to me upon request.
3. Being so advised, I do NOT request that the court require my spouse and I participate
in counseling prior to a divorce decree being handed down by the court.
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.
d~c}- a S~
Leigh A. Stoey
(Plaintiff)
Date: June 15, 2001
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LAW OFFICES
SNELBAKER.
BRENNEMAN
& SPARE
LEIGH A. STOEY,
v.
TODD E. STOEY,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 01-3733 CIVIL TERM
CIVIL ACTION - LAW
Defendant
IN DIVORCE
PLAINTIFF'S AFFIDAVIT OF CONSENT
UNDER SECTION 3301 (C) OF THE DIVORCE CODE
1. A complaint in divorce under Section 3301(c) ofthe Divorce Code was filed on
June 18,2001.
2. The marriage of the Plaintiff and the 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 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,
Date: 91/~2.
a.
Leigh A. Stoey
(Plaintiff)
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LAW OFFICES
SNELBAKER.
BRENNEMAN
& SPARE
LEIGH A. STOEY,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
v.
: NO. 01-3733 CIVIL TERM
CIVIL ACTION - LAW
TODD E. STOEY,
Defendant
IN DIVORCE
DEFENDANT'S AFFIDAVIT OF CONSENT
UNDER SECTION 3301(C) OF THE DIVORCE CODE
1. A complaint in divorce under Section 3301(c) ofthe Divorce Code was filed on
June 18,2001.
2. The marriage of the Plaintiff and the 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 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. ~ 4904, relating to
unsworn falsification to authorities.
Date:
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LAW OFFICES
SNELBAKER.
BRENNEMAN
& SPARE
LEIGH A. STOEY,
v.
TODD E. STOEY,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01-3733 CIVIL TERM
CIVIL ACTION - LAW
Defendant
IN DIVORCE
PLAINTIFF'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: q/15)OZ
~6.~
Leigh A. Stoe I
(Plaintiff)
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LEIGH A. STOEY,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 01-3733 CIVIL TERM
CIVIL ACTION - LAW
TODD E. STOEY,
Defendant
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:
LAW OFFICES
SNELBAKER.
BRENNEMAN
& SPARE
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LAW OFFICES
SNELBAKER.
BRENNEMAN
& SPARE
LEIGH A. STOEY,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
v.
NO. 01-3733 CIVIL TERM
CIVIL ACTION - LAW
TODD E. STOEY,
Defendant
IN DIVORCE
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA)
SS.
COUNTY OF CUMBERLAND
)
Keith O. Brenneman, Esquire, being duly sworn according to law deposes and says: that
he is a principal in the law firm ofSnelbaker, Brenneman & Spare, P. C., being the attorneys for
Leigh A. Stoey, Plaintiff in the above captioned action in divorce; that on July 24,2001, he did
send to Defendant Todd E. Stoey by certified mail, return receipt requested, restricted delivery, a
duly certified copy of the Complaint in Divorce which was filed in the above captioned action as
evidenced by the attached cover letter of the same date and Receipt for Certified Mail No. 7000
1670 0008 5047 3190; that both the Complaint and cover letter were duly received by Todd E.
Stoey, the Defendant herein, as evidenced by the return receipt card for said certified mail dated
August 3, 2001; that a copy of the aforementioned cover letter dated July 24,2001 is attached
hereto and incorporated by reference herein as "Exhibit A" and that the original Receipt for
Certified Mail and the Domestic Return Receipt are attached hereto and incorporated by
reference herein as "Exhibit B"; and that the foregoing facts are true and correct to the best of his
LAW OFFICES
SNELBAKER.
BRENNEMAN
& SPARE
knowledge, information and belief.
Sworn to and subscribed before me
this 6th day of August, 2001.
~A(}~ j;, ~.~
Notary Public
NotarIal Seat
Buaen L. ~ No8y PUlIc
~ BDro, CumberlaIIdCourllV
,My n Expn. Nov. 24. 2003
~ ~~, ~ MJhIIt8s
~~
Keith O. Brenneman
-2-
SNELBAKER, BRENNEMAN 8 SPARE
^ PROFESSIONAL CORPORATION
ATTORNEYS AT LAW
44 WEST MAIN STREET
MECHANICSBURG, PENNSYLVANIA 17055
RICHARD C. SNELBAKER
KEITH O. BRENNEMAN
PHILIP H SPARE
P. O. BOX 318
FACSIMILE (717) 697-7681
717'697-8528
July 24,2001
Todd E. Stoey
P. O. Box 53
Boiling Springs, P A 17007
Re: Stoey v. Stoey
No. 2001-3733, Cumberland County
Dear Mr. Stoey:
Enclosed please find a certified copy of a Divorce Complaint which was filed on behalf
of Leigh Stoey,
Yours truly,
Keith O. Brenneman
KOB/sz
Enclosure
CC: Leigh Stoey (w/enclosure)
Via certified mail, return receipt requested, restricted delivery,
parcel No. 7000 1670000850473190
.....
EXHIBIT A
, ...
u.s. Postal Service
CERTlflEO MAIL RECEIPT
(Domestic Mail Only; No Insurance Coverage Provided)
CJ
0-
M
IT1
I"'-
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CJ
LI1
Postage $
~q
11'1t1e.J 7f;'f}~ I
5' : is P.r11
Postmark
Here
Certified Fee
2.10
1.50
3.20
f1.3i
Jtd /3
<0
CJ
CJ
CJ
Return Receipt Fee
(Endorsement Required)
Restricted Delivery Fee
(Endorsement Required)
Cl
I"'-
;:;: Sent To
..".,'",'J:'()99,..~,~,",St.Q~y.,"',.,
CJ Street. Apt, No,. or PO Box No
CJ P.O. Box 53
CJ 'i5iy:State:ZtPt4...... ........,.....,' .........
I"'- Boiling Springs,
Total Postage & Fees
PA 17007
PS Form 3800, May 2000 See Reverse for Instructions
- -- - -- ----
Complete items 1, 2, ,and 3. Also complete
item 4 if 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:
0::;
o Agent
o Ad essee
Oves
o No
Todd E. Stoey
P. O. Box 53
Boiling. Spring~, PA 1700
3. Service Type
Certified Mail
o Registered
o Insured Mail
o Express Mail
o Return Receipt for Merchandise
OC,O.D.
4, Restricted Delivery? (Extra Fee)
/XIB
LAW OFFICES
SNELBAKER.
BRENNEMAN
& SPARE
2, Article Number (Copy from service label)
7000 1670 0008 5047 3190
PS Form 3811 , July 1999 Domestic Return Receipt
102595-00-M-0952
EXHIBIT B
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LAW OFFICES
SNELBAKER.
BRENNEMAN
& SPARE
LEIGH A. STOEY,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
v.
: NO. 01-3733
CIVIL TERM
TODD E, STOEY,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
PRAECIPE TO REINSTATE COMPLAINT
TO THE PROTHONOTARY:
Please reinstate the Complaint in the above-captioned action.
SNELBAKER, BRENNEMAN & SPARE, p, C.
1,{1r~
BY:
Keith O. Brenneman, Esquire
44 W. Main Street
Mechanicsburg, PA 17055
(717) 697-8528
Attorneys for Plaintiff
Leigh A. Stoey
Date: July 19,2001
a
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
__~ u~__u . ~
'('1- Sto%~intiff
:
File No.
01- ~1133
vs.
IN DIVORCE
~~ t.S~~
----- -_._.~----- -
" Defen nt
:
:
NOTICE TO RESUME PRIOR SURNAME
Notice is hereby given that the Plaintiff/Defendant in the
above matter, having been granted a Final Decree in Divorce on the
~__ day of ~ ' ~~E~_' ~erebY elects to resume the
prior surname of _~.e:. ~~\'.('\. ('Y\G.I\...-\-1(\ , and gives
this written notice pursuant to the provisions of 54 P.S. S 704.
DATE: 0_ 1'--1 - 03
--~------~-~
~t-
O,5~~
Signature ~
~t- {l. 1YJa.~~
. tu of name being resumed
COMMONWEALTH OF PENNSYLVANIA:
SS.
COUNTY OF CUMBERLAND
On the -LLL-~ day of A-L~~ Gl~t- , aQQ:2., 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.
In Witness Whereof, I
have her~t ~Yf hand
Notar
J
seal.
r<<:>TAAIAL iEN.
0ARC1E A. NEM..., Notary PubIlc
C....... Gurnbertand COl.lntv
My Qq~ l;ilqllj,. Nov. ~ 2005
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