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HomeMy WebLinkAbout05-6326 4) Jeffrey B. Engle, Esquire SHAFFER & ENGLE LAW OFFICES 129 Market Street Millersburg, PA 17061 Phone: 717-692-2345 Fax: 717-692-3554 vs, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO, OS - ~3:</p Cto;L <-r8zxvl, KENDRA C. JUMPER, Plaintiff CURTIS A. JUMPER, 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 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 at the Dauphin County Courthouse, Front and 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 Telephone: (800) 990-9108 ... A VISO USTED HA SIDO DEMANDADO/A EN CORTE, Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas, debe tomar accion dentro de IDS proximos veinte (20) dias despues de la notificacion de esta Demancta y A visa radicando personalmente 0 por media de un abogado una comparecenia escrita y radicando en la Corte por escrito sus defensas de, y ojecciones a, las demandas presentadas aqui en contra suya. Se Ie advierte de que si usted falIa de tomar accion como se describe anteriormente, el caso puede proceder sin listed y un fallo por cualquier suma de dinero reclernada en la demanda 0 cualquier otra reclamacion 0 remedio solicitado por eI demandante puede seT dictado en contra suya por la Corte sin mas aviso adicional. U sted puede perder dinero 0 propiedad u otros derechos importantes para usted, USTED DEBE LLEV AR ESTE DOCUMENTO A SU ABOGADO INMEDIATEMNTE, SI USTED NO TIENE UN ABOGADO, LLAME 0 VA Y A A LA SIGUlENTE OFlCINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERA DE COMO CONSEGUlR UN ABOGADO. SI USTED NO PUEDE PAGER POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTE OFICINA LE PUEDE PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVIClOS LEGALES SIN CARGO 0 BAJO COSTO A PERSONAS QUE CUALIFICAN, CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty A venue Carlisle, PA 17013 Telephone: (800) 990-9108 ... KENDRA C. JUMPER, Plaintiff vs, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO, OS- l.3~b C.;o~LY~ : CIVIL ACTION - LAW : IN DIVORCE CURTIS A, JUMPER, Defendant COMPLAINT SECTION 3301(C) DIVORCE 1. Plaintiff is KENDRA C. JUMPER, an adult individual currently residing at 658 Hillcrest Drive, Carlisle, Cumberland County, Pennsylvania, 2, Defendant is CURTIS A, JUMPER, an adult individual currently residing at 658 Hillcrest Drive, Carlisle, Cumberland County, Pennsylvania, 3, Plaintiff has been a bona fide resident in the Commonwealth of Pennsylvania for at least six (6) months immediately prior to the filing of this Complaint. 4, Plaintiff and defendant were married on June 6, 1992, m Boiling Springs, Pennsylvania, 5, Plaintiff avers that there has been no prior action for divorce or annulment of marriage by the parties in this or any other jurisdiction, 6, The marriage is irretrievably broken, 7, Plaintiff avers that she has been advised of the availability of counseling and that she may have the right to request that the Court require the parties to paJticipate in counseling, 8, Plaintiff avers that the Defendant is not in the Military or Naval Service of the United States or its allies or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of 1940, as amended, WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce, Respectfully submitted, SHAFFER & ENGLE LAW OFFICES DATED: Iztk , I ~ VERIFICATION I verify that the averments in this Complaint for Divorce 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: I,;) ~. ~ - Cf~ , ..to ~~~ - :c Vi ~~~ ~ ~ -1- [<1 .~_. Q -n \ KENDRA C, JUMPER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs, : NO, 05-6326 Civil Term CURTIS A. JUMPER, Defendant : CIVIL ACTION - LAW : IN DIVORCE ACCEPTANCE OF SERVICE TO THE PROTHONOTARY: I hereby accept service of the Divorce Complaint filed at the above-captioned docket on behalf of my client, Curtis A. Jumper. Date: 11 19 !O~ By: ~ C<L3..v 0 - Robert L. O'Brien, Esquire 19 West South Street Carlisle,PA 17013 Attorney for Defendant 9 "" C) C'::) 0<::-;:;::> 'T1 <.,;:.J"" c..... --t ~. :~: ;n ! .j7' =E::~ .- ..',-, I''':> KENDRA C, JUMPER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs, :NO, 05-6326 Civil Term CURTIS A. JUMPER, Defendant : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF COUNSELING ], A Complaint in Divorce under Section 330 I ( c) of the Divorce Complaint was filed on December 12,2005, .., ~. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3, I consent to the entry of a final decree in divorce after service of Notice of Intention to Request Entry of the Decree, 4, 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, Being so advised, I do not request that my spouse and I participate in counseling prior to a Decree in Divorce being handed down by the Court, DATE: C!/ltt~ J j ./' 1) c c., l: . i ~{f'- .. tcJ'Y~)/C"L Kendra C, Jumper, Plaintiff .~. ,,-,r: KENDRA C, JUMPER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA vs, :NO, 05-6326 Civil Term CURTIS A. JUMPER, Defendant : CIVIL ACTION - LAW : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER &3301(c) 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, 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 affidavit are true 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, f; 'I ';rl.<C-w~ V ~ '- Kendra C, Jumper, Plaintif SS# 184-48-9956 DATE: zJ- / / -D{." " KENDRA C. mMPER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 05-6326 Civil Term CURTIS A. mMPER, Defendant : CIVIL ACTION - LA W : IN DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF COUNSELING 1. A Complaint in Divorce under Section 3301(c) of the Divorce Complaint was filed on December 12,2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree in divorce after service of Notice of Intention to Request Entry of the Decree. 4. 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. Being so advised, I do not request that my spouse and I participate in counseling prior to a Decree in Divorce being handed down by the Court. DATE: d;tJ /0 6 ./ ~d'~ Curtis A. Jumper, I)eWndan f~ C~ r-....~~) (.:::::l G::J c::r- > """"-:j ;:;:; N -..l c> -n ~~;.;, --,.... " . S'? o C;t', KENDRA C. JUMPER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 05-6326 Civil Term CURTIS A. JUMPER, Defendant : CIVIL ACTION - LAW : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 63301(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 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. ~/9.~ Curtis A. Jumper, Def{ndant SS# 202-46-6269 DATE: y/;;../ /06 , / p ~~". r--.> i"=':::> C:::) c""\. () -'1'1 ~'" '., :;'~J r', -.J c..:; o en Nov 22 05 09:14a NAVICF MECH 05835 717-605-3494 p.2 10128/2005 10:1& 7172495755 DES PAGE 01 MARRIAGE SETTLEMENT AGREEMENT THIS AGREEME:NT. made thiS..L. day of AI tV, , 2005, by and " between Curtis A, Jumper, hereinafter caNed Husband, llnd Kendra C. Jumper, hereinafter called Wife; WITNESSETH: WHEREAS, Husband and Wife were lawfully married on June 6,1992; and WHEREAS, difl'erencss have arisen between Husband and Wife In consequence of which they hElve determined to live separate and apart from each other and have consented t<;) a mutual consent dlvorcej and WHEREAS, HUllbilnd and Wife desire \0 settle and determine their rights and obligations, including Ilhe settling of their property rights and other rights and obligations growing out of their mllrr1age in accordance with the provisions of the Divorce Code of Pennsylvania, NOW, THERE~=ORE, the parties, intending to be legally bound hereby, agree as follows: 1. Sellaratlon, It shan be lawful for each party at alf limes hereafter 10 live separate and apart from the other al such place ashe or she may from time to time choose or deem fit, 1"I1e foregoing provision shall not be taken as admission on the part of either party of the lawfulne!lS or unlawfulness of the causes leading to them living ---apart. Each-partY-!jhllll1lefree-from;nterference;-authority-and .controt;-direct or.- ---- Indirect, by the other as fully as If he or she were single and unmarried. Neither shall 1 Nov 22 05 09:15a NAVICP MECH 05835 l~/~Mll~~O l~:lb 11 (:lQYb (b~ U~:; 717-605-3494 !"AUt. ~:l p.3 molest the other or compel or endeavor to compel the other to cohabit or dwell with him or her, 2. Division of PlroDertv and Joint Debt. The parties have divided between them, the personal effects, tcols, equipment, household furniture and furnishings, and other articles of personal prt:'perty which have heretofore been used by them, Individually or In common, The IlernE; listed on Schedule A are Husband's property and shall be removed by the Husbalnd within 60 days of the date of thts agreement. The parties' residence located at 668 Hillcrest Drive, Carlisle, Pennsylvania, shall become the sole and separate property of Wife. The parties agree that the home is worth $200.000 as determined by a recel'lt appraisal. Wife will refinanc;:e the home and pay Husband one half of the equity in h! home at the time of refinancing. The only lien against the value of the home Is a morllilage to Dollar Bank, which will be paid off at the time of refinancing. Husband shall tender to Wife a Special Warranty Deed. prepared by Husband, transferring his interest in the home to Wife at the time of Ille refinancing, Within 60 days of the date of this agreement Husband agrees to vacate the marital residence. Each party sh~11I retain the vehicle they currently drive and make arrangements within sixty days to rennance any vehicle financing if the other party is responsible on the loan. The parties will also cooperate in transferring IIny ownership interest in the --other partyirvehlc1!':'--.-- --- ..-- ..,-----.- .---- 2 Nov 22 05 09:15a NAVrC? MECH 05835 717-605-3494 The Member~: First account shall be equally divided, Wife shall retain the Postmark Credit Uni-:>n account that is in her name, Wife shall act as custodian of thc records for the college tuition account that is set up for Kanlerin and shall furnish copies to Husband when he requests them, Both parties agree to contribute at least $1200.00 annually to Kamerin's college tuition account and to equally share the actual cost of Kamerin's post secondary education, including tuition and expenses, not covered by the college tuition account. Husband shall act as custodian of his son Scott's tuition account, The parties agree to me a joint income tax return for 2005 and equally share any expense or savings, Husband shall retain his life insurance policy with State Fann Insurance and each pany shall retain their perspective term life insurance policies. Each party shall retain his/her pension/retirement accounts and they agree that they will each sign any documentation reasonably requested to release and extinguish any interest that they may have in the other's account(s). 3. Alimony and SDousal SUDDort. Neither party will pay alimony and/or spousal support to the otht;,r. 4. Debts, The parties agree that there are no marital debts other than the home mOltgage. Except for the debts and obligations created hereunder, each pany agrees to pay and hereby agrees to hold the other harmless from any and all personal debts and obligations incurred by him or her prior to or subsequent to the date or separation, If any claim, action or proceeding is hereafter brought seeking to hold the other party liable on account of such debts or obligations, each party will at his or her sole expense defend the other party against any such claim, action or proceedings, whether or not 3 p.4 -") t. 0'1 ." 'J- 'A') II 1\" Nov 22 05 09:15a NAVICP MECH 05835 18/28/2885 18:16 7172Q9S'/55 DES 717-605-3494 PAGE 03 p.5 well-founded, and indemnify the other party against any loss or liability resulting therefrom. 5. Eauitl!lble Prooertv. this Agreement constitutes an equitable division of the parties' marital property. The parties have determined thallhe division of this property oonforms with regard to the rights of each party. The dIVision of existing marital property is not intended by the parties to constitute in any way a sale or exchange of assets, and the division Is being effectuated without the introduction of outside funds or other property not constituting the matrimonial estate. Each party hern!by acknowledges that this Agreement adequately provides for his or her needs and is in his or her best Interest, and that the agreement is not the result of any fraud or undue Influence exercised by either party upon the other or by any other person or persons upon either party. Both parties hereby waive the fOllOwing procedural rights: A. The right to obtain an Inventory and appraisement of all marital and separate property as defined by the Pennsylvania Divorce Code. B. rhe right to obtain an income and expense statement of the other party as provided by ~he Pennsylvania Divorce Code. C. "I!'he right to have the court determine which properly is marital Bnd which in non-marital, and equitably distrlbute between the parties that property which the courtaetermlnes 'toDe marltal.~--'u --- ----.------- .--- 4 Nav 22 05 09:16a NAVICP MECH 05835 16/28/2665 16:1& 71 nQ9S'/55 OilS 717-605-3494 PAGE 64 p.6 D. nle right to have the court decide any other rights, remedies, privileges, or obllgatio!1S covered by this Agreement, including but not limited to poasible claims for divorce, spousal support, alimony, alimony pendente lite (temporary alimony), and counsel fees, oosts and expenses. 6. Mutuat Re'e~. Husband relinquishes his inchoate intestate right in the estale of Wife, and Wife relinquishes her Inohoate intestate right in the estate of Husband, and each 01' the parties hereto by these presents, for himself or herself, his or her heirs, executors, I1Idministrators or assigns, does remise, release, quit-claim and forever discharge the other 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 suils at law ()r in equity, of whatsoever kind or nature, for or because of any matter or thing done, admitted, or sulTered 10 be done by said other party prior to and including the date hereof; further, the parties hereto have been advised by their legal representatives, respectively, of all their rights under the Pennsylvania Divorce Code, and such rIghts as are not specifICSl1y Incorporated herein are hereby expreslJly waived. Notwithstanding the loregolnglanguage ofthis paragraph, this release shall in no way exonerate or dlscha'l~e either party hereto from the obligations and promises mede and imposed by reason (If this Agreement and shall In no way affect any cause of action in absolute divorce which either party may have against the other. ----- n___._-7. Relea&eol' AifCl8iins. EaCh partY. excepias'-othelwlSe- provided for in this --- -- Agreement, release~1 the other from aJl claims, f1abfllties, debts, obllgatfons. actions IInd 5 Nov 22 05 09:16a NAVICP MECH 05835 1~1"~1.~~~ 1~:16 71nq95755 OBS 717-605-3494 PAGE ~5 p.7 causes of action of eV~1ry kind that have been Incurred, or may be Incurred, relating to or arising from the marriage between the parties, including waiving any claim to their respective pensions 01" retirement accounts. However, neither party Is relieved or discharged from any obligations under this Agreement or under any Instrument or document executed pursuant to this Agreement. 8. Breach. If e,ither party breaches any provision of this Agreement, the other par1y shall have the right, at his or her election. to sue for damages for such breach, and seek any other remedy allowed in law or equity. The party breaching this contract shall be responsible for the payment of legal fees and costs incurred by the other In enforcing his or her rights under this Agreement, or seeking such other remedy or relief as may be available to him or her. Waiver by one party of any breach of this Agreement by the other party shall nol be deemed a waiver of any subsequent, similar breach or other breaches. 9. Full Disclosure. Husband and Wife each represent and warrant to the other that he or she has m~lde a full and complete disctosure to ttle other of all assets of any nature whatsoever in which such party has an interest, of the source and amount of the income of such party. of every type whetsoever and all other facts relatlns to the subject matter ofthls Agreement. 10. Oivorce. This Agreement shall not be construed to affect or bar the right of -----either HuSBana or WifiTcj aWe ancsbsolLitellivorcii on legal and truthful grounds 88"-'-- they now exist or may hereafter arise. It Is understood, however, that Wife will file an 6 Nov 22 05 09:16a NAVICP MECH 05835 1~/~~/~~~~ l~:lb Il/<qY~/bb UBS 717-605-3494 f'Al*. ~ I p.B of any of the provislon.'l of this Agreement shall not I1e construed as a waiver of any subsequent default of lhe same or similar nature. 14. DescriDtive Headlnas. The descriptive headings used herein are for convenience only. ThlaY shall have no effect whatsoever In determining the rights or obligations of the parties. 15. Successom and Assicms. This Agreement, except as otherwise expressly provided herein, shall be binding upon and shall Inure to the benefit of the respective legatees, devisees, heirs, executors, administrators, assignees and successors in intel'e$t to the pArties. 16. GoveminoJ.Bla! This Agreement shall be governed by and shall be construed in lIcoordallce with the laws of the Commonwealth of Pennsylvania. 17. Order of Court. With the approval of any court of competent jurisdiction in which any divorce pmceeding may now be pending or which may hereafter be instituted, this Agreement shall be Incorporated in any decree of absolute divorce which may be passed by said court. In the event the court shall fail or decline to Incorporate this agreement or any provisions thereof in said decree, then and in that event the parties, for themsel\ll:lS and their respective heirs, perscnal representatives and assigns, agree that tlley will nevertheless abide by and carry out all of the provisions thereof. --- -:- .---1t isfurmeragieea1flat regiifaJesS 'OfWfiettier -siildagreement or anYparfthereof . ---:-- is incorporated In any such decree, the same shall not be merged in said decree, but said agreement and all the tenns thereof shall continue to be binding upon the parties and their respectlve heirs, personal representatives and assigns. Nov 22 05 09:16a MAVlC? MECH 05835 717-605-3494 p.9 WITNESS: ~ ~CJ6 -;-: ~':-'- ~... ,f~~ ~ /9-.~ (SEAL) Curtis A. JumPer ~ cJQ.{/),~ (SEAL) 'Kendra C. Jur6Per COMMONWEALTH OF Pennsylvania 55. COUNTY OF Cumberland AND NOW, thisafH1day of ~ , 2005, before me, the undersigned officer, personally appeared Curtis A. Jumper, 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. COMMONWEALTH OF jS WHEREOF, I hereunto set my hand and official seal. Notanal Seal Jennifer 6. Undsay, Notary Public . Canl"'. Born. CUmberland County . My Commission Expires Nov. 29. 2007 Member. Pennsylvanle A6~ocialion Of No1tarles COMMONWEALTH OF Pennsylvania 55. COUNTY OF Cumberland AND NOW, this 1st: day of tf,ldve;,,/'t'!f:., 2005, before me, the undersigned officer, personally appeared Kendra C. Jumper, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. COMMONWE=::~:'NNSYLVANIA . Mnn RiD$Oll. NoIaly PublIc ~ Roro CumbortandCounly My Comm,,:,~' " Elcpj...... July 27. 2008 Member. Pennsylvani:S AS5cc;;atlon Of Notaries rcbfdomfjumper.agr ~~~ Notary Public Nov 22 05 09:17a . NAVlCP MECH 05835 p.10 Scott's room: Bed Vcr, Tv@ entertainment center Desk, comshelf, Speakers Clothes Justin's room: Bed Dresser Book Shelf Desk TvNcr Recorder, Tapes Clothes Kitchen: V:. dishes @ untensils pots and pans cups food Laundry Closet: y, sheets towels pillow cases, soap, toilet supplies Miscellaneous: Couch Loveseat Dresser Lamps Table Powersaw and safe Paints Old record player My antiques Suitcases V:. shovels @ rakes 2 bikes mowers ladders gas cans wheel barrow 717-605-3494 A'J. Nov 22 05 09:17a NAVlCP MECH 05835 p.11 2 tables, hedge trimmer weedwacker weights y. lawn furniture old lanterns comer shetfin basement I made Tree trimmer y. hoses @ sprayers leaf blowers chainsaw 'l'. power cords y. xmas supplies gun rach and guns boys and my sports equipment picnic table and benches vacumn sweeper kgt tub Y. fans in house record player and records propane grill Kamerin's room: 1/3 of clothes records tapes Y. Kamerins's toys 1 bike My bedroom: All clothes and dresser 2 phones y. family pictures 717-605-3494 A-2- (') ,;; <-:,. "t~ i:) \ q-: f! ' ~'t 1: i) ~-f..~) ~'C=- ":;,r ~- -; -<. ,..., = r:~ "" :;r; :D- --< ~ --i :J:." r"F """NrTJ -iJY ~~~~--r: ;",l") :.:2 2M ,', :::--t 1; '< -.l ;t>' :x <-n ...- KENDRA C. JUMPER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 05-6326 Civil Term CURTIS A. JUMPER, Defendant : 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 divorce: irretrievable breakdown under Section (X) 330I(c) U 3301(d)(l) of the Divorce Code. (Check applicable section) 2. Date and manner of service of the complaint: December 19.2005. bv Acceptance of Service bv Robert L. O'Brien. Attornev for Defendant 3. (Complete either paragraph (a) or (b). (a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff 4-11-06 ; by Defendant 4-21-06 (b) (I) Date of execution of the Plaintiff's Affidavit required by Section 3301(d) of the Divorce Code; ; (2) date of service of the Plaintiff's Affidavit upon the Defendant: 4. Related claims pending: Settlement Agreement dated November 1. 2005 5. (Complete either paragraph (a) or (b).) (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached. (b) Date plaintiffs Waiver of Notice was filed with the prothonotary: 4-24-06 Date defendant's Waiver of Notice was filed with the prothonotary: 4- :]-06 ~ "",'1'; -0 ~. rnrT' ;2", ' :i. (.:l SQ'~;":," ~\= ~(.j :P'c: ~ ~ <::> "" ~ ~ - ...J ':P' ::J;: - - ~ ~:n r; "Oli,..2 -Ot -r"l ') "....-;; - :~;I~ Ii ~'.:,;. (,.1 om -. ~ :;<:;. lfl .r:- '" '" '" '" "'if. '" itiiti Of. Of. if. Of. Of.iti iti iti iti itiiti iti iti '" iti '" IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY '" iti iti '" PENNA. STATE OF iti '" ;t; '" '" iti '" '" if. KENDRA C. JUMPER, Plaintiff No. 05-6326 Civil Term '" VERSUS CURTIS A. JUMPER, Defendant DECREE IN DIVORCE ~~, KENDRA C. JUMPER ~ IT IS ORDERED AND AND NOW, DECREED THAT , PLAINTIFF, AND CURTIS A IIlMffiR , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECOR~~;~S ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; '~L **The terms ofa Postnuptial Agreement between the parties, dated November 1, '" J. 2005, are hereby incorporated but not merged into and m /' / BY THE COURT: Ii PROTHONOTARY iti "'''' if. if. if. if. if.;t; if."'if. if. if.'" "'if.if. if. "'if."'if. if. '" '" '" iti '" '" '" '" '" '" '" '" if. iti if. iti '" '" '" '" if. '" if. if. if. if. if. '" if. '" '" '" '" iti '" '" '" if. '" if. '" '" '" '" '" '" if. '" if. '" '" '" '" '" '" '" '" '" if. if. if'!; ~ (/ -P ~ ~.~ -2? 1/-?, n r ~~ ~ -~ &?Jr? ;;/-9 . ~.. I"' '- ~-'! .