HomeMy WebLinkAbout06-1245
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
DAVID W. ALEXANDER,
Plaintiff,
v.
CIVIL ACTION - LAW
2006 - I J.l.J.5 CIVIL TERM
CHARLOTTE M. ALEXANDER,
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 maniage,
you may request maniage counseling. A list of maniage 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
1-800-990-9108
AMERICANS WITH DISABILITIES
ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with
Disabilities Act of 1990. For infonnation about accessible facilities and reasonable accommodations available to
disabled individuals having business before the court, please contact our office. AU arrangements must be made at
least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or
hearing.
DAVID W. ALEXANDER,
Plaintiff,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2006 -/J.'iS CIVIL TERM
CHARLOTTE M. ALEXANDER,
Defendant.
IN DIVORCE
COMPLAINT IN DIVORCE PURSUANT TO
SECTIONS 3301(C) AND illl OF THE DIVORCE CODE
AND NOW, comes the Plaintiff, David W, Alexander, by and through his attorneys, Irwin,
& McKnight, and files this Complaint in Divorce against the Defendant, Charlotte M. Alexander,
representing as follows:
1. The Plaintiff is David W. Alexander, an adult individual residing at 511 North
Bedford Street, Carlisle, Cumberland County, Pennsylvania 17013.
2. The Defendant is Charlotte M. Alexander, an adult individual currently residing at
511 North Bedford Street, Carlisle, Cumberland County, Pennsylvania 17013.
3. The Plaintiff and Defendant have been residents of the Commonwealth of
Pennsylvania at least six months prior to the filing of this action in divorce.
4. The Plaintiff and the Defendant were married on October 25, 1997 in Mifflin
County, Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the parties.
6. Pursuant to the Divorce Code, Sections 3301(c) and 3301(d), the Plaintiff avers as
the grounds upon which this action is based that the marriage between the parties is irretrievably
broken.
7. The Plaintiff avers that she has been advised of the availability of counseling and
that said party has the right to request that the court require the parties to participate in
counseling.
WHEREFORE, the Plaintiff respectfully requests judgment dissolving the marriage
between the two parties.
Respectfully submitted,
IRWIN & McKNIGHT
Date: March 3, 2006
VERIFICATION
The foregoing Complaint in Divorce is based upon information which has been gathered
by counsel and myself in the preparation of this action. I have read the statements made in this
document and they are true and correct to the best of my knowledge, information and belief. I
understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section
4904, relating to unsworn falsification to authorities.
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DAVID W. ALEXANDER
Date: March 3, 2006
DAVID W. ALEXANDER,
Plaintiff,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2006 - / ~ ".: CIVIL TERM
CHARLOTTE M. ALEXANDER,
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.
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DAVID W. ALEXANDER
Date: March 3, 2006
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DAVID W. ALEXANDER,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
2006 - 1245 CIVIL TERM
CHARLOTTE M. ALEXANDER,
Defendant
IN DIVORCE
ACCEPTANCE OF SERVICE
I, CHARLOTTE M. ALEXANDER, the defendant in the above-captioned divorce
action, hereby verify that I have accepted service of the Complaint in Divorce filed under
Sections 3301(c) and 3001(d) of the Divorce Code on March 3, 2006
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'~OTTE M. 'ALE NDER
Date: March 3, 2006
t/.,. -..
COMMONWEALTH OF PENNSYLVANIA
SS:
COUNTY OF CUMBERLAND
On this, the 3rd day of March 2006, before me, the undersigned officer, personally
appeared CHARLOTTE M. ALEXANDER, known to me to be the person whose name is
subscribed to the above instrument and acknowledge that she executed same for the purposes
therein contained.
COMMONWEALTH OF PENNSYLVANIA
NollIllII SeIII
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MARRIAGE SETTLEMENT AGREEMENT
THIS AGREEMENT made this
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/lwi
, 2006, by and
between CHARLOTTE M. ALEXANDER, (hereinafter referred to as "WIFE") and DAVID
W. ALEXANDER, (hereinafter referred to as "HUSBAND").
WITNESSETH:
WHEREAS, HUSBAND and WIFE were lawfully married on October 25, 1997, in
Mifflin County, Pennsylvania. HUSBAND filed a Complaint in Divorce in Cumberland County,
Pennsylvania, docketed at 2006- ,? Lt 5" Civil Term on March 3, 2006. The parties hereto
agree and covenant as follows:
1.
The parties intend to maintain separate and permanent domiciles and to live apart from
each other. It is the intent and purpose of this Agreement to set forth the respective rights and
duties of the parties while they continue to live apart from each other.
2.
The parties have attempted to divide their matrimonial property in a manner which
conforms to a just and right standard, with due regard to the rights of each party. It is the intent
of the parties that such division shall be final and shall forever determine their respective rights.
The division of existing marital property is not intended by the parties to constitute in any way a
sale or exchange of assets.
3.
Further, the parties agree to continue living separately and apart from the other at any
place or places that he or she may select as they have heretofore been doing. Neither party shall
molest, harass, annoy, injure, threaten or interfere with the other party in any matter whatsoever.
Each party may carry on and engage in any employment, profession, business or other activity as
he or she may deem advisable for his or her sole use and benefit. 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.
The consideration for this contract and agreement is the mutual benefit to be obtained by
both of the parties hereto and the covenants and agreements of each of the parties to the other.
The adequacy of the consideration for all agreements herein contained is stipulated, confessed,
and admitted by the parties, and the parties intend to be legally bound hereby.
Each party to the Agreement acknowledges and declares that he or she, respectively:
(a) is represented by counsel of his or her own choosing;
(b) is fully and completely informed of the facts relating to
the subject matter of this Agreement and of the rights
and liabilities of the parties;
(c) enters into this Agreement voluntarily after receiving the
advice of counsel;
(d) has given careful and mature thought to the making of this
Agreement;
( e) has carefully read each provision of this Agreement; and
(f) fully and completely understands each provision of this
Agreement, both as to the subject matter and legal effect.
This Agreement shall become effective immediately as of the date of execution.
2
5.
It is the purpose and intent of this Agreement to settle forever and completely the interest
and obligations of the parties in all property that they own separately, and all property that would
qualify as marital property under the Pennsylvania Divorce Code, Title 23, Section 401 (e), and
that is referred to in this Agreement as "Marital Property", as between themselves, their heirs and
assigns. The parties have attempted to divide their Marital Property in a manner that conforms to
a just and fair standard, with due 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 effected without the introduction of outside funds or other
property not constituting a part of the marital estate.
It is the further purpose of this Agreement to settle forever and completely any obligation
under the Pennsylvania Divorce Code relating to spousal support or alimony.
6.
Each party represents and warrants that he or she has made a full and fair disclosure to the
other of all of his or her property interests of any nature, including any mortgage, pledge, lien,
charge, security interest, encumbrance, or restriction to which any property is subject. Each party
further represents that he or she has made a full and fair disclosure of all debts and obligations of
any nature for which he or she is currently liable or may become liable. Each further represents
and warrants that he or she has not made any gifts or transfers for inadequate consideration of
Marital Property without the prior consent of the other.
Each party acknowledges that, to the extent desired, he or she has had access to all joint
and separate State and Federal Tax. Returns filed by or on behalf of either or both parties during
mamage.
3
7.
REAL ESTATE: The house located at 511 North Bedford Street, Carlisle, Cumberland
County, Pennsylvania. WIFE agrees to convey her right, title and interest in the property to
HUSBAND. HUSBAND agrees to refinance the mortgage into his own name within one (1)
year from the date this Agreement is signed.
8.
SUPPORT: HUSBAND will not provide spousal support or alimony to WIFE during
the marriage or following the divorce. WIFE waives spousal support or alimony to HUSBAND
following the issuance of the Decree in Divorce.
9.
PERSONAL PROPERTY: The parties agree that the personal property shall be divided
as follows:
a. The personal property in his possession;
b. His bank: accounts;
c. Any life insurance policy;
d. His employee benefits at Highmark, Inc.;
e. The real estate at 511 North Bedford Street, Carlisle, P A 17013.
WIFE shall receive the following items:
a. The personal property in her current possession;
b. Her bank: accounts;
c. Any life insurance policy; and
d. Her employee benefits.
4
The WIFE hereby waives all right and title which she may have in any personal property
of the HUSBAND. HUSBAND likewise waives any interest which he has in the personal
property of the WIFE. Henceforth, each of the parties shall own, have and enjoy independently
of any claim or right of the other party, all items of personal property of every kind, nature and
description and wherever situated, which are then owned or held by or which may hereafter
belong to the HUSBAND or WIFE with full power to the HUSBAND or the WIFE to dispose
of same as fully and effectually, in all respects and for all purposes as if he or she were
unmarried.
Each party agrees that neither will incur obligations, liens or liabilities on account of the
other and that from the date of this Agreement, neither party shall contract or incur obligations,
liens or any liability whatsoever on account of the other.
10.
AUTOMOBILES:
(a) HUSBAND agrees to waive any and all interest which he may
have in WIFE'S 1997 Subaru.
(b) WIFE agrees to waive any and all interest which she may have in
HUSBAND'S 2002 Subaru. WIFE agrees to sign any documents
necessary to transfer title into HUSBAND's name.
11.
MARITAL DEBTS AND BANKRUPTCY: Each party will be responsible for their
own debt incurred after the date of separation. It is hereby understood and agreed by and
between the parties that their obligations pursuant to this Agreement shall not be affected by any
bankruptcy proceeding and shall not be deemed to constitute or be a dischargeable debt of a
bankruptcy. Both parties warrant that he/she has not heretofore instituted any proceeding
pursuant to the bankruptcy laws nor are there any such proceedings pending with respect to
himlher which have been initiated by others.
5
WIFE agrees to pay and be solely responsible for and will hold HUSBAND hannless
from the following debts:
MBNA.. ................. ..... ........ ........... ....$16,000.00
DISCOVER.......................................... .6,000.00
KAY JEWELERS....................................993.00
SEARS..................................................3 ,200. 00
CINGULAR CELL ....................................80.00
HUSBAND agrees to pay and be solely responsible for and will hold WIFE hannless
from the following debts:
CHASE............................................. ..$5,000.00
GM CARD ..........................................18,000.00
CIRCUIT CITY-CHASE ......................1,700.00
CAPITO LONE.................................... .6,000.00
CITY FINANCIAL .... .... ............... .... ....5,000.00
LOAN (Mr. & Mrs. J. Alexander) ........2,900.00
WELLS FARGO MORTAGE.......................
12.
INSURANCE AND EMPLOYEE BENEFITS: The parties agree that any life
insurance policies on the life of HUSBAND or WIFE or any other employee benefits, including
but not limited to retirement, profit sharing or medical benefits of either party, shall be their own.
WIFE waives all right, title and claim to HUSBAND'S employee benefits, and HUSBAND
waives all right, title and claim to any of WIFE'S employee benefits.
13.
BENEFITS AND BANK ACCOUNTS: WIFE agrees to waive all right, title and
interest which she may have in the savings or checking or any other bank: accounts of the
HUSBAND. The HUSBAND agrees to waive all interest which he has in the bank: accounts of
the WIFE.
6
14.
DIVORCE: The parties both agree to cooperate with each other in obtaining a final
divorce of the marriage. It is agreed that the parties will execute and file the consents necessary
to obtain the divorce. Any party who fails to cooperate with obtaining the Divorce shall pay all
the costs and legal fees of the party who is seeking the divorce.
15.
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 such 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.
16.
ADDITIONAL INSTRUMENTS: Ea~h 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 that may be reasonably required to give full force and effect to the provisions of this
Agreement.
17
VOLUNTARY EXECUTION: The provisions of this Agreement and their legal effect
have been fully explained to the parties by their respective counsel, and each party
acknowledges that the Agreement is fair and equitable, and that it is being entered into
voluntarily, and that it is not the result of any duress or undue influence. The provisions of this
Agreement are fully understood by both parties and each party acknowledges that the Agreement
is fair and equitable, that it is being entered into voluntarily, and that it is not the result of any
duress or undue influence.
7
18.
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.
19.
APPLICABLE LAW: This Agreement shall be construed under the Laws of the
Commonwealth of Pennsylvania.
20.
PRIOR AGREEMENTS: It is understood and agreed that any and all property
settlement agreements which mayor have been executed prior to the date and time of this
Agreement are null and void and of no effect.
21.
PAYMENT OF COSTS: The parties agree to pay for their own costs required to obtain
and complete the divorce.
22.
WAIVER OF CLAIMS AGAINST ESTATES: 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, dower, courtesy, statutory allowance, widow's
allowance, right to take in intestacy, right to take against the Will of the other, and right to act as
administrator or executor of the other's estate, and 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 interests, rights and claims.
8
and year first above written.
IN WITNESS WHEREOF, the parties hereunto have set their hands and seals the day
WITNESSES:
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AviD W. ALEXANDER
(SEAL)
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COMMONWEALTH OF PENNSYLVANIA
SS:
COUNTY OF CUMBERLAND
PERSONALLY APPEARED BEFORE ME, this ,E111 day of ~ ' 2006, a
Notary Public, in and for the Commonwealth of Pennsylvania, and County of Cumberland,
CHARLOTTE M. ALEXANDER, known to me (or satisfactorily proven) to be the person whose name
same for the purposes therein contained.
is subscribed to the within Marriage Settlement Agreement, and acknowledges that she executed the
IN WITNESS WHEREOF, I have hereunto set my hand and official seal.
COMMONWEALTH OF PENNSYLVANIA
~ Se91
Mar1ha L. Neal. Notary Pui:Mc
CadIsIe Bora. CumttOf'.anr.; Cc<JI"lly
MyCarnrnis8lcY. ElIj)i1e5 ~. lb. 1.007
Member. Penn_ylvenl. A..oci~lionOt Noterles
COMMONWEALTH OF PENNSYLVANIA :
: SS:
COUNTY OF CUMBERLAND
PERSONALLY APPEARED BEFORE ME, this 3t1" day of 'JJ! 1tI~. ,2006, a
Notary Public, in and for the Commonwealth of Pennsylvania and County O~A VID W.
ALEXANDER, known to me (or satisfactorily proven) to be the person whose name is subscribed to the
therein contained.
within Marriage Settlement Agreement, and acknowledges that he executed the same for the purposes
IN WITNESS WHEREOF, I have hereunto set my hand and official seal.
COMMONwEALTH OF PENNSYLVANIA
Notarial Seal
Mart1a L. Noel. NoIary PtiIIc
CaIfisIe Bom. ~ County
~ Com..~, EllPir9s Sept. 18, 2007
Member. Penns\Ilvania AssOCIallon Of Noterl.s
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DAVID W. ALEXANDER,
Plaintiff
v.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2006-1245 - CIVIL TERM
CHARLOTTE M. ALEXANDER,
Defendant
IN DIVORCE
PLAINTIFF'S AFFIDAVIT OF CONSENT
1. A complaint in divorce under Section 3301(c) or 3301(d) ofthe Divorce Code was filed on
March 3, 2006.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed
from the date of the filing of the complaint.
3. I consent to the entry of a final decree in divorce.
4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or
expenses if I do not claim them before a divorce is granted.
I 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.
Date: ~ /1/.2()()G,
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DAVID W. ALEXANDER
Plaintiff
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DAVID W. ALEXANDER,
Plaintiff
v.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2006-1245 - CIVIL TERM
CHARLOTTE M. ALEXANDER,
Defendant
IN DIVORCE
DEFENDANT'S AFFIDA VIT OF CONSENT
1. A complaint in divorce under Section 3301(c) or 3301(d) ofthe Divorce Code was filed on
March 3, 2006.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed
from the date of the filing of the complaint.
3. I consent to the entry of a final decree in divorce.
4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or
expenses if I do not claim them before a divorce is granted.
I 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.
Date: (j) ~ j(j-f1L.
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DAVID W. ALEXANDER,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 2006-1245 - CIVIL TERM
CHARLOTTE M. ALEXANDER,
Defendant
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUEST
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 made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn
falsification to authorities.
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DAVID W. ALEXANDER
Plaintiff
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DAVID W. ALEXANDER,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 2006-1245 - CIVIL TERM
CHARLOTTE M. ALEXANDER,
Defendant
IN DIVORCE
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 made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn
falsification to authorities.
Date:
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: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2006-1245 - CIVIL TERM
DAVID W. ALEXANDER,
Plaintiff
CHARLOTTE M. ALEXANDER,
Defendant
IN DIVORCE
DEFENDANT'S MARRIAGE COUNSELING AFFIDA VIT
The defendant, 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.
Date: ~
TE M. ALEXAND
Defendant
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DAVID W. ALEXANDER,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
NO. 2006-1245 - CIVIL TERM
CHARLOTTE M. ALEXANDER,
Defendant
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) and or (d) ofthe Divorce Code.
2. Date and manner of service of complaint: A certified copy of the Complaint in Divorce was served upon the
defendant, Charlotte M. Alexander, on March 3, 2006, by hand delivery, to her at the Law Offices of Irwin & McKnight,
60 West Pomfret Street, Carlisle, Pennsylvania, 17013.
3. Complete either paragraph (a) or (b).
(a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorfe Code:
by plaintiff: June 9,2006; by defendant: June 14,2006.
(b)(1) Date of execution of the affidavit required by Section 3301(d) of the Divorce Code:
(b )(2) Date of filing and service of the plaintiffs affidavit upon the defendant:
4. Related claims pending: NONE.
5. Complete either (a) or (b).
(a)
of which is attached:
Date and manner of service of the Notice of Intention to file Praecipe to Transmit Record, a copy
(b)
Date plaintiffs Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary:
June 19, 2005
June 19, 2005.
Date: June 19, 2006
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IN THE COURT OF COMMON PLEAS
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OF CUMBERLAND COUNTY
STATE OF
PENNA.
DAVID W. ALEXANDER,
No. 2006-1245 CIVIL TERM
PLAINTIFF
VERSUS
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CHARLOTTE M. ALEXANDER,
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DEFENDANT
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DECREE IN
DIVORCE
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AND NOW,
~\.lJ'\~ 7.1
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DECREED THAT
DAVID W. Al.UA\II))ER
, PLAINTIFF,
AND
CHAJlI.O'1'TE M. ALEXANDER
, DEFENDANT,
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ARE DIVORCED FROM THE BONDS OF MATRIMONY.
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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;
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The Marriage Settlement Agreement dated March 3, 2006, and signed by the
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parties is hereby incorporated into this Decree, but not merged.
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PROTHONOTARY
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