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HomeMy WebLinkAbout05-6222 r , v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Docket No. (")S'-/.,,J).:1 Ciu~L I~ , Samantha Cammack, Plaintiff Scott D. Cammack, 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 reliefrequested 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 Dauphin County Courthouse, Front & Market Streets, Harrisburg, P A 17101. 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Dauphin County Bar Association Lawyer Referral Service 213 North Front Street Harrisburg, PA 17101 (717) 232-7536 r Samantha Cammack, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. Docket No. 05, (,";;;.2, Scott D. Cammack, Defendant CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(d) OF THE DIVORCE CODE AND NOW, comes Plaintiff, Samantha Cammack, by and through her attorney, Stephen O. Fugett, Esquire, who files this Complaint in Divorce under Sections 3301(c) ofthe Divorce Code, and who, in support thereof, avers as follows: 1. Plaintiff is Samantha Cammack, who currently resides at 835 Erford Road, Camp Hill, Cumberland County, Pennsylvania, ] 70 II, since 2000. 2. Defendant is Scott D. Cammack, who currently resides at 210 Senate A venue, Apartment 425, Camp Hill, Cumberland County, Pennsylvania, 1 70] I, since October, 2003. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on September 14, 2002 in Camp Hill, Cumberland County, Pennsylvania. 5. The parties separated in October, 2003 and have been living separate and apart since then. 6. There have been no prior actions of divorce or annulment between the parties. 7. The marriage is irretrievably broken. 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. Neither the Plaintiff nor the Defendant is in the military or naval service or in any branch of the armed forces of the United States of America or its allies or is ,. otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940 and its amendments. 10. Plaintiff requests the court to enter a decree of divorce. I verify that 1 have read the foregoing Complaint in Divorce and verify that the statements made therein are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. S 4904 relating to unsworn falsification to authorities. ~"a~ ~ Samantha Cammack, Plaintiff Respectfully submitted, Ste en O. Fugett, sq e P A Supreme Court ID No. 85643 240 South 18th Street Camp Hill, PA 17011 Telephone: (717) 737-2390 Facsimile; (717)763-4958 (:) .ta. ~ - "}:) "'F- ..0 t ~ C) . ,.<~ . U'\ { -\-l - & ()- ,.--'; --'J ~ 1.11 f! Vl I "v 1',1 -- . " g C~, r," _A; '-, "-...(. Samantha Cammack, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. Docket No. 05-6222 Civil Term Scott D. Cammack, Defendant CIVIL ACTION - LAW IN DIVORCE ACCEPTANCE OF SERVICE I hereby accept service of the Complaint In Divorce under 23 Pa.C.S. 9330I(d). I certify that I am authorized to accept service on behalf of the defendant. /!j-/;;Zr05 Date ~~w~ ~ott D. Cammack, Defendant Samantha Cammack, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. Docket No. 05-6222 Civil Term Scott D. Cammack, Defendant CIVIL ACTION - LAW IN DIVORCE NOTICE If you with to deny any of the statements set forth in this affidavit, you must file a counter-affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE I. The parties to this action separated on October 1, 2003 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 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. I verity that the statements made in this affidavit are tme and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 94904 relating to unsworn falsification to authorities. Date: 1,~- /-;; -!)S \, .:::):llnlibctkO. On'l)\' Y,U1C'l\2 Samantha Cammack, Plaintiff ....., C;l <;.::;;:;. c.,., Cl ", " N c' -f1 ...... I~ rn--'..J- r- -yr2 ,.1....--1 ~-~(:} .,...:--1< -";j :rJ ..(") (jrr1 ,--l ]:... "'LJ :.:<: -":J 't? c, c:' Samantha Cammack, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. Docket No. 05-6222 Civil Term Scott D. Cammack, Defendant CIVIL ACTION - LAW IN DIVORCE PLAINTIFF'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(d) OF THE DIVORCE CODE I. 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, attorney's fees and expenses in do not claim them beti)re a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true aad 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: Id" IJ 05 '-- /)(il, 'Y71CU ,,,-\REI ([JC\'YRY\<.Cl(' ~( Samantha Cammack, Plaintiff ,...., c::.., 1:::;;J. C.....-! o ., -l ~:o r-- -:--RfT'i _.....0 ~2(~) ...- ~1~: --;:;"1-; ~,~~ (") ,:5n1 -.4 2;; ::< C'J p'j " 1'V -0 ::;:';: G:? c:') C-' Samantha Cammack, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. Docket No. 05-6222 Civil Term Scott D. Cammack, Defendant CNIL ACTION - LAW IN DIVORCE DEFENDANT'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(d) OF THE DIVORCE CODE I. 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, attorney's fees and expenses if! do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. S 4904 relating to unsworn falsification to authorities. Date: /). -/cl-' {};- vW~9~ -6( VScott D. Cammack, Defendant ....., c::.:~~ ,= c.n o {""'.q C-, N o " ::::l 01:0 ,- -afT! ;:3'6 -,-1': '.:;:'"i1 c{.c') ~^"m , ) ,-I ~> ,U -< :s ...;..> ~? o 0', Samantha Cammack, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. Docket No. 05-6222 Civil Term Scott D. Cammack, Defendant CNIL ACTION - LAW IN DNORCE Certificate of Service I hereby certify that I did, on December 12, 2005, serve a true and correct copy of Plaintiffs Affidavit Under S 3301(d) ofthe Divorce code upon the persons listed in the manner indicated: SERVICE BY HAND DELIVERY: Scott D. Cammack, Defendant s~ n O. FUgett~ Es Attomey for Plaintiff Date: r/VIOG ~::- c,'-' (,..J C:) C"J -.'1 " THIS AGREEMENT made this I) i) day of 'J:::e CN;4/j,Ju( 200 s:- by and OOPY between Samantha Cammack, of 835 Erford Road, Camp Hill, Cumberland County, Commonwealth of Pennsylvania, 17011, hereinafter referred to as "Wife," and, Scott D. Cammack, of210 Senate Avenue, Apartment 425, Camp Hill, Cumberland County, Commonwealth of Pennsylvania, 17011, hereinafter referred to as "Husband." WIT NE S SETH: WHEREAS, the parties hereto were duly married to each other on September 14, 2002 in Camp Hill, Cumberland County, Commonwealth of Pennsylvania. WHEREAS, it is the intention of the parties to enter into an Agreement under which their respective financial and property rights, and an other respective rights, remedies, privileges and obligations to each other arising out ofthe marriage relation, or otherwise, including those rights over which the Court retained jurisdiction, will be fully prescribed and bounded thereby; and WHEREAS, the parties hereto have been fully, separately, and independently apprised and advised of their legal rights, remedies, privileges, and obligations arising out of the marriage relationship, or otherwise, by counsel of their own choice and selection, to the extent each has deemed necessary and appropriate. WHEREAS, both parties have made independent inquiry and investigation with respect to their respective legal rights, remedies, privileges and obligations, arising out of the marriage, or otherwise, and each has been fully informed of the other's assets, property, holdings, income and prospects; and I . . WHEREAS, the parties hereto each warrant and represent to the other that they each fully understand all the terms, covenants, conditions, provisions, and obligations incumbent upon each of them by virtue ofthis Agreement to be performed or contemplated by each of them hereunder, and each believes the same to be fair, just, reasonable and to the respective individual best interest of each, and not the result of any fraud, duress, or undue influence exercised by either party upon the other or by any other person or persons upon either; WHEREAS, the parties hereto both agree that this agreement shall remain in full force and effect even upon the Parties' reconciliation unless a written change is made. NOW THEREFORE, the recitals set forth hereinabove, being incorporated by reference herein, and deemed an essential part hereof, and further consideration of the promises contained within this Agreement, the parties hereto intending to be legally bound, mutually agree as follows: 1. PERSONAL RIGHTS: Wife and Husband may and will, at all times hereafter, live separate and apart. Each will be free from all control, restraint, interference or authority, direct or indirect, by the other in all respects as fully as if she or he were unmarried. Each may reside at such place or places as she or he may select. Each may, for her or his separate use or benefit, conduct, carryon and engage in any business, occupation, profession or employment which to her or him may seem advisable. This provision will not be taken, however, to be an admission on the part of either Wife or Husband ofthe lawfulness ofthe causes which led to, or resulted in the continuation 2 of, their living apart, Wife and Husband will not molest, harass, disturb, or malign each other or their respective families of each other, nor compel or attempt to compel the other to cohabit or dwell by any means or in any manner whatsoever with her or him. 2. FULL DISCLOSURE; The parties hereby acknowledge and agree that each of them has made to the other a true, full, complete disclosure of all property and interests which either or both of them have in all marital and separate property as defined by the Pennsylvania Divorce Code and they do hereby waive an inventory of said property. The parties further acknowledge and agree that they have each had an opportunity to value or have appraised any and all marital property, and they do hereby waive a formal appraisal of same, and no statement or representation by either party as to value will be deemed a misstatement or misrepresentation to the other or be deemed fraudulent. Both the legal and practical effect of this Agreement in each and every respect and the financial status of the parties has been fully explained to both parties by their respective counsel, and they both acknowledge that this Agreement is reasonable and that it is not the result of any fraud, duress, or undue influence exercised by either party upon the other or by any other person or persons upon either. 3. MUTUAL RELEASE: Wife and Husband each do hereby mutually remise, release, quit claim 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, titles, and interests, or claims in or against the property (including income and gain from property 3 hereafter accruing) of the other or against the estate of each other, of whatsoever nature and wheresoever situate, which she or he now has or at any time hereafter may have against each other, the estate of each other or any part thereof, whether arising out of any former acts, contracts, engagements or liabilities of each other or by way of dower or curtesy, or claims in the nature of dower or curtesy of widow's or widower's rights, family exemption or similar allowance, or under the intestate laws, or the right to take against the other's will; or the right to treat a lifetime conveyance by the other as testamentary, or all other rights of a surviving spouse to participate in a deceased spouse's estate, whether arising under the laws of (a) Pennsylvania (b) any State, Commonwealth or Temtory ofthe United States, or (c) any other country, or the right which both parties may have or at any time hereafter have for past, present, or future spousal support or maintenance, alimony, alimony pendente lite, 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 part thereof. It is the intention of Wife and Husband to give to each other by the execution of the Agreement a full, 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 part thereof, subject, however, to the implementation and satisfaction of the conditions precedent as set forth herein. 4. DEBTS: Both parties represent and warrant to the other party that they have not incurred any debts to which the other, or the estate of the other may be held liable 4 since the date of separation or the date of filing of the Divorce Complaint except as provided herein, and that except only for the rights arising out oftrns Agreement, neither party will hereafter incur any liability whatsoever for which the other party nor the estate of the other party will be liable. Husband and Wife agree that should any debt or liability be incurred by one party, that party acknowledges that such debt is the sole responsibility of the person who incurred that debt and any and all claims made against the other on account of such debt may be deducted from the share to which the person incurring the debt is entitled as the result of this Agreement. The parties acknowledge and warrant that no marital debt exists. 5. PERSONAL PROPERTY: Husband and Wife each will continue to own and enjoy, free of any claim or right of the other, all of his or her personal effects, such as clothing, jewelry, and the like, wherever located. The parties have mutually agreed on the division of their household goods, furnishings and furniture. Husband agrees that all property in the possession of Wife will be the sole and separate property of Wife. Wife agrees that all property in the possession of Husband will be the sole and separate property of Husband. The parties hereby relinquish any and all right or claim to such articles chosen by the other. Henceforth, each of them will own, have and enjoy independently of any claim or right of the other, all items of personal property of every kind, now and hereafter owned, 5 or held by him or her, with full power to dispose of same as fully and effectively in all respects and for all purposes as ifhe or she were unmarried. 6. REAL ESTATE: The parties hereby acknowledge that no real property was by them purchased, either individually or jointly or as tenants by the entireties. 7. APPLICABILITY OF TAX LAW TO PROPERTY TRANSFERS: The parties hereby agree and express their intent that any transfers of property pursuant to this Agreement will be within the scope and applicability of the Deficit Reduction Act of 1984 (herein the "Act"), as amended, specifically, the provisions of said Act pertaining to transfers of property between spouses or former spouses. The parties agree to sign and cause to be filed any elections or other documents required by the Internal Revenue Service to render the act applicable to the transfers set forth in this Agreement, without recognition of gain on such transfers and subject to the carry-over basis provisions of said Act. 8. FINANCIAL ACCOUNTS/AUTOMOBILES: Husband and Wife have already divided all, if any, bank checking and savings accounts, life insurance policies, financial instruments and accounts, certificates of deposit, cash, stocks, bonds, and accounts to the parties' satisfactions. Each party will retain sole ownership of all financial instruments and accounts currently in their possessions. Each party will pay and assume any loans on any vehicle(s) currently in his/her possessIOn. 6 9. TAXES: The parties agree and acknowledge that prior to the last full calendar year, the parties jointly filed Returns for Federal and State income tax purposes. The parties agree that they will file separate future Tax Returns for all tax obligations, and any tax obligation will be the responsibility of the individual party. Husband and Wife warrant that they have heretofore paid aJl taxes on such prior Returns including the calendar year ending December 31, 200_; that they do not owe any interest or penalties thereon; and that no tax deficiency proceeding or audit is pending or notice thereof received. Husband will give Wife notice of any deficiency assessment. Wife will give Husband notice of any deficiency assessment of which they individuaJly or coJlectively become aware. The parties agree that should it ultimately be determined that any deficiency and/or penalty exist with respect to the jointly filed returns, the party responsible for the erroneous preparation and/or improper or nondisclosure of information which has resulted in the deficiency and/or penalty, wiJl be solely responsible for the payment of the amount ultimately determined to be due, together with interest, as well as expenses that may be incurred to contest the assessment. Should said surns become due as a result of individually filed returns, the party which filed said return will be solely responsible for all sums due, and will indemnify and hold harmless the other party for any payment thereon. 10. CHILD CUSTODY: No children were born of the relationship between Wife and Husband 7 11. PENSIONS, RETIREMENT. AND PROFIT SHARING PLANS: The parties will retain as their sole property any interest and each spouse waives any interest in all of each others Pensions, Retirement, and Profit Sharing Plans, or the like, which the parties now own or may own in the future. Both parties will promptly sign all required papers to release any interest they may have acquired. 12. WAIVER OF RIGHTS: The parties waive all other past, present and future rights provided in the 1980 Divorce Code, as amended, or any future laws and amendments including their right to alimony, spouse support, equitable distribution, alimony pendente lite, costs and expenses, and attorney's fees, except as otherwise provided herein. 13. EOUITABLE DISTRIBUTION - GENERAL CONSIDERATIONS: The parties have attempted to distribute their marital property in a manner which conforms to the criteria set forth in Section 3502(a) of the Pennsylvania Divorce Code, and taking into account the following consideration: the length ofthe marriage; the age, health, station, amount and sources of income; contribution of each party; the opportunity of each party for future acquisitions of capital assets and income; the sources of income of both parties, including but not limited to medical, retirement, insurance or other benefits; the contribution or dissipation of each property, including the contribution of each spouse as a homemaker; the value of the property set apart to each party; the standard of living of the parties established during the marriage; and the economic circumstances of each party at the time the division of property is to become effective. 8 14. SUCCESSORS' RIGHTS AND LIABILITIES: This Agreement will, except as otherwise provided herein, be binding upon and inure to the benefit ofthe parties hereto, their respective heirs, executors, administrators, successors or assigns. 15. ENTIRE AGREEMENT: Wife and Husband do hereby covenant and warrant that this Agreement contains all of the representations, promises, and agreements made by either of them to the other for the purposes set forth in the preamble hereinabove; that there are no claims, promises, or representations not herein contained, either oral or written, which will or may be charged or enforced or enforceable unless reduced to writing and signed by both ofthe parties hereto; and the waiver of any term, condition, clause or provision of this Agreement will in no way be deemed to be considered a waiver of any other terms, conditions, clauses or provisions of this Agreement. 16. ADDITIONAL INSTRUMENTS: The Husband and Wife will, at any and all times, upon request by the other party of his or her legal representatives, make, execute, and deliver any and all such other and further instruments, Deeds, notes, releases, car titles, tax forms, insurance forms, or such other writings as may be necessary or desirable for the purpose of giving full force and effect to the provisions of this Agreement and as their respective counsel will mutually agree should be executed in order to fulfill promptly the terms of this Agreement. 17. GOVERNING LAW: All matters affecting the interpretations of this Agreement and the rights ofthe parties hereto will be governed by the laws of the Commonwealth of Pennsylvania. 9 18. INDEMNIFICATION UPON BREACH: If for any reason either the Husband or the Wife fails to perform his or her obligations hereunder to the other spouse, and the other spouse incurs any expense thereby (including but not limited to legal fees) in enforcing his or her rights, the spouse who failed to perform the obligations agrees to reimburse and indemnify the other spouse and hold him or her harmless for any and all such expenses. Each party hereby agrees to pay all attorney's fees and costs of litigation that the other spouse may sustain or incur in any way whatsoever as a consequence of any default or breach by the other spouse of any of the terms or provisions of this Agreement; provided that the party who seeks to recover such attorney's fees, and costs of litigation must first be successful in whole or in part, before such liability may be imposed. It is the specific agreement and intent of the parties that the breaching or wrongdoing party will bear the burden and obligation of any and all costs and expenses and counsel fees incurred by him or herself as well as the other party in endeavoring to protect and enforce his or her rights under this Agreement. 19. INDEPENDENT COVENANTS: Each of the respective rights and obligations of the parties hereunder will be deemed independent and may be enforced independently irrespective of any ofthe other rights, and obligations set forth herein. In case any provision ofthis Agreement should be held to be contrary to, or invalid under, the law of any country, state or other jurisdiction that is applicable to this Agreement, such illegality or invalidity will not affect in any way other provisions hereto, 10 all of which will continue, nevertheless, in full force and effect under the law of the country, state, or other jurisdiction that is applicable to this Agreement. 20. NO MERGER IN DIVORCE DECREE: In the event that either of the parties shall recover a final judgment or decree of absolute divorce against the other in a court of competent jurisdiction, the provisions of the Agreement may be incorporated by reference or in substance but will not be deemed merged into such judgment or decree of absolute divorce and will be entirely independent thereof. 21. SUBSEQUENT DIVORCE: There is pending between the parties and action for divorce instituted in the Court of Common Pleas of Cumberland County, Pennsylvania. The Husband and Wife agree that their marriage is irretrievably broken and that the same will be dissolved pursuant to Section 3301(d)(I) of the Divorce Code of Pennsylvania. The parties therefore agree as follows, TO WIT: A. Wife will file with said court an Affidavit Under Section 3301(d)(1) of the Divorce Code within seven (7) days of the signing of this Agreement; B. Unless either party will have requested counseling prior to the filing of said Affidavit of Consent, the right to request such counseling will be deemed waived; C. The Court of Conunon Pleas of Cumberland County, Pennsylvania will retain jurisdiction over the parties and causes of action resolved herein. 11 IN WITNESS WHEREOF, I have hereunto willingly and voluntarily set my hand and seal to this AGREEMENT, this ~ day of 0 r(!f)?JtY'fl, 2005. ~L~/ (SEAL) IN WITNESS WHEREOF, I have hereunto willingly and voluntarily set my hand and seal to this AGREEMENT, this tJ-b~day of~<JJ0~-< ,2005. " ~~"'~~C!\t: Samantha Cammack (Wife) (SEAL) Signed, sealed and executed by Scott D. Cammack and Samantha Cammack, above-named Husband and Wife, respectively, in the presence of us, who, at their request an in eir presence and at the same time, have hereunto subscribed our names as w' es es. [M [) ~+ri~ Name 5111 frJ41"k [(>'It C..J-. Address Signature of Witness !I1cJ1/;'M'O ~ &J City State no~- Zip --=/&,{r) ;JI /J1cR~rnd'/? ~ ? Name ";)"8"~O U/l7/yrlcmtP 2/t/~, Address ~ ,,";i.~; (?/-l- City State /?fJ/ I Zip 12 ACKNOWLEDGEMENT COMMONWEALTH OF PENNSYLVANIA SS. COUNTY OF CUMBERLAND I, Scott D. Cammack, hereinbefore named Husband, having been duly qualified according to law, do hereby acknowledge that I signed and executed the foregoing AGREEMENT and that I signed it freely, willi Iy and ~ary. -~~ oU . Cammack (Husband) On this, the I f2.. day of P reE /#"?r rr:::[8005, before me, the undersigned officer, personally appeared " <)u-i-/ b, (l tLrnff'''- ct-. , known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he executed same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official ea. No.TARIAL SEAL PATRICIA D HESSON Notory Public (SIOIn:bf CAMP HILL N t P bl ,__-._CUMBERlANDCOUNTY o ary u ic My Commission Expires feb 26, 2008 ACKNOWLEDGEMENT COMMONWEALTH OF PENNSYLVANIA SS. COUNTY OF CUMBERLAND I, Samantha Cammack, hereinbefore named Wife, having been duly qualified according to law, do hereby acknowledge that I signed and executed the foregoing AGREEMENT and that I signed it freely, willingly and voluntary. ~'clw<P.o..~~\;? Samantha Cammack (Wife) On this, the 1'y-1 day of ~~ , 2005, before me, the undersigned officer, personally appeared 0IJJY\()-""-h4-- UfY".-rNl.. c I:...J ,known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he executed same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. ~')~ J!J . ~ (SEAL) Notary Public 13 ARIAl PATRICIA 0 HESSON Notary Public CITY OF CAMP Hill ", CUMBERlAND COUNTY My Commission EXpires Feb 26. 2008 .. AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA SS. COUNTY OF CUMBERLAND fY'L 0 p..fYldL We, and -J-e>-4n ~/ mL~ elm ~ ~he witnesses whose names are signed to the attached or foregoing instrument, being duly qualified according to law, do depose and say: that we were present and saw the parties sign and execute the foregoing AGREEMENT; that they both signed willingly and executed the AGREEMENT as their free and voluntary act for the purposes therein expressed; that each subscribing witness in the hearing and sight of the parties signed the AGREEMENT as a witness; and that, to the best of our knowledge, the parties were each at that time 18 or more years of age, of so 'O'C" 000""",,,,", ~'"O 'nnurnoo s sE;nc~ ' ,'-----' ~ Sworn to or affirmed and subscribed to before me by hie. 0, PtL-n-;lK , and .JoN) tf. jA~d~ RL , witnesses, this 1<2~ dayof '--w.ttnl b;...r ,2005 \jJ~ ~ . J1/.lM>0 Notary Public TARtAL AL PATRICIA D HESSON Notary Public CItY OF CAMP HILL CUMBERlAND COUNtY COlTll'l\llllOO Expkes Feb 26. 2008 14 ~------- C) c_ r-') () --n ::;! 1-~-:t7j , '.- - l.' ~ - Samantha Cammack, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. Docket No. 05-6222 Civil Term Scott D. Cammack, Defendant CNIL ACTION - LAW IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Please transmit the record, together with the following information, to the Court for the entry of a divorce decree: I. Grounds for divorce: irretrievable breakdown under ~3301(d)(l) ofthe Divorce Code. 2. Date and manner of service ofthe complaint: December 12,2005, in person. 3. Date of execution of the affidavit required by ~ 3301(d) of the Divorce Code: December 12, 2005, Date of filing and service of the plaintiffs affidavit upon the respondent: December 12, 2005. 4. Related claims pending: None. 5. Date Plaintiffs Waiver of Notice ofIntention to Request Entry of Divorce Decree was filed with the prothonotary: December 21,2005. Date Defendant's Waiver of Notice of Intention to Request Entry of Divorce Decree was filed with the prothonotary: December 21, 2005. ,;> Date: ;I V;;.:{ r', t.,,! C. ,,~) ,::--" r:-:; c.>' \"J -j'1 c " 1-' (T" .< +.'+' '+',t' ,t' . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . + . . . . + . + . + . + . . + . . . . . . . . + . . . . . . . . . . . . . . . + + + + + + . + + + + + + + + + + + + + + + :+',+:+,,+,+. + '+::ti:ti:t' :t':t''+:O+; ,.; :+; :t' + . .. :t':ti:t':ti '+::f. + Of.:+: ~~~:+::+:++.+:+::+;'+::+'+++:+'++:+'+:+'++ + . . . . . . . IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA. SAMANTHA CAMMACK, Plaintiff No. 05-6222 VERSUS SCOTT D. CAMMACK, Defendant DECREE IN DIVORCE AND NOW, 1o..V\vll.'l''i 1.."\ , ).()()fo, tT IS ORDERED AND DECREED THAT Samantha Cammack , PLAINTIFF, AND Scott D. Cammack , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD tN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; It is further ORDERED and DECREED that the AGREEMENT executed by and between the parties, dated December 12, 2005, is incorporated by reference into this Decree for the purpose of enforcement, but shall not be deemed to have been merged with this Decree. ~~.$-~"'''' By THE COURT: ATIm!!. . ~ !!.k . ~ ~ PROTHONOTARY :t::+:Of.'+: +'+''1' :+' +0+; 0+;'1' '+: +'I'+'I':+':t''I':+'++'I'+:+'++:+: '1'+'+'++:+:'1' + . . . . . . . . . . . . . . + + . . . . . J. . + . . . . . + . . . . . . . . + . . . . . . . + . . . . . . + + . . + . . . . . + . . . + + + . . + + . . . . . . + . , . . + . . + + . . . + .H ( /~rifO~ -:rrt;J 7~ /~ ~J) '~;7 .;z r~~ r~o/t, '7(7.It'LI ~ .~, /lF~: ~<?r? --;0' he '/ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ,--CSQvY\Q.Vy-\-hR CommG(il-< Plaintiff Vs Sco+t D. Comma<!\<, Defendant FileNo. ro.6 - G, d;;)~ IN DIVORCE (") ~ 0 c: <.-::;:) -n :;;,,~ 0.... ~Jli~ ::n: -----4 [PL(l ~ ffl:n Z;'S =Be:; ~;: t.' en ":2 (~ .,:;:::- > :;:::",. c: :J: S2B _ prior to the, entry of a Final Decree in Divorce, ;; [~; '!? ,c:?, en or 'L after the entry ofaFinal Decree in Divorce dated,-=so.nuo ,.~ ~ ~1)D~ hereby elects to resume the prior surname of ~ \1' n ~ ' and gives this written notice avowing his / her intention pursuant to the provisions of 54 P.S. 704. Date: 3//1o/()~ \. ~nlW~ CDF)V..,v~Q\e , Signature NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff / defendant in the above matter, [select one by marking "x"] ~ 'h\)>c~~ ~ t ~~ Signature of name being res e COMMONWEALTH OF PENNSYLVANIA ) COUNTYOF C<>.",J,-<r/a.d ) On the J fo11> day of )r) ~ , 200 J:, before me, the Prothonotary or fhe notary public, personally appeared the above affiant lmown to me to be the person whose name is subscribed to the within document and acknowledged that he / she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand hereunto set my hand and official seal. ~~ c~:ru' rothonotary or Notary lie tlDlAAIAI. SiAL c.... _~ WTAIIYPIlIUll ""~ l:OllN1Y c:otJImtDtJsr MY COMMI88lON fIflRaqARY Ill~o