Loading...
HomeMy WebLinkAbout06-1786 ABRAHAM LAW OFFICES 2157 Market Street, Camp Hill, PA 17011 (717) 763-1700 BRIAN L. TANNEHILL Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA : NO. Olr, - 17ft", (!.;u~l ~~I : CIVIL ACTION - LAW : DIVORCE SHARON C. TANNEHILL Defendant 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 rnay lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of Court Administrator, 4th Floor, Cumberland County Courthouse, Carlisle, Pennsylvania. 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 LA WYER 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: Court Administrator 4th Floor, Cumberland County Courthouse Carlisle, P A 17013 (717) 240-6200 BRIAN L. TANNEHILL Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. O~- rrrb C;UtL~82J"', I SHARON C. TANNEHILL Defendant : CIVIL ACTION - LAW : DIVORCE COMPLAINT AND NOW, comes Plaintiff, Brian L. Tannehill, by and through his attorney, James W. Abraham, Esquire, Abraham Law Offices, Camp Hill, Pennsylvania, 17011, and files the following: COUNT I - NO-F AUL T DIVORCE (Pursuant to 23 Pa.C.S.A. Section 3301(c)) 1. Plaintiff, Brian L. Tannehill, is an adult individual whose residence is 139 South 17th Street, Camp Hill, Cumberland County, Pennsylvania. 2. Defendant" is an adult individual whose residence is 139 South 17th Street, Camp Hill, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents of the Comrnonwealth of Pennsylvania for at least six (6) months immediately prior to the filing of this Complaint. 4. Plaintiff and Defendant were rnarried on March 31, 200 I in Mechanicsburg, Pennsylvania. 5. There have been no prior actions of divorce or for annulrnent between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available and that Defendant may have the right to request that the Court require the parties to participate in counseling. 8. Plaintiff and Defendant are not mernbers of the Armed Forces of the United States. WHEREFORE, Plaintiff requests Your Honorable Court to enter a decree in divorce dissolving the marriage. COUNT II - INDIGNITIES 9. Paragraphs I through 8 are incorporated herein by reterence. 10. Defendant has caused such indignities against Plaintiff which has made life burdensome and intolerable for Plaintiff, the innocent and injured spouse. WHEREFORE, Plaintiff respectfully requests Your Honorable Court to enter a decree in divorce dissolving the marriage. Respectfully submitted: ~ - James W. Abraham, Esq. Abraham Law Offices 2157 Market St. Camp Hill, PA 17011 (717) 763-1700 Attorney for Plaintiff. Brian L. Tannehill DATE: 3/28/06 VERIFICATION I, 13 I:..f A0 J... J;.,IAU IEI"I LL ,the undersigned, hereby verify and confirm that the foregoing document and the statements made therein are true and correct to the best of my knowledge, information and belief. I further understand that any false statements made herein are subject to the penalties ofl8 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. DATE: 5 -.;:2. 7 - () (/ ~~p~-~ - ~ c' n N 1'\ ...0 !:t_ ~ D ...... t- ~ ~ () {) ~ ;U () -...... ~ r---- ~ :e t- ~ r-,) C) :::-3 " , -.'" .-4 ~ --= -n ~~ rl1~, f\~ CD (Jff-..,\ -. "J:::; .- , CD :::~'I ~ :-.:9 Co' _ ...- v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA : NO. 06-1786 CIVIL TERM : CIVIL ACTION - LAW : DIVORCE BRIAN L. TANNEHILL Plaintiff SHARON C. TANNEHILL Defendant MARITAL SE'ULliMENT AGREEMENT THIS AGREEMENT, made this .1 c:. ,..... day of ~\ '" I ,l , 2006. by and between SHARON C. TANNEIDLL ("Wife"), ofHummelstown, PerinsyIvania, and BRIAN 1. TANNEHILL ("Husband"), of Camp Hill, Pennsylvania. WITNESSETH WHEREAS, the parties hereto are Husband and Wife, married on March 31, 2001 in Mechanicsburg, Pennsylvania. WHEREAS, diverse, unhappy 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 hereto are desirous of settling fully and finally their respective financial and property rights and obligations as between each other including, without limitation by specification: the settling of all matters between them relating to the ownership and equitable distribution of real and personal property, and the settling of any and all claims and possible claims by one against the other or against their respective estates, as well as any other matters related hereto. NOW THEREFORE, in consideration of the mutual promises, covenants and undertakings hereinafter set forth and for other good and valuable conSideration, receipt of which is hereby acknowledged by each ohhe parties hereto, Husband and Wife, each intending to be legally bound hereby, covenant and agree as follows: 1. AGREEMENT NOT A BAR TO DIVORCE PROCEEDINGS: This Agreement shall not be considered to affect or bar the right of Husband and Wife to an absolute divorce on lawful grounds if such grounds now exist or shall hereafter exist or to such defense as may be available to either party. This Agreement is not intended to condone and shall not be deemed to be a condonation on the part of either party hereto of any act or acts on the part of the other party which have occasioned the disputes or unhappy differences which may occur subsequent to the date hereof. The parties intend to secure a mutual consent, no-fault divorce pursuant to the terms of Section 3301(c) of the Divorce Code ofI980, as amended February 12,1988. 2. EFFECT OF DIVORCE DECREE: The parties agree that unless otherwise specifically provided herein, this Agreement shall continue in full force and effect after such time as a final decree in divorce may be entered with respect to the parties. The parties agree that in the event of absolute divorce between them, they shall nonetheless continue to be bound by all the terms of this Agreement. 3. DATE OF EXECUTION: 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. 4. DISTRIBUTION DATE: The transfer of property, funds and/or documents provided for herein shall only take place on the "distribution date" which shall be defined as the date of execution of this Agreement, unless otherwise specified herein. 5. CONSENT OF PARTIES/ADVICE OF COUNSEL: Husband and Wife acknowledge that they fully understand the facts as to their legal rights and obligations under this Agreement. Husband and Wife acknowledge and accept that this Agreement is, under the circumstances, fair and equitable and that it is being entered into freely and voluntarily, and that the execution of this Agreement is not the result of any collusion or improper or illegal agreement or agreements. Husband and Wife acknowledge that they have each had the opportunity to have this Agreement reviewed by an attorney and/or have done so, prior to signing. 6. FINANCIAL DISCLOSURE: The parties confirm that each has relied on the substantial accuracy of the financial disclosure of the other, except as set forth herein as an inducementto the execution of this Agreement. 7. PERSONAL PROPERTY: Wife shall receive the Plymouth Neon vehicle as her sole and separate property and Wife shall be solely responsible for all insurance and any other expenses regarding said vehicle and shall hold Husband harmless and indemnify Husband as to any default by Wife of said obligations. Husband shall keep the Subaru Impreza vehicle as his sole and separate property, which is a pre-marital asset. Husband shall be solely responsible for the insurance and any other expenses regarding the vehicle and shall hold Wife hannless and indemnify Wife as to any default by Husband of said obligations. 2 The household personal property of the parties shall be divided as stated on the Property List attached hereto and made part hereof as Exhibit "A". Except as otherwise stated above and in Exhibit "A", all other person:uyroperty, including but not limited to, the parties' savings account, DVDs and books, has been dmded be~een t,he parties to their mutual satisfaction and agreement and neither party shall make any claun agamst said property. . 8. REAL PROPERTY: Husband and Wife hereby agree that the former marital residence located at 139 South 17th Street, Camp Hill, Pennsylvania (hereinafter "property"), sha11 become the sole and separate property of Husband, upon Husband's refInancing of the existing mortgage and/or liens against said property and the removal of Wife's name from said mortgage and/or liens; as Husband shall refinance in an amount sufficient to payoff the mortgage and to pay the closing costs of said refinancing; and shall apply for approval of a refInancing loan in an amount sufficient to pay to also pay to Wife Twenty Thousand ($20,000.00) Dollars, as Wife's equitable share of said property and as to Wife's equitable share of the marital estate in general. In the event Husband is not approved for refinancing in an amount sufficient to payoff the mortgage, plus the closing costs, plus the aforesaid $20,000.00 to Wife, which would be verified in writing to Wife by Husband, Wife shall accept a lesser amount, but not less than Fifteen Thousand ($15,000.00) Dollars. Husband agrees to refInance the property as stated above and pay the aforesaid amount to Wife within six (6) months from the date of entry of the fina1 decree in divorce. Upon the signing of this Agreement, Wife agrees to sign a deed transferring the property to Husband, which deed shall be held by Husband's attorney and shall only be recorded in accordance with and at the time of the aforesaid refmancing and payment to Wife. Pending the aforesaid refinancing, Husband agrees to be solely responsible to pay any and all debts relating to the property, including but not limited to, the mortgage, taxes, insurance and utilities and shall hold Wife harmless and indemnify Wife for any default of said obligation. Upon.the signing of this Agreement and pending the aforesaid refinancing and transfer of sole ownership of the property to Husband by deed, Husband shall have and enjoy exclusive and sole possession of the property. 9. MARITAL DEBTS: Husband and Wife agree that Wife will pay the following marital debts: A. One-half(I/2) of the Capital One credit card account in the amount of $700. 3 Husband and Wife agree that Husband will pay the following marital debts: A. One-half (112) of the Capital One credit card account in the amount of$700. B. Best Buy credit card account. C. Lowes credit card account. D. NB Liebman credit card account. Except as otherwise stated above, Husband and Wife agree that they shall be solely responsible for any and all debts which are in their individual name and will hold the other hannIess and indemnify the other party for any default of said obligation. 10. AFTER ACQUIRED PROPERTY: Each of the parties shall own and e~oy, independently of any claims or right of the other, all items of personal property, tangible or intangible, andlor real property, acquired by him or her, after the date of fmal separation, January 28, 2006, with full power in him or her to dispose of the same as fully and effectively, in all respect and for all purposes, as though he or she were unmarried. 11. WIFE'S DEBTS: Wife represents and warrants to Husband that since the date of fmal separation, on or about January 28,2006,' she has not contracted or incurred any debt or liability for which Husband or his estate might be responsible and Wife further represents and warrants to Husband that she will not contract or incur any debt or liability after the execution of this Agreement for which Husband or his estate might be responsible. Wife shall indemnify and save harmless Husband from any and all claims or demands made against Husband by reason of debts or obligations incurred by Wife. 12. HUSBAND'S DEBTS: Husband represents and warrants to Wife that since the date of fmal separation, on 01' about January 28, 2006, he has not contracted or incurred any debt or liability for which Wife or her estate might be responsible and Husband further represents and warrants to Wife that he will not contract or incur any debt or liability after the execution of this Agreement for which Wife or her estate might be responsible. Husband shall indemnify and save harmless Wife from any and all claims or demands against Wife by reason of debts or obligations incurred by Husband. 13. PENSION AND RETIREMENT BENEFITS: Husband and Wife agree to waive any and all past, present or future interest in any pension or retirement benefits, including but not limited to, 40I(k) accounts, deferred pensions, stock options, retirement savings plans or retirement plans, of the other and neither party shall make any claim against the other's pension or retirement benefits, ifany. 4 14. WAIVER OF RIGHTS: The parties hereto fully understand their rights under and pursuant to the Divorce Code, Act of 1980, as Amended February 12, 1988, particularly the provisions for alimony, alimony pendente lite, spousal support, equitable distribution of marital property, attorney fees and expenses. Both parties agree that this Agreement shall conclusively provide for the distribution of property under the said law the parties hereby waive, release and forever relinquish any further rights they may respectively have against the other for alimony, alimony pendente lite, spousal support, equitable distribution of marital property, attorney fees and expenses. IS. PERSONAL RIGHTS: Husband and Wife may and shall, at all times hereafter, live separate and apart. They shall be free from any control, restraint, interference or authority, direct or indirect, by the other in all respects as fully as if they were unmarried. They may reside at such place or places as they may select. Each may, for his or her separate use or benefit, engage in any business, occupation, profession or employment which to him or her may seem advisable. Husband and Wife shall not molest, harass, disturb or malign each other or the respective families of each other nor cornpel or attempt to compel the other to cohabitate or dwell by any means or in any manner whatsoever with him or her. 16. MUTUAL RELEASE: Except as otherwise stated hereto, Husband and Wife each hereby mutually remise, release, quitclaim and forever discharge the other and the estate of each other, for all time to come, and for all purposes whatsoever, of and from any and all rights, title and interests, or claims in or against the property (including income and gain from property hereafter accruing) of the other or against the estate of each other, of whatever nature and wheresoever situate, which he or she now has or may have at any time in the future. Except as otherwise stated hereto, Husband and Wife each hereby further mutually remise, release, quitclaim, waive and forever discharge the other and the estate of each other, for all time to come and for all purposes whatsoever, of and from any and all rights which either party may have, or at any time hereafter have, for past, present or future spousal support or maintenance, alimony, alimony pendente lite, equitable distribution of marital property, attorney 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 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. 5 l7.W AIVER OR MODIFICATION TO BE IN WRITING: A modification or waiver of any of the terms of this Agreement shall be effective only if in writing, signed by both parties and executed with the same fonnality as this Agreement. No waiver of any breach hereof or default hereunder shall be deemed a waiver of any subsequent default of the same or similar nature. 18. MUTUAL COOPERATION: Each party 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 future instruments and/or documents that the other party may reasonably require for that purpose of giving full force and effect to the provisions of this Agreement. 19. INTEGRATION: This Agreement constitutes the entire understanding of the parties and supersedes any and all prior agreements and negotiations between them. There are no representations or warranties other than those expressly set forth herein. 20, AGREEMENT BINDING ON HEIRS: This Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective legatees, devises, heirs, executors, administrators, successors and assigns in the interest of the parties. 21. OTHER DOCUMENTATION: Wife and Husband covenant and agree that they will forthwith and within thirty (30) days after demand or due date, execute any and all written instruments,. assignments, releases, satisfactions, deeds, notes, stock certificates, or such other writings as may be necessary or desirable for the proper effectuation of this Agreement, and as their respective counsel shall mutually agree, should be so executed in order to carry out fully and effectively the terms of this Agreement. 22. NO WAIVER OF DEFAULT: This Agreement shall remain in full force and effect unless and until terminated under and pursuant to the tenns of this Agreement. The failure of either party to insist upon strict perfonnance 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 subsequent default of the same or similar nature, nor shall it be construed as a waiver of strict perfonnance of any other obligations herein. 6 23. BREACH: If either party breaches any provision of this Agreement, the other party shall have the rights, at his or her election, to sue in law or in equity to enforce any rights and remedies which the party may have, and the party breaching this Agreement shall be responsible for payment of attorney fees and all costs incurred by the other in enforcing his or her rights 1Ulder this Agreement. 24. SEVERABILITY: If any term, condition, clause or provisions 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. Likewise, the failure of any party to meet his or her obligations 1Ulder anyone or more of the provisions herein, with the exception of the satisfaction of the conditions precedent, shall in no way avoid or alter the remaining obligations of the parties. 25. LAW OF PENNSYL VANIA APPLICABLE: . This Agreement shall be construed in accordance with the laws of the Commonwealth of Pennsylvania 26. HEADINGS NOT PART OF AGREEMENT: Any headings preceding the text of the several paragraphs/provisions and subparagraphs hereof, are inserted solely for convenience of reference and shall not constitute a part of this Agreement nor shall they affect its meaning, construction or effect. 27. DIVORCE: The parties hereto agree that their marriage is irretrievably broken, and subsequent to the filing of a Complaint in Divorce, both parties agree to enter into a mutual consent divorce under Section 3301(c) of the Pennsylvania Divorce Code ofI980, as amended February 12,1988. The parties further agree to sign the necessary documents, including the Affidavit of Consent and Waiver, at such a time after the ninety (90) days of the filing of the Complaint as either party may request. 7 WITNESS WHEREOF, the parties hereto, have set their hands and seals the day and year fIrst above written. Witness: ~ ~C SHARON c. TANNEHILL ~~ 8 PERSONAL PROPERTY LIST HOUSElIOLD ITEMS ("PM" refers to a Pre-Marital item) ROOM WIFE HUSBAND Fover: Lighthouse print Coat tree Chair End table Container for keys LivinlZ Room: Antique sewing machine (PM) Papasan chair Oak plant stand/table Straight back chair All photos, frames except for Husband's parents and 3 photos of Husband's family Guitar & books (PM) Red footstool Magazine container Candle holders wi River Rocks White blanket MinoIta camera Stained glass Small mirror w/glass Turtle (Dominican Republic) Television (PM) Home theater (PM) XBOX (PM) GameCube Digital camera Video games Coffee table (PM) Chess set (PM) Steelers blanket Storage containers for VG peripherals Furniture Floor rug Records Hand painted crock Hippies' sign Spider plant & planter Black metal quilt rack Window treatments Marble coasters End table wlIamps Floor pillows Furniture pillows Fleece blanket (black) Red candle Shelf wl7 coat pegs Wall art Other plants & planters Butler rum candle Tumblers wlround candIes EXHIBIT "A" Hallwav: Picture frame BIue bottles Soare Bedroom: Oak quilt rack Key on door Placemats on hangers Decorative flags Flag holder Contents of closet (wedding dress, etc.) Dressers (PM) Black rocker Yoga ball Pink bench ALL items already stores/packed in comer Lamp Records Square picture frames Ceramic house Child's rocker Office: X-long twin bed Twin box spring/mattress All bedding Lamp Black Pier One pot Clear playing cards Black coasters Pastel set Red fleece blanket Water fountain Striped couch African giraffes Bathroorn: Y. bath towels, etc. Things already packed. White footstool 3 Candle holders (2) SheIfw/3 coat pegs Full size bed Mattress &- box spring Fichus treet Wall hanging Pictures of parents Pine I-drawer lamp table Biscotti crock Flannel sheets for full bed Edward Hopper print Paintings (PM) Prayer set Marble candIe holder (PM) Computer CD display Floor rog Window treatments Black bookshelf File cabinet Computer Desk Black storage bins Black telephone Office chair Y. bath towels, etc. Shower curtain Floor rogs Q-tip dispenser Blue bowl w/candle PantrY I Walkway: Kitchen: Laundry Room: Blue candles Window treatment Toilet paper dispenser Trash can Books belonging to Wife Picture albums Birdcage Frames Tin Art in pantry Books belonging to Husband Black table base Marble table top Cook books Loose coffee mugs Pampered chef cookware AJI other glassware Glass canisters Laundry sign Window treatment Cutting board (missing) Mixer (missing) Pampered chef chopper (missing) Bread basket Monet print Blender Breakfast table Grill books Espresso machine Cat dish . Rio dishware Green bowls (PM) Pizza stone Pots & pans Non-pampered chef cookware Pampered chef cheese slicer Pint glasses 8 wine glasses Marble cutting board Knife block Tea kettle Tea towels & potholder Calendar Black chairs Coffee maker Toaster Microwave Toaster oven Clock Paper towel dispenser Utensils, etc. One-half of cleaning products as of date of separation. One-half of cleaning products as of date of separation. Washer & dryer (3) Dininsz Room: Antique buffet Candles inside telephone stand Contents of buffet drawers AIl vases in closet & floor Master Bedroom: AIl women's clothing Craft table AIl scrap booking materials FISKARS roIIint tote Vacuum cleaner (missing) White plastic 3.drawer stand Contents of 3-drawer stand White bookshelf Contents of White bookshelf Canvas hamper Wedding video 2. Tier end table Contents of white cabinet Art of winemaking rug Brown virgin acrylic blanket Snowman bucket White decorative bucket & contents Rose picture Gold "3-picture" frame Entire contents of bathroom Iron (missing) Trampoline (PM) Red pillows & red blanket Red box Brown leather storage boxes Tiffany's bracelet Antique blue dresser & contents Kama sutra Blue luggage & contents (4) Pilsner set Antique telephone stand (green) Dining room table & chairs White tablecloth Starry night print 4 yellow placemats Vase dining room Poker set Mirror Wine rack Bar set Plastic plant AIl men's clothing Iron Christmas tree stand Stool Night stand (PM) Bed, mattress & box spring Holiday/Christmas ornaments Blue rocking chair Alarm cIock/CD player Brown floor 11Ig White telephone Striped chair White cabinet Basement Computer Y. of camping gear Camp chair (x2) Tools (PM) AIl basement antiques, etc. TV Garage: Bicycle Foose ball table y, of camping gear Barnes & Noble chair Godiva rack Tools (PM) ("Freezer :-:J Lamp Lava lamp Basement speakers Green furnit\ire TV stand White plastic display Black plastic display Lawnmower Leaf blower Hedge trimmer (5) COMMONWEALTH OF PENNSYL VANIA c.... ....'--\.. ~ J SS: COUNTY OF On this .1 C. ,.. day of ~ ~ \ / . 2006, before me, the subscriber, a Notary Public, in and for the said Commonwealth and County, came the above-named person, Sharon C. Tannehill, satisfactorily proven to me to be the person whose name is subscribed to the within instnunent and acknowledged that she executed the same for the purposes stated herein contained and that such instrument may be filed and/or recorded. WITNESS {my hand and Notarial seal. i-\. -~_/- ~'v )C? NOTARY PUBLIC MY COMMISSION EXPIRES: COMMONWEALTH OF PENNSYLVANIA NoIariaI Seal Darrell C. Oelhiefs, Nolary Public Hampden Twp.. Cumberland County My Commlssiir1 E~ Aug. 5, 2008 Member, Pen",j'fva-;;;aA-S~ociation Of Notaries COMMONWEALTH OF PENNSYLVANIA ss: COUNTY OF ( ,,_l.....l~) ~ On this LG. r... day of j '" \ / , 2006, before me, the subscriber, Notary Public, in and for the said Commonwealth and County, came the above-named person, Brian 1. Tannehill. satisfactorily proven to me to be the person whose name is subscribed to the within instrument and acknowledged that he executed the same for the purpose herein contained and that such instnunent may be filed and/or recorded. WITNESS my h d and Notarial Seal. <~ NOTARY IC MY COMMISSION EXPIRES: COMMONWEALTH OF PENNSYLVANIA NalaIlaI5eoII Danell C. DeIhIeIs, NoIary Public Hampden Twp.. Q.rnbertand County MyCommissior> "<Oil8SAug. 5, 2008 Member, Penneylv81\iS'A55.oc1l3tlon Of Notarl.. () ..., Q = c: <'-" <':': <J" l"!',:~! 2= ~:!I , G") me- -:grn N ~~;:JO s;- C) 1- .~_._:c' -0 ~S =I1 :x .'.0 <: ;,;jnl (~- 0., ::! .s::- ?Ii 0 '< .' l BRIAN 1. TANNEHILL Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 061786 CIVIL TERM SHARON C. TANNEHILL Defendant : CIVIL ACTION - LAW : DIVORCE AFFIDAVIT OF SERVICE I, James W. Abraham, Esquire, the undersigned, as attorney for Plaintiff, Brian 1. Tannehill, in the above-captioned action, hereby affirm that the Complaint in Divorce filed herein, was served upon Defendant, Sharon C. Tannehill, by certified mail on March 29, 2006, as verified by the green return receipt card from the US Post Office, which is attached below: . CompIelo n.me 1, 2. MIl 3. AlIo~ Item 4 It RMIclIo4 .,.,.t ~ ,1 '..d. .. Prlnt)'lll'..... MIl IlddnIIlI OI! the _ 10 that we .." rIIIum the C8ItI to YOU. . _Ihlo C8ltl1o the beck dthe mal~ Of OI! the fIont It IIl8Ce permIla. 1.__tD: StlSfMI'l C. TI't<<I(~f'l.I' ,'. l3iS'(.f ~.Lv1C.M<ce- 'fJ...SD ~I<<S lUll(, **.<M~ 'Bi/~ t4 t ..t~.i-L. O~ ~OAddo ll'ff--"UA Cft"MIr' CIIIWoy___lIoml? 0'11Io JtYEll,_CIIIWoy__ ONo a. Sonloe ~ ~_Moll O__MoI o "". l..d 0 IIIlIn1 AocoIpt far Moo..._..... o _ Moll 00.0.0. 4. _1iJ>.d lloIMIy'I /EIIh"" Q!'IIIo , 1003 ..liD DoD],( i! ,~. .- PS......3I11.'. III W" DATE: 8/24/06 ~-f/ James W. Abraham, Esquire o c: s: -oeu mI'!. Z'.. 7'. (f~ ,.':" ~;. >c z ::< l , -. ,.., = = "'" ,... c:: G"l N -I'"' s:fi ~F1 -am :IJ 'I' 00 .:::!.,.; -0 ;'55 ::J:: '2m ~ w ~ UJ , -- ,'" BRIAN 1. TANNEHILL Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 06 1786 CIVIL TERM SHARON C. TANNEHILL Defendant : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT I. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on March 28, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of service and filing of the Complaint. 3. I consent to the entry of a Final Decree of Divorce after service of notice of intention to request entry of the Decree. I verifY that the statements made in the Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to the unsworn falsification to authorities. DATE: ~ 2.2.. 21<6 Z:L~~ WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF DIVORCE DECREE UNDER SETION 330I(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 ifI 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 Waiver are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to the unsworn falsification to authorities. DATE: tJ9. ').2 . ZK"- -~~---- =- B .T 8 s: ""O(P mr, z:;r -:;'''; C7;:J, ~~r~ ,-~" g:8 z ::< . , ...., = = Q'o :>- c: r:;? N ~ ~ ::r!::n en...... -om :p)? 1.:~C~ ~,.- -r~ (~f--) Zr" ~ ~ -0 ::l: s:- o ~, ~.. BRIAN 1. TANNEHILL Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 06 1786 CIVIL TERM SHARON C. TANNEHILL Defendant : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on March 28, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of service and filing of the Complaint. 3. I consent to the entry of a Final Decree of Divorce after service of notice of intention to request entry of the Decree. I verify that the statements made in the Affidavit are troe and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to the unswom falsification to authorities. ~SHAR~ON~ C. ~-- ., --rh..L DATE: 7. ?(". ~nt'l~ ~ WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF DIVORCE DECREE UNDER SETlON 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 Waiver are troe and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to the unswom falsification to authorities. DATE: c. 2Jo. ~~ S~~~ (') c: :<;;. ""'OC";) III r'~ Z'~\' ~:... .- '(:/':., ~.z. .., k(~ ~~: ~ , ~ ....., =' ~ ~ N +:" ~ .~ "89 --\Q. -:r:--" -O'J5 s ;~ 7:n _ s:. +:" ~ o .' , ABRAHAM LAW OFFICES 2157 Market Street, Camp Hill, PA 17011 (717) 763-1700 v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL V ANlA : NO. 06 1786 CIVIL TERM BRIAN 1. TANNEHILL Plaintiff SHARON C. TANNEHILL Defendant : CIVIL ACTION - LAW : DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the Record, together with the following infonnation, to the Court for the entry of a divorce decree: 1. Ground for Divorce: irretrievable breakdown under Section (x) 3301(c) ( ) 3301(d)(I) of the Divorce Code. 2. Date and manner of service of the Complaint: March 29. 2006: see attached Affidavit of Accentance of Service. 3. Complete either paragraph (a) or (b): (a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff on 8/22/06; and by Defendant on 7/26/06. (bXI) Date of execution of the affidavit required by Section 330I(d) of the Divorce Code: (2) Date of filing and service of plaintiff's affidavit upon the Defendant 4. Related claims pending: None Dursuant to 7/26/06 Marital Settlement Allreement. 5. Complete either paragraph (a) or (b). (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: . (b) Date Plaintiff's Waiver of Notice was filed with the Prothonotary: 8/24/06. (c) Date Defendant's Waiver of Notice was filed with the Prothonotary: 8/24/06. DATE: 8/24/06 James W. Abraham, Esquire Abraham Law Offices 2157 Market St. Camp Hill, P A 17011 (717) 763-1700 Attorney for Plaintiff, Brian 1. Tannehill n c ~.S: ,-'cn 92ff 7':;;:"''' 0)> ~::~. "...~ ~~~, Z =< , '0 ,..., = = ",... > c:: c:n N .:::- " ::r o ." :I! rn:TI .",fTi ~6 j!-~ {~):t! 'z'''''c' ,._~ rTl 2 ~ W \D ~~ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ;f.:+.if.:+. +~ :+.:+:if.:+. +:+.++ +:+.+ +++++++++++:+.++ :+. ++ +:f.++++'++ +++++ ++++++ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. BRIAN L. TANNEHILL No. 06 - 1786 VERSUS SHARON c. TANNEHlLL DECREE IN DIVORCE AND Now,-4~r- BRIAN L. TANNEHILL '2-'\ 2006 , IT IS ORDERED AND , PLAINTIFF, DECREED THAT SHARON C. TANNEHILL , DEFENDANT, AND ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECO~D,IN THIS ACTION FOR WHICH A FINAL ORDER HAS YET BEEN ENTERED: W~ The Marital Settlement ~ reement dated Jul 26, 2006, +:+. + + shall be incorporated, but shall not merge, in Divorce. PROTHONOTARY ... .. .. ++++++++++++.+++++++ :+.:+.:+. Of. Of ++:+.'+'+'+' if. +++'li++ +++:+.+'1'::+'+'1;+ '+':+. "'+ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . NOT . . . . . . . . . . . . . . . . . . . . . . . . . . . J. . . . . . . . . . . . . . . . . . . . . . :+.:+. + '1'+ ,yfrpg ~ ~u, ~ ~:;2 ff~4Jn . . . CJCl. /(1 111' If; ~~, C::::'J "C'-:,l ':;.... IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA .JSr i av,- L. -ran n-e h ,j I Plaintiff Vs SkJA'{'QY\ ~.f~/-fl Defendant File No. 0& - 11g 0 IN DIVORCE 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 9,. 2 q . 2000, hereby elects to resume the prior surname of C 0- (- b D n.€... , and gives thi~ written notice avowing bis / her intention pursuant to the proY!~JQ!!lLqt~~ P. Date: II. 20. 2600. Sl^~.'- Signature ~'4~ C.. CN-~ Signature of name being resumed COMMONWECtTH OF PENNSYLVANIA ) COUNTY OF CUVI. b-er( Jd . On the d- rJ day of No V C 0\. b ~ r , 200.f, before me, the Prothonotary or the 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 he / she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand hereunto set my hand and official seal. d4' ~ &:~. c~~~ rothonotary " J /Jc '() NOTARIAl. SEAL PROTHONOTNr( NOTARY MUC CARUSl.E CUMBERLAND COlII1Y COURJHOUSE MY COMMISSION DPIRES JNIMRY 4, 2010 1"'0 c::.; c:::;;:; 0..... (:) -n C:=j ....=-. N o v -".,>> N CJ'"1 (.....'J....."'fIl"'1- -.q "R.I_1IIIlIoiM r _ ~;:'-ll&~"'" .~.......#Wt-"'""'q ';!, ];:; Jjl):-;.!':,I'I :!l!~Uq '*i:' .... .V','.<.I''':r~!'q '."'~< '}J 'rr~,'~;'jJ) ;;V~;.J~""; ':"J '!~,.;o<) ",:,?<" ',:f_l~\,f.;~.~, ~:~'.;~,~';.~ {''\' ~:~. 1 ~ , _-.."_o.r,,.;,# _.......,'.......,.,.~.