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HomeMy WebLinkAbout06-1123SANDRA I.REHM, vs. : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA No. 06 - 103 Civil Term RALPH J. REHM, JR., Defendant ACTION 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. Where the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage coimseling. A list of marriage counselors is available at the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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 St. Carlisle, Pa. 17013 (717) 249-3166 SANDRA I. REHM, vs. : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA RALPH J. REHM, JR., Defendant No. O io - /1.23 Civil Term ACTION IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Sandra I. Rehm, a competent adult individual, who has resided at 203 Forge Rd., Boiling Springs, Cumberland County, Pennsylvania, since 17007. 2. Defendant is Ralph J. Rehm, Jr., a competent adult individual, who resides at 39 Queen Ave., Enola, Pa. 17025. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on October 27, 1973 in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. 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. 7. Plaintiff and Defendant have six children together; however, five are adults. 8. Plaintiff and Defendant are both citizens of the United States of America. 9. Neither Plaintiff or Defendant are a member of the Armed Forces of the United States of any of its allies. 10. The Plaintiff avers that the grounds on which this action is based are: That the marriage is irretrievably broken. WHEREFORE, Plaintiff requests the court to enter a decree in divorce. I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unworn falsification to authorities. ? ?,(,n dh c.. ? , j r Sandra I. Rehm, Plai ti Respectfully submitted, Date: JJanedams , Esquire 79 465 Pitt Street Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF ri ? c ?" ?" ? ._' rr u ?, :? 1. C` a .. U ? ? C ? ? o-, O ??i r ??1 SANDRA I. REHM, VS. : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA RALPH J. REHM, JR., Defendant No. 06 - 1123 Civil Term ACTION IN DIVORCE AFFIDAVIT OF SERVICE AND NOW, this March 7, 2006, I, Jane Adams, Esquire, hereby certify that on March 4, 2006, a certified true copy of the NOTICE TO DEFEND AND COMPLAINT IN DIVORCE were served, via certified mail, return receipt requested, addressed to: Ralph J. Rehm, Jr. 39 Queen Ave. ' • ' ' ' Enola, Pa. 17025 ¦ Complete items 1, 2, and 3. Also complete DEFENDANT 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. 1. Article Addressed to: ?l ? ??E ?U la V E E? o?w Pfd ?'10?5 X ? Agent B. RecAVed by Name) C. to of Delivery D. Is delivery address tlifferent fro item 19 ?,?r Y'e's If YES, enter delivery address below: tcylvo 3. Service Type )91- ifiad Mail 0 Express Mail ? Registered 0 Return Receipt for Merchandise 0 Insured Mail 0 C.O.D. 4. Restricted Delivery? (Extra Fee) Nil-yes 2. Article Number om service label) 7004 1350 0003 7288 4707 (Transfer from PS Form 3811, February 2004 Domestic Return Receipt 102595-02-M-1540 : ?- IXIN ?V L J J Adams, Esquire U.D. No. 79465 outh Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF Theresa Barrett Male Supreme Court # 46439 513 North Second Street Harrisburg, PA 17101 (717) 233-3220 tbm@tbmesquire.com Counsel for Defendant COURT OF SANDRA I. REHM Plaintiff V. RALPH J. REHM, JR. Defendant To the Prothonotary: Please enter Defendant in this proc MMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-1123 Civil Term CIVIL ACTION - DIVORCE PRAECIPE e appearance of Theresa Barrett Male, Esquire on behalf of i ng. Theresa Barrett Male, Esquire Supreme Court # 46439 513 North Second Street Harrisburg, Pennsylvania 17101 (717) 233-3220 Counsel for Defendant Date: June 1, 2006 . ...? 1 O nJ4J 07, ti SANDRA I. REHM, VS. IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA RALPH J. REHM, JR., Defendant No. 06 - 1123 Civil Term ACTION IN DIVORCE NOTICE If you wish 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. AFFIDAVIT OF SEPARATION 1. The parties to this action separated on June 1, 2005 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 my rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 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: Sandra I. Rehm, Plaintiff c? W SANDRA I. REHM, vs. IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA RALPH J. REHM, JR., Defendant : No. 06 - 1123 Civil Term ACTION IN DIVORCE THIS AGREEMENT, made this / 1?- day of , 2007, by and between, SANDRA I. REHM, of Boiling Springs, Pennsylvania, h emafter referred to as 11 nrr+r t t7 A T PITT n •, T* ,: + r. +. P- `-j''?n"' h re:?aft r r:°` `. a v? tr L. , and' R ?L r t i J. "HUSBAND". WITNESSETH: WHEREAS, Husband and Wife were lawfully married on October 27, 1973, in New Cumberland, Pennsylvania, and; WHEREAS, there were six born of this marriage, all of which are now adults; WHEREAS, differences, disputes, and difficulties have arisen between the parties and it is the intention of Husband and Wife to live separate and apart for the rest of their natural lives, and the parties desire to settle their respective financial property rights and obligations as between each other, including the settling of all matters between them relating to ownership and equitable distribution of real and personal property; the settling of all matters between them relating to the past, present, and future support, alimony, and/or maintenance of Husband or Wife, and in general, the settling of any and all possible claims by one against the other or against their respective estates; NOW THEREFORE; Wife and Husband, each intending to be legally bound. hereby agree as follows: + . FULL DISCLOSURE OF ASSETS. Each party warrants that he or she has made a full and fair disclosure of income, assets, and their valuation prior to the execution of this Agreement as well as any other fact relating in any way to the subject matter of this agreement. These disclosures are part of the consideration made by each party for entering into this agreement. 2. ADVICE OF COUNSEL. The Husband has employed and had the benefit or counsel of Theresa Barrett Male, Esquire, as his attorney. The Wife has employed and had the benefit or counsel of Jane Adams, Esquire, as her attorney. Each party has carefully and completely read this agreement and has been advised and is completely aware not only of its contents but of its legal effect. 3. SEPARATION. The parties intend to maintain separate and permanent domiciles and to live apart from each other. It is the intention and purpose of this agreement to set forth their respective rights and duties while they continue to live apart from each other. Neither party shall harass, annoy, injure, threaten, or interfere with the other party in any manner whatsoever. Each party may carry on and engage in any employment, profession, business or other activity as he or she may deem advisable. Neither party shall interfere with the uses, ownership, enjoyment, or disposition of any property now owned and not specified herein or property hereafter acquired by the other. 4. SUBSEQUENT DIVORCE. The parties hereby acknowledge that Wife has filed a Complaint in Divorce in Cumberland County, Pennsylvania, claiming that the marriage is irretrievably broke I expresses his infent to emeente any and all affidavits or othe. doetunents hparties hereby waive all rights to request Court Ordered counseling under the Divorce Code. The provisions of this Agreement relating to equitable distribution of property of the parties are accepted by each party as a final settle t for all purposes ? whatsoever, as O contemplated by the Pennsylvania Divorce C*seara -&M fe intends proceed under section 3301(d). Should a decree, judgment, or order oion 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 or revision thereof shall alter, amend, or vary any term of this Agreement, whether or not either or both of the parties shall remarry. It is specifically agreed that a copy of this Agreement or the substance of the provisions thereof, may be incorporated by reference into any divorce, judgment, or decree. This incorporation 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. 5. DATE OF EXECUTION. The "date of execution" or "execution date" of this agreement shall be defined as the date upon which it is executed by the parties if they have each executed the Agreement on the same date. Otherwise, the "date of execution" or "execution date" of this Agreement shall be defined as the date of execution by the party last executing this Agreement. All provisions of this agreement shall be effectuated by the parties within thirty (30) days of the execution date of this agreement unless otherwise specified within this agreement. 6. MUTUAL RELEASE OF ALL CLAIMS. Other than as provided in this agreement, each parry may dispose 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. 7. WARRANTY OF DEBTS AND FUTURE OBLIGATIONS. Each party warrants that they have not contracted any debt or liability for the other or which the estate of the other party may be responsible or liable, and except only for the rights arising out of this agreement, neither party will hereafter incur any liability whatsoever for which the other party or the estate of the other party, will be liable. Each party agrees to indemnify or hold harmless from the other and against all future obligations of every kind incurred by them, including those for necessities. 8. EQUITABLE DIVISION OF MARITAL PROPERTY. The parties have attempted to distribute their marital property in a manner which conforms to the criteria set forth in 23 Pa.C.S.A. s3501 et. seq. and taking into account the following considerations: the length of the marriage, the age, health, station, amount, and sources of income, vocational skills, employability, estate, liabilities, and needs of each of the parties, the contribution of each party to the education, training, or increased earning power of the other party; the opportunity for 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 party in the acquisition, preservation, depreciation, or appreciation of the marital property, including the contribution of each spouse as a homemaker; the value of the property set apart to each party; the standard of living the parties established during the marriage; and the economic circumstances of each party at the time the division of property is to become effective. 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 effected without the introduction of outside funds or other property not constituting marital property. The division of property under this Agreement shall be in full satisfaction of all the marital rights of the parties. As such, the parties acknowledge that Husband or Wife's obligation to make the payments defined in this agreement shall not be subject to termination, discharge, or discontinuance in bankruptcy or for any other reason or by any Court or tribunal. Should Husband or Wife pursue and action in bankruptcy and be successful in extinguishing his obligation to pay any debts for which he has assumed sole obligation as set forth herein, he or she shall immediately be obligated to pay alimony to the other party in an amount equal to the monthly obligation on such debts that he or she otherwise had assumed and for which he had taken sole obligation and responsibility, plus an additional fifteen percent (15%) in consideration of the tax consequences associated with receipt of alimony. At the time of the implementation of this alimony award, which may be made through the appropriate Domestic Relations of support office with the Court of Common Pleas of appropriate jurisdiction as Husband or Wife may select, such party shall then be responsible for any such debts extinguished through the other party's bankruptcy as described herein. 9. OTHER PERSONAL PROPERTY. Husband and Wife do hereby acknowledge that they have previously divided all their tangible personal property. Except as may otherwise be provided in this Agreement, Wife agrees that all of the property of Husband or in his possession shall be the sole and separate property of Husband; and Husband agrees that all of the property of Wife or in her possession shall be the sole and separate property of Wife. The parties do hereby specifically waive, release, renounce, and forever abandon whatever claim, if any, he or she may have with respect to the above items which shall become the sole and separate property of the other. 10. MOTOR VEHICLES. Each party shall retain the respective motor vehicles in their possession and shall be responsible for any amounts owing against each vehicle. The titles to the said motor vehicles shall be executed by the parties, if appropriate for effecting transfer as herein provided, within thirty days of the execution date of this Agreement, and said executed titles shall be delivered to the proper parties on the distribution date. 11. MARITAL HOME. HUSBAND and WIFE hold title as Tenants by the Entireties to the premises identified as 203 Forge Road, Boiling Springs, Cumberland County, Pennsylvania, 17070. The parties agree as follows with respect to the marital residence: (a) Husband shall continue to pay timely the monthly mortgage payments on the marital residence. Husband will satisfy the mortgage within twelve (12) months of date on which the parties execute this agreement. If he is able to do so, Husband will satisfy the mortgage within an earlier time frarnG?.Upon Wife's counsel forwarding the deed, Husband shall, within ten (10) days, execute and deliver such deed, conveying to Wife, all of his right, title and interest in and to the marital residence. Wife shall pay for the preparation and filing of the deed to the marital home. (b) Wife acknowledges that Husband has paid the homeowner's insurance and real estate taxes; which are escrowed in the mortgage payment, after the parties separated. From and after the date of this agreement, Wife shall be solely responsible for these expenses. If necessary, she will reimburse Husband1for such expenses upon proof of such amounts which are currently escrowed into the mortgage payment. Additionally, within fourteen (14) days of recording the deed, Wife shall provide written confirmation to Husband that ,A(ff she has removed his name from the homeowner's policy. Wife also shall indemnify and L? JJ hold harmless Husband from all fines, penalties and assessments related to improvements made to the marital residence for which Wife should have secured building permits, lic fe??n??1 es, or other municipal gpve ?tal a prov?l. ?? (c) As of the date of separation, and without regard to when bills for such items are incurred, received or due, Wife shall be solely responsible for all past, present, and future costs or liabilities associated with or attributable to maintaining the marital residence (except as provided herein), including but not limited to, water and sewer rents, gas, electric, and telephone service, and gardening xpenses and repairs, and Wife shall keep ?? S I w ' Husband and his successors, assigns, heirs, executors, and administrators indemnified and held harmless from any liability, cost or expense, including attorney's fees, which are incurred in connection with such maintenance, costs, and expense. 12. MUTUAL WAIVER OF EMPLOYMENT BENEFITS. The parties agree to waive any and all rights they have in and to each other's employment benefits, including but not limited to both parties pensions and retirement plans and Incentive Savings Plans. The parties agree never to assume any claim to such benefits of the other at any time in the future. 13. ALIMONY, ALIMONY PENDENTE LITE and LEGAL FEES. Other than as provided in this agreement, each party hereby waives any right to spousal support, alimony, or alimony pendente lite, and each party agrees to be responsible for his or her own legal fees and expenses. The parties herein acknowledge that by this Agreement, they have respectively secured and maintained a substantial and adequate fund with which to provide for themselves sufficient financial resources to provide for their comfort, maintenance, and support in the station of life to which they are accustomed. Wife and Husband do hereby waive, release, and give up any rights they may respectively have against the other for alimony, support, or maintenance. It shall be from the execution of this Agreement the sole responsibility of each of the respective parties to sustain themselves without seeking any support from the other party. All alimony to be paid under this agreement shall terminate upon the recipient's remarriage or cohabitation with a person of the opposite sex. 14. INCOME TAX RETURNS. Husband and wife represent to each other that to the best of their knowledge all federal, state, and local taxes required to paid with during the marriage and during the periods covered by such tax returns have been paid. Husband and Wife further represent that there are no tax deficiencies proposed or assessed against Husband and/or Wife for such periods, and neither Husband nor Wife executed any waiver of the Statute of limitations on the assessment or collection of any tax for such periods. If any deficiency in federal, state, or local income taxes is proposed, or any assessment of any such tax is made against the other party by reason of his or her having joined in the filing of joint federal, state or local income tax returns, Husband and Wife shall indemnify and hold harmless the other against and from any and all tax, interest, penalty, or expense relating from any such tax deficiency, including reasonable counsel and accounting fees, and such tax, interest, and penalties or expenses shall be paid solely and entirely by the responsible party as determined to be attributable to that party on account of misrepresentation or failure to disclose relevant information of income on the aforesaid joint returns. 15. WAIVER OR MODIFICATION TO BE IN WRITING. No modification or waiver of any of the terms hereof shall be valid unless in writing and signed by both parties, and no waiver of any breach hereof or default hereunder shall be deemed a waiver of any subsequent default of the same or similar nature. 16. MUTUAL COOPERATION. Each parry shall, at any time and from time to time hereafter, take any and all steps and execute, acknowledge, and deliver to the other party any and all further instruments and/or documents that the other party may reasonably require for the purpose of giving full force and effect to the provisions of this Agreement. 17. APPLICABLE LAW. The Agreement shall be construed in accordance with the laws of the Commonwealth of Pennsylvania which are in effect as of the date of execution of this Agreement. 18. INTEGRATION. This Agreement constitutes the entire understanding of the parties and supersedes any and all prior agreements or negotiations between them. There are no representations or warranties other than those expressly set forth herein. 19. OTHER DOCUMENTATION. Wife and Husband covenant and agree that they will forthwith execute any and all written instruments, assignments, releases, satisfactions, deeds, notes, or such other writings as may be necessary or desirable for the proper effectuation of this Agreement. 20. NO WAIVER OF DEFAULT. This Agreement shall remain in full force and effect unless and until terminated under and pursuant to the terms of this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall in no way affect the right of such party hereafter to enforce the same, nor shall the waiver of any default or breach of any provision hereof by construed as a waiver of any subsequent default or breach of the same or similar nature, not shall it be construed as a waiver or strict performance of any other obligations herein. 21. SEVERABILITY. 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 provisions shall be stricken from this Agreement; and in all other respects, this Agreement shall be valid and continue in full force, effect, and operation. Likewise, the failure of any party to meet his or her obligations under any one or more of the paragraphs herein, with the exception of the satisfaction of the conditions precedent, shall in no way avoid or alter the remaining obligations of the parties. 22. BREACH. If either party breaches any provisions of this agreement, the other party shall have the right, at his or her election, to sue for damages for such breach, or seek other remedies or relief as may be available to him or her, and the party breaching this contract should be responsible for payment of legal fees and costs incurred by the other in enforcing their rights under this agreement. 23. INFORMED AND VOLUNTARY EXECUTION. Each party to this agreement acknowledges that he or she is fully informed as to the facts relating to the subject matter of this agreement, is entering into this agreement voluntarily, free from fraud, undue influence, coercion or duress of any kind, has given careful thought to the making of this agreement, has carefully read each provision of this agreement, and fully and completely understands each provision of this agreement. IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the day and year first above written: WITNESS: Theresa Barrett Male, Esquire 513 N. Second St. Harrisburg, Pa. 1710!-1058 (717) 233-3220 Attorney for Husband alp J. R us and Date: Ja9f Adams, Esquire PittSt. C lisle, Pa. 17013 17) 245-8508 Attorney for Wife - ""W' '/ 4, Sandra I. Rehm, Wife Date: q • '? , /-/ c'> ? a c _. Fr; ` r?- ` C1 SANDRA I. REHM, Plaintiff vs. RALPH J. REHM, JR., AND NOW, this July 3, on June 7, 2007, a certified true AFFIDAVIT were served, via Theresa Barrett Male, Esquire 513 N. 2nd St. Harrisburg, Pa., 17101 DEFENDANT ¦ C ¦ Pri era ¦ AM 1 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 06 - 1123 Civil Term is : ACTION IN DIVORCE AFFIDAVIT OF SERVICE 7, I, Jane Adams, Esquire, hereby certify that of the AFFIDAVIT OF SEPARATION and COUNTER- ified mail, return receipt requested, addressed to: "sto Items 1, 2, and 3. Also complete 4 if estric?ted Delivery is desired. roar name and address on the reverse tt w can return the card to you. i th card to the back of the mailpiece, the If space permits. Addressed to: A. SWneture x r-'? n M T--t' B. Received by (Printed Nwm)l 1 C. Date D. Is delvery address different from Item 1? ? 'M If YES, enter delivery address below: ? No TB R4A BARRETT MALE ESQ 513 N,2nd ST HARRISBURG PA 17101 - AW 5c2 14. Re.11,1 d Deft W 05ft Fee) ? Vis 2. AtieleNumber 7007 0220 0002 2522 2229 M1010I11irfrom Service lab. _ Ps Form 3811, February tow Domestic Return Receipt toxoee eaa,t tseo Respectfully Submitted: 9.Dan. e Adams, Esquire No. 79465 64 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF 3I service Iwo Owtllled Mail C1 Express Mall 41Rvistered 13 Return Receipt for Merolmrdiee 0 ktwend mail 0 c.o.D. C - ? rr? cn .C- SANDRA I. REHM, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 06 - 1123 Civil Term RALPH J. REHM, JR., ACTION IN DIVORCE Defendant NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE. TO. Ralph Rehm, Defendant c/o Theresa Barrett Male, Esquire 513 N. 2"d St. Harrisburg, Pa. 17101 Plaintiff, Sandra I. Rehm, intends to file with the Court the Attached Praecipe to Transmit Record on or after July 23, 2007, requesting that a final decree in Divorce be entered. Respectfully submitted: Date: 7/3/07 tD eAdams, Esquire . No. 79465 64 South Pitt St. Carlisle, Pa. 17013 ATTORNEY FOR PLAINTIFF rm Z N ?'? tSE Qd r SANDRA I. REHM, Plaintiff VS. RALPH J. REHM, JR., Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 06 - 1123 Civil Term ACTION IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: decree: Transmit the record, together with the following information to the Court for entry of a divorce 1. Ground for divorce: irretrievable breakdown under 43301(d) of the Divorce Code. 2. Date and manner of the service of the Complaint: Delivered by certified mail, restricted delivery return receipt requested on or about March 4 2006 3. Date of execution of the affidavit required by §3301(d) of the Divorce Code: By Plaintiff June 1. 2007 Date of filing and service of the plaintiffs affidavit of separation required by §3301(d) of the Divorce Code on respondent: Filed: June 1.2007. Served on Defendant: June 7. 2007 Affidavit of Service filed: July 3. 2007 4. Related claims pending: None. 5. Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which was filed of record with the Prothonotary: Served on or about July 3. 2007 via certified mail, return receipt requested. Respectfully Submitted: Date: Jane Adams, Esquire I.D. No. 79465 64 S. Pitt St. Carlisle, Pa. 17013 (717) 245-8508 Attorney for Plaintiff SANDRA I. REHM, Plaintiff VS. RALPH J. REHM, JR., Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : No. 06 - 1123 Civil Term ACTION IN DIVORCE AFFIDAVIT OF SERVICE AND NOW, this September 25, 2007, I, Jane Adams, Esquire, hereby certify that on July 6, 2007, a certified true copy of the NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE was served, via certified mail, return receipt requested, addressed to: Theresa Barrett Male, Esquire 513 N. 2nd St. Harrisburg, Pa., 17101 DEFENDANT ¦ Complieta i[on'1, 2,;and& l?oc9mpilete item 4 If f i!d i lieft?4d' demd. ¦ Print your ww1 on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mailpiece, or on theftnt if space permits. 1. Article Addressed to: by (ft*xf" ,I ggWp of Dabwry D. R deft iy address dlfererrt fmm Item 1? O Yin K YES, enter deiivery addnrse below: 0 No THVR'RSA BARRETT MALE ESQ 513N 2nd ST HARROISBURG PA 17101 Service Type ApMs~ 0 Erq M Mail 0 Return Receipt for MetdwxNso 0 inatved Md 0 C.O.D. 4. 14e0lated Dawyl 01oft AW ? ym 2. Artide"umber 7007 0220 0002 2522 2366 (rMwer-from servke i ? e6ruary;2(>la4 Dor#estii;iRetum Receipt 100N64E41.1640 Respectfully Submitted: ,?#'e Adams, Esquire D. No. 79465 64 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF ?, ? ?? ?. ?.} 1 - ??? ?r?^'y ? ry ?.+?' ? ? {.? Pr :, ?- ?,. ?_-; fl r SANDRA I. REHM, VS. IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA RALPH J. REHM, JR., Defendant TO THE PROTHONOTARY: : No. 06 - 1123 Civil Term : ACTION IN DIVORCE PRAECIPE TO TRANSMIT RECORD Transmit the record, together with the following information to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under 43301 (d) of the Divorce Code. 2. Date and manner of the service of the Complaint: Delivered by certified mail, restricted delivery, return receipt requested, on March 4, 2006. 3. Date of execution of the affidavit required by §3301(d) of the Divorce Code: By Plaintiff. June 1, 2007 Date of filing and service of the plaintiffs affidavit of separation required by §3301(d) of the Divorce Code on respondent: Filed: June 1, 2007. Served on Defendant: June 7, 2007 Affidavit of Service filed: July 3, 2007 4. Related claims pending: None. 5. Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which was filed of record with the Prothonotary: Served on or about July 6, 2007, upon Defendant's Attorney, via certified mail. Submitted: Date: ? " a ?5- - / Ate Adams, Esquire rNo. 79465 64 S. Pitt St. Carlisle, Pa. 17013 (717) 245-8508 Attorney for Plaintiff Q ce IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Aft STATE OF PENNA. Sandra 1. Rehm, Plaintiff NO. No. 06 - 1123 Civil Term VERSUS Ralph J Rehm Jr., Defendant DECREE IN DIVORCE AND NOW; oCTA- x .-y.'orA?,, ,?0?, IT IS ORDERED AND DECREED THAT Sandra 1Rehm PLAINTIFF, AND Ralph J. Rehm, Jr. 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; The marriage settlement agreement which was filed and signed by the parties on on May 7, 2007, shall be incorporated and not into this Decree. BY ATTEST: J. PROTHONOTARY 6 °r .V .