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HomeMy WebLinkAbout05-5479KAREN L. MURRAY, Plaintiff V. JOHN M. MURRAY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2005- Sli79 IN DIVORCE CIVIL TERM 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 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 the 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, Cumberland County Court House, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Lawyers Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 LAW OFFICES OF PETER J. RUSSO, P.C. Attorneys for Plaintiff PETER J. RUSSO, ESQUIRE PA Supreme Court ID: 72897 SCOTT A. STEIN, ESQUIRE PA Supreme Court ID: 81738 3800 Market Street Camp Hill, PA 17011 (717) 591-1755 KAREN L. MURRAY, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW JOHN M. MURRAY, NO. 200.5'. S"V79 CIVIL TERM Defendant IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) AND 3301(d) OF THE DIVORCE CODE AND NOW, COMES, the above-named Plaintiff by and through Law Offices of Peter J. Russo, P.C., and seeks to obtain a Decree in Divorce from the above-named Defendant, upon the grounds hereinafter more fully set forth: 1. Plaintiff is an adult individual domiciled at 45 Sycamore Drive, Mechanicsburg, Cumberland County, Pennsylvania and is a citizen of the United States. 2. Defendant is an adult individual whose mailing address is 103 A Strawberry Alley, Shiremanstown, Cumberland County, Pennsylvania and is a citizen of the United States. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for 32 years and has resided continuously therein for at least six months prior to filing of this Complaint. 4. Plaintiff and Defendant were married on July 27, 1996, in Lebanon County, Pennsylvania. 5. There are two (2) children of the parties under the age of eighteen (18). 6. There has been no prior action for divorce by either party against the other. 7. Neither Plaintiff nor Defendant is in the Armed Forces of the United States or any of its allies. 8. Plaintiff avers that the marriage between the parties is irretrievably broken. 9. 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, but does not request the same. 10. Plaintiff and Defendant have property which will be subject to a property settlement agreement, which will be filed herein at the appropriate time. WHEREFORE, Plaintiff, Karen L. Murray, prays that a decree be entered in favor of the Plaintiff and against Defendant dissolving the marriage between the two parties. Respectfully submitted, Law Offices of Peter J. Russo, P.C. By: Scott A. Stein, Esquire 3800 Market Street Camp Hill, PA 17011 (717) 591-1755 Date: %h - /a - 05 LAW OFFICES OF PETER J. RUSSO, P.C. PETER J. RUSSO, ESQUIRE PA Supreme Court ID: 72897 SCOTT A. STEIN, ESQUIRE PA Supreme Court ID: 81738 3800 Market Street Camp Hill, PA 17011 (717) 591-1755 Attorneys for Plaintiff KAREN L. MURRAY, Plaintiff V JOHN M. MURRAY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2004 - IN DIVORCE CIVIL TERM VERIFICATION I, Karen L. Murray, verify that the statements made in the foregoing document are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. §4904 relating to Unsworn Falsification to Authorities. Date: 1 U / 610 -5- lu Karen L. Murray W KAREN L. MURRAY, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW JOHN M. MURRAY, NO. 2005 - 5479 CIVIL TERM Defendant IN DIVORCE PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Please Re-instate the Divorce Complaint in the above captioned matter. Date: Respectfully submitted, v Scott A. Stein, Esqurre 3800 Market Street Camp Hill, PA 17011 (717) 591-1755 KAREN MURRAY IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW JOHN M. MURRAY NO. 2005 - 5479 CIVIL TERM Defendant IN DIVORCE ACCEPTANCE OF SERVICE AND ENTRY OF APPEARANCE TO THE PROTHONOTARY: 1 hereby accept service of the Complaint in Divorce and enter my appearance for defendant in the above matter. James W. Abraham, Esquire Attorney ID No.? 35" Abraham Law Offices 2157 Market Street Camp Hill, PA 17011 (717) 763-1700 Date: I- /O -06 ?. , o `? ?? _. t,?: • _,.,i ` r.:; KAREN L. MURRAY : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2005 - 5479 JOHN M. MURRAY : CIVIL ACTION - LAW Defendant : DIVORCE MARITAL SETTLEMENT AGREEMENT THIS AGREEMENT, made this k?? day of fiv?1 C' , 2007, by and between Karen L. Murray ("Wife"), of Mechanicsburg, Pennsylvania, and John M. Murray ("Husband"), of Shiremanstown, Pennsylvania. WITNESSETH WHEREAS, the parties hereto are Husband and Wife, married on July 27, 1996 in Lebanon County, Pennsylvania. The parties have two children, Lucas John Murray and Lindsay Nicole Murray, born on December 26, 1999. WHEREAS, diverse, unhappy differences, disputes and difficulties have arisen between the parties and it is the intention of Husband and Wife to live separate and apart for the rest of their natural lives, and the parties hereto are desirous of settling fully and finally their respective financial and property rights and obligations as between each other including, without limitation by specification: the settling of all matters between them relating to the ownership and equitable distribution of real and personal property, and the settling of any and all claims and possible claims by one against the other or against their respective estates, as well as any other matters related hereto. NOW THEREFORE, in consideration of the mutual promises, covenants and undertakings hereinafter set forth and for other good and valuable consideration, receipt of which is hereby acknowledged by each of the parties hereto, Husband and Wife, each intending to be legally bound hereby, covenant and agree as follows: AGREEMENT NOT A BAR TO DIVORCE PROCEEDINGS: This Agreement shall not be considered to affect or bar the right of Husband and Wife to an absolute divorce on lawful grounds if such grounds now exist or shall hereafter exist or to such defense as may be available to either party. This Agreement is not intended to condone and shall not be deemed to be a condonation on the part of either party hereto of any act or acts on the part of the other party which have occasioned the disputes or unhappy differences which may occur subsequent to the date hereof. The parties intend to secure a mutual consent, no-fault divorce pursuant to the terms of Section 3301(c) of the Divorce Code of 1980, as amended February 12,1988. 2. EFFECT OF DIVORCE DECREE: 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 to the parties. The parties agree that in the event of absolute divorce between them, they shall nonetheless continue to be bound by all the terms of this Agreement. 3. DATE OF EXECUTION: The "date of execution" or "execution date" of this Agreement shall be defined as the date of execution by the party last executing this Agreement. 4. DISTRIBUTION DATE: The transfer of property, funds and/or documents provided for herein shall only take place on the "distribution date which shall be defined as the date of execution of this Agreement, unless otherwise specified herein. 5. CONSENT OF PARTIES: Husband and Wife acknowledge that they fully understand the facts as to their legal rights and obligations under this Agreement. Husband and Wife acknowledge and accept that this Agreement is, under the circumstances, fair and equitable and that it is being entered into freely and voluntarily, and that the execution of this Agreement is not the result of any collusion or improper or illegal agreement or agreements. Both Husband and Wife have had this Agreement reviewed by an attorney of their choice prior to signing the Agreement or otherwise have had the opportunity to do so before signing this Agreement. 6. FINANCIAL DISCLOSURE: Except as may otherwise be stated herein, the parties confirm that each has relied on the substantial accuracy of the financial disclosure of the other as an inducement to the execution of this Agreement. 7. PERSONAL PROPERTY & REAL PROPERTY: A. Personal ProoRerty: Husband and Wife hereby agree, that except as otherwise stated in this paragraph, Wife shall have the following assets as her sole and separate property: Approx. Net Value/Eauity a. Marital Residence $208,445 b. Roth IRA - Vanguard 500 Index 32,587 c. Vanguard Healthcare mutual fund 20,788 (55% of fund = 138.79 shares) 2 d. 1999 Nissan Quest 7,215 e. Joint assets/accounts received post separation 7,000 TOTAL: $278,951 Husband shall have the following assets as his sole and separate property: a. EDS 401(k) b. Vanguard Healthcare mutual fund c. Vanguard annuity d. EDS Pension e. Roth IRA - Vanguard Total Stock Market f. 2003 Saab 9-5 Aero g. EDS Stock h. Kindercare 401(k) i. Joint assets/accounts received post-separation TOTAL: $147,748 17,008 (45% of fund = 113.56 shares) 19,767 22,880 6,406 6,503 1,872 1,044 4,000 $227,228 The following assets shall be set aside for the parties' children: a. Vanguard Long Term-PA Tax Exempt $59,602 b. 529 Plan - Lucas 28,348 c. 529 Plan - Lindsay 27,221 d. Savings Bond - Lucas 3,496 e. Savings Bond - Lindsay 3,496 f. Vanguard Education IRA - Lucas 400 g. Vanguard Education IRA - Lindsay 400 TOTAL: $122,962 Husband and Wife further agree that Husband shall be solely responsible for the vehicle loan for the 2003 Saab 9-5 Aero, of approximately $14,517; and Husband shall be responsible for payment of all financial obligations relating to the vehicle, including but not limited to, the monthly loan payment, insurance and any other costs related to the vehicle. Husband shall not be required to refinance the vehicle. Husband agrees to indemnify and hold Wife harmless from any default by Husband as to said financial obligations. Wife shall transfer sole title to the vehicle to Husband after the loan against the vehicle is paid in full. Husband and Wife fiwther agree that Wife shall be solely responsible for all financial obligations relating to the 1999 Nissan Quest, including but not limited to, insurance and any other costs related to said vehicle. Husband agrees to transfer title to the vehicle within thirty (30) days from the date of this Agreement. 3 B. Real Property: Husband and Wife hereby agree and acknowledge that the former marital residence, located at 45 Sycamore Drive, Mechanicsburg, Pennsylvania, shall become the sole and separate property of Wife. Wife shall refinance the mortgage against the property and remove Husband's name on or before October 31, 2007. In the event Wife fails to refinance as stated, Wife shall immediately list the property for sale and sell the property. Wife shall be entitled to all sales proceeds from said sale. At the time of the refinancing and/or sale of the property, Husband shall sign a deed transferring sole title to Wife or to the buyer upon its sale. Pending the refinancing and/or sale of the property, Wife shall be solely responsible for all financial obligations as to the property, including but not limited to, the monthly mortgage payment, taxes and homeowners insurance as well as any and all other costs or expenses which in any way relate to the property. Wife hereby agrees to indemnify and hold Husband harmless from any and all default by Wife as to said financial obligations. 8. MARITAL DEBTS: Except as otherwise stated herein, any and all debts in Husband's name shall be Husband's sole and separate responsibility and any and all debts in Wife's name shall be Wife's sole and separate responsibility and each party hereby indemnifies and holds the other harmless from any default as to said debt responsibilities. 9. ALIMONY Husband and Wife agree that in consideration of the overall equitable distribution of property, including but not limited to, the distribution of the equity in the marital residence to Wife and the division of personal property and payment of marital debts, as stated in Paragraphs 7 and 8 herein, as well as other consideration as provided in this Agreement, Husband shall pay the amount of Seven Hundred ($700.00) Dollars per month to Wife in alimony for a period of two (2) years, from June 1, 2007 through May 1, 2009. Said amount and term of alimony are non-modifiable. The alimony shall otherwise terminate upon Husband's death or upon Wife's death, remarriage or cohabitation. 10. AFTER ACQUIRED PROPERTY: Each of the parties shall own and enjoy, independently of any claims or right of the other, all items of personal property, tangible or intangible, and/or real property, acquired by him or her, after the date of final separation, March 19, 2005, with full power in him or her to dispose of the same as fully and effectively, in all respect and for all purposes, as though he or she were unmarried. 4 11. WIFE'S DEBTS: Wife represents and warrants to Husband that since the date of final separation, on or about March 19, 2005, she has not contracted or incurred any debt or liability for which Husband or his estate might be responsible and Wife further represents and warrants to Husband that she will not contract or incur any debt or liability after the execution of this Agreement for which Husband or his estate might be responsible. Wife shall indemnify and save harmless Husband from any and all claims or demands made against Husband by reason of debts or obligations incurred by Wife. 12. HUSBAND'S DEBTS: Husband represents and warrants to Wife that since the date of final separation, on or about March 19, 2005, he has not contracted or incurred any debt or liability for which Wife or her estate might be responsible and Husband fuuther represents and warrants to Wife that he will not contract or incur any debt or liability after the execution of this Agreement for which Wife or her estate might be responsible. Husband shall indemnify and save harmless Wife from any and all claims or demands against Wife by reason of debts or obligations incurred by Husband. 13. PENSION AND RETIREMENT BENEFITS: Except as otherwise stated hereto, Husband and Wife agree to waive any and all past, present or future interest in any pension or retirement benefits of the other and neither party shall make any claim against the other's pension or retirement benefits, if any. 14. WAIVER OF RIGHTS: The parties hereto fully understand their rights under and pursuant to the Divorce Code, Act of 1980, as Amended February 12,1988, particularly the provisions for alimony, alimony pendente lite, spousal support, equitable distribution of marital property, attorney fees and expenses. Both parties agree that this Agreement shall conclusively provide for the distribution of property under the said law the parties hereby waive, release and forever relinquish any further rights they may respectively have against the other and their respective estates, for alimony, alimony pendente lite, spousal support, equitable distribution of marital property, attorney fees and expenses. 15. PERSONAL RIGHTS: Husband and Wife may and shall, at all times hereafter, live separate and apart. They shall be free from any control, restraint, interference or authority, direct or indirect, by the other in all respects as fully as if they were unmarried. They may reside at such place or places as they may select. Each may, for his or her separate use or benefit, engage in any business, occupation, profession or employment which to him or her may seem advisable. Husband and Wife shall not molest, harass, disturb or malign each other or the respective families of each other nor compel or attempt to compel the other to cohabitate or dwell by any means or in any manner whatsoever with him or her. 5 16. MUTUAL RELEASE: Except as otherwise stated hereto, Husband and Wife each hereby mutually remise, release, quitclaim and forever discharge the other and the estate of each other, for all time to come, and for all purposes whatsoever, of and from any and all rights, title and interests, or claims in or against the property (including income and gain from property hereafter accruing) of the other or against the estate of each other, of whatever nature and wheresoever situate, which he or she now has or may have at any time in the future. Except as otherwise stated hereto, Husband Wife each hereby mutually remise, release, quitclaim and forever discharge the other and the estate of the other as to any rights which either party may have or at any time hereafter have for past, present or future spousal support or maintenance, alimony, alimony pendente lite, spousal support, equitable distribution of marital attorney fees, costs or expenses, whether arising as a result of the marital relation or otherwise, except, and only except, all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provision thereof. It is the intention of Husband and Wife to give to each other and the estate of the other, by the execution of this Agreement a fiill, complete and general release with respect to any and all property of any kind or nature, real, personal or mixed, which the other now owns or may hereafter acquire, except and only except all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provision thereof. ITWAIVER OR MODIFICATION TO BE IN WRITING: A modification or waiver of any of the terms of this Agreement shall be effective only if in writing, signed by both parties and executed with the same formality as this Agreement. No waiver of any breach hereof or default hereunder shall be deemed a waiver of any subsequent default of the same or similar nature. 18. MUTUAL COOPERATION: Each party shall, at any time and from time to time hereafter, take any and all steps and execute, acknowledge and deliver to the other party, any and all future instruments and/or documents that the other party may reasonably require for that purpose of giving full force and effect to the provisions of this Agreement. 19. INTEGRATION: 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 than those expressly set forth herein. 6 20. AGREEMENT BINDING ON HEIRS: This Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective legatees, devises, heirs, executors, administrators, successors and assigns in the interest of the parties. 21.OTHER DOCUMENTATION: Wife and Husband covenant and agree that they will forthwith and within thirty (30) days after demand or due date, execute any and all written instruments, assignments, releases, satisfactions, deeds, notes, stock certificates, or such other writings as may be necessary or desirable for the proper effectuation of this Agreement, and as their respective counsel shall mutually agree, should be so executed in order to carry out fully and effectively the terms of this Agreement. 22. NO WAIVER OF DEFAULT: 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 subsequent default of the same or similar nature, nor shall it be construed as a waiver of strict performance of any other obligations herein. 23. BREACH: If either party breaches any provision of this Agreement, the other party shall have the rights, at his or her election, to sue in law or in equity to enforce any rights and remedies which the party may have, and the party breaching this Agreement shall be responsible for payment of attorney fees and all costs incurred by the other in enforcing his or her rights under this Agreement. 24. SEVERABILITY: If any term, condition, clause or provisions of this Agreement shall be determined or declared to be void or invalid in law or otherwise, then only that term, condition, clause or provision shall be stricken from this Agreement 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 his or her obligations under any one or more of the provisions herein, with the exception of the satisfaction of the conditions precedent, shall in no way avoid or alter the remaining obligations of the parties. 7 25. LAW OF PENNSYLVANIA APPLICABLE: This Agreement shall be construed in accordance with the laws of the Commonwealth of Pennsylvania. 26. HEADINGS NOT PART OF AGREEMENT: Any headings preceding the text of the several paragraphs/provisions 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. 27. DIVORCE Husband and Wife agree that their marriage is irretrievably broken and subsequent to the filing of the Complaint in divorce, both parties agree to enter into a mutual consent divorce under Section 3301(c) of the Pennsylvania Divorce Code of 1980, as amended February 12, 1988. The parties further agree to sign the necessary documents, including the Affidavit of Consent and Waiver of Notice, at such a time after ninety (90) days of the filing and service of the Complaint as either party may request. The parties further agree that this Agreement shall be incorporated, but shall not merge, into the final Decree in Divorce. IN WITNESS WHEREOF, the parties hereto, have set their hands and seals the day and year first above written. Witness: N L. MU Y ?r JOHN M. MURRAY COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF On this 2-may of %,.r , , 2007, before me, the subscriber, a Notary Public, in and for the said Commonwealth and County, came the above-named person, Karen L. Murray , satisfactorily proven to me to be the person whose name is subscribed to the within instrument and acknowledged that she executed the same for the purposes stated herein contained and that such instrument may be filed and/or recorded. my hand and Notarial seal. MY COMMISSION EXPIRES: COMMONWEALTH OF PENNSYLVANIA Notarial Seel Efin N. Hwvdan T w? CoirdY MY C?rrr?elon Expires Jan, 1A 2008 Member, Pennsylvania AssoolaNon of Notaries COMMONWEALTH OF PENNSYLVANIA ?a COUNTY OF W W g ie K-L- ? Ij- SS: On this S-77, day of <-'>?lt e-. , 2007, before me, the subscriber, Notary Public, in and for the said Commonwealth and County, came the above-named person, John M. Murray , satisfactorily proven to me to be the person whose name is subscribed to the within instrument and acknowledged that he executed the same for the purpose herein contained and that such instrument may be filed and/or recorded. WITNESS my hand d Notarial Seal. NOTARY PUBLIC MY COMMISSION EXPIRES: COMMONWBAL:r>i OF PLNW)Y', 'to No dal Seal James W. Abraham, Notary Public Camp Hill Boro, Cumberland County My Commission Expires Apr. 30, 2008 Member, Pennsylvania Assmiatlon of Notaries ?, ? n ...? _.- -- ? ?_ /^- CY'ti .??. ^_ .. '?t ? KAREN L. MURRAY : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2005 - 5479 JOHN M. MURRAY : CIVIL ACTION - LAW Defendant : DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on October 20, 2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of service and filing 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 the Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to the unworn falsification to authorities. DATE: Jun1 E 2007 P?A :6-5-07 JOHN M. MURRA fendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER SETION 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. I verify that the statements made in this Waiver are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to the unworn falsification to authorities. DATE: juv? 5 200^7 , ?- S- 07 qJO M. fendant rz Q C --' .-4 5 ? - tir C,n KAREN L. MURRAY, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2005 - 5479 JOHN M. MURRAY, CIVIL ACTION - LAW Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under § 3301(c) of the Divorce Code was filed on October 20, 2005. 2. The marriage of plaintiff and defendant is irretrievable 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. § 4904 relating to unsworn falsification to authorities. Date: '//'?P v KAREN L. t '? c3i KAREN L. MURRAY, Plaintiff V. JOHN M. MURRAY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2005 - 5479 CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(c) AND § 3301(d) 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. I verify that the statement 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: 02 7 KA&EN L. C - A J fem.., P i f _ i`l LAW OFFICES OF PETER J. RUSSO, P.C. SCOTT A. STEIN, ESQUIRE PA Supreme Court ID: 81738 3800 Market Street Camp Hill, PA 17011 (717) 591-1755 KAREN L. MURRAY, Plaintiff V. JOHN M. MURRAY, Defendant Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2005 - 5479 CIVIL ACTION - LAW 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 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Complaint served on counsel for Defendant James W. Abraham, Esquire, by first class mail January 10, 2006 . Acknowledgement of Service executed by the attorney for Defendant dated January 10, 2006. The original acknowledgement was filed by counsel on January 17, 2006 . 3. (a) Date of execution of the affidavit of consent required by § 3301(c) of the Divorce Code: by Plaintiff June 20, 2007 ; by Defendant June 5, 2007 . 4. Related claims pending: None 5. (b) Date plaintiff's Waiver of Notice was filed with the prothonotary: Jules 2007 . Date defendant's Waiver of Notice was filed with the prothonotary: July 03, 2007. Date: Respect lly submitted CottA. Stein C? C ev o ?; ? -rf s 4 71 '?lJ. ...1. X70 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. KAREN L. MURRAY, Plaintiff VERSUS JOHN M. MURRAY, Defendant No. 2005 - 5479 DECREE IN DIVORCE AND NOW, -S%)`?{ 1 , IT IS ORDERED AND KAREN L. MURRAY DECREED THAT AND JOHN M. MURRAY ARE DIVORCED FROM THE BONDS OF MATRIMONY. , PLAINTIFF, ,DEFENDANT, 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; PROTHONOTARY '' moy, ?`? '11 oil