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HomeMy WebLinkAbout06-22066 TAMMY J. SOLLENBERGER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION -LAW LAWRENCE L. SOLLENBERGER, III, NO. P 10( CIVIL TERM Defendant 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 will proceed without you and a decree of divorce or annulment may be entered against you for any 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 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 the Prothonotary at Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania, 17013 YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 TAMMY J. SOLLENBERGER, Plaintiff V. LAWRENCE L. SOLLENBERGER, III, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. CIVIL TERM IN DIVORCE COMPLAINT IN DIVORCE NO FAULT I. Plaintiff is Tammy J. Sollenberger, an adult individual currently residing at 107 Meals Drive, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Lawrence L. Sollenberger, III, an adult individual currently residing at 1226 Walnut Bottom Road, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff is a bonafide resident of the Commonwealth of Pennsylvania and has been so for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on August 6, 1983, in Carlisle, Cumberland County, Pennsylvania. 5. There have been no other prior actions for divorce or annulment between the parties. 6. Neither the Plaintiff nor the Defendant are members of the United States Armed Forces or its Allies. 7. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling. & Plaintiff and Defendant are citizens of the United States of America. 9. The parties' marriage is irretrievably broken. 10. Plaintiff desires a divorce based upon the belief that the Defendant will, ninety (90) days from the date of the filing of this Complaint, consent to this divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a divorce pursuant to 23 P.S. Section 3301 (c) of the Domestic Relations Code. COUNT V EQUITABLE DISTRIBUTION 11. Paragraphs 1 through 10 are incorporated herein by reference as if set forth in their full text. 12. Plaintiff and Defendant are joint owners of various items of personal property, furniture, and household furnishings acquired during their marriage which are subject to equitable distribution. 13. Plaintiff and Defendant have incurred debts and obligations during their marriage which are subject to equitable distribution. WHEREFORE, Plaintiff requests your Honorable Court to enter a decree equitably dividing the parties' property and equitable apportioning the debts incurred by the parties. Respectfully submitted, 4 y iffie, Esquire t ey r Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsifications to authorities. DATE `/ - Id "C) r0 MiP.t . ?-?J ?-?'^ --n O A Tammy J. o lenberger, Plaintiff (`-? ^„?. r ? Kl 5 o C? ?? _? ._ ?^ i _+ TAMMY J. SOLLENBERGER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLANDCOUNTY, PENNSYLVANIA VS. CIVIL ACTION -LAW • ?tao? LAWRENCE L. SOLLENBERGER, III, : NO. 06-ML CIVIL TERM Defendant IN DIVORCE AFFIDAVIT OF SERVICE I, Bradley L. Griffie, Esquire, counsel of record for Plaintiff, and states that a true and attested copy of a Complaint in Divorce was sent to Defendant, Lawrence Sollenberger III, at his address of 1226 Walnut Bottom Road, Carlisle, Pennsylvania, by certified mail, turn receipt requested. A copy of said receipt is attached hereto indicating service was made on April 26, 2006. ie, Es ;re 4ey o r Plainti GRIFFIE & ASSOCIATES 200 N. Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 Sworn and subscrib V to before me this day of ffid'u .2006 NOTARY ?• 1 ' CERTIFIED MAIL RECEIPT ('Domestic Vail Only: No Insurance Coverage Provided) cc Ln Postage S , . ly L„ C3 CertHied Fee r ? . 0 (Erxloreement RRequireM CO (Restrbted DeiNary Fee (Endoreemem Required) tv Total Postage & Fees 0 N Sent To .DJ .?? c er Sheet, Apt. No.; or PO Box No. CRY, Stab, mp" 1 ?O 1. . it :11 11 a?l 1 . y rvi{Tl I T C _ - 1 c''? C 3 .. > C J .. TAMMY J. SOLLENBERGER : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY PENNSYLVANIA V. : NO. 06-2206 Civil Term LAWRENCE L. SOLLENBERGER, III. CIVIL ACTION - LAW Defendant IN DIVORCE PRAECIPE TO ENTER APPEARANCE Please enter my appearance on behalf of the Defendant, Lawrence L. Sollenberger, III, in the above-captioned matter. RESPECTFULLY SUBMI Cbarles Rec)6r, Esquire (ID # 39121) 1104 Fernwood Avenue, Ste. 203 Camp Hill, PA 17011-6912 (717) 761-8101 Date: /Ir/to I ?,FT (? :S7 TAMMY J. SOLLENBERGER, Plaintiff V. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. No -oZol0(o CIVIL TERM IN DIVORCE LAWRENCE L. SOLLENBERGER, III, Defendant MOTION FOR APPOINTMENT OF MASTER AND NOW comes Plaintiff, by and through her attorney of record, Bradley L. Griffie, Esquire, and moves the Court to appoint a Master with respect to the following claims: (X) Divorce (X) Distribution of Property () Annulment () Support () Alimony () Counsel Fees () Costs and Expenses () Alimony Pendente Lite and in support of the Motion states: (1) (2) (3) (4) (5) (6) (7) Date: ,.?,- (0 ? 0-7 Discovery is complete as to the claims (s) for which the appointment of a master is requested. The defendant has appeared in the action by his Attorney Charles Rector, Esquire. The Statutory ground(s) for divorce are 3301 c The action is contested with respect to the following claims: All of the above except divorce. The action involves complex issues of law or fact. The hearing is expected to take one day. Additional information, if any, relevant to the motion: 200 North Hanover Street Carlisle, PA 17013 (717)243-5551 (800)347-5552 "rte l }h=;L -10 Fe 1 2 2om?? TAMMY J. SOLLENBERGER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW ,,r CIVIL TERM LAWRENCE L. SOLLENBERGER, III, NO.//??IW AM& Defendant IN DIVORCE ORDER APPOINTING MASTER AND NOW this 15t?ay of 2007, E. Robert Elicker, II, Esquire, is appointed Master with respect to the following claims: Divorce and Equitable Distribution or Distribution of Property. C B COURT, yr-!", J. cc: Bradley L. Griffie, Esquire Attorney for Plaintiff Charles Rector, Esquire Attorney for Defendant ?- i r LO '-' CL- O o Lo ` ? b --- ` ?} I , I LJ Q C-A TAMMY J. SOLLENBERGER, Plaintiff VS. LAWRENCE L. SOLLENBERGER, III, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLANDCOUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 06-2206 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on April 20, 2006 and served on April 26, 2006 as indicated in Acceptance of Service. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service 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 FOREGOING 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: 9 Q a2u?? V_A_ TAI&Y J. SOLLENBE ER, Plaintiff C rv o r'FC r t'T7 ? $_ -t 70t cc) to TAMMY J. SOLLENBERGER, Plaintiff VS. LAWRENCE L. SOLLENBERGER, III, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLANDCOUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 06-2206 CIVIL TERM IN DIVORCE 1. I consent to the entry of a final decree in 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 THE FOREGOING 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: 9-11-6-7 T J. SOLLENBE ER, Plaintiff -z? a ? cfs s^ - M , y © 3 TAMMY J. SOLLENBERGER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLANDCOUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW LAWRENCE L. SOLLENBERGER, III, : NO. 06-2206 CIVIL TERM Defendant : IN DIVORCE Aff AV OF CONSENT 1. A Complaint in Divorce under §3301 (c) of the Divorce Code was filed on April 20, 2006 and served on April 26, 2006 as indicated in Acceptance of Service. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service 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 FOREGOING 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 AUTHORMES. DATE: /,, Z LcZ LAWRENCE L. SOLLENBERGER, ., Defendant a ' - cry ? ? mgr, -V cn TAMMY J. SOLLENBERGER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLANDCOUNTY, PENNSYLVANIA VS. : CIVIL. ACTION -LAW LAWRENCE L. SOLLENBERGER, III, : NO. 06-2206 CIVIL TERM Defendant : IN DIVORCE W IV ? OF OF NOTICE OF EVFIVTION TO RTOUEST THE ENTRY OF A DIVORCE RF&M UNDER 63301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in 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 THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS F[EREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. §4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. O ? o GG?RC.ui , DATE: ?//t LA,WREN L. SOLLENBERGER, III., Defendant G Y' i zr- TAMMY J. SOLLENBERGER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 06 - 2206 CIVIL LAWRENCE L. SOLLENBERGER, III,: Defendant IN DIVORCE ORDER OF COURT AND NOW, this 7 day of , 2007, the parties and counsel having entered into an agreement and stipulation resolving the economic issues on September 19, 2007, the date set for a conference, the agreement and stipulation having been transcribed, the appointment of the Master is vacated and counsel can conclude the proceedings by the filing of a praecipe to transmit the record with the affidavits of consent of the parties so that a final decree in divorce can be entered. cc: Bradley L. Griffie Attorney for Plaintiff Charles Rector Attorney for Defendant Edgar 0earks n*(l L 9?av/off BY THE COURT, Ui CV z U :-' C7- Ell C%j a z CCLLJ 0- w JLU to 0 cv TAMMY J. SOLLENBERGER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 06 - 2206 CIVIL LAWRENCE L. SOLLENBERGER, III,: Defendant IN DIVORCE THE MASTER: Today is Wednesday, September 19, 2007. This is the date set for a conference with counsel and the parties. Present in the hearing room are the Plaintiff, Tammy J. Sollenberger, and her counsel Bradley L. Griffie, and the Defendant, Lawrence L. Sollenberger, III, and his counsel Charles Rector. This action was commenced by the filing of a complaint in divorce on April 20, 2006, raising grounds for divorce of irretrievable breakdown of the marriage. Counsel and the parties are going to return later this morning and will, at that time, provide the Master's office with affidavits of consent and waivers of notice of intention to request entry of divorce decree so that the divorce can be concluded under Section 3301(c) of the Domestic Relations Code. The complaint also raised a claim for equitable distribution. Neither party has raised any claims for alimony or counsel fees and costs. The parties were married on August 6, 1983, and separated September 2004. There is one child of the 1 marriage who has completed his education and is emancipated. The Master has been advised that after negotiations this morning the parties have reached an agreement with respect to the outstanding economic issue of equitable distribution. The agreement is going to be placed on the record in the presence of the parties and will be considered the substantive agreement of the parties, not subject to any changes or modifications except for correction of typographical errors which may be made during the transcription. When the parties leave the hearing room today they are bound by the terms of settlement even though they have not signed an agreement affirming those terms of settlement. The agreement is going to be transcribed and counsel and the parties are going to return later this morning to review the draft of the agreement, make any correction of typographical errors as necessary, and then affix their signatures affirming the terms of settlement. Upon receipt by the Master of a completed agreement, the Master will prepare an order vacating his appointment and counsel can then file a praecipe transmitting the record to the Court requesting a final decree this divorce. Mr. Griffie. MR. GRIFFIE: In full and final satisfaction of all of the claims that the parties made in the divorce proceedings, they stipulate and agree as follows: 2 1. The parties have endorsed a check in the amount of $26,256.68 that was received for the sale of a motor home that they had purchased during the marriage. Of these funds checks will be written to the parties in the following amounts: To Tammy Sollenberger, the sum of $17,305.68 and to Lawrence Sollenberger, the sum of $8,950.99. Those checks will be delivered at the time of the signing of this agreement. 2. The parties have a 1996 Toyota vehicle and a 2003 Chevrolet Silverado vehicle. This day the parties will go to Sollenberger's Messenger Service for the purpose of transferring the titles to those vehicles. Tammy Sollenberger shall secure and retain sole title and possession of the 1996 Toyota and Lawrence Sollenberger shall retain ownership and title to the 2003 Chevrolet Silverado. 3. The parties are owners of cemetery plots as joint owners and they will simply retain joint ownership of those cemetery plots which include two plots so that they may both use those plots and retain ownership of them from this time forward. 4. All other personal property items, including tangible and intangible assets that the parties secured during their marriage are currently in the possession of the party who shall retain possession of them. Neither party will make any claim against the other for any other assets or property in the other parties' possession. 5. The parties will consent to the entry of a divorce under Section 3301(c) by signing affidavits of consent and waivers of notice of intention to request entry of divorce decree at the same time that they sign this agreement. 6. At the time of entering into this agreement there is no marital debt that exist of which either party is aware. Any debts that the parties have incurred in their own name since separation shall remain their sole responsibility. 7. Except as herein otherwise provided, each party may dispose of his or her property in any way and each party hereby waives and relinquishes any and all rights he or she may now have or hereafter acquire under the present or future laws of any jurisdiction to share in the property or the estate of the other as a result of the marital relationship including without limitation, statutory allowance, widow's allowance, right of intestacy, right to take against the will of the other, and right to act as 3 0 administrator or executor in the other's estate. Each will at the request of the other execute, acknowledge, and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interest, rights, and claims. MR. GRIFFIE: That is the total agreement of the parties. MR. RECTOR: Larry, you heard the agreement that has been recited on the record today? MR. SOLLENBERGER: Yes. MR. RECTOR: Do you understand it? MR. SOLLENBERGER: Yes. MR. RECTOR: Do you agree with it? MR. SOLLENBERGER: Yes. MR. RECTOR: And are you satisfied with my representation of you in this case? MR. SOLLENBERGER: Yes, I am. MR. GRIFFIE: Mrs. Sollenberger, were you present while I dictated the agreement? MRS. SOLLENBERGER: Yes. MR. GRIFFIE: And did you understand the terms of the agreement? MRS. SOLLENBERGER: Yes. MR. GRIFFIE: And is this how you wish to have the entire divorce case settled? MRS. SOLLENBERGER: Yes. 4 MR. GRIFFIE: And are you satisfied with the. representation provided to you by our office? MRS. SOLLENBERGER: Yes. THE MASTER: Thank you. I acknowledge that I have read the above stipulation and agreement, that I understand the terms of settlement as set forth herein, and that by signing below I ratify and affirm the agreement previously made and intend to bind myself to the settlement as a contract obligating myself to the terms of settlement and subjecting myself to the methods and procedures of enforcement which may be imposed by law and in particular Section 3105 of the Domestic Relations Code. WITNESS: ?Grifr or Pl in ff ?h?arles ect r Y(rt(c,?.. Attorn for efendant DATE: Tammy J4JShclenberge awrence L. Sollenberger, III 5 r ¦ '% TAMMY J. SOLLENBERGER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 06 - 2206 CIVIL LAWRENCE L. SOLLENBERGER, III,: Defendant IN DIVORCE THE MASTER: Today is Wednesday, September 19, 2007. This is the date set for a conference with counsel and the parties. Present in the hearing room are the Plaintiff, Tammy J. Sollenberger, and her counsel Bradley L. Griffie, and the Defendant, Lawrence L. Sollenberger, III, and his counsel Charles Rector. This action was commenced by the filing of a complaint in divorce on April 20, 2006, raising grounds for divorce of irretrievable breakdown of the marriage. Counsel and the parties are going to return later this morning and will, at that time, provide the Master's office with affidavits of consent and waivers of notice of intention to request entry of divorce decree so that the divorce can be concluded under Section 3301(c) of the Domestic Relations Code. The complaint also raised a claim for equitable distribution. Neither party has raised any claims for alimony or counsel fees and costs. The parties were married on August 6, 1983, and separated September 2004. There is one child of the 1 16. marriage who has completed his education and is emancipated. The Master has been advised that after negotiations this morning the parties have reached an agreement with respect to the outstanding economic issue of equitable distribution. The agreement is going to be placed on the record in the presence of the parties and will be considered the substantive agreement of the parties, not subject to any changes or modifications except for correction of typographical errors which may be made during the transcription. When the parties leave the hearing room today they are bound by the terms of settlement even though they have not signed an agreement affirming those terms of settlement. The agreement is going to be transcribed and counsel and the parties are going to return later this morning to review the draft of the agreement, make any correction of typographical errors as necessary, and then affix their signatures affirming the terms of settlement. Upon receipt by the Master of a completed agreement, the Master will prepare an order vacating his appointment and counsel can then file a praecipe transmitting the record to the Court requesting a final decree this divorce. Mr. Griffie. MR. GRIFFIE: In full and final satisfaction of all of the claims that the parties made in the divorce proceedings, they stipulate and agree as follows: 2 I L 1. The parties have endorsed a check in the amount of $26,256.68 that was received for the sale of a motor home that they had purchased during the marriage. Of these funds checks will be written to the parties in the following amounts: To Tammy Sollenberger, the sum of $17,305.68 and to Lawrence Sollenberger, the sum of $8,950.99. Those checks will be delivered at the time of the signing of this agreement. 2. The parties have a 1996 Toyota vehicle and a 2003 Chevrolet Silverado vehicle. This day the parties will go to Sollenberger's Messenger Service for the purpose of transferring the titles to those vehicles. Tammy Sollenberger shall secure and retain sole title and possession of the 1996 Toyota and Lawrence Sollenberger shall retain ownership and title to the 2003 Chevrolet Silverado. 3. The parties are owners of cemetery plots as joint owners and they will simply retain joint ownership of those cemetery plots which include two plots so that they may both use those plots and retain ownership of them from this time forward. 4. All other personal property items, including tangible and intangible assets that the parties secured during their marriage are currently in the possession of the party who shall retain possession of them. Neither party will make any claim against the other for any other assets or property in the other parties' possession. 5. The parties will consent to the entry of a divorce under Section 3301(c) by signing affidavits of consent and waivers of notice of intention to request entry of divorce decree at the same time that they sign this agreement. 6. At the time of entering into this agreement there is no marital debt that exist of which either party is aware. Any debts that the parties have incurred in their own name since separation shall remain their sole responsibility. 7. Except as herein otherwise provided, each party may dispose of his or her property in any way and each party hereby waives and relinquishes any and all rights he or she may now have or hereafter acquire under the present or future laws of any jurisdiction to share in the property or the estate of the other as a result of the marital relationship including without limitation, statutory allowance, widow's allowance, right of intestacy, right to take against the will of the other, and right to act as 3 I administrator or executor in the other's estate. Each will at the request of the other execute, acknowledge, and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interest, rights, and claims. MR. GRIFFIE: That is the total agreement of the parties. MR. RECTOR: Larry, you heard the agreement that has been recited on the record today? MR. SOLLENBERGER: Yes. MR. RECTOR: Do you understand it? MR. SOLLENBERGER: Yes. MR. RECTOR: Do you agree with it? MR. SOLLENBERGER: Yes. MR. RECTOR: And are you satisfied with my representation of you in this case? MR. SOLLENBERGER: Yes, I am. MR. GRIFFIE: Mrs. Sollenberger, were you present while I dictated the agreement? MRS. SOLLENBERGER: Yes. MR. GRIFFIE: And did you understand the terms of the agreement? MRS. SOLLENBERGER: Yes. MR. GRIFFIE: And is this how you wish to have the entire divorce case settled? MRS. SOLLENBERGER: Yes. 4 i 1 i MR. GRIFFIE: And are you satisfied with the representation provided to you by our office? MRS. SOLLENBERGER: Yes. THE MASTER: Thank you. I acknowledge that I have read the above stipulation and agreement, that I understand the terms of settlement as set forth herein, and that by signing below I ratify and affirm the agreement previously made and intend to bind myself to the settlement as a contract obligating myself to the terms of settlement and subjecting myself to the methods and procedures of enforcement which may be imposed by law and in particular Section 3105 of the Domestic Relations Code. WITNESS: DATE: Tammy t o lenber e g Vey fle y J. t flor P aintiff -? NO Q w.f.?-tom r-- Charles e c(Lor Y rq j?. awrence L. Sollenberger, III Attorn v for Defendant 5 r-4 TAMMY J. SOLLENBERGER, Plaintiff VS. LAWRENCE L. SOLLENBERGER, III, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLANDCOUNTY, PENNSYLVANIA CIVIL ACTION - LAW : NO. 06-2206 CIVIL TERM : 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 §3301(c) 3 301 (d)(1) of the DiveFee Godee. (Strike out inapplicable section). 2. Date and manner of service of the Complaint: by certified mail, restricted delivery on April 25, 2005. 3. Complete either paragraph (a) or (b). (a) Date of execution of the Affidavit of Consent required by §3301 (c) of the Divorce Code: by Plaintiff: 9/19/07 by Defendant: 9/19/07 (b) (1) Date of execution of the affidavit required by §3301 (d) of the Divorce Code: (2) Date of filing and service of the plaintiff's affidavit upon the respondent: 4. Related claims pending: none 5. Complete either (a) or (b). (a) Date and manner of service of the notice of intention to file Praecipe to Transmit record, a copy of which is attached: (b) Date of plaintiff's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: September 19, 2007 Date defendant's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: September 19, 2007 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. >1~ TAMMY J. SOLLENBERGER No. 06-2206 Plaintiff VERSUS LAWRENCE L. SOLLENBERGER, III, Defendant DECREE IN DIVORCE ?-- y•o3fo,?l. g"k AND NOW, © ?v0? IT IS ORDERED AND DECREED THAT Tammy So 1 nh q _r PLAINTIFF, AND Lawrence L. Sollenberger, III 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; The parties' Stipulation entered into before the Divorce Master on September 19, 2007 is inco ate but not merged into this Decree. ATTEST: J PROTHONOTARY wYlw o a /r""" mac, ?0- j-- 0/ Z-a - E , Q/