HomeMy WebLinkAbout06-0317
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HAROLD S. IRWIN, III, ESQUIRE
ATTORNEY ID NO. 29920
64 SOUTH PITT STREET
CARLISLE PA 17013
(717) 243-8090
ATTORNEY FOR PLAINTIFF
TERRY L. SNOOK,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: NO. 2006 - -3 17 CIVIL TERM
APRIL E. SNOOK,
Defendant
: IN DIVORCE
NOTICE
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 in divorce or annulment may be
entered against you by the court. A judgment may also be entered against you for any
other claim or relief requested in these papers by the plaintiff. You may lose money or
property or other rights important to you, including custody or visitation of your children.
When the ground for divorce is indignities or irretrievable breakdown of the marriage,
you may request marriage counseling. A list of marriage counselors is available in the
Office of the Prothonotary, Cumberland County Courthouse, Carlisle, Pennsylvania
17013.
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
32 South Bedford Street
Carlisle, Pennsylvania 17013
717-249-3166
.
PlaIntIff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
TERRY L. SNOOK,
v.
: CIVIL ACTION. LAW
: NO. 2006 - ~CIVIL TERM
APRIL E. SNOOK,
Defendant
: IN DIVORCE
COMPLAINT IN DIVORCE UNDER SECTION
3301 (!tl OF THE DIVORCE CODE
NOW, comes the plaintiff, by his attorney, Harold S. Irwin, III, Esquire, and files this
complaint in divorce against the defendant, representing as follows:
1. The plaintiff is TERRY L. SNOOK, an adult individual residing at 1228 Pheasant
Drive South, Carlisle, Cumberland County, Pennsylvania 17013.
2. The defendant is APRIL E. SNOOK, an adult individual residing at 3 Fieldcrest
Drive, Mechanicsburg, Cumberland County, Pennsylvania 1705e.
3. The parties have been residents of the Commonwealth of Pennsylvania at least
six months prior to the filing of this action in divorce.
4. The parties were married on June 7, 2003 in New Kingstown, Cumberland
County, Pennsylvania.
5. Pursuant to the Divorce Code, Section 3301 (c), the plaintiff avers as the grounds
upon which this action is based that the marriage between the parties is irretrievably
broken.
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6. The plaintiff avers that she has been advised of the availability of counseling and
that he has the right to request that the court require the parties to participate in
counseling.
WHEREFORE, the plaintiff demands judgment dissolving the marriage between the two
parties.
I verify that the facts contained herein are true and correct. I understand that false
statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904
relating to unsworn falsification to authorities.
January l:l, 2006
~K~:--
HAROLD S. IRWIN, III
Attorney for Plaintiff
64 South Pitt Street
Carlisle, Pennsylvania 17013
(717) 243-6090
Supreme Court ID No. 29920
. . ('0 .
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
TERRY L. SNOOK,
v.
: CIVIL ACTION - LAW
: NO. 2006 - 2L2..-CIVIL TERM
APRIL E. SNOOK,
Defendant
: IN DIVORCE
PLAINTIFF"S MARRIAGE COUNSELING AFFIDAVIT
The plaintiff, being duly sworn according 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
Prothonotary's Office, which list is available to me upon request.
3, Being so advised, I do not request that the court require that my spouse and I
participate in counseling prior to a divorce decree being handed down.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein made are subject to the penalties of 18 Pa. C,S. Section 4904
relating to unsworn falsification to authorities.
January .\.,:t., 2006 --;J ~ ~
TER;;;'-;'~ SNOOk. ."'01':-
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TERRY L. SNOOK,
PlalntiH
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
v.
: CIVIL ACTION. LAW
: NO. 2006 - 0317 CIVIL TERM
APRIL e. SNOOK,
Defendant
: IN DIVORCE
AFFIDAVIT OF SERVICE OF COMPLAINT
PURSUANT TO PA. R.C.P. RULE NO. 1920.4 (M(!}ffi
NOW, Harold S. Irwin, III, Esquire, being duly sworn according to law, does depose and
state:
1. That he is a competent adult and attorney for the plaintiff in the above captioned
action in divorce.
2. That a certified copy of the complaint in divorce was served upon the defendant
on January 23, 2006, by certified mail addressed to the defendant at 3 Fieldcrest Drive,
Mechanicsburg, PA 17050, certified mail No. 70040390000326353730.
3. A copy of the sender's and return receipts are attached hereto.
I verify that the statements made in this affidavit are true and correct. I understand that
false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904,
relating to unsworn falsification to authorities.
Harold S. Irwin, III
Attorney for plaintiff
January 25, 2006
64 South Pitt Street
Carlisle, PA 17013
717-243-6090
Supreme Court 10 No. 29920
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CERTIFIED MAil," RECEIPT
(Domestic Mail Only; No Insurance Coverage Provided)
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. 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.
t. Article Addressed to:
D. Is detlvery address different from Item ?
If YES, enter delivery address below:
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1\PRIL E SNOOK
3 FIELDCREST DR ~~
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3. Service Type
)il:certifred Mail [] Express Mail
[J RegIstered [] Return Receipt for Merchandise
[J Insured Mail [] C.O.D.
4. Restricted Delivery? (Extra Fee) as
2. ArtIcle Number
(Transfer from selVlce label)
PS Form 3811, February 2004
7005 0390 0003 2635 3730
Domestic Return Receipt
102595-02.M-1540
EXHIBIT "A"
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TERRY L SNOOK,
Plaintiff
I IN THE COURT OF COMMON PLEAS OF
I CUMBERLAND COUNTY, PENNSYLVANIA
I
v.
I CIVIL ACTION - LAW
I NO. 2006 - 0317 CIVIL TERM
APRIL E. SNOOK,
I
Defendant
I IN DIVORCE
AFFDAVIT OF CONSENT
1. A complaint in divorce under Section 3301 (c) of the Divorce Code was filed in this matter on or
about January 17, 2006. Service of the complaint was made by certified mail, return receipt
requested, restricted delivery, on January 23, 2006 (see affidavit of service previousiy filed on
January 25, 2006).
2. The marriage of piaintiff and defendant is irretrievably broken and ninety days have elapsed from
the date of the service of the amended compiaint.
3.
I consent to the entry of a final decree in divorce after service of notice of intention to request
entry of the divorce.
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TER L. SNOOK
April L ~ 2006
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE
UNDER SECTION 3301(cl 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 fiied 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. Section 4904 relating to unsworn falsification to
authorities.
April L (';006
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PROPERTY SETTLEMENT AGREEMENT
THIS IS AN AGREEMENT made thiSZ~ of April, 2006, by and between Terry L. Snook ,of
1228 Pheasant Drive South, Carlisle, Cumberland County, Pennsylvania,(hereinafter referred to
as Husband) and April E. Snook, of 402 West Pine Street, Mt. Holly Springs, Cumberland
County, Pennsylvania, (hereinafter referred to as Wife).
WHEREAS, Husband and Wife were married on June 7, 2003 in New Kingstown, Cumberland
County, Pennsylvania; and
WHEREAS, various differences have arisen between Husband and Wife, whereby they have
been living separate and apart since April 14, 2005; and
WHEREAS, the parties have agreed to maintain separate and permanent domiciles and to live
apart from each other; and
WHEREAS, the parties desire to enter into an amicable settlement to provide for all of the
property rights of the parties and to dispose of the rights and obligations of each to the other in
respect to support, maintenance, alimony, counsel fees, equitable distribution, and all other rights
and obligations under the Divorce Code of 1980, as amended, and it is the intention and
agreement of the parties that this Agreement be a full, complete and final settlement of all of
those rights and obligations under said Divorce Code; and
NOW, THEREFORE, for and in exchange of mutual considerations, and intending to be bound
by the provisions hereof, the parties agree that their recitals form a part of this Agreement and
waive any right to counseling under the Divorce Code of 1980, as amended, and right to counsel
fees, costs, alimony, support, maintenance, and any other rights under the said Divorce Code not
provided for herein and agree as follows:
1. SEPARATION. The parties agree that it shall be lawful for each party, at all times
hereafter, to live separate and apart from the other, at such place or places as he or she may, from
time-to-time, choose or deem fit. Each party shall be free from interference, authority or contact
by the other, as fully as if he or she were single and unmarried, except as may be necessary to
carry out the provisions of this Agreement and as may be necessary to exchange information that
pertains to the parties' minor child. Neither party shall molest the other or attempt to endeavor to
molest the other, nor compel the other to cohabit with the other, or in any way harass or malign
the other, nor in any way interfere with the peaceful existence, separate and apart, from the other.
2. REAL ESTATE. Husband owns the marital residence located at 1228 Pheasant Drive
South, Carlisle, Pennsylvania. The marital residence presently has an outstanding mortgage in
1
favor of National City Mortgage. Wife shall deed any rights, title and interest she has in the
marital residence to Husband at such time Husband pays sum of$5225.00 to Wife for her half-
equity in the house. Husband shall refinance or assume the National City mortgage and solely
bear the financial responsibility of the property. Husband shall be solely responsible for all
mortgage payments, liabilities, taxes, assessments, insurance and the cost of maintenance on the
marital residence, Husband shall indemnify and hold Wife harmless from any liability, claims,
causes of action, suits, or litigation for money owed, damages, indirect or consequential,
including legal fees, arising out of failure of Wife to so pay such liens and encumbrances.
3. AUTOMOBILES. Husband shall have as his sole and exclusive property, title to and
possession of the 2003 Jeep Liberty and the 1985 Honda VF500C. Wife shall have as her sole
and exclusive property, title to and possession of the 2000 Ford Escort. Each party shall
indemnify and hold the other harmless from and liability on any loan encumbering the vehicle,
cost of repairs, maintenance, registration, insurance and/or inspection of the vehicle which each
is taking as his/her sole and exclusive property.
4. PERSONAL PROPERTY. The parties have divided or have agreed to a division of their
personal property which includes bank accounts, certificates of deposit, life insurance policies,
jewelry, clothing, furniture and other personal items. Wife agrees to grant Husband sole
possession of engagement ring and Wife shall receive $1500.00 from Husband for
reimbursement of the payment she made towards its purchase. Husband and Wife agree to divide
equally the refund due from the 2005 federal income tax return filing. After the aforesaid
division of the personal property is complete, any and all property in the possession of Husband
shall be his sole and separate property. Any and all property in the possession of Wife shall be
her sole and separate property. Each party forever renounces whatever claims helshe may have
with respect to the property which the other is taking, Each party understands that he/she has no
right or claim to any property acquired by the other after the signing of this Agreement.
5, PENSION/RETIREMENT PLANS. Wife hereby releases any and all claims or demands
she may have on Husband's pension or retirement plans. Husband hereby releases any and all
claims or demands he may have on Wife's pension or retirement plans.
6. DEBTS. The parties represent and warrant to each other that neither has incurred any
other debts nor made any other contracts for which the other or his/her estate may be liable, from
date of separation forward. Neither party shall contract nor incur any debt or liability for which
the other or his/her property or estate might be responsible and agrees to indemnify the other
from any claims made against the other because of debtslobligations not incurred by the other.
7. ALIMONY, ALIMONY PENDENTE LITE, SUPPORT OF SPOUSE. The parties waive
any and all right to receive from the other any payment of alimony, alimony pendente lite, and/or
spousal support.
2
8. EFFECTIVE DATE, The effective date of this Agreement shall be the date of execution
by the parties if they had each executed the Agreement on the same date. Otherwise, the
execution date of this Agreement shall be defined as the date of execution by the party last
executing this Agreement.
9. DIVORCE. A divorce action was initiated and filed at docket number 2006-317 Civil
Term in the Court of Common Pleas of Cumberland County on January 17, 2006. Both parties
agree to execute any and all affidavits or other documents necessary for the parties to obtain an
absolute divorce pursuant to Sections 3301(c ) of the Divorce Code including waiver of all rights
to request Court ordered counseling.
10. INCORPORATION INTO DECREE. Should a decree, judgment or order of separation
or divorce be obtained by either of the parties in this or any other state, country, or jurisdiction,
each of the parties hereby consents and agrees that this Agreement and all of its covenants shall
not be affected in any way by any such separation or divorce; and that nothing in any such decree,
judgment, order or further modification and revision thereof shall alter, amend or vary any term
of this Agreement, whether or not either or both of the parties shall remarry, it being understood
by and between the parties hereto that this Agreement shall survive and shall not be merged into
any decree, judgment, or order of divorce or separation. It is specifically agreed, however, that a
copy of this Agreement or the substance of the provisions thereof, may be incorporated by
reference into any divorce, judgment or its decree. This incorporation, however, shall not be
regarded as a merger, it being the specific intent of the parties to permit this Agreement to
survive any judgment and to be forever binding and conclusive upon the parties.
11. MUTUAL RELEASE. Husband and Wife do hereby mutually remise, release, quit claim
or forever discharge the other and the estate of such other, for all time to come, and for all
purposes whatsoever, from any and all rights, title and interest, or claims in or against the estate
of such other, of whatever nature and wherever situate, which he or she now has or at anytime
hereafter may have against such other, the estate of such other or any part thereof, whether
arising out of any former acts, contracts, engagements or liabilities of such other or by way of
dower or curtesy of claims in the nature of dower or curtesy, or widow's or widower's rights,
family exemption or similar allowance or under the intestate laws; or the right to take against the
spouse's will; or the right to treat a lifetime conveyance by the other as testamentary or all or
other rights of the surviving spouse to participate in a deceased spouse's estate, whether arising
under the laws of Pennsylvania, any state, commonwealth or territory of the United States, or any
other country or any right which either party may now have or at anytime hereafter have for past,
present or future support or maintenance, alimony, alimony pendente lite, counsel 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
3
to give to each other by the execution of this 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 provision thereof.
12. COUNSEL FEES, Each party individually covenants and agrees that he or she will
individually assume the full and sole responsibility for legal expenses for his or her attorney and
court costs in connection with any divorce action which may be brought by either party and shall
make no claim against the other for such costs or fees.
13. ADDITIONAL INSTRUMENTS. Each of the parties shall, from time-to-time, at the
request of the other, execute, acknowledge and deliver to the other party any and all further
instruments or documents that may be reasonable required to give full force and effect to the
provisions of this Agreement.
14. MODIFICATION OR WAIVER. A modification or waiver of any of the provisions of
this Agreement shall be effective only if made in writing and executed with the same formality as
this Agreement. The failure of either party to insist upon the strict performance of any of the
provisions of this Agreement shall not be construed as a waiver of any subsequent default of the
same or similar nature,
15. ENTIRE AGREEMENT. This Agreement contains the entire understanding of the parties
and there are no representations, warranties, covenants or undertakings other than those expressly
set forth herein.
16. SEPARATE PARAGRAPHS. It is specifically understood and agreed by and between
the parties thereto that each paragraph hereof shall be deemed to be a separate and independent
agreement.
17. BREACH, If either party breaches any provision of this Agreement, the other party shall
have the right, at his or her election, to sue for damages for such breach or seek such other
remedies or relief as may be available to him or her and the party breaching this Agreement shall
be responsible for payment of legal fees and costs incurred by the other in enforcing the rights
under this Agreement, or in seeking such other remedies or relief as may be available to him or
her.
18. CONTROLLING LAW. This Agreement shall be construed under the laws of the
Commonwealth of Pennsylvania.
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19. INVALIDITY OF PROVISIONS. If any term, condition, clause or provision 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,
20. BINDING NATURE. Except as otherwise set forth herein, this Agreement shall be
binding and shall inure to the benefit of the parties hereto and their respective heirs, executors,
administrators, successors and assigns.
IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the day and year
first above written.
WITNESS
<~ 7 ;;fp(
L. Snook
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April . Snook
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COMMONWEALTH OF PENNSYLVANIA
ss:
COUNTY OF CUMBERLAND
On this the l.~ay of April, 2006, before me, fJ"iMlJ) ~ 14lW,..J $the undersigned
officer, personally appeared Terry L. Snook, known to me (or satisfactorily proven) to be the person
whose name is subscribed to the within instrument, and acknowledged that she executed the same for the
purposes therein contained,
In witness whereof, I hereunto set my hand and
(SEAL)
NOTARiAl SEAL
"ROLD S.IRWlN.III. NOTARYPUBI.IC,
SLE BOROUGH. COUNTY OF CUMBERWIl>
COMMISSION EXPIRES OCTOBER 22. 2006
COMMONWEALTH OF PENNSYL VANIA
ss:
COUNTY OF CUMBERLAND
On this the & day of .11!!~lho06, before me, Lindsay D. Baird, the undersigned officer,
personally appeared April E. Snook, known to me (or satisfactorily proven) to be the person whose name
is subscribed to the within instrument, and acknowledged that she executed the same for the purposes
therein contained,
In witness whereof, I hereunto set my hand and official seal.
~~7#'~FAL)
'No Public
Not<Jf:al,-38a)
Lindsay' D. Baird, Notary Public
Carlisle Boro, Cumberland County
My Commission Expires Oct. 21. 2006
I\.~mber, ?ennsY\\lania Associat"lOn Of Notaries
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HAROLD S. IRWIN, III, ESQUIRI!
AnoRNBY ID NO. 28lIZO
14 SOUTH PITT STREET
CAIlLISLI! PA 17013
(717) Z4WDlID
AnoRNBY POR DI!FI!NDANT
Plaintiff
I IN THE COURT OF COMMON PLEAS OF
I CUM.ERLAND COUNTY, PENNSYLVANIA
TERRY L. SNOOK,
.
.
Y.
I CIVIL ACTION. LAW
I NO. 2008 - 0317 CIVIL TERM
APRIL E. SNOOK,
I
Defendant
I 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: On or about November 16, 2005, defendant was
served with a copy of the divorce complaint by certified mail (see Affidavit of Service previously
filed),
3. Complete either paragraph (a) or (b):
(a) Date of execution of conse t equirQ..d QltSection 3301 (c) of the Divorce Code:
By the plaintiff: iIl2IL. z.:r Z~_
By the defendant:
(b)(l) Date of execution of the affi avit equired by Section 3301(d) of the Divorce Code:
N/A.
(b)(2) Date of filing and service of the plaintiff's affidavit upon the defendant: N/A.
4. Related claims pending: None
5. Complete either (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: N/A.
(b) Date plaintiff's Waiver of Notice il]... Section 3301 (c) divorce was filed with the
Prothonotary: If/Jlf/L 2S . ZoO<
Date defendant's Waiver of Notice in Section 3301 (c) Divorce was filed with the
Prothonotary: /If Ay I~ 2~c..
f1!kf I Y ,2006
HA D S. IRWIN, III
Attorney for Plaintiff
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Plaintiff
= IN THE COURT OF COMMON PLEAS OF
= CUMBERLAND COUNTY, PENNSYLVANIA
TERRY L. SNOOK,
v.
= CIVIL ACTION. LAW
= NO. 2006 - 0317 CIVIL TERM
APRIL E. SNOOK,
Defendant
= IN DIVORCE
AFFDAVIT OF CONSENT
1. A complaint in divorce under Section 3301 (c) of the Divorce Code was filed in this matter on or
about January 17, 2006. Service of the complaint was made by certified mail, return receipt
requested, restricted delivery, on January 23, 2006 (see affidavit of service filed on January 25,
2006).
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from
the date of the service of the amended complaint.
3. I consent to the entry of a final decree in divorce after service of notice of intention to request
entry of the divorce.
May &, 2006
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AP It! E. SNOOK
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.
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. Section 4904 relating to unsworn falsification to
authorities.
May R, 2006
~~_ '~laliL
ALE. SNOOK
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IN THE COURT OF COMMON PLEAS
OFCUMBERLANDCOUNTY
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STATE OF
TERRY L. SNOOK
Plaintiff
VERSUS
APRIL E. SNOOK
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Defendant
PENNA.
No. 2006- 0317 CIVIL TERM
DECREE IN
DIVORCE
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, IT IS ORDERED AND
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AND NOW,
fr1d ;;~
DECREED THAT
TERRY L. SNOOK
, PLAINTIFF,
AND
APRIL E. SNOOK
, DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY,
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED; NONE
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The attached Property Settlement Agreement dated April 25, 2006,
is
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:+:..,:+:+:+ :+
..
:+:+: :+:'t'
:+: :+:+::+:+::+::+:+::+ :+: :+:+::+~:+:+: :+::++.:+::+: :+:+
:+:+:+ :+::++;1'+:+:++:+:+ :of
but ,not
the final decree.
ATTEST:
PROTHONOTARY
Of. Of.:+:+:+:+ Of':+:+
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.Pt~ ~ ~ 'f}"'"Pln ~h;
~7 ~ ~ ~trZ1'l4r- ~C1;? "-r?i[)
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0/(7 (l r '':;'
?r7 el:,>
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
r 1Ete.1C.L/ /-,. .s l\/gtJ Ie.. :
I Plaintiff .
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Vs : File No. d~~~ - 03/""9- (11// L /61l ft-J
: IN DIVORCE
APR.IL E. SA ( tl-U/C :
Defendant :
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NOTICE TO RESUME PRIOR SURNAME
Notice is hereby given that the Plaintiff / defendant in the above matter,
[select one by marking "x"]
_ prior to the entry of a Final Decree in Divorce,
- or . -X- after the entry of a Final Decree in Divorce dated tilt; ~ 'JjAd It>
hereby elects to resume the prior surname of ApR.JL EYE. ~/2.. , and gives this
written notice avowing his / her intention pursuant to the provisions of 54 P .S. 704.
Date: ,"-: c)S-: tfU ~ Elt-l ~Ct'Jt.
SIgna e
~ ])dUA-
- ignature 0 name being resumed
COMMONWEALTH OF PENNSYLVANIA )
COUNTY OFCa~ItJ.d)
On the X ~ day of ~tJ; , 200", bef{)re me, the ~rothQB.etary sr tJ.:1e
notary public, personally appeared the above affiant mown to me to be the person whose
name is subscribed to the within document and acknowledged that h~xecuted the
foregoing for the purpose therein contained.
In Witness Whereof, I have hereunto set my hand hereunto set my hand and official
seID. ~=~~.. ~?~:~
Carlisle Bolo, CunbeIIand County
My Cooll'lllNun &ptesOct. 21, 2006
Member. PennsylvanIa Association Of Notaries
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