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HomeMy WebLinkAbout02-1151ANDREA M. VATHIS, Plaintiff RANDALL C. VATHIS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA _. : NO. 02 - J I~ ! 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 the Court may enter a decree of divorce or annulment against you. 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 grounds for divorce are indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Prothonotary's Office at the Cumberland County Courthouse, Carlisle, Pennsylvania. 1F 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 717-249-3166 ANDREA M. VATHIS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : v : NO. 02- 11~I RANDALL C. VATHIS, Defendant : IN DIVORCE CIVIL ACTION - LAW COMPLAINT Plaintiff, Andrea M. Vathis, by her attorneys, Broujos & Gilroy, P.C., sets forth the following: 1 Plaintiff, Andrea M. Vathis, is an adult individual residing at 20 Stone Run Road, Mechanicsburg, Cumberland County, Pennsylvania. 2 Defendant, Randall C. Vathis, is an adult individual residing at 1413 Silver Creek Drive, Meehanicsburg, Cumberland County, Pennsylvania. 3 The parties were married on October 22, 2000, in Dauphin County, Pennsylvania. 4 Plaintiff and Defendant have lived continuously in the Commonwealth of Pennsylvania and in Cumberland County for at least six months prior to the commencement of this action. 5 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. 6 There have been no prior actions for divorce or annulment in this or any other jurisdiction within the knowledge of the Plaintiff. 7 In accordance with Section 3301(c) of the Divorce Code, the marriage between the parties is irretrievably broken. WHEREFORE, the Plaintiff requests your Honorable Court to decree that the Plaintiff be divorced from the Defendant. BROUJOS & GILROY, P.C. BY Hu~be~ X.~G~u ireAttorney for Pi~fatiff Broujos & Gi~oy, P.C. 4 North Ha96ver Street CarLisle, PA 17013 717 - 243-4574 I verify that the statements in the foregoing pleading 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. Andrea M. Vathis ANDREA M. VATHIS, Plaintiff V. RANDALL C. VATHIS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-1151 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF ACCEPTANCE OF SERVICE I, Austin F. Grogan, Esq., accept service of the Divorce Complaint on behalf of Randall C. Vathis, Defendant, in the above-captioned case and verify that I am authorized to do so. 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 unswom falsification to authorities. Date Respectfully submitted, Camp Hill, PA 17011 (717) 737-1956 Attorney for Defendant ID # 59020 ANDREA M. VATHIS, Plaintiff Vo RANDALL C. VATHIS, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02-1151 : : CIVIL ACTION - LAW : IN DIVORCE PETITION FOR SPECIAL REI JEF AND NOW, this 31st day of October, 2002, the Defendant, Randall C. Vathis, by and through his Attorney, Austin F. Grogan, Esq., avers the following in support of this Petition for Special Relief; 1. The Plaintiff filed a divorce action on or about March 7, 2002 requesting the Court to grant a divorce between the parties; 2. On or about October 31, 2002 the Defendant filed an Answer raising New Matter in the form of an Equitable Distribution claim; 3. The parties constructed a home during the brief 14 month marriage, which is currently occupied by the Plaintiff; 4. The Plaintiff and the Defendant have been attempting to sell the home in that the Plaintiff placed the home on the market in August 2002 for a ninety day period; 5. Plaintiff requires that she be present as a condition on showing the marital home at all times and that no lock box be placed on the door to facilitate frequent showings; 6. Furthermore, the Plaintiff does not permit the listing agent to have a key to the house to show the home unless she is present; 7. The contract is expired on October 31, 2002 and the Plaintiff is unwilling to extend the listing agreement for an additional six months; 8. The Defendant has signed the listing extension and wishes to continue the same realtor, who has akeady established a working relationship with various interested parties; 9. The Defendant has agreed to reduce the price to sell the house quicker in order to resolve the economic issues and the Plaintiff refused to respond to the realtors requests for meetings to discuss the sale of the house; 10. Plaintiff continues to frustrate and delay the ultimate liquidation of the home in order to strengthen her case in equitable distribution and as is relates to spousal support claim. WHEREFORE, the Defendant respectfully requests this Honorable Court to schedule a Hearing, Order the Plaintiff to sign the listing agreement with Jack Gaughen realtor, who has been showing the house, Order the Plaintiff to use a lockbox on the door in order to provide extended times to show the house, and suspend spousal support payments. Respectfully submitted, Date 2A~stix~ Fr th' 3G;n°dg~nt~eet~Uir e,(J Camp Hill, PA 17011 (717) 737-1956 Attorney for Defendant I.D.//59020 VERIFICATION I, RANDALL C. VATHIS, verify that the statements made in the foregoing Petition for Special Relief 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. § 4904, relating to unsworn falsification to authorities. Date c. v×Tuls ANDREA M. VATHIS, Plaintiff RANDALL C. VATHIS, Defendant full. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-1151 CIVIL ACTION - LAW IN DIVORCE ANSWER WITH NEW MATTER 1. Admitted; 2. Admitted; 3. Admitted; 4. Admitted; 5. Admitted; 6. Admitted; 7. Admitted. WHE~REFORE, Plaintiff requests this Honorable Court to enter a Decree of Divorce. NEW MATTER EQUITABLE DISTRIBUTION 8. Paragraphs 1 through 7 are incorporated herein by reference as though set forth in 9. Plaimiff and Defendant have acquired property, both real and personal, during their marriage from October 22, 2000, until January 9, 2002, the date of their separation, which property is "marital property". 10. Plaintiff and Defendant may have owned, prior to the marriage, property which has increased in value during the marriage and/or which has been exchanged for other property, which has increased in value during the marriage, all of which property is "marital property". 11. Plaintiff and Defendant have been unable to agree as to an equitable division of said property prior to the filing of this Complaint. WHEREFORE, Plaintiff requests this Honorable Court to equitably divide all marital property. Respectfully submitted, Date Austin F. Grogan, Esqui~ 24 North 32nd Street Camp Hill, PA 17011 (717) 737-1956 Attorney for Defendant I.D. #59020 VERIFICATION I, RANDALL C. VATHIS, verify that the statements made in the foregoing Answer with New Matter 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. § 4904, relating to unswom falsification to authorities. Date R3k~ALL C. VATHIS In the Court of Common Pleas of Cumberland County, Pennsylvania No. ~-' Civil. 19 To Prothonotary 19 Attorney~tr.]~m~ No. Term. 19 ~ VS. PRAECIPE Filed 19 , Atty. ANDREA M. VATHIS, Plaintiff VS. RANDALL C. VATHIS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COIZNTY, PENNSYLVANIA 02-1151 CIVIL CIVIL ACTION - LAW IN DIVORCE IN RE: DEFENDANT'S PETITION FOR SPECIAL RELIEF ORDER AND NOW, this ~ day of November, 2002, a nde is issued on the plaintiff to show cause why a hearing ought not to be scheduled on this matter. This role returnable twenty (20) days after service. BY THE COURT, 11-13-02. Hess, J. ANDREA M. VATHIS, Plaintiff VS. RANDALL C. VATHIS, Defendant : THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 02 - 1151 CIVIL IN DIVORCE TO: Hubert X. Gilroy Austin F. Grogan , Attorney for Plaintiff , Attorney for Defendant DATE: Monday, January 26, 2004 CERTIFICATION I certify that discovery is complete as to the claims for which the Master has been appointed. (a) OR IF DISCOVERY IS NOT COMPLETE: Outline what information is required that is not complete in order to prepare the case for trial and indicate whether there are any outstanding interrogatories or discovery moti3ns. (bi Provide approximate date when discovery will be complete and indicate what action is being taken to complete discovery. DATE C~ FOR PLAINTIFF COUNSEL FOR DEFENDANT NOTE: PRETRIAL DIRECTIVES WILL NOT BE ISSUED FOR THE FILING OF PRETRIAL STATEMENTS UNTIL COUNSEL HAVE CERTIFIED THAT DISCOVERY IS COMPLETE, OR OTHERWISE AT THE MASTER'S DISCRETION. AFTER RECEIVING THIS DOCUMENT FROM BOTH COUNSEL OR A PARTY TO THE ACTION, IF NOT REPRESENTED BY COUNSEL, INDICATING THAT DISCOVERY IS NOT COMPLETE, THE DIRECTIVE FOR FILING OF PRETRIAL STATEMENTS WILL BE ISSUED AT THE MASTER'S DISCRETION. HOWEVER, IF BOTH COUNSEL, OR A PARTY NOT REPRESENTED, CERTIFY THAT DISCOVERY IS COMPLETE, A DIRECTIVE TO FILE PRETRIAL STATEMENTS WILL BE ISSUED IMMEDIATELY. THE CERTIFICATION DOCUMENT SHOULD BE RETURNED TO THE MASTER'S OFFICE WITHIN TWO (2) WEEKS OF THE DATE SHOWN ON THE DOCUMENT. ANDREA M. VATHIS Plaintiff, RANDALL C. VATHIS Defendant. : COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-1151- CIVIL ACTION : 1N DIVORCE . : PRAECIPE TO ENTER APPEARANCE Kindly enter the appearance of Gerald S. Robinson, Esquire on behalf of the Defendant in the above-captioned matter. Respectfully submitted, ROBINSON & GERALDO Date: February 16, 2004 Gerald S. Robinson, Esquire Attorney I.D. No. 27423 4407 North Front Street P.O. Box 5320 Harrisburg, PA 17110 (717) 232-8525 ANDREA M. VATmS, Plaintiff Vs RANDALL C. VATHIS, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02-1151 : : CIVIL ACTION - LAW : IN DIVORCE PRAEC~IPE TO WITHDRAWAl, AN I, Randall C. Vathis, authorize Austin F. Grogan, Esquire, to withdrawal as above captioned divorce. counsel in the Date ANDREA M. VATHIS, Plaintiff V RANDALL C. VATHIS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : 02- 1151 CIVI[LTERM : IN DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE tINDER SECTION 3301(c) OF THE DIVORCE CODE 1. A Complaint in divorce under Section 3301(C) of the Diivorce Code was filed on March 7, 2002. 2. Defendant acknowledges receipt and accepts service of the Complaint on or about March 8, 2002. 3. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 4. I consent to the entry of a final decree of divorce withont notice. 5. 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. 6. 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. 7. I have been advised of the availability of marriage counseling and understand that I may request that the Court require counseling. I do not request that the Court require counseling. I verify that the statements made in this affidavit are true and ,correct. 1 understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Andrea M. Vathis, Plaintiff ANDREA M. VATHIS, Plaintiff V RANDALL C. VATHIS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : 02- 1151 CIVIL TERM : : IN DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION ~[O REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. A Complaint in divorce under Section 3301(C) of the Divorce Code was filed on March 7, 2002. 2. Defendant acknowledges receipt and accepts service of the Complaint on or about March 8, 2002. 3. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 4. I consent to the entry of a final decree of divorce without notice. 5. I understand that 1 may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 6. I understand that 1 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. 7. I have been advised of the availability of marriage connseling and understand that 1 may request that the Court require counseling. I do not request that the Court require counseling. 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: ~ q~o'V/ ANDREA M. VATHIS, Plaintiff vs. RANDALL C. VATHIS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02 - 1151 CIVIL IN DIVORCE 2004, ORDER OF COURT AND NOW, this /~ the parties and counsel having day of entered ifto an agreement and stipulation resolving the economic issues on June 1, 2004, the date set for a conference, the agreement and stipulation having been transcribed, the appointment of the Master is vacated and counsel can conclude the proceedings by the filing of a praecipe to transmit the record with the affidavits of consent of the parties so that a final decree in divorce can be entered. BY THE COURT, cc: ~ubert X. Gilroy Attorney for Plaintiff w~erald S. Robinson Attorney for Defendant ANDREA M. VATHIS, Plaintiff VS. RANDALL C. VATHIS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAN£1 COUNTY, PENNSYLVANIA : : NO. 02 - 1151 CIVIL : IN DIVORCE THE MASTER: This is the date set parties in the above Today is Tuesday, June 1, 2004. for a conference with counsel and the captioned divorce proceedings. Present in the hearing room are the Plaintiff, Andrea M. Vathis, and her counsel Hubert X. Gilroy, and the Defendant, Randall C. Vathis, and his counsel Gerald S. Robinson. Mr. Robinson entered his appearance on behalf of the Defendant on February 16, 2004; Mr. Grogan withdrew by praecipe dated February 14, 2004. 2002, A complaint in divorce was filed on March 7, raising grounds for divorce of irretrievable breakdown of the marriage. The Master has been provided affidavits of consent and waivers of notice of intention to request entry of divorce decree so that the divorce can be concluded Section 3301(c) of the Domestic Relations Code. The complaint did not raise any economic claims. On November 1, 2002, the Defendant filed an answer and new matter. In new matter a claim for equitable distribution was raised. No claims have been raised by either party for alimony or counsel fees and expenses. The Master has been advised that after negotiations this morning the parties have reached an agreement with respect to the equitable distribution claim. The agreement is going to be placed on the record in the presence of the parties. The agreement as placed on the record will be considered the substantive agreement of the parties not subject to any changes or modifications except for correction of typographical errors which may be made during the transcription. Counsel have indicated that because the agreement is fairly simple in its context that they do not believe it is necessary for the parties to return later today to affirm the agreement by signing the transcribed document. Consequently, we will present the document to the Court without the signatures of the p~rties affirming the settlement. However, following the statement of the agreement on the record the parties will have an opportunity to assent record. to the terms of the settlement as stated on the they are, even though they have not affixed their document. The Master will prepare When the parties leave: the hearing room today therefore, bound by the terms of the agreement signatures to the an order for the Court's signature vacating his appointment. Counsel will then be in a position to file a praecipe transmitting the record to the Court requesting a final decree in divorce. The Master's office will also file the affidavits of consent and waivers of notice of intention to request entry of divorce decree which have been provided to the Master this morning. Mr. Gilroy. MR. GILROY: The agreement between the parties is as follows: 1. The parties waive all further claims of equitable distribution, and acknowledge that the property in the possession of Mr. Vathis shall be his sole property and the property in possession of Mrs. Vathis shall be her sole property. 2. There exists an escrow fund totalling $54,794.12. The parties agree that that escrow fund shall be distributed with the payment of $25,500.00 to Mr. Vathis and a payment of $29,294.12 to Mrs. Vathis. 3. The above two provisions completely satisfy all equitable distribution claims between the parties. 4. Except as herein otherwise provided, each party may dispose of his or her property in any way and each party hereby waives and relinquishes any and all rights he or she may now have or hereafter acquire under the present or future laws of any jurisdiction to share in the property or the estate of the other as a result of the marital relationship including without limitation, statutory allowance, widow's allowance, right of intestacy, right to take against the will of the other, and right to act as administrator or executor in the other's estate. Each will at the request of the other execute, acknowledge, and deliver any and all instruments which, may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interest, rights, and claims. MR. GILROY: I beliew~ that to be the settlement between the parties. Mrs. Vathis, of that settlement? MRS. MR. VATHIS: GILROY: you are satisfied with the terms Yes. And you agree to the terms and acknowledge that you are not coming back here to review this transcript or to sign in any way? MRS. VATHIS: No. MR. GILROY: And you are ready to get a divorce? MRS. VATHIS: Yes. MR. GILROY: And you are ready to split up the money as indicated? MRS. VATHIS: Yes. MR. ROBINSON: You've heard what we are asking you to agree to, are you satisfied with how the property has been divided? MR. VATHIS: Yes. MR. ROBINSON: You agree that a divorce should be entered? MR. VATHIS: Oh, yes. MR. ROBINSON: I have nothing further. cc: Hubert X. Gilroy, Attorney for Plaintiff Andrea M. Vathis, Plaintiff Gerald S. Robinson, Attorney for Defendant Randall C. Vathis, Defendant ANDREA M. VATHIS, Plaintiff RANDALL C. VATHIS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 02- 1151 CIVIL : : ACTION IN DIVORCE NOTICE OF ELECTION TO RETAKE FORMER NAME Notice is hereby given that the Plaintiff in the above matter, having been granted a Final Decree in divorce from the bonds of matrimony on the day of ,2004, hereby elects to retake and hereafter use her previous ~ame of Andrea Marie Lacy. Andrea Marie Vathis To Be Known As: Andrea Marie Lacy COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND On the ~ day of . L~L~...~. appeared Andrea Marie Vathis, known the within document, and acknowledged that she executed the foregoing for the purpose therein contained. , 2004, before me, a Notary Public, personally to me to be the person whose name is subscribed to IN WITNESS WHEREOF, I have hereunto set my hand and notarial seal. Notary Public Notarial Seal I Bridget Ann Corcoran, Nota~ Public Carlisle Boro, Cumberland County My Commission Expires June 10, 2006 Member, PennsyNania Association ~ Notafle~ ANDREA M. VATHIS, Plaintiff V RANDALL C. VATHIS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02-1151 CIVIL : : CIVIL ACTION - LAW : AFFIDAVIT OF SERVICE 1, Hubert X. Gilroy, being duly sworn according to law do depose and state that a copy of the Complaint and Notice to Plea filed in the above referenced matter was served on Defendant's Attorney, Austin F. Grogan, Esquire, by certified mail on March 8, 2002. A copy of the Affidavit of Acceptance of Service, is attached hereto and marked Exhibit A. ub~ X. G'~,oy, Esquire Attorney f~ Plaintiff Bronjos_~_ Gilroy~ P.C. 4 North Hanover Street Carlisle, PA 17013 717 - 243-4574 Sworn and subscribed before mc this I (t I~ day Notary Pt~blic Notadal Seal Bridget Ann Corcoran Notary Public Carlisle Bom, Cumberland County My Commission Expires June 10, 2006 ANDREA M. ~aintiff~> V. RANDALL C. VATHIS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-1151 !-' CIVIL ACTION - LAW . IN DIVORCE AFFIDAVIT OF ACCEPTANCE OF SERVICE I, Austin F. Grogan, Esq., accept service of the Divorce Complaint on behalf of Randall C. Vathis, Defendant, in the above-captioned case and verify thai: I am authorized to do so. 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 Respectfully submitted, Camp Hill, PA 170IL1 (717) 737-1956 Attorney for Defendant ID # 59020 ANDREA M. VATHIS, Plaintiff v RANDALL C. VATHIS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : 02-1151 CIVIL TERM · IN DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER .SECTION 3301(c) OF THE DIVORCE CODE 1· A Complaint in divorce under Section 3301 (C) of the Divorce Code was filed on March 7, 2002. 2. Defendant acknowledges receipt and accepts service of the Complaint on or about March 8, 2002. 3. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 4. I consent to the entry of a final decree of divorce without notice. 5. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI do not claim them before a divorce is granted. 6. 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. 7. I have been advised of the availability of marriage counseling and understand that I may request that the Court require counseling. I do not request that the Court require counseling. 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: Andrea M. Vathis, Plaintiff ANDREA M. VATHIS, Plaintiff v RANDALL C. VATHIS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02-1151 CIVIL : CIVIL ACTION - LAW 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 (x)3301(c) ()3301(d)(1) of the Divorce Code. (Check applicable section.) 2. Date and manner of service of the Complaint: March 8, 2002, by Affidavit of Acceptance of Service by Austin F. Grogan, Esquire, attorney for Defendant Randall C. Vathis. 3. (Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent reqnired by Section 3301(c) of the Divorce Code: By Plaintiff: June 1, 2004; Defendant: June 1, 2004. (b) (1) 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: None. 5. Complete either (a) (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 Plaintiff's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: June 15, 2004. (c) Date Defendant's Waiver of Prothonotary: June 1, 2004. ~vorce Hubert X. Gilr~, Esquire Attorney fo~Plaintiff Broujos~& Gilroy, PC 4 North Hanover Street Carlisle, PA 17013 717-243-4574 was filed with the 1N THE cOUrt OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF ~ PENNA. ANDREA M. VATHIS Plaintiff VERSUS RANDALL C. VATHIS Defendant NO. 02 - 1151 DECREE IN DIVORCE AND NOW,~~T~~'~, ~ IT IS ORDERED AND DECREED THAT ANDREA M. VATHIS , PLAINTIFF, AND RANDALL C. VATHIS , 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 WHIDH A FINAL ORDER HAS NOT YET BEEN ENTERED; BiTHE CO : ATTEST: /~ . [ /~ j. ~___~L~-: l~ROThONOTary